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and was second in command to Perez. 24. During the discussion of what discipline would be meted out to Yahnke based upon one of the fictitious complaints, Ziman asked Perez what type of discipline he would give ...
statement of the claim showing that the pleader is entitled to relief." Fed. R. Civ. P. 8(a)(2). The short and plain statement must "give the defendant fair notice of what the claim is and the grounds upon ...
, if he told anyone what occurred. Id. C/O Kauffman, a control room officer, allegedly witnessed the incident. Id. Plaintiff told Mrs. Destman in mental health what happened. (Doc. 1, p. 5). She asked ...
Brief • July 20, 2023
the same question: could this death have been prevented? The fact that the disturbingly long list 23 of names keeps growing raises another: what is happening inside the Jail? The answers to these 24 ...
Brief • December 29, 2021
Filed under: Wrongful Death
(of continually conducting belated checks), that they were utterly untrained in how, when and what manner to conduct such checks and/or that the TCSD were deliberately placing undertrained personnel in areas where ...
Brief • December 6, 2023
: The formulation adopted by the House is pregnant with litigious mischief. The committee has, therefore, adopted what we believe will be a clearer and more practical guideline for determining when courts should ...
Brief • July 20, 2023
Filed under: Failure to Treat
the same question: could this death have been prevented? The fact that the disturbingly long list 23 of names keeps growing raises another: what is happening inside the Jail? The answers to these 24 ...
Brief • June 30, 2022
prisoners safe return to their own cells. 18. After the physical assault was over, Defendant Bowser did not take any action against the assailants. The assailants did not appear concerned about what they had ...
Brief • December 27, 2016
in a correctional/jail setting. 11. 17 Determining standard of care requires one to review what a prudent 18 practitioner would do or would have done in the same or similar circumstances. In this case, 19 ...
Brief • January 8, 2024
of what Ms. Weathers, and other inmates, experienced while incarcerated at VPRJ. 14. First, Defendants intentionally created a fearful and dangerous environment to emotionally torture their inmates ...
Brief • June 21, 2022
.” This requirement can by met by pleading (1) precisely what statements or omissions were made; (2) the time and place the statements were made and by whom; (3) the content of the statements and how they misled ...
Brief • August 18, 2020
Filed under: Censorship
that is not the appropriate course of action, or what prejudice it would suffer as a result. If the Court at the Pre-Motion Conference denies Movant-Intervenor’s request to file the Motion, then the Motion is moot ...
Brief • November 3, 2008
□ Threat to safety □ Other: _ _ _ _ _ _ _ _ _ _ _ __ 3. Supporting Facts. State as briefly as possible the FACTS supporting Count I. Describe exactly what. each Defendant did or did not do that violated your ...
Brief • October 27, 2011
Filed under: Excessive Force
: _ _ _ _ _ _ _ _ _ _ __ . . (',\·";.·.. ~ '• FACTS · 3; Supporting Facts. .State .a'.s briefly ·as possibl~ the sup?,)rting CoUIJt I. Describe exac~y what- · -each Defendant did or did nbt_do"that violated your rights. State the fi!Cts clearly ...
Brief • April 20, 2012
Filed under: Excessive Force
.Other: ■ Excessive force by an officer D Thre tly what FACTS:supporting ·count IL Describe exac ~e hie ossi as:p ly brief as e Stat ts, Fac 3. Supporting own words without your rights. State the facts ...
Brief • April 18, 2012
-physically pushed her forward, bending her over the back seat of the 8 9 10 van, and pulled her pants down. Plaintiff demanded to know what Defendant GOMEZ was doing, but he told her to be quiet, and inserted ...
Brief • September 15, 2021
. The reasonable hourly rate is the rate a paying client would be willing to pay. In determining what rate a paying client would be willing to pay, the district court should consider, among others, the Johnson ...
slips with no attention by Medical what so ever, he assured me that my X-Ray results would be available that day and that I should be seen shortly there after, none the less I was never seen ...
Brief • August 29, 2013
these assaults, Doe would sometimes observe the jailers congratulate themselves, joke and laugh about what they had done. 24. Doe also observed the jailers constantly watching videos of mixed-martial arts (“MMA ...
knew Marty was “in a state of psychosis 11 17 whether it was mental psychosis or drug-related psychosis” ; that the video of the events 18 “show[ed] French using what appears to be a choke hold ...
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