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Brief • 2009
March 11, 2008, Plaintiff began vomiting what she thought was Instead, her medical records note that she had only 62 days remaining at the facility, and that she "purges," having last purged two months ...
Brief • 2008
Cir. 2007) (quoting Fed. R. Civ. P. 8(a)(2)). The complaint “must describe the claim in sufficient detail to give the defendant ‘fair notice of what the … claim is and the grounds upon which it rests ...
Brief • 2005
. Yet, that is exactly what the DOC has done here. Creation of such an impossible standard is unconscionable. The DOC has an obligation to each and every person in this state, including sex offenders ...
Brief • 2006
(3d Cir. 1999) (citations and internal quotation marks omitted). Here, plaintiffs argue for reconsideration on the basis of the third ground—what plaintiffs characterize as “manifest error of law.” See ...
Brief • 1992
Kilby yesterday, and A lengthy delay was get him cleaned and dressed. It 1 understand appears that my son's condition has gotten worse. that some prison employees were even shocked by what they saw ...
Brief • 2001
. Jail. 26. No advance notice was given to the parents of the Subject Children to warn them of what awaited their children at the D.C. Jail. In addition, the corrections officers and staff ofthe D.C ...
Brief • 2006
does not define what “accompanied by an adult person” means. Specifically, there is no explanation as to how close the accompanying person must remain to the sex offender in order to satisfy ...
Brief • November 15, 2007
Filed under: Immigration
as to what might have happened to allegedly missing emails, many of them attributable to Bakhtiari, or his representatives who had access to his email account before it was frozen. UMR also presented evidence ...
Brief • November 17, 2017
, one common question of fact is what the appropriate standard of care is for a person with chronic HCV. Common questions of law include whether FDC’s failure to meet that standard of care constitutes ...
Brief • September 8, 2014
to get a lot worse, I’ll tell you that.” 21. Plaintiff asked Defendant Yetter, “Are you serious?”, to which Defendant Feehan threatened, “Do what they tell you to do. Yeah, we’re serious. Do what ...
did he interview and what policies etc. did he rely on? Dr. Thomas states that “[he] personally spoke to over 100 inmates [and that] [a]ll inmates interviewed related positive experiences ...
, oppression, or undue burden or expense." Fed. R. Civ. P. 26(c)(l). Rule 26(c) "confers broad discretion on the trial court to decide when a protective order is appropriate and what degree of protection ...
Brief • August 9, 2016
to this comple.int to ".:.he Warden or any of t..he prison officials? ~~ 2. c. II:!: .. dispos~tion: your a~swer was Yes: What was the ::-esul t { s) If yoill:' 2.Ilswer is NO, ex?lain why not: z / ?1 ...
Brief • October 16, 2013
Filed under: Telephone Rates
not state that $0.102 was a reasonable rate. While the Petitioners knew that 35 percent of the rate charged by GTL was dedicated to site commissions, they had no way of knowing what the basis ...
Brief • March 2, 2018
testified: Detective: I asked him whose meth it was. Mr. Boyd: And what was the response from him? Detective: First response he stated it wasn’t hers. Mr. Boyd: Was there another response? Detective: Yes. He ...
Brief • September 29, 2017
Filed under: Expert Witnesses
” and on “policies, procedures, guidelines directives and/or guidelines,”34 the Defendants do not address the gravamen of the Plaintiffs’ argument, namely; who did he interview and what policies etc. did he rely ...
Brief • March 11, 2015
psychosis” ; that the video of the events 18 “show[ed] French using what appears to be a choke hold,” and further showed “both Hanlon 12 19 and French actively engaging in taking Atencio down to the ground ...
Brief • November 28, 2017
on the applicable guidelines range. But its language in urging that sentence is what defendant claims, and the government acknowledges, violated the agreement governing the debriefing: The defendant wasn’t a retail ...
Brief • August 14, 2015
of Corrections is now in the possession of the Court. The Court has not listened to any of the recordings. The State acknowledges that the CD should be sealed and suppressed from use as evidence. What remains ...
the Plaintiff no explanation of what had happened to her husband despite numerous inquiries from her and other family members. 23. On February 24, 2018, the Plaintiff received a copy of the autopsy report ...
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