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Brief • 2008
of Corrections. She does not know the events that led to her son's death, whether there were witnesses to his condition, who found him, or what caused the bruising on his body. Defendants' attorneys blocked Ms ...
Brief • July 31, 2013
at times be . . . the ‘best’ evidence of what occurred does not render first-hand testimony of the event incompetent”) (citing O'Brien v. Ed Donnelly Enterprises, Inc., 575 F.3d 567, 598–99 (6th Cir. 2009 ...
Brief • November 25, 2005
will no doubt now spread the details of these crimes before the Court in order to argue that plaintiffs are violent, aggressive people. This strategy is a precursor of what defendants intend to do at trial ...
Brief • 2008
of Corrections. She does not know the events that led to her son's death, whether there were witnesses to his condition, who found him, or what caused the bruising on his body. Defendants' attorneys blocked Ms ...
Brief • 2009
stress. This training also includes the evaluation of physical actions in combative environments, including what is required to create effective human combatives responses and decision-making under duress ...
Brief • 2007
The declaration from Allen Wilcher that defendants offer in 10 support of their opposition to summary judgment is similarly 11 flawed. In his declaration, Mr. Wilcher described what occurs after 12 a juvenile ...
Brief • 2011
" instruction and does so with proper documentation, despite what N.Y. Penal Law § 70.40(3) provides. The DOP recognizes the authority of the sentencing judge to detelmine how sentences run and understands ...
Fitzgerald performed a blood pressure check and took plaintiffs temperature, asking "What is the problem?". Plaintiff explained that both his big toes were swollen and hurting. LPN Fitzgerald told plaintiff ...
Brief • January 23, 2018
 conference.  5 This status conference would result in the first of what would eventually be three  6 court‐ordered competency exams, each of which would confirm that Tigano was  7 competent to stand ...
Brief • October 10, 2017
and was therefore constitutionally valid. The district court believed that it was required to defer to this conclusion under AEDPA. We turn now to the question of what level of deference, if any, the district court ...
Brief • 2009
that he "didn't write it on that form but they have it on their record, their intake sheet, that that is what I take when I went in there." (Id.36:25-37:2.) However, Nurse Isom testified that the only ...
Brief • 2007
be filed. This formal grievance, signed by the employee, is presented to his/her supervisor within two weeks of the occurrence. The employee should include a statement regarding what action ...
Brief • 2009
of justice. That attorneys should be compensated for achieving exceptional results is what Congress intended for “private attorneys general.” b. The argument that court-awarded fees burden taxpayers and divert ...
Brief • 2012
determined that Plaintiff is entitled to attorneys’ fees, the Court next considers what constitutes a “reasonable” amount. In making this assessment, the Court uses the lodestar method, which entails ...
Brief • 2009
to death, or (d) to other federal prisoners who may be objects of acute public interest because of who they are or what crimes they have committed. (App. 35a, 105a). With respect to each of those four groups ...
Brief • 2009
)..................................6 Matteucci, Sherry, What the Heck Is “Value Billing” Anyway?, THE MONTANA LAWYER (Nov. 1992) ...................................................................11 Ross, William G., The Ethics ...
Brief • October 27, 2017
.  And was that lineup viewed by Miss Park?  A.  Yes.  Q.  Can you tell us what position Ryan Dufort occupied in the lineup at the time  it was viewed by Miss Park?  A.  I, I don’t have the position.  Q.  Would your ...
Brief • November 2, 2017
a duty to preserve the material; and (3) if the State did have a duty to preserve the material, whether the duty was breached and what consequences should flow from the breach. In determining what ...
Publication • February 18, 2014
, 2012.3 Privatizing entities once under exclusive governmental control has eliminated a key component of public accountability -- access to information that explains how the prisons are being run, at what ...
Publication • February 12, 2016
section of officials from 45 state corrections departments in an effort to spotlight the most effective management practices. What we found is that success is not simply a product of money or other ...
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