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was and what she was doing?; b. Called the plaintiff repeatedly and sent her email messages approximately two to three times per week for no work-related reason; c. Summoned the plaintiff to his office 3-4 ...
-alleges the above paragraphs as though fully set forth herein. 117. As detailed above, DEFENDANT OFFICERS detained PLAINTIFF pursuant to what DEFENDANT OFFICERS characterized as “investigative holds ...
that what actually violated his due process rights was tl1e guards' Page 15 of 19 Case 3:16-cv-00877-MJR-SCW Document 11 Filed 11/14/16 Page 16 of 19 Page ID #102 actions in refusing to remove him from his ...
Brief • July 5, 2023
Filed under: False Arrest
“be considered a threat to inflict bodily injury.”55 This statement — which Appellee described below as an “offer to fight”56 — firstly is not a threat of harm, it is exactly what Appellee agrees it is: an offer ...
Brief • January 4, 2023
inhibiting breathing. Gilbert 10 grabbed Mr. Zumwalt’s face in 11 what he called a “mandibular 12 jaw thrust,” and directed Arceo 13 to put a spit sock over Mr. 14 Zumwalt’s face because his 15 ...
Brief • November 15, 2018
Filed under: Staff-Prisoner Assault
for the consideration delineated hereinabove other than what is stated herein, and that this Agreement is executed without reliance on any statement or representation by those released or their representatives, or anyone ...
Brief • January 2, 2020
Plaintiffs' theory of inadequate training is vaguely based on the County 25 Defendants' alleged failure to comply with PREA's audit requirements, it is not clear 26 precisely what training the County ...
Brief • August 15, 2019
Levetiracetam Fentanyl Urine 6-Monoacetylmorphine Vitreous humor 6-Monoacetylmorphine 262 ng/mL Not Detected 7.1 mcg/mL 0.5 ng/mL Not Detected Not Detected Medico-legal questions 1. What were the underlying ...
Brief • May 3, 2021
Filed under: Hepatitis
21, 2018, which included the four new plaintiffs (because DOC began treating Barfield with DAAs in October 2018 in what Plaintiff Barfield considered an attempt to moot this case). ECF 35. Plaintiffs ...
Brief • June 7, 2018
what had happened at the Jail. 83. Even after becoming aware of the Taser and dog attacks, neither Mr. Toone nor any Department official ensured that Mr. Drollette was evaluated for possible physical ...
Brief • May 17, 2018
Filed under: Wrongful Death
. 47. On October 25, Mr. Madden submitted a written Health Care Request Form to be seen by medical staff. He reported that he was experiencing “bad symptoms” for what he thought was severe allergies ...
Brief • August 17, 2011
employees. 25 d. 26 violations. 27 31. 28 What remedies are available to Plaintiffs to address these Class action treatment is superior to the alternatives for the fair and efficient adjudication ...
Brief • January 19, 2017
Filed under: Wrongful Conviction
, but they also stood to be rewarded for closing a case no matter what the cost. In this way, the system proximately caused abuses, such as the misconduct at issue in this case. 57. As described more fully herein ...
Brief • March 6, 2020
that Sheriff Jordan was reviewing video footage of Mr. Carter’s fall to determine for himself if he was hurt. No one asked Mr. Carter if he was hurt, what assistance he needed, or if he was in pain. 27. After ...
Brief • May 31, 2022
Filed under: Prison Conditions
Detainees in Quarantine and Isolation, access to books, reading materials, TV, showers, telephones, their personal items and commissary, similar to what Detainees in regular housing have access to. 7 ...
Brief • October 30, 2018
Filed under: Censorship
what these attorneys can do for these and other clients. 87. In addition, SCIs prohibit attorneys from hand-delivering documents to their clients during in-person visits unless the attorney receives ...
Brief • November 15, 2022
.) Watkins declares 16 that he was “not told what it was that [he] was signing and was not given an option not to 17 sign,” and was “not given an option to receive [his] money by any other means.” (ECF ...
through institutional mail, containing facts regarding each aspect of the complaint, including what happened, when, where, and the name of each person involved. An offender may still file a grievance ...
detention at Menard CC. 80. Plaintiff is a mentally-ill individual, who was unaware of the grievance procedures and was never informed of what procedures he should follow to file his grievances by Wexford ...
Brief • April 19, 2018
by the corrections officer who told him that he could not get cleaning supplies and that he should “write a grievance like you always do, that’s what you get for being a troublemaker.” Defendant Engelson never ...
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