Re: Request for Settlements and Verdicts Records
The Human Rights Defense Center (HRDC) makes this request pursuant to the New Mexico Inspection of Public Records Act, N.M. Stat. Ann. § 14-2-1, et seq.
HRDC is seeking records related to all claims or lawsuits brought against the Las Cruces Police Department and/or any of its agents or employees in which the Las Cruces Police Department (or any agent, insurer, or entity acting on its behalf) made Payments totaling $1,000 or more to resolve such claims or lawsuits (each a “Relevant Claim”). For the purposes of this request:
- The relevant time period is January 1, 2010 to the present.
- “Payments” includes, without limitation, settlements, damages, attorneys’ fees, and sanctions.
- Records shall be produced in electronic native format where possible, and otherwise in electronic format. To the extent production in electronic format is not possible, records may be produced in hard copy.
For each Relevant Claim, HRDC requests records sufficient to show:
- the name of all parties involved;
- the date of resolution;
- the amount of money paid to resolve the claim;
- the person or entity to whom the money was paid;
- for those Relevant Claims that did not result in litigation:
- the claim form or other document that describes the claim; and
- the final agreement resolving the claim; and
- for those Relevant Claims that resulted in litigation:
- the docket number;
- the jurisdiction in which the action was brought (e.g., US District Court for the District of New Mexico, New Mexico Supreme Court, etc.);
- the complaint and any amendments thereof; and
- the verdict form, final judgment, settlement agreement, consent decree, or other document that resolved the case.
If any of these requests, or any portion thereof, is denied in whole or in part, please provide an accounting of each record being withheld, and the specific exemption being invoked for such record. In addition, to the extent the Las Cruces Police Department or any other party claims that any portion of a record is confidential or otherwise protected from disclosure, please redact the allegedly confidential or protected portion and produce the redacted record. By making this request, HRDC does not waive, but rather expressly reserves, its right to challenge a claim that any portion of a record is confidential or otherwise protected from disclosure.
Please contact me via email, email@example.com, should you require any additional information. My phone number is 206-257-1355. Thank you for your time and attention in this matter.
Public Records Manager
Human Rights Defense Center
Prison Legal News
720 Third Ave., Suite #1605
Seattle, WA 98104