CLASS ACTION COMPLAINT AND PETITION FOR WRIT OF HABEAS CORPUS (request for injunctive relief found within) filed by Randolph Mitchell, Michael Singleton, Rhonda Jones, Barry Watkins. (Filing fee $400, receipt number AGANDC-9861789) (Attachments: # (1) Statement of Related Case, # (2) Civil Cover Sheet)(tmf) Please visit our website at http://www.gand.uscourts.gov/commonly-used-forms to obtain Pretrial Instructions and Pretrial Associated Forms which includes the Consent To Proceed Before U.S. Magistrate form. Modified on 7/2/2020 to edit text(tmf).

1 Statement of Related Case

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2 Civil Cover Sheet

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Certificate of Interested Persons and Corporate Disclosure Statement by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (tmf)

Electronic Summons Issued as to Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas. (Attachments: # (1) Summons Gibson, # (2) Summons Hill, # (3) Summons Johnson, # (4) Summons Thomas)(tmf)

1 Summons Gibson

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2 Summons Hill

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3 Summons Johnson

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4 Summons Thomas

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GENERAL ORDER 20-01 Fourth Amendment IN RE: COURT OPERATIONS UNDERTHE EXIGENT CIRCUMSTANCES CREATED BY COVID-19 AND RELATED CORONAVIRUS Signed by Judge Thomas W. Thrash, Jr. on 7/1/2020. (tmf)

NOTICE FROM THE COURT: INSTRUCTIONS FOR CIVIL CASES ASSIGNED TO THE HONORABLE ELEANOR L. ROSS. (mlb)

NOTICE Of Filing by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins (Attachments: # (1) Exhibit A: Declarations of Named Plaintiffs Currently Incarcerated in the Clayton County Jail, # (2) Exhibit B: Redacted Declarations of People Currently Incarcerated in or Recently Released from the Clayton County Jail)(Cutting, Jeremy)

1 Exhibit A: Declarations of Named Plaintiffs Currently Incarcerated in the Clayto

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2 Exhibit B: Redacted Declarations of People Currently Incarcerated in or Recently

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MOTION to Certify Class with Brief In Support by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Attachments: # (1) Brief in Support of Plaintiffs' Motion to Certify Class)(Primerano, Ryan)

1 Brief in Support of Plaintiffs' Motion to Certify Class

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Clerks Notation re 2 Certificate of Interested Persons/Corporate Disclosures by Rhonda Jones, Randolph Mitchell, Michael Singleton and Barry Watkins. Read and approved by District Judge Eleanor L. Ross. (mlb)

Submission of 1 Complaint,, to District Judge Eleanor L. Ross. (tmf)

ORDER: The Court DENIES Plaintiffs' request for preliminary injunctive relief. Furthermore, because Plaintiffs' Complaint seeks habeas corpus relief pursuant to 28 U.S.C. §§ 2241 and 2243, the Court DIRECTS the Clerk to refer this case to a Magistrate Judge pursuant to Standing Order 18-01. Signed by Judge Eleanor L. Ross on 7/9/2020. (jed)

CASE REFERRED to Magistrate Judge Christopher C. Bly. (jed)

Submission of 8 Order and 1 Complaint to Magistrate Judge Christopher C. Bly. (jed)

MOTION for Leave to File Excess Pages with Brief In Support by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Primerano, Ryan)

FIFTH AMENDMENT TO GENERAL ORDER 20-01 RE: COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID-19 AND RELATED CORONAVIRUS. Signed by Judge Thomas W. Thrash, Jr. on 7/10/2020 (mmc) (ADI)

NOTICE of Appearance by Arash A. Sabzevari on behalf of Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas (Sabzevari, Arash)

APPLICATION for Admission of David Fathi Pro Hac Vice (Application fee $ 150, receipt number AGANDC-9910935).by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Geraghty, Sarah) Documents for this entry are not available for viewing outside the courthouse.

NOTICE of Appearance by Jack Reynolds Hancock on behalf of Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas (Hancock, Jack)

APPLICATION for Admission of Stephen Pevar Pro Hac Vice (Application fee $ 150, receipt number AGANDC-9916491).by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Tucker, Kosha) Documents for this entry are not available for viewing outside the courthouse.

APPLICATION for Admission of Robert W. Hunter Pro Hac Vice (Application fee $ 150, receipt number AGANDC-9916569).by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Tucker, Kosha) Documents for this entry are not available for viewing outside the courthouse.

ORDER granting [9] Motion for Leave to File Excess Pages. Plaintiffs may file an additional ten (10) pages - for a total of thirty-five (35) pages - to its forthcoming Motion for Preliminary Injunction. Signed by Judge Eleanor L. Ross on 7/15/2020. (jpk)

APPROVAL by Clerks Office re: 12 APPLICATION for Admission of David Fathi Pro Hac Vice (Application fee $ 150, receipt number AGANDC-9910935).. Attorney David C. Fathi added appearing on behalf of Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins (nmb)

MINUTE ORDER (by docket entry only) GRANTING 12 Application for Admission Pro Hac Vice of David C. Fathi. Approved by District Judge Eleanor L. Ross on 7/16/20. If the applicant does not have CM/ECF access in the Northern District of Georgia already, they must request access at http://pacer.gov. If they have electronically filed in this district in a previous case, please omit this step.(mlb)

Clerk's Certificate of Mailing (via email) to Attorney David C. Fathi as to Rhonda Jones, Randolph Mitchell, Michael Singleton and Barry Watkins regarding Order on Application for Admission PHV. (mlb)

APPLICATION for Admission of Brandon Buskey Pro Hac Vice (Application fee $ 150, receipt number AGANDC-9924715).by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Tucker, Kosha) Documents for this entry are not available for viewing outside the courthouse.

Clerk's Certificate of Mailing (via email) to Attorneys Stephen Pevar and Robert Hunter as to Michael Singleton and Barry Watkins regarding Order(s) on Application for Admission PHVs. (mlb)

APPROVAL by Clerks Office re: 15 APPLICATION for Admission of Robert W. Hunter Pro Hac Vice (Application fee $ 150, receipt number AGANDC-9916569).. Attorney Robert W. Hunter added appearing on behalf of Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins (nmb)

MINUTE ORDER (by docket entry only) GRANTING 15 Application for Admission Pro Hac Vice of Robert W. Hunter. Approved by District Judge Eleanor L. Ross on 7/17/20. If the applicant does not have CM/ECF access in the Northern District of Georgia already, they must request access at http://pacer.gov. If they have electronically filed in this district in a previous case, please omit this step.(mlb)

Submission of 7 MOTION to Certify Class to Magistrate Judge Christopher C. Bly. (jpk)

NOTICE of Leave of Absence for the following dates: July 27, 2020 - July 31, 2020 by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas (Hancock, Jack) Modified on 7/22/2020 to edit text and add dates (jpk).

MINUTE ORDER (by docket entry only) GRANTING 17 Application for Admission Pro Hac Vice of Brandon Buskey. Approved by District Judge Eleanor L. Ross on 7/24/20. If the applicant does not have CM/ECF access in the Northern District of Georgia already, they must request access at http://pacer.gov. If they have electronically filed in this district in a previous case, please omit this step.(mlb)

Clerk's Certificate of Mailing (via email) to Attorney Brandon Buskey as to Rhonda Jones, Randolph Mitchell, Michael Singleton and Barry Watkins regarding Order on Application for Admission PHV. (mlb)

APPROVAL by Clerks Office re: 17 APPLICATION for Admission of Brandon Buskey Pro Hac Vice (Application fee $ 150, receipt number AGANDC-9924715).. Attorney Brandon Buskey added appearing on behalf of Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins (nmb)

MOTION for Preliminary Injunction with Brief In Support by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Attachments: # (1) Brief in Support of Motion for Preliminary Injunction, # (2) Exhibit A: Declaration of Nina H. Fefferman, Ph.D, # (3) Exhibit B: Declaration of Fred Rottnek, M.D., # (4) Exhibit C: Declaration of Emmitt L. Sparkman, # (5) Exhibit D: Declarations of 12 Current or Recent Detainees, # (6) Exhibit E: Email from E. Cross to Defendants, Mar. 13, 2020, # (7) Exhibit F: Email from Sheriff Victor Hill, Mar. 17, 2020, # (8) Exhibit G: Records from Clayton County Health District, # (9) Exhibit H: Records from CorrectHealth, LLC, # (10) Exhibit I: Detainee Grievances, # (11) Exhibit J: Assorted COVID-19 Records from Clayton Cty. Sheriffs Office, # (12) Exhibit K: Clayton Cty. Sheriffs Office Advisory, Jul. 2, 2020, # (13) Exhibit L: CDC Interim Guidance, # (14) Exhibit M: Ga. Dept of Public Health Interim Guidance, # (15) Text of Proposed Order Granting Motion for Preliminary Injunction)(Cutting, Jeremy)

1 Brief in Support of Motion for Preliminary Injunction

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2 Exhibit A: Declaration of Nina H. Fefferman, Ph.D

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3 Exhibit B: Declaration of Fred Rottnek, M.D.

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4 Exhibit C: Declaration of Emmitt L. Sparkman

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5 Exhibit D: Declarations of 12 Current or Recent Detainees

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6 Exhibit E: Email from E. Cross to Defendants, Mar. 13, 2020

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7 Exhibit F: Email from Sheriff Victor Hill, Mar. 17, 2020

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8 Exhibit G: Records from Clayton County Health District

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9 Exhibit H: Records from CorrectHealth, LLC

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10 Exhibit I: Detainee Grievances

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11 Exhibit J: Assorted COVID-19 Records from Clayton Cty. Sheriffs Office

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12 Exhibit K: Clayton Cty. Sheriffs Office Advisory, Jul. 2, 2020

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13 Exhibit L: CDC Interim Guidance

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14 Exhibit M: Ga. Dept of Public Health Interim Guidance

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15 Text of Proposed Order Granting Motion for Preliminary Injunction

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MOTION for Hearing re [19] MOTION for Preliminary Injunction, MOTION to Expedite Hearing on Motion for Preliminary Injunction with Brief In Support by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Cutting, Jeremy)

MOTION for Discovery, MOTION to Expedite Discovery with Brief In Support by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Attachments: # (1) Brief in Support of Motion for Expedited Discovery, # (2) Exhibit A: Plaintiffs Proposed Written Discovery, # (3) Text of Proposed Order Granting Plaintiffs Request for Expedited Discovery)(Cutting, Jeremy)

1 Brief in Support of Motion for Expedited Discovery

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2 Exhibit A: Plaintiffs Proposed Written Discovery

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3 Text of Proposed Order Granting Plaintiffs Request for Expedited Discovery

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ORDER OF RECUSAL. Judge Eleanor L. Ross recused. Case reassigned to Judge J. P. Boulee for all further proceedings NOTICE TO ALL COUNSEL OF RECORD: The Judge designation in the civil action number assigned to this case has been changed to 1:20-CV-02791-JPB-CCB. Please make note of this change in order to facilitate the docketing of pleadings in this case. Signed by Judge Eleanor L. Ross on 7/28/2020. (jpk)

First MOTION to Dismiss with Brief In Support by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas. (Attachments: # (1) Brief Memorandum of Law, # (2) Exhibit)(Sabzevari, Arash)

1 Brief Memorandum of Law

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2 Exhibit

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First Certificate of Interested Persons by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas. (Sabzevari, Arash)

First MOTION to Stay Discovery with Brief In Support by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas. (Attachments: # (1) Text of Proposed Order)(Sabzevari, Arash)

1 Text of Proposed Order

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Consent MOTION for Leave to File Excess Pages in Brief in Opposition to Motion for Preliminary Injunction by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas. (Attachments: # (1) Text of Proposed Order)(Sabzevari, Arash)

1 Text of Proposed Order

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SIXTH AMENDMENT TO GENERAL ORDER 20-01 RE: COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID-19 AND RELATED CORONAVIRUS. Signed by Judge Thomas W. Thrash, Jr. on 08/03/2020. (dgs) (ADI)

MOTION to Stay or in the Alternative, MOTION for Extension of Time to File Response in Opposition to Plaintiffs' Motion for Preliminary Injunction re: [19] MOTION for Preliminary Injunction with Brief In Support by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas. (Attachments: # (1) Text of Proposed Order Staying Motion for Preliminary Injunction, # (2) Text of Proposed Order Granting Extension of Time)(Sabzevari, Arash)

1 Text of Proposed Order Staying Motion for Preliminary Injunction

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2 Text of Proposed Order Granting Extension of Time

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RESPONSE in Opposition re [20] MOTION for Hearing re [19] MOTION for Preliminary Injunction MOTION to Expedite Hearing on Motion for Preliminary Injunction filed by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas. (Attachments: # (1) Text of Proposed Order Denying Motion for Expedited Hearing)(Sabzevari, Arash)

1 Text of Proposed Order Denying Motion for Expedited Hearing

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RESPONSE in Opposition re [21] MOTION for Discovery MOTION to Expedite Discovery filed by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas. (Attachments: # (1) Text of Proposed Order Denying Motion for Expedited Discovery)(Sabzevari, Arash)

1 Text of Proposed Order Denying Motion for Expedited Discovery

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ORDER: For good cause shown, the 26 Consent Motion for Leave to File Excess Pages is GRANTED. IT IS HEREBY ORDERED that Defendants response in opposition to Plaintiffs Motion for Preliminary Injunction may exceed the page limit by ten additional pages for a total of thirty-five pages. Signed by Judge J. P. Boulee on 8/4/20. (bnw)

ORDER: This Court HEREBY ORDERS expedited briefing on Defendants' 28 Motion to Stay Plaintiffs' Motion for Preliminary Injunction. Plaintiffs shall file their response to Defendants' Motion to Stay no later than noon on August 10, 2020. Defendants' reply, if any, shall be filed no later than the close of business on August 11, 2020. Signed by Judge J. P. Boulee on 8/6/20. (bnw)

RESPONSE in Opposition re [28] MOTION to Stay or in the Alternative MOTION for Extension of Time to File Response in Opposition to Plaintiffs' Motion for Preliminary Injunction re: [19] MOTION for Preliminary Injunction filed by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Attachments: # (1) Exhibit A: CorrectHealth June Statistical Report)(Primerano, Ryan)

1 Exhibit A: CorrectHealth June Statistical Report

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REPLY BRIEF re [28] MOTION to Stay or in the Alternative MOTION for Extension of Time to File Response in Opposition to Plaintiffs' Motion for Preliminary Injunction re: [19] MOTION for Preliminary Injunction filed by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas. (Sabzevari, Arash)

MOTION for Leave to File Excess Pages with Brief In Support by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Attachments: # (1) Text of Proposed Order Granting Motion for Leave to File Excess Pages)(Primerano, Ryan)

1 Text of Proposed Order Granting Motion for Leave to File Excess Pages

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STANDING ORDER REGARDING CIVIL LITIGATION. Signed by Judge J. P. Boulee on 8/14/20. (bnw)

ORDER granting [21] Plaintiffs' Motion for Expedited Discovery. At this time, this Court will not determine the exact scope of the permissible discovery or the corresponding deadlines to complete discovery. Discovery, however, shall not be broader than that requested in the Motion for Expedited Discovery. No later than August 21, 2020, the parties are to meet and confer to determine the proper scope of the allowable discovery pursuant to this Court's Standing Order. Defendants; Motion to Stay Plaintiffs' Motion for Preliminary Injunction, or in the alternative, Motion for Extension of Time [28] is granted in part. Defendants shall file their response to Plaintiffs' Motion for Preliminary Injunction no later than August 31, 2020. Plaintiffs' reply, if any, shall be filed no later than September 14, 2020. Signed by Judge J. P. Boulee on 8/14/2020. (ddm)

MINUTE ORDER: Plaintiffs' unopposed motion for a page-limit extension, (Doc. 33), is GRANTED. Plaintiffs may file a brief of up to 35 pages in length in response to Defendants' motion to dismiss, and Defendants may file a reply brief of up to 25 pages in length. Ordered by Magistrate Judge Christopher C. Bly on 8/14/20. (jtj)

RESPONSE in Opposition re [23] First MOTION to Dismiss filed by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Attachments: # (1) Exhibit A: Clayton County Sheriff's Office Request for Proposal No. SO-02)(Cutting, Jeremy)

1 Exhibit A: Clayton County Sheriff's Office Request for Proposal No. SO-02

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RESPONSE in Opposition re [25] First MOTION to Stay Discovery filed by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Primerano, Ryan)

Submission of 20 MOTION for Hearing re 19 MOTION for Preliminary Injunction, MOTION to Expedite Hearing on Motion for Preliminary Injunction, to Magistrate Judge Christopher C. Bly. (ddm)

CERTIFICATE OF SERVICE by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas.(Sabzevari, Arash)

REPLY BRIEF re [23] First MOTION to Dismiss filed by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas. (Sabzevari, Arash)

RESPONSE in Opposition re [19] MOTION for Preliminary Injunction filed by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas. (Attachments: # (1) Exhibit Declaration of Terrance Gibson, # (2) Exhibit Declaration of Demarco May, # (3) Exhibit Declaration of Doctor Charles Clopton, # (4) Exhibit Declaration of Edward Sweeney)(Sabzevari, Arash)

1 Exhibit Declaration of Terrance Gibson

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2 Exhibit Declaration of Demarco May

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3 Exhibit Declaration of Doctor Charles Clopton

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4 Exhibit Declaration of Edward Sweeney

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SEVENTH AMENDMENT TO GENERAL ORDER 20-01 RE: COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID-19 AND RELATED CORONAVIRUS. Signed by Judge Thomas W. Thrash, Jr. on 9/1/2020. (ddm) (ADI)

RESPONSE re [35] Order on Motion for Discovery,,,, Order on Motion to Expedite,,,, Order on Motion to Stay,,,, Order on Motion for Extension of Time,,, Consolidated/Joint Discovery Statement filed by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Attachments: # (1) Exhibit A: Description of Proposed Inspection, # (2) Exhibit B: Excerpt of Original Relevant Discovery Requests)(Cutting, Jeremy)

1 Exhibit A: Description of Proposed Inspection

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2 Exhibit B: Excerpt of Original Relevant Discovery Requests

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Submission of 23 First MOTION to Dismiss, 25 First MOTION to Stay Discovery, to Magistrate Judge Christopher C. Bly. (ddm)

Unopposed MOTION for Leave to File Excess Pages, First MOTION for Extension of Time to File Reply in Support of Plaintiffs' re: [19] MOTION for Preliminary Injunction with Brief In Support by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Attachments: # (1) Text of Proposed Order)(Cutting, Jeremy)

1 Text of Proposed Order

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RESPONSE re [44] Unopposed MOTION for Leave to File Excess Pages First MOTION for Extension of Time to File Reply in Support of Plaintiffs' re: [19] MOTION for Preliminary Injunction filed by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas. (Sabzevari, Arash)

ORDER: For good cause shown, Plaintiffs' 44 Motion for Extension of Time and Page Limit is GRANTED. IT IS HEREBY ORDERED that Plaintiffs' reply brief can exceed the allowable page limitation, but shall not exceed twenty-five pages. IT IS FURTHER ORDERED that Plaintiffs' deadline to file the reply brief is extended through and including September 24, 2020. Signed by Judge J. P. Boulee on 9/10/20. (bnw)

CERTIFICATE OF SERVICE by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas.(Sabzevari, Arash)

Minute Entry for proceedings held before Judge J. P. Boulee: The Court held a discovery hearing on 9/11/20. The Court granted Plaintiffs request for an inspection to be performed at a time agreeable to the parties. The limitations proposed by Defendants in footnote 8 of the discovery statement are approved with the following exceptions: (1) the court will not appoint a court appointed expert; and (2) the authorized individuals who can attend the inspection are the four experts (two from each party), and two counsel for Plaintiffs and two counsel for Defendants. Plaintiffs request for production of documents is granted and Plaintiffs are entitled to documents from July 1, 2020, to the present assuming that a protective order is in place. No later than the close of business on Wednesday, September 16, 2020, Plaintiffs shall brief any issues associated with the protective order. Defendants shall respond regarding the protective order no later than close of business on Friday, September 18, 2020. (Court Reporter Penny Coudriet)(ddm)

NOTICE of TELECONFERENCE Hearing: Hearing set for 9/11/2020 at 2:00 PM EST before Judge J. P. Boulee. (bnw)

NOTICE Of Filing DEFENDANTS NOTICE OF FILING ADDITIONAL EVIDENCE IN OPPOSITION TO PLAINTIFFS MOTION FOR PRELIMINARY INJUNCTION by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas re [41] Response in Opposition to Motion, Plaintiffs Motion for Preliminary Injunction (Attachments: # (1) Exhibit Exhibit 1, # (2) Exhibit Exhibit 2, # (3) Exhibit Exhibit 3, # (4) Exhibit Exhibit 4, # (5) Exhibit Exhibit 5, # (6) Exhibit Exhibit 6, # (7) Exhibit Exhibit 7, # (8) Exhibit Exhibit 8, # (9) Exhibit Exhibit 9, # (10) Exhibit Exhibit 10, # (11) Exhibit Exhibit 11, # (12) Exhibit Exhibit 12, # (13) Exhibit Exhibit 13, # (14) Exhibit Exhibit 14, # (15) Exhibit Exhibit 15, # (16) Exhibit Exhibit 16, # (17) Exhibit Exhibit 17)(Sabzevari, Arash)

1 Exhibit Exhibit 1

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2 Exhibit Exhibit 2

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3 Exhibit Exhibit 3

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4 Exhibit Exhibit 4

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5 Exhibit Exhibit 5

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6 Exhibit Exhibit 6

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7 Exhibit Exhibit 7

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8 Exhibit Exhibit 8

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9 Exhibit Exhibit 9

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10 Exhibit Exhibit 10

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11 Exhibit Exhibit 11

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12 Exhibit Exhibit 12

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13 Exhibit Exhibit 13

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14 Exhibit Exhibit 14

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15 Exhibit Exhibit 15

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16 Exhibit Exhibit 16

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17 Exhibit Exhibit 17

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CERTIFICATE OF SERVICE by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas.(Sabzevari, Arash)

MOTION to Withdraw Robert W. Hunter as Attorneyby Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Attachments: # (1) Text of Proposed Order)(Hunter, Robert)

1 Text of Proposed Order

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RESPONSE re [47] Discovery Hearing,,,, Plaintiffs' Supplemental Memorandum of Law in Support of the Production of Certain Grievances and "Sick Call" Requests Related to COVID-19 filed by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Attachments: # (1) Exhibit A: Proposed Protective Order, # (2) Exhibit B: Protective Order - Barnett v. Tony, # (3) Exhibit C: CorrectHealth Contract)(Cutting, Jeremy)

1 Exhibit A: Proposed Protective Order

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2 Exhibit B: Protective Order - Barnett v. Tony

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3 Exhibit C: CorrectHealth Contract

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NON-FINAL REPORT AND RECOMMENDATION RECOMMENDING that Defendants' motion to dismiss (Doc. 23) be GRANTED IN PART and DENIED IN PART, Plaintiff Randolph Mitchel's individual claims be DISMISSED, the remaining Plaintiffs' claims of deliberate indifference be ALLOWED TO PROCEED, and the remaining Plaintiffs' remaining claims be DISMISSED. Signed by Magistrate Judge Christopher C. Bly on 9/16/20. (jtj)

ORDER for Service of [52] Non-Final Report and Recommendation, by Magistrate Judge Christopher C. Bly. Each party may file written objections to the Report & Recommendation within 14 days of service. If no objections are filed, the Report & Recommendation may be adopted as the opinion and order of the District Court. Signed by Magistrate Judge Christopher C. Bly on 9/16/20. (jtj)

ORDER granting 50 Motion to Withdraw as Attorney. Attorney Robert W. Hunter terminated. Signed by Judge J. P. Boulee on 9/16/20. (bnw)

ORDER advising the parties that, upon further consideration, the Court is satisfied that the filing fee has been paid in this case. Signed by Magistrate Judge Christopher C. Bly on 9/17/2020. (ddm)

RESPONSE re [47] Discovery Hearing,,,, DEFENDANTS RESPONSE TO PLAINTIFFS MEMORANDUM OF LAW FOR THE PRODUCTION OF COVID-19 RELATED GRIEVANCES AND SICK CALL REQUESTS filed by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas. (Sabzevari, Arash)

ORDER re [43] Consolidated/Joint Discovery Statement. This Court is not persuaded that individual medical releases are required. This Court is satisfied that Plaintiffs are entitled to the discovery of the sick call requests, medical requests and grievances filed in relation to COVID-19 and that a protective order should allay any concerns about patient privacy where, as here, a non-covered entity under the Health Insurance Portability and Accountability Act (HIPAA) is the one producing medical information. The Proposed HIPAA-Qualified Protective Order [Doc. 51-1] is APPROVED as if fully incorporated herein. Signed by Judge J. P. Boulee on 9/24/20. (jpa)

REPLY BRIEF re [19] MOTION for Preliminary Injunction filed by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Attachments: # (1) Exhibit A: Supplemental Declaration of Nina H. Fefferman, Ph.D, # (2) Exhibit B: Declarations of Thirteen Current or Recent Detainees, # (3) Exhibit C: Email from E. Smith, CorrectHealth, # (4) Exhibit D: Screenshots from Court Appearances, # (5) Exhibit E: Email from O. Adewale, Clayton County Health District)(Cutting, Jeremy)

1 Exhibit A: Supplemental Declaration of Nina H. Fefferman, Ph.D

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2 Exhibit B: Declarations of Thirteen Current or Recent Detainees

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3 Exhibit C: Email from E. Smith, CorrectHealth

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4 Exhibit D: Screenshots from Court Appearances

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5 Exhibit E: Email from O. Adewale, Clayton County Health District

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Submission of 19 MOTION for Preliminary Injunction, to District Judge J. P. Boulee. (ddm)

NOTICE of Appearance by Andres Martin Lopez-Delgado on behalf of Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins (Lopez-Delgado, Andres)

EIGHTH AMENDMENT TO GENERAL ORDER 20-01 RE: COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID19 AND RELATED CORONA VIRUS. Signed by Judge Thomas W. Thrash, Jr. on 09/28/2020. (adg) (ADI)

OBJECTIONS to [52] Report and Recommendation filed by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Lopez-Delgado, Andres)

CERTIFICATE OF SERVICE of Discovery Materials by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas.(Sabzevari, Arash)

MOTION to Withdraw Kosha Shonyetta Tucker as Attorneyby Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Attachments: # (1) Text of Proposed Order)(Tucker, Kosha)

1 Text of Proposed Order

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ORDER granting 62 Motion to Withdraw as Attorney. Attorney Kosha Shonyetta Tucker terminated. Signed by Judge J. P. Boulee on 10/2/20. (bnw)

Submission of the 52 REPORT AND RECOMMENDATION and 23 First MOTION to Dismiss to District Judge J. P. Boulee. (aaq)

Joint MOTION for Protective Order Regarding Photographs Taken During Jail Inspection by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins. (Attachments: # (1) Text of Proposed Order)(Primerano, Ryan)

1 Text of Proposed Order

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Consent MOTION for Extension of Time Respond to Plaintiff's Objections to Report and Recommendation by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas. (Attachments: # (1) Text of Proposed Order)(Sabzevari, Arash)

1 Text of Proposed Order

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ORDER: For good cause shown, the 64 Consent Motion for Extension of Time for Defendants to Respond to Plaintiffs' Objections is GRANTED. IT IS HEREBY ORDERED that Defendant shall respond to Plaintiffs' objections no later than October 21, 2020. Signed by Judge J. P. Boulee on 10/9/20. (bnw)

CERTIFICATE OF SERVICE by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas.(Sabzevari, Arash)

Petition for Leave of Absence for the following date(s): November 13 and 16 2020; November 20, 2020 through November 24, 2020; December 28, 2020 through January 4, 2021; January 15, 2021 through January 19, 2021; February 12, 2021 through February 22, 2021; April 2, 2021 through April 12, 2021; May 28, 2021 through June 1, 2021; July 2, 2021 through including July 5, 2021., by Arash A. Sabzevari. (Sabzevari, Arash)

CERTIFICATE OF SERVICE of Discovery Materials by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas.(Sabzevari, Arash)

Petition for Leave of Absence for the following date(s): October 23 and 24, 2020; November 2, 2020 through and including November 6, 2020, by Jack Reynolds Hancock. (Hancock, Jack)

RESPONSE re [60] Objections to Report and Recommendation filed by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas. (Sabzevari, Arash)

Submission of 63 Joint MOTION for Protective Order Regarding Photographs Taken During Jail Inspection, to Magistrate Judge Christopher C. Bly. (ddm)

ORDER granting [63] the parties' Joint Motion for Protective Order Regarding Photographs Taken During Jail Inspection. Signed by Judge J. P. Boulee on 10/27/2020. (ddm)

First Initial Disclosures by Rhonda Jones, Randolph Mitchell, Michael Singleton, Barry Watkins.(Cutting, Jeremy)

CERTIFICATE OF SERVICE of Discovery Materials by Roland Boehrer, Terrance Gibson, Victor Hill, Maurice Johnson, Kevin Thomas.(Sabzevari, Arash)

ORDER - The Non-Final Report and Recommendation [Doc. [52]] is ADOPTED as the order of this Court. For the reasons stated by the Magistrate Judge, Defendants' Motion to Dismiss [Doc. [23]] is GRANTED IN PART AND DENIED IN PART. Plaintiff Randolph Mitchell's individual claims are DISMISSED, the remaining Plaintiffs' claims of deliberate indifference are ALLOWED TO PROCEED, and the remaining Plaintiffs' remaining claims are DISMISSED. Signed by Judge J. P. Boulee on 11/19/2020. (tcc)

ORDER: In light of this Court's 73 Order, the First 25 Motion to Stay Discovery is DENIED AS MOOT. Signed by Judge J. P. Boulee on 11/19/20. (bnw)