Case: S.H. v. District of Columbia

S.H., et al v. District of Columbia

COMPLAINT against All Defendants with Jury Demand ( Filing fee $ 400 receipt number 0090-3798532) filed by S.H., SHANDALYN HARRISON, S.R., S.B., STERLING HARRISON. (Attachments: # 1 Exhibit 1, # 2 Civil Cover Sheet, # 3 Summons, # 4 Summons)(Karakatsanis, Alec) (Entered: 08/04/2014)

1 Exhibit 1

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2 Civil Cover Sheet

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3 Summons

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4 Summons

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Case Assigned to Judge Ketanji Brown Jackson. (kb)

NOTICE of Filing by SHANDALYN HARRISON, STERLING HARRISON, S.B., S.H., S.R. (Attachments: # 1 Summons, # 2 Summons)(Karakatsanis, Alec) (Entered: 08/04/2014)

1 Summons

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2 Summons

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GENERAL ORDER AND GUIDELINES FOR CIVIL CASES BEFORE JUDGE KETANJI BROWN JACKSON. The Court will hold the parties and counsel responsible for following these directives; failure to conform to this Order may, when appropriate, result in the imposition of sanctions. Signed by Judge Ketanji Brown Jackson on 08/04/2014. (lckbj1) (Entered: 08/04/2014)

SUMMONS (3) Issued Electronically as to TAYLOR VOLPE, District of Columbia Attorney General, and the District of Columbia Mayor. (Attachments: # 1 Summons, # 2 Summons, # 3 Summons)(sth, ) (Entered: 08/05/2014)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the District of Columbia Attorney General. Date of Service Upon District of Columbia Attorney General 8/5/2014. ( Answer due for ALL D.C. DEFENDANTS by 8/26/2014.), RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. DISTRICT OF COLUMBIA served on 8/5/2014, RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on the Mayor of the District of Columbia. Date of Service Upon the Mayor for the District of Columbia on 08/05/2014. (Karakatsanis, Alec) (Entered: 08/06/2014)

Consent MOTION for Extension of Time to File Answer re 1 Complaint, by DISTRICT OF COLUMBIA (Gonzalez, Joseph) (Entered: 08/26/2014)

MINUTE ORDER granting, for good cause shown, 6 Consent Motion for Extension of Time to Answer, nunc pro tunc to 9/26/2014. Defendant District of Columbia shall answer or otherwise respond to the Complaint by 9/9/2014. Any further requests for extensions of time must comply with 3 the Court's General Order and Guidelines for Civil Cases. Counsel is specifically directed to Section 5 of the Appendix to the General Order and Guidelines. Signed by Judge Ketanji Brown Jackson on 08/27/2014. (lckbj1, )

Second MOTION for Extension of Time to File Answer re 1 Complaint, by DISTRICT OF COLUMBIA (Finkhousen, Aaron) (Entered: 09/05/2014)

MINUTE ORDER granting, for good cause shown, 7 Motion for Extension of Time to Answer. Defendant District of Columbia shall answer or otherwise respond to the complaint by 9/15/2014. Signed by Judge Ketanji Brown Jackson on 09/08/2014. (lckbj1)

MOTION to Dismiss by DISTRICT OF COLUMBIA, JOHN DOE OFFICERS 1-20, TAYLOR VOLPE (Finkhousen, Aaron) (Entered: 09/15/2014)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. TAYLOR VOLPE served on 8/5/2014, answer due 8/26/2014, WAIVER OF SERVICE by S.R.; S.B.; SHANDALYN HARRISON; S.H.; STERLING HARRISON. TAYLOR VOLPE waiver sent on 8/5/2014, answer due 8/26/2014. (Karakatsanis, Alec) (Entered: 09/22/2014)

Unopposed MOTION for Extension of Time to File Response/Reply to Defendants' Motion to Dismiss by SHANDALYN HARRISON, STERLING HARRISON, S.B., S.H., S.R. (Karakatsanis, Alec) (Entered: 09/22/2014)

MINUTE ORDER granting, for good cause shown, 10 Motion for Extension of Time to File Response 8 MOTION to Dismiss. Plaintiffs' response to 8 is due by by 10/16/2014. Signed by Judge Ketanji Brown Jackson on 09/22/2014. (lckbj1)

Memorandum in opposition to re 8 MOTION to Dismiss filed by SHANDALYN HARRISON, STERLING HARRISON, S.B., S.H., S.R.. (Karakatsanis, Alec) (Entered: 10/13/2014)

REPLY to opposition to motion re 8 MOTION to Dismiss filed by DISTRICT OF COLUMBIA, JOHN DOE OFFICERS 1-20, TAYLOR VOLPE. (Finkhousen, Aaron) (Entered: 10/23/2014)

MOTION for Leave to File Sur-Reply by SHANDALYN HARRISON, STERLING HARRISON, S.B., S.H., S.R. (Karakatsanis, Alec) (Entered: 10/27/2014)

Memorandum in opposition to re 13 MOTION for Leave to File Sur-Reply filed by DISTRICT OF COLUMBIA, JOHN DOE OFFICERS 1-20, TAYLOR VOLPE. (Finkhousen, Aaron) (Entered: 11/13/2014)

Case randomly reassigned to Judge Randolph D. Moss. Judge Ketanji Brown Jackson no longer assigned to the case. (gt, )

MOTION to Compel by SHANDALYN HARRISON, STERLING HARRISON, S.B., S.H., S.R. (Attachments: # 1 Exhibit Exhibit 1, # 2 Exhibit Exhibit 2, # 3 Exhibit Exhibit 3)(Karakatsanis, Alec) (Entered: 01/27/2015)

MINUTE ORDER: It is hereby ORDERED that Defendants shall respond to the Motion to Compel on or before February 10, 2015. Plaintiffs shall file a reply on or before February 17, 2015. The parties shall appear for a status conference on February 20, 2015 at 10:00 AM, in Courtroom 21. Signed by Judge Randolph D. Moss on January 27, 2015. (lcrdm3, )

Set/Reset Deadlines/Hearing: The Defendants shall respond to the Motion to Compel on or before 2/10/2015; Plaintiffs shall file a reply on or before 2/17/2015. A Status Conference is set for 2/20/2015, at 10:00 AM, in Courtroom 21, before Judge Randolph D. Moss. (kt)

NOTICE of Appearance by Phil Telfeyan on behalf of SHANDALYN HARRISON, STERLING HARRISON, S.B., S.H., S.R. (znmw, ) (Entered: 02/05/2015)

MOTION for Extension of Time to File Response/Reply as to 15 MOTION to Compel by DISTRICT OF COLUMBIA (Gonzalez, Joseph) (Entered: 02/10/2015)

RESPONSE re 17 MOTION for Extension of Time to File Response/Reply as to 15 MOTION to Compel filed by SHANDALYN HARRISON, STERLING HARRISON, S.B., S.H., S.R.. (Telfeyan, Phil) (Entered: 02/11/2015)

MINUTE ORDER: Upon consideration of Defendants' Motion for Extension of Time to File Response/Reply 17, it is hereby ORDERED that the motion is GRANTED. Defendants shall respond to Plaintiffs' Motion to Compel 15 on or before February 13, 2015. Signed by Judge Randolph D. Moss on 2/11/2015. (lcrdm2, )

Set/Reset Deadline: Defendants shall respond to Plaintiffs' Motion to Compel 15 on or before 2/13/2015. (kt)

RESPONSE re 15 MOTION to Compel filed by DISTRICT OF COLUMBIA. (Attachments: # 1 Exhibit)(Gonzalez, Joseph) (Entered: 02/13/2015)

MINUTE ORDER: It is hereby ORDERED that the parties shall be prepared to discuss the pending motion to compel and whether limited discovery should be authorized at this time at the February 20, 2015 status conference. Signed by Judge Randolph D. Moss on February 16, 2015. (lcrdm3, )

REPLY to opposition to motion re 15 MOTION to Compel filed by SHANDALYN HARRISON, STERLING HARRISON, S.B., S.H., S.R.. (Telfeyan, Phil) (Entered: 02/16/2015)

Minute Entry for proceedings held before Judge Randolph D. Moss: Status Conference held on 2/20/2015. (Court Reporter Lisa Foradori) (kt)

NOTICE OF WITHDRAWAL OF APPEARANCE as to DISTRICT OF COLUMBIA, JOHN DOE OFFICERS 1-20, TAYLOR VOLPE. Attorney Aaron Josiah Finkhousen terminated. (Finkhousen, Aaron) (Entered: 02/20/2015)

MINUTE ORDER: As discussed at today's status conference, the Court shall construe Plaintiff's Motion to Compel 15 as a Motion for Expedited Discovery. It is hereby ORDERED that Defendants may file any supplemental opposition to the motion on or before March 6, 2015. Signed by Judge Randolph D. Moss on 2/20/2015. (lcrdm2, )

Set/Reset Deadline: The Defendants may file any supplemental opposition to the motion on or before 3/6/2015. (kt)

NOTICE regarding consent to expedited discovery by DISTRICT OF COLUMBIA (Gonzalez, Joseph) (Entered: 03/11/2015)

MINUTE ORDER: In light of Defendants' Notice Regarding Consent to Expedited Discovery 22, it is hereby ORDERED that Plaintiffs' Motion to Compel 15 is DENIED without prejudice as moot. Signed by Judge Randolph D. Moss on March 20, 2015. (lcrdm3, )

MOTION for Leave to File Amended Complaint by SHANDALYN HARRISON, STERLING HARRISON, S.B., S.H., S.R. (Attachments: # 1 Exhibit Exhibit 1: First Amended Complaint)(Karakatsanis, Alec) (Entered: 04/22/2015)

1 Exhibit Exhibit 1: First Amended Complaint

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MINUTE ORDER: Upon consideration of Plaintiffs' Motion for Leave to File Sur-Reply 13 and Defendants' Opposition 14, it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that Plaintiffs may file a sur-reply of no more than seven pages on or before September 30, 2015. Signed by Judge Randolph D. Moss on 9/25/2015. (lcrdm3, )

MINUTE ORDER: Upon consideration of Plaintiffs' Motion for Leave to File Amended Complaint 23, it is hereby ORDERED that the motion is GRANTED. The Amended Complaint [23-1] is deemed FILED. Signed by Judge Randolph D. Moss on 9/25/2015. (lcrdm3, )

First AMENDED COMPLAINT against ZACHARY BLIER, JAMES BOETLER, GREGORY COLLINS, DISTRICT OF COLUMBIA, JOHN DOE OFFICERS 1-20, HERBERT NICHOLLS, TAYLOR VOLPE with Jury Demand filed by S.R., S.B., SHANDALYN HARRISON, S.H., STERLING HARRISON.(zrdj) (Entered: 09/28/2015)

ENTERED IN ERROR.....NOTICE by SHANDALYN HARRISON, STERLING HARRISON, S.B., S.H., S.R. re 24 Amended Complaint (Karakatsanis, Alec) Modified on 9/29/2015 counsel WILL Refile (zrdj). (Entered: 09/29/2015)

NOTICE of Summons by SHANDALYN HARRISON, STERLING HARRISON, S.B., S.H., S.R. re 24 Amended Complaint (Attachments: # 1 Summons, # 2 Summons, # 3 Summons)(Karakatsanis, Alec) (Entered: 09/29/2015)

SUMMONS (4) Issued Electronically as to ZACHARY BLIER, JAMES BOETLER, GREGORY COLLINS, HERBERT NICHOLLS. (Attachments: # 1 Consent Forms)(zrdj) (Entered: 09/29/2015)

NOTICE by SHANDALYN HARRISON, STERLING HARRISON, S.B., S.H., S.R. re 24 Amended Complaint (Attachments: # 1 Exhibit Search Warrant Application)(Karakatsanis, Alec) (Entered: 09/29/2015)

SURREPLY to re 8 MOTION to Dismiss filed by SHANDALYN HARRISON, STERLING HARRISON, S.B., S.H., S.R.. (Karakatsanis, Alec) (Entered: 09/30/2015)

Consent MOTION for Extension of Time to File Answer re 24 Amended Complaint by DISTRICT OF COLUMBIA (Gonzalez, Joseph) (Entered: 10/13/2015)

MINUTE ORDER: Defendants' Consent Motion for Extension of Time 30 is hereby GRANTED. Defendants shall respond to Plaintiffs' First Amended Complaint 24 on or before October 23, 2015. Signed by Judge Randolph D. Moss on 10/14/2015. (lcrdm3, )

Set/Reset Deadline: Defendants shall respond to Plaintiffs' First Amended Complaint 24 on or before 10/23/2015. (kt)

Joint MOTION for Order permitting the Parties to incorporate previous Motion to Dismiss briefing by DISTRICT OF COLUMBIA (Gonzalez, Joseph) (Entered: 10/23/2015)

MINUTE ORDER: The parties' Joint Motion to Incorporate Prior Briefing 31 is hereby GRANTED. The motion to dismiss 8, opposition 11, reply 12, and sur-reply 29 are hereby deemed applicable to the Amended Complaint. Signed by Judge Randolph D. Moss on 10/28/2015. (lcrdm3, )

NOTICE of Acceptance of Service by ZACHARY BLIER, JAMES BOETLER, GREGORY COLLINS, HERBERT NICHOLLS re 24 Amended Complaint (Gonzalez, Joseph) (Entered: 12/04/2015)

MINUTE ORDER: In light of the parties' representation that they have agreed to stay this case in order to focus on settlement efforts, it is hereby ORDERED that this case be STAYED pending further notice. The parties shall notify the Court if at any time they wish to employ alternative dispute resolution or mediation before a magistrate judge. It is FURTHER ORDERED that the parties shall file a joint status report on or before January 9, 2017, regarding the status of the settlement talks. Signed by Judge Randolph D. Moss on 12/9/2016. (lcrdm3, )

Set/Reset Deadlines: The parties shall file a joint status report on or before 1/9/2017. (kt)

NOTICE of Appearance by Katherine Hubbard on behalf of All Plaintiffs (Hubbard, Katherine) (Entered: 01/09/2017)

Joint STATUS REPORT by SHANDALYN HARRISON, STERLING HARRISON, S.B., S.H., S.R.. (Hubbard, Katherine) (Entered: 01/09/2017)

MINUTE ORDER: As the parties requested in their Joint Status Report 34, it is hereby ORDERED that the parties shall file a further joint status report on or before February 8, 2017, unless the parties have filed a stipulation of dismissal by that date. Signed by Judge Randolph D. Moss on 1/9/2017. (lcrdm3, )

Set/Reset Deadlines: The parties shall file a further joint status report on or before 2/8/2017. (kt)

Joint STATUS REPORT by SHANDALYN HARRISON, STERLING HARRISON, S.B., S.H., S.R.. (Hubbard, Katherine) (Entered: 02/08/2017)

MINUTE ORDER: Upon consideration of the parties' Joint Status Report 35, it is hereby ORDERED that, on or before February 22, 2017, unless the parties have filed a stipulation of dismissal by that date, the parties shall file a further joint status report. The status report shall (1) advise the Court as to the status of the settlement negotiations and (2) state both parties' views as to whether mediation before a magistrate judge or in the Circuit Executive's Office would further the negotiation process. Signed by Judge Randolph D. Moss on 2/8/2017. (lcrdm3, )

Set/Reset Deadlines: Joint Status Report due by 2/22/2017. (dot)

Joint STATUS REPORT by ZACHARY BLIER, JAMES BOETLER, GREGORY COLLINS, DISTRICT OF COLUMBIA, HERBERT NICHOLLS, TAYLOR VOLPE. (Finkhousen, Aaron) (Entered: 02/22/2017)

MINUTE ORDER: Upon consideration of the parties' Joint Status Report 36, it is hereby ORDERED that the parties appear for a status conference on April 4, 2017, at 2:30 p.m. Signed by Judge Randolph D. Moss on 3/5/2017. (lcrdm3, )

Set/Reset Hearings: A Status Conference is set for 4/4/2017, at 2:30 PM, in Courtroom 21, before Judge Randolph D. Moss. (kt)

Minute Entry for proceedings held before Judge Randolph D. Moss: Status Conference held on 4/4/2017. Case UNSTAYED. Briefs identifying additional authorities and/or cases, due within one week. (Court Reporter: Pat Kaneshiro-Miller). (kt)

NOTICE OF SUBSTITUTION OF COUNSEL by Aaron Josiah Finkhousen on behalf of ZACHARY BLIER, JAMES BOETLER, GREGORY COLLINS, DISTRICT OF COLUMBIA, HERBERT NICHOLLS, TAYLOR VOLPE Substituting for attorney Joseph Gonzalez (Finkhousen, Aaron) (Entered: 04/06/2017)

NOTICE OF SUPPLEMENTAL AUTHORITY by ZACHARY BLIER, JAMES BOETLER, GREGORY COLLINS, DISTRICT OF COLUMBIA, HERBERT NICHOLLS, TAYLOR VOLPE (Finkhousen, Aaron) (Entered: 04/11/2017)

NOTICE OF SUPPLEMENTAL AUTHORITY by SHANDALYN HARRISON, STERLING HARRISON, S.B., S.H., S.R. (Hubbard, Katherine) (Entered: 04/11/2017)

MEMORANDUM OPINION AND ORDER: Defendants' motion to dismiss, Dkt. 8, is hereby GRANTED as to Count Four, GRANTED in part and DENIED in part as to Counts One and Seven, and otherwise DENIED. See document for details. Signed by Judge Randolph D. Moss on 9/16/2017. (lcrdm1, ) (Main Document 40 replaced on 9/18/2017) (zkt). (Entered: 09/16/2017)

ORDER setting Initial Scheduling Conference for October 25, 2017 at 2:45 pm, in Courtroom 21. See document for details. Signed by Judge Randolph D. Moss on 9/18/17. (lcrdm3, ) (Entered: 09/18/2017)

Set/Reset Hearings: Initial Scheduling Conference set for 10/25/2017, at 2:45 PM, in Courtroom 21, before Judge Randolph D. Moss. (kt)

NOTICE OF WITHDRAWAL OF APPEARANCE as to SHANDALYN HARRISON, STERLING HARRISON, S.B., S.H., S.R.. Attorney Phil Telfeyan terminated. (Telfeyan, Phil) (Entered: 09/18/2017)

ANSWER to 24 Amended Complaint by ZACHARY BLIER, JAMES BOETLER, GREGORY COLLINS, DISTRICT OF COLUMBIA, HERBERT NICHOLLS. Related document: 24 Amended Complaint filed by S.H., SHANDALYN HARRISON, S.B., S.R., STERLING HARRISON.(DeBerardinis, Robert) (Entered: 10/02/2017)

MEET AND CONFER STATEMENT. (Attachments: # 1 Exhibit Protective Order)(Hubbard, Katherine) (Entered: 10/18/2017)

Minute Entry for proceedings held before Judge Randolph D. Moss: Initial Scheduling Conference held on 10/25/2017. Scheduling Order forthcoming. A Status Conference is set for 5/3/2018, at 10:00 AM, in Courtroom 21, before Judge Randolph D. Moss. (Court Reporter: Jeff Hook.) (kt)

SCHEDULING ORDER: It is hereby ORDERED that (1) Rule 26(a)(1) initial disclosures shall be submitted on or before November 27, 2017; (2) Any additional parties shall be joined on or before December 4, 2017; (3) Any amendments to the pleadings shall be filed on or before December 4, 2017; (4) The parties shall conclude fact discovery on or before May 1, 2018; (5) The parties shall appear for a status conference on May 3, 2018, at 10:00 a.m. in Courtroom 21; (6) Plaintiffs expert reports shall be filed on or before June 1, 2018; (7) Defendants expert reports shall be filed on or before August 1, 2018; (8) Any expert depositions shall occur on or before September 1, 2018; and (9) The Court will set a schedule for briefing dispositive motions, if any, after the close of discovery. Signed by Judge Randolph D. Moss on 10/26/17. (lcrdm3, ) (Entered: 10/26/2017)

PROTECTIVE ORDER: The parties are hereby ORDERED to comply with the directives in the attached Protective Order. Signed by Judge Randolph D. Moss on 10/26/17. (lcrdm3, ) (Entered: 10/26/2017)

Set/Reset Deadlines: Rule 26(a)(1) initial disclosures shall be submitted on or before 11/27/2017; Any additional parties shall be joined on or before 12/4/2017; Any amendments to the pleadings shall be filed on or before 12/4/2017; The parties shall conclude fact discovery on or before 5/1/2018; Plaintiffs expert reports shall be filed on or before 6/1/2018; Defendants expert reports shall be filed on or before 8/1/2018; Any expert depositions shall occur on or before 9/1/2018. (kt)

NOTICE of Appearance by Premal Dharia on behalf of All Plaintiffs (Dharia, Premal) (Entered: 11/28/2017)

Consent MOTION for Extension of Time to Amend 24 Amended Complaint by SHANDALYN HARRISON, STERLING HARRISON, S.B., S.H., S.R. (Attachments: # 1 Text of Proposed Order)(Hubbard, Katherine) (Entered: 12/04/2017)

MINUTE ORDER: Upon consideration of Plaintiffs' Motion for Extension of Time to Amend 48, the motion is hereby GRANTED. Plaintiffs may amend their complaint on or before March 5, 2018. Signed by Judge Randolph D. Moss on 12/5/17. (lcrdm3, )

Set/Reset Deadlines: Plaintiffs to amend their complaint on or before 3/5/2018. (kt)

Consent MOTION for Settlement of Minors by SHANDALYN HARRISON, STERLING HARRISON, S.B., S.H., S.R. (Attachments: # 1 Text of Proposed Order)(Hubbard, Katherine) (Entered: 04/03/2018)

1 Text of Proposed Order

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MINUTE ORDER: Upon consideration of Plaintiffs' Consent Motion to Approve Settlement of Minor, it is hereby ORDERED that the motion is GRANTED. Plaintiff Shandalyn Harrison is hereby authorized to settle the claims of the minor children, S.H., S.B., and S.R., with Defendant District of Columbia with regard to the search warrant execution of April 13, 2013, for the sum of $0.00, and said settlement is hereby APPROVED by the Court. It is further ORDERED that Shandalyn Harrison shall create a trust for her daughters and deposit a portion of the settlement in that trust according the terms set forth by Plaintiffs' motion. See Dkt. 49 at 2 n.1. The Clerk of the Court is directed to terminate this case. Signed by Judge Randolph D. Moss on 4/4/18. (lcrdm3, )

Order on Motion for Settlement