Case: United States v. Erie County

1:09-cv-00849 | U.S. District Court for the Western District of New York

Filed Date: Sept. 30, 2009

Case Ongoing

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Case Summary

On September 30, 2009, following a two year investigation, the United States Department of Justice (DOJ) filed this lawsuit in the U.S. District Court of the Western District of New York under the Civil Rights of Institutionalized Persons Act of 1980 (CRIPA) against Erie County. The DOJ asked the court for declaratory and injunctive relief, claiming that confinement conditions at Erie County Holding Center (ECHC) and the Erie County Correction Facility (ECCF) violated the federal constitutional rights of inmates incarcerated there. The complaint and the attached findings letter detailed the defendants' alleged failures in the areas of protection from harm, environmental safety, medical care, mental health care, and suicide prevention.

The court (Judge William M. Skretny) ordered expedited discovery related to suicide prevention and mental health treatment protocols at ECHC. 2010 WL 986505 (W.D.N.Y. Mar. 17, 2010). The court subsequently granted additional motions to expedite discovery, granted in part and denied in part the plaintiff's motion to compel, and granted in part and denied in part the defendants' motion for a protective order. 2010 WL 1038650 (W.D.N.Y. Mar. 19, 2010).

On June 22, 2010, the court approved the parties' stipulated settlement agreement concerning only the suicide prevention and related mental health claims. As part of this stipulation, the parties agreed to select a Joint Compliance Officer (JCO) with relevant experience in the field of corrections, mental health care, suicide prevention, or medical care, to file with the court and provide the parties with reports evaluating the extent to which the defendants were in compliance with each substantive provision of the settlement. These reports were to be issued every four months, after a two-week comment period afforded to the parties.

On July 9, 2010, the court denied the defendants' motion to dismiss, holding that CRIPA was not unconstitutional as applied to the defendants. However, despite technical compliance, the original complaint violated the spirit underlying Rules 8 and 10 of the Federal Rules of Civil Procedure. Consequently, the court ordered the DOJ to file an amended complaint within 14 days. 724 F. Supp. 2d 357 (W.D.N.Y. 2010). On July 23, 2010, the DOJ filed an amended complaint.

On August 25, 2011, the court ordered a stipulated dismissal of the action agreed upon by the parties. This second Stipulated Order of Dismissal resolved the remaining claims, including protection from harm, provision of medical and mental health treatment, and environmental health and safety. This stipulation recognized that, without any admission of liability on their part, the defendants would continue developing and implementing policies, practices, and procedures to address concerns at ECHS and ECCF. The Stipulated Order stated general goals with respect to each of the areas of concern raised, as well as more specific actions for achieving these goals, such as procedure development, additional training and staffing, and enhanced record keeping.

On June 21, 2012, the New York Civil Liberties Union (NYCLU) moved for leave to intervene and to unseal the the previously filed compliance reports and vacate the standing order permitting future sealed filings. The court denied the motion to unseal the records and vacate the standing order and terminated NYCLU from the case. 2013 WL 4679070 (W.D.N.Y. Aug. 30, 2013). NYCLU appealed this decision to the United States Court of Appeals for the Second Circuit (13-3653).

On August 18, 2014, the Court of Appeals reversed the District Court, granting NYCLU's motion to intervene and unseal the independently filed TCC records. 763 F.3d 235. On October 30, 2014, the District Court granted in part and denied in part NYCLU's motion. The court denied NYCLU's motion to unseal the semiannual compliance reports filed by the defendant and denied a motion to vacate the standing order, which allowing the sealing of future compliance reports.

Following the court's order, there was a series of document requests and unsealing. This is process is still ongoing. As of May, 2020 the monitor appointed in the settlement agreement was still conducting site visits to ensure compliance with the stipulated order of dismissal.

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Summary Authors

Jessica Kincaid (4/12/2014)

Brent Winslow (11/6/2016)

Keagan Potts (3/13/2019)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/4909358/parties/united-states-v-erie-county-new-york/

Judge(s)

Calabresi, Guido (Connecticut)

Lynch, Gerard E. (New York)

McCarthy, Jeremiah J. (New York)

Skretny, William M. (New York)

Attorneys(s) for Plaintiff

Bagenstos, Samuel R. (District of Columbia)

Coon, Laura (District of Columbia)

Fleisher, Aaron S (District of Columbia)

Fleming, Mary Pat (New York)

Green, Cheryl A (New York)

Hart, Charles W. Jr. (District of Columbia)

Judge(s)

Calabresi, Guido (Connecticut)

Lynch, Gerard E. (New York)

McCarthy, Jeremiah J. (New York)

Skretny, William M. (New York)

Attorneys(s) for Plaintiff

Bagenstos, Samuel R. (District of Columbia)

Coon, Laura (District of Columbia)

Fleisher, Aaron S (District of Columbia)

Fleming, Mary Pat (New York)

Green, Cheryl A (New York)

Hart, Charles W. Jr. (District of Columbia)

Hochul, William J. Jr. (New York)

Jansen, Regina (District of Columbia)

King, Loretta (District of Columbia)

Lareau, Alyssa Connell (District of Columbia)

Lopez, Zazy I (District of Columbia)

Mehltretter, Kathleen M. (New York)

Myrthil, Marlysha (District of Columbia)

Perez, Thomas E. (District of Columbia)

Preston, Judy C. (District of Columbia)

Rifkin, Lori Ellen (District of Columbia)

Saucedo, Luis E. (District of Columbia)

Smith, Jonathan Mark (District of Columbia)

Weiss, Daniel H. (District of Columbia)

Attorneys(s) for Defendant

Colby, Jeremy A (New York)

Kirkpatrick, Thomas F Jr. (New York)

Liebenow, Brian R (New York)

Parker, Michelle M (New York)

Sleight, David J (New York)

Wheaton, Kristin Klein (New York)

Other Attorney(s)

Dunn, Christopher (New York)

Eisenberg, Arthur (New York)

Stoughton, Corey (New York)

Attorney Contact Information via CourtListener

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Documents in the Clearinghouse

	Document
1:09-cv-00849	Docket [PACER]	Nov. 29, 2018	Nov. 29, 2018 Docket
1:09-cv-00849	Re: CRIPA Investigation of the Erie County Holding Center and the Erie County Correctional Facility USA v. Erie County No Court	July 15, 2009	July 15, 2009 Findings Letter/Report
1 1:09-cv-00849	Complaint USA v. Erie County	Sept. 30, 2009	Sept. 30, 2009 Complaint
42 1:09-cv-00849	Decision and Order USA v. Erie County	March 6, 2010	March 6, 2010 Order/Opinion
54 1:09-cv-00849	Decision and Order USA v. Erie County	March 17, 2010	March 17, 2010 Order/Opinion
89-2 1:09-cv-00849	Stipulated Settlement Agreement and Order Concerning Suicide Prevention and Related Mental Health Issues U.S. v. Erie County	June 18, 2010	June 18, 2010 Settlement Agreement
91 1:09-cv-00849	Order Approving Stipulated Settlement Agreement Concerning Suicide Prevention and Related Mental Health Issues USA v. Erie County	June 22, 2010	June 22, 2010 Order/Opinion
94 1:09-cv-00849	Decision and Order USA v. Erie County	July 9, 2010	July 9, 2010 Order/Opinion
97 1:09-cv-00849	Amended Complaint USA v. Erie County	July 23, 2010	July 23, 2010 Complaint
225-1 1:09-cv-00849	Stipulated Order of Dismissal U.S. v. Erie County	Aug. 18, 2011	Aug. 18, 2011 Order/Opinion

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Docket

See docket on RECAP: https://www.courtlistener.com/docket/4909358/united-states-v-erie-county-new-york/

Last updated May 27, 2023, 3:20 a.m.

ECF Number	Description	Date	Link Date / Link
1	COMPLAINT against Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier, filed by United States of America. (Attachments: #(1) Continuance of Exhibits.) (DLC) (Entered: 09/30/2009) 2 Continuance of Exhibits View on PACER	Sept. 30, 2009	Sept. 30, 2009 PACER
2	AUTOMATIC REFERRAL to Mediation. (DLC) (Entered: 09/30/2009)	Sept. 30, 2009	Sept. 30, 2009 PACER
3	NOTICE of Appearance by Mary Pat Fleming on behalf of United States of America (Fleming, Mary) (Entered: 09/30/2009)	Sept. 30, 2009	Sept. 30, 2009 PACER
4	AFFIDAVIT of Service for Summons & Complaint served on Barbara Leary, First Deputy Superintendent Erie County Holding Center on October 1, 2009, filed by United States of America. (Attachments: # 1 Exhibit A&B)(Fleming, Mary) (Entered: 10/19/2009) 2 Exhibit A&B View on PACER	Oct. 19, 2009	Oct. 19, 2009 PACER
5	AFFIDAVIT of Service for Summons & Complaint served on Timothy B. Howard, Erie County Sheriff on October 1, 2009, filed by United States of America. (Attachments: # 1 Exhibit A&B)(Fleming, Mary) (Entered: 10/19/2009) 2 Exhibit A&B View on PACER	Oct. 19, 2009	Oct. 19, 2009 PACER
6	AFFIDAVIT of Service for Summons & Complaint served on Donald Livingston, First Deputy Superintendent, Erie County Correctional Facility on October 1, 2009, filed by United States of America. (Attachments: # 1 Exhibit A&B)(Fleming, Mary) (Entered: 10/19/2009) 2 Exhibit A&B View on PACER	Oct. 19, 2009	Oct. 19, 2009 PACER
7	AFFIDAVIT of Service for Summons & Complaint served on The Honorable Christopher Collins, Erie County Executive on October 1, 2009, filed by United States of America. (Attachments: # 1 Exhibit A&B)(Fleming, Mary) (Entered: 10/19/2009) 2 Exhibit A&B View on PACER	Oct. 19, 2009	Oct. 19, 2009 PACER
8	AFFIDAVIT of Service for Summons & Complaint served on Erie County, New York c/o Christopher Collins on October 1, 2009, filed by United States of America. (Attachments: # 1 Exhibit A&B)(Fleming, Mary) (Entered: 10/19/2009) 2 Exhibit A&B View on PACER	Oct. 19, 2009	Oct. 19, 2009 PACER
9	AFFIDAVIT of Service for Summons & Complaint served on Anthony Billittier IV, M.D., Erie County Health Commissioner on October 1, 2009, filed by United States of America. (Attachments: # 1 Exhibit A&B)(Fleming, Mary) (Entered: 10/19/2009) 2 Exhibit A&B View on PACER	Oct. 19, 2009	Oct. 19, 2009 PACER
10	AFFIDAVIT of Service for Summons & Complaint served on Robert Koch, Superintendent, Administrative Services Division, Jail Management Division on October 1, 2009, filed by United States of America. (Attachments: # 1 Exhibit A&B)(Fleming, Mary) (Entered: 10/19/2009) 2 Exhibit A&B View on PACER	Oct. 19, 2009	Oct. 19, 2009 PACER
11	AFFIDAVIT of Service for Summons & Complaint served on Richard T. Donovan, Undersheriff on October 1, 2009, filed by United States of America. (Attachments: # 1 Exhibit A&B)(Fleming, Mary) (Entered: 10/19/2009) 2 Exhibit A&B View on PACER	Oct. 19, 2009	Oct. 19, 2009 PACER
12	ORDER GRANTING Defendants' request to extend the page limit to 40 pages. Signed by William M. Skretny U.S.D.J. on 10/21/2009. (MEAL) (Entered: 10/21/2009)	Oct. 21, 2009	Oct. 21, 2009 PACER
13	MOTION to Dismiss the Complaint by Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier.(Wheaton, Kristin) (Entered: 10/21/2009)	Oct. 21, 2009	Oct. 21, 2009 PACER
14	DECLARATION signed by Cheryl A. Green re 13 MOTION to Dismiss the Complaint filed by Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier. (Attachments: # 1 Exhibit A - August 2009 letters, # 2 Exhibit B - 091009 response letter, # 3 Exhibit C - COC lawsuit Ex A-U, # 4 Exhibit C - contd- COC lawsuit Ex V-TT)(Wheaton, Kristin) (Entered: 10/21/2009) 2 Exhibit A - August 2009 letters View on PACER 3 Exhibit B - 091009 response letter View on PACER 4 Exhibit C - COC lawsuit Ex A-U View on PACER 5 Exhibit C - contd- COC lawsuit Ex V-TT View on PACER	Oct. 21, 2009	Oct. 21, 2009 PACER
15	MEMORANDUM IN SUPPORT re 14 Declaration, 13 MOTION to Dismiss the Complaint byTimothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier. (Attachments: # 1 Exhibit A - City of Columbus case)(Wheaton, Kristin) (Entered: 10/21/2009) 2 Exhibit A - City of Columbus case View on PACER	Oct. 21, 2009	Oct. 21, 2009 PACER
16	NOTICE of Appearance by Cheryl A. Green on behalf of Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier. (DLC) (Entered: 10/27/2009)	Oct. 23, 2009	Oct. 23, 2009 PACER
17	TEXT SCHEDULING ORDER on Defendants' 13 Motion to Dismiss. Response due by 11/23/2009. Reply due by 12/7/2009. Oral Argument is scheduled for 12/16/2009 at 2:00 p.m. SO ORDERED. Issued by William M. Skretny U.S.D.J. on 10/29/2009. (MEAL) (Entered: 11/01/2009)	Nov. 1, 2009	Nov. 1, 2009 PACER
18	ORDER GRANTING the Plaintiff's request for a page extension. Signed by William M. Skretny U.S.D.J. on 11/18/2009. (MEAL) (Entered: 11/19/2009)	Nov. 19, 2009	Nov. 19, 2009 PACER
19	RESPONSE in Opposition re 13 MOTION to Dismiss the Complaint filed by United States of America. (Attachments: # 1 Supplement Declaration of United States Attorney)(Lopez, Zazy) (Entered: 11/23/2009) 2 Supplement Declaration of United States Attorney View on PACER	Nov. 23, 2009	Nov. 23, 2009 PACER
20	NOTICE by United States of America of Appearance by Samuel R. Bagenstos (Hart, Charles) (Entered: 12/04/2009)	Dec. 4, 2009	Dec. 4, 2009 PACER
21	REPLY/RESPONSE to re 19 Response in Opposition to Motion filed by Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier. (Wheaton, Kristin) (Entered: 12/07/2009)	Dec. 7, 2009	Dec. 7, 2009 PACER
22	ORDER GRANTING page extension request. Signed by William M. Skretny U.S.D.J. on 12/7/2009. (MEAL) (Entered: 12/08/2009)	Dec. 8, 2009	Dec. 8, 2009 PACER
23	Minute Entry for proceedings held before William M. Skretny U.S.D.J.: Oral Argument held on 12/16/2009 on Defendants' 13 Motion to Dismiss the Complaint. Court reserves decision. For the pltf. - Samuel R. Bagenstos, Mary Roach, Zazy Ivonne Lopez. For the defts. - Cheryl Green, Kristin Klein Wheaton. (Court Reporter Michelle McLaughlin.) (MEAL) (Entered: 12/20/2009)	Dec. 16, 2009	Dec. 16, 2009 PACER
24	NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Proceedings held on December 16, 2009, before Judge William M. Skretny. Court Reporter/Transcriber Michelle L. McLaughlin, Telephone number 716-332-3560. 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.. Redaction Request due 2/11/2010. Redacted Transcript Deadline set for 2/22/2010. Release of Transcript Restriction set for 4/21/2010. (DLC) (Entered: 01/21/2010)	Jan. 21, 2010	Jan. 21, 2010 PACER
25	MOTION to Expedite Discovery by United States of America.(Lareau, Alyssa) (Entered: 02/04/2010)	Feb. 4, 2010	Feb. 4, 2010 PACER
26	MOTION to Expedite Discovery, Memorandum in Support by United States of America.(Lareau, Alyssa) (Entered: 02/04/2010)	Feb. 4, 2010	Feb. 4, 2010 PACER
27	MOTION to Expedite Discovery, Declaration of Aaron Fleisher by United States of America. (Attachments: # 1 Exhibit Proposed Interrogatories, # 2 Exhibit Proposed Document Requests, # 3 Exhibit Proposed Request for Entry and Inspection)(Lareau, Alyssa) (Entered: 02/04/2010) 2 Exhibit Proposed Interrogatories View on PACER 3 Exhibit Proposed Document Requests View on PACER 4 Exhibit Proposed Request for Entry and Inspection View on PACER	Feb. 4, 2010	Feb. 4, 2010 PACER
28	MOTION to Expedite Discovery, Declaration of Lindsay M. Hayes by United States of America. (Attachments: # 1 Exhibit Curriculum Vitae of Lindsay M. Hayes, # 2 Exhibit List of Documents Reviewed)(Lareau, Alyssa) (Entered: 02/04/2010) 2 Exhibit Curriculum Vitae of Lindsay M. Hayes View on PACER 3 Exhibit List of Documents Reviewed View on PACER	Feb. 4, 2010	Feb. 4, 2010 PACER
29	MOTION to Expedite Discovery by United States of America.(Lareau, Alyssa) (Entered: 02/05/2010)	Feb. 5, 2010	Feb. 5, 2010 PACER
30	Memorandum in Support to expedite by United States of America.(Lareau, Alyssa) Modified on 2/17/2010 (DLC). (Entered: 02/05/2010)	Feb. 5, 2010	Feb. 5, 2010 PACER
31	TEXT SCHEDULING ORDER on Plaintiff's 29 Motion to Expedite Discovery. Response due by 2/23/2010. Reply due by 2/26/2010. SO ORDERED. Issued by William M. Skretny, Chief Judge U.S.D.C. on 2/16/2010. (MEAL) (Entered: 02/17/2010)	Feb. 17, 2010	Feb. 17, 2010 PACER
32	DECLARATION signed by Robert A. Koch, Jr. re 29 MOTION to Expedite Discovery, 25 MOTION to Expedite Discovery filed by Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier in opposition to the DOJ's motion to expedite discovery filed by Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier. (Attachments: # 1 Exhibit A - Suicide Screening Policy, # 2 Exhibit B - Training materials, # 3 Exhibit C - Constant Observation policy, # 4 Exhibit D - Technical Assistance Report, # 5 Exhibit E - NCCHC standards on suicide prevention)(Wheaton, Kristin) (Entered: 02/23/2010) 2 Exhibit A - Suicide Screening Policy View on PACER 3 Exhibit B - Training materials View on PACER 4 Exhibit C - Constant Observation policy View on PACER 5 Exhibit D - Technical Assistance Report View on PACER 6 Exhibit E - NCCHC standards on suicide prevention View on PACER	Feb. 23, 2010	Feb. 23, 2010 PACER
33	DECLARATION signed by Cheryl A. Green re 29 MOTION to Expedite Discovery, 25 MOTION to Expedite Discovery filed by Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier in opposition to the DOJ's motion to expedite discovery filed by Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier. (Wheaton, Kristin) (Entered: 02/24/2010)	Feb. 23, 2010	Feb. 23, 2010 PACER
34	MEMORANDUM in Opposition re 29 MOTION to Expedite Discovery, 30 MOTION to Expedite Discovery, Memorandum in Support, 25 MOTION to Expedite Discovery, 28 MOTION to Expedite Discovery, Declaration of Lindsay M. Hayes, 26 MOTION to Expedite Discovery, Memorandum in Support, 27 MOTION to Expedite Discovery, Declaration of Aaron Fleisher filed by Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier. (Wheaton, Kristin) (Entered: 02/24/2010)	Feb. 24, 2010	Feb. 24, 2010 PACER
35	ORDER GRANTING Plaintiff's page extension request. Signed by William M. Skretny, Chief Judge U.S.D.C. on 2/25/2010. (MEAL) (Entered: 02/26/2010)	Feb. 26, 2010	Feb. 26, 2010 PACER
36	REPLY to Response to Motion re 29 MOTION to Expedite Discovery filed by United States of America. (Hart, Charles) (Entered: 02/26/2010)	Feb. 26, 2010	Feb. 26, 2010 PACER
37	DECLARATION signed by Zazy I. Lopez re 36 Reply to Response to Motion filed by United States of America filed by United States of America. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Hart, Charles) (Entered: 02/26/2010) 2 Exhibit A View on PACER 3 Exhibit B View on PACER	Feb. 26, 2010	Feb. 26, 2010 PACER
38	DECLARATION signed by Lindsay M. Hayes re 36 Reply to Response to Motion filed by United States of America filed by United States of America. (Hart, Charles) (Entered: 02/26/2010)	Feb. 26, 2010	Feb. 26, 2010 PACER
39	DECLARATION signed by James E. Lawrence re 36 Reply to Response to Motion filed by United States of America filed by United States of America. (Attachments: # 1 Exhibit 1)(Hart, Charles) (Entered: 02/26/2010) 2 Exhibit 1 View on PACER	Feb. 26, 2010	Feb. 26, 2010 PACER
40	REPLY to Response to Motion re 29 MOTION to Expedite Discovery filed by United States of America. (Lopez, Zazy) (Entered: 03/01/2010)	March 1, 2010	March 1, 2010 PACER
41	MOTION for Leave to File Supplemental Declaration by United States of America. (Attachments: # 1 Proposed Declaration of Zazy I. Lopez)(Lopez, Zazy) (Entered: 03/04/2010) 2 Proposed Declaration of Zazy I. Lopez View on PACER	March 4, 2010	March 4, 2010 PACER
42	DECISION AND ORDER GRANTING the Justice Department's 29 Motion for Expedited Discovery; DIRECTING the defendants to respond to the [27-2] First Set of Interrogatories within 14 days of service; DIRECTING the defendants to respond to the [27-3] First Request for Production of Documents within 14 days of service; DIRECTING the defendants to respond to the [27-4] First Request for Entry and Inspection within 14 days of service; DIRECTING the defendants to permit the Justice Department's attorneys and consultants to enter and inspect the ECHC on March 22 and 23, 2010, for the purposes stated in the [27-4] First Request for Entry and Inspection; GRANTING the Justice Department's 41 Motion to File a Supplemental Declaration. Signed by William M. Skretny, Chief Judge U.S.D.C. on 3/6/2010. (MEAL) (Entered: 03/06/2010)	March 6, 2010	March 6, 2010 PACER
43	MOTION to Compel Defendants' Compliance with the Court's March 6, 2010 Decision and Order by United States of America. (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Lopez, Zazy) (Entered: 03/11/2010) 2 Memorandum in Support View on PACER 3 Text of Proposed Order View on PACER	March 11, 2010	March 11, 2010 PACER
44	DECLARATION signed by Zazy I. Lopez re 43 MOTION to Compel Defendants' Compliance with the Court's March 6, 2010 Decision and Order filed by United States of America. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Lopez, Zazy) (Entered: 03/11/2010) 2 Exhibit A View on PACER 3 Exhibit B View on PACER 4 Exhibit C View on PACER	March 11, 2010	March 11, 2010 PACER
45	MOTION to Expedite Hearing of Motion to Compel (Docket No. 43) by United States of America.(Lopez, Zazy) (Entered: 03/11/2010)	March 11, 2010	March 11, 2010 PACER
46	MOTION for Protective Order and for a FRCP 16 conference by Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier.(Wheaton, Kristin) (Entered: 03/12/2010)	March 12, 2010	March 12, 2010 PACER
47	AFFIDAVIT re 46 MOTION for Protective Order and for a FRCP 16 conference by Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier. (Attachments: # 1 Exhibit A - County Response to FRCP 34 Noticeo of Entry and Inspection, # 2 Exhibit B - Consent Decree from Carey case)(Wheaton, Kristin) (Entered: 03/12/2010) 2 Exhibit A - County Response to FRCP 34 Noticeo of Entry and Inspection View on PACER 3 Exhibit B - Consent Decree from Carey case View on PACER	March 12, 2010	March 12, 2010 PACER
48	MEMORANDUM IN SUPPORT re 47 Affidavit, 46 MOTION for Protective Order and for a FRCP 16 conference byTimothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier. (Wheaton, Kristin) (Entered: 03/12/2010)	March 12, 2010	March 12, 2010 PACER
49	MOTION to Expedite Hearing under Local Rule 7.1(d) on Motion for Protective Order and for FRCP 16 conference by Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier.(Wheaton, Kristin) (Entered: 03/12/2010)	March 12, 2010	March 12, 2010 PACER
50	RESPONSE to Motion re 46 MOTION for Protective Order and for a FRCP 16 conference filed by United States of America. (Lopez, Zazy) (Entered: 03/15/2010)	March 15, 2010	March 15, 2010 PACER
51	DECLARATION signed by Zazy I. Lopez re 43 MOTION to Compel Defendants' Compliance with the Court's March 6, 2010 Decision and Order filed by United States of America (Supplemental). (Attachments: # 1 Text of Proposed Order)(Lopez, Zazy) (Entered: 03/15/2010) 2 Text of Proposed Order View on PACER	March 15, 2010	March 15, 2010 PACER
52	DECLARATION signed by Cheryl A. Green re 51 Declaration, 50 Response to Motion filed by Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier in further support of the defendants motion for a protective order filed by Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier. (Attachments: # 1 Exhibit A - Newspaper article)(Wheaton, Kristin) (Entered: 03/16/2010) 2 Exhibit A - Newspaper article View on PACER	March 16, 2010	March 16, 2010 PACER
53	REPLY/RESPONSE to re 51 Declaration, 50 Response to Motion reply memorandum of law on behalf of the defendants filed by Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier. (Wheaton, Kristin) (Entered: 03/16/2010)	March 16, 2010	March 16, 2010 PACER
54	DECISION AND ORDER GRANTING the parties' 45 49 Motions to Expedite; GRANTING in part and DENYING in part the Justice Department's 43 Motion to Compel; GRANTING in part and DENYING in part the Defendants' 46 Motion for Protective Order. Signed by William M. Skretny, Chief Judge U.S.D.C. on 3/17/2010. (MEAL) (Entered: 03/17/2010)	March 17, 2010	March 17, 2010 RECAP
55	TEXT REFERRAL ORDER - Hon. Jeremiah J. McCarthy, United States Magistrate Judge, is hereby designated to act in this case as follows: Pursuant to 28 U.S.C. § 636(b)(1)(A), all pre-trial matters in this case are referred to the above-named United States Magistrate Judge, including but not limited to: (1) conduct of a scheduling conference and entry of a scheduling order pursuant to Fed. R. Civ. P. 16, (2) hearing and disposition of all non-dispositive motions or applications, (3) supervision of discovery, and (4) supervision of all procedural matters involving the aforementioned or involving the preparation of the case or any matter therein for consideration by the District Judge. The Magistrate Judge shall not hear and report upon dispositive motions for the consideration of the District Judge pursuant to 28 U.S.C. § 636(b)(1)(B) and (C), unless further ordered by this Court. All motions or applications shall be filed with the Clerk and made returnable before the Magistrate Judge. The parties are encouraged to consider the provisions of 28 U.S.C. § 636(c) governing consent to either partial or complete disposition of the case, including trial if necessary, by the Magistrate Judge. Consent forms are available from the office of the Magistrate Judge or the office of the Clerk of Court. IT IS SO ORDERED. Issued by Judge William M. Skretny on 3/17/2010. (JCD) (Entered: 03/17/2010)	March 17, 2010	March 17, 2010 PACER
56	MOTION to Stay re 42 Order on Motion to Expedite,, Order on Motion for Leave to File,,,,,,,,, 54 Order, Terminate Motions, Set Hearings,,, Partial Stay by Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier.(Wheaton, Kristin) (Entered: 03/18/2010)	March 18, 2010	March 18, 2010 PACER
57	AFFIDAVIT re 56 MOTION to Stay re 42 Order on Motion to Expedite,, Order on Motion for Leave to File,,,,,,,,, 54 Order, Terminate Motions, Set Hearings,,, Partial Stay MOTION to Stay re 42 Order on Motion to Expedite,, Order on Motion for Leave to File,,,,,,,,, 54 Order, Terminate Motions, Set Hearings,,, Partial Stay by Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier. (Wheaton, Kristin) (Entered: 03/18/2010)	March 18, 2010	March 18, 2010 PACER
58	MEMORANDUM IN SUPPORT re 56 MOTION to Stay re 42 Order on Motion to Expedite,, Order on Motion for Leave to File,,,,,,,,, 54 Order, Terminate Motions, Set Hearings,,, Partial Stay MOTION to Stay re 42 Order on Motion to Expedite,, Order on Motion for Leave to File,,,,,,,,, 54 Order, Terminate Motions, Set Hearings,,, Partial Stay byTimothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier. (Wheaton, Kristin) (Entered: 03/18/2010)	March 18, 2010	March 18, 2010 PACER
59	MOTION to Expedite Hearing on Motion for Partial Stay by Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier.(Wheaton, Kristin) (Entered: 03/18/2010)	March 18, 2010	March 18, 2010 PACER
60	TEXT ORDER. IT HEREBY IS ORDERED THAT Defendants' 59 Motion to Expedite its 56 Motion to Stay is GRANTED. Plaintiff shall file its response to Defendants' 56 Motion to Stay by 10:00 a.m. on March 19, 2010, at which time the motion will be taken under advisement. SO ORDERED. Issued by William M. Skretny, Chief Judge U.S.D.C. on 3/18/2010. (MEAL) (Entered: 03/18/2010)	March 18, 2010	March 18, 2010 PACER
61	MEMORANDUM in Opposition re 56 MOTION to Stay re 42 Order on Motion to Expedite,, Order on Motion for Leave to File,,,,,,,,, 54 Order, Terminate Motions, Set Hearings,,, Partial Stay MOTION to Stay re 42 Order on Motion to Expedite,, Order on Motion for Leave to File,,,,,,,,, 54 Order, Terminate Motions, Set Hearings,,, Partial Stay filed by United States of America. (Lopez, Zazy) (Entered: 03/19/2010)	March 19, 2010	March 19, 2010 PACER
62	DECISION AND ORDER DENYING Defendants' 56 Motion to Stay. Signed by William M. Skretny, Chief Judge U.S.D.C. on 3/19/2010. (MEAL) (Entered: 03/19/2010)	March 19, 2010	March 19, 2010 RECAP
63	Minute Entry for proceedings held before Hon. Jeremiah J. McCarthy: Rule 16 Conference re: facility inspections and interviews held on 3/19/2010. Participants: Mary Pat Fleming/Mary Roach for Plaintiff; Aaron Saul Fleisher, Zazy Ivonne Lopez, Daniel H. Weiss (via telephone) for Plaintiff; Cheryl Green/Kristin Klein Wheaton for Defendants. (DAZ) (Entered: 03/19/2010)	March 19, 2010	March 19, 2010 PACER
64	Minute Entry for proceedings held before Hon. Jeremiah J. McCarthy: Telephonic Status Conference re dispute held on 3/22/2010. Participants: Mary Pat Fleming, Daniel H. Weiss for Plaintiff; Cheryl A. Green, Kristin Klein Wheaton for Defendants. (DAZ) (Entered: 03/22/2010)	March 22, 2010	March 22, 2010 PACER
65	MEMORANDUM in Opposition re 56 MOTION to Stay re 42 Order on Motion to Expedite,, Order on Motion for Leave to File,,,,,,,,, 54 Order, Terminate Motions, Set Hearings,,, Partial Stay MOTION to Stay re 42 Order on Motion to Expedite,, Order on Motion for Leave to File,,,,,,,,, 54 Order, Terminate Motions, Set Hearings,,, Partial Stay filed by United States of America. (Lopez, Zazy) (Entered: 03/25/2010)	March 25, 2010	March 25, 2010 PACER
66	ORDER OF PRELIMINARY PRETRIAL CONFERENCE set for 4/23/2010 at 02:30 PM before Hon. Jeremiah J. McCarthy. Signed by Hon. Jeremiah J. McCarthy on 3/26/10. (DAZ) (Entered: 03/29/2010)	March 26, 2010	March 26, 2010 PACER
67	Joint motion to extend the deposition and notice deadlines of Judge Skretny's March 17, 2010 Decision and Order (Zazy I. Lopez) (Filed at the request of Hon. Jeremiah J. McCarthy). (DAZ) (Entered: 03/30/2010)	March 30, 2010	March 30, 2010 PACER
68	ORDER granting 67 Joint Motion to extend the deposition and notice deadlines of Judge Skretny's March 17, 2010 Decision and Order. Signed by Hon. Jeremiah J. McCarthy on 3/30/10. (DAZ) (Entered: 03/30/2010)	March 30, 2010	March 30, 2010 PACER
69	Parties' joint motion to adjourn the Preliminary Pretrial Conference (Zazy I. Lopez)(Filed at the request of Hon. Jeremiah J. McCarthy). (DAZ) (Entered: 04/01/2010)	April 1, 2010	April 1, 2010 PACER
70	TEXT ORDER : The parties' motion to adjourn the preliminary pretrial conference 69 is GRANTED. The April 23, 2010 preliminary pretrial conference is converted to a status conference. The parties may still participate via telephone by providing the court with telephone numbers where they can be contacted. The court will initiate the call. SO ORDERED. Issued by Hon. Jeremiah J. McCarthy on 4/1/10. (DAZ) (Entered: 04/01/2010)	April 1, 2010	April 1, 2010 PACER
71	NOTICE by United States of America of Appearance by Luis E. Saucedo (Hart, Charles) (Entered: 04/19/2010)	April 19, 2010	April 19, 2010 PACER
72	Minute Entry for proceedings held before Hon. Jeremiah J. McCarthy: Status Conference re discovery issues held on 4/23/2010. Participants: Mary Pat Fleming, Luis Saucedo and Zazy Lopez for Plaintiff; Cheryl Green and Kristin Klein Wheaton for Defendants. (DAZ) (Entered: 04/23/2010)	April 23, 2010	April 23, 2010 PACER
73	TEXT ORDER : A further status conference will be held on May 4, 2010 at 11:00 am. The parties may participate by telephone upon prior notice to chambers. By May 3, 2010, the parties will submit a joint or separate proposals for mediation, including the scope of the mediation and suggestions as to the mediator. SO ORDERED. Issued by Hon. Jeremiah J. McCarthy on 4/26/10. (DAZ) (Entered: 04/26/2010)	April 26, 2010	April 26, 2010 PACER
74	NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Proceedings held on March 19, 2010, before Judge Jeremiah McCarthy. Court Reporter/Transcriber Debra L. Potocki, Telephone number 843-723-2208. 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.. Redaction Request due 5/21/2010. Redacted Transcript Deadline set for 5/31/2010. Release of Transcript Restriction set for 7/29/2010. (DLC) (Entered: 04/30/2010)	April 30, 2010	April 30, 2010 PACER
75	NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Proceedings held on April 23, 2010, before Judge Jeremiah McCarthy. Court Reporter/Transcriber Debra L. Potocki, Telephone number 843-723-2208. 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.. Redaction Request due 5/21/2010. Redacted Transcript Deadline set for 5/31/2010. Release of Transcript Restriction set for 7/29/2010. (DLC) (Entered: 04/30/2010)	April 30, 2010	April 30, 2010 PACER
76	Minute Entry for proceedings held before Hon. Jeremiah J. McCarthy: Status Conference re mediation issues held on 5/4/2010. Participants: Mary Pat Fleming (in person), Zazy Ivonne Lopez and Luis E. Saucedo (via telephone) for plaintiff; Cheryl A. Green and Kristin Klein Wheaton for Defendants. (DAZ) (Entered: 05/04/2010)	May 4, 2010	May 4, 2010 PACER
77	TEXT ORDER : In accordance with today's proceeding, this case is referred for expedited mediation on the issue of suicide prevention, as well as mental health treatment to the extent it relates to suicide prevention. This referral is without prejudice to the other issues in the case being mediated at a later time. The parties agree that: 1) by May 7, 2010 at 12:00 p.m. they shall advise the court of a mutually agreeable mediator, or if they are unable to reach agreement, they shall submit their proposed mediators (including their availability), and the court will thereafter designate a mediator; 2) by May 14, 2010 at 5:00 p.m. they shall submit their initial mediation statements to the mediator; 3) subject to the mediator's availability, the initial mediation session will occur on May 18-19, 2010; 4) to the extent the Second Circuit has addressed the deliberate indifference standard applicable to this case, such authority will control for purposes of the mediation; 5) the mediation process will conclude by May 28, 2010 at 5:00 p.m.; and 6) a further status conference is set for June 1, 2010 at 1:30 p.m. before Hon. Jeremiah J. McCarthy. Out of town counsel may participate by telephone. SO ORDERED. Issued by Hon. Jeremiah J. McCarthy on 5/4/10. (DAZ) (Entered: 05/04/2010)	May 4, 2010	May 4, 2010 PACER
78	ORDER DESIGNATING MEDIATOR. Amy Glass, Esq. is designated as Mediator in this case. Mediation schedule as specified. Signed by William M. Skretny, Chief Judge U.S.D.C. on 5/11/2010. (MEAL) (Entered: 05/11/2010)	May 11, 2010	May 11, 2010 PACER
79	TEXT ORDER : The June 1, 2010 status conference before Hon. Jeremiah J. McCarthy is rescheduled from 1:30 p.m. to 4:30 p.m. SO ORDERED. Issued by Hon. Jeremiah J. McCarthy on 5/27/10. (DAZ) (Entered: 05/27/2010)	May 27, 2010	May 27, 2010 PACER
80	Mediation Certification by Amy Glass(JMS) (Entered: 06/01/2010)	June 1, 2010	June 1, 2010 PACER
81	Minute Entry for proceedings held before Hon. Jeremiah J. McCarthy: Status Conference re discovery issues held on 6/1/2010. Mediation unsuccessful. Parties to submit joint or separate proposed case management deadlines by 6/9/10. Status/Scheduling Conference set for 6/16/2010 at 02:00 PM before Hon. Jeremiah J. McCarthy. Participants: Mary Pat Fleming, Zazy Ivonne Lopez, Regina Jansen (via telephone) for plaintiff and Cheryl A. Green for defendant. (DAZ) (Entered: 06/02/2010)	June 1, 2010	June 1, 2010 PACER
82	TEXT ORDER: The parties shall confer pursuant to Fed. R. Civ. P. 26(f) and submit a joint or separate proposed case management orders by June 9, 2010. The preliminary pretrial conference is set for June 16, 2010 at 2:00 p.m. before Hon. Jeremiah J. McCarthy. The parties may participate via telephone by providing the court with telephone numbers where they can be contacted. The court will initiate the call. SO ORDERED. Issued by Hon. Jeremiah J. McCarthy on 6/2/10. (DAZ) (Entered: 06/02/2010)	June 2, 2010	June 2, 2010 PACER
83	MOTION to Expedite Discovery in the issue of suicide prevention and related mental health treatment by Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier.(Wheaton, Kristin) (Entered: 06/11/2010)	June 11, 2010	June 11, 2010 PACER
84	DECLARATION signed by Kristin Klein Wheaton re 83 MOTION to Expedite Discovery in the issue of suicide prevention and related mental health treatment filed by Timothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier. (Attachments: # 1 Exhibit A - May 28 adn June 4 interrogatories, # 2 Exhibit B - May 28 and June 24 Document demands, # 3 Exhibit C - May 28 and June 4 Demand for Expert disclosure, # 4 Exhibit D - May 28 and June 4 notices for deposition of experts)(Wheaton, Kristin) (Entered: 06/11/2010) 2 Exhibit A - May 28 adn June 4 interrogatories View on PACER 3 Exhibit B - May 28 and June 24 Document demands View on PACER 4 Exhibit C - May 28 and June 4 Demand for Expert disclosure View on PACER 5 Exhibit D - May 28 and June 4 notices for deposition of experts View on PACER	June 11, 2010	June 11, 2010 PACER
85	MEMORANDUM IN SUPPORT re 84 Declaration,, 83 MOTION to Expedite Discovery in the issue of suicide prevention and related mental health treatment byTimothy B. Howard, Richard T. Donovan, Robert Koch, Barbara Leary, Donald Livingston, Erie County, New York, Chris Collins, Anthony Billittier. (Wheaton, Kristin) (Entered: 06/11/2010)	June 11, 2010	June 11, 2010 PACER
86	ORDER GRANTING Plaintiff's request for an extension of the page limitation. Signed by William M. Skretny, Chief Judge U.S.D.C. on 6/14/2010. (MEAL) (Entered: 06/14/2010)	June 14, 2010	June 14, 2010 PACER
87	TEXT ORDER : At the parties' request, tomorrow's preliminary pretrial conference 82 is rescheduled to June 18, 2010 at 2:00 p.m. SO ORDERED. Issued by Hon. Jeremiah J. McCarthy on 6/14/10. (DAZ) (Entered: 06/15/2010)	June 15, 2010	June 15, 2010 PACER
88	NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Proceedings held on June 1, 2010, before Judge Jeremiah J. McCarthy. Court Reporter/Transcriber Christi A. Macri, Telephone number 585-613-4310. 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.. Redaction Request due 7/8/2010. Redacted Transcript Deadline set for 7/19/2010. Release of Transcript Restriction set for 9/15/2010. (DLC) (Entered: 06/17/2010)	June 17, 2010	June 17, 2010 PACER
89	MOTION for Settlement on Suicide Prevention and Related Mental Health Care by United States of America. (Attachments: # 1 Stipulated Settlement Agreement)(Lopez, Zazy) (Entered: 06/18/2010) 2 Stipulated Settlement Agreement View on PACER	June 18, 2010	June 18, 2010 PACER
90	Minute Entry for proceedings held before Hon. Jeremiah J. McCarthy: Status Conference re CMO deadlines held on 6/18/2010. Participants: Mary Pat Fleming (in person), Charles W. Hart, Jr., Zazy Ivonne Lopez and Luis E. Saucedo (via telephone) for plaintiff; Kristin Klein Wheaton and Cheryl A. Green for Defendants. (DAZ) (Entered: 06/18/2010)	June 18, 2010	June 18, 2010 PACER
93	Minute Entry for proceedings held before William M. Skretny, Chief Judge: Status Conference held on 6/18/2010 on order approving settlement. Counsel to submit a 3rd order with compromise language. For the pltf. - Charles Hart, Luis Saucedo -- by telephone, Mary Pat Fleming. For the defts. - Cheryl Green, Kristin Klein Wheaton. (Court Reporter Michelle McLaughlin.) (MEAL) (Entered: 06/22/2010)	June 18, 2010	June 18, 2010 PACER
92	CASE MANAGEMENT ORDER (Please Note: This docket text may not contain the entire contents of the attached Order. It is your responsibility to read the attached Order and download it for future reference. Direct any questions to the Chambers of the Judge who entered this Order.) Discovery completed by 10/5/11, Dispositive motions due by 12/7/11, Pretrial Statements due by 12/21/11, Final Pretrial Conference set for 1/25/12 at 09:00 a.m. before Hon. William M. Skretny, U.S.D.J., Jury Selection set for 3/27/12 at 9:30 a.m. with Jury Trial thereafter set for 09:00 a.m. before Hon. William M. Skretny, U.S.D.J. Status Conference set for 7/21/2010 at 2:00 p.m. before Hon. Jeremiah J. McCarthy. Signed by Hon. Jeremiah J. McCarthy on 6/21/10. (DAZ) (Entered: 06/22/2010)	June 21, 2010	June 21, 2010 PACER
91	ORDER APPROVING STIPULATED SETTLEMENT AGREEMENT CONCERNING SUICIDE PREVENTION AND RELATED MENTAL HEALTH ISSUES. Signed by William M. Skretny, Chief Judge U.S.D.C. on 6/22/2010. (MEAL) (Entered: 06/22/2010)	June 22, 2010	June 22, 2010 RECAP
94	DECISION AND ORDER DENYING Defendants' 13 Motion to Dismiss; DIRECTING the Justice Department to file an amended complaint within 14 days of the filing date of this Decision and Order; DIRECTING the Defendants to file answers to or otherwise move against the amended complaint within 14 days of its filing. Signed by William M. Skretny, Chief Judge U.S.D.C. on 7/9/2010. (MEAL) (Entered: 07/09/2010)	July 9, 2010	July 9, 2010 RECAP
95	TEXT ORDER. IT HEREBY IS ORDERED THAT, in light of the parties' 89 91 settlement concerning suicide and related mental health issues, Defendants' 83 Motion for Expedited Discovery on those issues is DENIED as moot. SO ORDERED. Issued by William M. Skretny, Chief Judge U.S.D.C. on 7/9/2010. (MEAL) (Entered: 07/12/2010)	July 12, 2010	July 12, 2010 PACER
96	Minute Entry for proceedings held before Hon. Jeremiah J. McCarthy: Status Conference held on 7/21/2010. Participants: Mary Pat Fleming (in person), Zazy Lopez, Aaron Saul Fleisher, Charles W. Hart, Jr. (via telephone) for Plaintiff; Cheryl Green and Kristin Klein Wheaton for Defendants. (DAZ) (Entered: 07/22/2010)	July 21, 2010	July 21, 2010 PACER
97	AMENDED COMPLAINT against all defendants, filed by United States of America. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Lopez, Zazy) (Entered: 07/23/2010) 2 Exhibit A View on RECAP 3 Exhibit B View on RECAP	July 23, 2010	July 23, 2010 PACER
98	MOTION Access to Documents Pursuant to Stipulated Settlement by United States of America. (Attachments: # 1 Memorandum in Support of Motion for Access Pursuant to Stipulated Settlement)(Lareau, Alyssa) (Entered: 08/04/2010) 2 Memorandum in Support of Motion for Access Pursuant to Stipulated Settlement View on PACER	Aug. 4, 2010	Aug. 4, 2010 PACER
99	MOTION to Expedite Hearing by United States of America.(Lareau, Alyssa) (Entered: 08/04/2010)	Aug. 4, 2010	Aug. 4, 2010 PACER
100	MOTION to Seal Document by United States of America. (Attachments: # 1 Text of Proposed Order)(Lareau, Alyssa) (Entered: 08/04/2010) 2 Text of Proposed Order View on PACER	Aug. 4, 2010	Aug. 4, 2010 PACER