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Brief • December 9, 2009
. See Act of May 29, 1995, 74th Leg., RS., § 5, art. 42.18, sec. 2(c-I), 1995 Tex. Gen. Laws 2592, 2592-93 (current version at Tex. Govt. Code Ann. § 508.149(b) (West Supp. 2008)). 2 Case 1:05-cv-01008 ...
Brief • 2012
, analyses and summaries that concern (a) facility staffing, (b) facility training, or (c) staff-initiated violence; (2) all facility budgets for the Cimarron Correctional Facility; and (3) all corporate level ...
Brief • February 23, 2009
escalation of force, 11 Case 1:08-cv-00406-MAC Document 24 44. Filed 02/23/09 Page 12 of 15 b. the use of excessive force, c. the illegality of excessive force, d. the constitutional limits ...
Brief • August 18, 2004
, January 31, 2005; 4 b. Last day to hear dispositive motions, January 31, 2004; 5 c. Mutual expert witness disclosure, February 7, 2005; 6 d. Designation of rebuttal expert witnesses, February 21 ...
Brief • May 16, 2011
CIRCUIT _____________________________________________________________ ESTATE OF KELLY A. ALLEN, Deceased; MARIA NICOLE ALLEN, a minor by next friend, Kenneth B. Allen; ALEXIS LANE ALLEN, a minor by next ...
Brief • 2012
damages as to all defendants; B. Punitive damages as to defendants Hagy, Farley, Jenkins, Layton, Brooks, Walker, Cook, Verrecchio, Williams, Lloyd, Young, and Himmons; C. Reasonable attorneys’ fees ...
Brief
and local public body as those terms are defined in the New Mexico Tort Claims Act, §§ 41-4-3(B) and (C) NMSA 1978, as amended. At all times material hereto, Dona Ana County was the employer and supervisor ...
Brief • January 6, 2011
. Johnson’s colon cancer; (b) Refusing to transfer Mr. Johnson to the infirmary, where his colon cancer could be monitored and treated and his chronic pain could be managed; and (c) Failing to take any ...
Brief • June 7, 2006
Form is timely and valid; (b) that the information on the form is consistent with available data previously provided by Defendants, and supplemented by Defendants in their objection, if any; and (c ...
Brief • July 25, 2008
Block. 4 DISCUSSION Section 1988(b) provides that “[i]n any action or proceeding to enforce a provision of . . . the Religious Land Use and Institutionalized Persons Act of 2000, . . . the court, in its ...
Brief • 2005
(b)(3) and 52.1(h). Defendants dispute Plaintiffs’ entitlement under all of these provisions 2 and also argue that the plaintiffs who have resolved their individual claims for damages 3 waived any ...
Brief • May 30, 2014
for the City of Tallahassee. 138. The conduct of the Officers constituted the torts of: a. Assault; b. Battery; c. Fraudulent charging. 139. By reason of the acts alleged above, Defendant City caused David West ...
Brief
of relief. C. B. With the waiver in place and municipal policy discovery declared offlimits, this Court would be faced with frequent disputes concerning the scope of permissible discovery. The aim ...
Brief • 2010
5411b(c) directs the DOC to adopt , rules and identify such offenders. The rule appears in the Vermont Administrative Code as § 128-4:1-6 or DOC Rule 4, and is available on Westlaw at VT ADC B 130025 ...
Brief • 2008
by: A. entering a contract with PHS that allowed it to provide medical care to Vermont inmates including Plaintiff; B. knowingly failing to consider, evaluate, and/or adequately investigate, or by ignoring ...
Brief • 2008
and Constitutional rights, and otherwise wrongful conduct, and award the following relief, as appropriate: a. Declaratory relief; b. Injunctive relief to eradicate ongoing constitutional violations; c ...
Brief • 2012
.......................................................8 V. Defendant Upah Is Not Entitled To Qualified Immunity ......................9 A. There was a constitutional violation ........................................10 B. C. VI. Defendant Upah’s ...
Brief • August 3, 2015
Filed under: Age Discrimination
OF PENNSYLVANIA WALTER MIKULAN Plaintiff, v. ALLEGHENY COUNTY Defendant. ) ) ) ) ) ) ) ) ) C. A. No. JURY TRIAL DEMANDED COMPLAINT IN CIVIL ACTION I) Introduction 1) This Complaint alleges that Defendant ...
Brief
of and provision of services at the Probation Camps. B. “DOJ” means the United States Department of Justice, Civil Rights Division, its agents and employees. C. “The Probation Camps” means Camp Afflerbaugh; Camp ...
: 1. Introduction. This action arises from the sexual abuse (See Exhibit 8, KRS §510.120(1)(c)) of John Roe then a twenty-eight (28) year old prisoner at the Marion Adjustment Center (MAC) in St. Mary ...
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