Case: Carter v. City of Montgomery

U.S. Department of Justice

Leslie Bailey

CLASS ACTION COMPLAINT against Branch D. Kloess, The City of Montgomery ( Filing fee $ 400.00 receipt number 4602037820.), filed by Aldaress Carter. (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 fee receipt)(djy, ) (Entered: 08/05/2015)

Jury Demand

DEMAND for Trial by Jury by Aldaress Carter. (NO PDF document attached to this notice-see Docket Entry 1 ). (djy, )

Corporate/Conflict Disclosure Statement by Aldaress Carter. (djy, ) (Entered: 08/05/2015)

Summons Issued as to Branch D. Kloess, The City of Montgomery and returned to counsel for personal service on defendant. (djy, ) (Entered: 08/05/2015)

SUMMONS Returned Executed by Aldaress Carter. The City of Montgomery served by process server on 8/3/2015 signed by Dennis Potter, answer due 8/24/2015. (djy, ) (Entered: 08/05/2015)

SUMMONS Returned Executed by Aldaress Carter. Branch D. Kloess served by process server on 8/3/2015 signed by Carol Kloess, answer due 8/24/2015. (djy, ) (Entered: 08/05/2015)

Case Assigned/Reassigned

Case reassigned to Honorable Judge Wallace Capel, Jr. Honorable Judge Charles S. Coody no longer assigned to the case as referral judge. (NO PDF Document attached to this notice). (djy, )

Case reassigned to Chief Judge William Keith Watkins. Honorable Judge W. Harold Albritton, III no longer assigned to the case as presiding judge. (djy, ) (Entered: 08/05/2015)

NOTICE of Appearance by Maurine C. Evans on behalf of Aldaress Carter (Evans, Maurine) (Entered: 08/10/2015)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by The City of Montgomery. (Holliday, Shannon) (Entered: 08/24/2015)

Add and Terminate Attorneys

MOTION Motion for a Briefing Schedule on 8 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by The City of Montgomery. (Holliday, Shannon) Modified on 8/25/2015 to clarify text to reflect as Motion for briefing schedule (qc/djy, ). (Entered: 08/24/2015)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Branch D. Kloess. (Jackson, Micheal) (Entered: 08/24/2015)

MOTION to Sever by Branch D. Kloess. (Jackson, Micheal) (Entered: 08/24/2015)

MOTION for the court to enter a briefing schedule re 10 MOTION TO DISMISS, and 11 MOTION to Sever by Branch D. Kloess. (Jackson, Micheal) Modified on 8/25/2015 to clarify text to reflect as a motion to enter briefing schedule (qc/djy, ). (Entered: 08/24/2015)

***Attorney Robert David Segall,Joel Thomas Caldwell for The City of Montgomery added pursuant to 8 motion to dismiss (NO PDF document attached to this notice). (djy, )

Notice of Deficiency requiring filing of Corporate Disclosure/Conflict Statement sent to The City of Montgomery; Corporate Disclosures due by 9/4/2015. (Attachments: # 1 standing order and format)(djy, ) (Entered: 08/25/2015)

Notice of Deficiency requiring filing of Corporate Disclosure/Conflict Statement sent to Branch D. Kloess; Corporate Disclosures due by 9/4/2015. (Attachments: # 1 standing order and format)(djy, ) (Entered: 08/25/2015)

Corporate/Conflict Disclosure Statement by The City of Montgomery re 13 Notice of Deficiency requiring filing of Corporate Disclosure/Conflict Statement. (Holliday, Shannon) (Entered: 08/25/2015)

Corporate/Conflict Disclosure Statement by Branch D. Kloess re 14 Notice of Deficiency requiring filing of Corporate Disclosure/Conflict Statement. (Jackson, Micheal) (Entered: 09/02/2015)

ORDER GRANTING City of Montgomery's 9 MOTION for a Briefing Schedule as follows: (1) that, on or before 10/1/2015 def City of Montgomery shall file a brief in support of its 8 motion to dismiss, (2) that, no later than 21 days after def's intial brief is filed, plf shall file a brief in response the def City of Montgomery's motion to dismiss; and (3) def City of Montgomery shall file a brief in reply to plf's brief no later than 14 days after plf's response brief is filed; FURTHER ORDERING that def Kloess's 12 MOTION for briefing schedule is GRANTED as follows: (1) that, on or before 10/1/2015, def Kloess shall file a single brief in support of his 10 motion to dismiss and 11 motion to sever; (2) that, no later than 21 days after def Kloess's initial brief is filed, plf shall file a brief in response to Kloess's motion to dismiss and motion to sever; and (3) def Kloess hsall file a brief in reply to plf's brief no later than 14 days after plf's response brief is filed, as further set out in order; for all future motions to dismiss, motions for judgment on the pleadings, motions for summary judgment, and Daubert motions filed in this case, setting briefing schedule, as further set out in order. Signed by Chief Judge William Keith Watkins on 9/4/15. (djy, ) (Entered: 09/04/2015)

AMENDED COMPLAINT FIRST AMENDED COMPLAINT against Judicial Correction Services, Inc., Correctional Healthcare Companies, Inc., CHC Companies, Inc., filed by Aldaress Carter. (Attachments: # 1 Supplement Part 2 of Amended Complaint, # 2 Supplement Park 3 of Amended Complaint)(Evans, George) (Entered: 09/14/2015)

Jury Demand

DEMAND for Trial by Jury by Aldaress Carter. (NO PDF Document attached to this notice-See Docket entry 18 ). (djy, )

Summons Issued as to CHC Companies, Inc., Judicial Correctional Services, Inc. and returned to counsel for personal service on the defendants. (djy, ) (Entered: 09/21/2015)

ORDER directing (1) the 8 MOTION TO DISMISS filed by The City of Montgomery is DENIED without prejudice to file a motion to dismiss in response to the amended complaint; (2) that def Kloess's 10 MOTION TO DISMISS is DENIED without prejudice to file a motion to dismiss in response to the amended complaint; (3) that def Kloess's 11 MOTION to Sever is DENIED without prejudice; and (4) that the briefing deadlines on def City of Montgomery's 8 motion to dismiss, def Kloess's 10 motion to dismiss, and def Kloess's 11 motion to sever, which were previously set by the Court's 17 order are CANCELLED; all other provisions of the 17 Order including all briefing requirements for future motions filed in this case, remain in effect. Signed by Chief Judge William Keith Watkins on 9/16/15. (djy, ) (Entered: 09/16/2015)

MOTION for Extension of Time to File Response/Reply as to 18 Amended Complaint, by The City of Montgomery. (Holliday, Shannon) (Entered: 09/16/2015)

Summons Issued as to Correctional Healthcare Companies, Inc. and mailed CMRRR with copy of amended complaint. (djy, ) (Entered: 09/17/2015)

TEXT ORDER GRANTING 20 MOTION for Extension of Time; EXTENDING time for The City of Montgomery to respond to the complaint to and including 10/15/2015. Signed by Chief Judge William Keith Watkins on 9/17/15. (NO PDF document attached to this notice).(djy, ) (Entered: 09/17/2015)

MOTION for Extension of Time to File Response/Reply as to 18 Amended Complaint, by Branch D. Kloess. (Jackson, Micheal) (Entered: 09/25/2015)

TEXT ORDER GRANTING 24 MOTION for Extension of Time to File Response; and extending the time for def Branch D. Kloess to respond to the amended complaint to and including 10/15/2015. Signed by Chief Judge William Keith Watkins on 9/28/15. (NO PDF Document attached to this notice).(djy, ) (Entered: 09/28/2015)

Return Receipt Card showing service of summons & amended complaint signed by (illegible) for Correctional Healthcare Companies, Inc. served on 9/21/2015, answer due 10/13/2015. (djy, ) (Entered: 09/29/2015)

SUMMONS Returned Executed by Aldaress Carter. Judicial Correctional Services, Inc. served on 9/24/2015, answer due 10/15/2015. (Evans, George) (Entered: 09/30/2015)

SUMMONS Returned Executed by Aldaress Carter. CHC Companies, Inc. served on 9/24/2015, answer due 10/15/2015. (Evans, George) (Entered: 09/30/2015)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Correctional Healthcare Companies, Inc., Judicial Correctional Services, Inc.. (Jackson, Michael) (Entered: 10/13/2015)

Add and Terminate Attorneys

MOTION for Briefing Schedule on Defendant Judicial Correction Services, Inc.'s and Correctional Healthcare Companies, Inc.'s Motion to Dismiss by Correctional Healthcare Companies, Inc., Judicial Correctional Services, Inc.. (Logsdon, Larry) (Entered: 10/13/2015)

***Attorney Wesley Kyle Winborn for Correctional Healthcare Companies, Inc.,Wesley Kyle Winborn for Judicial Correctional Services, Inc. added pursuant to 29 motion (NO PDF document attached to this notice). (djy, )

Corporate/Conflict Disclosure Statement by Correctional Healthcare Companies, Inc.. (Jackson, Michael) (Entered: 10/14/2015)

Corporate/Conflict Disclosure Statement by Judicial Correctional Services, Inc.. (Jackson, Michael) (Entered: 10/14/2015)

ORDER GRANTING 30 MOTION for Briefing Schedule as follows: (1) on or before 11/12/2015 defs Judicial Correction Services, Inc., and Correctional Healthcare Companies, Inc., shall file a brief in support of the 29 motion to dismiss; (2) no later than 21 days after defs' initial brief is file, plf shall file a brief in response to the 29 motion to dismiss; and (3) defs Judicial Correction Services, Inc., and Correctional Healthcare Companies, Inc., shall file a brief in reply to plf's brief no later than 14 days after plf's response brief is filed, as further set out in order; BRIEFING ORDER for all future motions to dismiss, motions for judgment on the pleadings, motions for summary judgment, and Daubert motions filed in this case, setting briefing scheduled as further set out in order. Signed by Chief Judge William Keith Watkins on 10/15/15. (djy, ) (Entered: 10/15/2015)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM [MOTION TO DISMISS FIRST AMENDED AND RESTATED COMPLAINT] by Branch D. Kloess. (Jackson, Micheal) (Entered: 10/15/2015)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by The City of Montgomery. (Holliday, Shannon) (Entered: 10/15/2015)

BRIEF/MEMORANDUM in Support re 35 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by The City of Montgomery. (Holliday, Shannon) (Entered: 10/15/2015)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by CHC Companies, Inc.. (Finch, Frederick) (Entered: 10/27/2015)

Add and Terminate Attorneys

Corporate/Conflict Disclosure Statement by CHC Companies, Inc.. (Finch, Frederick) (Entered: 10/27/2015)

***Attorney Brian C. Richardson for CHC Companies, Inc. added pursuant to 37 motion to dismiss (NO PDF Document attached to this notice). (djy, )

RESPONSE in Opposition re 34 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM [MOTION TO DISMISS FIRST AMENDED AND RESTATED COMPLAINT] PLAINTIFFS RESPONSE IN OPPOSITION TO KLOESS MOTION TO DISMISS FIRST AMENDED & RESTATED COMPLAINT filed by Aldaress Carter. (Evans, George) (Entered: 11/05/2015)

RESPONSE in Opposition re 35 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM Plaintiff's Responsive Brief in Opposition to the City of Montgomerys Motion to Dismiss filed by Aldaress Carter. (Evans, George) (Entered: 11/05/2015)

BRIEF/MEMORANDUM in Support re 29 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Correctional Healthcare Companies, Inc., Judicial Correctional Services, Inc.. (Jackson, Michael) (Entered: 11/12/2015)

REPLY BRIEF re 40 Response in Opposition to Motion City's Brief in Opposition to Carter's Response to the City's Brief in Support of Its Motion to Dismiss filed by The City of Montgomery. (Holliday, Shannon) (Entered: 11/12/2015)

(STRICKEN pursuant to 46 ORDER) BRIEF/MEMORANDUM in Support re 37 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by CHC Companies, Inc.. (Finch, Frederick) Modified on 11/24/2015 (qc/djy, ). (Entered: 11/17/2015)

Amended Document

MOTION to Strike 43 BRIEF/MEMORANDUM in Support MOTION TO STRIKE CHC COMPANIES, INC.S SUPPLEMENT TO MOTION TO DISMISS (DOC. 43) by Aldaress Carter. (Evans, George) (Entered: 11/17/2015)

RESPONSE in Opposition re 37 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM PLAINTIFFS RESPONSE IN OPPOSITION TO CHC COMPANIES, INC.S MOTION TO DISMISS FIRST AMENDED COMPLAINT filed by Aldaress Carter. (Evans, George) (Entered: 11/17/2015)

(STRICKEN pursuant to 46 ORDER) SUPPLEMENT to 37 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by CHC Companies, Inc.. (No pdf attached to this entry - See doc 43 for pdf) (wcl, ) Modified on 11/24/2015 (djy, ).

ORDER directing : (1) that the 44 MOTION to Strike is GRANTED; (2) that CHC's 43 supplemental brief is STRICKEN; (3) that, on or before 12/7/2015, def CHC shall file a motion for leave to file a supplement to its motion to dismiss and shall show cause why the motion for leave to file should be granted; and (4) pending the court's ruling on CHC's forthcoming motion for leave to file, the deadline for CHC to file a reply to plf's response brief is suspended, as further set out in order. Signed by Chief Judge William Keith Watkins on 11/24/15. (djy, ) (Entered: 11/24/2015)

MOTION for Leave to File a Supplement to Motion to Dismiss by CHC Companies, Inc.. (Finch, Frederick) (Entered: 11/25/2015)

RESPONSE in Opposition re 29 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM Plaintiffs Response in Opposition to Judicial Correction Services & Correctional Healthcare Companies, Inc.S Motion to Dismiss filed by Aldaress Carter. (Evans, George) (Entered: 12/03/2015)

ORDER granting 47 Motion for Leave to File a supplement to the motion to dismiss; further ORDERING: (1) that on or before 12/9/2015 def CHC shall file a supplemental motion to dismiss; (2) that, no later than 21 days after def CHC's supplemental motion is filed, plf shall file a brief in response to thesupplemental motion; and (3) that, within 7 days of the filing of plf's response to the supplemental motion, def CHC may file a single reply to both of plfs' briefs, as further set out in order. Signed by Chief Judge William Keith Watkins on 12/7/15. (djy, ) (Entered: 12/07/2015)

REPLY BRIEF re 29 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM, 41 BRIEF/MEMORANDUM in Support filed by Correctional Healthcare Companies, Inc., Judicial Correctional Services, Inc.. (Jackson, Michael) (Entered: 12/17/2015)

ORDERED that, on or before 12/29/2015, Dft CHC may file a reply to Plf's 45 response to Dft CHC's 37 motion to dismiss. Signed by Chief Judge William Keith Watkins on 12/21/2015. (wcl, ) (Entered: 12/21/2015)

REPLY to plf's 45 Response to 37 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by CHC Companies, Inc. (Finch, Frederick) Modified on 12/30/2015 to clarify text to reflect as a REPLY to 45 response (qc/djy, ). (Entered: 12/29/2015)

MOTION to Stay Discovery and Incorporated Brief in Support by CHC Companies, Inc.. (Finch, Frederick) (Entered: 01/05/2016)

MOTION to Stay Discovery by Correctional Healthcare Companies, Inc., Judicial Correctional Services, Inc.. (Jackson, Michael) (Entered: 01/06/2016)

ORDER directing that on or before 1/15/2016, plf and all other defs shall file responses to the 53 and 54 MOTIONS to Stay Discovery. Signed by Chief Judge William Keith Watkins on 1/7/16. (djy, ) (Entered: 01/07/2016)

MOTION to Stay re 53 MOTION to Stay Discovery and Incorporated Brief in Support by The City of Montgomery. (Holliday, Shannon) (Entered: 01/07/2016)

CONSOLIDATED RESPONSE in Opposition re 54 MOTION to Stay Discovery, 56 MOTION to Stay re 53 MOTION to Stay Discovery and Incorporated Brief in Support, 53 MOTION to Stay Discovery and Incorporated Brief in Support Plaintiffs Consolidated Response in Opposition to Defendants Motions to Stay Discovery filed by Aldaress Carter. (Evans, George) Modified on 1/13/2016 to clarify text to reflect as CONSOLIDATED RESPONSE (qc/djy, ). (Entered: 01/12/2016)

RESPONSE to Motion re 54 MOTION to Stay Discovery, 53 MOTION to Stay Discovery and Incorporated Brief in Support filed by The City of Montgomery. (Holliday, Shannon) (Entered: 01/15/2016)

RESPONSE to Motion re 54 MOTION to Stay Discovery, 56 MOTION to Stay re 53 MOTION to Stay Discovery and Incorporated Brief in Support, 53 MOTION to Stay Discovery and Incorporated Brief in Support [DEFENDANT BRANCH D. KLOESS'S RESPONSE TO MOTIONS TO STAY] filed by Branch D. Kloess. (Jackson, Micheal) (Entered: 01/15/2016)

NOTICE of Additional Authority in support of defendant's 56 MOTION to Stay re 53 MOTION to Stay Discovery and Incorporated Brief in Support by The City of Montgomery. (Attachments: # 1 Exhibit, # 2 Exhibit)(Holliday, Shannon) Modified on 2/10/2016 to clarify text to reflect as a NOTICE not a MOTION document (qc/djy, ). (Entered: 02/09/2016)

ORDER (1) STAYING CASE, including all discovery, until further order; (2) the 53] MOTION to Stay discovery filed by def CHC Companies, Inc. is GRANTED; (2) the 54 MOTION to Stay filed by defs Correctional Healthcare Companies, Inc., and Judicial Correctional Services, Inc. is GRANTED; (4) the 56 motion to stay discovery filed by Def City of Montgomery is GRANTED, as further set out in order. Signed by Chief Judge William Keith Watkins on 5/2/16. (djy, ) (Entered: 05/02/2016)

Case reassigned to Honorable Judge Royce C. Lamberth. Chief Judge William Keith Watkins no longer assigned to the case as presiding judge. (djy, ) (Main Document 62 replaced on 7/22/2016 to correct erroneous main PDF document ) (qc/djy, ). (Entered: 06/15/2016)

ORDER Setting Motion Hearing re: 29, 34, 35, and 37 MOTIONS TO DISMISS for 8/18/2016 @ 10:00 AM before Honorable Judge Royce C. Lamberth, in Courtroom 2F ; advising counsel that the Court shall also be hearing similar motions in cases, as further set out in order; the cases shall be heard in the order in which they were filed; counsel should be present for all hearings. Signed by Honorable Judge Royce C. Lamberth on 7/20/16. Furnished to calendar group & AR.(djy, ) (Entered: 07/20/2016)

MOTION to Continue Hearing by The City of Montgomery. (Holliday, Shannon) (Entered: 07/22/2016)

NOTICE of Correction re 62 Case Assigned to correct erroneous main PDF document previously attached (Attachments: # 1 corrected main document to Docket Entry 62 )(djy, ) (Entered: 07/22/2016)

ORDER GRANTING 64 MOTION to Continue; and the Hearing re: 29, 34, 35, & 37 MOTIONS TO DISMISS is rescheduled for 8/18/2016 @ 01:00 PM in Courtroom 2F before Honorable Judge Royce C. Lamberth.. Signed by Honorable Judge Royce C. Lamberth on 8/11/16. Furnished to calendar group & AR (previously set for 8/18/2016 @ 10 am).(djy, ) (Entered: 08/11/2016)

NOTICE of Appearance by Wilson F. Green on behalf of Correctional Healthcare Companies, Inc., Judicial Correctional Services, Inc. (Green, Wilson) (Entered: 08/17/2016)

Minute Entry for proceedings held before Honorable Judge Royce C. Lamberth: Motion Hearing held on 8/18/2016 re 29 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Correctional Healthcare Companies, Inc., Judicial Correctional Services, Inc., 37 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by CHC Companies, Inc., 34 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM [MOTION TO DISMISS FIRST AMENDED AND RESTATED COMPLAINT] filed by Branch D. Kloess, 35 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by The City of Montgomery (PDF available for court use only). (Court Reporter Patricia G. Starkie.) (war, ) (Entered: 08/19/2016)

MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT TO DECLARE THE CITY OF MONTGOMERYS PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL PROTECTION by Aldaress Carter. (Evans, George) (Entered: 09/21/2016)

BRIEF/MEMORANDUM in Support re 69 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT TO DECLARE THE CITY OF MONTGOMERYS PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL PROTECTION filed by Aldaress Carter. (Evans, George) (Entered: 09/21/2016)

MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT DECLARING THE CONTRACT BETWEEN JCS & MONTGOMERY VOID AB INITIO by Aldaress Carter. (Evans, George) (Entered: 09/21/2016)

BRIEF/MEMORANDUM in Support re 71 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT DECLARING THE CONTRACT BETWEEN JCS & MONTGOMERY VOID AB INITIO filed by Aldaress Carter. (Evans, George) (Entered: 09/21/2016)

Evidentiary Submission re 69 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT TO DECLARE THE CITY OF MONTGOMERYS PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL PROTECTION, 70 BRIEF/MEMORANDUM in Support, 71 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT DECLARING THE CONTRACT BETWEEN JCS & MONTGOMERY VOID AB INITIO, 72 BRIEF/MEMORANDUM in Support filed by Aldaress Carter. (Attachments: # 1 Exhibit 1 - 4/1/14 Deposition of Kenneth Nixon and exhibits, # 2 Exhibit 2 - 4/29/14 Deposition of Les Hayes, # 3 Exhibit 3 - 6/20/14 Deposition of Colleen Ray and exhibits Part 1, # 4 Exhibit 3 - 6/20/14 Deposition of Colleen Ray Part 2, # 5 Exhibit 3 - 6/20/14 Deposition of Colleen Rayand exhibits and exhibits Part 3, # 6 Exhibit 3 - 6/20/14 Deposition of Colleen Rayand exhibits Part 4, # 7 Exhibit 3 - 6/20/14 Deposition of Colleen Ray and exhibits Part 5, # 8 Exhibit 4 - 4/14/15 Deposition of Colleen Ray and exhibits, # 9 Exhibit 5 - 6/25/14 Deposition of Lisha Kidd and exhibits Part 1, # 10 Exhibit 5 - 6/25/14 Deposition of Lisha Kidd Part 2, # 11 Exhibit 5 - 6/25/14 Deposition of Lisha Kidd and exhibits Part 3, # 12 Exhibit 6 - 4/20/15 Deposition of Lisha Kidd and Exhibits Part 1, # 13 Exhibit 6 - 4/20/15 Deposition of Lisha Kidd and exhibits Part 2, # 14 Exhibit 7 - 9/1/15 Deposition of Lisha Kidd and exhibits Part 1, # 15 Exhibit 7 - 9/1/15 Deposition of Lisha Kidd Part 2, # 16 Exhibit 8 - 9/12/16 Deposition of Don Houston, # 17 Exhibit 9 - JCS' Probation Order for Mr. Carter, # 18 Exhibit 10 - Petition for Revocation, # 19 Exhibit 11 - Email from Colleen Ray to Karen LLoyd, # 20 Exhibit 12 - Montomgery Municipal Code, # 21 SEALED- Exhibit 13 - Agreement and Plan of Merger filed under seal, # 22 Exhibit 14 - JCS Marketing Materials)(Evans, George) (Attachment 21 replaced on 9/23/2016 to add SEALED EXHIBIT 13-RETURNED TO PLF COUNSEL AND NOT PUBLICLY AVAILABLE ON PACER PURSUANT TO 132 ORDER) (qc/djy, ). (Entered: 09/22/2016)

MOTION for leave to file exhibit under Seal by Aldaress Carter. (Attachments: # 1 Exhibit 13-RETURNED TO PLF COUNSEL AND NOT PUBLICLY AVAILABLE ON PACER PURSUANT TO 132 ORDER)(djy, ) Modified on 8/17/2017 (qc/djy, ). (Entered: 09/23/2016)

MOTION to Strike 69 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT TO DECLARE THE CITY OF MONTGOMERYS PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL PROTECTION, 71 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT DECLARING THE CONTRACT BETWEEN JCS & MONTGOMERY VOID AB INITIO by Correctional Healthcare Companies, Inc., Judicial Correctional Services, Inc.. (Jackson, Michael) (Entered: 09/26/2016)

MOTION to Strike 73 Evidentiary Submission,,,,,,,, 69 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT TO DECLARE THE CITY OF MONTGOMERYS PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL PROTECTION, 70 BRIEF/MEMORANDUM in Support, 72 BRIEF/MEMORANDUM in Support, 71 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT DECLARING THE CONTRACT BETWEEN JCS & MONTGOMERY VOID AB INITIO by The City of Montgomery. (Holliday, Shannon) (Entered: 09/26/2016)

RESPONSE to Motion re 76 MOTION to Strike 73 Evidentiary Submission,,,,,,,, 69 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT TO DECLARE THE CITY OF MONTGOMERYS PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL, 75 MOTION to Strike 69 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT TO DECLARE THE CITY OF MONTGOMERYS PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL PROTECTION, 71 MOTION for Pa filed by Aldaress Carter. (Evans, George) (Entered: 09/28/2016)

MOTION for Extension of Time to File Response/Reply as to 69 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT TO DECLARE THE CITY OF MONTGOMERYS PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL PROTECTION, 71 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT DECLARING THE CONTRACT BETWEEN JCS & MONTGOMERY VOID AB INITIO (Unopposed) by Correctional Healthcare Companies, Inc., Judicial Correctional Services, Inc.. (Jackson, Michael) (Entered: 10/06/2016)

RESPONSE in Opposition re 71 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT DECLARING THE CONTRACT BETWEEN JCS & MONTGOMERY VOID AB INITIO filed by CHC Companies, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, Part I, # 3 Exhibit B, Part II, # 4 Exhibit C, # 5 Exhibit D)(Finch, Frederick) (Additional attachment(s) added on 10/27/2016: # 6 REDACTED Exhibit B, Part I) (djy, ). (Entered: 10/12/2016)

[SEE CORRECTED DOCKET ENTRY DOC. 81 .] RESPONSE in Opposition re 69 MOTION for Partial Summary Judgment TO DECLARE THE CITY OF MONTGOMERY'S PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL PROTECTION filed by Judicial Correctional Services, Inc. (Jackson, Michael) Modified on 10/14/2016 to reflect that Doc. 81 replaces Doc. 80 . (dmn, ) (Entered: 10/12/2016)

RESPONSE (Correcting Doc. 80 ) in Opposition re 69 MOTION for Partial Summary Judgment TO DECLARE THE CITY OF MONTGOMERY'S PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL PROTECTION filed by Judicial Correctional Services, Inc. (Jackson, Michael) Modified on 10/14/2016 to reflect that this document is correcting Doc. 80 . (dmn, ) (Entered: 10/12/2016)

Evidentiary Submission in Support of JCS's Responses in Opposition to Plaintiff's Motions for Partial Summary Judgment (Docs. 69, 70, 71, & 72 ) filed by Judicial Correctional Services, Inc.. (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)(Jackson, Michael) Modified on 10/14/2016 to create links to additional documents. (dmn, ) (Entered: 10/12/2016)

RESPONSE in Opposition to Plaintiff's MOTION for Partial Summary Judgment DECLARING THE CONTRACT BETWEEN JCS & MONTGOMERY VOID AB INITIO (Docs. 71 & 72 ) filed by Judicial Correctional Services, Inc. (Jackson, Michael) Modified on 10/14/2016 to clean up text. (dmn, ) (Entered: 10/12/2016)

RESPONSE in Opposition to PLAINTIFFS 69 MOTION FOR PARTIAL SUMMARY JUDGMENT TO DECLARE THE CITY OF MONTGOMERYS PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL PROTECTION, 71 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT DECLARING THE CONTRACT BETWEEN JCS & MONTGOMERY VOID AB INITIO AND MEMORANDA IN SUPPORT (Docs. 70 and 72 ) filed by The City of Montgomery. (Holliday, Shannon) Modified on 10/20/2016 to create actual links to Docs. 70 & 72. (dmn, ) (Entered: 10/12/2016)

MOTION for Leave to File CORRECTED RESPONSE IN OPPOSITION TO PLAINTIFF'S MOTIONS FOR SUMMARY JUDGMENT AND MEMORANDA IN SUPPORT THEREOF (Docs. 69, 70, 71, 72 ) by The City of Montgomery. (Attachments: # 1 Exhibit 1)(Holliday, Shannon) Modified on 10/20/2016 to create links to Docs. 69-72. (dmn, ) (Entered: 10/19/2016)

NOTICE of Filing Supplemental Support (Affidavit) in further support of Opposition to Plaintiff's Motions for Partial Summary Judgment (Docs. 69 & 71 ) by The City of Montgomery re 84 Opposition (Attachments: # 1 Affidavit)(Holliday, Shannon) Modified on 10/20/2016 to create links to Docs. 69 & 71. (dmn, ) (Entered: 10/19/2016)