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Rutherford v Baca Ca Motion for Protective Order Confinement Conditions 2010
Brief • 2010
us that they are too fearful to speak with us or to file complaints because of what will happen to them if they do so. These allegations of retaliation make it almost impossible for our staff ...
Reynolds v Hall Fl Class Action Complaint Censorship Prisoner Mail 2010
Brief • 2010
of law and fact common to the members of the Plaintiff Class. The same policy and practice applies to all class members. The question common to all members of the Plaintiff Class is what justification ...
Valadez-lopez v Chertoff Ca Eaja Fee Order 2007 Habeas Immigration
Brief • 2007
obtained in this action and what 27 appears to be an excessive number of hours (perhaps resulting from the use of three attorneys and 28 four law students), that petitioner should be entitled to recover ...
Benjamin v Fraser Ny Discovery Documents Restraint Practices 2002
Brief • 2002
requests observation of the Red ID restraint process one day from beginning to end_' This request is based on our experts' statement of what they need to see to render a fully informed opinion on the Red 10 ...
Pln v Werholtz Ka Opinion and Injunction Re Kdoc Censorship Oct 1 2007
Brief • 2007
authorities, those factors do not mean that every prison regulation is insulated from review no matter what the facts may be. As the Court stated in Procunier v. Martinez, 416 U.S. 396, 94 S.Ct. 1800, 40 L.Ed ...
Ahlers v Grygo Ny Findings and Conclusions Med Denial and Retaliation 2009
Brief • 2009
March 17, 2002, but after the Smith complaint had been filed and served on Grygo, Grygo said to Ahlers, “Payback’s a bitch,” and “What goes around 3 Case 1:02-cv-03256-JG-LB Document 84 Filed 10/27/09 ...
Peschel v City of Missoula Mt Second Amended Complaint Jail Medical Care 2008
Brief • 2008
impaired Dr. Peschel=s defense in his criminal case, and will severely impair his civil case as well, because the video contains incontrovertible evidence of what occurred on August 18, 2007, at the scene ...
Baxter v State of New Hampshire Nh Complaint Due Process 2010
Brief • 2010
only to his medical bills. He could not wait any longer due to lack of court funding. Therefore, the plaintiff sacrificed what should have been a reasonable settlement and took an unreasonably low ...
Ziemba v Armstrong Ct Plf Amended Complaint Prison Beating 2003.pdf
Brief • 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 ...
Mast v. Donahue, Settlement, In, Shu Mental Health, 2007
Brief • 2007
and the Director of Classification in order to make a decision and to determine what department-wide unit would be most appropriate. 7. The Regional Director shall advise the Superintendent of the decision ...
Burton v City of Peoria Il Pltfs Response to Motion for Summary Judgment Contrator Misconduct Police Intimidation 2007
Brief • 2007
call to the Peoria Police and he informed Plaintiff that she was not allowed to complain to anyone about what was happening. 30. On March 15, 2006, Plaintiff consulted with a private attorney in regards ...
Al Haramain Islamic Fdn Inc v Bush or Plf Motion to Intervene Fisa Violations 2006.pdf
Brief • 2006
what they are prohibited from observing.'" Oregonian Pub. Co., 920 F.2d at 1465, quoting On January 24, 2006, The New York Times reported that "[s]everal challenges have now been lodged in civil ...
Mitchell v Cca of Tennessee Inc La Memo in Supp Mot for Sj Prison Sexual Assault 2006
Brief • 2006
ofLt. McCoy; none ofthe evidence shows that he knew about the conduct and facilitated it, approved it, condoned it, or turned a blind eye for fear of what he might sec. We must affinn, therefore ...
Borck v County of Lenawee Mi Def Response to Plf Mot to Compel Jail Med Neglect 2008
Brief • 2008
when he has claimed in discovery responses that he is relying only upon information produced by Defendants. Plaintiff’s unsupported factual allegations are not evidence of what any Defendant remembers ...
Gabriel v County of Herkimer Ny Complaint Failure to Provide Care Pretrial Death 2008
Brief • 2008
and punitive damages payable to Mr. DiCamillo's estate, but a declaration that the Herkimer County Sheriff s Department and the County of Herkimer are responsible for what happened to this man ...
Nyclu v Erie County Ny Motion Prison Public Records Foia 2010
Brief • 2010
, it is not the case that the County genuinely cannot be expected to understand what records the NYCLU sought and how it could locate them. Konigsberg, 68 N.Y.2d at 247. For that reason, the County should be ordered ...
Chaney v. Lehman, Wa, Sex Offender Over Detention, Complaint 2004
Brief • 2004
Fax: (509) 267-4125 CLASS ACTION COMPLAINT -3- 1 17. The policies and procedures manuals that are provided to inmates inform them about 2 every aspect of what to expect and how to behave while ...
Heston v. City of Salinas, CA, Plf Opp to Def MTD, police taser death cardiac arrest, 2006
Brief • December 23, 2005
Filed under: Cardiovascular, Stun Guns/Tasers, Police--Excessive Force
in 2 Pike v. Frank G. Hough Co. (1970) 2 Cal.3d 465, 470, 85 Cal. Rptr. 629. 3 “What is ‘reasonable care,’ of course, varies with the facts of each case, but it involves 4 a balancing ...
Borck v County of Lenawee Mi Plf Mot to Compel Discovery Jail Med Neglect 2008
Brief • 2008
, the date and time of such statements, and a summary of the substance of the statement. 14. For each Defendant, please state what affirmative defenses you will rely upon in answering Plaintiffs Complaint ...
Doe v Young Fl Discovery Officer Sexual Misconduct 2010
Brief • 2010
, custody or control of defendant, state: unless he has made reasonable inquiry and unless the information known or readily obtainable by him 1. what was done with the document; is insufficient to enable him ...
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