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there is no specific allegation of specific knowledge.” Id. at 378. The court stated that the information about “who observed [J.M.V.] day to day and what reports” existed were “what ought to be discovered in this case ...
had not been paid. b. On or about January 27, 2015, at approximately 1:31 p.m., HUBERFELD placed a call to CC-1. During the call, HUBERFELD told CC-1 "what are we doing about speaking about gelt," which ...
Wallace told them, "I should not have a celly and ya'II [meaning the c/o's] know this." (Doc. l, p. 4). C/O Spiller responded, "We're just doing what we are told." Id. Inmate Wallace then stepped away from ...
Brief • May 4, 2018
something,you do it no matter what." 26. On information and belief, the actions described herein are consistent with a pattern and practice of excessive force against persons detained in the Lake County ...
in time does suggest that 17 it sounds like retaliation. That’s what we frequently see in cases, link in time with respect 18 to actions and adverse actions that are taken.”)] Their 19 While ...
Brief • September 28, 2015
video recordings at the Border Patrol stations, but would inquire into what video recordings 20 Defendants actually had and how it could be produced to Plaintiffs. (Sanction Motion, 21 Mayer Decl ...
. But that is not what actually happens—disguised as a drug and alcohol rehabilitation program, Cenikor’s program actually requires patients to work as much as 80 hours per week in manual labor jobs for Centikor’s ...
) (“It seems to us that responding to an inmate’s acknowledged medical need with what amounts to a shoulder-shrugging refusal even to consider whether a particular course of treatment is appropriate is the very ...
Brief • January 5, 2021
a dark-colored SUV drive past at what he estimated to be between 90 and 95 miles per hour, with its hazard lights flashing. App. 155, 244-45, 247-50. Tpr. Burke did not immediately pursue the SUV. He spent ...
Brief • 2021
Filed under: Telephone Rates
that provides the service at a rate well above what is available to inmates in other California counties and to the general public.. In addition, Sonoma County’s contract adds a 70% commission to the cost ...
mediation, arbitration, neutral evaluation, special masters and referees, and settlement conferences, among others forms. What are the advantages of choosing ADR Instead of litigation? ADR can have a number ...
bumping her 15 chest on Plaintiff, yelling, “You don’t fucking tell me what to do, I don’t have to ask you shit” 16 and “Grab your shit and get the fuck out.” As Plaintiff attempted to leave, Defendant ...
Brief • September 30, 2021
Filed under: Tattoos, Censorship, Magazines
penological goals in general. The Court understands it must defer to the expertise of prison officials on what is likely to be inflammatory in the prison environment, see Murchison, 779 F.3d at 888 ...
Brief • June 21, 2023
Filed under: Wrongful Death
U.S. 97, 103 (1976). (citation omitted). That is exactly what Defendants caused here. 24 Moreover, the jury can find that Randall Johnson’s suffering and death was set in motion by 25 Defendant CFMG ...
Brief • December 22, 2021
Filed under: Protests, Excessive Force
responded: “that’s what we are, tactical officers… if we’re deployed, we deploy tactically” (Eberharter deposition, pp. 56-57). This is a circular argument that lacks credibility. It suggests that Metro/SWAT ...
Brief • April 15, 2022
Filed under: Failure to Treat
then quoted or cited Dr. Favilla’s report. Id. at pages 1-2. He wrote, “Mr. Jarvis 7 Case 1:20-cv-02028-RMR-GPG Document 127 Filed 04/15/22 USDC Colorado Page 8 of 16 missing what amounts to 3 doses ...
Brief • May 20, 2022
Filed under: Failure to Treat
Mr. Jarvis’ medications did not put him at substantial risk for medical harm “as stated by Dr. Favilla in his report.” Exhibit 8 at page 8. “Mr. Jarvis missing what amounts to 3 doses of lisinopril did ...
Brief • March 4, 2024
what she should do on 2D3. 19. Plaintiff went to Unit 2D3. Unit 2D3 was fully staffed. There were three officers working on that unit. In addition, another Correctional Police Officer ...
Brief • June 27, 2023
warrant, and the number of officers involved in the incident. He also identified what he characterized as a legal difference between the Fourth Amendment rights at issue in Snowden’s case and in Bivens. He ...
Brief • April 15, 2022
Filed under: Failure to Treat
then quoted or cited Dr. Favilla’s report. Id. at pages 1-2. He wrote, “Mr. Jarvis 7 Case 1:20-cv-02028-RMR-GPG Document 127 Filed 04/15/22 USDC Colorado Page 8 of 16 missing what amounts to 3 doses ...
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