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Brief • 2007
or inmates which resulted in serious 10 injury or loss of life; 11 e. 12 to periodically monitor an inmate's serious mental/medical condition which may result in serious injury or loss of life; 13 f ...
probability due to the death of their father, son and spouse; d. Loss of inheritance sustained by Plaintiffs as a result of the death of their father, son and spouse; e. Physical Pain and suffering endured ...
Brief • September 9, 2011
PLAINTIFFS’ REQUESTED STOCK INSTRUCTIONS 2 In accordance with Paragraph (E)(7) of the Court’s Trial Preparation Instructions, 3 Plaintiffs request the following stock jury instructions be given at trial ...
Brief • 2009
.) I. (a) PLAINTIFFS DEFENDANTS Victor L. Martin (b) Alvin W. Keller, Secretary of North Carolina Department of Correction; et al. 0 County of Residence of First Listed Defendant ..;W......;a...e ...
Brief • 2011
... bears the burden of overcoming th[e] strong presumption by meeting the 'compelling reasons' standard." Id. (citation omitted). Here, no such showing has been made, and the Settlement Agreement must ...
Brief • 2006
the guidelines for "Foods Used," "Preparation Methods," and "Sanitation and Safety" as described in Exhibit A. 3 (e) 4 5 6 7 8 9 10 11 Enforcement of Rights: All kosher-observant inmates whose rights ...
Brief • 2005
, Gallagher was transported 19 to the McGuire Correctional Facility ("MCF") in downtown Redwood City. Compl. at ¶ 23; Decl. of 20 Mark E. Merin ("Merin Decl.") at Ex. B (Gallagher Depo. at 23:20-26:5 ...
Brief • 2011
Today_ If you receive more than one Claim Form, sign and file all Claim Forms you Form) sign and file all Claim Forms you receive, receIve. 2 2 EX1llBITC EXI-llBITC EXHIBlTC EXHIBIT C 36 Nn e Case 1:07 ...
Brief • March 6, 2008
Department of Corrections; ROBERT BANNISTER, ) Medical Director, Nevada Department of Corrections; and ) E. K. MCDANIEL, Warden, Ely State Prison. ) ) Defendants ...
Brief • 2006
executed this Settlement Agreement voluntarily. Page 6 of 11 o t//d.-!3/vt:/ DATE DATE 7 E D. OWEN, ESQ. A At Law 5354 North High Street Columbus,OH 43214 COUNSEL FOR PLAINTIFF ~ bif J!(J.() ~ePETER ...
Brief • 2007
, the opposing party may not simply rest upon the pleadings but must instead submit evidentiary materials that “set forth specific facts showing that there is a genuine issue for trial.” Fed. R. Civ. P. 56(e ...
Brief • 2013
: “it remains Respondent‟s abiding conviction that he has not violated any of his duties as an attorney and that all the charges against him should be dismissed.” Mitigation Good Character (Std. 1.2(e)(vi ...
Brief • 2010
affidavit, however, the verified complaint must be based on personal knowledge and set forth specific facts admissible in evidence." Id. (citing Fed.R.Civ.P. 56(e); McElyea, 833 F.2d at 197; Lew v. Kona Hosp ...
Brief
UNION, LOCAL 1000, Defendant, Cross-complainant and Respondent. APPEAL from a judgment of the Superior Court of Sacramento County, Kevin R. Culhane, Judge. Reversed with directions. Christopher E. Thomas ...
Brief • 2009
conclusory or confusing expert testimony: “[e]xpert evidence can be both powerful and quite misleading because of the difficulty in evaluating it. Because of this risk, the judge in weighing possible prejudice ...
Brief • March 31, 2011
it was happening because she was afraid. 67. On May 13, 2009, this prisoner also took a polygraph test, which confirmed that she was telling the truth. E. THE OHIO STATE HIGHWAY PATROL INVESTIGATES the Plaintiff’S ...
to follow the policies that were in place, if any, for the care and maintenance of mentally ill detainees of the Lincoln County Jail; e. Repeatedly denied Mr. Thomas the opportunity to be taken ...
by placing pregnant women into solitary confinement, and whether those practices violate the eighth and fourteenth amendments to the U.S. Constitution; and e. whether Defendants’ failure to provide pre ...
. Constitution; e. whether Plaintiff and the other members of the class are entitled to declaratory relief; and 19 Case 4:19-cv-00094-MW-CAS Document 1 Filed 02/19/19 Page 20 of 27 f. whether Plaintiff ...
; and (iv) any further appropriate injunctions to prevent future violations of Plaintiffs’ and the Plaintiff Class’s rights. d. Award named Plaintiffs compensatory and punitive damages. e. Award Plaintiffs ...
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