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Brief • July 10, 2009
Officer Hiller or DiLauro of a police wagon with a handcuffed person not secured by proper vehicle safety restraints was what Philadelphia Police Officers commonly refer to as a "nickel ride." 26 ...
Brief • 2009
observation filtered through the experience of the decision maker and leading to a predictive judgment as to what is best both for the individual inmate and for the community. This latter conclusion requires ...
Brief • 2009
that “a reasonable official would understand that what he is doing violates that right.” Hope v. Pelzer, 536 U.S. 730, 739 (2002). The Supreme Court has likened this requirement to the right to fair notice held ...
Brief • January 29, 2013
and could not get up. Whitmire told him to call Defendant Bruce Bailey. Defendant Bailey said he would see what he could do. Captain Milford called Whitmire back, relayed Bailey’s message, and was told ...
Brief • March 13, 2014
truth about what had happened at the 70th precinct on August 9, 1997."] d. Barry v. New York City Police Dep't, 2004 U.S. Dist. LEXIS 5951, 40-41 (S.D.N. Y. April 7, 2004) ["[P]laintitrs witnesses speak ...
contends that the details of the Lonoaea assault and disturbance “are relevant to evaluating what, if anything, CCA and DPS learned from those incidents, and whether and how they applied that knowledge ...
Brief • February 20, 2013
to the members of the Plaintiff Class. The same policies and practices apply to all class members. The question common to all members of the Plaintiff Class is what justification Sheriff Manfre has ...
Brief • June 14, 2013
what process is provided, unless the infringement is narrowly tailored to serve a compelling state interest. Reno v. Flores, 507 U.S. Page 7 MEMORANDUM IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION ...
Brief • August 5, 2013
special conditions, it will not result in permanent designation as a sex offender or a prolonged term of supervision.” (Docket #22, p. 16.) What the state defendants fail to address is that if Mr. Wilson ...
Brief • September 26, 2014
Filed under: Environmental Law, Sewage
engineer (at the expense of ADS) to resolve the dispute. The Parties must agree whom to select as the third engineer. Time is of the essence in working out any disagreements that may occur over what may ...
Brief • August 23, 2013
Filed under: Exercise
into this Settlement Agreement as a complete compromise of the matters involving disputed issues of law and fact. The Plaintiffs assume the risk that the facts or law may be other than what the Plaintiffs believe ...
Brief • July 28, 2014
is not at this time seeking a ruling as to the legal sufficiency of her Monell claim. Instead, plaintiff seeks only to ask CMC’s chief executive officer what he knows about previous incidents that have been given ...
Brief • 2010
denied her request. As a result, on February 8, 2005, Plaintiff attempted to hang herself in her cell at USMCFP Springfield. Thereafter, BOP’s staff psychologist observed that what Plaintiff “really wants ...
Brief • 2008
Rights Act of 1992, §760.01 et seq. (hereinafter the "FCRA"). Plaintiff was denied a promotion after she engaged in what she reasonably believed was protected activity when she earlier made complaints ...
Brief • 2006
States; what his immigration statIrs is now and 21 when he came to the United States; whether he is a legal resident of Califomia; and whether he has a 22 Green Card or a visa that permits him to work ...
Brief • November 13, 2013
the defendant fair notice of what the . . . claim is and the grounds upon which it rests.’” Bell Atl. Corp. 5 4:12-cv-03115-JFB-TDT Doc # 124 Filed: 11/13/13 Page 6 of 12 - Page ID # 964 v. Twombly, 550 U.S ...
Brief • April 20, 2012
adoption is what effect, 6 if any, the adoption should have on the parent-child relationship between the child and 7 his or her natural parents. If the classic adoption rule were to apply, the adoption ...
Brief • 2008
a case also may vary widely. A subject matter expert or historian may be more able to marshal facts about what already is in the public record on a particular issue, while an individual with a more ...
Brief • 2011
what alternative types of force or control techniques they considered and why those types of force were rejected; d. require deputies to fill out a use of force report following the use ofa CED that sets ...
Brief • 2004
by counsel for Defendants 12 MCDA and Schrunk to correct what is undoubtedly an unintentional misrepresentation of fact. 13 Opposing counsel represents that Plaintiff’s “time in custody from his return ...
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