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Brief • 2013
fails to define “Pure Impact” and it is 11 unclear what this entails or how it is used. 12 34. The 2,436 inmates Dr. Austin lists in Table 4 of his declaration describing the 13 amount ...
Brief • 2008
Federal Rule of Civil Procedure 8(a) establishes a “liberal system of notice pleading” which requires only “a short and plain statement of the claim that will give the defendant fair notice of what ...
Brief • 1996
and to maintain proper safety, sanitation, control of security at Washington State Penitentiary. This order specifies what property is authorized. Anything not specified in this instruction, other than items ...
Brief • 2009
reviewed all abnormal laboratory tests and other test results and what action if any was indicated. All paper laboratory reports and other reports that indicate an abnormal result shall not be filed ...
Brief • 2005
hardly be disputed PlaintiCrs Original Petition Page 14 other than resolving the rather large issue of what specifically was the ligature, how did he put the pressure on to hang himself and where did ...
Brief • March 3, 2005
(1982). A clearly established constitutional right is one for which “a reasonable official would understand that what he was doing violates that right.” Saucier v. Katz, 533 U.S. 194, 202 (2001 ...
Brief • June 2, 2011
-proc:ec1uraJdiTcctives/proceG\lraJ-directiveslj.-studentsas it pertains to ,bird parties in addition to students and empl Jyees ofthe District. Specwcclly, the Student Handboo1,<:wi1l s-tateunder WHAT TO DO IF YOU BELIEVE ...
Brief • July 11, 2007
shacldes and'limited movement. Let me Imow what you think." That same day, Columbia staff member AnoIa Barber wrote: "please put this student [H.D] in leg shac1des and onlirnited movement per attached memo ...
Brief • March 5, 2008
the name of Allah, such as “Bismillah Allah-u-Akbar.” While the method bears striking similarities to Kosher slaughter rituals, what is Kosher is not Halal, and vice-versa, in the Jewish and Muslim ...
Brief • 2012
Filed under: Telephones
" with prison telephone contracts to the extent that it limits what companies may charge customers. The DTC is mandated to set just and reasonable rates based on the cost of service plus a reasonable rate ...
Brief • July 12, 2011
Davis took any action to stop the officer’s use of excessive force on Haines. Further, while watching this conduct, Captain Clark stated to Haines: “That’s what you get for hanging around with niggers ...
that they have 21 no idea what facts were known by Deputies when they stopped Plaintiffs. Id. at 11. 22 Given the absence of evidence showing Plaintiffs were inside a security perimeter, the 23 expert ...
Brief • December 29, 2010
what we can On the same piece of paper, Hoven wrote: This is jail — hard to accommodate Don’t get arrested again Lesson learn — jail sucks Id. Bahl then communicated with another inmate, Windish, who ...
Brief • 2007
. That is exactly what footnote 15 accomplished. B. The AUMF does not authorize detentions beyond those allowed by the law of war. The Authorization for Use of Military Force (“AUMF”) does not authorize detentions ...
Brief • March 31, 2009
, and has no idea what “civil rights” are. Id. at 44. Furthermore, she has never heard the term “body cavity search,” although she believes that the “standard procedure” does not qualify as a body cavity ...
Brief
. An actor may misuse power that he possesses by virtue of state law even if his acts violate state law; what is important is that the defendant was clothed with the authority of state law ...
Brief • August 23, 2010
. The terms of the PSA apply equally to all TCI Class and ADA Subclass members. No class member or group of class members is singled out for injunctive relief beyond what is afforded to all other class members ...
Brief • February 17, 2005
to enforce compliance with an order of the court or to compensate for losses or damages sustained by reason of non-compliance....Since the purpose is remedial, it matters not with what intent the defendant did ...
of what their testimony will cover”). Defendants argue that the seventh factor, ease of access to sources of proof, weighs in favor of transfer because most of the relevant documents are in 21 Case 1:11-cv ...
Brief • May 5, 2004
the defendant fair notice 17 of what the plaintiff’s claim is and the grounds upon which it rests.” Leatherman v. Tarrant County 18 Narcotics Intelligence and Coordination Unit, 507 U.S. 163, 168 (1993 ...
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