Case: Costa v. Bazron

Costa v. District of Columbia

Costa v. District of Columbia

Costa v. District of Columbia

ACLU District of Columbia

COMPLAINT against BARBARA J. BAZRON, MARK J. CHASTANG, DISTRICT OF COLUMBIA ( Filing fee $ 400 receipt number ADCDC-6474930) filed by STEFON KIRKPATRICK, ENZO COSTA, WILLIAM DUNBAR, VINITA SMITH. (Attachments: # 1 Civil Cover Sheet, # 2 Summons, # 3 Summons, # 4 Summons, # 5 Summons)(Spitzer, Arthur) (Entered: 10/23/2019)

1 Civil Cover Sheet

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2 Summons

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3 Summons

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4 Summons

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5 Summons

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NOTICE of Appearance by John Arak Freedman on behalf of All Plaintiffs (Freedman, John) (Entered: 10/25/2019)

Amended NOTICE of Appearance by John Arak Freedman on behalf of All Plaintiffs (Freedman, John) (Entered: 10/25/2019)

NOTICE of Appearance by Tirzah S. Lollar on behalf of ENZO COSTA, WILLIAM DUNBAR, STEFON KIRKPATRICK, VINITA SMITH (Lollar, Tirzah) (Entered: 10/25/2019)

CIVIL COVER SHEET signed (corrected) by STEFON KIRKPATRICK, ENZO COSTA, WILLIAM DUNBAR, VINITA SMITH re 1 Complaint, filed by STEFON KIRKPATRICK, ENZO COSTA, WILLIAM DUNBAR, VINITA SMITH. Related document: 1 Complaint, filed by ENZO COSTA, STEFON KIRKPATRICK, WILLIAM DUNBAR, VINITA SMITH.(Spitzer, Arthur) (Entered: 10/25/2019)

Case Assigned/Reassigned

Case assigned to Judge Christopher R. Cooper. (zmc)

SUMMONS (4) Issued Electronically as to BARBARA J. BAZRON, MARK J. CHASTANG, District of Columbia Attorney General, and the District of Columbia Mayor. (Attachment: # 1 Notice and Consent)(zmc) (Entered: 10/30/2019)

1 Notice and Consent

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Case randomly reassigned to Judge Randolph D. Moss. Judge Christopher R. Cooper is no longer assigned to the case. (ztnr) (Entered: 10/31/2019)

NOTICE of Appearance by Scott Michelman on behalf of All Plaintiffs (Michelman, Scott) (Entered: 10/31/2019)

STANDING ORDER: The parties are hereby ORDERED to comply with the directives set forth in the attached Standing Order. See document for details. Signed by Judge Randolph D. Moss on 10/31/19. (lcrdm2, ) (Entered: 10/31/2019)

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WITHDRAWN PURSUANT TO DOCKET ENTRY NO. 22 . . . . . Emergency MOTION to Take Deposition from 30(b)(6) Witness and Leave to Conduct Expedited Discovery by WILLIAM DUNBAR, STEFON KIRKPATRICK, VINITA SMITH (Attachments: # 1 Text of Proposed Order)(Freedman, John) Modified on 12/18/2019 (ztd). (Entered: 11/05/2019)

1 Text of Proposed Order

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MINUTE ORDER: In light of Plaintiffs' Emergency Motion to Take Deposition, Dkt. 10, Plaintiffs are hereby ORDERED to confer with Defendants and, together with Defendants, jointly contact the Courtroom Deputy Clerk at or before 3:00 p.m. on November 6, 2019, to identify a day and time the parties are available for a hearing on Plaintiffs' motion. Signed by Judge Randolph D. Moss on 11/04/2019. (lcrdm2, ) Modified on 11/6/2019 to correct clerk title(kt).

NOTICE of Appearance by Micah Ian Bluming on behalf of All Defendants (Bluming, Micah) (Entered: 11/06/2019)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the District of Columbia Attorney General. Date of Service Upon District of Columbia Attorney General 11/4/2019. Answer due for ALL D.C. DEFENDANTS by 11/25/2019. (Freedman, John) (Entered: 11/07/2019)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on the Mayor of the District of Columbia. Date of Service Upon the Mayor for the District of Columbia on 11/4/2019. (Freedman, John) (Entered: 11/07/2019)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. BARBARA J. BAZRON served on 11/4/2019 (Freedman, John) (Entered: 11/07/2019)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. MARK J. CHASTANG served on 11/4/2019 (Freedman, John) (Entered: 11/07/2019)

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MINUTE ORDER: The parties are hereby ORDERED to appear for a hearing on Plaintiffs' Emergency Motion to Take Deposition, Dkt. 10, on November 21, 2019, at 10:00 a.m. in Courtroom 21. It is further ORDERED that the parties shall file a joint status report on or before November 19, 2019 apprising the Court whether the parties have conferred on the motion, and, if so, whether they have narrowed the issues in dispute with respect to it. Signed by Judge Randolph D. Moss on 11/12/2019. (lcrdm2, )

Order

NOTICE of Appearance by Kaitlin Rose Banner on behalf of All Plaintiffs (Banner, Kaitlin) (Entered: 11/19/2019)

Joint STATUS REPORT by ENZO COSTA, WILLIAM DUNBAR, STEFON KIRKPATRICK, VINITA SMITH. (Banner, Kaitlin) (Entered: 11/19/2019)

Set/Reset Deadlines

Order on Motion for Extension of Time to

MOTION for Extension of Time to Respond to Complaint by BARBARA J. BAZRON, MARK J. CHASTANG, DISTRICT OF COLUMBIA (Bluming, Micah) (Entered: 11/20/2019)

MINUTE ORDER: In light of the parties' joint status report, Dkt. 17, the hearing currently set for November 21, 2019 is hereby VACATED. It is further ORDERED that the parties shall file a joint status report on or before December 3, 2019 apprising the Court on the status of the dispute regarding Plaintiffs' November 5, 2019 Emergency Motion for Leave to Conduct Limited Expedited Discovery ("Pending Motion"), Dkt. 10. It is further ORDERED that the Court shall hold the Pending Motion, including Defendants' obligation to oppose, in ABEYANCE. Signed by Judge Randolph D. Moss on 11/20/2019. (lcrdm2, )

Order

RESPONSE re 18 MOTION for Extension of Time to Respond to Complaint filed by ENZO COSTA, WILLIAM DUNBAR, STEFON KIRKPATRICK, VINITA SMITH. (Banner, Kaitlin) (Entered: 11/22/2019)

MINUTE ORDER: Upon consideration of Defendants' motion for extension, Dkt. 18, and Plaintiffs' opposition, Dkt. 19, it is hereby ORDERED that Defendants' motion is GRANTED in part and DENIED in part. Defendant shall file a responsive pleading or motion on the pleadings on or before December 16, 2019. Signed by Judge Randolph D. Moss on 11/22/2019. (lcrdm2, )

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Notice of QC

Joint STATUS REPORT re: Emergency Motion for Leave to Conduct Limited Expedited Discovery by ENZO COSTA, WILLIAM DUNBAR, STEFON KIRKPATRICK, VINITA SMITH. (Banner, Kaitlin) (Entered: 12/03/2019)

NOTICE OF ERROR re 20 Status Report; emailed to kaitlin_banner@washlaw.org, cc'd 11 associated attorneys -- The PDF file you docketed contained errors: 1. On future filings, please make sure your signature is on the signature line of you document(s). (ztd, )

MOTION to Dismiss Plaintiffs' Complaint by BARBARA J. BAZRON, MARK J. CHASTANG, DISTRICT OF COLUMBIA (Attachments: # 1 Memorandum in Support of Defendants' Motion To Dismiss, # 2 Exhibit A (Declaration of K. Singh Taneja), # 3 Text of Proposed Order)(Bluming, Micah) (Entered: 12/16/2019)

1 Memorandum in Support of Defendants' Motion To Dismiss

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2 Exhibit A (Declaration of K. Singh Taneja)

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3 Text of Proposed Order

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WITHDRAWAL of Motion by ENZO COSTA, WILLIAM DUNBAR, STEFON KIRKPATRICK, VINITA SMITH For Leave to Conduct Limited Expedited Discovery. (Banner, Kaitlin) (Entered: 12/17/2019)

MOTION for Discovery for Jurisdictional Discovery by ENZO COSTA, WILLIAM DUNBAR, STEFON KIRKPATRICK, VINITA SMITH (Banner, Kaitlin) (Entered: 12/20/2019)

NOTICE OF PROPOSED ORDER to Add Proposed Order on Motion for Jurisdictional Discovery by ENZO COSTA, WILLIAM DUNBAR, STEFON KIRKPATRICK, VINITA SMITH (Banner, Kaitlin) Modified text on 12/23/2019 (ztd). (Entered: 12/20/2019)

Consent MOTION for Extension of Time to File Response/Reply as to 21 MOTION to Dismiss Plaintiffs' Complaint by ENZO COSTA, WILLIAM DUNBAR, STEFON KIRKPATRICK, VINITA SMITH (Attachments: # 1 Text of Proposed Order)(Freedman, John) (Entered: 12/26/2019)

1 Text of Proposed Order

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MINUTE ORDER: Upon consideration of Plaintiffs' unopposed motion to extend, Dkt. 25, it is hereby ORDERED that the motion is GRANTED. Plaintiffs shall file their opposition to Defendants' motion to dismiss, Dkt. 21, on or before January 13, 2020, unless otherwise directed by further order of the Court. Signed by Judge Randolph D. Moss on 12/27/2019. (lcrdm2, )

Order on Motion for Extension of Time to File Response/Reply

Set/Reset Deadlines

Order on Motion for Extension of Time to File Response/Reply

NOTICE of Appearance by Honey C. Morton on behalf of All Defendants (Morton, Honey) (Entered: 12/30/2019)

Memorandum in opposition to re 23 MOTION for Discovery for Jurisdictional Discovery filed by BARBARA J. BAZRON, MARK J. CHASTANG, DISTRICT OF COLUMBIA. (Attachments: # 1 Text of Proposed Order)(Bluming, Micah) (Entered: 01/03/2020)

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MINUTE ORDER: Upon consideration of the Plaintiffs' motion for leave to conduct jurisdictional discovery, Dkt. 23, the Court has determined that a motions hearing is appropriate. It is hereby ORDERED that the parties shall appear for a motions hearing on January 22, 2020, at 2:00p.m., in Courtroom 21. Signed by Judge Randolph D. Moss on 01/06/2020. (lcrdm2, )

Order

Consent MOTION for Extension of Time to File Response/Reply as to 21 MOTION to Dismiss Plaintiffs' Complaint by ENZO COSTA, WILLIAM DUNBAR, STEFON KIRKPATRICK, VINITA SMITH (Attachments: # 1 Text of Proposed Order)(Banner, Kaitlin) (Entered: 01/07/2020)

Order on Motion for Extension of Time to File Response/Reply

MINUTE ORDER: Upon consideration of Plaintiffs' unopposed motion for extension, Dkt. 28, it is hereby ORDERED that the motion is GRANTED. Plaintiffs response to Defendants' motion to dismiss, Dkt. 21, shall be due fourteen days after (i) Defendants complete jurisdictional discovery production, or (ii) the Court denies Plaintiff' motion for jurisdictional discovery, Dkt. 23. Signed by Judge Randolph D. Moss on 01/10/2020. (lcrdm2, )

REPLY to opposition to motion re 23 MOTION for Discovery for Jurisdictional Discovery filed by ENZO COSTA, WILLIAM DUNBAR, STEFON KIRKPATRICK, VINITA SMITH. (Attachments: # 1 Exhibit Exhibit 1 - Testimony of Barbara J. Bazron)(Banner, Kaitlin) (Entered: 01/10/2020)

1 Exhibit Exhibit 1 - Testimony of Barbara J. Bazron

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MOTION to Certify Class by ENZO COSTA, WILLIAM DUNBAR, STEFON KIRKPATRICK, VINITA SMITH (Attachments: # 1 Text of Proposed Order)(Freedman, John) (Entered: 01/21/2020)

1 Text of Proposed Order

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Motion Hearing

Minute Entry for proceedings held before Judge Randolph D. Moss: Motion Hearing held on 1/22/2020 re: 23 MOTION for Discovery for Jurisdictional Discovery filed by ENZO COSTA, STEFON KIRKPATRICK, WILLIAM DUNBAR, VINITA SMITH. For the reasons stated on the record, the motion is GRANTED IN PART and DENIED IN PART; Discovery permitted as to items 1, 2, 4, 5, and 6 of Exhibit 1; As to item 8 of Exhibit 1, Plaintiffs' are allowed to serve a request for admission as outlined by the Court on the record. The Court will hold in abeyance Defendants' obligation to respond to Plaintiffs' pending 30 Motion to Certify Class. (Court Reporter: Jeff Hook.) (kt)

Exhibit List by ENZO COSTA, WILLIAM DUNBAR, STEFON KIRKPATRICK, VINITA SMITH. (kt) (Entered: 01/22/2020)

PLAINTIFFS' EXHIBIT (Chart submitted in open court, in support of Plaintiffs' Motion). "Let It Be Filed" by Judge Randolph D. Moss. (kt) (Entered: 01/22/2020)

TRANSCRIPT OF MOTION HEARING before Judge Randolph D. Moss held on January 22, 2020. Page Numbers: 1 - 47. Date of Issuance: February 5, 2020. Court Reporter: Jeff Hook. Telephone number: 202-354-3373. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter refer enced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 2/26/2020. Redacted Transcript Deadline set for 3/7/2020. Release of Transcript Restriction set for 5/5/2020.(Hook, Jeff) (Entered: 02/05/2020)

Joint MOTION for Protective Order by BARBARA J. BAZRON, MARK J. CHASTANG, DISTRICT OF COLUMBIA (Bluming, Micah) (Entered: 03/12/2020)

PROTECTIVE ORDER: It is hereby ORDERED that the parties shall comply with the terms of the stipulated Protective Order, which the Court adopts in full. See document for details. Signed by Judge Randolph D. Moss on 03/13/2020. (lcrdm2, ) (Entered: 03/13/2020)

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Emergency MOTION for Hearing, MOTION for Leave to File Amended Complaint by ENZO COSTA, WILLIAM DUNBAR, STEFON KIRKPATRICK, VINITA SMITH (Attachments: # 1 Exhibit Proposed Amended Complaint, # 2 Exhibit Redline of Proposed Amended Complaint, # 3 Text of Proposed Order)(Freedman, John) (Entered: 04/16/2020)

1 Exhibit Proposed Amended Complaint

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2 Exhibit Redline of Proposed Amended Complaint

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3 Text of Proposed Order

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MINUTE ORDER: In light of Plaintiffs' motion for emergency hearing, Dkt. 36, it is hereby ORDERED that the parties shall appear telephonically for a status conference on April 17, 2020 at 12:00pm. The parties shall contact the Court's Deputy Clerk for logistical information concerning appearing telephonically. Signed by Judge Randolph D. Moss on 04/16/2020. (lcrdm2, )

Set/Reset Hearings

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Set/Reset Hearings: Telephonic Status Conference set for 4/17/2020 at 12:00 PM before Judge Randolph D. Moss. (kt)

Order on Motion for Miscellaneous Relief

Status Conference

MINUTE ORDER: Upon consideration of the parties' joint motion to reschedule, Dkt. 37, it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that the status conference currently scheduled for today at noon is RESCHEDULED to April 17, 2020, at 2:00pm. Signed by Judge Randolph D. Moss on 04/17/2020. (lcrdm2, )

Joint MOTION to Reschedule Hearing by BARBARA J. BAZRON, MARK J. CHASTANG, DISTRICT OF COLUMBIA (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Bluming, Micah) Modified event on 4/17/2020 (znmw). (Entered: 04/17/2020)

NOTICE of Appearance by Michael Krevans Perloff on behalf of All Plaintiffs (Perloff, Michael) (Entered: 04/17/2020)

Minute Entry for proceedings held before Judge Randolph D. Moss: Telephonic Status Conference held on 4/17/2020. All parties and the Court appeared via telephone. Plaintiffs shall file their Motion for Temporary Restraining Order by 12 noon on 4/18/2020; Defendants shall file their Response to Plaintiffs' Motion for Temporary Restraining Order by 4:00 PM on 4/21/2020, and their Opposition to Plaintiffs' Motion for Leave to File Amended Complaint by 10:00 AM on 4/21/2020. A Telephonic Motion Hearing is set for 4/22/2020, at 3:30 PM, before Judge Randolph D. Moss. The parties shall utilize the same conference call line and access code. (Court Reporter: Jeff hook.) (kt)

MOTION for Temporary Restraining Order by ENZO COSTA, WILLIAM DUNBAR, VINITA SMITH (Attachments: # 1 Memorandum in Support, # 2 Exhibit 1. Jones Declaration, # 3 Exhibit 2. Stern Declaration, # 4 Exhibit 3. Golob Declaration, # 5 Exhibit 4. Truettner Declaration, # 6 Exhibit 5. Costa Declaration, # 7 Exhibit 6. Dunbar Declaration, # 8 Exhibit 7. Smith Declaration, # 9 Exhibit 8. Guzman Declaration, # 10 Exhibit 9. Rose Declaration, # 11 Exhibit 10. Mason Declaration, # 12 Exhibit 11. Donkar Declaration, # 13 Text of Proposed Order)(Freedman, John) (Entered: 04/18/2020)

1 Memorandum in Support

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2 Exhibit 1. Jones Declaration

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3 Exhibit 2. Stern Declaration

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4 Exhibit 3. Golob Declaration

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5 Exhibit 4. Truettner Declaration

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6 Exhibit 5. Costa Declaration

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7 Exhibit 6. Dunbar Declaration

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8 Exhibit 7. Smith Declaration

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9 Exhibit 8. Guzman Declaration

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10 Exhibit 9. Rose Declaration

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11 Exhibit 10. Mason Declaration

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12 Exhibit 11. Donkar Declaration

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13 Text of Proposed Order

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MINUTE ORDER: In light of the upcoming motion hearing, Defendants are hereby ORDERED to file a notice on or before April 22, 2020, at 10:00 AM, containing the following information: the numbers of persons affiliated with St. Elizabeths Hospital who have been tested for COVID-19 and an anonymized break-down of those results by date of test, test results, housing unit, and status (e.g., resident or staff) and location (e.g., hospitalized, quarantined, general housing) of the person tested; whether all new residents and staff are tested and, if so, when that protocol took effect; and all relevant written procedures and practices concerning COVID-19, including the Emergency Preparedness Plan that was implemented on March 12, 2020. If any of this information could reveal personal medical information relating to an identifiable person, Defendants may file that information, but only that information, under seal. As the Court previously directed, Plaintiffs shall file its reply in support of its motion on or before April 22, 2020, at 12:00 PM. Signed by Judge Randolph D. Moss on 04/20/2020. (lcrdm2, )

Order

Memorandum in opposition to re 36 Emergency MOTION for Hearing MOTION for Leave to File Amended Complaint filed by BARBARA J. BAZRON, MARK J. CHASTANG, DISTRICT OF COLUMBIA. (Attachments: # 1 Text of Proposed Order)(Bluming, Micah) (Entered: 04/21/2020)

1 Text of Proposed Order

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REPLY to opposition to motion re 36 Emergency MOTION for Hearing MOTION for Leave to File Amended Complaint filed by ENZO COSTA, WILLIAM DUNBAR, VINITA SMITH. (Freedman, John) (Entered: 04/21/2020)

Memorandum in opposition to re 39 MOTION for Temporary Restraining Order filed by BARBARA J. BAZRON, MARK J. CHASTANG, DISTRICT OF COLUMBIA. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Text of Proposed Order)(Bluming, Micah) (Entered: 04/21/2020)

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 Text of Proposed Order

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STIPULATION of Dismissal of Plaintiff Stefon Kirkpatrick's Claims by ENZO COSTA, WILLIAM DUNBAR, STEFON KIRKPATRICK, VINITA SMITH. (Banner, Kaitlin) (Entered: 04/21/2020)

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Order on Sealed Motion for Leave to File Document Under Seal

Notice of QC

MINUTE ORDER: Upon consideration of the parties' joint stipulation of dismissal, Dkt. 43, it is hereby ORDERED that the claims of Plaintiff Stefon Kirkpatrick are DISMISSED without prejudice. The Clerk's Office is directed to terminate Plaintiff Kirkpatrick as a party in this case. Signed by Judge Randolph D. Moss on 04/22/2020. (lcrdm2, ) Modified on 4/22/2020 to add clerk's office language (kt).

Motion Hearing

SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by BARBARA J. BAZRON, MARK J. CHASTANG, DISTRICT OF COLUMBIA (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Memorandum in Support, # 2 Exhibit A Part 1, # 3 Exhibit A Part 2, # 4 Exhibit A Part 3, # 5 Exhibit A Part 4, # 6 Text of Proposed Order)(Bluming, Micah) (Entered: 04/22/2020)

RESPONSE TO ORDER April 20, 2020 Minute Order by BARBARA J. BAZRON, MARK J. CHASTANG, DISTRICT OF COLUMBIA (Attachments: # 1 Exhibit 1 - Patient Data, # 2 Exhibit 2 - Staff Data, # 3 Exhibit 3 - Administrative Issuance)(Morton, Honey) Modified text on 4/22/2020 (ztd). (Entered: 04/22/2020)

1 Exhibit 1 - Patient Data

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2 Exhibit 2 - Staff Data

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3 Exhibit 3 - Administrative Issuance

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MINUTE ORDER: There is a strong presumption in favor of public access to judicial records and documents, but that presumption "may be outweighed in certain cases by competing interests." Metlife, Inc. v. Fin. Stability Oversight Council, 865 F.3d 661, 665 (D.C. Cir. 2017). Here, Defendants seek leave to file under seal Saint Elizabeths Hospital's Emergency Preparedness Plan ("EPP"). The EPP contains non -public details about operations at Saint Elizabeths Hospital and how the District plans to maintain operations during various emergency situations, including information about which kinds of patients are kept where, logistics for moving people in emergency situations, and locations of emergency supplies. The Court finds that the public interest in the disclosure of this document is low because little, if any of the EPP's contents bear on the matters being litigated in the case--the Defendants' response to COVID-19. Instead, the EPP's contents pertain to more general emergency preparedness measures. The reason for sealing, in contrast, is compelling. The EPP contains sensitive operational and security details that could be compromised by public disclosure. Accordingly, Defendants' motion for leave to file under seal, Dkt. 44, is hereby GRANTED. The EPP, Dkt. 44-1 (attached exhibits to Dkt. 44), shall be filed under SEAL. Signed by Judge Randolph D. Moss on 04/22/2020. (lcrdm2, ) Modified on 4/23/2020 to add language for the Clerk's Office (kt).

REPLY to opposition to motion re 39 MOTION for Temporary Restraining Order filed by ENZO COSTA, WILLIAM DUNBAR, VINITA SMITH. (Attachments: # 1 Exhibit Jones Supplemental Declaration, # 2 Exhibit Stern Supplemental Declaration, # 3 Exhibit Barkenow Declaration, # 4 Exhibit Mason Supplemental Declaration)(Freedman, John) (Entered: 04/22/2020)

1 Exhibit Jones Supplemental Declaration

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2 Exhibit Stern Supplemental Declaration

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3 Exhibit Barkenow Declaration

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4 Exhibit Mason Supplemental Declaration

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ENTERED IN ERROR. . . . .NOTICE of additional Exhibit 5, Truettner Supplemental Declaration by ENZO COSTA, WILLIAM DUNBAR, STEFON KIRKPATRICK, VINITA SMITH re 46 Reply to opposition to Motion, (Banner, Kaitlin) Modified on 4/22/2020 (ztd). (Entered: 04/22/2020)