Case: American Association of People With Disabilities v. Harris

American Association of People With Disabilities v. Hood

U.S. Court of Appeals for the Eleventh Circuit

U.S. Court of Appeals for the Eleventh Circuit

American Association of People With Disabilities v. Smith

American Association of People With Disabilities v. Smith

COMPLAINT for injunctive and declaratory relief and demand for jury trial filed (lrb) (Entered: 11/09/2001)

MAGISTRATE JUDGE CASE ASSIGNMENT Magistrate assigned: Timothy J. Corrigan (lrb) (Entered: 11/09/2001)

SUMMONS(ES) issued for Katherine Harris, L. Clayton Roberts, John Stafford, Warren Alvarez, Elaine Brown, Matt Carlucci, Doyle D. Carter, Gwen Chandler−Thompson, Lad Daniels, Reggie Fullwood, Alberta Hipps, Jerry Holland, King Holzendorf, Suzanne Jenkins, Pat Lockett−Felder, Jim Overton, Lake Ray III, Faye Rustin, Lynette Self, Ginger Soud, Mary A. Southwell, Gwen Yates . Consent(s) issued. (lrb) (Entered: 11/13/2001)

CONSENTED MOTION with memorandum of law by John Stafford, Warren Alvarez, Elaine Brown, Matt Carlucci, Doyle D. Carter, Gwen Chandler−Thompson, Lad Daniels, Reggie Fullwood, Alberta Hipps, Jerry Holland, King Holzendorf, Suzanne Jenkins, Pat Lockett−Felder, Jim Overton, Lake Ray III, Faye Rustin, Lynette Self, Ginger Soud, Mary A. Southwell, Gwen Yates extend time to answer or otherwise plead (CONSENTED) referred to Magistrate Judge Timothy J. Corrigan (lpp) (Entered: 12/05/2001)

ORDER granting [2−1] consent motion for extension of time to respond to complaint , resetting answer due for 12/24/01 for Gwen Yates, Mary A. Southwell, Ginger Soud, Lynette Self, Faye Rustin, Lake Ray III, Jim Overton, Pat Lockett−Felder, Suzanne Jenkins, King Holzendorf, Jerry Holland, Alberta Hipps, Reggie Fullwood, Lad Daniels, Gwen Chandler−Thompson, Doyle D. Carter, Matt Carlucci, Elaine Brown, Warren Alvarez, John Stafford, L. Clayton Roberts, Katherine Harris any required response by plaintiffs due 1/18/02 ( Signed by Magistrate Judge Timothy J. Corrigan ) ctc (lrb) (Entered: 12/06/2001)

ORDER scheduling preliminary pretrial conference and directing answers to standard interrogatories. Response to standard interrogatories due 1/17/02; pretrial conference set for 10:00 on 2/1/02; Scheduled for Magistrate Judge Timothy J. Corrigan ( Signed by Deputy Clerk ) ctc (lrb) (Entered: 01/17/2002)

MOTION by John Stafford, Warren Alvarez, Elaine Brown, et al. with memorandum in support to dismiss action (ddj) (Entered: 12/26/2001)

MOTION by Katherine Harris, L. Clayton Roberts to dismiss Plaintiff's Complaint (ddj) (Entered: 12/26/2001)

ANSWERS to standard interrogatories filed by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen (lrb) (Entered: 01/17/2002)

RESPONSE by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen in opposition to [5−1] motion to dismiss Plaintiff's Complaint (lrb) (Entered: 01/18/2002)

RESPONSE by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen in opposition to [6−1] motion to dismiss action (lrb) (Entered: 01/18/2002)

CASE MANAGEMENT REPORT (lrb) (Entered: 01/22/2002)

RESPONSE to standard interrogatories filed by John Stafford, Warren Alvarez, Elaine Brown, et al. (ddj) Modified on 02/21/2002 (Entered: 01/24/2002)

RESPONSE to standard interrogatories filed by Katherine Harris, L. Clayton Roberts (ddj) (Entered: 01/29/2002)

PRELIMINARY PRETRIAL CONFERENCE held on 2/1/02 before Magistrate Judge Timothy J. Corrigan Court Reporter: Richetta Brown (ddj) (Entered: 02/04/2002)

ORDER: plaintiff's deadline for filing a motion for class certification is 2/15/02 and defendant's response deadline to same is 3/22/02 ( Signed by Magistrate Judge Timothy J. Corrigan ) ctc (ddj) (Entered: 02/04/2002)

CASE MANAGEMENT AND SCHEDULING ORDER setting Joining of parties,amending of pleadings on 8/6/02 ; Discovery cutoff 12/6/02 ; dispositive motion filing deadline for 1/17/03; Pretrial conference for 9:45 4/4/03 ; Jury trial set for term commencing 5/5/03; (Stricken and not disseminated by order #17) Scheduled for Judge Ralph W. Nimmons Jr. ( signed by Judge Ralph W. Nimmons Jr. ) ctc (ddj) Modified on 02/06/2002 (Entered: 02/05/2002)

ORDER striking [16−1] Scheduling order and said order shall not be disseminated ( Signed by Judge Ralph W. Nimmons Jr. ) (ddj) (Entered: 02/06/2002)

MOTION by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen to certify class action (ddj) (Entered: 02/15/2002)

MEMORANDUM by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen in support of [18−1] motion to certify class action (ddj) (Entered: 02/15/2002)

MOTION by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen for leave to file reply brief to defendants' opposition to plaintiff's motion for class certification (ddj) (Entered: 02/15/2002)

NOTICE OF HEARING: Motion hearing set for 2:30 on 2/28/02 for [5−1] motion to dismiss Plaintiff's Complaint; set for 2:30 2/28/02 for [6−1] motion to dismiss action; Scheduled for Judge Ralph W. Nimmons Jr. ( Signed by Deputy Clerk ) ctc (def) (Entered: 02/19/2002)

MOTION HEARING held on 2/28/02 re: [5−1] motion to dismiss Plaintiff's Complaint, [6−1] motion to dismiss action before Judge Ralph W. Nimmons Jr., order to enter, Court Reporter: Marie Splane (ddj) Modified on 04/17/2002 (Entered: 02/28/2002)

RESPONSE by John Stafford, Warren Alvarez, Elaine Brown, et al. in opposition to [20−1] motion for leave to file reply brief to defendants' opposition to plaintiff's motion for class certification (ddj) (Entered: 03/05/2002)

CASE MANAGEMENT AND SCHEDULING ORDER setting Joining of parties, amending of pleadings on 6/4/02; Discovery cutoff 10/2/02; dispositive motion filing deadline for 12/2/02; Pretrial conference for 10:30 1/30/03; Bench trial set for term commencing 3/3/03; Scheduled for Judge Ralph W. Nimmons Jr. ( signed by Judge Ralph W. Nimmons Jr. ) ctc (ddj) (Entered: 03/06/2002)

ORDER directing answers to standard interrogatories. Response to standard interrogatories due 3/18/02 ( Signed by Judge Ralph W. Nimmons Jr. ) ctc (ddj) (Entered: 03/06/2002)

ENDORSED ORDER denying as premature [20−1] motion for leave to file reply brief to defendants' opposition to plaintiff's motion for class certification ( Signed by Judge Ralph W. Nimmons Jr. ) ctc (ddj) (Entered: 03/07/2002)

TRANSCRIPT of hearing on motion to dismiss complaint held on 2/28/02 before Judge Ralph W. Nimmons, Jr. Transcript filed separately. (ddj) (Entered: 03/11/2002)

ORDER vacating [25−1] order ( Signed by Judge Ralph W. Nimmons Jr. ) ctc (ddj) (Entered: 03/12/2002)

MEMORANDUM by John Stafford, Warren Alvarez, Elaine Brown, et al. in opposition to [18−1] motion to certify class action (sms) (Entered: 03/22/2002)

RESPONSE AND MEMORANDUM by Katherine Harris, L. Clayton Roberts in opposition to [18−1] motion to certify class action (ddj) (Entered: 03/25/2002)

MOTION by American Assoc., Daniel W. O'Connor, Kent Bell, et al. for leave to file reply to defendants' opposition to plaintiffs' motion for class certification (ddj) Modified on 04/09/2002 (Entered: 04/08/2002)

RESPONSE by John Stafford and members of the City Council in opposition to [31−1] motion for leave to file reply to defendants' opposition to plaintiffs' motion for class certification (slc) (Entered: 04/12/2002)

CONSENTED TO MOTION by John Stafford, Warren Alvarez, Elaine Brown, Matt Carlucci, Doyle D. Carter, Gwen Chandler−Thompson, Lad Daniels, Reggie Fullwood, Alberta Hipps, Jerry Holland, King Holzendorf, Suzanne Jenkins, Pat Lockett−Felder, Jim Overton, Lake Ray III, Faye Rustin, Lynette Self, Ginger Soud, Mary A. Southwell, Gwen Yates with memorandum in support for extension of time to respond to plaintiffs' discovery (consented) referred to Magistrate Judge Timothy J. Corrigan (Titled: Consented to Motion for Extension of Time to Respond to Complaint) (spw) (Entered: 07/30/2002)

ORDER granting [33−1] consent motion for extension of time to respond to complaint, which the Court construes as an unopposed motion for extension of time to respond to plaintiffs' discovery; all defendants shall respond to plaintiffs' discovery requests by 8/23/02; other deadlines in the Scheduling Order (#24) remain in effect ( Signed by Magistrate Judge Timothy J. Corrigan ) ctc (spw) (Entered: 08/01/2002)

SUGGESTION to substitute names of defendants by Katherine Harris, L. Clayton Roberts (jec) (Entered: 08/20/2002)

ORDER granting [35−1] suggestion to substitute names of defendants and Jim Smith is substituted as party defendant in place of Katherine Harris; and Edward C. Kast is substituted as party defendant L. Clayton Roberts. The clerk is directed to amend the docket and all parties' future submissions shall conform thereto. (Signed by Judge Ralph W. Nimmons Jr. ) ctc (jec) (Entered: 08/22/2002)

ORDER granting [31−1] motion for leave to file reply to defendants' opposition to plaintiffs' motion for class certification, and the clerk is directed to file the plaintiffs' reply memorandum. ( Signed by Judge Ralph W. Nimmons Jr. ) ctc (jec) (Entered: 08/22/2002)

REPLY MEMORANDUM by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen to response to [18−1] motion to certify class action (jec) (Entered: 08/22/2002)

CONSENTED TO MOTION by John Stafford, Warren Alvarez, Elaine Brown, et al., with memorandum in support for extension of time to conclude discovery (consented) referred to Magistrate Judge Timothy J. Corrigan (spw) (Entered: 09/10/2002)

ORDER granting [39−1] consent motion for extension of time to conclude discovery to the extent the discovery deadline is extended; resetting discovery due for 11/22/02 , all other deadlines in the Scheduling Order (#24) remain in full force and effect ( Signed by Magistrate Judge Timothy J. Corrigan ) ctc (spw) (Entered: 09/12/2002)

MAGISTRATE JUDGE CASE ASSIGNMENT Magistrate assigned: Howard T. Snyder (spw) (Entered: 09/23/2002)

ORDER granting in part [5−1] motion to dismiss Plaintiff's Complaint such that Counts 1 &3 are dismissed with prejudice to the extent plaintiffs assert they have been denied the benefits of a program of direct and secret voting that does not permit the type of assistance provided for in Section 101.051, Count 2 is dismissed with prejudice, and Count 3 is dismissed with leave to amend; granting in part [6−1] motion to dismiss action such that all counts are dismissed with prejudice as to defendants Alvarez, Brown, Carlucci, Carter, Chandler−Thompson, Daniels, Fullwood, Hipps, Holland, Holzendorf, Jenkins, Lockett−Felder, Overton, Ray, Rustin, Self, Soud, Southwell, and Yates, Counts 1 &3 are dismissed with prejudice as to defendant Stafford to the extent plaintiffs assert they have been denied the benefits of a program of direct and secret voting that does not permit the type of assistance provided for in Section 101.051, and Count 2 is dismissed with prejudice; setting amended complaint deadline at 11/5/02 for Beth Bowen, Kent Bell, Daniel W. O'Connor, and American Assoc. as described in the Order (Signed by Judge Ralph W. Nimmons Jr.) ctc (spw) Modified on 10/17/2002 (Entered: 10/16/2002)

CONSENTED TO MOTION by John Stafford to continue trial date (consent) , and to amend [24−1] Case Management and Scheduling order (consent) (spw) (Entered: 10/24/2002)

MOTION by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen to compel production of documents , for designation of 30(B)(6) witnesses , and for sanctions referred to Magistrate Judge Howard T. Snyder (spw) (Entered: 10/25/2002)

MEMORANDUM by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen in support of [44−1] motion to compel production of documents, [44−2] motion for designation of 30(B)(6) witnesses, [44−3] motion for sanctions (spw) (Entered: 10/25/2002)

MOTION by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen with memorandum in support for reconsideration of [42−1] order (spw) (Entered: 10/29/2002)

AMENDED COMPLAINT for injunctive and declaratory relief, by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen, amending [1−1] complaint (Answer due 11/20/02 for Edward C. Kast, for Jim Smith, for John Stafford ) (spw) (Entered: 11/05/2002)

AMENDED ORDER amending [24−1] order; granting [43−1] consent motion to continue trial date; granting [43−2] consent motion to amend [24−1] Case Management and Scheduling order; resetting scheduling order deadlines: Discovery cutoff 4/3/03; Deadline for filing dispositive motions 6/2/03; Pretrial conference set for 10:30 on 8/8/03; Pretrial statement due by 8/5/03; Bench trial set for term of 9/2 − 9/26/03; scheduled for Judge Ralph W. Nimmons Jr. ; trial briefs and proposed findings due 5 days prior to the commencement of the trial term with 2 copies to chambers (Signed by Judge Ralph W. Nimmons Jr.) ctc (spw) (Entered: 11/05/2002)

RESPONSE by Jim Smith, Edward C. Kast to [44−1] motion to compel production of documents, [44−2] motion for designation of 30(B)(6) witnesses, [44−3] motion for sanctions (shs) (Entered: 11/06/2002)

RESPONSE by Jim Smith, Edward C. Kast to [46−1] motion for reconsideration of [42−1] order (mgg) (Entered: 11/12/2002)

RESPONSE by John Stafford, Warren Alvarez, Elaine Brown, Matt Carlucci, Doyle D. Carter, Gwen Chandler−Thompson, Lad Daniels, Reggie Fullwood, Alberta Hipps, Jerry Holland, King Holzendorf, Suzanne Jenkins, Pat Lockett−Felder, Jim Overton, Lake Ray III, Faye Rustin, Lynette Self, Ginger Soud, Mary A. Southwell, Gwen Yates in opposition to [46−1] motion for

MOTION by John Stafford with memorandum in support to dismiss amended complaint , or, alternatively, for summary judgment (spw) (Entered: 11/21/2002)

SUMMARY JUDGMENT NOTICE: response to motion set to 12/5/02 for [53−2] motion for summary judgment by defendant (Signed by Deputy Clerk ) ctc (spw) (Entered: 11/21/2002)

MOTION by Jim Smith, Edward C. Kast with memorandum in support to dismiss 2nd amended complaint , or in the alternative motion for for summary judgment (spw) (Entered: 11/27/2002)

SUMMARY JUDGMENT NOTICE: response to motion set to 12/11/02 for [55−2] motion for summary judgment by defendants (Signed by Deputy) ctc (spw) (Entered: 11/27/2002)

NOTICE of filing exhibit by Jim Smith, Edward C. Kast re: [55−1] motion to dismiss 2nd amended complaint (exhibit, Innovations in Election Administration, filed separately) (spw) (Entered: 12/03/2002)

CONSOLIDATED OPPOSITION by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen to [55−1] motion to dismiss 2nd amended complaint, [55−2] motion for summary judgment, [53−1] to dismiss amended complaint, [53−2] motion for summary judgment (shs) (Entered: 12/05/2002)

SUPPLEMENTAL RULE 56(F) OPPOSITION by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen to [53−1] motion to dismiss amended complaint, [53−2] motion for summary judgment (shs) (Entered: 12/05/2002)

REQUEST for oral argument by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen re: [55−1] motion to dismiss 2nd amended complaint, [55−2] motion for summary judgment, [53−1] motion to dismiss amended complaint, [53−2] motion for summary judgment (shs) (Entered: 12/05/2002)

SUPPLEMENTAL RULE 56(F) OPPOSITION by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen to [55−1] motion to dismiss 2nd amended complaint, [55−2] motion for summary judgment (mgg) (Entered: 12/11/2002)

NOTICE of correction of plaintiff's supplemental rule 56(F) opposition to defendant Stafford's motion to dismiss amended complaint or alternatively for summary judgement by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen (mgg) Modified on 12/12/2002 (Entered: 12/11/2002)

RESPONSE by John Stafford in opposition to [59−1] motion response (shs) (Entered: 12/23/2002)

RESPONSE by Jim Smith, Edward C. Kast to response to [55−1] motion to dismiss 2nd amended complaint, [55−2] motion for summary judgment (Titled: Defendants Smith and Kast's Response to Plaintiffs' Motion under Rule 56(f)) (spw) (Entered: 01/02/2003)

SUGGESTION to substitute names of defendants, by Ken Detzner, replacing Jim Smith (spw) (Entered: 01/21/2003)

ENDORSED ORDER granting [65−1] suggestion to substitute names of defendants. ( Signed by Judge Ralph W. Nimmons Jr. ) ctc (jec) (Entered: 01/24/2003)

NOTICE OF HEARING: Motion hearing set for 10:30 2/25/03 for [44−1] motion to compel production of documents, [44−2] motion for designation of 30(B)(6) witnesses, [44−3] motion for sanctions Scheduled for Magistrate Judge Howard T. Snyder ( Signed by Deputy Clerk ) ctc (mgg) (Entered: 02/07/2003)

NOTICE of withdrawal of plaintiffs' motion to compel production of documents, designation of 30(b)(6) witnesses, and for sanctions, by American Assoc., Daniel W. O'Connor, Kent Bell, et al. (spw) (Entered: 02/21/2003)

WITHDRAWAL of/terminating [44−1] motion to compel production of documents, terminating [44−2] motion for designation of 30(B)(6) witnesses, terminating [44−3] motion for sanctions (spw) (Entered: 02/21/2003)

DEPOSITION of John Lawton Stafford, Jr. by American Assoc., et al., re: [58−1] response in opposition; Transcript filed separately. (mgg) (Entered: 02/25/2003)

NOTICE of substitution of counsel by American Assoc. (substituting Ari N. Rothman for Courtney O. Taylor) (spw) (Entered: 03/04/2003)

SUGGESTION to substitute names of defendants, by Ken Detzner (spw) (Entered: 03/24/2003)

ENDORSED ORDER granting [71−1] suggestion to substitute names of defendants ( Signed by Judge Ralph W. Nimmons Jr. ) ctc (spw) (Entered: 03/28/2003)

NOTICE of filing of deposition transcripts in further support of plaintiffs' opposition to defendant Stafford's motion to dismiss amended complaint or alternatively for summary judgment and plaintiffs' opposition to defendants Smith and Kast's motion to dismiss amended complaint or alternatively for summary judgment, by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen (spw) (Entered: 04/03/2003)

VIDEO DEPOSITION of Edward Kast by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen re: [59−1] motion response, [61−1] opposition response; Transcript filed separately. (spw) (Entered: 04/03/2003)

VIDEO DEPOSITION of Hal Lench by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen re: [61−1] opposition response, [59−1] motion response; Transcript filed separately. (spw) (Entered: 04/03/2003)

VIDEO DEPOSITION of L. Clayton Roberts by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen re: [61−1] opposition response, [59−1] motion response; Transcript filed separately. (spw) (Entered: 04/03/2003)

DEPOSITION of American Association of People with Disabilities, by and through its designated representative, James Dickson, by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen re: [61−1] opposition response, [59−1] motion response; Transcript filed separately. (spw) (Entered: 04/03/2003)

DEPOSITION of Daniel William O'Connor by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen re: [61−1] opposition response, [59−1] motion response; Transcript filed separately. (spw) (Entered: 04/03/2003)

DEPOSITION of Harriet Elizabeth Bishop Bowen by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen re: [61−1] opposition response, [59−1] motion response; Transcript filed separately. (spw) (Entered: 04/03/2003)

DEPOSITION of Kenton Ray Bell by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen re: [61−1] opposition response, [59−1] motion response; Transcript filed separately. (spw) (Entered: 04/03/2003)

DEPOSITION of Julie Shaw by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen re: [61−1] opposition response, [59−1] motion response; Transcript filed separately. (spw) (Entered: 04/03/2003)

VIDEOTAPED DEPOSITION of Cathy Cox by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen re: [61−1] opposition response, [59−1] motion response; Transcript filed separately. (spw) (Entered: 04/03/2003)

VIDEOTAPED DEPOSITION of Honorable Katherine Harris by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen re: [61−1] opposition response, [59−1] motion response; Transcript filed separately. (spw) (Entered: 04/03/2003)

VIDEOTAPED DEPOSITION of Larry Crow by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen re: [61−1] opposition response, [59−1] motion response; Transcript filed separately. (spw) (Entered: 04/03/2003)

VIDEOTAPED DEPOSITION of Kurt Browning by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen re: [61−1] opposition response, [59−1] motion response; Transcript filed separately. (spw) (Entered: 04/03/2003)

CONSENTED−TO MOTION by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen for leave to file supplemental memorandum in support of plaintiffs' motion for reconsideration (consented−to) (proposed supplemental memo received) (spw) (Entered: 04/07/2003)

NOTICE by John Stafford regarding [86−1] consent motion for leave to file supplemental memorandum in support of plaintiffs' motion for reconsideration (spw) (Entered: 04/08/2003)

NOTICE of filing of deposition transcripts in further support of plaintiffs' opposition to defendant Stafford's motion to dismiss amended complaint or alternatively for summary judgment, and plaintiffs' opposition to defendants Smith and Kast's motion to dismiss amended complaint or alternatively for summary judgment, by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen (spw) (Entered: 04/10/2003)

VIDEOTAPED DEPOSITION of Cheryl L. Brown by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen re: [61−1] opposition response, [59−1] motion response; Transcript filed separately. (spw) (Entered: 04/10/2003)

DEPOSITION of Jacquelyn H. Gibbs by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen re: [61−1] opposition response, [59−1] motion response; Transcript filed separately. (spw) Modified on 04/14/2003 (Entered: 04/10/2003)

DEPOSITION of Preston H. Haskell by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen re: [61−1] opposition response, [59−1] motion response; Transcript filed separately. (spw) (Entered: 04/10/2003)

DEPOSITION of Jason Teal by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen re: [61−1] opposition response, [59−1] motion response; Transcript filed separately. (spw) (Entered: 04/10/2003)

DEPOSITION of Beverly B. Kaufman by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen re: [61−1] opposition response, [59−1] motion response; Transcript filed separately. (spw) (Entered: 04/10/2003)

DEPOSITION of Brian J. O'Connor by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen re: [61−1] opposition response, [59−1] motion response; Transcript filed separately. (spw) (Entered: 04/10/2003)

MOTION by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen for summary judgment against defendant John Stafford on Count I (ADA) of the amended complaint (spw) (Entered: 04/14/2003)

MEMORANDUM by American Assoc., Daniel W. O'Connor, Kent Bell, Beth Bowen in support of [95−1] motion for summary judgment against defendant John Stafford on Count I (ADA) of the amended complaint (spw) (Entered: 04/14/2003)

SUMMARY JUDGMENT NOTICE: response to motion set to 4/28/03 for [95−1] motion for summary judgment against defendant John Stafford on Count I (ADA) of the amended complaint ( Signed by Deputy Clerk ) ctc (spw) (Entered: 04/14/2003)

RESPONSE by John Stafford to plaintiffs' supplemental memorandum in support of motion for reconsideration (Note: supplemental memorandum not yet filed) (spw) (Entered: 04/22/2003)

RESPONSE by John Stafford in opposition to [95−1] motion for summary judgment against defendant John Stafford on Count I (ADA) of the amended complaint (spw) (Entered: 04/29/2003)