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to this complaint as Exhibit A. 4. Venue is proper under 28 U.S.C. § 1391(e)(2) because the events giving rise to Plaintiff’s claims occurred in this judicial district. PARTIES 5. The Plaintiff, Frank B ...
Brief • 2011
” that Rule 12(b)(1) motions do not convert to summary judgment motions upon review of extrinsic materials). 2 In addition, a court must “constru[e] all ambiguities and draw all inferences in plaintiff’s ...
Brief • 2007
of 15 1 Accepting as true Plaintiff's version of the facts--that he told 2 Defendants that he opposed the transfer because he was waiting to ~~e .~ Z 3 a specialist and a transfer would delay his ...
Brief • 2013
, Columbia University April 1998 Opening Plenary Lecturer, Scientific Sessions of the North American Society of Pacing and Electrophysiology (NASPE) May 1998 Annual Jesse E. Edwards, M.D. Lectureship ...
Brief • 2004
, condoned, and/or promoted by Sheriff's personnel ·7·· in such a manner that it served to add to Plaintiffs distress and injuries and 2 3 facilitate and encourage such assaultive behavior. e. 4 Plaintiff ...
Brief • 2008
suspicion that the arrestee subjected to the search is concealing weapons or other contraband to be unconstitutional and improper. E. A monetary award for attorney's fees and the costs of this action ...
Brief • 2008
6 STATE OF WASHINGTON THURSTON COUNTY SUPERIOR COURT 7 8 DEREK E. GRaNQUIST, 9 10 NO. 05-2-01941-4 Plaintiff, RESPONSE TO PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT v. II 12 13 14 VICTORIA ...
Brief • 2009
Constitution; COMPLAINT 22 c) Nominal damages to remedy the constitutional violations; d) Compensatory damages in an amount to be proven at trial; e) Punitive damages in an amount to be proven at trial ...
Brief • 2008
. 729 Evans Avenue Post Office Box 3344 Reno, NV 89505-3344 Telephone: 775/324-4533 Facsimile: 775/324-5444 DONALD YORK EVANS, ESQ. (SBN 1070) 216 E. Liberty Street Post Office Box 864 Reno, Nevada 89504 ...
Brief • January 29, 2013
commenced during her incarceration; d) That Plaintiff be awarded attorney's fees and reasonable expenses of litigation; e) That all costs of this action be taxed against Defendants; and f ...
Brief • January 11, 2012
that there is a genuine issue for trial.” Id. at 324 (quoting Fed. R. Civ. P. 56(e)). The evidence must be viewed in the light most favorable to the nonmoving party. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 251-52 ...
Brief • February 20, 2013
or participation with him, from continuing their unlawful Postcard-Only Mail Policy or any other policy that limits incoming inmate mail to postcards; E. An order declaring the Sheriffs Outgoing Mail Censorship ...
Brief • September 30, 2013
entirety. IT IS SO ORDERED. e tember 30 2013 ate ~~-~1 12 Benita Y. Pearson United States District Judge 13 ...
Brief • June 14, 2013
. Neal, 131 F.3d at 828-29. The court sated “[w]e can hardly conceive of a state’s action bearing more ‘stigmatizing consequences’ than the labeling of a prison inmate as a sex offender.” Neal, 131 F.3d ...
Brief • August 5, 2013
of an extensive treatment program, which included their confession to past sex offenses, as a pre-condition to parole eligibility. Neal, 131 F.3d at 828-29. The court stated “[w]e can hardly conceive of a state’s ...
Brief • July 28, 2014
Complaint (Doc. 36) at ¶¶ 91, 106. Indeed, as the Honorable Jan E. DuBois noted in denying defendant CMC’s motion to dismiss plaintiff’s Monell claims, plaintiff “does not base the Complaint’s allegations ...
– interviews that were expressly confidential – CCA’s attorney attempted to listen to and observe these interviews. Gluck Decl. ¶¶ 7-8. Before this visit, CCA’s attorney stated via e-mail that she would ...
Brief • 2012
allegations of the pleadings and set forth specific facts by producing competent evidence 11 that shows a genuine issue for trial. See Fed. R. Civ. P. 56(e); Celotex Corp., 477 U.S. at 12 324. 13 ...
No. 215228 WILLIAM DOWNER, State Bar No. 257644 Deputy Attorneys General 455 Golden Gate Avenue, Suite 11000 San Francisco, CA 94102-7004 Telephone: (415) 703-3035 Fax: (415) 703-5843 E-mail: Patrick.McKinney ...
Brief • July 27, 2015
PLN v. IDOC, IL, Complaint, FOIA, 2015 E-Notice 2015-CH-11292 CALENDAR: 16 To: Matthew Vincent Topic matt@loevy.com NOTICE OF ELECTRONIC FILING IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS PRISON ...
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