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Brief • February 16, 2018
(b) The defendant's vocabulary may impede clear communication with the court and opposing counsel; (c) Judges will not act on behalf of a defendant in asserting objections or making appropriate ...
old sophomore at Howard High School of Technology, sent a relatively innocuous text message to a friend warning her to be careful in her communications with schoolmates, some of whom might ...
Brief • 2018
Filed under: Qualified Immunity
the police, strained relationships with communities of color, tight budgets, low unemployment rates, and the reduction of retirement benefits. Id. at 1813 & n.101. 14 III. THERE ARE MANY PLAUSIBLE ...
Brief • February 24, 2021
healthcare encounters where a prisoner was not fluent in 4 English and, yet, Paragraph 14 was not followed. Defendants explain those encounters did 5 not involve any problems in communication ...
assaulted on April 13. The inmate was discharged after undergoing a SANE (sexual assault nurse examiner) evaluation. That same day, the New York State Department of Corrections and Community Supervision ...
Brief • May 29, 2018
Filed under: Sexual Assault
and utterly intolerable in a civilized community. 138. Defendant Dunn’s conduct caused severe emotional distress to Plaintiff and this emotional distress resulted in bodily harm. 24 Case 5:18-cv-06074-BP ...
Brief • February 4, 2022
the circumstances; providing truthful information in reports, statements, and verbal communications; intervening in and preventing misconduct by fellow employees; reporting misconduct by fellow employees; obtaining ...
Brief • January 20, 2022
Counsel further agree not to initiate any conversation regarding this Release or the Settlement without express written approval from all parties to this Release. The only authorized communication ...
Brief • January 11, 2017
communication by Releasor or legal counsel for Releasor regarding the Release and/or Settlement shall be the statement that the matter was resolved to the mutual satisfaction of all concerned. Provided ...
Brief • August 1, 2022
to be inadequate medical care, substandard food, and disrespectful staff members. A BOP after-action report found deficiencies in staffing levels, staff experience, communication between staff and inmates ...
Brief • February 20, 2018
Filed under: Retaliation
medical expenses, as well as physical and emotional 7 distress and loss of reputation in the community. 8 9 10 4. This is also an action to vindicate Plaintiff’s rights and the rights of other ...
Brief • July 8, 2022
Filed under: Failure to Treat
by police officers); Doe v. Whitebread, No. 15-1165, 2017 WL 590272, at *4 (M.D. Pa. Feb. 14, 2017) (“Based on a review of cases involving officers assaulting members of the community or arrestees, which ...
Brief • October 20, 2018
. 103. As a direct and proximate result of Defendant Hanna’s acts, which were so outrageous in character and extreme in degree as to be utterly intolerable in a civilized community, Ms. Biggs suffered ...
that the prison official’s action communicated a threat not to use the prison's grievance procedure and that the threatened retaliation was of sufficient severity to deter a reasonable prisoner from filing ...
, including Defendant Officer Kemp, Defendant Nurse Kaiser, and Defendant Nurse Potts. 18. Mr. Primm communicated to Defendants Kemp, Kaiser, and Potts (among others) that he needed medical attention ...
Brief • August 30, 2022
review, the Court expressly finds that the provision of preforfeiture notice by text or other notice as provided for in the Settlement Agreement shall not be deemed a marketing communication or a violation ...
Brief • December 30, 2019
with the community level of care.” 117. On July 8, 2019 Mr. Fuller tried multiple times to use the Prison Rape Elimination Act (“PREA”) Hotline number. Posters with the PREA phone number and directions on how ...
Brief • June 24, 2021
, the removal of architectural, communication, or transportation barriers, or the provision of auxiliary aids and services, meets the essential eligibility requirements for the receipt of services ...
Brief • August 12, 2022
Filed under: False Imprisonment
community-based 4 organizations (“CBO” or “CBOs”) that are located in and perform a majority of their 5 work in Santa Clara County and for the purpose of providing reentry or related 6 services ...
Brief • May 1, 2012
intentionally or recklessly caused severe emotional distress to Santiago. Further, the conduct described was so outrageous as to be utterly intolerable in a civilized community. 91. As a result ...
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