Michelle H v. McMaster

MH v. Haley

Michelle H. v. McMaster

MH v. McMaster

Michelle H. v. McMaster

COMPLAINT against Susan Alford, Nikki Haley ( Filing fee $ 400 receipt number 0420-5729224.), filed by A B, S B, M B, Z L, K S, A R(by his next friend Cheryl Kreider), M H, R B, S V, C B, A R(by her next friend Tamara Coppinger). Service due by 5/15/2015(sshe, ) (Entered: 01/12/2015)

Local Rule 26.01 Answers to Interrogatories by A B, C B, M B, R B, S B, M H, Z L, A R(by his next friend Cheryl Kreider), A R(by her next friend Tamara Coppinger), K S, S V.(sshe, ) (Entered: 01/12/2015)

Summons Issued as to Susan Alford, Nikki Haley. (sshe, ) (Entered: 01/12/2015)

ACCEPTANCE OF SERVICE OF COMPLAINT by A B, S B, M B, Z L, K S, A R(by his next friend Cheryl Kreider), M H, R B, S V, C B, A R(by her next friend Tamara Coppinger). Susan Alford served on 1/14/2015, answer due 2/4/2015. (Attachments: # 1 Acceptance of Personal Service of the Summons on Defendant Susan Alford in her official capacity as Acting Director of the South Carolina Department of Social Services)(Richardson, Matthew) (Entered: 01/14/2015)

1 Acceptance of Personal Service of the Summons on Defendant Susan Alford in her

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MOTION to Appear Pro Hac Vice by Ira Lustbader ( Filing fee $ 250 receipt number 0420-5736975) by A B, C B, M B, R B, S B, M H, Z L, A R(by his next friend Cheryl Kreider), A R(by her next friend Tamara Coppinger), K S, S V. Response to Motion due by 2/2/2015. (Attachments: # 1 Affidavit Application, # 2 Supporting Documents Certificate of Good Standing, # 3 Proposed Order PDF of Order)Proposed order is being emailed to chambers with copy to opposing counsel.(Suggs, Steve) (Entered: 01/15/2015)

1 Affidavit Application

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2 Supporting Documents Certificate of Good Standing

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3 Proposed Order PDF of Order

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MOTION to Appear Pro Hac Vice by Kathryn Wood ( Filing fee $ 250 receipt number 0420-5737030) by A B, C B, M B, R B, S B, M H, Z L, A R(by his next friend Cheryl Kreider), A R(by her next friend Tamara Coppinger), K S, S V. Response to Motion due by 2/2/2015. (Attachments: # 1 Affidavit Application, # 2 Supporting Documents Certificate of Good Standing, # 3 Proposed Order pdf copy)Proposed order is being emailed to chambers with copy to opposing counsel.(Suggs, Steve) (Entered: 01/15/2015)

1 Affidavit Application

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2 Supporting Documents Certificate of Good Standing

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3 Proposed Order pdf copy

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ACCEPTANCE OF SERVICE OF COMPLAINT by A B, S B, M B, Z L, K S, A R(by his next friend Cheryl Kreider), M H, R B, S V, C B, A R(by her next friend Tamara Coppinger). Nikki Haley served on 1/14/2015, answer due 2/4/2015. (Attachments: # 1 Acceptance of Personal Service of the Summons on Defendant Nikki Haley in her official capacity as Governor of the State of South Carolina)(Richardson, Matthew) (Entered: 01/15/2015)

1 Acceptance of Personal Service of the Summons on Defendant Nikki Haley in her o

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ORDER granting 6 Motion of Ira Lustbader to Appear Pro Hac Vice for Plaintiffs. Signed by Honorable Richard M Gergel on 1/15/2015.(sshe, ) (Entered: 01/16/2015)

ORDER granting 7 Motion of Kathryn A. Wood to Appear Pro Hac Vice for Plaintiffs. Signed by Honorable Richard M Gergel on 1/15/2015.(sshe, ) (Entered: 01/16/2015)

MOTION for Confidentiality Order by A B, C B, M B, R B, S B, M H, Z L, A R(by his next friend Cheryl Kreider), A R(by her next friend Tamara Coppinger), K S, S V. Response to Motion due by 3/2/2015. (Attachments: # 1 Proposed Order)Proposed order is being emailed to chambers with copy to opposing counsel.(Richardson, Matthew) (Entered: 02/11/2015)

1 Proposed Order

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CONFIDENTIALITY ORDER granting 11 Motion for Confidentiality Order Signed by Honorable Richard M Gergel on 2/12/2015.(sshe, ) (Entered: 02/12/2015)

Consent MOTION for Extension of Time to Answer, Move, or Otherwise Plead in Response to Plaintiffs' Complaint by Susan Alford. Response to Motion due by 3/9/2015. No proposed order.(Laffitte, Rebecca) (Entered: 02/20/2015)

TEXT ORDER granting 13 Motion for Extension of Time to Answer, Move, or Otherwise Plead in Response to Plaintiff's Complaint. Defendants' Answers now due by March 15, 2015. Entered at the Direction of Honorable Richard M Gergel on 2/23/2015.(sshe, ) (Entered: 02/23/2015)

NOTICE of Appearance by Karl S Bowers, Jr on behalf of Nikki Haley (Bowers, Karl) (Entered: 03/16/2015)

First MOTION to Dismiss by Nikki Haley. Response to Motion due by 4/2/2015. (Attachments: # 1 Memo in Support)No proposed order.(Bowers, Karl) (Entered: 03/16/2015)

1 Memo in Support

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MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Susan Alford. Response to Motion due by 4/2/2015. (Attachments: # 1 Memo in Support)No proposed order.(Todd, Monteith) (Entered: 03/16/2015)

1 Memo in Support

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Local Rule 26.01 Answers to Interrogatories by Susan Alford.(Todd, Monteith) (Entered: 03/16/2015)

Consent MOTION for Extension of Time to File Response/Reply as to 16 First MOTION to Dismiss, 17 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by A B, C B, M B, R B, S B, M H, Z L, A R(by his next friend Cheryl Kreider), A R(by her next friend Tamara Coppinger), K S, S V. Response to Motion due by 4/6/2015. No proposed order.(Richardson, Matthew) (Entered: 03/20/2015)

TEXT ORDER: Plaintiffs have moved, with the consent of Defendants, for an extension of time to respond to Defendants' motions to dismiss. (Dkt. No. 19). The motion is granted. The time to respond to Defendants' motions to dismiss (Dkt. Nos. 16, 17) is extended to 5/4/15. AND IT IS SO ORDERED. Entered at the direction of the Honorable Richard M Gergel on 3/25/15.(ltap, ) (Entered: 03/25/2015)

TEXT ORDER: The Court has had considerable success in recent years promoting early mediation in complex litigation, which has allowed the parties to focus their energies on seeking common solutions rather than engaging in protracted litigation. The most notable of these successful mediations involved the litigation over the deepening of the Savannah Harbor, which involved environmental groups, the Georgia Ports Authority and the Army Corps of Engineers. The mediators in that matter were former Congressman John Spratt and then Magistrate Judge (now District Judge) Bruce Hendricks. In light of that experience, the Court has asked Senior United States District Judge Michael Duffy whether he would be willing to serve as a mediator in this matter and he has graciously agreed to do so. Mediation, of course, requires willing participants who enter into the process with the objective of seeking a resolution of a legal dispute through a negotiated settlement. The Court directs the parties to consult their clients and to advise the Court within 10 days of this order whether they are willing to participate in early mediation. To the extent there is an interest in early mediation, the parties should further advise the Court whether they would like the entry of a brief stay while negotiations are pursued. AND IT IS SO ORDERED. Signed by Honorable Richard M Gergel on 3/30/2015. (erav, ) (Entered: 03/30/2015)

REPLY by Susan Alford, Nikki Haley to 21 Order,,,,, . (Laffitte, Rebecca) (Entered: 04/03/2015)

REPLY by A B, C B, M B, R B, S B, M H, Z L, A R(by his next friend Cheryl Kreider), A R(by her next friend Tamara Coppinger), K S, S V to 21 Order,,,,, . (Richardson, Matthew) (Entered: 04/03/2015)

AMENDED NOTICE of Hearing: Status Conference set for 4/15/2015 at 02:00 PM in Charleston Courtroom #1, Hollings Judicial Center, 83 Meeting St, Charleston before Honorable Patrick Michael Duffy. **PLEASE NOTE: Out of state attorneys may participate by telephone and are not required to appear in person at the hearing (chub, ) Modified text on 4/8/2015 (erav, ). (Entered: 04/08/2015)

First MOTION to Appear Pro Hac Vice by Christina Wilson Remlin ( Filing fee $ 250 receipt number 0420-5918751) by A B, C B, M B, R B, S B, M H, Z L, A R(by his next friend Cheryl Kreider), A R(by her next friend Tamara Coppinger), K S, S V. Response to Motion due by 5/15/2015. (Attachments: # 1 Exhibit Application for Admission, # 2 Exhibit Certificate of Good Standing, # 3 Proposed Order Proposed Order of Admission)Proposed order is being emailed to chambers with copy to opposing counsel.(Suggs, Steve) (Entered: 04/28/2015)

1 Exhibit Application for Admission

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2 Exhibit Certificate of Good Standing

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3 Proposed Order Proposed Order of Admission

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First MOTION to Appear Pro Hac Vice by Aaron Hirsh Finch ( Filing fee $ 250 receipt number 0420-5918808) by A B, C B, M B, R B, S B, M H, Z L, A R(by his next friend Cheryl Kreider), A R(by her next friend Tamara Coppinger), K S, S V. Response to Motion due by 5/15/2015. (Attachments: # 1 Exhibit Application for Admission, # 2 Exhibit Certificate of Good Standing, # 3 Proposed Order Proposed Order of Admission)Proposed order is being emailed to chambers with copy to opposing counsel.(Suggs, Steve) (Entered: 04/28/2015)

1 Exhibit Application for Admission

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2 Exhibit Certificate of Good Standing

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3 Proposed Order Proposed Order of Admission

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First MOTION to Appear Pro Hac Vice by Sarah Teresa Russo ( Filing fee $ 250 receipt number 0420-5918843) by A B, C B, M B, R B, S B, M H, Z L, A R(by his next friend Cheryl Kreider), A R(by her next friend Tamara Coppinger), K S, S V. Response to Motion due by 5/15/2015. (Attachments: # 1 Exhibit Application for Admission, # 2 Exhibit Certificate of Good Standing, # 3 Proposed Order Proposed Order of Admission)Proposed order is being emailed to chambers with copy to opposing counsel.(Suggs, Steve) (Entered: 04/28/2015)

1 Exhibit Application for Admission

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2 Exhibit Certificate of Good Standing

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3 Proposed Order Proposed Order of Admission

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ORDER granting 25 Motion for Christina Wilson Remlin to Appear Pro Hac Vice; granting 26 Motion for Aaron Hirsh Finch to Appear Pro Hac Vice; granting 27 Motion for Sarah Teresa Russo to Appear Pro Hac Vice; for A B, C B, M B, R B, S B, M H, Z L, A R(by his next friend Cheryl Kreider), A R(by her next friend Tamara Coppinger), K S, S V Signed by Honorable Richard M Gergel on 4/29/2015.(sshe, ) (Entered: 04/29/2015)

CONSENT IMMEDIATE INTERIM RELIEF ORDER Signed by Honorable Richard M Gergel on 9/28/2015. (sshe, ) (Entered: 09/28/2015)

TEXT ORDER: The Court has pending on its docket two motions to dismiss. (Dkt. Nos. 16, 17). In light of the progress made by the parties in mediation, the Court denies these motions to dismiss without prejudice and with leave to restore to the docket if the parties wish to do so. AND IT IS SO ORDERED. Entered at the direction of the Honorable Richard M Gergel on 2/3/16.(ltap, ) (Entered: 02/03/2016)

ORDER re 29 Consent Immediate Interim Relief Order. The parties consent and agree to the extension of the Co-Monitors' authority under Section II.4 of Dkt. No. 29 until final approval and entry of a full negotiated settlement agreement or until the mediator reports to the court that mediation was ultimately unsuccessful, to allow the parties to complete negotiations and file a proposed full settlement agreement. Signed by Honorable Richard M Gergel on 3/17/2016. (sshe, ) (Entered: 03/17/2016)

Joint MOTION for Settlement Approval of the Class Action by A B, C B, M B, R B, S B, M H, Z L, A R(by his next friend Cheryl Kreider), A R(by her next friend Tamara Coppinger), K S, S V. Response to Motion due by 6/20/2016. (Attachments: # 1 Exhibit A - Final Settlement Agreement, # 2 Exhibit B - Proposed Order Granting Preliminary Approval, # 3 Exhibit C - Notice of Class Action Settlement, # 4 Exhibit D - Resumes of Co-Monitors)Proposed order is being emailed to chambers with copy to opposing counsel.(Richardson, Matthew) (Entered: 06/03/2016)

NOTICE of Hearing on 32 Joint MOTION for Settlement Approval of the Class Action : Motion Hearing set for 6/24/2016 at 10:00 AM in Hon. Sol Blatt, Jr., Courtroom, J. Waties Waring Judicial Cntr, 83 Meeting St, Charleston before Honorable Richard M Gergel. (ltap, ) (Entered: 06/14/2016)

Minute Entry. Proceedings held before Honorable Richard M Gergel: Motion Hearing held on 6/24/2016 re 32 Joint MOTION for Settlement Approval of the Class Action. Court to issue an order approving settlement. Parties submit to court final Notice of Class. Hearing to be set for final approval. Court Reporter Debbie Potocki. (erav, ) (Entered: 06/24/2016)

ORDER GRANTING PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT AGREEMENT, SETTING HEARING FOR FINAL APPROVAL, AND DIRECTING NOTICE TO THE CLASS granting 32 Motion for Settlement. Details set forth in Order. Signed by Honorable Richard M Gergel on 6/28/2016.(sshe, ) (Entered: 06/28/2016)

NOTICE of Hearing: Settlement Conference set for 10/4/2016 10:00 AM in Courtroom To Be Determined, J. Waties Waring Judicial Cntr, Meeting St and Broad, Charleston before Honorable Richard M Gergel. (sshe, ) (Entered: 06/28/2016)

AFFIDAVIT of Anthony Catone by Susan Alford. (Attachments: # 1 Affidavit Affidavit of Compliance with Notice Requirements)(Laffitte, Rebecca) (Entered: 07/15/2016)

MOTION to Withdraw as Attorney - Alex E. Davis by Susan Alford. Response to Motion due by 8/8/2016. No proposed order.(Laffitte, Rebecca) (Entered: 07/21/2016)

ORDER granting 38 Motion of Alex E. Davis to Withdraw as counsel of record for defendant Susan Alford. Signed by Honorable Richard M Gergel on 7/26/2016.(sshe, ) (Entered: 07/26/2016)

AFFIDAVIT (Supplemental Affidavit of Compliance with Notice Requirements) by Susan Alford. (Attachments: # 1 Affidavit)(Laffitte, Rebecca) (Entered: 08/22/2016)

NOTICE OF RESCHEDULED HEARING *NOTE TIME CHANGE ONLY* Settlement Conference set for 10/4/2016 10:00 AM cancelled and rescheduled to: Settlement Conference set for 10/4/2016 09:00 AM in Courtroom To Be Determined, J. Waties Waring Judicial Cntr, 83 Meeting St, Charleston before Honorable Richard M Gergel. (sshe, ) (Entered: 08/24/2016)

MOTION to Withdraw as Attorney Sarah T. Russo by A B, C B, M B, R B, S B, M H, Z L, A R(by his next friend Cheryl Kreider), A R(by her next friend Tamara Coppinger), K S, S V. Response to Motion due by 10/6/2016. Proposed order is being emailed to chambers with copy to opposing counsel.(Richardson, Matthew) (Entered: 09/19/2016)

NOTICE OF RESCHEDULED HEARING *NOTE TIME CHANGE ONLY: In light of the Order and Notice to Class at Dkt. #35 the Settlement Conference will be held on 10/4/2016 at 10:00 AM as per the ORDER. The hearing will be held in the Hon. Sol Blatt, Jr., Courtroom, J. Waties Waring Judicial Cntr, 83 Meeting St, Charleston before Honorable Richard M Gergel. (ltap, ) (Entered: 09/22/2016)

Joint MOTION for Settlement Approval by A B, C B, M B, R B, S B, M H, Z L, A R(by his next friend Cheryl Kreider), A R(by her next friend Tamara Coppinger), K S, S V. Response to Motion due by 10/11/2016. (Attachments: # 1 Exhibit Award, # 2 Exhibit Letter, # 3 Exhibit Letters, # 4 Exhibit Letters, # 5 Exhibit Letter, # 6 Exhibit Letter, # 7 Exhibit Letter, # 8 Exhibit Letter, # 9 Exhibit Letter, # 10 Exhibit Letter, # 11 Exhibit Letter, # 12 Exhibit Letter, # 13 Exhibit Letters from Group Homes, # 14 Exhibit Number of Group Homes, # 15 Exhibit Letter)No proposed order.(Suggs, Steve) (Entered: 09/22/2016)

ORDER GRANTING MOTION FOR WITHDRAWAL OF APPEARANCE OF SARAH T RUSSO granting 43 Motion to Withdraw as Attorney. Signed by Honorable Richard M Gergel on 9/29/2016.(sshe, ) (Entered: 09/29/2016)

Minute Entry. Proceedings held before Honorable Richard M Gergel: Settlement Conference (Fairness Hearing) held on 10/4/2016. Court to issue an order approving settlement. Court Reporter Debbie Potocki. (erav, ) (Entered: 10/04/2016)

FINAL JUDGMENT AND ORDER APPROVING CLASS ACTION SETTLEMENT granting 45 Motion for Settlement Signed by Honorable Richard M Gergel on 10/4/2016.(sshe, ) (Entered: 10/04/2016)

NOTICE OF FILING OF OFFICIAL TRANSCRIPT of fairness hearing held on 10-4-16, before Judge Richard M. Gergel. Court Reporter/Transcriber Debra Potocki, Telephone number/E-mail 843-723-2208/potockidebra@bellsouth.net. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Parties have 7 calendar days from the filing of the transcript to file with the court a Notice of Intent to Request Redaction.. Redaction Request due 11/14/2016. Redacted Transcript Deadline set for 11/21/2016. Release of Transcript Restriction set for 1/19/2017. (dpotocki, ) (Entered: 10/21/2016)

Letter dated 1/23/2017 from Co-Monitors. (sshe, ) Modified docket text on 2/8/2017 (sshe, ). (Entered: 02/08/2017)

Letter dated 1/24/2017 from DSS General Counsel. (sshe, ) Modified docket text on 2/8/2017 (sshe, ). (Entered: 02/08/2017)

Letter dated 2/7/2017 from Co-Monitors. (sshe, ) Modified docket text on 2/8/2017 (sshe, ). (Entered: 02/08/2017)

ORDER The Court has reviewed the Co-Monitors letters of January 23, 2017 52 and February 7, 2017 54, and a letter from the DSS General Counsel of January 24, 2017 53 . If any party to this action desires to provide any additional information on this issue before the Court reaches a determination concerning this dispute over data access under the Final Settlement Agreement, such response shall be filed with the Court on or before February 13, 2017. The Court further directs that DSS General Counsel provide to the Court under seal on or before February 13, 2017 a sample of the data and records from the child protective services portion of the CAPSS system that the agency seeks to prevent access to by the Co-Monitors. The Court intends to review such data and records in camera to determine the relevancy and necessity of the requested disclosure. S.C. Code ยง 63-7-690(11). AND IT IS SO ORDERED. (Further details provided in Order) Signed by Honorable Richard M Gergel on 2/8/2017. (sshe, ) (Entered: 02/08/2017)

Letter from Matthew Richardson pursuant to Order, Dkt # 55. (Richardson, Matthew) (Entered: 02/13/2017)

Letter from DSS. (Attachments: # 1 Exhibit A - E-mail from CSSP 2/3/17, # 2 Exhibit B - E-mail to CSSP from SCDSS 2/6/17, # 3 Exhibit C - E-mail from CSSP to SCDSS 2/6/17, # 4 Exhibit D - Email CSSP to Jude Duffy 2/6/17, # 5 Exhibit E - Email from SCDSS to CSSP 2/7/17)(Laffitte, Rebecca) (Entered: 02/13/2017)

Sealed Documents. Filed per Direction of Honorable Richard M Gergel on 2/14/2017. (sshe, ) (Entered: 02/14/2017)

ORDER that the Court hereby orders and directs, pursuant to the terms of the Settlement Agreement and the Court's injunctive powers, that the Defendants, without delay, provide direct access to the Co-Monitors to the child protective portion of the CAPSS. The parties are directed to file a joint certification with the Court on or before February 21, 2017 that there has been full compliance with this order. AND IT IS SO ORDERED. Signed by Honorable Richard M Gergel on 2/14/2017. (sshe, ) (Entered: 02/14/2017)

REPLY by Susan Alford to 59 Order,, (Joint Certification). (Laffitte, Rebecca) (Entered: 02/21/2017)

MOTION for Extension of Time for Submission of Health Care Improvement Plan by Susan Alford. Response to Motion due by 6/15/2017. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. Proposed order is being emailed to chambers with copy to opposing counsel.(Todd, Monteith) (Entered: 06/01/2017)

ORDER EXTENDING TIME granting 61 Defendant's Motion for Extension of Time. The Health Care Improvement Plan shall be submitted by September 30, 2017. AND IT IS SO ORDERED. Signed by Honorable Richard M Gergel on 6/5/2017.(sshe, ) (Entered: 06/05/2017)

Letter from Co-Monitors Judith Meltzer and Paul Vincent. (Attachments: # 1 Exhibit Co-Monitors Monitoring Report)(sshe, ) (Entered: 09/13/2017)

NOTICE of Hearing: Status Conference set for 11/17/2017 10:00 AM in Courtroom To Be Determined, J. Waties Waring Judicial Cntr, 83 Meeting St, Charleston before Honorable Richard M Gergel. (sshe, ) (Entered: 10/11/2017)

First MOTION to Appear Pro Hac Vice by Stephen Suggs for Stephanie Persson ( Filing fee $ 250 receipt number 0420-7460161) by AB, AR(by his next friend Cheryl Kreider), AR(by her next friend Tamara Coppinger), CB, KS, MB, MH, RB, SB, SV, ZL. Response to Motion due by 11/27/2017. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: # 1 Affidavit Application/Affidavit, # 2 Supporting Documents Certificate of Good Standing, # 3 Proposed Order Proposed Order)Proposed order is being emailed to chambers with copy to opposing counsel.(Suggs, Steve) Modified on 11/14/2017 to add filer as listed on document(sshe, ). (Entered: 11/13/2017)

ORDER granting 65 Motion for Stephanie Persson to Appear Pro Hac Vice for AB, AR(by his next friend Cheryl Kreider), AR(by her next friend Tamara Coppinger), CB, KS, MB, MH, RB, SB, SV, ZL. Signed by Honorable Richard M Gergel on 11/14/2017.(sshe, ) Modified on 11/14/2017 to edit docket text to add represented party(sshe, ). (Entered: 11/14/2017)

Minute Entry. Proceedings held before Honorable Richard M Gergel: Status Conference held on 11/17/2017. Court Reporter Debbie Potocki. (erav, ) (Entered: 11/17/2017)

NOTICE OF FILING OF OFFICIAL TRANSCRIPT of status conference held on 11-17-17, before Judge Richard M. Gergel. Court Reporter/Transcriber Debra Potocki, Telephone number/E-mail potockidebra@bellsouth.net. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Parties have 7 calendar days from the filing of the transcript to file with the court a Notice of Intent to Request Redaction.. Redaction Request due 12/18/2017. Redacted Transcript Deadline set for 12/28/2017. Release of Transcript Restriction set for 2/26/2018. (dpotocki, ) (Entered: 11/27/2017)

NOTICE of Appearance by Thomas Ashley Limehouse, Jr on behalf of Henry Dargan McMaster (Limehouse, Thomas) (Entered: 01/24/2018)

Letter from Co-Monitors Judith Meltzer and Paul Vincent. (Attachments: # 1 Exhibit Co-Monitors Monitoring Report)(sshe, ) (Entered: 04/06/2018)

ORDER The Court hereby orders and directs Defendants to submit to the Court on or before May 21, 2018 a comprehensive five year budget plan that provides year to year budgets for each year and sets forth in detail the additional funding, staff, and other resources necessary to meet each of the performance requirements set forth in IV(A) - (K) of the Settlement Agreement. Further, the Court sets the next status conference with the parties on June 1, 2018 at 10:00 a.m. at the J. Waties Waring Judicial Center. The Court at that time will address in detail the Co-Monitors' report filed on April 6, 2018, any compliance concerns of the Plaintiffs, the Defendants' five year budget plan, and other issues which any of the parties desire to bring to the attention of the Court. See Order for all details. AND IT IS SO ORDERED. Signed by Honorable Richard M Gergel on 4/19/2018. (sshe, ) (Entered: 04/19/2018)

RESPONSE by Susan Alford and Henry Dargan McMaster to 71 Order to Submit. (Attachments: # 1 5-Year Budget Plan)(ltap, ) (Entered: 05/22/2018)

1 5-Year Budget Plan

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Minute Entry. Proceedings held before Honorable Richard M Gergel: Status Conference held on 6/1/2018. Status reports from Co-monitors. Court Reporter Debbie Potocki. (erav, ) (Entered: 06/01/2018)

TEXT ORDER The co-monitors have proposed the use of consultants to assist in certain areas where critical work in meeting the goals of the Settlement Agreement needs to be accomplished. Pursuant to Paragraph III(B) of the Settlement Agreement, the co-monitors have a duty to consult with the parties on these proposed hires, with the ultimate decision left to the discretion of the co-monitors. The Court directs the parties to promptly complete that consultation process and a final decision be made by the co-monitors regarding the consultants on or before June 30, 2018. The co-monitors have also provided the parties their proposed annual budget for their services, pursuant to Paragraph III(I) of the Settlement Agreement. The parties are to advise the co-monitors and the Court in writing on or before June 15, 2018 of any objections to the proposed budget. The co-monitors are to submit to the Court a written response to any written objections by June 22, 2018, and the Court will thereafter approve a budget for the co-monitors for the next 12 months. AND IT IS SO ORDERED. Entered at the Direction of Honorable Richard M Gergel on 6/4/2018. (sshe, ) (Entered: 06/04/2018)

REPLY Letter from Monteith Todd Providing DSS' Objections to Co-Monitors' Budget by Susan Alford to 74 Order.(Todd, Monteith) Filing corrected for event type (sshe, ) (Entered: 06/18/2018)

MOTION for Hearing by Susan Alford. Response to Motion due by 7/5/2018. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. No proposed order.(Laffitte, Rebecca) (Entered: 06/21/2018)

TEXT ORDER: Defendants have moved for a hearing on their objections to the Co-Monitors' budget. (Dkt. No. 76). The Court will set a hearing via telephone conference on July 3, 2018. Details will be provided by the Clerk in the entry of the hearing notice. The parties should appreciate that the Court remains deeply concerned about the lack of meaningful progress in many critical areas addressed in the Settlement Agreement and is aware that the consultants previously retained by the Co-Monitors have contributed to much of the progress that has been made. The Court directs that the Co-Monitors and Ms. Alford participate in the hearing. The Court further directs that the Co-Monitors and Ms. Alford directly communicate between now and the July 3, 2018 hearing in an effort to resolve areas of disagreement. If the matter is not resolved by the parties, the Court will rule promptly on the issues still in dispute. AND IT IS SO ORDERED. Entered at the direction of the Honorable Richard M Gergel on 6/26/2018. (ltap, ) (Entered: 06/26/2018)

NOTICE of Hearing: Telephone Conference on 76 MOTION for Hearing set for 7/3/2018 10:30 AM before Honorable Richard M Gergel. Court staff needed. Defense must provide all parties and the Court conference call-in information for the same no later than July 2nd. AND IT IS SO ORDERED.(ltap, ) (Entered: 06/26/2018)

NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Status Conference held on 6-1-18, before Judge Richard M. Gergel. Court Reporter/Transcriber Debra Potocki, Telephone number/E-mail potockidebra@bellsouth.net. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Parties have 7 calendar days from the filing of the transcript to file with the court a Notice of Intent to Request Redaction.. Redaction Request due 7/23/2018. Redacted Transcript Deadline set for 8/2/2018. Release of Transcript Restriction set for 10/1/2018. (dpotocki, ) (Entered: 07/02/2018)

Withdrawal of Motions: 76 MOTION for Hearing filed by Susan Alford.. (Laffitte, Rebecca) (Entered: 07/02/2018)

NOTICE of Cancellation of Hearing: Telephone Conference 7/3/2018 10:30 AM is CANCELED per 80 Withdrawal of Motion requesting Hearing (sshe, ) (Entered: 07/02/2018)

Co-Monitors proposed budget for 2018 from Co-Monitors. (sshe, ) (Entered: 07/02/2018)

TEXT ORDER The Court has before it the Co-Monitors' proposed budget for 2018. (Dkt. No. 83 ) Defendants initially filed an objection to one aspect of the proposed budget but have since reached an amicable resolution of the matter with the Co-Monitors. (Dkt. Nos. 75, 80). Consequently, the Court hereby approves the Co-Monitors' budget for the calendar year 2018. AND IT IS SO ORDERED. Entered at the Direction of Honorable Richard M Gergel on 7/2/2018. (sshe, ) (Entered: 07/02/2018)

NOTICE of Appearance by Adam Protheroe on behalf of AB, AR(by his next friend Cheryl Kreider), AR(by her next friend Tamara Coppinger), CB, KS, MB, MH, RB, SB, SV, ZL (Protheroe, Adam) (Entered: 08/02/2018)

Letter from Co-Monitors Judith Meltzer and Paul Vincent. (Attachments: # 1 Exhibit Co-Monitors Monitoring Report)(sshe, ) (Entered: 10/01/2018)

1 Exhibit Co-Monitors Monitoring Report

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NOTICE of Hearing: Status Conference set for 12/4/2018 10:00 AM in Charleston Courtroom #1, J. Waties Waring Judicial Center, 83 Meeting St, Charleston before Honorable Richard M Gergel. (sshe, ) (Entered: 11/06/2018)

MOTION for Contempt and Enforcement of Final Settlement Agreement by AB, AR(by his next friend Cheryl Kreider), AR(by her next friend Tamara Coppinger), CB, KS, MB, MH, RB, SB, SV, ZL. Response to Motion due by 12/10/2018. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: # 1 Memo in Support, # 2 Exhibit A - Workforce Report, # 3 Exhibit B - Co-Monitor Letters)No proposed order.(Protheroe, Adam) Modified on 11/29/2018 to reference 91 Supplement filed 11/28/18(sshe, ). (Entered: 11/26/2018)

1 Memo in Support

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2 Exhibit A - Workforce Report

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3 Exhibit B - Co-Monitor Letters

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SUPPLEMENT to 90 MOTION by AB, AR(by his next friend Cheryl Kreider), AR(by her next friend Tamara Coppinger), KS, MB, MH, RB, SB, SV, ZL . (Attachments: # 1 Exhibit A - Co-Monitor Letter re Facility Visits, # 2 Exhibit B - Co-Monitor Letter re Additional Consultants, # 3 Exhibit C - Co-Monitor Response to DSS, # 4 Exhibit D - Co-Monitor Response re DSS Budget Objections, # 5 Exhibit E - Co-Monitor Letter re Children in Facility)(Protheroe, Adam) Modified on 11/29/2018 to link correct event to associated event(sshe, ). (Entered: 11/28/2018)

1 Exhibit A - Co-Monitor Letter re Facility Visits

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2 Exhibit B - Co-Monitor Letter re Additional Consultants

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3 Exhibit C - Co-Monitor Response to DSS

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4 Exhibit D - Co-Monitor Response re DSS Budget Objections

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5 Exhibit E - Co-Monitor Letter re Children in Facility

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RESPONSE in Opposition re 90 MOTION for Contempt and Enforcement of Final Settlement Agreement Response filed by Susan Alford, Henry Dargan McMaster.Reply to Response to Motion due by 12/7/2018 Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6. (Montgomery, John) (Entered: 11/30/2018)

REPLY to Response to Motion re 90 MOTION for Contempt and Enforcement of Final Settlement Agreement Response filed by AB, AR(by his next friend Cheryl Kreider), AR(by her next friend Tamara Coppinger), CB, KS, MB, MH, RB, SB, SV, ZL. (Protheroe, Adam) (Entered: 12/03/2018)

Minute Entry. Proceedings held before Honorable Richard M Gergel: Status Conference held on 12/4/2018. Status conferences to be held every 30 days. Court to issue order regarding new implementations. Court Reporter Debbie Potocki. (cper, ) (Entered: 12/04/2018)

Report from Judith Meltzer. Workforce Assessment by Sue Steib. (sshe, ) (Entered: 12/05/2018)

DELETION OF DOCKET ENTRY NUMBER 96 Reason: per Chambers. Filing date of original filing: 12/5/18 (sshe, ) (Entered: 12/05/2018)

ORDER See Order for All Details. Status Conference set for 1/11/2019 09:00 AM in Charleston Courtroom #1, J. Waties Waring Judicial Center, 83 Meeting St, Charleston before Honorable Richard M Gergel. Signed by Honorable Richard M Gergel on 12/5/2018. (sshe, ) (Entered: 12/05/2018)

TEXT ORDER re: 90 Plaintiffs' Motion for contempt and enforcement of final settlement agreement. In light of the Court's December 5, 2018 Order (Dkt. No. 98), Plaintiffs' motion for contempt and enforcement is denied without prejudice. AND IT IS SO ORDERED. Entered at the direction of the Honorable Richard M Gergel on 12/10/2018.(ltap, ) (Entered: 12/10/2018)

NOTICE OF FILING OF OFFICIAL TRANSCRIPT of status conference held on 12-4-18, before Judge Richard M. Gergel. Court Reporter/Transcriber Debra Potocki, Telephone number/E-mail potockidebra@bellsouth.net. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Parties have 7 calendar days from the filing of the transcript to file with the court a Notice of Intent to Request Redaction.. Redaction Request due 1/7/2019. Redacted Transcript Deadline set for 1/17/2019. Release of Transcript Restriction set for 3/18/2019. (dpotocki, ) (Entered: 12/17/2018)

NOTICE of Hearing: Mediation Hearing set for 1/8/2019 at 10:00 AM in Charleston Courthouse, J. Waties Waring Judicial Center, 83 Meeting St, Charleston (Room Location To Be Determined) before Retired Judge Patrick Michael Duffy. (ltap, ) (Entered: 12/18/2018)

ORDER The Court makes the following modification to Paragraph 5 of the Court's order of December 5, 2018 (Dkt. No. 98 ). See ORDER for details. AND IT IS SO ORDERED. Signed by Honorable Richard M Gergel on 12/21/2018. (sshe, ) (Entered: 12/21/2018)

Minute Entry. Proceedings held before Honorable Richard M Gergel: Status Conference held on 1/11/2019. Order is forthcoming. (Status Conference set for 2/26/2019 10:00 AM in Charleston Courtroom #1, J. Waties Waring Judicial Center, 83 Meeting St, Charleston before Honorable Richard M Gergel). Court Reporter Tana Hess. (cper, ) (Entered: 01/11/2019)

ORDER The Court conducted a status conference on January 11, 2019 to discuss the continued work of the South Carolina Department of Social Services ("DSS") with the Co-Monitors to make the meaningful reforms necessary to meet the benchmarks and standards of the October 4, 2016 Settlement Agreement. See Order for All Details re implementation of these reforms. NOTICE of Hearing The next monthly Status Conference is set for 2/26/2019 at 10:00 AM in Charleston Courtroom #1, J. Waties Waring Judicial Center, 83 Meeting St, Charleston before Honorable Richard M Gergel. Signed by Honorable Richard M Gergel on 1/15/2019. (sshe, ) (Entered: 01/15/2019)

NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Proceedings. Status Conference held on January 11, 2019, before Judge Richard M. Gergel. Court Reporter/Transcriber Tana J. Hess, Telephone number/E-mail 843.779.0837 tana_hess@scd.uscourts.gov. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Parties have 7 calendar days from the filing of the transcript to file with the court a Notice of Intent to Request Redaction.. Redaction Request due 3/4/2019. Redacted Transcript Deadline set for 3/14/2019. Release of Transcript Restriction set for 5/13/2019. (thes, ) (Entered: 02/11/2019)

MOTION for Extension of Time Regarding Health Care Implementation Plan by Susan Alford. Response to Motion due by 3/6/2019. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. No proposed order.(Laffitte, Rebecca) (Entered: 02/20/2019)

Minute Entry. Proceedings held before Honorable Richard M Gergel: finding as moot 107 Motion for Extension of Time; Status Conference held on 2/26/2019. Budget staff is to be present at the April Status conference. Before the April status conference, the foster care rate number is to be established, the placement plan's undetermined numbers are to be determined, the family visitation plan is to be resolved and what constitutes a visit is to be defined. (Status Conference set for 4/2/2019 10:00 AM in Charleston Courtroom #1, J. Waties Waring Judicial Center, 83 Meeting St, Charleston before Honorable Richard M Gergel.) Court Reporter Debbie Potocki. (cper, ) (Entered: 02/26/2019)

ORDER The Court conducted a status conference on February 26, 2019 to discuss the continued work of the South Carolina Department of Social Services ("DSS") with the Co-Monitors to comply with the provisions of the benchmarks and standards of the October 4, 2016 Settlement Agreement. See Order for All Details re continued implementation of the mandates of the Settlement Agreement. The next monthly Status Conference is set for 4/2/2019 at 10:00 AM. AND IT IS SO ORDERED. Signed by Honorable Richard M Gergel on 2/27/2019. (sshe, ) (Entered: 02/27/2019)