JOSEPH MCGHEE PO BOX 91 FLAGSTAFF, AZ 86002 COCONINO COUNTY ATTORNEY’S OFFICE ATTN: CUSTODIAN OF PUBLIC RECORDS 110 E CHERRY AVE FLAGSTAFF, AZ 86001 RE: PUBLIC RECORDS REQUEST To whom it may concern: Pursuant to A.R.S. §§ -39-101 to -161, I, Joseph McGhee (“undersigned”), hereby request that the Coconino County Attorney’s Office, within thirty (30) days of the receipt of this request, make available for my inspection and duplication, 1 the following public records in their entirety , related in any manner to the following: 2 1. All criminal history information as to undersigned, which was alleged by the State at undersigned’s initial appearance held on June 9, 2021 in Flagstaff Justice Court subsequent to undersigned’s arrest on June 8, 2021. 2. Complete transcripts of undersigned’s initial appearance in Flagstaff Justice Court held on June 9, 2021 subsequent to undersigned’s arrest on June 8, 2021. 3. All criminal history information as to undersigned, which was alleged by the State in its Response to undersigned’s Motion to Modify Conditions of Release (case no. CR-21- 00508), which was heard in Division II of the Coconino Superior Court on August 17, 2021. 4. Complete transcripts of the evidentiary hearing on undersigned’s Motion to Modify Conditions of Release (case no. CR-21-00508) held on August 17, 2021 in Division II of the Coconino Superior Court. 5. Any and all communications, including email and text messages, between any employee 1 Carlson v. Pima Cty. , 141 Ariz. 487, 491, 687 P.2d 1242, 1246 (1984) (As a general rule, "all records required to be kept under A.R.S. § 39-121.01(B), are presumed open to the public for inspection as public records."); see also Star Publ’g Co. v. Pima Cty. Attorney’s Office , 181 Ariz. 432, 434, 891 P.2d 899, 901 (App. 1994) (County Attorney failed to provide specific factual basis to support argument that records were protected from disclosure); 2 "Records" are defined in A.R.S. § 41-151.18 as: all books, papers, maps, photographs or other documentary materials, regardless of physical form or characteristics, including prints or copies of such items produced or reproduced on film or electronic media pursuant to § 41-151.16, made or received by any governmental agency in pursuance of law or in connection with the transaction of public business and preserved or appropriate for preservation by the agency or its legitimate successor as evidence of the organization, functions, policies, decisions, procedures, operations or other activities of the government, or because of the informational and historical value of data contained in the record, and includes records that are made confidential by statute. of the Coconino County Attorney’s Office and Flagstaff Mayor Paul Deasy, or any member of Mr. Deasy’s staff or any other City of Flagstaff employee acting on his behalf or at his direction including his counsel, in any manner regarding the undersigned, since Mr. Deasy’s election to this office. 6. Any and all communications, including email and text messages, between any employee of the Coconino County Attorney’s Office and Governor Ducey, or any member of Mr. Ducey’s staff or any other State of Arizona employee acting on his behalf or at his direction including his counsel, in any manner regarding undersigned, since March 16, 2020. 7. Any and all communications, including email and text messages, between any employee of the Coconino County Attorney’s Office and any employee of the Flagstaff Police Department, regarding undersigned in any manner, since June 7, 2021. 8. Any and all communications, including email and text messages, between any employee of the Coconino County Attorney’s Office and any employee of the Coconino County Sheriff’s Office, regarding undersigned in any manner, since June 7, 2021. 9. Any and all communications, including email and text messages, between any employee of the Coconino County Attorney’s Office and the Arizona Attorney General’s office, regarding undersigned in any manner, since March 16, 2020. 10. Any court orders sought by law enforcement, or granted, to permit access to the Coconino County Superior Court case file DO-2016-00407, which has been under seal since 2018. 11. Any documents, materials, or other evidence, which shows the exact date and time that the GPS device owner-information related to the undersigned, requested from LandAirSea Asset Protection pursuant to a search warrant executed on or about June 7, 2021, was received by the Flagstaff Police Department. 12. Any communications, documents, or any other materials, including internal memos and official or unofficial policies, to or from any employee of the Coconino County Attorney’s Office, which detail or describe in any manner the duties, procedures, or recommendations, in prosecuting stalking allegations. 13. Any communications, documents, or any other materials, including internal memos, to or from any employee of the Coconino County Attorney’s Office, which detail or describe in any manner case number CV-2021-0002-SA, McGhee v. Deasy, et al. , in the Arizona Supreme Court. 14. Any communications, including text messages or email, documents, or any other materials, including internal memos, to or from any employee of the Coconino County Attorney’s Office, which detail or describe in any manner case number CV-20-08081- PCT-GMS, McGhee v. City of Flagstaff , et al. , in the U.S. District Court for the District of Arizona. 15. Paper copies of any electronic text messages in possession of the Coconino County Attorney’s Office, transmitted to or from undersigned while he was in custody at the Coconino County Detention Facility in 2021. Include a chain of custody with the names and contact information of all individuals who were in control or possession of such messages. 16. Copies of all materials submitted for investigation to the grand jury by the Coconino County Attorney’s Office in 2021 related to in any manner to undersigned. With regard to this public records request, I explicitly request disclosure of all public records as defined in A.R.S. § 41-151.18 related in any manner to the enumerated requests set forth above . I need not specifically request each type of record (i.e., emails, text messages, documents, transcripts, etc.) in the separate requests enumerated above, because I have requested any and all public records related to these separate requests in their entirety. This request is therefore not overbroad. The purpose of this request is twofold: (1) I am a litigant against the State of Arizona in State v. McGhee, no. CR-21-00508, Coconino Superior Court; and (2) I intend to file suit against the County of Coconino, the Coconino County Attorney, and individuals, related to the prosecution of the aforementioned criminal case. 3 Be advised that I will seek statutory special action relief pursuant to A.R.S. § 31-121.02, and an award of fees and costs, should the Coconino County Attorney’s Office either deny, or fail to timely respond to, this request. If you have any questions you may feel free to contact me via telephone at (928) 600-0954, or by emailing to spurfy@icloud.com. Sincerely, Joseph McGhee 3 Bolm v. Custodian of Records of Tucson Police Dep’t , 193 Ariz. 35, 39, ¶ 10, 969 P.2d 200, 204 (App. 1998)( If a party to litigation against the State requests records under the Public Records Law, the party need not demonstrate that the "documents are relevant to anything" and therefore may obtain records that would not be discoverable in litigation).