Case: Black Love Resists in the Rust v. City of Buffalo

Black Love Resists et al v. City of Buffalo et al,

Center for Constitutional Rights

Tessa Bialek

U.S. Department of Justice

COMPLAINT against City of Buffalo $ 400 receipt number 0209-3149240, filed by Black Love Resists. (Attachments: # 1 Civil Cover Sheet, # 2 Civil Cover Sheet Attachment, # 3 Summons, # 4 Summons, # 5 Summons, # 6 Summons, # 7 Summons, # 8 Summons, # 9 Summons, # 10 Summons, # 11 Attachment, # 12 Exhibit Summons)(Williams, Keisha) (Entered: 06/28/2018)

1 Civil Cover Sheet

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2 Civil Cover Sheet Attachment

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3 Summons

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4 Summons

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5 Summons

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6 Summons

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7 Summons

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8 Summons

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9 Summons

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10 Summons

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11 Attachment

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12 Exhibit Summons

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Case assigned to Hon. Christina Clair Reiss. Notification to chambers of on-line civil opening. (KLH)

Case Assigned/Reassigned

Notice of Availability of Magistrate Judge: A United States Magistrate of this Court is available to conduct all proceedings in this civil action in accordance with 28 U.S.C. 636c and FRCP 73. The Notice, Consent, and Reference of a Civil Action to a Magistrate Judge form (AO-85) is available for download at http://www.uscourts.gov/services-forms/forms. (KLH)

Notice of Availability of Magistrate Judge

AUTOMATIC REFERRAL to Mediation The ADR Plan is available for download at http://www.nywd.uscourts.gov/alternative-dispute-resolution. (KLH)

Automatic Referral to Mediation

Summons Issued as to Kevin Brinkworth, Byron B Brown, City of Buffalo, N.Y., Daniel Derenda, Byron C Lockwood, Philip Serafini, Robbin Thomas, Aaron Young. (KLH) (Entered: 06/29/2018)

AFFIDAVIT of Service for Summons & Complaint served on Daniel Derenda on July 9, 2018, filed by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, De'Jon Hall, Taniqua Simmons. (Williams, Keisha) (Entered: 07/24/2018)

SUMMONS Returned Executed by Jane Doe, Dorethea Franklin, Black Love Resists in the Rust, Taniqua Simmons, De'Jon Hall. Byron C Lockwood served on 7/9/2018, answer due 7/30/2018. (Williams, Keisha) (Entered: 07/24/2018)

SUMMONS Returned Executed by Jane Doe, Dorethea Franklin, Black Love Resists in the Rust, Taniqua Simmons, De'Jon Hall. City of Buffalo, N.Y. served on 7/9/2018, answer due 7/30/2018. (Williams, Keisha) (Entered: 07/24/2018)

ANSWER to 1 Complaint, by Kevin Brinkworth, Byron B Brown, City of Buffalo, N.Y., Daniel Derenda, Byron C Lockwood, Philip Serafini, Robbin Thomas, Unknown Officers 1-20, Unknown Supervisory Personnel 1-10, Aaron Young. (Attachments: # 1 Certificate of Service)(Quinn, Robert) (Entered: 07/30/2018)

1 Certificate of Service

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ADR Plan electronically forwarded to attorneys. The ADR Plan is available for download at http://www.nywd.uscourts.gov/alternative-dispute-resolution.(KLH)

ADR Plan

Z ** DEACTIVATED** ADR Plan

ORDER regarding Scheduling Conference set for 10/9/2018 03:00 PM in US Courthouse, 2 Niagara Square, Buffalo, NY 14202-3350 before Hon. Christina Clair Reiss, who will appear by videoconference. Signed by Hon. Christina Clair Reiss on 8/21/2018. (Attachments: # 1 Case Management Order Template)(KLH) (Entered: 08/22/2018)

1 Case Management Order Template

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SUMMONS Returned Executed by Jane Doe, Dorethea Franklin, Black Love Resists in the Rust, Taniqua Simmons, De'Jon Hall. Philip Serafini served on 9/8/2018, answer due 10/1/2018. (Williams, Keisha) (Entered: 09/17/2018)

SUMMONS Returned Executed by Jane Doe, Dorethea Franklin, Black Love Resists in the Rust, Taniqua Simmons, De'Jon Hall. Kevin Brinkworth served on 9/11/2018, answer due 10/2/2018. (Williams, Keisha) (Entered: 09/17/2018)

SUMMONS Returned Executed by Jane Doe, Dorethea Franklin, Black Love Resists in the Rust, Taniqua Simmons, De'Jon Hall. Aaron Young served on 9/5/2018, answer due 9/26/2018. (Williams, Keisha) (Entered: 09/17/2018)

SUMMONS Returned Executed by Jane Doe, Dorethea Franklin, Black Love Resists in the Rust, Taniqua Simmons, De'Jon Hall. Byron B Brown served on 9/6/2018, answer due 9/27/2018. (Williams, Keisha) (Entered: 09/17/2018)

SUMMONS Returned Executed by Jane Doe, Dorethea Franklin, Black Love Resists in the Rust, Taniqua Simmons, De'Jon Hall. Robbin Thomas served on 9/8/2018, answer due 10/1/2018. (Williams, Keisha) (Entered: 09/17/2018)

DISCOVERY PLAN by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, De'Jon Hall, Taniqua Simmons.(Wilner, Claudia) (Entered: 09/19/2018)

Minute Entry for proceedings held before Hon. Christina Clair Reiss. Scheduling Conference via video conference held on 10/9/2018. Parties have agreed to select a mediator and complete first mediation session by 12/1/2018. Discovery schedule, potential class action, proposed protective order and general case management issues discussed. The Court will schedule a further telephone conference in 60 days. Parties may contact the Court directly for assistance with discovery issues. Appearances: Darius Charney, Esq., Anjana Malhotra, Esq., and Claudia Wilner, Esq., on behalf of plaintiffs; Robert Quinn, Esq., on behalf of defendants. (Court Reporter FTR Gold.) (JDK) (Entered: 10/09/2018)

ORDER. The 13 Joint Discovery Plan is SO ORDERED. Please note: This docket entry does not contain every detail of this order. It is your responsibility to read and download the pdf to this document for future reference. Motions to Join Parties/Amend Pleadings due by 5/14/2019, Discovery completed by 6/14/2019, Expert Witness List due by 9/13/2019, Motions due by 10/9/2019. Signed by Hon. Christina Clair Reiss on 10/9/2018. (KLH) (Entered: 10/09/2018)

NOTICE of Hearing: Telephone Status Conference set for 12/21/2018 11:00 AM before Hon. Christina Clair Reiss. Call-in instructions will be emailed shortly before this conference is held. (LMD)

Notice of Hearing

NOTICE of Appearance by Andrea Chinyere Ezie on behalf of All Plaintiffs (Ezie, Andrea) (Entered: 10/29/2018)

Stipulation-Selection of Mediator by Kevin Brinkworth, Byron B Brown, City of Buffalo, N.Y., Daniel Derenda, Byron C Lockwood, Philip Serafini, Robbin Thomas, Unknown Officers 1-20, Unknown Supervisory Personnel 1-10, Aaron Young (Attachments: # 1 Certificate of Service)(Quinn, Robert) (Entered: 11/06/2018)

1 Certificate of Service

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Minute Entry for proceedings held before Hon. Christina Clair Reiss. Telephone Status Conference held on 12/21/2018. Discovery issues discussed. The Court will not intervene in discovery dispute at this time, but directs the parties to contact the Court within the next 30 days either individually or jointly regarding issues that can not be resolved. The Court will schedule either a telephone conference or a video conference following report of the parties. Appearances: Claudia Wilner, Esq., Andrea Ezie, Esq., Britney Wilson, Esq., Darius Charney, Esq., Travis England, Esq., Anjana Malhotra, Esq., on behalf of plaintiffs; Robert Quinn, Esq., on behalf of defendants. (Court Reporter FTR Gold.) (JDK) (Entered: 12/21/2018)

Letter filed by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, De'Jon Hall, Taniqua Simmons as to Aaron Young, City of Buffalo, N.Y., Philip Serafini, Unknown Officers 1-20, Byron C Lockwood, Kevin Brinkworth, Robbin Thomas, Unknown Supervisory Personnel 1-10, Byron B Brown, Daniel Derenda re Current Status of Discovery. (Charney, Darius) (Entered: 01/22/2019)

TEXT ORDER granting 19 letter request for an extension of time. Signed by Hon. Christina Clair Reiss on 1/25/2019. (KLH) (Entered: 01/28/2019)

Letter filed by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, De'Jon Hall, Michael Menard, Taniqua Simmons as to Aaron Young, City of Buffalo, N.Y., Philip Serafini, Unknown Officers 1-20, Byron C Lockwood, Kevin Brinkworth, Robbin Thomas, Unknown Supervisory Personnel 1-10, Byron B Brown, Daniel Derenda re Current Status of Discovery. (Wilner, Claudia) (Entered: 01/29/2019)

First MOTION for Extension of Time to Complete Discovery, Move to Amend Pleadings, and Make Dispositive Motions by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, De'Jon Hall, Taniqua Simmons.(Charney, Darius) (Entered: 05/06/2019)

NOTICE of Hearing: Telephone Status Conference set for 5/30/2019 03:30 PM before Hon. Christina Clair Reiss in the Cattaraugus Courtroom. Call-in information will be provide to the attorneys via email. (LB)

Notice of Hearing

Letter filed by Black Love Resists in the Rust as to Aaron Young, City of Buffalo, N.Y., Philip Serafini, Unknown Officers 1-20, Byron C Lockwood, Kevin Brinkworth, Robbin Thomas, Unknown Supervisory Personnel 1-10, Byron B Brown, Daniel Derenda to supplement May 9, 2019 letter motion (ECF 22) with regard to outstanding discovery issues. (Attachments: # 1 Exhibit A - First Set of RFPs, # 2 Exhibit B - Supplemental Responses to First Set of RFPs, # 3 Exhibit C - 311 Records - Police Issue (excerpt), # 4 Exhibit D - SF Daily Reports Redacted (excerpt))(Wilner, Claudia) (Entered: 05/28/2019)

1 Exhibit A - First Set of RFPs

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2 Exhibit B - Supplemental Responses to First Set of RFPs

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3 Exhibit C - 311 Records - Police Issue (excerpt)

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4 Exhibit D - SF Daily Reports Redacted (excerpt)

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LETTER regarding 22 First MOTION for Extension of Time to Complete Discovery, Move to Amend Pleadings, and Make Dispositive Motions by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, De'Jon Hall, Taniqua Simmons. (Attachments: # 1 Exhibit A - First Set of RFPs, # 2 Exhibit B - Supplemental Responses to First Set of RFPs, # 3 Exhibit C - 311 Records - Police Issue (excerpt), # 4 Exhibit D - SF Daily Reports Redacted (excerpt))(Wilner, Claudia) Modified on 5/30/2019 to correct event and description (KLH). (Entered: 05/29/2019)

1 Exhibit A - First Set of RFPs

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2 Exhibit B - Supplemental Responses to First Set of RFPs

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3 Exhibit C - 311 Records - Police Issue (excerpt)

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4 Exhibit D - SF Daily Reports Redacted (excerpt)

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Minute Entry for proceedings held before Hon. Christina Clair Reiss. Telephone Status Conference held on 5/30/2019. Parties identify several discovery disputes. The Court provides instructions for narrowing the scope for production of documents, redaction of documents and privilege logs. Plaintiffs request an extension of the discovery schedule. The Court will sign off on an agreed to revised discovery schedule, otherwise a motion will be required. The Court will schedule a further status conference in 90 days absent a request for an earlier date. Appearances: Claudia Wilner, Esq., Darius Charney, Esq., Anjana Malhotra, Esq., on behalf of plaintiffs; Robert Quinn, Esq., on behalf of defendants. (Court Reporter FTR Gold.) (JDK) (Entered: 05/31/2019)

NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Proceedings held on 10/9/2018, before Judge Christina Clair Reiss. Court Reporter/Transcriber Christi A. Macri, Contact Info christimacri50@gmail.com. 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 6/21/2019. Redacted Transcript Deadline set for 7/1/2019. Release of Transcript Restriction set for 8/29/2019. (CM) (Entered: 05/31/2019)

NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Proceedings held on 12/21/2018, before Judge Christina Clair Reiss. Court Reporter/Transcriber Christi A. Macri, Contact Info christimacri50@gmail.com. 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 6/21/2019. Redacted Transcript Deadline set for 7/1/2019. Release of Transcript Restriction set for 8/29/2019. (CM) (Entered: 05/31/2019)

Consent MOTION to Modify Scheduling Order by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, De'Jon Hall, Taniqua Simmons.(Wilner, Claudia) (Entered: 06/03/2019)

Set/Reset Deadlines

TEXT ORDER granting 28 Consent Motion to modify the scheduling order. Issued by Hon. Christina Clair Reiss on 6/5/2019. (KLH) (Entered: 06/05/2019)

Set/Reset Deadlines: Motions to Join Parties/Amend Pleadings due by 11/14/2019. Discovery completed by 12/13/2019. Expert Reports due by 1/31/2020. Motions due by 4/30/2020. (KLH)

NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Proceedings held on 5/30/2019, before Judge Christina Clair Reiss. Court Reporter/Transcriber Christi A. Macri, Contact Info christimacri50@gmail.com. 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 7/3/2019. Redacted Transcript Deadline set for 7/15/2019. Release of Transcript Restriction set for 9/10/2019. (CM) (Entered: 06/12/2019)

MOTION to Withdraw as Attorney Anjana Malhotra by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, De'Jon Hall, Taniqua Simmons.(Malhotra, Anjana) (Entered: 06/26/2019)

TEXT ORDER granting 31 Motion to Withdraw as Attorney. Attorney Anjana Malhotra terminated. Signed by Hon. Christina Clair Reiss on 7/1/2019. (KLH) (Entered: 07/02/2019)

MOTION to Compel Non-Party Erie County Central Police Services to Comply with Subpoena by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, De'Jon Hall, Taniqua Simmons. (Attachments: # 1 Memorandum in Support of Motion to Compel, # 2 Declaration in support of Motion to Compel, # 3 Exhibit A - Subpoena with Proof of Service, # 4 Exhibit B - Responses to Document Requests, # 5 Exhibit C - Jan. 18 letter, # 6 Exhibit D - Service of Subpoena on Defendants, # 7 Exhibit E - Emails to ECCPS)(Wilner, Claudia) (Entered: 07/18/2019)

1 Memorandum in Support of Motion to Compel

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2 Declaration in support of Motion to Compel

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3 Exhibit A - Subpoena with Proof of Service

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4 Exhibit B - Responses to Document Requests

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5 Exhibit C - Jan. 18 letter

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6 Exhibit D - Service of Subpoena on Defendants

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7 Exhibit E - Emails to ECCPS

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MOTION to Compel Defendants to Comply with May 30, 2019 Discovery Order and Other Discovery Obligations by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, De'Jon Hall, Taniqua Simmons. (Attachments: # 1 Memorandum in Support of Motion to Compel, # 2 Declaration in support of Motion to Compel, # 3 Exhibit A - Supp Response to First RFPs, # 4 Exhibit B - Response to Second RFPs, # 5 Exhibit C - Interrogatories (excerpt), # 6 Exhibit D - Supp Response to Interrogatories (excerpt), # 7 Exhibit E - 11.15 email, # 8 Exhibit F - 1.3 email, # 9 Exhibit G - 1.18 letter, # 10 Exhibit H - 1.21 email, # 11 Exhibit I - 1.28 email, # 12 Exhibit J - 2.4-12 email chain, # 13 Exhibit K - 2.27 email, # 14 Exhibit L - 3.6 email, # 15 Exhibit M - 3.18 letter, # 16 Exhibit N - 3.25 email & attachments, # 17 Exhibit O - 5.6 email, # 18 Exhibit P - 6.5 email, # 19 Exhibit Q - 6.6-11 email chain, # 20 Exhibit R - 6.20 letter, # 21 Exhibit S - 6.21 email, # 22 Exhibit T - 6.27-7.9 email chain, # 23 Exhibit U - 7.3-8 email chain, # 24 Exhibit V - Housing Unit Monthly Report)(Wilner, Claudia) (Entered: 07/24/2019)

1 Memorandum in Support of Motion to Compel

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2 Declaration in support of Motion to Compel

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3 Exhibit A - Supp Response to First RFPs

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4 Exhibit B - Response to Second RFPs

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5 Exhibit C - Interrogatories (excerpt)

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6 Exhibit D - Supp Response to Interrogatories (excerpt)

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7 Exhibit E - 11.15 email

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8 Exhibit F - 1.3 email

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9 Exhibit G - 1.18 letter

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10 Exhibit H - 1.21 email

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11 Exhibit I - 1.28 email

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12 Exhibit J - 2.4-12 email chain

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13 Exhibit K - 2.27 email

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14 Exhibit L - 3.6 email

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15 Exhibit M - 3.18 letter

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16 Exhibit N - 3.25 email & attachments

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17 Exhibit O - 5.6 email

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18 Exhibit P - 6.5 email

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19 Exhibit Q - 6.6-11 email chain

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20 Exhibit R - 6.20 letter

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21 Exhibit S - 6.21 email

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22 Exhibit T - 6.27-7.9 email chain

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23 Exhibit U - 7.3-8 email chain

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24 Exhibit V - Housing Unit Monthly Report

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TEXT ORDER denying as moot 22 Motion for Extension of Time to Complete Discovery, based on the court's granting of the consent motion to extend time to complete discovery. Issued by Hon. Christina Clair Reiss on 8/6/2019. (KLH) (Entered: 08/06/2019)

Mediation Certification by Michael Menard(AGW) (Entered: 08/08/2019)

Letter filed by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, De'Jon Hall, Taniqua Simmons as to Aaron Young, City of Buffalo, N.Y., Philip Serafini, Unknown Officers 1-20, Byron C Lockwood, Kevin Brinkworth, Robbin Thomas, Unknown Supervisory Personnel 1-10, Byron B Brown, Daniel Derenda withdrawing Motion to Compel Non-Party Erie County Central Police Services to Comply with Plaintiffs' May 17, 2019 Subpoena. (Wilner, Claudia) (Entered: 08/13/2019)

MOTION for Entry of Order Granting Motion to Compel re 34 MOTION to Compel Defendants to Comply with May 30, 2019 Discovery Order and Other Discovery Obligations by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, De'Jon Hall, Taniqua Simmons. (Attachments: # 1 Text of Proposed Order)(Wilner, Claudia) (Entered: 08/19/2019)

1 Text of Proposed Order

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Letter filed by Aaron Young, City of Buffalo, N.Y., Philip Serafini, Unknown Officers 1-20, Byron C Lockwood, Kevin Brinkworth, Robbin Thomas, Unknown Supervisory Personnel 1-10, Byron B Brown, Daniel Derenda as to Aaron Young, City of Buffalo, N.Y., Philip Serafini, Unknown Officers 1-20, Byron C Lockwood, Kevin Brinkworth, Robbin Thomas, Unknown Supervisory Personnel 1-10, Byron B Brown, Daniel Derenda . (Quinn, Robert) (Entered: 08/19/2019)

DECLARATION re 34 MOTION to Compel Defendants to Comply with May 30, 2019 Discovery Order and Other Discovery Obligations filed by Aaron Young, City of Buffalo, N.Y., Philip Serafini, Unknown Officers 1-20, Michael Menard, Byron C Lockwood, Kevin Brinkworth, Robbin Thomas, Unknown Supervisory Personnel 1-10, Byron B Brown, Daniel Derenda filed by Aaron Young, City of Buffalo, N.Y., Philip Serafini, Unknown Officers 1-20, Michael Menard, Byron C Lockwood, Kevin Brinkworth, Robbin Thomas, Unknown Supervisory Personnel 1-10, Byron B Brown, Daniel Derenda. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K)(Quinn, Robert) (Entered: 08/20/2019)

1 Exhibit A

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2 Exhibit B

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3 Exhibit C

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4 Exhibit D

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5 Exhibit E

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6 Exhibit F

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7 Exhibit G

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8 Exhibit H

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9 Exhibit I

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10 Exhibit J

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11 Exhibit K

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REPLY to Response to Motion re 38 MOTION for Entry of Order Granting Motion to Compel re 34 MOTION to Compel Defendants to Comply with May 30, 2019 Discovery Order and Other Discovery Obligations filed by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, De'Jon Hall, Taniqua Simmons. (Wilner, Claudia) (Entered: 08/26/2019)

MOTION to Compel Production of BPD Internal Affairs Division Files by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, De'Jon Hall, Taniqua Simmons. (Attachments: # 1 Memorandum in Support Plaintiffs Memorandum of Law In Support of Motion to Compel Production of BPD Internal Affairs Division Files, # 2 Declaration Declaration of Darius Charney In Support of Motion to Compel Production of BPD Internal Affairs Division Files Files, # 3 Exhibit Charney Decl Exhibit A- Defendants' 1st Supplemental Responses to Plaintiffs' First Set of Document Requests, # 4 Exhibit Charney Decl Exhibit B- Charney Oct 15, 2018 email to Quinn and Proposed Confidentiality Order, # 5 Exhibit Charney Decl Exhibit C- Wilner Jan 18, 2019 Letter to Quinn, # 6 Exhibit Charney Decl Exhibit D- Wilner March 18, 2019 Letter to Quinn, # 7 Exhibit Charney Decl Exhibit E- Parties' July 12-15, 2019 email exchange, # 8 Exhibit Charney Decl Exhibit F- Parties' July 18, 2019 email exchange, # 9 Exhibit Charney Decl Exhibit G- Charney July 24, 2019 email to Quinn and Highlighted Spreadsheets, # 10 Exhibit Charney Decl Exhibit H- Parties' July 29-30 email exchange)(Charney, Darius) (Entered: 08/30/2019)

1 Memorandum in Support Plaintiffs Memorandum of Law In Support of Motion to Compe

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2 Declaration Declaration of Darius Charney In Support of Motion to Compel Product

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3 Exhibit Charney Decl Exhibit A- Defendants' 1st Supplemental Responses to P

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4 Exhibit Charney Decl Exhibit B- Charney Oct 15, 2018 email to Quinn and Proposed

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5 Exhibit Charney Decl Exhibit C- Wilner Jan 18, 2019 Letter to Quinn

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6 Exhibit Charney Decl Exhibit D- Wilner March 18, 2019 Letter to Quinn

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7 Exhibit Charney Decl Exhibit E- Parties' July 12-15, 2019 email exchange

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8 Exhibit Charney Decl Exhibit F- Parties' July 18, 2019 email exchange

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9 Exhibit Charney Decl Exhibit G- Charney July 24, 2019 email to Quinn and Highlig

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10 Exhibit Charney Decl Exhibit H- Parties' July 29-30 email exchange

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First MOTION for Extension of Time to File Response/Reply as to 38 MOTION for Entry of Order Granting Motion to Compel re 34 MOTION to Compel Defendants to Comply with May 30, 2019 Discovery Order and Other Discovery Obligations, 34 MOTION to Compel Defendants to Comply with May 30, 2019 Discovery Order and Other Discovery Obligations, 40 Declaration,,, with supporting Declaration and Certificate of Service by Kevin Brinkworth, Byron B Brown, City of Buffalo, N.Y., Daniel Derenda, Byron C Lockwood, Philip Serafini, Robbin Thomas, Unknown Officers 1-20, Unknown Supervisory Personnel 1-10, Aaron Young.(Quinn, Robert) (Entered: 09/03/2019)

TEXT ORDER: The court finds good cause for Defendants untimely opposition and will consider it in conjunction with the merits of the parties dispute. Plaintiffs motion for entry of an order granting their motion to compel 38 solely on the grounds of Defendants untimely opposition is thus DENIED. The court does not set briefing schedules sua sponte, but rather expects the parties to follow the deadlines set forth in the Federal Rules of Civil Procedure unless otherwise ordered. Signed by Hon. Christina Clair Reiss on 9/5/2019. (KLH) (Entered: 09/05/2019)

DECLARATION re 42 MOTION to Compel Production of BPD Internal Affairs Division Files filed by Aaron Young, City of Buffalo, N.Y., Philip Serafini, Unknown Officers 1-20, Byron C Lockwood, Kevin Brinkworth, Robbin Thomas, Unknown Supervisory Personnel 1-10, Byron B Brown, Daniel Derenda filed by Aaron Young, City of Buffalo, N.Y., Philip Serafini, Unknown Officers 1-20, Byron C Lockwood, Kevin Brinkworth, Robbin Thomas, Unknown Supervisory Personnel 1-10, Byron B Brown, Daniel Derenda. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Memorandum in Support, # 7 Certificate of Service)(Quinn, Robert) (Entered: 09/13/2019)

1 Exhibit A

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2 Exhibit B

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3 Exhibit C

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4 Exhibit D

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5 Exhibit E

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6 Memorandum in Support

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7 Certificate of Service

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REPLY to Response to Motion re 42 MOTION to Compel Production of BPD Internal Affairs Division Files filed by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, De'Jon Hall, Taniqua Simmons. (Charney, Darius) (Entered: 09/20/2019)

Mediation Certification by Michael Menard. Not settled, mediation to continue on 10/18/2019.(AGW) (Entered: 09/30/2019)

MOTION to Modify Scheduling Order re 29 Order on Motion for Miscellaneous Relief by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, De'Jon Hall, Taniqua Simmons.(England, Travis) (Entered: 11/05/2019)

Set/Reset Scheduling Order Deadlines

TEXT ORDER granting 48 Motion to modify the scheduling order. Signed by Hon. Christina Clair Reiss on 11/13/2019. (KLH) (Entered: 11/13/2019)

Set/Reset Scheduling Order Deadlines: Motions to Join Parties/Amend Pleadings due by 5/14/2020. Discovery completed by 6/12/2020. Motions to Compel Discovery due by 6/12/2020. Motions due by 10/30/2020. (KLH)

Mediation Certification by Michael Menard. Mediation adjourned to 1/21/20.(AGW) (Entered: 11/14/2019)

OPINION AND ORDER granting in part and denying in part 34 and 42 Plaintiffs' Motions to Compel. Signed by Hon. Christina Clair Reiss on 12/19/2019. (KLH)

TEXT ORDER denying as moot 43 Motion for Extension of Time to File Response/Reply as to 38 Motion for Entry of Order Granting Motion to Compel. Issued by Hon. Christina Clair Reiss on 1/2/2020. (KLH) (Entered: 01/02/2020)

Letter filed by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, De'Jon Hall, Taniqua Simmons as to Aaron Young, City of Buffalo, N.Y., Philip Serafini, Unknown Officers 1-20, Byron C Lockwood, Kevin Brinkworth, Robbin Thomas, Unknown Supervisory Personnel 1-10, Byron B Brown, Daniel Derenda re Production of BPD IAD Files. (Attachments: # 1 Text of Proposed Order Proposed Attorneys' Eyes Only Protective Order)(Charney, Darius) (Entered: 01/21/2020)

1 Text of Proposed Order Proposed Attorneys' Eyes Only Protective Order

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PROTECTIVE ORDER. Signed by Hon. Christina Clair Reiss on 1/23/20. (SG) (Entered: 01/24/2020)

MOTION to Withdraw as Attorney Travis England, Esq. by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, De'Jon Hall, Taniqua Simmons.(England, Travis) (Entered: 03/18/2020)

ORDER granting 55 Motion to Withdraw as Attorney. Attorney Travis W. England terminated. Signed by Hon. Christina Clair Reiss on 3/24/20. (SG) (Entered: 03/24/2020)

MOTION for Leave to File Amended and Supplemental Class Action Complaint by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, De'Jon Hall, Taniqua Simmons. (Attachments: # 1 Memorandum of Law in Support of Plaintiffs' Motion to Amend and Supplement Complaint, # 2 Declaration of Claudia Wilner in Support of Plaintiffs' Motion to Amend and Supplement Complaint, # 3 Exhibit 1 - Plaintiffs' Proposed Amended and Supplemental Class Action Complaint, # 4 Exhibit 2 - Redline of Plaintiffs' Proposed Amended and Supplemental Class Action Complaint Reflecting Changes, # 5 Exhibit 3 - Plaintiffs' First Set of Requests for the Production of Documents on Defendants dated November 5, 2018, # 6 Exhibit 4 - Defendants' Responses and Objections to Plaintiffs First Set of Requests for Production dated December 8, 2018, # 7 Exhibit 5 - Defendants' Supplemental Responses and Objections to Plaintiffs First Set of Requests for Production dated March 15, 2019, # 8 Exhibit 6 - Plaintiffs' Third-Party Subpoena on the Erie County Central Police Services (ECCPS) dated March 15, 2019, # 9 Exhibit 7 - Plaintiffs' Second Set of Requests for the Production of Documents on Defendants dated April 19, 2019)(Ezie, Andrea) (Entered: 04/23/2020)

1 Memorandum of Law in Support of Plaintiffs' Motion to Amend and Supplement

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2 Declaration of Claudia Wilner in Support of Plaintiffs' Motion to Amend and

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3 Exhibit 1 - Plaintiffs' Proposed Amended and Supplemental Class Action Comp

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4 Exhibit 2 - Redline of Plaintiffs' Proposed Amended and Supplemental Class

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5 Exhibit 3 - Plaintiffs' First Set of Requests for the Production of Documen

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6 Exhibit 4 - Defendants' Responses and Objections to Plaintiffs First Set o

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7 Exhibit 5 - Defendants' Supplemental Responses and Objections to Plaintiffs

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8 Exhibit 6 - Plaintiffs' Third-Party Subpoena on the Erie County Central Pol

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9 Exhibit 7 - Plaintiffs' Second Set of Requests for the Production of Docume

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Mediator Recusal by Michael Menard(Menard, Michael) (Entered: 04/24/2020)

CONTINUATION OF EXHIBITS to 57 MOTION for Leave to File Amended and Supplemental Class Action Complaint -Corrected Proposed Amended Complaint & Redline (replacing Dkt Items 57.3 and 57.4). (Attachments: # 1 Corrected Redline of Proposed Amended Complaint)(Ezie, Andrea) (Entered: 04/30/2020)

1 Corrected Redline of Proposed Amended Complaint

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Set/Reset Deadlines

Consent MOTION to Modify Scheduling Order by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, De'Jon Hall, Taniqua Simmons.(Wilner, Claudia) (Entered: 05/15/2020)

TEXT ORDER granting 60 Motion to modify Scheduling Order. Signed by Hon. Christina Clair Reiss on 5/15/20. (SG) (Entered: 05/15/2020)

Set/Reset Deadlines:( Discovery completed by 12/12/2020.), Set/Reset Hearings:, Set/Reset Scheduling Order Deadlines:( Discovery completed by 12/12/2020., Motions due by 4/30/2021.) (SG)

TEXT ORDER granting, as unopposed, 57 Motion for Leave to File an Amended Complaint. Signed by Hon. Christina Clair Reiss on 5/21/20. (SG) (Entered: 05/21/2020)

AMENDED COMPLAINT against All Defendants, filed by Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, Taniqua Simmons, De'Jon Hall, Shirley Sarmiento, Ebony Yeldon, Charles Palmer, Shaketa Redden, Joseph Bonds.(Ezie, Andrea) (Entered: 05/21/2020)

ANSWER to 63 Amended Complaint by Kevin Brinkworth, Byron B Brown, City of Buffalo, N.Y., Daniel Derenda, Byron C Lockwood, Philip Serafini, Robbin Thomas, Unknown Officers 1-20, Unknown Supervisory Personnel 1-10, Aaron Young. (Attachments: # 1 Certificate of Service)(Quinn, Robert) (Entered: 06/04/2020)

1 Certificate of Service

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MOTION to Compel Defendants to Comply with the Court's December 19, 2019 Order and Other Discovery Obligations by Black Love Resists in the Rust, Joseph Bonds, Jane Doe, Dorethea Franklin, De'Jon Hall, Charles Palmer, Shaketa Redden, Shirley Sarmiento, Taniqua Simmons, Ebony Yeldon. (Attachments: # 1 Memorandum in Support)(Wilner, Claudia) (Entered: 10/22/2020)

1 Memorandum in Support

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DECLARATION re 65 MOTION to Compel Defendants to Comply with the Court's December 19, 2019 Order and Other Discovery Obligations filed by Shirley Sarmiento, Shaketa Redden, Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, Charles Palmer, Taniqua Simmons, Ebony Yeldon, Joseph Bonds, De'Jon Hall filed by Shirley Sarmiento, Shaketa Redden, Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, Charles Palmer, Taniqua Simmons, Ebony Yeldon, Joseph Bonds, De'Jon Hall. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19, # 20 Exhibit 20, # 21 Exhibit 21, # 22 Exhibit 22, # 23 Exhibit 23, # 24 Exhibit 24)(Wilner, Claudia) (Entered: 10/22/2020)

1 Exhibit 1

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2 Exhibit 2

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3 Exhibit 3

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4 Exhibit 4

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5 Exhibit 5

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6 Exhibit 6

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7 Exhibit 7

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8 Exhibit 8

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9 Exhibit 9

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10 Exhibit 10

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11 Exhibit 11

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12 Exhibit 12

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13 Exhibit 13

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14 Exhibit 14

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15 Exhibit 15

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16 Exhibit 16

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17 Exhibit 17

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18 Exhibit 18

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19 Exhibit 19

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20 Exhibit 20

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21 Exhibit 21

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22 Exhibit 22

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23 Exhibit 23

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24 Exhibit 24

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AFFIDAVIT in Opposition re 65 MOTION to Compel Defendants to Comply with the Court's December 19, 2019 Order and Other Discovery Obligations filed by Kevin Brinkworth, Byron B Brown, City of Buffalo, N.Y., Daniel Derenda, Byron C Lockwood, Philip Serafini, Robbin Thomas, Unknown Officers 1-20, Unknown Supervisory Personnel 1-10, Aaron Young. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I)(Quinn, Robert) (Entered: 11/06/2020)

REPLY to Response to Motion re 65 MOTION to Compel Defendants to Comply with the Court's December 19, 2019 Order and Other Discovery Obligations filed by Black Love Resists in the Rust, Joseph Bonds, Jane Doe, Dorethea Franklin, De'Jon Hall, Charles Palmer, Shaketa Redden, Shirley Sarmiento, Taniqua Simmons, Ebony Yeldon. (Wilner, Claudia) (Entered: 11/13/2020)

DECLARATION re 68 Reply to Response to Motion, filed by Shirley Sarmiento, Shaketa Redden, Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, Charles Palmer, Taniqua Simmons, Ebony Yeldon, Joseph Bonds, De'Jon Hall filed by Shirley Sarmiento, Shaketa Redden, Black Love Resists in the Rust, Jane Doe, Dorethea Franklin, Charles Palmer, Taniqua Simmons, Ebony Yeldon, Joseph Bonds, De'Jon Hall. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(Wilner, Claudia) (Entered: 11/13/2020)

Consent MOTION Modify Scheduling Order by Black Love Resists in the Rust, Joseph Bonds, Jane Doe, Dorethea Franklin, De'Jon Hall, Charles Palmer, Shaketa Redden, Shirley Sarmiento, Taniqua Simmons, Ebony Yeldon.(Wilner, Claudia) (Entered: 11/17/2020)

TEXT ORDER granting 70 Motion to Modify Scheduling Order. Signed by Hon. Christina Reiss on 12/1/2020. (CGJ) (Entered: 12/01/2020)

NOTICE of Hearing: Status Conference set for 12/14/2020 10:00 AM before Hon. Christina Reiss. This proceeding will be conducted through Zoom for Government. (LMD)

Notice of Hearing

MOTION to appear pro hac vice filed on behalf of Jordan Joachim ( Filing fee $ 200 receipt number 0209-4070967.) by Black Love Resists in the Rust, Joseph Bonds, Jane Doe, Dorethea Franklin, De'Jon Hall, Charles Palmer, Shaketa Redden, Shirley Sarmiento, Taniqua Simmons, Ebony Yeldon. (Attachments: # 1 J. Joachim Admission Petition Form, # 2 Affidavit of Chinyere Ezie, # 3 J. Joachim Attorney Oath, # 4 J. Joachim Civility Principles & Guidelines Oath, # 5 J. Joachim ECF Registration Form)(Ezie, Andrea) (Entered: 12/07/2020)

1 J. Joachim Admission Petition Form

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2 Affidavit of Chinyere Ezie

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3 J. Joachim Attorney Oath

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4 J. Joachim Civility Principles & Guidelines Oath

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5 J. Joachim ECF Registration Form

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Verified admission to the New York State Bar for Attorney Jordan Scott Joachim. (MD)

Remark

TEXT ORDER granting 72 MOTION to appear pro hac vice. Signed by Hon. Christina Reiss on 12/8/2020. (JLV) (Entered: 12/08/2020)

Letter filed by Black Love Resists in the Rust, Joseph Bonds, Jane Doe, Dorethea Franklin, De'Jon Hall, Charles Palmer, Shaketa Redden, Shirley Sarmiento, Taniqua Simmons, Ebony Yeldon as to Aaron Young, City of Buffalo, N.Y., Philip Serafini, Unknown Officers 1-20, Byron C Lockwood, Kevin Brinkworth, Robbin Thomas, Unknown Supervisory Personnel 1-10, Byron B Brown, Daniel Derenda regarding depositions. (Attachments: # 1 Exhibit Correspondence with R. Quinn)(Wilner, Claudia) (Entered: 12/10/2020)

Minute Entry for proceedings held before Hon. Christina Reiss: Status Conference held on 12/14/2020. The Court informs the parties it intends to take up 65 MOTION to Compel Defendants to Comply with the Court's December 19, 2019 Order and Other Discovery Obligations filed by Taniqua Simmons, Dorethea Franklin, Charles Palmer, Ebony Yeldon, Joseph Bonds, Shaketa Redden, Jane Doe, Shirley Sarmiento, De'Jon Hall, Black Love Resists in the Rust. The Court resolves in part Plaintiff's 65 Motion to Compel as stated on the record. The parties are directed to notify the Court within 60 days the discovery issues that cannot be resolved. An additional status conference will be scheduled. The Court defers ruling on attorney's fees and expenses. Appearances: Claudia Wilner, Esq., Darius Charney, Esq., Jordan Joachim, Esq., on behalf of plaintiffs; Robert Quinn, Esq., on behalf of defendants. All Appearances by Zoom for Government (JDK) (Entered: 12/14/2020)

NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Status Conference Proceedings held on 12/14/2020, before Judge Christina Clare Reiss. Court Reporter/Transcriber Megan E. Pelka, RPR, Contact Info (716)364-6449. 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 1/11/2021. Redacted Transcript Deadline set for 1/21/2021. Release of Transcript Restriction set for 3/22/2021. (JLV) (Entered: 12/21/2020)

MOTION to set ESI benchmarks and compel scheduling of depositions by Black Love Resists in the Rust, Joseph Bonds, Jane Doe, Dorethea Franklin, De'Jon Hall, Charles Palmer, Shaketa Redden, Shirley Sarmiento, Taniqua Simmons, Ebony Yeldon.(Wilner, Claudia) (Entered: 01/22/2021)