Case: Does v. Snyder

2:12-cv-11194 | U.S. District Court for the Eastern District of Michigan

Filed Date: March 6, 2012

Closed Date: 2018

Clearinghouse coding complete

Case Summary

On March 6, 2012, a group of individuals convicted of sexual offenses prior to 2011 filed this lawsuit in the Eastern District of Michigan. The plaintiffs sued the Governor of Michigan and the director of the Michigan State Police. The plaintiffs alleged that Michigan's 2011 Sex Offender Registration Act (SORA) could not be applied to them retroactively. Under SORA, one of the plaintiffs was required to register as a sex offender even though he was not originally convicted of a sex offense. Ano…

On March 6, 2012, a group of individuals convicted of sexual offenses prior to 2011 filed this lawsuit in the Eastern District of Michigan. The plaintiffs sued the Governor of Michigan and the director of the Michigan State Police. The plaintiffs alleged that Michigan's 2011 Sex Offender Registration Act (SORA) could not be applied to them retroactively. Under SORA, one of the plaintiffs was required to register as a sex offender even though he was not originally convicted of a sex offense. Another plaintiff was required to register on a public registry even though he was promised privacy in his plea agreement. And two of the plaintiffs were required to remain on a public registry for life instead of 25 years. Represented by the ACLU of Michigan, Michigan Clinical Law Program, and private counsel, the plaintiffs sought declaratory and injunctive relief barring SORA's retroactive application. The plaintiffs claimed that SORA violated the prohibition on ex post facto laws, interfered with their fundamental rights to work, travel, speak, and raise their children without being narrowly tailored to a compelling state interest, violated the Due Process Clause, and was void for being too vague. The case was assigned to Judge Robert H. Cleland and referred to Magistrate Judge David R. Grand.

On April 24, 2012, the defendants moved to dismiss the complaint for failure to state a claim. Nearly a year later, on March 18, 2013, the defendants’ motion was granted in part and denied in part. The court granted the defendants’ motion on the ex post facto claim, finding that SORA was a regulatory action and not a criminal statute. The court also granted the defendants’ motion on the claims that SORA interfered with the plaintiffs’ rights to travel and work. The court concluded that the extra procedures imposed by SORA, such as reporting temporary residences or prohibiting loitering in a school zone, did not significantly burden the plaintiffs’ ability to travel interstate or intrastate. Similarly, the court found that SORA did not bar the plaintiffs from electing a particular career. The Act’s only restriction on employment regarded working in a school zone, and the court found that provision to be narrowly tailored to serve the legitimate interests of the State. The court also granted the defendants’ motion to dismiss for claims that applying SORA retroactively was unconstitutional for the plaintiff who were originally convicted of a non-sexual offense and the plaintiff who was offered a plea agreement that stipulated they would not have to register on a public registry. Applying SORA retroactively to these plaintiffs had a legitimate legislative purpose.

However, the court denied the defendants’ motion to dismiss the claim that SORA interfered with the plaintiffs’ rights to raise their children. The court found that the prohibition against any loitering in a school zone may have impeded on the plaintiffs’ ability to raise their children and participate in their education. The court also denied the motion to dismiss the claims from plaintiffs whose registration period on a public registry was extended from twenty-five years to life. The court denied the motion since it was unclear from the complaint whether the defendants had a rational legislative purpose for requiring lifetime registration. The court denied the motion to dismiss claims as to SORA’s vagueness, which had made it impossible for the plaintiffs to comply with its reporting requirements. The court found that additional information was needed to determine if SORA was specific enough for the plaintiffs to understand the requirements imposed on them. The court similarly denied the motion to dismiss the plaintiffs’ First Amendment claim. The court found that additional information was needed to conclude whether SORA’s requirements that the plaintiffs provide all online usernames chilled the plaintiffs’ right to free speech. 932 F.Supp.2d 803.

Discovery continued for the next year. On February 20, 2014, the plaintiffs moved for summary judgment. Less than two weeks later, the defendants also moved for summary judgment. Both motions were denied on May 1, 2014. The court instead ordered the parties to cooperate and produce one stipulated factual record, to notify the court of any disputed material facts, and to each file a Motion for Judgment.

On March 31, 2015, the court granted in part and denied in part the plaintiffs’ June 27, 2014 Motion for Judgment and the defendants’ July 9, 2014 Motion for Judgment. The court held the plaintiffs’ claims that certain aspects of SORA were too vague were valid, since the plaintiffs had curtailed their conduct as a result of the statute's uncertainty. Specifically, the court held that geographic exclusion zones proscribing where registrants could stand were unconstitutional since they were too vague to inform registrants and law enforcement was constituted a violation. Similarly, requirements that registrants report their telephone numbers, e-mail addresses, instant message addresses, and vehicle registration were too vague to provide registrants or law enforcement with necessary guidelines for what acts triggered a reporting requirement. The court reserved ruling on the plaintiffs’ remaining claims. 101 F.Supp.3d 672.

On June 5, 2015, the defendants appealed the district court’s initial ruling to the Sixth Circuit Court of Appeals.

On September 3, 2015, the district court ruled on the plaintiffs’ remaining claims. The court held that SORA could not retroactively extend the plaintiffs’ reporting requirements from twenty-five years to life. The court found that the defendants did not show that this extension was narrowly tailored to public safety because there was no evidence that sex offenders who had not re-offended in twenty-five years were at an increased risk of committing a different sex offense. 101 F.Supp.3d 722.

On October 26, 2015 the plaintiffs appealed to the U.S. Court of Appeals for the Sixth Circuit. The defendants filed another appeal on November 20, 2015.

On August 25, 2016, the Sixth Circuit ruled on the appeals. The Sixth Circuit unanimously found that SORA imposed a punishment on the plaintiffs and therefore was an Ex Post Facto law. As a result, retroactive application of SORA was unconstitutional. The case was remanded to the district court to enter judgment consistent with the Sixth Circuit’s opinion. 834 F.3d 696.

The defendants appealed the Sixth Circuit’s holding to the U.S. Supreme Court on December 14, 2016.

The parties entered into a stipulated order on April 3, 2017 granting interim injunctive relief pending resolution of the appeal to the U.S. Supreme Court. The parties agreed that the plaintiffs would not be listed on a public registry, the defendants would not enforce any of SORAs’ provisions that became effective since 2006 against the plaintiffs, and the plaintiffs’ registration periods would run for 25 years instead of life.

The U.S. Supreme Court denied the defendant's petition for certiorari on October 2, 2017.

The parties reopened the case in the district court the following month. The defendants moved for judgment on December 4, 2017. The defendants contended that the Sixth Circuit’s decision only affected the plaintiffs in this case and did not apply to SORA itself.

On January 26, 2018, the district court issued a stipulated final judgment on remand. The court held that retroactive application of SORA’s 2006 and 2011 amendments violated the Ex Post Facto Clause. Therefore, the defendants and any other individual were enjoined from enforcing the 2006 and 2011 SORA amendments against the plaintiffs. The court further held that the plaintiffs would not be listed on a public registry and the only requirements of SORA that applied to them were to verify their address quarterly, provide fingerprints, and pay annual fees. Further, their registration period was amended to 25 years instead of life.

This case is now closed.

Summary Authors

Craig Streit (10/21/2016)

Hannah Greenhouse (3/10/2019)

People

For PACER's information on parties and their attrorneys, see: https://www.courtlistener.com/docket/5225024/parties/does-v-snyder/


Judge(s)

Batchelder, Alice Moore (Ohio)

Cleland, Robert Hardy (Michigan)

Grand, David R. (Michigan)

Attorneys(s) for Plaintiff

Allen, Marc S. (Michigan)

Aukerman, Miriam (Michigan)

Moss, Kary L. (Michigan)

Reingold, Paul (Michigan)

Steinberg, Michael J. (Michigan)

Swor, William W. (Michigan)

Attorneys(s) for Defendant

Grill, Erik A. (Michigan)

Judge(s)

Batchelder, Alice Moore (Ohio)

Cleland, Robert Hardy (Michigan)

Grand, David R. (Michigan)

Attorneys(s) for Plaintiff

Allen, Marc S. (Michigan)

Aukerman, Miriam (Michigan)

Moss, Kary L. (Michigan)

Reingold, Paul (Michigan)

Steinberg, Michael J. (Michigan)

Swor, William W. (Michigan)

Attorneys(s) for Defendant

Grill, Erik A. (Michigan)

Nelson, Margaret A. (Michigan)

Sadowski, Adam P. (Michigan)

Documents in the Clearinghouse

Document

2:12-cv-11194

Docket [PACER]

Aug. 17, 2018

Aug. 17, 2018

Docket
1

2:12-cv-11194

Complaint

March 16, 2012

March 16, 2012

Complaint
1-1

2:12-cv-11194

Exhibits to Complaint

March 16, 2012

March 16, 2012

Other
14

2:12-cv-11194

Amended Motion to Dismiss and Defendants Amended Brief in Support of Motion to Dismiss

April 24, 2012

April 24, 2012

Pleading / Motion / Brief
21

2:12-cv-11194

Plaintiff's Brief Opposing Defendants' Motion to Dismiss

May 25, 2012

May 25, 2012

Pleading / Motion / Brief
21-1

2:12-cv-11194

Exhibits to Plaintiff's Brief Opposing Defendants' Motion to Dismiss

May 25, 2012

May 25, 2012

Other
24

2:12-cv-11194

Defendants' Reply Brief

June 15, 2012

June 15, 2012

Pleading / Motion / Brief
27

2:12-cv-11194

Opinion and Order Granting in Part and Denying in Part Defendants' Amended Motion to Dismiss

Doe v. Snyder

932 F.Supp.2d 803, 2013 WL 1119405

March 18, 2013

March 18, 2013

Order/Opinion
46

2:12-cv-11194

First Amended Complaint

Dec. 2, 2013

Dec. 2, 2013

Complaint
103

2:12-cv-11194

Opinion and Order Resolving Motions for Judgment

Doe v. Snyder

101 F.Supp.3d 672, 2015 WL 1497852

March 31, 2015

March 31, 2015

Order/Opinion

Resources

Docket

See docket on RECAP: https://www.courtlistener.com/docket/5225024/does-v-snyder/

Last updated Aug. 7, 2022, 3:15 a.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT filed by John Does 1-4, Mary Doe against KRISTE ETUE, RICHARD D. SNYDER. Plaintiff requests summons issued. Receipt No: 0645-3440001 - Fee: $ 350. County of 1st Plaintiff: Wayne - County Where Action Arose: Wayne - County of 1st Defendant: Ingham. [Previously dismissed case: No] [Possible companion case(s): None] (Attachments: # 1 Index of Exhibits Index, # 2 Exhibit Ex. 1 Obligations, Disabilitis and Restraints Imposed, # 3 Exhibit Ex. 2 Declaration of John Doe 1, # 4 Exhibit Ex. 3 Declaration of John Doe 2, # 5 Exhibit Ex. 4 Declaration of John Doe 3, # 6 Exhibit Ex. 5 Declaration of John Doe 4, # 7 Exhibit Ex. 6 Declaration of Mary Doe, # 8 Exhibit Ex. 7 Declaration of I.G., # 9 Exhibit Ex. 8 Declaration of Dr. JJ Prescott, # 10 Exhibit Ex. 9 Declaration of Dr. Jill Levenson, # 11 Exhibit Ex. 10 Declaration of Dr. Janet Fay-Dumaine, # 12 Exhibit Ex. 11 Declaration of Peter Wagner, # 13 Exhibit Ex. 12 Declaration of Anne Yantus, # 14 Exhibit Ex. 13 Texas Association of Cunties Report) (Reingold, Paul) (Entered: 03/16/2012)

1 Index of Exhibits Index

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2 Exhibit Ex. 1 Obligations, Disabilitis and Restraints Imposed

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3 Exhibit Ex. 2 Declaration of John Doe 1

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4 Exhibit Ex. 3 Declaration of John Doe 2

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5 Exhibit Ex. 4 Declaration of John Doe 3

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6 Exhibit Ex. 5 Declaration of John Doe 4

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7 Exhibit Ex. 6 Declaration of Mary Doe

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8 Exhibit Ex. 7 Declaration of I.G.

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9 Exhibit Ex. 8 Declaration of Dr. JJ Prescott

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10 Exhibit Ex. 9 Declaration of Dr. Jill Levenson

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11 Exhibit Ex. 10 Declaration of Dr. Janet Fay-Dumaine

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12 Exhibit Ex. 11 Declaration of Peter Wagner

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13 Exhibit Ex. 12 Declaration of Anne Yantus

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14 Exhibit Ex. 13 Texas Association of Cunties Report

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March 16, 2012

March 16, 2012

PACER
2

SUMMONS Issued for *KRISTE ETUE* (KKra) (Entered: 03/16/2012)

March 16, 2012

March 16, 2012

PACER
3

SUMMONS Issued for *RICHARD D. SNYDER* (KKra) (Entered: 03/16/2012)

March 16, 2012

March 16, 2012

PACER
4

MOTION Proceed Anonymously re 1 Complaint,,,, by All Plaintiffs. (Attachments: # 1 Index of Exhibits Index, # 2 Exhibit Ex A Proposed Protective Order, # 3 Exhibit Ex B Articles on Sex Offender) (Reingold, Paul) (Entered: 03/16/2012)

1 Index of Exhibits Index

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2 Exhibit Ex A Proposed Protective Order

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3 Exhibit Ex B Articles on Sex Offender

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March 16, 2012

March 16, 2012

PACER
5

NOTICE of Appearance by Michael J. Steinberg on behalf of All Plaintiffs. (Steinberg, Michael) (Entered: 03/16/2012)

March 16, 2012

March 16, 2012

PACER
6

NOTICE of Appearance by Miriam J. Aukerman on behalf of All Plaintiffs. (Aukerman, Miriam) (Entered: 03/16/2012)

March 16, 2012

March 16, 2012

PACER
7

NOTICE of Appearance by William W. Swor on behalf of All Plaintiffs. (Swor, William) (Entered: 03/19/2012)

March 19, 2012

March 19, 2012

PACER
8

NOTICE of Appearance by Margaret A. Nelson on behalf of All Defendants. (Nelson, Margaret) (Entered: 03/28/2012)

March 28, 2012

March 28, 2012

PACER
9

NOTICE of Appearance by Erik A. Grill on behalf of All Defendants. (Grill, Erik) (Entered: 03/28/2012)

March 28, 2012

March 28, 2012

PACER
10

STIPULATION AND ORDER Extending Time to File Answer and Response to Motion until April 20, 2012. Signed by District Judge Robert H. Cleland. (Chubb, A) (Entered: 04/06/2012)

April 6, 2012

April 6, 2012

PACER
11

ORDER granting 4 Motion to Proceed Anonymously and Directing Parties to Submit Stipulated Protective Order. Signed by District Judge Robert H. Cleland. (Werner, L) (Entered: 04/18/2012)

April 18, 2012

April 18, 2012

RECAP
12

MOTION for Leave to File Excess Pages by KRISTE ETUE, RICHARD D. SNYDER. (Nelson, Margaret) (Entered: 04/23/2012)

April 23, 2012

April 23, 2012

PACER
13

MOTION to Dismiss and Brief in Support by KRISTE ETUE, RICHARD D. SNYDER. (Nelson, Margaret) (Entered: 04/23/2012)

April 23, 2012

April 23, 2012

PACER
14

Amended MOTION to Dismiss and Brief in Support by KRISTE ETUE, RICHARD D. SNYDER. (Nelson, Margaret) (Entered: 04/24/2012)

April 24, 2012

April 24, 2012

PACER
15

STIPULATED ORDER FOR Second Extension of time for response to plaintiffs' complaint to 4/23/2012 Signed by District Judge Robert H. Cleland. (LWag) (Entered: 05/01/2012)

May 1, 2012

May 1, 2012

PACER
16

STIPULATED PROTECTIVE ORDER Signed by District Judge Robert H. Cleland. (LWag) (Entered: 05/01/2012)

May 1, 2012

May 1, 2012

RECAP
17

MOTION for Leave to File Excess Pages by All Plaintiffs. (Reingold, Paul) (Entered: 05/14/2012)

May 14, 2012

May 14, 2012

PACER
18

[STRICKEN] RESPONSE to 14 Amended MOTION to Dismiss and Brief in Support filed by All Plaintiffs. (Attachments: # 1 Exhibit Exhibit14 Attorney General Letter, # 2 Exhibit Exhibit 15 MIRS Reports, # 3 Exhibit Exhibit 16 Mikaloff, # 4 Exhibit Exhibit 17 Elwell, # 5 Exhibit Exhibit 18 Whitaker, # 6 Exhibit Exhibit 19 Blood Legislative Report, # 7 Exhibit Exhibit 20 MN DOC Report, # 8 Exhibit Exhibit 21 Iowa County Attorneys Association, # 9 Exhibit Exhibit 22 Misguided Measures) (Steinberg, Michael) Modified on 5/18/2012 (LWag). (Entered: 05/14/2012)

May 14, 2012

May 14, 2012

PACER
19

ORDER STRIKING 18 Response to Motion, filed by Mary Doe, John Does, AND GRANTING IN PART 17 MOTION for Leave to File Excess Pages filed by Mary Doe, John Does. Signed by District Judge Robert H. Cleland. (LWag) (Entered: 05/18/2012)

May 18, 2012

May 18, 2012

RECAP
20

NOTICE of hearing on 14 Amended MOTION to Dismiss and Brief in Support. Motion Hearing set for 7/11/2012 02:00 PM before District Judge Robert H. Cleland (LWag) (Entered: 05/18/2012)

May 18, 2012

May 18, 2012

PACER
21

RESPONSE to 14 Amended MOTION to Dismiss and Brief in Support filed by All Plaintiffs. (Attachments: # 1 Exhibit Exhibit14 Attorney General Letter, # 2 Exhibit Exhibit 15 MIRS Reports, # 3 Exhibit Exhibit 16 Mikaloff, # 4 Exhibit Exhibit 17 Elwell, # 5 Exhibit Exhibit 18 Whitaker, # 6 Exhibit Exhibit 19 Blood Watson Report, # 7 Exhibit Exhibit 20 Minn DOC, # 8 Exhibit Exhibit 21 Iowa County Attorneys Association, # 9 Exhibit Exhibit 22 Misguided Measures) (Aukerman, Miriam) (Entered: 05/25/2012)

1 Exhibit Exhibit14 Attorney General Letter

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2 Exhibit Exhibit 15 MIRS Reports

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3 Exhibit Exhibit 16 Mikaloff

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4 Exhibit Exhibit 17 Elwell

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5 Exhibit Exhibit 18 Whitaker

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6 Exhibit Exhibit 19 Blood Watson Report

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7 Exhibit Exhibit 20 Minn DOC

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8 Exhibit Exhibit 21 Iowa County Attorneys Association

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9 Exhibit Exhibit 22 Misguided Measures

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May 25, 2012

May 25, 2012

RECAP
22

STIPULATION AND ORDER Extending time to file a reply brief as to as to 14 Amended MOTION to Dismiss and Brief in Support :( Replies due by 6/15/2012) Signed by District Judge Robert H. Cleland. (LWag) (Entered: 06/12/2012)

June 12, 2012

June 12, 2012

PACER
23

MOTION for Leave to File Excess Pages for a Reply Brief by KRISTE ETUE, RICHARD D. SNYDER. (Nelson, Margaret) (Entered: 06/15/2012)

June 15, 2012

June 15, 2012

PACER
24

REPLY to Response re 14 Amended MOTION to Dismiss and Brief in Support filed by KRISTE ETUE, RICHARD D. SNYDER. (Nelson, Margaret) (Entered: 06/15/2012)

June 15, 2012

June 15, 2012

PACER
25

EXHIBIT A - re 24 Reply to Response to Motion by KRISTE ETUE, RICHARD D. SNYDER (Nelson, Margaret) (Entered: 06/18/2012)

June 18, 2012

June 18, 2012

PACER
26

SUPPLEMENTAL BRIEF re 14 Amended MOTION to Dismiss and Brief in Support, 21 Response to Motion,, filed by All Plaintiffs. (Reingold, Paul) (Entered: 02/01/2013)

Feb. 1, 2013

Feb. 1, 2013

PACER
27

OPINION AND ORDER granting in part and denying in part 14 Defendant's Amended Motion to Dismiss. Signed by District Judge Robert H. Cleland. (LWag) (Entered: 03/18/2013)

March 18, 2013

March 18, 2013

RECAP
28

ANSWER to Complaint with Affirmative Defenses by KRISTE ETUE, RICHARD D. SNYDER. (Grill, Erik) (Entered: 04/02/2013)

April 2, 2013

April 2, 2013

PACER
29

NOTICE TO APPEAR : Scheduling Conference set for 4/23/2013 10:00 AM before District Judge Robert H. Cleland (LWag) (Entered: 04/16/2013)

April 16, 2013

April 16, 2013

PACER
30

SCHEDULING ORDER: Discovery due by 12/3/2013 Dispositive Motion Cut-off set for 1/6/2014 Final Pretrial Conference set for 3/10/2014 02:00 PM before District Judge Robert H. Cleland Bench Trial set for 3/24/2014 09:00 AM before District Judge Robert H. Cleland Signed by District Judge Robert H. Cleland. (Refer to image for additional dates) (LWag) (Entered: 06/03/2013)

June 3, 2013

June 3, 2013

PACER
31

Plaintiffs' Preliminary WITNESS LIST by All Plaintiffs (Reingold, Paul) (Entered: 06/17/2013)

June 17, 2013

June 17, 2013

PACER
32

Preliminary WITNESS LIST by KRISTE ETUE, RICHARD D. SNYDER (Grill, Erik) (Entered: 06/17/2013)

June 17, 2013

June 17, 2013

PACER
33

[STRICKEN] CERTIFICATE OF SERVICE by All Plaintiffs (Aukerman, Miriam) Modified on 8/5/2013 (PMil). (Entered: 08/05/2013)

Aug. 5, 2013

Aug. 5, 2013

PACER
34

STIPULATED ORDER Permitting Intervenor John Doe #5 to be Added to the Case and to File an Intervenor's Complaint. Signed by District Judge Robert H. Cleland. (KKra) (Entered: 08/27/2013)

Aug. 27, 2013

Aug. 27, 2013

PACER
35

INTERVENOR COMPLAINT of John Doe #5 filed by John Doe #5 against John Doe #5. (Reingold, Paul) Modified on 9/4/2013 (PMil).[INTERVENOR COMPLAINT FILED BY JOHN DOE AGAINST ALL DEFENDANTS] (Entered: 09/03/2013)

Sept. 3, 2013

Sept. 3, 2013

PACER
36

ANSWER to Intervenor Complaint with Affirmative Defenses by KRISTE ETUE, RICHARD D. SNYDER. (Grill, Erik) (Entered: 09/16/2013)

Sept. 16, 2013

Sept. 16, 2013

PACER
37

AFFIDAVIT of John Doe # 5 verification re 35 Intervenor Complaint by John Doe #5 (Reingold, Paul) (Entered: 09/30/2013)

Sept. 30, 2013

Sept. 30, 2013

PACER
38

STIPULATED ORDER for Extension of time for plaintiffs to provide expert report of Peter Wagner and for defendants to provide any responsive expert report. Signed by District Judge Robert H. Cleland. (LWag) (Entered: 10/04/2013)

Oct. 4, 2013

Oct. 4, 2013

PACER
39

DECLARATION by John Doe IV re 1 Complaint,,,, Amended filed by John Does (Aukerman, Miriam) (Entered: 10/15/2013)

Oct. 15, 2013

Oct. 15, 2013

PACER
40

DECLARATION by I.G. re 1 Complaint,,,, Amended filed by All Plaintiffs (Aukerman, Miriam) (Entered: 10/15/2013)

Oct. 15, 2013

Oct. 15, 2013

PACER
41

DECLARATION by John Doe IV and I.G. re 1 Complaint,,,, Amended filed by John Does (Aukerman, Miriam) (Entered: 10/17/2013)

Oct. 17, 2013

Oct. 17, 2013

PACER
42

Joint MOTION Extension of time and amendment of complaint by All Plaintiffs. (Aukerman, Miriam) (Entered: 11/08/2013)

Nov. 8, 2013

Nov. 8, 2013

PACER
43

WITNESS LIST by KRISTE ETUE, RICHARD D. SNYDER (Grill, Erik) (Entered: 11/19/2013)

Nov. 19, 2013

Nov. 19, 2013

PACER
44

FINAL WITNESS LIST by Mary Doe, John Doe #5, John Does (Aukerman, Miriam) (Entered: 11/19/2013)

Nov. 19, 2013

Nov. 19, 2013

PACER
45

STIPULATION AND ORDER granting 42 Joint Motion Extending Discovery and other Dates Discovery cutoff 1/3/2014 and Dispositive Motion Deadline is 2/6/2014. Signed by District Judge Robert H. Cleland. (LWag) (Entered: 11/27/2013)

Nov. 27, 2013

Nov. 27, 2013

RECAP
46

AMENDED COMPLAINT filed by John Does, John Doe #5, Mary Doe against John Does, John Doe #5, Mary Doe. NO NEW PARTIES ADDED. (Attachments: # 1 Index of Exhibits, # 2 Exhibit 1: Obligations, Disabilities and Restraints, # 3 Exhibit 2: Doe 1 Declaration, # 4 Exhibit 3: Doe 2 Declaration, # 5 Exhibit 4: Doe 3 Declaration, # 6 Exhibit 5: Amended Doe 4 Declaration, # 7 Exhibit 6: Mary Doe Declaration, # 8 Exhibit 7: Amended I.G. Declaration, # 9 Exhibit 8: Prescott Declaration, # 10 Exhibit 9: Levenson Declaration, # 11 Exhibit 10: Fay-Dumaine Declaration, # 12 Exhibit 11: Wagner Declaration, # 13 Exhibit 12: Yantus Declaration, # 14 Exhibit 13: Texas Study, # 15 Exhibit 14: Doe 5 Declaration, # 16 Exhibit 15: Public Act 149) (Aukerman, Miriam) (Entered: 12/02/2013)

1 Index of Exhibits

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2 Exhibit 1: Obligations, Disabilities and Restraints

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3 Exhibit 2: Doe 1 Declaration

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4 Exhibit 3: Doe 2 Declaration

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5 Exhibit 4: Doe 3 Declaration

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6 Exhibit 5: Amended Doe 4 Declaration

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7 Exhibit 6: Mary Doe Declaration

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8 Exhibit 7: Amended I.G. Declaration

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9 Exhibit 8: Prescott Declaration

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10 Exhibit 9: Levenson Declaration

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11 Exhibit 10: Fay-Dumaine Declaration

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12 Exhibit 11: Wagner Declaration

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13 Exhibit 12: Yantus Declaration

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14 Exhibit 13: Texas Study

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15 Exhibit 14: Doe 5 Declaration

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16 Exhibit 15: Public Act 149

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Dec. 2, 2013

Dec. 2, 2013

RECAP
47

MOTION to Compel Access to MSP Training on New Sex Offender Data Management System by Mary Doe, John Doe #5, John Does. (Attachments: # 1 Exhibit A: MSP Letter, # 2 Exhibit B: Discovery Request) (Aukerman, Miriam) (Entered: 12/02/2013)

1 Exhibit A: MSP Letter

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2 Exhibit B: Discovery Request

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Dec. 2, 2013

Dec. 2, 2013

PACER
48

STIPULATION AND ORDER Regarding 47 Plaintiffs' Motion to Compel Access to Michigan State Police Training on Sex Offender Registration Data Management System. Signed by District Judge Robert H. Cleland. (LWag) (Entered: 12/06/2013)

Dec. 6, 2013

Dec. 6, 2013

RECAP
49

ANSWER to Amended Complaint with Affirmative Defenses by KRISTE ETUE, RICHARD D. SNYDER. (Grill, Erik) (Entered: 12/16/2013)

Dec. 16, 2013

Dec. 16, 2013

PACER
50

Joint MOTION TO EXTEND Time to File Dispositive Motions by Mary Doe, John Doe #5, John Does. (Aukerman, Miriam) (Entered: 01/28/2014)

Jan. 28, 2014

Jan. 28, 2014

PACER
51

ORDER granting 50 Motion to Extend Deadline for Dispositive Motions to 2/20/2014.. Signed by District Judge Robert H. Cleland. (LWag) (Entered: 01/31/2014)

Jan. 31, 2014

Jan. 31, 2014

PACER
52

NOTICE of Appearance by Sofia V. Nelson on behalf of All Plaintiffs. (Nelson, Sofia) (Entered: 02/04/2014)

Feb. 4, 2014

Feb. 4, 2014

PACER
53

MOTION for Leave to File Excess Pages by KRISTE ETUE, RICHARD D. SNYDER. (Grill, Erik) (Entered: 02/14/2014)

Feb. 14, 2014

Feb. 14, 2014

PACER
54

MOTION for Leave to File Excess Pages on Motion for Summary Judgment by Mary Doe, John Doe #5, John Does. (Aukerman, Miriam) (Entered: 02/17/2014)

Feb. 17, 2014

Feb. 17, 2014

PACER
55

ORDER granting 54 Plaintiffs' Motion for Leave to File Brief with Excess Pages in support of the Motion for Summary Judgment.. Signed by District Judge Robert H. Cleland. (LWag) (Entered: 02/20/2014)

Feb. 20, 2014

Feb. 20, 2014

PACER
56

STIPULATION AND ORDER Authorizing Filing Exhibits under Seal. Signed by District Judge Robert H. Cleland. (LWag) (Entered: 02/20/2014)

Feb. 20, 2014

Feb. 20, 2014

PACER
57

ORDER granting 53 Defendants' Motion for Leave to File Excess Pages. Signed by District Judge Robert H. Cleland. (LWag) (Entered: 02/20/2014)

Feb. 20, 2014

Feb. 20, 2014

PACER
58

MOTION for Summary Judgment by Mary Doe, John Doe #5, John Does. (Attachments: # 1 Statement of Material Facts, # 2 Index of Exhibits) (Aukerman, Miriam) (Entered: 02/20/2014)

1 Statement of Material Facts

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2 Index of Exhibits

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Feb. 20, 2014

Feb. 20, 2014

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59

EXHIBIT 1: John Doe #1 Deposition re 58 MOTION for Summary Judgment by Mary Doe, John Doe #5, John Does (Attachments: # 1 Exhibit 2: John Doe #2 Deposition, # 2 Exhibit 3: John Doe #3 Deposition, # 3 Exhibit 4: John Doe #4 Deposition, # 4 Exhibit 5: John Doe #5 Deposition, # 5 Exhibit 6: Mary Doe Deposition, # 6 Exhibit 7: I.G. Deposition, # 7 Exhibit 8: S.F. Deposition) (Aukerman, Miriam) (Entered: 02/20/2014)

1 Exhibit 2: John Doe #2 Deposition

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2 Exhibit 3: John Doe #3 Deposition

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3 Exhibit 4: John Doe #4 Deposition

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4 Exhibit 5: John Doe #5 Deposition

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5 Exhibit 6: Mary Doe Deposition

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6 Exhibit 7: I.G. Deposition

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7 Exhibit 8: S.F. Deposition

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Feb. 20, 2014

Feb. 20, 2014

PACER
60

EXHIBIT 9: Levenson Deposition re 58 MOTION for Summary Judgment by Mary Doe, John Doe #5, John Does (Attachments: # 1 Exhibit 10: Prescott Deposition, # 2 Exhibit 11: P. Wagner Deposition, # 3 Exhibit 12: Fay-Dumaine Deposition, # 4 Exhibit 13: Stapleton Deposition, # 5 Exhibit 14: Poxson Deposition, # 6 Exhibit 15: Johnson Deposition, # 7 Exhibit 16: Burchell Deposition, # 8 Exhibit 17: Payne Deposition) (Aukerman, Miriam) (Entered: 02/20/2014)

1 Exhibit 10: Prescott Deposition

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2 Exhibit 11: P. Wagner Deposition

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3 Exhibit 12: Fay-Dumaine Deposition

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4 Exhibit 13: Stapleton Deposition

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5 Exhibit 14: Poxson Deposition

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6 Exhibit 15: Johnson Deposition

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7 Exhibit 16: Burchell Deposition

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8 Exhibit 17: Payne Deposition

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Feb. 20, 2014

Feb. 20, 2014

PACER
61

EXHIBIT 18: L. Wagner Deposition re 58 MOTION for Summary Judgment by Mary Doe, John Doe #5, John Does (Attachments: # 1 Exhibit 19: Hawkins Deposition, # 2 Exhibit 20: Yantus Deposition, # 3 Exhibit 21: Tanner Deposition, # 4 Exhibit 22: Prescott Expert Report, # 5 Exhibit 23: Levenson Expert Report, # 6 Exhibit 24: Fay-Dumaine Expert Report) (Aukerman, Miriam) (Entered: 02/20/2014)

1 Exhibit 19: Hawkins Deposition

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2 Exhibit 20: Yantus Deposition

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3 Exhibit 21: Tanner Deposition

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4 Exhibit 22: Prescott Expert Report

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5 Exhibit 23: Levenson Expert Report

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6 Exhibit 24: Fay-Dumaine Expert Report

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Feb. 20, 2014

Feb. 20, 2014

PACER
62

EXHIBIT 25: P. Wagner 1st Expert Report re 58 MOTION for Summary Judgment by Mary Doe, John Doe #5, John Does (Attachments: # 1 Exhibit 26: P. Wagner 2nd Expert Report) (Aukerman, Miriam) (Entered: 02/20/2014)

1 Exhibit 26: P. Wagner 2nd Expert Report

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Feb. 20, 2014

Feb. 20, 2014

RECAP
63

EXHIBIT 27: Yantus Expert Report re 58 MOTION for Summary Judgment by Mary Doe, John Doe #5, John Does (Attachments: # 1 Exhibit 28: Stapleton Expert Report, # 2 Exhibit 29: John Doe # 5 Declaration (Second), # 3 Exhibit 30: Mary Doe Declaration (Second), # 4 Exhibit 31: Amended Declaration of I.G., # 5 Exhibit 32: Poxson Declaration, # 6 Exhibit 33: Granzotto Declaration) (Aukerman, Miriam) (Entered: 02/20/2014)

1 Exhibit 28: Stapleton Expert Report

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2 Exhibit 29: John Doe # 5 Declaration (Second)

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3 Exhibit 30: Mary Doe Declaration (Second)

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4 Exhibit 31: Amended Declaration of I.G.

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5 Exhibit 32: Poxson Declaration

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6 Exhibit 33: Granzotto Declaration

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Feb. 20, 2014

Feb. 20, 2014

PACER
64

EXHIBIT 34: Summary of Obligations, Disabilities and Restraints Imposed by SORA 2013 re 58 MOTION for Summary Judgment by Mary Doe, John Doe #5, John Does (Attachments: # 1 Exhibit 35: Plaintiffs' Response to Defendants' Interrogatory 11, # 2 Exhibit 36: Doe #1 Interrogatory Responses, # 3 Exhibit 37: Doe #2 Interrogatory Responses, # 4 Exhibit 38: Doe #3 Interrogatory Responses, # 5 Exhibit 39: Doe #4 Interrogatory Responses, # 6 Exhibit 40: Doe #5 Interrogatory Responses, # 7 Exhibit 41: Mary Doe Interrogatory Responses, # 8 Exhibit 42: Defendants' Responses to Plaintiffs' First Interrogatories, # 9 Exhibit 43: Defendants' Supplemental Responses to Plaintiffs' First Interrogatories) (Aukerman, Miriam) (Entered: 02/20/2014)

1 Exhibit 35: Plaintiffs' Response to Defendants' Interrogatory 11

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2 Exhibit 36: Doe #1 Interrogatory Responses

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3 Exhibit 37: Doe #2 Interrogatory Responses

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4 Exhibit 38: Doe #3 Interrogatory Responses

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5 Exhibit 39: Doe #4 Interrogatory Responses

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6 Exhibit 40: Doe #5 Interrogatory Responses

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7 Exhibit 41: Mary Doe Interrogatory Responses

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8 Exhibit 42: Defendants' Responses to Plaintiffs' First Interrogatories

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9 Exhibit 43: Defendants' Supplemental Responses to Plaintiffs' First In

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Feb. 20, 2014

Feb. 20, 2014

PACER
65

EXHIBIT 44: Defendants' Answers to Plaintiffs' First Requests for Admission re 58 MOTION for Summary Judgment by Mary Doe, John Doe #5, John Does (Attachments: # 1 Exhibit 45: MSP SORA Charging Data, # 2 Exhibit 46: MSP SORA Conviction Data, # 3 Exhibit 47: MSP Official Order 79, # 4 Exhibit 48: Tier III Notification Letter, # 5 Exhibit 49: SOR Unit Student Safety Zone Cheatsheet, # 6 Exhibit 50: Offender Watch User Manual) (Aukerman, Miriam) (Entered: 02/20/2014)

1 Exhibit 45: MSP SORA Charging Data

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2 Exhibit 46: MSP SORA Conviction Data

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3 Exhibit 47: MSP Official Order 79

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4 Exhibit 48: Tier III Notification Letter

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5 Exhibit 49: SOR Unit Student Safety Zone Cheatsheet

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6 Exhibit 50: Offender Watch User Manual

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Feb. 20, 2014

Feb. 20, 2014

PACER
66

EXHIBIT 51: OffenderWatch Express Description re 58 MOTION for Summary Judgment by Mary Doe, John Doe #5, John Does (Attachments: # 1 Exhibit 52: OffenderWatch Contract, # 2 Exhibit 53: Total Number on SOR by Year, # 3 Exhibit 54: Total Number of Offenders by Tier, # 4 Exhibit 55: Roster of MSP/SOR Unit Staff, # 5 Exhibit 56: MSP List of SORA Coordinators, # 6 Exhibit 57: Sample SOR Letter to Registrant, # 7 Exhibit 58: MSP Sex Offender Registry and Enforcement Training Powerpoint 2011, # 8 Exhibit 59: Tanner Sex Offender Registry Training 2013 for Prosecutors, # 9 Exhibit 60: Tanner Sex Offender Registry Training 2011 for Prosecutors, # 10 Exhibit 61: Registration Length June/August 2011, # 11 Exhibit 62: Explanation of Duties Form) (Aukerman, Miriam) (Entered: 02/20/2014)

1 Exhibit 52: OffenderWatch Contract

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2 Exhibit 53: Total Number on SOR by Year

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3 Exhibit 54: Total Number of Offenders by Tier

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4 Exhibit 55: Roster of MSP/SOR Unit Staff

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5 Exhibit 56: MSP List of SORA Coordinators

View on PACER

6 Exhibit 57: Sample SOR Letter to Registrant

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7 Exhibit 58: MSP Sex Offender Registry and Enforcement Training Powerpoint 2011

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8 Exhibit 59: Tanner Sex Offender Registry Training 2013 for Prosecutors

View on PACER

9 Exhibit 60: Tanner Sex Offender Registry Training 2011 for Prosecutors

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10 Exhibit 61: Registration Length June/August 2011

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11 Exhibit 62: Explanation of Duties Form

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Feb. 20, 2014

Feb. 20, 2014

PACER
67

EXHIBIT 63: Doe #2 MSP Criminal History Print-Out re 58 MOTION for Summary Judgment by Mary Doe, John Doe #5, John Does (Attachments: # 1 Exhibit 64: Doe #2 Public Sex Offender Registry Print-Out, # 2 Exhibit 65: Doe #2 DD-214 Certificate of Release or Discharge from Active Duty, # 3 Exhibit 66: Affidavit of Victim in Case of Doe #2, # 4 Exhibit 67: Fiscal Year 2014 SOR Unit Budget, # 5 Exhibit 68: OffenderWatch Training Video Transcript) (Aukerman, Miriam) (Entered: 02/20/2014)

1 Exhibit 64: Doe #2 Public Sex Offender Registry Print-Out

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2 Exhibit 65: Doe #2 DD-214 Certificate of Release or Discharge from Active D

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3 Exhibit 66: Affidavit of Victim in Case of Doe #2

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4 Exhibit 67: Fiscal Year 2014 SOR Unit Budget

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5 Exhibit 68: OffenderWatch Training Video Transcript

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Feb. 20, 2014

Feb. 20, 2014

PACER
68

[STRICKEN] MOTION for Summary Judgment by KRISTE ETUE, RICHARD D. SNYDER. (Attachments: # 1 Index of Exhibits Index of Exhibits, # 2 Exhibit A. State v. Husband, # 3 Exhibit B. School Cuts Spur Michigan Conflict, # 4 Exhibit C. Mueller v. Raemisch) (Grill, Erik) Modified on 3/3/2014 (LWag). (Entered: 02/20/2014)

Feb. 20, 2014

Feb. 20, 2014

PACER
69

SEALED EXHIBIT 69: Doe #4 Busted Newspaper re 58 MOTION for Summary Judgment by Mary Doe, John Doe #5, John Does. (Attachments: # 1 Exhibit 70: Doe #4 Death Threat) (Aukerman, Miriam) (Entered: 02/20/2014)

Feb. 20, 2014

Feb. 20, 2014

PACER
70

EXHIBIT 71: Doe v. Thompson re 58 MOTION for Summary Judgment by Mary Doe, John Doe #5, John Does (Attachments: # 1 Exhibit 72: Cost Benefit Analyses of SORNA Implementation, # 2 Exhibit 73: California AWA Position Statement, # 3 Exhibit 74: Colorado AWA White Paper, # 4 Exhibit 75: Texas Study of Costs to Local Government of Implementing AWA, # 5 Exhibit 76: Senate Fiscal Agency Analysis for S.B. 221, # 6 Exhibit 77: Pew Research Center Email Article, # 7 Exhibit 78: Hanson Study, # 8 Exhibit 79: Hanson Declaration, # 9 Exhibit 80: Sex Offender Sexual Recidivism Risk Levels Over Time Graph, # 10 Exhibit 81: Collateral Damage:) (Aukerman, Miriam) (Entered: 02/20/2014)

1 Exhibit 72: Cost Benefit Analyses of SORNA Implementation

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2 Exhibit 73: California AWA Position Statement

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3 Exhibit 74: Colorado AWA White Paper

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4 Exhibit 75: Texas Study of Costs to Local Government of Implementing AWA

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5 Exhibit 76: Senate Fiscal Agency Analysis for S.B. 221

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6 Exhibit 77: Pew Research Center Email Article

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7 Exhibit 78: Hanson Study

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8 Exhibit 79: Hanson Declaration

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9 Exhibit 80: Sex Offender Sexual Recidivism Risk Levels Over Time Graph

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10 Exhibit 81: Collateral Damage:

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Feb. 20, 2014

Feb. 20, 2014

PACER
71

EXHIBIT 82: DOJ Evaluation of Sex Offender Residency Restrictions re 58 MOTION for Summary Judgment by Mary Doe, John Doe #5, John Does (Attachments: # 1 Exhibit 83: SOR Unit Manual, # 2 Exhibit 84: Judgment of Sentence Form, # 3 Exhibit 85: Doe #2 Order Amending Probation, # 4 Exhibit 86: Doe #3 Order of Probation, # 5 Exhibit 87: MSP Memo re Operation Verify, # 6 Exhibit 88: Legislative Analysis of P.A. 542 (2002), # 7 Exhibit 89: Regional Jail Feasibility Study) (Aukerman, Miriam) (Entered: 02/20/2014)

1 Exhibit 83: SOR Unit Manual

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2 Exhibit 84: Judgment of Sentence Form

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3 Exhibit 85: Doe #2 Order Amending Probation

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4 Exhibit 86: Doe #3 Order of Probation

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5 Exhibit 87: MSP Memo re Operation Verify

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6 Exhibit 88: Legislative Analysis of P.A. 542 (2002)

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7 Exhibit 89: Regional Jail Feasibility Study

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Feb. 20, 2014

Feb. 20, 2014

PACER
72

EXHIBIT 90: State of Michigan Prison Costs re 58 MOTION for Summary Judgment by Mary Doe, John Doe #5, John Does (Attachments: # 1 Exhibit 91: SMART SORNA States Listing, # 2 Exhibit 92: Legislative Service Bureau Report on SORA, # 3 Exhibit 93: MSP News Release on Sweeps, # 4 Exhibit 94: Michigan Attorney General Letter on Student Safety Zones, # 5 Exhibit 95: SMART Confirmation of Michigan's Substantial Compliance, # 6 Exhibit 96: Byrne Fund Reports 2011, # 7 Exhibit 97: Michigan S.B. 76 and 77, # 8 Exhibit 98: Defendants' 2nd Supplemental Responses to Plaintiffs 1st Interrogatories) (Aukerman, Miriam) (Entered: 02/20/2014)

1 Exhibit 91: SMART SORNA States Listing

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2 Exhibit 92: Legislative Service Bureau Report on SORA

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3 Exhibit 93: MSP News Release on Sweeps

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4 Exhibit 94: Michigan Attorney General Letter on Student Safety Zones

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5 Exhibit 95: SMART Confirmation of Michigan's Substantial Compliance

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6 Exhibit 96: Byrne Fund Reports 2011

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7 Exhibit 97: Michigan S.B. 76 and 77

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8 Exhibit 98: Defendants' 2nd Supplemental Responses to Plaintiffs 1st Interr

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Feb. 20, 2014

Feb. 20, 2014

PACER
73

APPENDIX re: 68 MOTION for Summary Judgment filed by RICHARD D. SNYDER, KRISTE ETUE. by KRISTE ETUE, RICHARD D. SNYDER (Attachments: # 1 Exhibit A. Deposition of Sgt. Bruce Payne, # 2 Exhibit B. Deposition of Trooper Timothy Burchell, # 3 Exhibit C. Deposition of Leslie Wagner, # 4 Exhibit D. Deposition of Herbert Tanner, # 5 Exhibit E. Deposition of Karen Johnson Vol. I, # 6 Exhibit F. Deposition of Karen Johnson Vol. II, # 7 Exhibit G. Deposition of Lt. Chris Hawkins, # 8 Exhibit H. Deposition of John Doe #1, # 9 Exhibit I. Deposition of John Doe #2, # 10 Exhibit J. Deposition of John Doe #3, # 11 Exhibit K. Deposition of S.F., # 12 Exhibit L. Deposition of John Doe #4, # 13 Exhibit M. Deposition of John Doe #5, # 14 Exhibit N. Deposition of Mary Doe) (Grill, Erik) (Entered: 02/20/2014)

1 Exhibit A. Deposition of Sgt. Bruce Payne

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2 Exhibit B. Deposition of Trooper Timothy Burchell

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3 Exhibit C. Deposition of Leslie Wagner

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4 Exhibit D. Deposition of Herbert Tanner

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5 Exhibit E. Deposition of Karen Johnson Vol. I

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6 Exhibit F. Deposition of Karen Johnson Vol. II

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7 Exhibit G. Deposition of Lt. Chris Hawkins

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8 Exhibit H. Deposition of John Doe #1

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9 Exhibit I. Deposition of John Doe #2

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10 Exhibit J. Deposition of John Doe #3

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11 Exhibit K. Deposition of S.F.

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12 Exhibit L. Deposition of John Doe #4

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13 Exhibit M. Deposition of John Doe #5

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14 Exhibit N. Deposition of Mary Doe

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Feb. 20, 2014

Feb. 20, 2014

PACER
74

APPENDIX re: 68 MOTION for Summary Judgment filed by RICHARD D. SNYDER, KRISTE ETUE. by KRISTE ETUE, RICHARD D. SNYDER (Attachments: # 1 Exhibit O. Letter Announcing Offender Watch dated 10/24/13, # 2 Exhibit P. SMART Substantial Implementation Review dated 5/9/11, # 3 Exhibit Q. SMART Annual Implementation Review Letter dated 9/17/13, # 4 Exhibit R. John Doe #1 Requests to Admit, # 5 Exhibit S. John Doe #2 Requests to Admit, # 6 Exhibit T. John Doe #3 Requests to Admit, # 7 Exhibit U. John Doe #4 Requests to Admit, # 8 Exhibit V. John Doe #5 Requests to Admit, # 9 Exhibit W. Mary Doe Requests to Admit, # 10 Exhibit X. SMART Letter dated 2/1/11, # 11 Exhibit Y. Federal Register, Vol. 73, No. 128, July 2, 2008, # 12 Exhibit Z. Michigan Sex Offender Registration Legislative Recommendations) (Grill, Erik) (Entered: 02/20/2014)

1 Exhibit O. Letter Announcing Offender Watch dated 10/24/13

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2 Exhibit P. SMART Substantial Implementation Review dated 5/9/11

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3 Exhibit Q. SMART Annual Implementation Review Letter dated 9/17/13

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4 Exhibit R. John Doe #1 Requests to Admit

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5 Exhibit S. John Doe #2 Requests to Admit

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6 Exhibit T. John Doe #3 Requests to Admit

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7 Exhibit U. John Doe #4 Requests to Admit

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8 Exhibit V. John Doe #5 Requests to Admit

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9 Exhibit W. Mary Doe Requests to Admit

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10 Exhibit X. SMART Letter dated 2/1/11

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11 Exhibit Y. Federal Register, Vol. 73, No. 128, July 2, 2008

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12 Exhibit Z. Michigan Sex Offender Registration Legislative Recommendations

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Feb. 20, 2014

Feb. 20, 2014

PACER
75

APPENDIX re: 68 MOTION for Summary Judgment filed by RICHARD D. SNYDER, KRISTE ETUE. by All Defendants (Attachments: # 1 Exhibit AA. SMART Sex Offender Registration and Notification Checklist, # 2 Exhibit BB. SMART National Guidelines for Sex Offender Registration and Notification, # 3 Exhibit CC. SMART Office Website, printed 1/15/14, # 4 Exhibit DD. House Fiscal Agency Analysis, # 5 Exhibit EE. PSOR Public Website Example, # 6 Exhibit FF. MSP Sex Offender Registry and Enforcement Training PowerPoint, # 7 Exhibit GG. Attorney General Letter Opinion dated 7/14/06, # 8 Exhibit HH. Tier Letters to Sex Offenders, # 9 Exhibit II. PSOR FAQs, # 10 Index of Exhibits JJ. Student Safety Zone Questions and Answers) (Grill, Erik) (Entered: 02/20/2014)

1 Exhibit AA. SMART Sex Offender Registration and Notification Checklist

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2 Exhibit BB. SMART National Guidelines for Sex Offender Registration and Notific

View on PACER

3 Exhibit CC. SMART Office Website, printed 1/15/14

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4 Exhibit DD. House Fiscal Agency Analysis

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5 Exhibit EE. PSOR Public Website Example

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6 Exhibit FF. MSP Sex Offender Registry and Enforcement Training PowerPoint

View on PACER

7 Exhibit GG. Attorney General Letter Opinion dated 7/14/06

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8 Exhibit HH. Tier Letters to Sex Offenders

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9 Exhibit II. PSOR FAQs

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10 Index of Exhibits JJ. Student Safety Zone Questions and Answers

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Feb. 20, 2014

Feb. 20, 2014

PACER
76

APPENDIX re: 68 MOTION for Summary Judgment filed by RICHARD D. SNYDER, KRISTE ETUE. by KRISTE ETUE, RICHARD D. SNYDER (Attachments: # 1 Exhibit KK. SOR Unit Training Manual, # 2 Exhibit LL. Tanner PowerPoint 2013, # 3 Exhibit MM. Tanner PowerPoint 2009, # 4 Exhibit NN. Tanner PowerPoint 2011, # 5 Exhibit OO. PAAM Outline of SORA Changes, # 6 Exhibit PP. SOR Unit Responses to ACLU, # 7 Exhibit QQ. ACLU Dissection of Draft dated 11/3/10, # 8 Exhibit RR. Explanation of Duties, # 9 Exhibit SS. Bill Analysis, SB 221) (Grill, Erik) (Entered: 02/20/2014)

1 Exhibit KK. SOR Unit Training Manual

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2 Exhibit LL. Tanner PowerPoint 2013

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3 Exhibit MM. Tanner PowerPoint 2009

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4 Exhibit NN. Tanner PowerPoint 2011

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5 Exhibit OO. PAAM Outline of SORA Changes

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6 Exhibit PP. SOR Unit Responses to ACLU

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7 Exhibit QQ. ACLU Dissection of Draft dated 11/3/10

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8 Exhibit RR. Explanation of Duties

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9 Exhibit SS. Bill Analysis, SB 221

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Feb. 20, 2014

Feb. 20, 2014

PACER
77

ERRATA Sheet re: 73 Appendix,,, filed by RICHARD D. SNYDER, KRISTE ETUE. by KRISTE ETUE, RICHARD D. SNYDER (Grill, Erik) (Entered: 02/24/2014)

Feb. 24, 2014

Feb. 24, 2014

PACER
78

JOINT STIPULATION AND ORDER TO STRIKE 68 MOTION for Summary Judgment and granting leave for defendants to refile with additional redactions. Signed by District Judge Robert H. Cleland. (LWag) (Entered: 03/03/2014)

March 3, 2014

March 3, 2014

RECAP
79

Amended MOTION for Summary Judgment by KRISTE ETUE, RICHARD D. SNYDER. (Attachments: # 1 Index of Exhibits Index of Exhibits, # 2 Exhibit A. State v. Husband, 2008 Ariz. App, # 3 Exhibit B. School Cuts Spur Michigan Conflict, Wall St. Journal, April 4, 2011, p 2, # 4 Exhibit C. Mueller v. Raemisch) (Grill, Erik) (Entered: 03/04/2014)

1 Index of Exhibits Index of Exhibits

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2 Exhibit A. State v. Husband, 2008 Ariz. App

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3 Exhibit B. School Cuts Spur Michigan Conflict, Wall St. Journal, April 4, 2011,

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4 Exhibit C. Mueller v. Raemisch

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March 4, 2014

March 4, 2014

PACER
80

NOTICE of Appearance by Douglas R. Mullkoff on behalf of Mary Doe, John Doe #5, John Does. (Mullkoff, Douglas) (Entered: 03/06/2014)

March 6, 2014

March 6, 2014

PACER
81

MOTION for Leave to File Brief as Amici Curiae by All Plaintiffs. (Mullkoff, Douglas) (Entered: 03/07/2014)

March 7, 2014

March 7, 2014

PACER
82

Amicus Curiae BRIEF by All Plaintiffs (Attachments: # 1 Exhibit Exhibit 1) (Mullkoff, Douglas) (Entered: 03/07/2014)

1 Exhibit Exhibit 1

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March 7, 2014

March 7, 2014

PACER
83

Joint MOTION for Extension of Time to File Response/Reply as to 58 MOTION for Summary Judgment by KRISTE ETUE, RICHARD D. SNYDER. (Grill, Erik) (Entered: 03/10/2014)

March 10, 2014

March 10, 2014

PACER
84

ORDER Suspending Briefing and Directing Parties to Appear for a ( Status Conference set for 4/15/2014 10:00 AM before District Judge Robert H. Cleland) Signed by District Judge Robert H. Cleland. (LWag) (Entered: 03/14/2014)

March 14, 2014

March 14, 2014

RECAP
85

ORDER SETTING New Briefing Schedule and Page Limits for Rule 52 Motions and Briefs; DENYING without prejudice 58 Motion for Summary Judgment; 79 Motion for Summary Judgment. Plaintiffs' Rule 52 Motion for Judgement due by 6/11/2014; Defendants' Response and Motion for Judgment due by 7/2/2014; Plaintiffs' Response and Reply due by 7/23/2014 and Defendants' Optional Reply due by 8/6/2014, . Signed by District Judge Robert H. Cleland. (LWag) (Entered: 05/01/2014)

May 1, 2014

May 1, 2014

RECAP
86

STIPULATED ORDER Setting New Schedule for Rule 52 Motions and Briefs (Plaintiffs' Rule 52 Motion for Judgment due by 6/27/2014; Defendants' Response and Rule 52 Motion due by 7/9/2014, Plaintiffs' Combined Response and Reply due by 7/23/2014; and Defendants' Reply Brief due by 8/6/2014) Signed by District Judge Robert H. Cleland. (LWag) (Entered: 06/06/2014)

June 6, 2014

June 6, 2014

PACER
87

MOTION in Limine and Brief in Support by KRISTE ETUE, RICHARD D. SNYDER. (Attachments: # 1 Index of Exhibits Listing of Exhibits, # 2 Exhibit A. Peter Wagner Report, # 3 Exhibit B. Peter Wagner Curriculum Vitae, # 4 Exhibit C. Peter Wagner Deposition Transcript, # 5 Exhibit D. Joseph Granzotto Deposition Transcript, # 6 Exhibit E. Timothy Poxson Deposition Transcript) (Grill, Erik) (Entered: 06/06/2014)

1 Index of Exhibits Listing of Exhibits

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2 Exhibit A. Peter Wagner Report

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3 Exhibit B. Peter Wagner Curriculum Vitae

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4 Exhibit C. Peter Wagner Deposition Transcript

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5 Exhibit D. Joseph Granzotto Deposition Transcript

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6 Exhibit E. Timothy Poxson Deposition Transcript

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June 6, 2014

June 6, 2014

PACER
88

RESPONSE to 87 MOTION in Limine and Brief in Support filed by Mary Doe, John Doe #5, John Does. (Attachments: # 1 Index of Exhibits, # 2 Exhibit 1: Declaration of Peter Wagner, # 3 Exhibit 2: First Expert Report of Peter Wagner, # 4 Exhibit 3: Declaration of Joseph Granzotto, # 5 Exhibit 4: Declaration of Timothy Poxson) (Aukerman, Miriam) (Entered: 06/17/2014)

1 Index of Exhibits

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2 Exhibit 1: Declaration of Peter Wagner

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3 Exhibit 2: First Expert Report of Peter Wagner

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4 Exhibit 3: Declaration of Joseph Granzotto

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5 Exhibit 4: Declaration of Timothy Poxson

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June 17, 2014

June 17, 2014

PACER
89

REPLY to Response re 87 MOTION in Limine and Brief in Support filed by KRISTE ETUE, RICHARD D. SNYDER. (Grill, Erik) (Entered: 06/20/2014)

June 20, 2014

June 20, 2014

PACER
90

STATEMENT of Joint Statement of Fact and Exhibit by KRISTE ETUE, RICHARD D. SNYDER (Attachments: # 1 Index of Exhibits Exhibit List, # 2 Exhibit 1. John Doe # 1 Deposition, # 3 Exhibit 2. John Doe # 2 Deposition, # 4 Exhibit 3. John Doe # 3 Deposition, # 5 Exhibit 4. John Doe # 4 Deposition, # 6 Exhibit 5. John Doe # 5 Deposition, # 7 Exhibit 6. Mary Doe Deposition, # 8 Exhibit 7. I.G. Deposition, # 9 Exhibit 8. S.F. Deposition, # 10 Exhibit 9. Jill Levenson Deposition, # 11 Exhibit 10. JJ Prescott Deposition, # 12 Exhibit 11. Peter Wagner Deposition, # 13 Exhibit 12. Janet Fay-Dumaine Deposition, # 14 Exhibit 13. Richard Stapleton Deposition, # 15 Exhibit 14. Timothy Poxson Deposition, # 16 Exhibit 15. Karen Johnson First and Second Depositions, # 17 Exhibit 16. Timothy Burchell Deposition, # 18 Exhibit 17. Bruce Payne Deposition, # 19 Exhibit 18. Leslie Wagner Deposition, # 20 Exhibit 19. Chris Hawkins Deposition, # 21 Exhibit 20. Anne Yantus Deposition, # 22 Exhibit 21. Herbert Tanner Deposition, # 23 Exhibit 22. Expert Report of Dr. James J. Prescott, J.D., Ph.D., # 24 Exhibit 23. Expert Report of Dr. Jill Levenson, Ph.D., # 25 Exhibit 24. Expert Report of Dr. Janet Fay-Dumaine, Psy. D.) (Grill, Erik) (Entered: 06/27/2014)

1 Index of Exhibits Exhibit List

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2 Exhibit 1. John Doe # 1 Deposition

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3 Exhibit 2. John Doe # 2 Deposition

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4 Exhibit 3. John Doe # 3 Deposition

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5 Exhibit 4. John Doe # 4 Deposition

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6 Exhibit 5. John Doe # 5 Deposition

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7 Exhibit 6. Mary Doe Deposition

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8 Exhibit 7. I.G. Deposition

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9 Exhibit 8. S.F. Deposition

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10 Exhibit 9. Jill Levenson Deposition

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11 Exhibit 10. JJ Prescott Deposition

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12 Exhibit 11. Peter Wagner Deposition

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13 Exhibit 12. Janet Fay-Dumaine Deposition

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14 Exhibit 13. Richard Stapleton Deposition

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15 Exhibit 14. Timothy Poxson Deposition

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16 Exhibit 15. Karen Johnson First and Second Depositions

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17 Exhibit 16. Timothy Burchell Deposition

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18 Exhibit 17. Bruce Payne Deposition

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19 Exhibit 18. Leslie Wagner Deposition

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20 Exhibit 19. Chris Hawkins Deposition

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21 Exhibit 20. Anne Yantus Deposition

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22 Exhibit 21. Herbert Tanner Deposition

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23 Exhibit 22. Expert Report of Dr. James J. Prescott, J.D., Ph.D.

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24 Exhibit 23. Expert Report of Dr. Jill Levenson, Ph.D.

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25 Exhibit 24. Expert Report of Dr. Janet Fay-Dumaine, Psy. D.

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June 27, 2014

June 27, 2014

PACER
91

EXHIBIT CONTINUED re 90 Statement,,,,, by KRISTE ETUE, RICHARD D. SNYDER (Attachments: # 1 Exhibit 25. First Expert Report of Peter Wagner, J.D., # 2 Exhibit 26. Second Expert Report of Peter Wagner, J.D., # 3 Exhibit 27. Expert Report of Anne Yantus, J.D., # 4 Exhibit 28. Expert Report of Richard Stapleton, # 5 Exhibit 29. Declaration (Second) of John Doe # 5, # 6 Exhibit 30. Declaration (Second) of Mary Doe, # 7 Exhibit 31. Amended Declaration of I.G., # 8 Exhibit 32. Declaration of Timothy Poxson, # 9 Exhibit 33. Declaration of Joseph Granzotto, # 10 Exhibit 34. Summary of Obligations, Disabilities, and Restraints Imposed by SORA 2013, # 11 Exhibit 35. Plaintiffs Response to Defendants Interrogatory 11, # 12 Exhibit 36. Doe # 1 Interrogatory Responses, # 13 Exhibit 37. Doe # 2 Interrogatory Responses, # 14 Exhibit 38. Doe # 3 Interrogatory Responses, # 15 Exhibit 39. Doe # 4 Interrogatory Responses, # 16 Exhibit 40. Doe # 5 Interrogatory Responses, # 17 Exhibit 41. Mary Doe Interrogatory Responses, # 18 Exhibit 42. Defendants Responses to Plaintiffs First Interrogatories, # 19 Exhibit 43. Defendants Supplemental Responses to Plaintiffs First Interrogatories and Requests for Production of Documents, # 20 Exhibit 44. Defendants Answers to Plaintiffs First Requests for Admission, # 21 Exhibit 45. MSP SORA Charging Data, # 22 Exhibit 46. MSP SORA Conviction Data, # 23 Exhibit 47. MSP Official Order 79, # 24 Exhibit 48. Tier Notification Letters, # 25 Exhibit 49. SOR Unit Student Safety Zone Cheatsheet, # 26 Exhibit 50. OffenderWatch User Manual, Selected Portions) (Grill, Erik) (Entered: 06/27/2014)

1 Exhibit 25. First Expert Report of Peter Wagner, J.D.

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2 Exhibit 26. Second Expert Report of Peter Wagner, J.D.

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3 Exhibit 27. Expert Report of Anne Yantus, J.D.

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4 Exhibit 28. Expert Report of Richard Stapleton

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5 Exhibit 29. Declaration (Second) of John Doe # 5

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6 Exhibit 30. Declaration (Second) of Mary Doe

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7 Exhibit 31. Amended Declaration of I.G.

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8 Exhibit 32. Declaration of Timothy Poxson

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9 Exhibit 33. Declaration of Joseph Granzotto

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10 Exhibit 34. Summary of Obligations, Disabilities, and Restraints Imposed by SORA

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11 Exhibit 35. Plaintiffs Response to Defendants Interrogatory 11

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12 Exhibit 36. Doe # 1 Interrogatory Responses

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13 Exhibit 37. Doe # 2 Interrogatory Responses

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14 Exhibit 38. Doe # 3 Interrogatory Responses

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15 Exhibit 39. Doe # 4 Interrogatory Responses

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16 Exhibit 40. Doe # 5 Interrogatory Responses

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17 Exhibit 41. Mary Doe Interrogatory Responses

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18 Exhibit 42. Defendants Responses to Plaintiffs First Interrogatories

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19 Exhibit 43. Defendants Supplemental Responses to Plaintiffs First Interrogatori

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20 Exhibit 44. Defendants Answers to Plaintiffs First Requests for Admission

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21 Exhibit 45. MSP SORA Charging Data

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22 Exhibit 46. MSP SORA Conviction Data

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23 Exhibit 47. MSP Official Order 79

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24 Exhibit 48. Tier Notification Letters

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25 Exhibit 49. SOR Unit Student Safety Zone Cheatsheet

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26 Exhibit 50. OffenderWatch User Manual, Selected Portions

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June 27, 2014

June 27, 2014

PACER
92

EXHIBIT Continued re 90 Statement,,,,, by KRISTE ETUE, RICHARD D. SNYDER (Attachments: # 1 Exhibit 51. OffenderWatch Express Description, # 2 Exhibit 52. OffenderWatch Contract, # 3 Exhibit 53. Total Number on SOR by Year, # 4 Exhibit 54. Total Number of Offenders by Tier, # 5 Exhibit 55. Roster of MSP/SOR Unit Staff, # 6 Exhibit 56. Michigan State Police List of SORA Coordinators, # 7 Exhibit 57. Sample SOR Letter to Registrant, # 8 Exhibit 58. MSP Sex Offender Registry and Enforcement Training Powerpoint 2011, # 9 Exhibit 59. Herb Tanner Sex Offender Registry Training 2013 for Prosecutors, # 10 Exhibit 60. Herb Tanner Sex Offender Registry Training 2011 for Prosecutors, # 11 Exhibit 61. Registration Length June/August 2011, # 12 Exhibit 62. Explanation of Duties Form, # 13 Exhibit 63. Doe #2 Michigan State Police Criminal History Print-out, # 14 Exhibit 64. Doe #2 Public Sex Offender Registry Print-Out, # 15 Exhibit 65. Doe #2 DD-214 Certificate of Release or Discharge from Active Duty, # 16 Exhibit 66. Affidavit of Victim in Case of Doe #2, # 17 Exhibit 67. Fiscal Year 2014 SOR Unit Budget, # 18 Exhibit 68. Offender Watch Training Video, Disk 3, Part 1 and Disk 4, Part 1,, # 19 Exhibit 69. Filed Under Seal, # 20 Exhibit 70. Filed Under Seal, # 21 Exhibit 71. Doe v. Thompson, Case No. 12-C-168 (Kan. Division 6, July 2013), # 22 Exhibit 72. The National Conference of State Legislatures, Cost-Benefit Analyses of SORNA Implementation, # 23 Exhibit 73. California AWA Position Statement, # 24 Exhibit 74. Colorado AWA White Paper, # 25 Exhibit 75. Texas Study of Costs to Local Government of Implementing AWA, # 26 Exhibit 76. Senate Fiscal Agency Analysis for Senate Bill 221, # 27 Exhibit 77. Pew Research Center, Search and email still top the list of most popular on-line activities (May 2011)) (Grill, Erik) (Entered: 06/27/2014)

1 Exhibit 51. OffenderWatch Express Description

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2 Exhibit 52. OffenderWatch Contract

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3 Exhibit 53. Total Number on SOR by Year

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4 Exhibit 54. Total Number of Offenders by Tier

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5 Exhibit 55. Roster of MSP/SOR Unit Staff

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6 Exhibit 56. Michigan State Police List of SORA Coordinators

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7 Exhibit 57. Sample SOR Letter to Registrant

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8 Exhibit 58. MSP Sex Offender Registry and Enforcement Training Powerpoint 2011

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9 Exhibit 59. Herb Tanner Sex Offender Registry Training 2013 for Prosecutors

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10 Exhibit 60. Herb Tanner Sex Offender Registry Training 2011 for Prosecutors

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11 Exhibit 61. Registration Length June/August 2011

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12 Exhibit 62. Explanation of Duties Form

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13 Exhibit 63. Doe #2 Michigan State Police Criminal History Print-out

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14 Exhibit 64. Doe #2 Public Sex Offender Registry Print-Out

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15 Exhibit 65. Doe #2 DD-214 Certificate of Release or Discharge from Active D

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16 Exhibit 66. Affidavit of Victim in Case of Doe #2

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17 Exhibit 67. Fiscal Year 2014 SOR Unit Budget

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18 Exhibit 68. Offender Watch Training Video, Disk 3, Part 1 and Disk 4, Part 1,

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19 Exhibit 69. Filed Under Seal

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20 Exhibit 70. Filed Under Seal

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21 Exhibit 71. Doe v. Thompson, Case No. 12-C-168 (Kan. Division 6, July 2013)

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22 Exhibit 72. The National Conference of State Legislatures, Cost-Benefit Analyses

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23 Exhibit 73. California AWA Position Statement

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24 Exhibit 74. Colorado AWA White Paper

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25 Exhibit 75. Texas Study of Costs to Local Government of Implementing AWA

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26 Exhibit 76. Senate Fiscal Agency Analysis for Senate Bill 221

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27 Exhibit 77. Pew Research Center, Search and email still top the list of most pop

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June 27, 2014

June 27, 2014

PACER
93

EXHIBIT Continued re 90 Statement,,,,, by KRISTE ETUE, RICHARD D. SNYDER (Attachments: # 1 Exhibit 78. Karl Hanson Study, # 2 Exhibit 79. Karl Hanson Declaration, # 3 Exhibit 80. Sex Offender Sexual Recidivism Risk Levels Over Time Graph (Hanson), # 4 Exhibit 81. Collateral Damage: Family Members of Registered Sex Offenders, # 5 Exhibit 82. DOJ Evaluation of Sex Offender Residency Restrictions in Michigan and Missouri, # 6 Exhibit 83. SOR Unit Manual, # 7 Exhibit 84. Judgment of Sentence Form CC219b, # 8 Exhibit 85. Doe #2 Order Amending Probation, # 9 Exhibit 86. Doe #3 Order of Probation, # 10 Exhibit 87. MSP Memo re Operation Verify, # 11 Exhibit 88. Legislative Analysis of Public Act 542 (2002), # 12 Exhibit 89. Regional Jail Feasibility Study, # 13 Exhibit 90. State of Michigan Prison Cost, # 14 Exhibit 91. SMART SORNA Substantial Compliance Jurisdictions, # 15 Exhibit 92. Legislative Services Bureau Report on SORA, # 16 Exhibit 93. Michigan State Police News Releases on Sweeps, # 17 Exhibit 94. Michigan Attorney General Letter Re Student Safety Zones, # 18 Exhibit 95. SMART Confirmation of Michigans Substantial Compliance, # 19 Exhibit 96. Byrne Fund Reports 2011, # 20 Exhibit 97. Michigan Senate Bills 76 and 77 Re Expanding Student Safety Zones to Include Daycares, # 21 Exhibit 98. Defendants Second Supplemental Responses to Plaintiffs First Interrogatories and Requests for Production of Documents, # 22 Exhibit 99. Letter Announcing Offender Watch dated 10/24/13, # 23 Exhibit 100. SMART Annual Implementation Review Letter dated 9/17/13, # 24 Exhibit 101. John Doe #1 Requests to Admit, # 25 Exhibit 102. John Doe #2 Requests to Admit, # 26 Exhibit 103. John Doe #3 Requests to Admit, # 27 Exhibit 104. John Doe #4 Requests to Admit, # 28 Exhibit 105. John Doe #5 Requests to Admit, # 29 Exhibit 106. Mary Doe Requests to Admit, # 30 Exhibit 107. SMART letter dated 2/1/11, # 31 Exhibit 108. Federal Register, Vol. 73, No. 128, July 2, 2008, # 32 Exhibit 109. Michigan Sex Offender Registration Legislative Recommendations, # 33 Exhibit 110. SMART Sex Offender Registration and Notification Checklist) (Grill, Erik) (Entered: 06/27/2014)

1 Exhibit 78. Karl Hanson Study

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2 Exhibit 79. Karl Hanson Declaration

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3 Exhibit 80. Sex Offender Sexual Recidivism Risk Levels Over Time Graph (Hanson)

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4 Exhibit 81. Collateral Damage: Family Members of Registered Sex Offenders

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5 Exhibit 82. DOJ Evaluation of Sex Offender Residency Restrictions in Michigan an

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6 Exhibit 83. SOR Unit Manual

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7 Exhibit 84. Judgment of Sentence Form CC219b

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8 Exhibit 85. Doe #2 Order Amending Probation

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9 Exhibit 86. Doe #3 Order of Probation

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10 Exhibit 87. MSP Memo re Operation Verify

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11 Exhibit 88. Legislative Analysis of Public Act 542 (2002)

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12 Exhibit 89. Regional Jail Feasibility Study

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13 Exhibit 90. State of Michigan Prison Cost

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14 Exhibit 91. SMART SORNA Substantial Compliance Jurisdictions

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15 Exhibit 92. Legislative Services Bureau Report on SORA

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16 Exhibit 93. Michigan State Police News Releases on Sweeps

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17 Exhibit 94. Michigan Attorney General Letter Re Student Safety Zones

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18 Exhibit 95. SMART Confirmation of Michigans Substantial Compliance

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19 Exhibit 96. Byrne Fund Reports 2011

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20 Exhibit 97. Michigan Senate Bills 76 and 77 Re Expanding Student Safety Zones to

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21 Exhibit 98. Defendants Second Supplemental Responses to Plaintiffs First Interr

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22 Exhibit 99. Letter Announcing Offender Watch dated 10/24/13

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23 Exhibit 100. SMART Annual Implementation Review Letter dated 9/17/13

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24 Exhibit 101. John Doe #1 Requests to Admit

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25 Exhibit 102. John Doe #2 Requests to Admit

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26 Exhibit 103. John Doe #3 Requests to Admit

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27 Exhibit 104. John Doe #4 Requests to Admit

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28 Exhibit 105. John Doe #5 Requests to Admit

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29 Exhibit 106. Mary Doe Requests to Admit

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30 Exhibit 107. SMART letter dated 2/1/11

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31 Exhibit 108. Federal Register, Vol. 73, No. 128, July 2, 2008

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32 Exhibit 109. Michigan Sex Offender Registration Legislative Recommendations

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33 Exhibit 110. SMART Sex Offender Registration and Notification Checklist

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June 27, 2014

June 27, 2014

PACER
94

EXHIBIT Continued re 90 Statement,,,,, by KRISTE ETUE, RICHARD D. SNYDER (Attachments: # 1 Exhibit 111. SMART National Guidelines for Sex Offender Registration and Notification, # 2 Exhibit 112. House Fiscal Agency Analysis for SB 188, 189, and 206., # 3 Exhibit 113. Public Sex Offender Registry (PSOR) Frequently Asked Questions, # 4 Exhibit 114. PAAM Outline of 2011 SORA Changes, # 5 Exhibit 115. SOR Unit Responses to ACLU, # 6 Exhibit 116. ACLU Dissection of Draft dated 11/3/10, # 7 Exhibit 117. Herb Tanner Sex Offender Registry Training 2009 for Prosecutors, # 8 Exhibit 118. OffenderWatch Home Screen, # 9 Exhibit 119. OffenderWatch Search Screen, # 10 Exhibit 120. Doe #2 OffenderWatch page, # 11 Exhibit 121. OffenderWatch Non-Compliant Offender Search Results, first page, # 12 Exhibit 122. OffenderWatch Search Results from Specified Point, # 13 Exhibit 123. OffenderWatch Individual Registrant Map, # 14 Exhibit 124. OffenderWatch Registration for Email Alerts on Individuals, # 15 Exhibit 125. OffenderWatch Registration for Email Alerts around Locations, # 16 Exhibit 126. MSP Annual Fee Letter dated March 2014, # 17 Exhibit 127. Doe #1 OffenderWatch page, # 18 Exhibit 128. eclaration of Peter Wagner) (Grill, Erik) (Entered: 06/27/2014)

1 Exhibit 111. SMART National Guidelines for Sex Offender Registration and Notific

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2 Exhibit 112. House Fiscal Agency Analysis for SB 188, 189, and 206.

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3 Exhibit 113. Public Sex Offender Registry (PSOR) Frequently Asked Questions

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4 Exhibit 114. PAAM Outline of 2011 SORA Changes

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5 Exhibit 115. SOR Unit Responses to ACLU

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6 Exhibit 116. ACLU Dissection of Draft dated 11/3/10

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7 Exhibit 117. Herb Tanner Sex Offender Registry Training 2009 for Prosecutors

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8 Exhibit 118. OffenderWatch Home Screen

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9 Exhibit 119. OffenderWatch Search Screen

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10 Exhibit 120. Doe #2 OffenderWatch page

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11 Exhibit 121. OffenderWatch Non-Compliant Offender Search Results, first page

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12 Exhibit 122. OffenderWatch Search Results from Specified Point

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13 Exhibit 123. OffenderWatch Individual Registrant Map

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14 Exhibit 124. OffenderWatch Registration for Email Alerts on Individuals

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15 Exhibit 125. OffenderWatch Registration for Email Alerts around Locations

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16 Exhibit 126. MSP Annual Fee Letter dated March 2014

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17 Exhibit 127. Doe #1 OffenderWatch page

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18 Exhibit 128. eclaration of Peter Wagner

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June 27, 2014

June 27, 2014

PACER
95

SEALED EXHIBIT Ex 69 and Ex 70 re 90 Statement,,,,, by KRISTE ETUE, RICHARD D. SNYDER. (Attachments: # 1 Exhibit 69. Doe # 4 filed under seal, # 2 Exhibit 70. Doe #4 filed under seal) (Grill, Erik) (Entered: 06/27/2014)

June 27, 2014

June 27, 2014

PACER
96

MOTION for Judgment by Mary Doe, John Doe #5, John Does. (Aukerman, Miriam) (Entered: 06/27/2014)

June 27, 2014

June 27, 2014

PACER
97

RESPONSE to 96 MOTION for Judgment and Combined Rule 52 Motion filed by KRISTE ETUE, RICHARD D. SNYDER. (Attachments: # 1 Index of Exhibits Index of Exhibits, # 2 Exhibit A. State v. Husband, 2008 Ariz. App. Unpub. LEXIS 44, Docket #1 CA-CR 07-0102 (2008), # 3 Exhibit B. School Cuts Spur Michigan Conflict, Wall St. Journal, April 4, 2011, p 2, # 4 Exhibit C. Mueller v. Raemisch, ___ F.3d ___, 11-16 (7th Cir. 2014)) (Grill, Erik) (Entered: 07/09/2014)

1 Index of Exhibits Index of Exhibits

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2 Exhibit A. State v. Husband, 2008 Ariz. App. Unpub. LEXIS 44, Docket #1 CA-

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3 Exhibit B. School Cuts Spur Michigan Conflict, Wall St. Journal, April 4, 2011,

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4 Exhibit C. Mueller v. Raemisch, ___ F.3d ___ , 11-16 (7th Cir. 2014)

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July 9, 2014

July 9, 2014

PACER
98

ERRATA Sheet re: 94 Exhibit,,,,, filed by RICHARD D. SNYDER, KRISTE ETUE. by KRISTE ETUE, RICHARD D. SNYDER (Attachments: # 1 Exhibit 127. DOE #1S OFFENDERWATCH PAGE) (Grill, Erik) (Entered: 07/15/2014)

1 Exhibit 127. DOE #1S OFFENDERWATCH PAGE

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July 15, 2014

July 15, 2014

PACER
99

RESPONSE to 97 Response to Motion, 96 MOTION for Judgment Defendants' Rule 52 Motion and Reply on Plaintiffs' Motion for Judgment by All Plaintiffs. (Reingold, Paul) (Entered: 07/23/2014)

July 23, 2014

July 23, 2014

PACER
100

REPLY to Response re 96 MOTION for Judgment filed by KRISTE ETUE, RICHARD D. SNYDER. (Grill, Erik) (Entered: 08/06/2014)

Aug. 6, 2014

Aug. 6, 2014

PACER

Case Details

State / Territory: Michigan

Case Type(s):

Criminal Justice (Other)

Special Collection(s):

Multi-LexSum (in sample)

Key Dates

Filing Date: March 6, 2012

Closing Date: 2018

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Michigan residents who have been retroactively required to comply with Michigan's Sex Offender Registration Act (SORA) as amended on July 1, 2011. These plaintiffs were all charged or convicted before the amended SORA came into effect.

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

Michigan Clinical Law Program

ACLU of Michigan

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

State of Michigan, State

Michigan State Police, State

Defendant Type(s):

Jurisdiction-wide

Law-enforcement

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Due Process

Ex Post Facto

Freedom of speech/association

Availably Documents:

Trial Court Docket

Complaint (any)

Injunctive (or Injunctive-like) Relief

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Declaratory Judgment

Source of Relief:

Litigation

Issues

General:

Sex offender regulation