Case: Reynolds v. Judicial Correction Services

Reynolds v. Judicial Correction Services, Inc.

U.S. Department of Justice

COMPLAINT against City of Clanton, Judicial Correction Services, Inc., and Steven Raymond ( Filing fee $ 400.00 receipt number 4602036045.), filed by Rodney Ware, Roxanne Reynolds, Edward Tylee Williams. (Attachments: # 1 Filing Fee Receipt)(dmn, ) Modified on 3/17/2015 to include Steven Raymond as a defendant, omitted in error at original time of filing. (dmn, ) (Entered: 03/13/2015)

1 Filing Fee Receipt

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DEMAND for Trial by Jury by Roxanne Reynolds, Rodney Ware, Edward Tylee Williams. (dmn, ) (This document has no pdf attached, see Doc. 1 for pdf.)

Corporate/Conflict Disclosure Statement by Edward Tylee Williams. (dmn, ) (Entered: 03/13/2015)

Corporate/Conflict Disclosure Statement by Roxanne Reynolds. (dmn, ) (Entered: 03/13/2015)

Corporate/Conflict Disclosure Statement by Rodney Ware. (dmn, ) (Entered: 03/13/2015)

Summons Issued; summons and complaint mailed CMRRR to City of Clanton, Judicial Correction Services, Inc., Steven Raymond. (dmn, ) (Entered: 03/17/2015)

NOTICE of Docket Text Correction re 1 Complaint. Steven Raymond was added to the docket text of the referenced document, omitted in error at original time of filing. (dmn, )

Return Receipt Card showing service of complaint and summons signed by Laura Payne for Judicial Correction Services, Inc. served on 3/16/2015, answer due 4/6/2015. (dmn, ) (Entered: 03/18/2015)

Return Receipt Card showing service of complaint and summons signed by Faith Pickett for City of Clanton served on 3/16/2015, answer due 4/6/2015. (dmn, ) (Entered: 03/20/2015)

Return Receipt Card showing service of complaint and summons signed by Steven Raymond for Steven Raymond served on 3/19/2015, answer due 4/9/2015. (dmn, ) (Entered: 03/24/2015)

AFFIDAVIT of Service for Summons & Complaint served on Lisa Losole, agent of Defendant Judicial Correction Service, Inc. on 03/24/2015, filed by Roxanne Reynolds, Rodney Ware, Edward Tylee Williams. (Brooke, Samuel) (Entered: 03/24/2015)

SUMMONS Returned Executed by Rodney Ware, Roxanne Reynolds, Edward Tylee Williams. Judicial Correction Services, Inc. served on 3/24/2015, answer due 4/14/2015. (dmn, ) (This document has no pdf attached, see Doc. 9 for pdf. Original docket entry did not set answer deadline.)

NOTICE of Appearance by Valentina Restrepo on behalf of All Plaintiffs (Restrepo, Valentina) (Entered: 03/30/2015)

AMENDED COMPLAINT against City of Clanton, Judicial Correction Services, Inc., Steven Raymond, filed by Rodney Ware, Roxanne Reynolds, Edward Tylee Williams.(Zampierin, Sara) (Entered: 03/30/2015)

MOTION to Certify Class by Roxanne Reynolds, Rodney Ware, Edward Tylee Williams. (Attachments: # 1 Text of Proposed Order Proposed Order Granting Motion for Class Certification)(Zampierin, Sara) (Entered: 03/30/2015)

1 Text of Proposed Order Proposed Order Granting Motion for Class Certification

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BRIEF/MEMORANDUM in Support re 12 MOTION to Certify Class filed by Roxanne Reynolds, Rodney Ware, Edward Tylee Williams. (Zampierin, Sara) (Entered: 03/30/2015)

MOTION for Preliminary Injunction by Roxanne Reynolds, Rodney Ware, Edward Tylee Williams. (Attachments: # 1 Text of Proposed Order Proposed Preliminary Injunction Order)(Zampierin, Sara) (Entered: 03/30/2015)

1 Text of Proposed Order Proposed Preliminary Injunction Order

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BRIEF/MEMORANDUM in Support re 14 MOTION for Preliminary Injunction filed by Roxanne Reynolds, Rodney Ware, Edward Tylee Williams. (Zampierin, Sara) (Entered: 03/30/2015)

AFFIDAVIT in Support re 14 MOTION for Preliminary Injunction, 12 MOTION to Certify Class filed by Roxanne Reynolds, Rodney Ware, Edward Tylee Williams. (Zampierin, Sara) (Entered: 03/30/2015)

AFFIDAVIT in Support re 14 MOTION for Preliminary Injunction, 12 MOTION to Certify Class filed by Roxanne Reynolds, Rodney Ware, Edward Tylee Williams. (Zampierin, Sara) (Entered: 03/30/2015)

AFFIDAVIT in Support re 14 MOTION for Preliminary Injunction, 12 MOTION to Certify Class filed by Roxanne Reynolds, Rodney Ware, Edward Tylee Williams. (Zampierin, Sara) (Entered: 03/30/2015)

AFFIDAVIT in Support re 14 MOTION for Preliminary Injunction, 12 MOTION to Certify Class filed by Roxanne Reynolds, Rodney Ware, Edward Tylee Williams. (Zampierin, Sara) (Entered: 03/30/2015)

Summons Issued as to City of Clanton, Judicial Correction Services, Inc.; returned to Counsel for personal service. (scn, ) (Entered: 03/31/2015)

Summons Issued as to Steven Raymond; mailed CMRRR with documents 10 - 19 . (scn, ) (Entered: 03/31/2015)

SUMMONS Returned Executed by Rodney Ware, Roxanne Reynolds, Edward Tylee Williams. City of Clanton served on 3/31/2015, answer due 4/21/2015. (Brooke, Samuel) (Entered: 03/31/2015)

SUMMONS Returned Executed by Rodney Ware, Roxanne Reynolds, Edward Tylee Williams. Judicial Correction Services, Inc. served on 3/31/2015, answer due 4/21/2015. (Brooke, Samuel) (Entered: 03/31/2015)

Set Hearings: Telephone Conference set for 4/8/2015 at 08:15 AM by telephone before Honorable Judge Myron H. Thompson. (war, )

Minute Entry for proceedings held before Honorable Judge Myron H. Thompson: Telephone Conference held on 4/8/2015 (PDF available for court use only). (Recording Time FTR: 8:18 AM - 8:41 AM.) (war, ) (Entered: 04/08/2015)

NOTICE of Appearance by Richard Warren Kinney on behalf of City of Clanton (Kinney, Richard) (Entered: 04/08/2015)

NOTICE of Appearance by Michael Leon Jackson on behalf of Judicial Correction Services, Inc., Steven Raymond (Jackson, Michael) (Entered: 04/08/2015)

NOTICE of Appearance by Larry Stephen Logsdon on behalf of Judicial Correction Services, Inc., Steven Raymond (Logsdon, Larry) (Entered: 04/08/2015)

***Attorney James Wallace Porter, II added for City of Clanton. (dmn, ) (see Doc. 25 for pdf)

ORDER: Based upon representations made on the record on 4/8/2015, it is ORDERED that the 14 Motion for Preliminary Injunction and the 12 Motion for Class Certification are set for hearing on 5/12/2015 at 10:00 AM in Courtroom 2FMJ in Montgomery, AL before Honorable Judge Myron H. Thompson. The defendants are to file responses to the motions by 4/27/2015, and the plaintiffs may file replies by 5/4/2015. Signed by Honorable Judge Myron H. Thompson on 4/9/2015. Copies furnished to calendar group, AG. (dmn, ) (Entered: 04/09/2015)

Corporate/Conflict Disclosure Statement by City of Clanton. (Kinney, Richard) (Entered: 04/09/2015)

ORDER that this matter be and is hereby set for a Mediation Conference on 4/28/2015 at 10:00 AM in Courtroom 4B in Montgomery, AL before Honorable Judge Charles S. Coody. It is further ORDERED that counsel and the parties or a representative with full authority to settle the case shall appear at and attend this conference. The plaintiff should be prepared to present documents substantiating any claims for damages. On or before the close of business on 4/24/2015, each party shall provide the undersigned judge with a confidential mediation conference statement.Signed by Honorable Judge Charles S. Coody on 4/9/2015. Copies furnished to calendar group, WS. (dmn, ) (Entered: 04/09/2015)

Corporate/Conflict Disclosure Statement by Judicial Correction Services, Inc.. (Jackson, Michael) (Entered: 04/10/2015)

Corporate/Conflict Disclosure Statement by Steven Raymond. (Jackson, Michael) (Entered: 04/10/2015)

Return Receipt Card showing service of summons & 11 amended complaint, docs 10 through 19 signed by Steven Raymond for Steven Raymond served on 4/6/2015, answer due 4/27/2015. (djy, ) (Entered: 04/14/2015)

Minute Entry for proceedings held before Honorable Judge Charles S. Coody: Mediation Conference Call held on 4/13/2015 (No PDF Attached). (ws, )

Evidentiary Submission re 12 MOTION to Certify Class Supplemental Submission of Evidence In Support of Motion for Class Certification filed by Roxanne Reynolds, Rodney Ware, Edward Tylee Williams. (Attachments: # 1 Brooke Decl and Exs. J to K)(Brooke, Samuel) (Entered: 04/14/2015)

1 Brooke Decl and Exs. J to K

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Minute Entry for proceedings held before Honorable Judge Charles S. Coody: Mediation Conference Call held on 4/15/2015 ( No PDF attached). (ws, )

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM, MOTION to Dismiss for Lack of Jurisdiction by Judicial Correction Services, Inc., Steven Raymond. (Attachments: # 1 Exhibit 1)(Jackson, Michael) (Entered: 04/21/2015)

1 Exhibit 1

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MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM, MOTION to Dismiss for Lack of Jurisdiction by City of Clanton. (Kinney, Richard) (Entered: 04/21/2015)

BRIEF/MEMORANDUM in Support re 36 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM MOTION to Dismiss for Lack of Jurisdiction filed by City of Clanton. (Kinney, Richard) (Entered: 04/21/2015)

***Attorney Wesley Kyle Winborn added for Judicial Correction Services, Inc. (dmn, ) (see Doc. 35 for pdf)

***Attorney Wesley Kyle Winborn added for Steven Raymond. (dmn, ) (see Doc. 35 for pdf)

RESPONSE to Motion re 14 MOTION for Preliminary Injunction filed by City of Clanton. (Kinney, Richard) (Entered: 04/27/2015)

RESPONSE to Motion re 12 MOTION to Certify Class filed by Judicial Correction Services, Inc., Steven Raymond. (Jackson, Michael) (Entered: 04/27/2015)

RESPONSE in Opposition re 14 MOTION for Preliminary Injunction filed by Judicial Correction Services, Inc., Steven Raymond. (Jackson, Michael) (Entered: 04/27/2015)

MOTION to Strike 16 Affidavit, 18 Affidavit, 17 Affidavit, 19 Affidavit in Support of Plaintiff's 14 Motion for Preliminary Injunction and 12 Motion for Class Certification by Judicial Correction Services, Inc., Steven Raymond. (Jackson, Michael) Modified on 4/28/2015 to clean up text and create links to Docs. 12 and 14 . (dmn, ) (Entered: 04/27/2015)

RESPONSE in Opposition re 36 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM MOTION to Dismiss for Lack of Jurisdiction, 35 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM MOTION to Dismiss for Lack of Jurisdiction filed by Roxanne Reynolds, Rodney Ware, Edward Tylee Williams. (Brooke, Samuel) (Entered: 04/27/2015)

RESPONSE to 12 MOTION for Class Certification and MOTION to Strike Class Allegations filed by City of Clanton. (Kinney, Richard) Modified on 4/28/2015 to reflect actual title and include motion text. (dmn, ) (Entered: 04/27/2015)

MOTION to Strike Class Allegations in the 11 Amended Complaint by City of Clanton. (dmn, ) (This document has no pdf attached, see Doc. 43 for pdf.)

ORDER as follows: (1) Defendants Judicial Correction Services, Inc. and Steven Raymond's 41 Motion to Strike is denied as further set out in the order. (2) However, to the extent defendants Judicial Correction Services, Inc. and Steven Raymond are merely objecting to the admissibility of evidence, the plaintiffs are allowed until 5/5/2015, to respond. In resolving the pending preliminary-injunction and class-certification motions, the court has implicitly considered the motion to strike as a notice of objections to the testimony described. The court is capable of sifting evidence, as is required, without resort to an exclusionary process, and the court will not allow this stage of the litigation to degenerate into a battle of motions to strike. Rather, as is apparent from this order, the court will entertain briefs on the admissibility of evidence. Signed by Honorable Judge Myron H. Thompson on 4/28/2015. (dmn, ) (Entered: 04/28/2015)

Strike

ORDER that the Mediation Conference be and is hereby continued to 5/7/2015 at 10:00 AM in Courtroom 4B in Montgomery, AL before Honorable Judge Charles S. Coody. Signed by Honorable Judge Charles S. Coody on 4/28/2015. Copies furnished to calendar group, WS.(Deadline terminated: Mediation Conference set for 4/28/2015.)(dmn, ) (Entered: 04/28/2015)

Joint MOTION for Extension of Deadline ALL DEADLINES FOR 60 DAYS re 36 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM MOTION to Dismiss for Lack of Jurisdiction, 44 Order on Motion to Strike,,, 14 MOTION for Preliminary Injunction, 35 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM MOTION to Dismiss for Lack of Jurisdiction, 12 MOTION to Certify Class, 28 Order Setting Hearing on Motion,, by Roxanne Reynolds, Rodney Ware, Edward Tylee Williams. (Brooke, Samuel) (Entered: 04/28/2015)

Minute Entry for proceedings held before Honorable Judge Charles S. Coody: Mediation Conference held on 4/28/2015 (NO PDF Attached). (ws, )

ORDER as follows: (1) The 46 Motion for Extension of Deadlines is granted. (2) The 14 Motion for Preliminary Injunction, the 12 Motion for Class Certification, and the Motions to Dismiss (doc. nos. 35 and 36 ), are reset for hearing on 7/14/2015. Motion Hearing set for 7/14/2015 at 10:00 AM in Courtroom 2FMJ in Montgomery, AL before Honorable Judge Myron H. Thompson. (3) All briefs and responses that were due May 4 and 5, 2015, are now due 7/7/2015. Signed by Honorable Judge Myron H. Thompson on 4/30/2015. Copies furnished to calendar group, AG. (dmn, ) (Entered: 04/30/2015)

ORDER as follows: (1) Defendant City of Clanton's 43 Motion to Strike is denied. (2) However, to the extent defendant City of Clanton is merely objecting that plaintiffs have failed to meet the requirements of FRCP 23, the plaintiffs are allowed until 7/7/2015 to respond. In resolving the pending class-certification motion, the court has implicitly considered the motion to strike as an objection that the plaintiffs have failed to comply with Rule 23. The court is capable of addressing the legal issues, as is required, without resort to an exclusionary process, and the court will not allow this stage of the litigation to degenerate into a battle of motions to strike. Rather, as is apparent from this order, the court will entertain briefs on the objection. Signed by Honorable Judge Myron H. Thompson on 4/30/2015. (dmn, ) (Entered: 04/30/2015)

ORDER that the Mediation Conference be and is hereby continued to 5/14/2015 at 10:00 AM in Courtroom 4B in Montgomery, AL before Honorable Judge Charles S. Coody. Signed by Honorable Judge Charles S. Coody on 5/7/2015. (Deadline terminated: Mediation Conference set for 5/7/2015.)(dmn, ) (Entered: 05/07/2015)

Minute Entry for proceedings held before Honorable Judge Charles S. Coody: Mediation Conference held on 5/7/2015 (No PDF attached). (ws, )

Minute Entry for proceedings held before Honorable Judge Charles S. Coody: Mediation Conference held on 5/14/2015 (NO PDF Attached). (ws, )

NOTICE of Appearance by Will Hill Tankersley, Jr on behalf of City of Clanton (Tankersley, Will) (Entered: 05/28/2015)

NOTICE of Appearance by Lewis Conrad Anderson, IV on behalf of City of Clanton (Anderson, Lewis) (Entered: 05/28/2015)

NOTICE of Appearance by Chase T Espy on behalf of City of Clanton (Espy, Chase) (Entered: 05/28/2015)

Minute Entry for proceedings held before Honorable Judge Charles S. Coody: Mediation Conference held on 6/3/2015 (NO PDF Attached). (ws, )

ORDER continuing the Mediation Conference to 6/16/2015 10:00 AM before Honorable Judge Charles S. Coody, in Courtroom 4B, US Courthouse, Montgomery, AL. Signed by Honorable Judge Charles S. Coody on 6/10/15. Furnished to calendar and WS (reset from 5/14/2015).(djy, ) (Entered: 06/10/2015)

Joint MOTION to Dismiss Dismissing Defendant City of Clanton by Roxanne Reynolds, Rodney Ware, Edward Tylee Williams, and City of Clanton. (Attachments: # 1 Exhibit A - Settlement Agreement)(Brooke, Samuel) Modified on 6/17/2015 to add additional filer. (dmn, ) (Entered: 06/16/2015)

1 Exhibit A - Settlement Agreement

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Minute Entry for proceedings held before Honorable Judge Charles S. Coody: Mediation Conference held on 6/16/2015 (NO PDF Attached). (ws )

JUDGMENT directing as follows: (1) The joint motion to dismiss defendant City of Clanton (doc no. 54 ) is granted; (2) Counts three and four of the amended complaint (doc. no. 11 ) are dismissed; (3) Defendant City of Clanton is dismissed without p rejudice and terminated as a party, with costs taxed as paid, as further set out; further ORDERED that defendant City of Clanton's motion to dismiss (doc. no. 36 ) is denied as moot; the clerk of the court is DIRECTED to enter this document on the civil docket as a final judgment pursuant to Rule 58 of the Federal Rules of Civil Procedure; this case is not closed. Signed by Honorable Judge Myron H. Thompson on June 19, 2015. (Attachments: # 1 Civil Appeals Checklist)(scn, )

1 Civil Appeals Checklist

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MOTION to Withdraw 14 MOTION for Preliminary Injunction, 12 MOTION to Certify Class by Roxanne Reynolds, Rodney Ware, Edward Tylee Williams. (Brooke, Samuel) (Entered: 06/19/2015)

ORDER setting a Status Conference for 7/7/2015 @ 10:00 AM before Honorable Judge Charles S. Coody, by telephone conference call; def Judicial Corrections Services, Inc. shall set up the conference call. Signed by Honorable Judge Charles S. Coody on 6/29/15. Furnished to calendar group & WS.(djy, ) (Entered: 06/29/2015)

Unopposed MOTION for Extension of Time on Briefs Due July 7, 2015 re 47 Order and MOTION to Continue Hearing on Motion to Dismiss (Doc. 35 and 36 ) by Judicial Correction Services, Inc., Steven Raymond. (Jackson, Michael) Modified on 7/6/2015 to reflect actual title and create link to Doc. 35 and 36 . (dmn, ) (Entered: 07/02/2015)

MOTION to Continue Hearing on Motion to Dismiss (Doc. 35 and 36 ) by Judicial Correction Services, Inc., Steven Raymond. (dmn, ) (NO PDF, see Doc. 58 for pdf.)

ORDER that the Status Conference presently set for 7/7/2015 at 10:00 AM be and is hereby RESET to 7/7/2015 at 03:00 PM by telephone conference call before Honorable Judge Charles S. Coody. Signed by Honorable Judge Charles S. Coody on 7/6/2015. Copies furnished to calendar group, WS. (dmn, ) (Entered: 07/06/2015)

Continue

ORDER that the 56 Motion to Withdraw is granted and that the 14 Motion for Preliminary Injunction and the 12 Motion to Certify Class are withdrawn. Signed by Honorable Judge Myron H. Thompson on 7/7/2015. (dmn, ) (Entered: 07/07/2015)

ORDER as follows: (1) The 58 Motion for Extension of Time and to Continue is granted. (2) The 35 Motion to Dismiss is reset for hearing on 8/27/2015. Motion Hearing set for 8/27/2015 10:00 AM in Courtroom 2FMJ in Montgomery, AL before Honorable Judge Myron H. Thompson. (3) All briefs and responses that were due 7/7/2015, are now due 8/20/2015. Signed by Honorable Judge Myron H. Thompson on 7/7/2015. Copies furnished to calendar group, AG. (Deadline terminated: Motion Hearing set for 7/14/2015.) (dmn, ) Modified on 7/7/2015 to include terminated deadline text. (dmn, ) (Entered: 07/07/2015)

Minute Entry for proceedings held before Honorable Judge Charles S. Coody: Status Conference held on 7/7/2015 ( NO PDF available ). (ws, )

RESPONSE to Motion re 35 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM MOTION to Dismiss for Lack of Jurisdiction, Responding to Plaintiffs' Opposition, filed by Judicial Correction Services, Inc., Steven Raymond. (Jackson, Michael) (Entered: 08/20/2015)

Minute Entry for proceedings held before Honorable Judge Myron H. Thompson: Motion Hearing held on 8/27/2015 re 35 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM MOTION to Dismiss for Lack of Jurisdiction filed by Steven Raymond, Judicial Correction Services, Inc. (PDF available for court use only). (Court Reporter Patricia Starkie.) (Attachments: # 1 Court's Exhibit) (ag, ) (Entered: 08/27/2015)

MOTION and incorporated memorandum of law for Leave to File Sur-Reply by Roxanne Reynolds, Rodney Ware, Edward Tylee Williams. (Attachments: # 1 Exhibit 1 - Plaintiffs' Proposed Sur-Reply)(Brooke, Samuel) Modified on 9/2/2015 to add additional text. (dmn, ) (Entered: 09/01/2015)

1 Exhibit 1 - Plaintiffs' Proposed Sur-Reply

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NOTICE OF FILING OF OFFICIAL TRANSCRIPT of MOTION HEARING Proceedings (PDF ACCESS RESTRICTED FOR 90 DAYS) held on August 27, 2015, in Montgomery, AL before Judge Myron H. Thompson. Court Reporter/Transcriber Patricia G. Starkie, Telephone number 334-262-1221. 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. NOTICE OF INTENT TO REQUEST REDACTION DUE WITHIN 7 BUSINESS DAYS. Redaction Request due 9/29/2015. Redacted Transcript Deadline set for 10/9/2015. Release of Transcript Restriction set for 12/7/2015. (dmn, ) (Entered: 09/08/2015)

TEXT ORDER granting 64 Motion for Leave to File Sur-Reply. Signed by Honorable Judge Myron H. Thompson on 9/15/2015. (dmn, )(NO PDF) (Entered: 09/15/2015)

Order on Motion for Leave to File

REPORT of Rule 26(f) Planning Meeting. (Brooke, Samuel) (Entered: 12/08/2015)

Joint MOTION for Entry of Protective Order by Judicial Correction Services, Inc. with the consent of the Plaintiffs. (Attachments: # 1 Text of Proposed Order Proposed Protective Order)(Jackson, Michael) Modified on 1/11/2016 to include consent statement. (dmn, ) (Entered: 01/08/2016)

1 Text of Proposed Order Proposed Protective Order

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ORDER that the 68 Motion for Protective Order be and is hereby DENIED as further set out in the order. On or before 1/28/2016, the parties may file a renewed motion with a proposed order that comports with Chicago Tribune. Signed by Honorable Judge Charles S. Coody on 1/14/2016. (dmn, ) (Entered: 01/14/2016)

Renewed Joint MOTION for Entry of Protective Order by Judicial Correction Services, Inc., Edward Tylee Williams, Rodney Ware, and Roxanne Reynolds. (Attachments: # 1 Text of Proposed Order Consent Protective Order)(Jackson, Michael) Modified on 1/22/2016 to add additional filers and reflect this is a "renewed" motion. (dmn, ) (Entered: 01/21/2016)

1 Text of Proposed Order Consent Protective Order

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CONSENT PROTECTIVE ORDER granting 70 Renewed Joint Motion for Entry of a Protective Order as further set out in the order. Signed by Honorable Judge Charles S. Coody on 1/27/2016. (dmn, ) (Entered: 01/27/2016)

MOTION to Withdraw as Attorney, Motion to Appear Pro Hac Vice, MOTION to Substitute Attorney by Roxanne Reynolds, Rodney Ware, Edward Tylee Williams. (Attachments: # 1 Exhibit Certificate of Good Standing, # 2 Text of Proposed Order)(Brooke, Samuel) (Entered: 04/19/2016)

1 Exhibit Certificate of Good Standing

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2 Text of Proposed Order

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Order on Motion to Substitute Attorney AND Order on Motion for Leave to Appear Pro Hac Vice AND Order on Motion to Withdraw as Attorney

Motion for Ivy Wang to Appear Pro Hac Vice Filing Fee: $ 50.00, receipt number 4602040839 (kh, ) (Entered: 04/19/2016)

TEXT ORDER granting 72 Motion to Withdraw as Attorney; granting 72 Motion for Leave to Appear Pro Hac Vice; granting 72 Motion to Substitute Attorney. Signed by Honorable Judge Myron H. Thompson on 4/19/2016. (no pdf document attached to this entry)(kh, ) (Entered: 04/19/2016)

***Attorney Ivy Wang for Roxanne Reynolds, Rodney Ware, Edward Tylee Williams added. Attorney Valentina Restrepo terminated pursuant to the 74 order. (kh, )

NOTICE by Roxanne Reynolds, Rodney Ware, Edward Tylee Williams of Supplemental Authority (Attachments: # 1 Exhibit A - Town of Harpersville v. Judicial Corr. Servs.)(Zampierin, Sara) (Entered: 05/03/2016)

1 Exhibit A - Town of Harpersville v. Judicial Corr. Servs.

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NOTICE of Appearance by Caren E Short on behalf of All Plaintiffs (Short, Caren) (Entered: 06/03/2016)

MOTION to Stay Proceedings and Notice of Settlement in Principle (Unopposed) by Roxanne Reynolds, Rodney Ware, Edward Tylee Williams. (Brooke, Samuel) (Entered: 08/19/2016)

ORDERED as follows: (1) The motion to stay (doc. no. 77 ) is granted. (2) All proceedings in this case are stayed until further order of the court. (3) All other pending motions are denied as moot. (4) On or before the first Wednesday in October and the first Wednesday of each month after that the parties are to file a status report on this litigation. (5) This case is closed administratively during the stay. Signed by Honorable Judge Myron H. Thompson on 8/24/2016. (kh, ) (Entered: 08/24/2016)