Case: Prison Legal News v. Berkeley County Sheriff

PLN v. Berkeley County Sheriff

PLN v. Berkeley County Sheriff

PLN v. Berkeley County Sheriff

Prison Legal News v. Berkeley County Sheriff's Office

PLN v. Berkeley County Sheriff

PLN v. Berkeley County Sheriff

PLN v. Berkeley County Sheriff

ACLU

COMPLAINT against All Defendants ( Filing fee $ 350 receipt number 0420-2982018.), filed by Prison Legal News, Human Rights Defense Center. (Attachments: # 1 Exhibit A-B)(asni, ) (Entered: 10/06/2010)

1 Exhibit A-B

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Summons Issued as to H Wayne DeWitt, John Doe 1, John Doe 2, John Doe 3, John Doe 4, Cliff McElvogue and Tony Riley. (asni, ) Modified to edit text on 10/6/2010 (asni, ). (Entered: 10/06/2010)

Local Rule 26.01 Answers to Interrogatories by Human Rights Defense Center, Prison Legal News.(asni, ) (Entered: 10/06/2010)

MOTION to Appear Pro Hac Vice by Lance T Weber ( Filing fee $ 250 receipt number 0420-2987581) by Human Rights Defense Center, Prison Legal News. Response to Motion due by 10/25/2010 (Attachments: # 1 Exhibit Application/Affidavit, # 2 Exhibit Certificate of Good Standing)Proposed order is being emailed to chambers with copy to opposing counsel(Dunn, Susan) (Entered: 10/08/2010)

1 Exhibit Application/Affidavit

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2 Exhibit Certificate of Good Standing

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MOTION to Appear Pro Hac Vice by David Michael Shapiro ( Filing fee $ 250 receipt number 0420-2987612) by Human Rights Defense Center, Prison Legal News. Response to Motion due by 10/25/2010 (Attachments: # 1 Exhibit Application/Affidavit, # 2 Exhibit Certificate of Good Standing)Proposed order is being emailed to chambers with copy to opposing counsel(Dunn, Susan) (Attachment 1 replaced on 11/3/2010) (asni, ). affidavit was replaced at the request of chambers since the notary was not the original signature on 11/4/2010 (asni, ). (Entered: 10/08/2010)

1 Exhibit Application/Affidavit

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2 Exhibit Certificate of Good Standing

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MOTION to Appear Pro Hac Vice by David C. Fahti ( Filing fee $ 250 receipt number 0420-2987626) by Human Rights Defense Center, Prison Legal News. Response to Motion due by 10/25/2010 (Attachments: # 1 Exhibit Application/Affidavit, # 2 Exhibit Certificate of Good Standing)Proposed order is being emailed to chambers with copy to opposing counsel(Dunn, Susan) additional attachment entry 15 added on 11/3/2010 (asni, ). (Attachment 1 replaced on 11/3/2010) (asni, ). affidavit was replaced at the request of chambers since the notary was not the original signature on 11/4/2010 (asni, ). (Entered: 10/08/2010)

1 Exhibit Application/Affidavit

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2 Exhibit Certificate of Good Standing

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TEXT ORDER granting 5 Motion to Appear Pro Hac Vice Signed by Honorable Margaret B Seymour on 10/14/2010.(asni, ) (Entered: 10/14/2010)

ANSWER to 1 Complaint by H Wayne DeWitt, John Doe 1, John Doe 2, John Doe 3, John Doe 4, Cliff McElvogue, Tony Riley.(Senn, Sandra) (Entered: 11/01/2010)

CONFERENCE AND SCHEDULING ORDER Rule 26(f) Conference Deadline 11/22/2010, 26(a) Initial Disclosures due by 12/6/2010, Rule 26 Report due by 12/6/2010, Amended Pleadings due by 1/4/2011, Plaintiffs ID of Expert Witness due by 1/31/2011, Defendants ID of Expert Witnesses Due by 3/1/2011, Records Custodian Affidavit due by 3/1/2011, Discovery due by 5/2/2011, Motion in Limine due by 8/11/2011, Motions due by 5/16/2011, Rule 26(a)(3) Disclosures due by 7/29/2011, Pretrial Briefs due by 8/27/2011, Jury Selection Deadline 9/1/2011, ADR Statement due by 6/14/2011, Mediation Due by 7/14/2011,. Signed by Honorable Margaret B Seymour on 11/2/2010. (asni, ) (Entered: 11/02/2010)

Additional Attachments to Main Document 7 MOTION to Appear Pro Hac Vice by David C. Fahti ( Filing fee $ 250 receipt number 0420-2987626) MOTION to Appear Pro Hac Vice by David C. Fahti ( Filing fee $ 250 receipt number 0420-2987626) Certificate of Good Standing. (Dunn, Susan) (Entered: 11/03/2010)

TEXT ORDER granting 6 Motion to Appear Pro Hac Vice; granting 7 Motion to Appear Pro Hac Vice Signed by Honorable Margaret B Seymour on 11/3/2010.(asni, ) (Entered: 11/04/2010)

Joint Rule 26(f) Report by H Wayne DeWitt, John Doe 1, John Doe 2, John Doe 3, John Doe 4, Human Rights Defense Center, Cliff McElvogue, Prison Legal News, Tony Riley. (Attachments: # 1 LR 26.03 Answers)(Dunn, Susan) (Entered: 12/06/2010)

1 LR 26.03 Answers

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CONSENT AMENDED SCHEDULING ORDER Amended Pleadings due by 2/4/2011, Plaintiffs ID of Expert Witness due by 3/4/2011, Defendants ID of Expert Witnesses Due by 4/4/2011, Records Custodian Affidavit due by 4/4/2011, Discovery due by 6/6/2011, Motion in Limine due by 9/9/2011, Motions due by 6/20/2011, Rule 26(a)(3) Disclosures due by 8/29/2011, Pretrial Briefs due by 9/28/2011, Jury Selection Deadline 10/3/2011, ADR Statement due by 7/15/2011, Mediation Due by 8/15/2011,. Signed by Honorable Margaret B Seymour on 12/7/2010. (asni, ) (Entered: 12/07/2010)

Consent MOTION to Amend/Correct 19 Scheduling Order,, by H Wayne DeWitt, John Doe 1, John Doe 2, John Doe 3, John Doe 4, Human Rights Defense Center, Cliff McElvogue, Prison Legal News, Tony Riley. Response to Motion due by 1/31/2011 (Attachments: # 1 Exhibit A- Consent Amended Scheduling Order)Proposed order is being emailed to chambers with copy to opposing counsel(Dunn, Susan) (Entered: 01/14/2011)

1 Exhibit A- Consent Amended Scheduling Order

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AMENDED SCHEDULING ORDER( Amended Pleadings due by 3/7/2011, Plaintiffs ID of Expert Witness due by 4/4/2011, Defendants ID of Expert Witnesses Due by 5/4/2011, Records Custodian Affidavit due by 5/4/2011, Discovery due by 7/6/2011, Motion in Limine due by 10/11/2011, Motions due by 7/20/2011, Rule 26(a)(3) Disclosures due by 9/28/2011, Pretrial Briefs due by 10/28/2011, Jury Selection Deadline 11/2/2011, ADR Statement due by 8/14/2011, Mediation Due by 9/14/2011, Service of Complaint due by 4/4/2011) Motions terminated: granting 20 Consent MOTION to Amend/Correct 19 Scheduling Order, filed by Tony Riley, John Doe 2, John Doe 4, Cliff McElvogue, H Wayne DeWitt, Human Rights Defense Center, Prison Legal News, John Doe 1, John Doe 3.. Signed by Honorable Margaret B Seymour on 1/18/2011. (asni, ) (Entered: 01/19/2011)

MOTION to Compel by Human Rights Defense Center, Prison Legal News. Response to Motion due by 3/21/2011 (Attachments: # 1 Memo in Support, # 2 Exhibit Declaration of Shapiro, # 3 Certificate of Service, # 4 Exhibit A- Pls 1st Set of RTA, # 5 Exhibit B- Pls 1st Set of RTP, # 6 Exhibit C- Pls 1st Set of ROGs, # 7 Exhibit D- Def's Resp to 1st Set of RTA, # 8 Exhibit E- Def's Resp to 1st Set of ROGs, # 9 Exhibit F- Def's Resp to 1st Set of RTP, # 10 Exhibit G- Ltr from Shapiro to Senn, # 11 Exhibit H- Email from Shapiro to Senn, # 12 Exhibit I- Email from Senn to Shapiro, # 13 Exhibit J- Email from Shapiro to Senn, # 14 Exhibit K- Email from Senn to Shapiro, # 15 Exhibit L- Detainee Grievance, # 16 Exhibit M- News Articles, # 17 Exhibit N- Website Printout, # 18 Exhibit O- Email from Senn to Shapiro, # 19 Exhibit Unpublished Cases)Proposed order is being emailed to chambers with copy to opposing counsel(Dunn, Susan) (Entered: 03/03/2011)

1 Memo in Support

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2 Exhibit Declaration of Shapiro

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3 Certificate of Service

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4 Exhibit A- Pls 1st Set of RTA

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5 Exhibit B- Pls 1st Set of RTP

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6 Exhibit C- Pls 1st Set of ROGs

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7 Exhibit D- Def's Resp to 1st Set of RTA

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8 Exhibit E- Def's Resp to 1st Set of ROGs

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9 Exhibit F- Def's Resp to 1st Set of RTP

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10 Exhibit G- Ltr from Shapiro to Senn

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11 Exhibit H- Email from Shapiro to Senn

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12 Exhibit I- Email from Senn to Shapiro

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13 Exhibit J- Email from Shapiro to Senn

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14 Exhibit K- Email from Senn to Shapiro

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15 Exhibit L- Detainee Grievance

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16 Exhibit M- News Articles

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17 Exhibit N- Website Printout

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18 Exhibit O- Email from Senn to Shapiro

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19 Exhibit Unpublished Cases

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Local Rule 26.01 Answers to Interrogatories by H Wayne DeWitt, John Doe 1, John Doe 2, John Doe 3, John Doe 4, Cliff McElvogue, Tony Riley.(Senn, Sandra) (Entered: 03/09/2011)

NOTICE of Request for Protection from Court Appearance by Sandra Jane Senn for March 28, 2011 - April 5, 2011 and April 18 - 22, 2011 (Senn, Sandra) (Entered: 03/14/2011)

REPLY by Prison Legal News to 25 Notice of Request for Protection from Court Appearance. (Dunn, Susan) (Entered: 03/15/2011)

MOTION to Amend/Correct 21 Scheduling Order,by Prison Legal News, Human Rights Defense Center. Response to Motion due by 4/7/2011 (Attachments: # 1 Exhibit A -- Current Scheduling Order)Proposed order is being emailed to chambers with copy to opposing counsel(Dunn, Susan) Modified to add filer listed on document on 3/21/2011 (asni, ). (Entered: 03/21/2011)

1 Exhibit A -- Current Scheduling Order

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RESPONSE in Opposition re 23 MOTION to Compel Response filed by H Wayne DeWitt, John Doe 1, John Doe 2, John Doe 3, John Doe 4, Cliff McElvogue, Tony Riley.Reply to Response to Motion due by 3/31/2011 (Attachments: # 1 Memo in Support, # 2 Table of Contents, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8Exhibit F)(Senn, Sandra) (Entered: 03/21/2011)

1 Memo in Support

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2 Table of Contents

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3 Exhibit A

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4 Exhibit B

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5 Exhibit C

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6 Exhibit D

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7 Exhibit E

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8 Exhibit F

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AMENDED SCHEDULING ORDER( Plaintiffs ID of Expert Witness due by 6/3/2011, Defendants ID of Expert Witnesses Due by 7/5/2011, Records Custodian Affidavit due by 7/5/2011, Discovery due by 9/6/2011, Motion in Limine due by 12/12/2011, Motions due by 9/19/2011, Rule 26(a)(3) Disclosures due by 11/28/2011, Pretrial Briefs due by 12/29/2011, Jury Selection Deadline 1/3/2012, ADR Statement due by 10/14/2011, Mediation Due by 11/14/2011,) Motions terminated: granting 27 Consent MOTION to Amend/Correct 21 Scheduling Order. Signed by Honorable Margaret B Seymour on 3/21/2011. (asni, ) (Entered: 03/22/2011)

REPLY to Response to Motion re 23 MOTION to Compel Response filed by Human Rights Defense Center, Prison Legal News. (Attachments: # 1 Affidavit Shapiro Declaration, # 2 Exhibit A--Incident Reports, # 3 Exhibit B--Commissary Forms, # 4 Exhibit C--HFDC 701, # 5 Exhibit D--Affidavit, # 6 Exhibit E--Letter, # 7 Exhibit F--Bates stamped documents, # 8 Affidavit Bair Declaration, # 9 Exhibit A--Curriculum Vitae, # 10 Addendum Unpublished Cases)(Dunn, Susan) (Entered: 03/29/2011)

MOTION for Extension of deadline for Motion To Compel by Human Rights Defense Center, Prison Legal News. Response to Motion due by 4/25/2011 Proposed order is being emailed to chambers with copy to opposing counsel(Dunn, Susan) (Entered: 04/08/2011)

TEXT ORDER granting 31 Motion for Extension of Time; Plaintiffs deadline for moving to compel as to Plaintiffs Second Set of Requests for Production and Third Set of Interrogatories is hereby extended to May 12, 2011. Signed by Honorable Margaret B Seymour on 4/8/2011.(asni, ) (Entered: 04/08/2011)

NOTICE of Hearing on Motion 23 MOTION to Compel : Motion Hearing set for 4/26/2011 03:00 PM before Honorable Margaret B Seymour. This hearing will be conducted via telephone. Plaintiff shall initiate the call and have all parties on the line prior to contacting the Court at 803-253-3421.(asni, ) (Entered: 04/11/2011)

NOTICE of Appearance by Barbara Murcier Bowens on behalf of United States of America (Bowens, Barbara) (Entered: 04/12/2011)

MOTION to Intervene by United States of America. Response to Motion due by 4/29/2011 (Attachments: # 1 Memo in Support, # 2 Complaint in Intervention)No proposed order(Bowens, Barbara) (Entered: 04/12/2011)

MOTION to Appear Pro Hac Vice by Michael J. Songer by United States of America. Response to Motion due by 5/2/2011 (Attachments: # 1 Affidavit Application/Affidavit for Pro Hac Admission, # 2 Addendum Certificate of Good Standing)Proposed order is being emailed to chambers with copy to opposing counsel(Bowens, Barbara) (Entered: 04/13/2011)

NOTICE of Appearance by William Norman Nettles on behalf of United States of America (Nettles, William) (Entered: 04/14/2011)

TEXT ORDER granting 36 Motion to Appear Pro Hac Vice Signed by Honorable Margaret B Seymour on 4/14/2011.(asni, ) (Entered: 04/14/2011)

NOTICE of Appearance by Robin Lilley Jackson on behalf of H Wayne DeWitt, John Doe 1, John Doe 2, John Doe 3, John Doe 4, Cliff McElvogue, Tony Riley (Jackson, Robin) (Entered: 04/19/2011)

Consent MOTION for Extension of Time of deadline for Motion to Compel by Human Rights Defense Center, Prison Legal News. Response to Motion due by 5/9/2011 Proposed order is being emailed to chambers with copy to opposing counsel(Dunn, Susan) (Entered: 04/21/2011)

TEXT ORDER granting 40 Motion for Extension of deadline for Motion to Compel. Signed by Honorable Margaret B Seymour on 4/21/2011.(asni, ) (Entered: 04/22/2011)

RESPONSE to Motion re 35 MOTION to Intervene Response filed by Human Rights Defense Center, Prison Legal News.Reply to Response to Motion due by 5/5/2011 (Dunn, Susan) (Entered: 04/25/2011)

Minute Entry. Proceedings held before Honorable Margaret B Seymour: granting 23 Motion to Compel; Motion Hearing held on 4/26/2011 re 23 MOTION to Compel filed by Human Rights Defense Center, Prison Legal News. Court Reporter Kathleen Richardson. (mdea ) (Entered: 04/26/2011)

RESPONSE in Support re 35 MOTION to Intervene Response filed by H Wayne DeWitt, John Doe 1, John Doe 2, John Doe 3, John Doe 4, Cliff McElvogue, Tony Riley. (Attachments: # 1 Certificate of Service)(Jackson, Robin) (Entered: 05/02/2011)

TEXT ORDER granting 35 Motion to Intervene Signed by Honorable Margaret B Seymour on 5/2/2011.(asni, ) (Entered: 05/03/2011)

Intervenor COMPLAINT Pursuant to 42 U.S.C. 14141 and 42 U.S.C. 2000cc. (Civil Rights), filed by United States of America. (Bowens, Barbara) (Entered: 05/03/2011)

MOTION for Preliminary Injunction by Human Rights Defense Center, Prison Legal News. Response to Motion due by 5/23/2011 (Attachments: # 1 Memo in Support, # 2 Affidavit (Declaration of Paul Wright), # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8 Exhibit F, # 9 Exhibit G, # 10 Exhibit H, # 11 Exhibit I, # 12 Exhibit J, # 13 Exhibit K, # 14 Exhibit L, # 15 Affidavit (Declaration of Toni Bair), # 16 Exhibit A, # 17 Exhibit B, # 18 Exhibit C, # 19 Exhibit D, # 20 Affidavit (Declaration of Aglaia Ovtchinnikova), # 21 Exhibit A, # 22 Exhibit B, # 23 Affidavit (Declaration of David Shapiro), # 24 Exhibit A, # 25 Exhibit B, # 26 Exhibit C, # 27 Exhibit D, # 28 Exhibit E, # 29 Exhibit F, # 30 Exhibit G, # 31 Exhibit H, # 32 Exhibit I, # 33 Exhibit J, # 34 Exhibit K, # 35 Exhibit L, # 36 Exhibit M, # 37 Exhibit N, # 38 Exhibit O, # 39 Exhibit P, # 40 Exhibit Q, # 41 Exhibit R, # 42 Exhibit S, # 43 Exhibit T, # 44 Exhibit U, # 45 Exhibit V, # 46 Exhibit W, # 47 Affidavit (Declaration of Emery), # 48 Affidavit (Declaration of Glidden), # 49 Affidavit (Declaration of Howard), # 50 Affidavit (Declaration of Jackson), # 51 Affidavit (Declaration of Kerce), # 52 Affidavit (Declaration of Mack), # 53 Affidavit (Declaration of McBeth), # 54 Affidavit (Declaration of Singleton), # 55 Affidavit (Declaration of Webster), # 56 Addendum (Unpublished Cases))Proposed order is being emailed to chambers with copy to opposing counsel(Dunn, Susan) (Entered: 05/04/2011)

1 Memo in Support

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2 Affidavit (Declaration of Paul Wright)

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3 Exhibit A

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4 Exhibit B

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5 Exhibit C

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6 Exhibit D

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7 Exhibit E

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8 Exhibit F

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9 Exhibit G

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10 Exhibit H

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11 Exhibit I

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12 Exhibit J

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13 Exhibit K

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14 Exhibit L

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15 Affidavit (Declaration of Toni Bair)

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16 Exhibit A

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17 Exhibit B

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18 Exhibit C

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19 Exhibit D

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20 Affidavit (Declaration of Aglaia Ovtchinnikova)

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21 Exhibit A

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22 Exhibit B

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23 Affidavit (Declaration of David Shapiro)

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24 Exhibit A

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25 Exhibit B

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26 Exhibit C

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27 Exhibit D

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28 Exhibit E

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29 Exhibit F

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30 Exhibit G

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31 Exhibit H

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32 Exhibit I

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33 Exhibit J

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34 Exhibit K

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35 Exhibit L

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36 Exhibit M

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37 Exhibit N

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38 Exhibit O

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39 Exhibit P

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40 Exhibit Q

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41 Exhibit R

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42 Exhibit S

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43 Exhibit T

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44 Exhibit U

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45 Exhibit V

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46 Exhibit W

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47 Affidavit (Declaration of Emery)

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48 Affidavit (Declaration of Glidden)

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49 Affidavit (Declaration of Howard)

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50 Affidavit (Declaration of Jackson)

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51 Affidavit (Declaration of Kerce)

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52 Affidavit (Declaration of Mack)

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53 Affidavit (Declaration of McBeth)

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54 Affidavit (Declaration of Singleton)

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55 Affidavit (Declaration of Webster)

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56 Addendum (Unpublished Cases)

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MOTION to Appear Pro Hac Vice by Amin Aminfar by United States of America. Response to Motion due by 5/23/2011 (Attachments: # 1 Application/Affidavit for Pro Hac Vice Admission)Proposed order is being emailed to chambers with copy to opposing counsel(Bowens, Barbara) (Entered: 05/05/2011)

TEXT ORDER granting 48 Motion to Appear Pro Hac Vice Signed by Honorable Margaret B Seymour on 5/5/2011.(asni, ) (Entered: 05/05/2011)

AFFIDAVIT in Opposition re 47 MOTION for Preliminary Injunction Affidavit of Sandra J. Senn. (Attachments: # 1 Exhibit Returned mail exhibit)(Jackson, Robin) (Main Document 50 replaced on 5/10/2011) (asni, ). (Entered: 05/05/2011)

AFFIDAVIT in Opposition re 47 MOTION for Preliminary Injunction Affidavit of Patrick Garrett. (Attachments: # 1 Exhibit Invoices)(Jackson, Robin) (Main Document 51 replaced on 5/6/2011) (asni, ). (Entered: 05/05/2011)

1 Exhibit Invoices

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AFFIDAVIT in Opposition re 47 MOTION for Preliminary Injunction Affidavit of Kris Jacumin. (Attachments: # 1 Exhibit Tattoo instrument photos)(Jackson, Robin) (Main Document 52 replaced on 5/6/2011) (asni, ). (Entered: 05/05/2011)

AFFIDAVIT in Opposition re 47 MOTION for Preliminary Injunction Affidavit of David Taschner. (Attachments: # 1 Exhibit 2010 work orders, # 2 Exhibit 2011 work orders)(Jackson, Robin) (Main Document 53 replaced on 5/6/2011) (asni, ). (Entered: 05/05/2011)

NOTICE OF FILING OF OFFICIAL TRANSCRIPT of teleconference hearing held on April 26, 2011, before Judge Margaret B. Seymour. Court Reporter/Transcriber Kathleen Richardson, Telephone number/E-mail (803)779-6709 or Kathleen_Richardson@scd.uscourts.gov. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Parties have 7 calendar days from the filing of the transcript to file with the court a Notice of Intent to Request Redaction.. Redaction Request due 5/27/2011. Redacted Transcript Deadline set for 6/6/2011. Release of Transcript Restriction set for 8/4/2011. (kari, ) (Entered: 05/06/2011)

AFFIDAVIT in Opposition re 47 MOTION for Preliminary Injunction Affidavit of Garrett Harvey. (Attachments: # 1 Exhibit Meridian)(Jackson, Robin) (Entered: 05/06/2011)

NOTICE of Hearing on Motion 47 MOTION for Preliminary Injunction : Motion Hearing set for 5/16/2011 02:00 PM in Columbia # 5, Matthew J. Perry, Court House, 901 Richland St, Columbia before Honorable Margaret B Seymour. (asni, ) (Entered: 05/06/2011)

NOTICE OF RESCHEDULED HEARING Motion Hearing set for 5/16/2011 02:00 PM in Columbia # 5, Matthew J. Perry, Court House, 901 Richland St, Columbia before Honorable Margaret B Seymour. cancelled and rescheduled to: Motion Hearing set for 6/14/2011 10:30 AM in Columbia # 5, Matthew J. Perry, Court House, 901 Richland St, Columbia before Honorable Margaret B Seymour. (asni, ) (Entered: 05/09/2011)

Second MOTION to Compel Discovery by Human Rights Defense Center, Prison Legal News. Response to Motion due by 5/31/2011 (Attachments: # 1 Memo in Support, # 2 Affidavit (Declaration of David Shapiro), # 3 Exhibit A (Plaintiffs' Second Set of Requests for Production), # 4 Exhibit B (Plaintiffs' Third Set of Interrogatories), # 5 Exhibit C (Defendants' Response to Plaintiffs' Second Set of Requests for Production), # 6 Exhibit D (Defendants' Response to Plaintiffs' Third Set of Interrogatories), # 7 Exhibit E (March 29, 2011 Letter), # 8 Exhibit F (April 5, 2011 Email), # 9 Exhibit G (Defendants' Supplemental Response to Plaintiffs' Second Set of Requests for Production), # 10 Exhibit H (Defendants' Supplemental Response to Plaintiffs' Third Set of Interrogatories), # 11 Exhibit I (Plaintiffs' Second Set of Requests for Admission), # 12 Exhibit J (Plainitffs' Third Set of Requests for Production), # 13 Exhibit K (Defendants' Response to Plaintiffs' Second Set of Requests for Admission), # 14 Exhibit L (Defendants' Response to Plaintiffs' Third Set of Requests for Production), # 15 Exhibit M (April 18, 2011 Letter), # 16 Exhibit N (April 21, 2011 Email), # 17 Exhibit O (Defendants' Supplemental Response to Plaintiffs' Third Set of Requests for Production), # 18 Exhibit P (April 7, 2011 Email Correspondence), # 19 Exhibit Q (Excerpts from April 26, 2011 Hearing), # 20 Exhibit R (Maintenance Records Involving Locks), # 21 Exhibit S (Maintenance Records Involving Intercoms), # 22 Addendum (Unpublished Case Cited in Memorandum))Proposed order is being emailed to chambers with copy to opposing counsel(Dunn, Susan) (Entered: 05/11/2011)

RESPONSE in Support re 47 MOTION for Preliminary Injunction Response filed by United States of America. (Attachments: # 1 Exhibit A, Declaration of Michael Songer, # 2 Exhibit B, Program Statement 5266.10, # 3 Exhibit C, Program Statement 5800.16, # 4 Exhibit D, Declaration of John Clark)(Bowens, Barbara) (Entered: 05/23/2011)

First MOTION for Extension of Time to File Response/Reply as to 47 MOTION for Preliminary Injunction by H Wayne DeWitt, John Doe 1, John Doe 2, John Doe 3, John Doe 4, Cliff McElvogue, Tony Riley. Response to Motion due by 6/9/2011 Proposed order is being emailed to chambers with copy to opposing counsel(Senn, Sandra) (Entered: 05/23/2011)

TEXT ORDER granting 60 Motion for Extension of Time to File Response/Reply re 47 MOTION for Preliminary Injunction Response to Motion due by 5/27/2011 Signed by Honorable Margaret B Seymour on 5/24/2011.(asni, ) (Entered: 05/24/2011)

ANSWER to 46 Intervenor Complaint by H Wayne DeWitt, John Doe 1, John Doe 2, John Doe 3, John Doe 4, Cliff McElvogue, Tony Riley.(Senn, Sandra) (Entered: 05/24/2011)

Consent MOTION for Extension of Time for Expert Report by Human Rights Defense Center, Prison Legal News. Response to Motion due by 6/13/2011 (Attachments: # 1 Exhibit A -- Current Scheduling Order)Proposed order is being emailed to chambers with copy to opposing counsel(Dunn, Susan) (Entered: 05/27/2011)

RESPONSE in Opposition re 47 MOTION for Preliminary Injunction Response filed by H Wayne DeWitt, John Doe 1, John Doe 2, John Doe 3, John Doe 4, Cliff McElvogue, Tony Riley.Reply to Response to Motion due by 6/6/2011 (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Senn, Sandra) additional attachments entries 65 66 67 68 69 70 71 72 on 5/31/2011 (asni, ). (Entered: 05/27/2011)

Additional Attachments to Main Document 64 Response in Opposition to Motion, Exhibit C. (Senn, Sandra) (Main Document 65 replaced on 5/31/2011) (asni, ). Modified at the request of the attorney to replace main document with correct exhibit C on 5/31/2011 (asni, ). (Main Document 65 replaced on 6/1/2011) (asni, ). (Entered: 05/27/2011)

Additional Attachments to Main Document 64 Response in Opposition to Motion, Exhibit D. (Senn, Sandra) (Entered: 05/27/2011)

Additional Attachments to Main Document 64 Response in Opposition to Motion, Exhibit E. (Attachments: # 1 Exhibit F)(Senn, Sandra) (Entered: 05/27/2011)

Additional Attachments to Main Document 64 Response in Opposition to Motion, Exhibit G. (Attachments: # 1 Exhibit H, # 2 Exhibit I)(Senn, Sandra) (Entered: 05/27/2011)

1 Exhibit H

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2 Exhibit I

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Additional Attachments to Main Document 64 Response in Opposition to Motion, Exhibit J. (Attachments: # 1 Exhibit K, # 2 Exhibit L)(Senn, Sandra) (Attachment 2 replaced on 5/31/2011) (asni, ). Modified at the request of the attorney to replace attachment 2 with correct exhibit L on 5/31/2011 (asni, ). (Attachment 2 replaced on 6/1/2011) (asni, ). (Entered: 05/27/2011)

Additional Attachments to Main Document 64 Response in Opposition to Motion, Exhibit M. (Attachments: # 1 Exhibit N, # 2 Exhibit O, # 3 Exhibit P)(Senn, Sandra) (Entered: 05/27/2011)

Additional Attachments to Main Document 64 Response in Opposition to Motion, Exhibit Q. (Senn, Sandra) (Entered: 05/27/2011)

Additional Attachments to Main Document 64 Response in Opposition to Motion, Unpublished Case 1. (Attachments: # 1 Unpublished Case 2, # 2 Unpublished Case 3, # 3 Unpublished Case 4, # 4 Unpublished Case 5, # 5 Unpublished Case 6)(Senn, Sandra) (Entered: 05/27/2011)

1 Unpublished Case 2

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2 Unpublished Case 3

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3 Unpublished Case 4

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4 Unpublished Case 5

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5 Unpublished Case 6

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RESPONSE in Opposition re 58 Second MOTION to Compel Discovery Response filed by H Wayne DeWitt, John Doe 1, John Doe 2, John Doe 3, John Doe 4, Cliff McElvogue, Tony Riley.Reply to Response to Motion due by 6/13/2011 (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit)(Jackson, Robin) Modified to correct filing date on 6/1/2011 (asni, ). (Entered: 06/01/2011)

TEXT ORDER granting 63 Consent MOTION for Extension of deadline for report by expert witness ( Plaintiffs ID of Expert Witness due by 6/9/2011,),. Signed by Honorable Margaret B Seymour on 6/1/2011. (asni, ) (Entered: 06/01/2011)

DELETION OF DOCKET ENTRY NUMBER 73 Reason: response to request for production is part of discovery and only served on opposing counsel not filed with the court. Attorney was notified by email he can file a response in opposition to a motion to compel but the document must reflect this event type. (asni, ) (Entered: 06/01/2011)

CONTESTED MOTION to Amend/Correct 29 Amend Scheduling Order by United States of America. Response to Motion due by 6/20/2011 Proposed order is being emailed to chambers with copy to opposing counsel(Bowens, Barbara) (Entered: 06/02/2011)

AMENDED NOTICE of Hearing on Motion 58 Second MOTION to Compel 47 MOTION for Preliminary Injunction : Motion Hearing set for 6/14/2011 10:30 AM in Columbia # 5, Matthew J. Perry, Court House, 901 Richland St, Columbia before Honorable Margaret B Seymour. "Should any party desire to present witnesses at the preliminary injunction hearing, the party should disclose such witnesses to opposing counsel no later than 5:00 PM on Tuesday, June 7, 2011."(asni, ) (Entered: 06/02/2011)

MOTION for Extension of Time for Response to Discovery Requests by Human Rights Defense Center, Prison Legal News. Response to Motion due by 6/20/2011 Proposed order is being emailed to chambers with copy to opposing counsel(Dunn, Susan) (Entered: 06/02/2011)

MOTION for Leave to File Excess Pages (Reply Brief in Support of Motion for Preliminary Injunction) by Human Rights Defense Center, Prison Legal News. Response to Motion due by 6/23/2011 Proposed order is being emailed to chambers with copy to opposing counsel(Dunn, Susan) (Entered: 06/06/2011)

DELETION OF DOCKET ENTRY NUMBER 82 Reason: Judge must rule on motion to file excess pages before the document can be filed in ECF. (asni, ) (Entered: 06/07/2011)

TEXT ORDER granting 81 Motion for Leave to File Excess Pages Signed by Honorable Margaret B Seymour on 6/7/2011.(asni, ) (Entered: 06/07/2011)

REPLY to Response to Motion re 47 MOTION for Preliminary Injunction Response filed by Human Rights Defense Center, Prison Legal News. (Attachments: # 1 Affidavit (Supplemental Declaration of Toni Bair), # 2 Exhibit 1 to Supplemental Bair Declaration, # 3 Affidavit (Supplemental Declaration of Paul Wright), # 4 Affidavit (Supplemental Declaration of David Shapiro), # 5 Exhibit A to Supplemental Shapiro Declaration, # 6 Exhibit B to Supplemental Shapiro Declaration, # 7 Exhibit C to Supplemental Shapiro Declaration, # 8 Exhibit D to Supplemental Shapiro Declaration, # 9 Exhibit E to Supplemental Shapiro Declaration, # 10 Exhibit F to Supplemental Shapiro Declaration, # 11 Exhibit G to Supplemental Shapiro Declaration, # 12 Exhibit H to Supplemental Shapiro Declaration, # 13 Exhibit I to Supplemental Shapiro Declaration, # 14 Exhibit J to Supplemental Shapiro Declaration, # 15 Exhibit K to Supplemental Shapiro Declaration, # 16 Exhibit L to Supplemental Shapiro Declaration, # 17 Exhibit M to Supplemental Shapiro Declaration, # 18 Exhibit N to Supplemental Shapiro Declaration, # 19 Exhibit O to Supplemental Shapiro Declaration, # 20 Affidavit (Declaration of Joanna Wright))(Dunn, Susan) (Attachment 17 replaced on 6/9/2011) (mdea, ). (Entered: 06/07/2011)

MOTION for Protective Order by United States of America. Response to Motion due by 6/27/2011 (Attachments: # 1 Attachment #1, Declaration of Michael J. Songer, # 2 Exhibit A, June 7, 2011 Letter)No proposed order(Bowens, Barbara) (Entered: 06/08/2011)

TEXT ORDER: With respect to the motion for preliminary injunction set for a hearing on Tuesday, June 14, 2011, the parties are directed to be prepared to address their arguments within the framework of Winter v. Natural Resources Defense Council, 555 U.S. 7 (2008). See Real Truth About Obama, Inc. v. FEC, 575 F.3d 342 (4th Cir. 2009), vacated in part on other grounds, 130 S. Ct. 2371 (2010). Directed by Honorable Margaret B Seymour on 06/10/2011. (bshr, ) (Entered: 06/10/2011)

REPLY to Response to Motion re 58 Second MOTION to Compel Discovery Response filed by Human Rights Defense Center, Prison Legal News. (Attachments: # 1 Affidavit (Supplemental Declaration of David Shapiro), # 2 Exhibit A to Supplemental Shapiro Declaration, # 3 Exhibit B to Supplemental Shapiro Declaration, # 4 Exhibit C to Supplemental Shapiro Declaration)(Dunn, Susan) (Entered: 06/10/2011)

RESPONSE in Opposition re 80 MOTION for Extension of Time for Response to Discovery Requests Response filed by H Wayne DeWitt, John Doe 1, John Doe 2, John Doe 3, John Doe 4, Cliff McElvogue, Tony Riley.Reply to Response to Motion due by 6/20/2011 (Jackson, Robin) (Entered: 06/10/2011)

MOTION to Appear Pro Hac Vice by Timothy D. Mygatt by United States of America. Response to Motion due by 6/27/2011 (Attachments: # 1 Application/Affidavit for Pro Hac Vice Admission)Proposed order is being emailed to chambers with copy to opposing counsel(Bowens, Barbara) (Entered: 06/10/2011)

TEXT ORDER granting 89 Motion to Appear Pro Hac Vice Signed by Honorable Margaret B Seymour on 6/13/2011.(asni, ) (Entered: 06/14/2011)

Minute Entry. Proceedings held before Honorable Margaret B Seymour: granting 58 Motion to Compel as to remaining unresolved issues; finding as moot 80 Motion for Extension of Time; granting 85 Motion for Protective Order; Motion Hearing held on 6/14/2011 re 58 Second MOTION to Compel Discovery filed by Human Rights Defense Center, Prison Legal News, 85 MOTION for Protective Order filed by United States of America, 47 MOTION for Preliminary Injunction filed by Human Rights Defense Center, Prison Legal News, 80 MOTION for Extension of Time for Responses to Discovery Requests filed by Human Rights Defense Center, Prison Legal News. Court takes 47 MOTION for Preliminary Injunction under advisement, written order forthcoming. Court Reporter Dan Mayo. (mdea ) (Entered: 06/14/2011)

NOTICE of Request for Protection from Court Appearance by Sandra Jane Senn for July 20 - 28, 2011 (Senn, Sandra) (Entered: 06/15/2011)

NOTICE of Request for Protection from Court Appearance by Robin Lilley Jackson for July 25 - August 1, 2011 (Jackson, Robin) (Entered: 06/15/2011)

MOTION for Leave to File Supplemental Declaration of Paul Wright by Prison Legal News. Response to Motion due by 7/5/2011 No proposed order(Dunn, Susan) (Entered: 06/20/2011)

DELETION OF DOCKET ENTRY NUMBER 94 Reason: 95 Corrected Filing Document Number 95 Modified filing date to that of original filing: 6/17/2011 Response due date modified to that of original filing: 7/5/2011 (asni, ) (Entered: 06/20/2011)

RESPONSE in Opposition re 78 MOTION to Amend/Correct United States' Contested Motion to Amend the Scheduling Order Response filed by H Wayne DeWitt, John Doe 1, John Doe 2, John Doe 3, John Doe 4, Cliff McElvogue, Tony Riley.Reply to Response to Motion due by 6/30/2011 (Attachments: # 1 Affidavit)(Senn, Sandra) (Entered: 06/20/2011)

1 Affidavit

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REPLY to Response to Motion re 78 MOTION to Amend/Correct the Scheduling Order Response filed by United States of America. (Bowens, Barbara) (Entered: 06/23/2011)

MOTION for Protective Order regarding deposition of Toni V Bair by Human Rights Defense Center, Prison Legal News. Response to Motion due by 7/11/2011 (Attachments: # 1 Exhibit A -- Deposition Transcript Excerpts)Proposed order is being emailed to chambers with copy to opposing counsel(Dunn, Susan) (Entered: 06/24/2011)

1 Exhibit A -- Deposition Transcript Excerpts

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MOTION for Protective Order Regarding Deposition of Paul Wright by Human Rights Defense Center, Prison Legal News. Response to Motion due by 7/14/2011 (Attachments: # 1 Exhibit A (Excerpt from Draft Transcript of Deposition of Toni Bair), # 2 Addendum -- Unpublished cases)Proposed order is being emailed to chambers with copy to opposing counsel(Dunn, Susan) (Entered: 06/27/2011)

1 Exhibit A (Excerpt from Draft Transcript of Deposition of Toni Bair)

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2 Addendum -- Unpublished cases

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Consent MOTION for Extension of Time for Motions To Compel by Human Rights Defense Center, Prison Legal News. Response to Motion due by 7/18/2011 Proposed order is being emailed to chambers with copy to opposing counsel(Dunn, Susan) (Entered: 06/30/2011)

Consent MOTION for Extension of Time for Motion to Compel by H Wayne DeWitt, John Doe 1, John Doe 2, John Doe 3, John Doe 4, Cliff McElvogue, Tony Riley. Response to Motion due by 7/18/2011 Proposed order is being emailed to chambers with copy to opposing counsel(Jackson, Robin) (Entered: 06/30/2011)

RESPONSE in Opposition re 101 MOTION for Protective Order Regarding Deposition of Paul Wright Response filed by H Wayne DeWitt, John Doe 1, John Doe 2, John Doe 3, John Doe 4, Cliff McElvogue, Tony Riley.Reply to Response to Motion due by 7/11/2011 (Attachments: # 1 Exhibit A- News Article)(Senn, Sandra) (Entered: 06/30/2011)

1 Exhibit A- News Article

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TEXT ORDER granting 78 Motion to Amend/Correct Scheduling Order Signed by Honorable Margaret B Seymour on 6/30/2011.(asni, ) (Entered: 07/01/2011)

AMENDED SCHEDULING ORDER Plaintiffs ID of Expert Witness due by 9/2/2011, Defendants ID of Expert Witnesses Due by 10/5/2011, Records Custodian Affidavit due by 10/5/2011, Discovery due by 12/6/2011, Motion in Limine due by 3/12/2012, Motions due by 12/19/2011, Rule 26(a)(3) Disclosures due by 2/28/2012, Pretrial Briefs due by 4/4/2012, Jury Selection Deadline 4/9/2012, ADR Statement due by 1/14/2012, Mediation Due by 2/14/2012,. Signed by Honorable Margaret B Seymour on 6/30/2011. (asni, ) (Entered: 07/01/2011)

TEXT ORDER granting 102 Motion for Extension of Deadlines for plaintiff's motions to compel ; granting 103 Motion for Extension of Deadlines for defendant's motions to compel. Signed by Honorable Margaret B Seymour on 6/30/2011.(asni, ) (Entered: 07/01/2011)

REPLY to Response to Motion re 101 MOTION for Protective Order Regarding Deposition of Paul Wright Response filed by Human Rights Defense Center, Prison Legal News. (Dunn, Susan) (Entered: 07/01/2011)

RESPONSE in Opposition re 95 MOTION for Leave to File Supplemental Declaration of Paul Wright Response filed by H Wayne DeWitt, John Doe 1, John Doe 2, John Doe 3, John Doe 4, Cliff McElvogue, Tony Riley.Reply to Response to Motion due by 7/18/2011 (Senn, Sandra) (Entered: 07/08/2011)

RESPONSE in Opposition re 100 MOTION for Protective Order Response filed by H Wayne DeWitt, John Doe 1, John Doe 2, John Doe 3, John Doe 4, Cliff McElvogue, Tony Riley.Reply to Response to Motion due by 7/21/2011 (Attachments: # 1 Memo in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K)(Senn, Sandra) (Entered: 07/11/2011)

1 Memo in Support

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2 Exhibit A

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3 Exhibit B

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4 Exhibit C

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5 Exhibit D

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6 Exhibit E

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7 Exhibit F

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8 Exhibit G

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9 Exhibit H

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10 Exhibit I

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11 Exhibit J

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12 Exhibit K

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REPLY to Response to Motion re 95 MOTION for Leave to File Supplemental Declaration of Paul Wright Response filed by Human Rights Defense Center, Prison Legal News. (Dunn, Susan) (Entered: 07/13/2011)