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Brief • 2008
claim are not a public record, or for which you claim a privilege not to disclose said record, please advise what this information pertains to and why you claim it is not a public record or why ...
Brief • 2009
subjected to what she was told was a routine strip search, Correctional Officers Glasco and Joy shackled her with a waist chain attached to hand cuffs and transported her to the hospital. 3.8 When she ...
Brief • 2007
-00377-WDM-BNB 15. Document 207 Filed 06/27/2007 Page 4 of 16 Defendants deny that Nurse Paulsen did not explain to Plaintiff what the medication she gave him on March 7, 2003, was for. [See DSUMF ...
Brief • 2008
their alternative proposals as to what the language should be. Exhibit A. Subsequently, Defendant Devine and the County objected to the Plaintiff’s/City’s settlement in writing, claiming they only wanted to preserve ...
Brief • March 31, 2010
and symptoms of alcohol withdrawal," the shall be initiated upon examination by the nurse. (Emphasis added). Protocol shall 73. 73. Based upon her examination of Michael and what she had learned from from ...
Brief • August 27, 2007
, what was the purpose of providing you 19 with copies of the newspaper articles? 20 A Mr. Diamondstone said it's simply to advise me of the 21 ongoing public interest in the disciplinary process and OPA ...
Brief • 2006
process of law reflects the high value embedded in our constitutional and political history that we place on a person's right to enjoy what is his, free from government interference. Fuentes v. Shevin, 407 ...
evidence through its own employees. Finally, CCA argues that the report is cumulative because the Plaintiffs will themselves testify to what happened to them during the riot, and “allowing the same testimony ...
Brief • 2008
in general terms what is to be done and by which agency. 9 State v. Simmons, 152 Wn.2d 450, 455, 98 P.3d 789 (2004); RCW 10.95.160- 10 .190; RCW 72.01.090; RCW 72.02.040; RCW 72.09.050; RCW 72.02.045. 11 ...
Brief • 2003
a blind eye for fear of what he or she might see. 22. The Defendants engaged in conduct out of policy, particularly the officers engaged in conduct against the Plaintiff in an unprofessional ...
Brief • 2012
courts have “wide discretion in deciding what constitutes ‘bad faith’ or whether the introduction of affidavits was ‘solely for the purpose of delay.’” Cobell v. Norton, 214 F.R.D. 13, 20 (D.D.C. 2003 ...
marks omitted.] The Court stated that “[t]he principal is only liable because the law creates a practical identity with his [agents], so that he is held to have done what they have done.” Id. (internal ...
Brief • 2010
was aware of the details of these incidents. 71. After the incidents, Howard and Works made express and implied threats to Neptune and/or Estes indicating that they should not talk about what happened ...
Brief • 2011
offered sufficient evidence to indicate that what the official allegedly did was objectively unreasonable in light of the clearly established constitutional rights. Dunn v. Matatall, 549 F.3d 348, 352-53 ...
Brief
. Williams to contact Columbia and request a legal visit. Ms. Williams called the Acting Administrator of Columbia, Defendant James, and asked if a visit could be arranged. When he heard what Ms. Williams ...
Brief • 2010
not identify the specific officer(s) who conducted the investigation, how the investigation was conducted, whether the prisoners who complained about retaliation were interviewed, what prisoner witnesses, if any ...
Brief • 2010
steps to reflect that change in his domicile. (Id. ¶¶ 2, 6; see also id. (Aff. of Gerraud Hill, sworn to on Jan. 20, 2010)). What Hill overlooks is that diversity of citizenship must exist when a lawsuit ...
Brief • December 12, 2003
of restraints. 6. The Security Division also found that three of the other guards on the scene “failed to truthfully report what took place,” and that, despite Mr. Ziemba’s complaints of injuries, members ...
Brief • 2009
. Farmer, 511 U.S. at 837. First, the plaintiff has alleged facts sufficient to raise a genuine issue as to what Officer Norris was aware of just prior to handcuffing and restraining Smith on October 17 ...
Brief • 2006
. At this point the guards could not see Mr. Steele or what he was doing through the cell window. Mr. Steele then turned around and tied the shoestring around his neck. He tied the other end of the shoestring ...
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