Case: Russell v. Harris County, TX

4:19-cv-00226 | U.S. District Court for the Southern District of Texas

Filed Date: Jan. 21, 2019

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Case Summary

On January 21, 2019, indigent pretrial detainees in Harris County Jail filed this lawsuit in the Southern District of Texas. The plaintiff sued Harris County under 42 U.S.C. § 1983 and 28 U.S.C. § 2201 et seq. The plaintiffs, represented by private counsel and the Civil Rights Corps sought declaratory and injunctive relief. The plaintiffs claimed that their 14th Amendment rights to Equal Protection and their substantive due process rights were being violated. Specifically, they alleged that the defendants were operating a system of wealth-based detention that kept them in jail simply because they could not afford to pay the bail amounts, without appropriate findings about the necessity of pretrial detention or the plaintiff's ability to pay. The case was assigned to District Judge Lee H. Rosenthal.

The March 27, 2020 motion for a temporary restraining order discussed the plaintiff's concerns over COVID-19, namely the inability of the jail's limited services to care for the 8,000 individuals in the tight quarters of the jail if members of the population started getting sick. The plaintiffs argued that subjecting them to a heightened risk of contracting the virus, separating them from their families, interrupting medications and medical care, and taking them from their homes was not necessary to serve the government's interest in preventing flight or assuring public safety. They also argued that the pandemic had made it more difficult for them to receive constitutional protections, specifically because their court appearances were cancelled and visits with lawyers have been postponed. Ultimately, the plaintiffs sought an emergency order requiring the defendants to not to enforce existing pretrial detention orders, and asked for their request to be heard as quickly as possible to prevent further irreparable harm to the plaintiffs.

On March 29, 2020, the State of Texas, the Governor of Texas, and the Attorney General filed a motion to intervene to defend the bail procedures. They argued that the defendants in this case "do not contest" any of the plaintiffs' arguments." They noted that on March 27, the Court ordered the Attorney General--a non-party--"to respond to the plaintiffs motion" requesting a temporary restraining order. They noted that the Attorney General intended to respond, but asked that the Court grant the motion to intervene to allow full participation as a party.

The plaintiffs replied the next day. They did not oppose the intervention of the Texas Attorney General, but noted that "many of the factual claims and legal principles cited in the memorandum are not correct." Chief Judge Lee H. Rosenthal granted the State of Texas, Governor of Texas, and the Attorney General's motion to intervene.

The defendants and the Texas Attorney General responded to the plaintiffs' motion for temporary restraining order on April 1, 2020. That same day, the plaintiffs filed another motion for a temporary restraining order, this time against Governor Abbott's Executive Order GA 13. The executive order, issued in light of COVID-19, allowed pretrial detainees to be released if they paid bail regardless of any individualized proceedings or findings by a state court judge, but halted individualized determinations. The plaintiffs requested a temporary restraining order prohibiting enforcement of Executive Order GA 13 to the extent that it bars such individualized bail determinations.

On April 6, 2020, the state intervenors filed their response to the temporary restraining order regarding Executive Order GA 13. They argued that plaintiffs did not have standing because they had not received an injury from the executive order, and that sovereign immunity barred the court from awarding relief against them as the State Intervenors.

On April 11, 2020, the plaintiffs notified the court that a Texas district court had issued a temporary restraining order that found Executive Order GA 13 to be unconstitutional under Texas law and enjoined Executive Order GA 13 from being enforced against judges.

Judge Rosenthal denied the plaintiffs' motion for a temporary restraining order on April 14, 2020. The opinion stated that the plaintiffs were likely to show a likelihood of success on the merits of their claim, but that they had not met their burden of showing that their release would be in the public interest. Furthermore, the county had implemented plans to identify those who were deemed safe for release, which had resulted in 372 releases as of April 13. The opinion allowed the plaintiffs to restate their claims if the county's efforts failed, or to move for class certification and motion for a preliminary injunction as to their underlying case, which could prove their entitlement to relief on a fuller record. 454 F. Supp. 3d 624.

On May 6, 2020, the plaintiffs filed their first amended complaint, which added two named plaintiffs as well as additional details regarding Governor Abbott's Executive Order GA-13. They also filed a motion to lift the stay on the case. Judge Rosenthal granted the motion to lift the stay on May 16, 2020, as it was no longer opposed by the defendants.

The plaintiffs filed a second amended complaint on June 26, 2020, adding additional facts to the complaint regarding several judges, known as the felony judges, who had moved to intervene in the case.

On July 10, 2020 the state intervenor-defendants filed a motion to dismiss, arguing that the plaintiffs had received the constitutionally-required bail process and thus could not adequately plead their procedural due process or equal protection claims. The County defendants also filed a motion to dismiss on July 30, 2020. The court denied the motion to dismiss on November 10, 2020, reasoning that there were disputed factual allegations in the case that could not be resolved by a judge at this moment in time.

Defendants began the process of appealing the court’s decision to deny the motion to dismiss the felony judges. In January 2021, the plaintiffs agreed to voluntarily dismiss with prejudice the felony judges as defendants pursuant to Rule 41(a)(2).

In May 2021, the plaintiffs filed a motion to certify class. The motion was denied in November as moot.

The case went into discovery. The plaintiffs filed several emergency motions to compel injunctive relief due to “intentional and wanton infliction of pain and suffering” in violation of the 8th and 14th Amendments and the Americans with Disabilities Act of 1990 and Amendments Act of 2009. All were denied by the court.

The plaintiffs also served three sets of subpoenas to the felony judges and others. The felony judges moved to quash, arguing that the subpoenas were barred because of 1). sovereign immunity 2). judicial immunity and the mental process privilege and 3). Rule 45 violation. On May 14, 2021, the district court granted in part and denied in part the motions to quash. The district court upheld parts of the defendants’ Rule 45 claim but largely denied their claim related to sovereign immunity and the mental process privilege.

On May 17, 2021, the defendants filed an appeal to the US Court of Appeals for the Fifth Circuit over the district court’s decision to uphold the subpoenas.On September 19, 2022, the circuit court affirmed in part and denied in part the defendants’ appeal. The circuit court affirmed the district court’s decision about the Rule 45 violation and the mental process privilege. Then, the circuit court reversed the district court’s decision regarding sovereign immunity.

Back at the district court level, the parties finished discovery in January, 2023.

On December 6, 2022, the plaintiffs filed a motion for summary judgment. The defendants responded on January 13, 2023, suggesting that there was still a question of material fact, particularly with regard to their standing to sue the sheriff and mootness in the face of the recently-passed S.B. 6, a new bail reform law. On January 15, 2023, the defendants filed a motion for summary judgment of their own.

On April 20, 2023, the plaintiffs filed an amended motion to certify class.

On August 31, 2023, the court dismissed the case as moot. A recently-decided Circuit Court case (Daves v. Dallas County) had determined that S.B. 6 mooted challenges to the bail system. As such, the court said that “adherence to Fifth Circuit authority require[d] that this case be dismissed as moot.”

	Document
4:19-cv-00226	Docket [PACER] Russell v. Harris County, Texas	Sept. 25, 2020	Sept. 25, 2020 Docket
2 4:19-cv-00226	Motion to Certify Class	Jan. 21, 2019	Jan. 21, 2019 Pleading / Motion / Brief
1 4:19-cv-00226	Complaint Russell v. Harris County	Jan. 21, 2019	Jan. 21, 2019 Complaint
32-7 4:19-cv-00226	Part 1/3 of Exhibit G of Motion and Memorandum in Support of Motion for Temporary Restraining Order and Preliminary Injunction Russell v. Harris County	March 27, 2020	March 27, 2020 Pleading / Motion / Brief
32-7 4:19-cv-00226	Part 3/3 of Exhibit G of Motion and Memorandum in Support of Motion for Temporary Restraining Order and Preliminary Injunction Russell v. Harris County	March 27, 2020	March 27, 2020 Pleading / Motion / Brief
32-7 4:19-cv-00226	Part 2 of Exhibit G of Motion and Memorandum in Support of Motion for Temporary Restraining Order and Preliminary Injunction Russell v. Harris County	March 27, 2020	March 27, 2020 Pleading / Motion / Brief
32-1 through 32-6 4:19-cv-00226	Exhibits A through F of Motion and Memorandum in Support of Motion for Temporary Restraining Order and Preliminary Injunction Russell v. Harris County	March 27, 2020	March 27, 2020 Pleading / Motion / Brief
32-8 through 32-12 4:19-cv-00226	Exhibit H through Exhibit K of Motion and Memorandum in Support of Motion for Temporary Restraining Order and Preliminary Injunction Russell v. Harris County	March 27, 2020	March 27, 2020 Pleading / Motion / Brief
32 4:19-cv-00226	Motion and Memorandum in Support of Motion for Temporary Restraining Order and Preliminary Injunction Russell v. Harris County	March 27, 2020	March 27, 2020 Pleading / Motion / Brief
38 4:19-cv-00226	Opposed Motion to Intervene by the State of Texas, Greg Abbott, Governor of Texas, and Ken Paxton, Attorney General of Texas and Memorandum in Support Russell v. Harris County	March 29, 2020	March 29, 2020 Pleading / Motion / Brief

Title	Description		External URL Date / External URL
DOJ Dear Colleague Letter to Courts Regarding Fines and Fees for Youth and Adults U.S. Department of Justice	The DOJ issued a Dear Colleague letter for state and local courts and juvenile justice agencies regarding the imposition and enforcement of fines and fees for adults and youth. The letter highlights …	April 20, 2023	April 20, 2023 https://www.justice.gov/...
Harris County, TX: Bail Civil Rights Corps	Our challenge to the money bail system in Harris County is the seminal challenge to the assembly line wealth-based detention that pervades local American courts. The case challenges the…	March 27, 2020	March 27, 2020 http://www.civilrightscorps.org/...

ECF Number	Description	Date	Link Date / Link
1	COMPLAINT against All Defendants (Filing fee $ 400 receipt number 0541-21691765) filed by Dwight Russell, Joseph Ortuno, Pierson Johnnie. (Attachments: # 1 Exhibit Exhibit 1 - Dwight Russell Declaration, # 2 Exhibit Exhibit 2 - Johnnie Pierson Declaration, # 3 Exhibit Exhibit 3 - Joseph Ortuno Declaration, # 4 Exhibit Exhibit 4 - Felony Bail Schedule)(Manne, Neal) (Entered: 01/21/2019) 1 Exhibit Exhibit 1 - Dwight Russell Declaration View on PACER 2 Exhibit Exhibit 2 - Johnnie Pierson Declaration View on PACER 3 Exhibit Exhibit 3 - Joseph Ortuno Declaration View on PACER 4 Exhibit Exhibit 4 - Felony Bail Schedule View on PACER	Jan. 21, 2019	Jan. 21, 2019 Clearinghouse
2	MOTION to Certify Class by Pierson Johnnie, Joseph Ortuno, Dwight Russell, filed. Motion Docket Date 2/11/2019. (Attachments: # 1 Exhibit Exhibit 1 - Declaration of A Karakatsanis, # 2 Exhibit Exhibit 2 - Declaration of N Cornelio, # 3 Proposed Order)(Manne, Neal) (Entered: 01/21/2019) 1 Exhibit Exhibit 1 - Declaration of A Karakatsanis View on PACER 2 Exhibit Exhibit 2 - Declaration of N Cornelio View on PACER 3 Proposed Order View on PACER	Jan. 21, 2019	Jan. 21, 2019 Clearinghouse
3	ORDER Scheduling Rule 16 Conference With the Court and Setting Out the Requirements for Initial Pretrial Work. Initial Conference set for 4/12/2019 at 02:30 PM in Courtroom 11B before Chief Judge Lee H Rosenthal. (Signed by Chief Judge Lee H Rosenthal) (Attachments: # 1 Attachments) Parties notified.(JenniferOlsonadi, 4) (Entered: 01/22/2019) 1 Attachments View on PACER	Jan. 22, 2019	Jan. 22, 2019 PACER
4	NOTICE of Appearance by Natalia M. Cornelio on behalf of Pierson Johnnie, Joseph Ortuno, Dwight Russell, filed. (Cornelio, Natalia) (Main Document 4 replaced on 1/22/2019) (leddins, 4). (Entered: 01/22/2019)	Jan. 22, 2019	Jan. 22, 2019 RECAP
5	MOTION for Alex Karakatsanis to Appear Pro Hac Vice by Pierson Johnnie, Joseph Ortuno, Dwight Russell, filed. Motion Docket Date 2/13/2019. (Manne, Neal) (Entered: 01/23/2019)	Jan. 23, 2019	Jan. 23, 2019 PACER
6	MOTION for Elizabeth Rossi to Appear Pro Hac Vice by Pierson Johnnie, Joseph Ortuno, Dwight Russell, filed. Motion Docket Date 2/13/2019. (Manne, Neal) (Entered: 01/23/2019)	Jan. 23, 2019	Jan. 23, 2019 PACER
7	NOTICE of Appearance by Lexie G. White on behalf of Pierson Johnnie, Joseph Ortuno, Dwight Russell, filed. (White, Lexie) (Entered: 01/23/2019)	Jan. 23, 2019	Jan. 23, 2019 PACER
8	NOTICE of Appearance by Joseph S. Grinstein on behalf of Pierson Johnnie, Joseph Ortuno, Dwight Russell, filed. (Grinstein, Joseph) (Entered: 01/23/2019)	Jan. 23, 2019	Jan. 23, 2019 PACER
9	ORDER granting 5 Motion for Alec Karakatsanis to Appear Pro Hac Vice.(Signed by Chief Judge Lee H Rosenthal) Parties notified.(gkelner, 4) (Entered: 01/25/2019)	Jan. 25, 2019	Jan. 25, 2019 PACER
10	ORDER granting 6 Motion for Elizabeth Ann Rossi to Appear Pro Hac Vice.(Signed by Chief Judge Lee H Rosenthal) Parties notified.(rguerrero, 4) (Entered: 01/28/2019)	Jan. 25, 2019	Jan. 25, 2019 PACER
11	AMENDED 2 MOTION by Pierson Johnnie, Joseph Ortuno, Dwight Russell, filed. Motion Docket Date 2/19/2019. (Attachments: # 1 Exhibit Ex. 1 - Amended Declaration of A. Karakatsanis, # 2 Exhibit Ex. 2 - Declaration of N. Cornelio, # 3 Proposed Order Ex. 3 - Proposed Order)(Manne, Neal) (Entered: 01/28/2019) 1 Exhibit Ex. 1 - Amended Declaration of A. Karakatsanis View on PACER 2 Exhibit Ex. 2 - Declaration of N. Cornelio View on PACER 3 Proposed Order Ex. 3 - Proposed Order View on PACER	Jan. 28, 2019	Jan. 28, 2019 PACER
12	AMENDED 6 MOTION by Pierson Johnnie, Joseph Ortuno, Dwight Russell, filed. Motion Docket Date 2/19/2019. (Manne, Neal) (Entered: 01/28/2019)	Jan. 28, 2019	Jan. 28, 2019 PACER
13	Minute entry for proceedings before the Hon. Lee H. Rosenthal. Status conference held on February 1, 2019. The parties must submit a proposed order abating the case for 90 days by Monday, February 4, 2019. The court will schedule a status conference following the expiration of the abatement. Appearances: Neal S Manne.(Court Reporter: B. Slavin), filed.(leddins, 4) (Entered: 02/04/2019)	Feb. 1, 2019	Feb. 1, 2019 PACER
14	Unopposed MOTION to Stay by Pierson Johnnie, Joseph Ortuno, Dwight Russell, filed. Motion Docket Date 2/25/2019. (Attachments: # 1 Proposed Order Proposed Order)(Manne, Neal) (Entered: 02/04/2019) 1 Proposed Order Proposed Order View on PACER	Feb. 4, 2019	Feb. 4, 2019 PACER
15	ORDER entered GRANTING 14 Unopposed MOTION to Stay, STAYED flag set. The IPTC will be reset by separate notice. (Signed by Chief Judge Lee H Rosenthal) Parties notified.(leddins, 4) (Entered: 02/05/2019)	Feb. 5, 2019	Feb. 5, 2019 RECAP
16	NOTICE of Resetting. Parties notified. Initial Conference reset for 6/19/2019 at 10:30 AM in Courtroom 11B before Chief Judge Lee H Rosenthal, filed. (leddins, 4) (Entered: 02/05/2019)	Feb. 5, 2019	Feb. 5, 2019 PACER
17	NOTICE of Appearance by Melissa L. Spinks on behalf of Harris County, Texas, filed. (Spinks, Melissa) (Entered: 02/06/2019)	Feb. 6, 2019	Feb. 6, 2019 PACER
18	NOTICE of Appearance by Victoria Jimenez & Murray Fogler on behalf of Sheriff Ed Gonzalez, filed. (Jimenez, Victoria) (Entered: 02/06/2019)	Feb. 6, 2019	Feb. 6, 2019 PACER
19	NOTICE of Appearance by Elizabeth B. Hadaway on behalf of Pierson Johnnie, Joseph Ortuno, Dwight Russell, filed. (Hadaway, Elizabeth) (Entered: 02/08/2019)	Feb. 8, 2019	Feb. 8, 2019 PACER
20	NOTICE of Appearance by Meagan Harding on behalf of Pierson Johnnie, Joseph Ortuno, Dwight Russell, filed. (Harding, Meagan) (Entered: 05/02/2019)	May 2, 2019	May 2, 2019 RECAP
21	Unopposed MOTION for Natalia Cornelio to Withdraw as Attorney by Pierson Johnnie, Joseph Ortuno, Dwight Russell, filed. Motion Docket Date 5/28/2019. (Attachments: # 1 Proposed Order)(Cornelio, Natalia) (Entered: 05/06/2019) 1 Proposed Order View on RECAP	May 6, 2019	May 6, 2019 RECAP
22	MOTION for Mimi Marziani to Appear Pro Hac Vice by Pierson Johnnie, Joseph Ortuno, Dwight Russell, filed. Motion Docket Date 5/28/2019. (lcorbett, 7) (Entered: 05/08/2019)	May 6, 2019	May 6, 2019 RECAP
23	ORDER granting 22 Motion for Mimi Marziami to Appear Pro Hac Vice.(Signed by Chief Judge Lee H Rosenthal) Parties notified.(kpicota, 4) (Entered: 05/08/2019)	May 8, 2019	May 8, 2019 RECAP
24	Joint MOTION to Stay Proceedings for 60 Days by Pierson Johnnie, Joseph Ortuno, Dwight Russell, filed. Motion Docket Date 5/30/2019. (Attachments: # 1 Proposed Order)(Rossi, Elizabeth) (Entered: 05/09/2019) 1 Proposed Order View on PACER	May 9, 2019	May 9, 2019 RECAP
25	ORDER granting 21 Unopposed MOTION for Natalia Cornelio to Withdraw as Attorney. (Signed by Chief Judge Lee H Rosenthal) Parties notified.(gclair, 4) (Entered: 05/10/2019)	May 10, 2019	May 10, 2019 RECAP
26	ORDER Granting 24 Joint MOTION to Stay Proceedings for 60 Days ( Status Conference set for 7/10/2019 at 08:30 AM in Courtroom 11B before Chief Judge Lee H Rosenthal), (Signed by Chief Judge Lee H Rosenthal) Parties notified.(jguajardo, 4) (Entered: 05/10/2019)	May 10, 2019	May 10, 2019 RECAP
	Terminate Deadlines	May 31, 2019	May 31, 2019 PACER
	***Deadlines terminated. The IPTC set for 6/19 is canceled based on the status conference set for 7/10/19 when the case was stayed. (leddins, 4)	May 31, 2019	May 31, 2019 PACER
27	NOTICE of Resetting. Parties notified. Status Conference reset for 7/24/2019 at 10:00 AM in Courtroom 11B before Chief Judge Lee H Rosenthal, filed. (leddins, 4) (Entered: 06/12/2019)	June 12, 2019	June 12, 2019 PACER
28	NOTICE of Resetting. Parties notified. Status Conference reset for 7/25/2019 at 11:00 AM in Courtroom 11B before Chief Judge Lee H Rosenthal, filed. (leddins, 4) (Entered: 07/22/2019)	July 22, 2019	July 22, 2019 RECAP
29	Minute entry for proceedings before the Hon. Lee H. Rosenthal. Status conference held on July 25, 2019. The parties informed the court as to the status. Appearances: Elizabeth Rossi/Meagan Harding/Neal Manne for Pltfs. and Victoria Jimenez/ Melissa Spinks for Defts.(Court Reporter: N. Forrest), filed.(leddins, 4) (Entered: 07/25/2019)	July 25, 2019	July 25, 2019 PACER
	Status Conference	July 25, 2019	July 25, 2019 PACER
30	NOTICE of Change of Address by Civil Rights Corps, counsel for Pierson Johnnie, Joseph Ortuno, Dwight Russell, filed. (Rossi, Elizabeth) (Entered: 10/08/2019)	Oct. 8, 2019	Oct. 8, 2019 RECAP
31	NOTICE Joint Notice of Status of Settlement Negotiations by Pierson Johnnie, Joseph Ortuno, Dwight Russell, filed. (Rossi, Elizabeth) (Entered: 01/10/2020)	Jan. 10, 2020	Jan. 10, 2020 RECAP
32	MOTION for Temporary Restraining Order by Pierson Johnnie, Joseph Ortuno, Dwight Russell, filed. Motion Docket Date 4/17/2020. (Attachments: # 1 Exhibit A - Letters from Prominent Local Physicians & Letter from CEO of Harris Health, Dr. Esmaeil Porsa, # 2 Exhibit B - Expert Declaration of Dr. Elizabeth Chiao, # 3 Exhibit C - Expert Declaration of Dr. Jaimie Meyer, # 4 Exhibit D - Declaration of Sarah V. Wood, # 5 Exhibit E - Felony Bail Schedule, # 6 Exhibit F - March 20, 2020 General Order of Felony Judges, # 7 Exhibit G - State Commission on Judicial Conduct Documents Part 1, # 8 Exhibit H - State Commission on Judicial Conduct Documents Part 2, # 9 Exhibit I - Felony Court Docket Schedule, # 10 Exhibit J - Court Operations Emergency Order, # 11 Exhibit K - Felony Pretrial Detention Reports, # 12 Proposed Order)(Rossi, Elizabeth) (Entered: 03/27/2020) 1 Exhibit A - Letters from Prominent Local Physicians & Letter from CEO of Harris View on Clearinghouse 2 Exhibit B - Expert Declaration of Dr. Elizabeth Chiao View on RECAP 3 Exhibit C - Expert Declaration of Dr. Jaimie Meyer View on RECAP 4 Exhibit D - Declaration of Sarah V. Wood View on RECAP 5 Exhibit E - Felony Bail Schedule View on PACER 6 Exhibit F - March 20, 2020 General Order of Felony Judges View on RECAP 7 Exhibit G - State Commission on Judicial Conduct Documents Part 1 View on Clearinghouse 8 Exhibit H - State Commission on Judicial Conduct Documents Part 2 View on Clearinghouse 9 Exhibit I - Felony Court Docket Schedule View on PACER 10 Exhibit J - Court Operations Emergency Order View on PACER 11 Exhibit K - Felony Pretrial Detention Reports View on RECAP 12 Proposed Order View on PACER	March 27, 2020	March 27, 2020 Clearinghouse
33	MOTION for Michael Gervais to Appear Pro Hac Vice by Pierson Johnnie, Joseph Ortuno, Dwight Russell, filed. Motion Docket Date 4/17/2020. (Gervais, Michael) (Entered: 03/27/2020)	March 27, 2020	March 27, 2020 PACER
34	ORDER entered: The Court orders the defendants and the Texas Attorney General to respond to the plaintiffs' motion for a temporary restraining order by 4/1/2020. A Hearing is set for 4/3/2020 at 09:00 AM by videoconferencing before Chief Judge Lee H Rosenthal.(Signed by Chief Judge Lee H Rosenthal) Parties notified.(leddins, 4) (Entered: 03/27/2020)	March 27, 2020	March 27, 2020 RECAP
35	ORDER granting 33 Motion for Michael Gervais to Appear Pro Hac Vice.(Signed by Chief Judge Lee H Rosenthal) Parties notified.(ShoshanaArnow, 4) (Entered: 03/27/2020)	March 27, 2020	March 27, 2020 PACER
36	MOTION for Liyah Brown to Appear Pro Hac Vice by Pierson Johnnie, Joseph Ortuno, Dwight Russell, filed. Motion Docket Date 4/17/2020. (Marziani, Mimi) (Entered: 03/27/2020)	March 27, 2020	March 27, 2020 RECAP
37	AGREED Minute Entry ORDER: entered: for proceedings held before Chief Judge Lee H Rosenthal. TELEPHONE CONFERENCE held on 3/27/2020. Telephone Conference set for 3/30/2020 at 04:00 PM by telephone before Chief Judge Lee H Rosenthal Appearances: Victoria Jimenez, Melissa Spinks, Michael Gervais, Joseph Grinstein, Alec Karakatsanis, Elizabeth Rossi, Neal Manne, Murray Fogler and Adam Biggs., filed.(leddins, 4) (Entered: 03/29/2020)	March 27, 2020	March 27, 2020 PACER

Case: Russell v. Harris County, TX

4:19-cv-00226 | U.S. District Court for the Southern District of Texas

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