Case: Woodcock v. Correct Care Solutions

Kentucky state trial court

U.S. Court of Appeals for the Sixth Circuit

Matthew J. Akiyama, MD, MSc; Tessa Bialek, JD; Raphael Simonson, BA

Tessa Bialek and Matthew J. Akiyama, M.D., M.Sc.

NOTICE OF REMOVAL from Franklin Circuit Court, case number 15-CI-63. ( Filing fee $400; receipt number 0643-3663482), filed by Correct Care Solutions, LLC. (Attachments: # 1 Civil Cover Sheet, # 2 State Court Record - Part 1 - 1st Amended Complaint, etc, # 3 State Court Record - Part 2, # 4 State Court Record - Part 3, # 5 State Court Record - Part 4)(AKR) (Entered: 12/08/2016)

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Add and Terminate Attorneys

Add and Terminate Parties

Attorney Update. Attorney Lainie Crouch Kaiser terminated per Notice of Substitution, NOR 1 -5, page ID 179. (CBD) Modified text on 12/9/2016 (CBD).

Amended Complaint

Party Update - Petitioner Ruben Rios Salinas, Respondent Kentucky Department of Corrections, Respondent LaDonna Thompson and Respondent Commonwealth of Kentucky added per Petition for Mandamus (NOR de 1 -5 of the SCR Part 4, page ID 181); and terminated per First Amended Complaint (NOR de 1 -2 of the SCR Part 1, page ID 7) (CBD)

Motion to Dismiss

FIRST AMENDED CLASS ACTION COMPLAINT against Rodney Ballard, Commonwealth of Kentucky, Correct Care Solutions, LLC, Doug Crall, MD, Cookie Crews, Frederick Kemen, MD, LaDonna Thompson, filed by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock. Filed at DE 1 -2 NOR as State Court Record Part 1, page ID 7.(CBD)

MOTION to Dismiss First Amended Complaint by Commonwealth of Kentucky. Filed at DE 1 -5 NOR as State Court Record Part 4, page ID 222. (CBD)

NOTICE OF DEFICIENCY RE: FAILURE TO FILE FRCP 7.1 DISCLOSURES to counsel of record, Megan O'Reilly. 1 Notice of Removal, has been filed by Correct Care Solutions, LLC without the required Rule 7.1 Disclosure statement. Rule 7.1 Disclosures must be filed within fourteen (14) calendar days. Failure to file the Disclosure Statement will cause the case to be submitted to the presiding judge for further action. cc: COR (AKR) (Entered: 12/08/2016)

FRCP 7.1 DISCLOSURE STATEMENT by Correct Care Solutions, LLC. (O'Reilly, Megan) (Entered: 12/08/2016)

NOTICE by Rodney Ballard, Doug Crall, MD, Cookie Crews, LaDonna Thompson Consent for Removal of State Court Action to U.S. District Court (Keeton, Linda) (Entered: 12/08/2016)

Conflict Check

Conflict Check run. (AKR)

Add and Terminate Attorneys

Attorney Update. Attorney Linda Marion Keeton for Doug Crall, MD added. (CBD)

NOTICE by Commonwealth of Kentucky to Consent to Removal (Payne, Taylor) (Entered: 12/09/2016)

NOTICE OF FILING by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock OF SUMMONS TO CORRECT CARE SOLUTIONS, LLC (Attachments: # 1 Summons)(Belzley, Gregory) (Entered: 12/12/2016)

Summons Issued as to Correct Care Solutions, LLC; Summons issued and returned to counsel electronically. (AKR) Modified correcting file date on 12/13/2016 (AKR). (Main Document 8 replaced on 12/13/2016) (CBD). (Entered: 12/13/2016)

NOTICE OF CLERICAL ERROR Re: PDF DOCUMENT: Error: INCORRECT document attached to docket entry by docket clerk; Incorrect issuance date on summons; re 8 Summons Issued ; Correct document attached to this entry. cc: COR (AKR) Modified file date on 12/13/2016 (CBD). (Entered: 12/13/2016)

RESPONSE to Motion re MOTION to Dismiss by Commonwealth of Kentucky filed by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock. (Attachments: # 1 Proposed Order)(Belzley, Gregory) (Entered: 12/29/2016)

Motion Submitted

***MOTION SUBMITTED TO CHAMBERS of Judge Van Tatenhove for review: re MOTION to Dismiss by Commonwealth of Kentucky - no objection by plaintiffs. (AKR)

ORDER: Plaintiffs' claims against Defendant Commonwealth of Kentucky are hereby dismissed without prejudice. Signed by Judge Gregory F. Van Tatenhove on 1/9/2017.(CBD)cc: COR Modified text on 1/9/2017 (AKR). (Entered: 01/09/2017)

File Submitted

***FILE SUBMITTED TO CHAMBERS of Judge Van Tatenhove for review re FRCP 4(m) as to Dr. Frederick Kemen, MD - Amended Complaint attached at DE 1 NOR as part of the State Court Record (CBD)

MOTION for Extension of Time by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock to Serve Defendant Frederick Kemen, MD With Summons (Attachments: # 1 Proposed Order)(Belzley, Gregory) (Entered: 03/16/2017)

Motion Submitted

***MOTION SUBMITTED TO CHAMBERS of Judge Van Tatenhove for review: re 12 MOTION for Extension of Time by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock to Serve Defendant Frederick Kemen, MD With Summons (CBD)

ORDER: Plaintiffs' motion for an extension of time 12 is GRANTED. Plaintiffs shall have an additional 30 days to effectuate service on Dr. Frederick Kemen. Signed by Judge Gregory F. VanTatenhove on 3/20/2017. (CBD)cc: COR (Entered: 03/20/2017)

NOTICE OF FILING by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock re 13 Order on Motion for Extension of Time OF PROOF OF SERVICE ON FREDERICK KEMEN, MD (Attachments: # 1 Exhibit Kemen proof of service)(Belzley, Gregory) (Entered: 03/27/2017)

MOTION for Entry of Default by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock (Attachments: # 1 Proposed Order)(Belzley, Gregory) (Entered: 03/27/2017)

Clerk's ENTRY OF DEFAULT as to Frederick Kemen, MD. cc: COR, attested copy mailed to Dr. Frederick Kemen, MD via US Mail (CBD) (Entered: 03/28/2017)

AGREED MOTION to Vacate 16 Clerk's Entry of Default by Frederick Kemen, MD (Attachments: # 1 Proposed Order)(O'Reilly, Megan) Modified text on 3/28/2017 (CBD). (Entered: 03/28/2017)

Motion Submitted

***MOTION SUBMITTED TO CHAMBERS of Judge Van Tatenhove for review: re 17 AGREED MOTION to Vacate 16 Clerk's Entry of Default (CBD) Modified text on 3/28/2017 (CBD).

ANSWER to Amended Complaint, by Correct Care Solutions, LLC.(O'Reilly, Megan) (Entered: 03/31/2017)

ANSWER to Amended Complaint, by Frederick Kemen, MD.(O'Reilly, Megan) (Entered: 03/31/2017)

File Submitted

***FILE SUBMITTED TO CHAMBERS of Judge Van Tatenhove for review & possible scheduling (CBD)

NOTICE by Correct Care Solutions, LLC Notice of Intent by Defendant to Obtain Inmate Medical Records Via SDT of Keath Bramblett (Attachments: # 1 Exhibit 1 - Subpoena for Medical Records)(O'Reilly, Megan) Modified text on 4/5/2017 (CBD). (Entered: 04/05/2017)

NOTICE by Correct Care Solutions, LLC Notice of Intent by Defendant to Obtain Inmate Grievance Records Via SDT of Keath Bramblett (Attachments: # 1 Exhibit 1 - Subpoena For Grievance Records)(O'Reilly, Megan) Modified text on 4/5/2017 (CBD). (Entered: 04/05/2017)

NOTICE by Correct Care Solutions, LLC Notice of Intent by Defendant to Obtain Inmate Medical Records Via SDT of Ruben Rios Salinas (Attachments: # 1 Exhibit 1 - Subpoena for Medical Records)(O'Reilly, Megan) Modified text on 4/5/2017 (CBD). (Entered: 04/05/2017)

NOTICE by Correct Care Solutions, LLC Notice of Intent by Defendant to Obtain Inmate Grievance Records Via SDT of Ruben Rios Salinas (Attachments: # 1 Exhibit 1 - Subpoena For Grievance Records)(O'Reilly, Megan) Modified text on 4/5/2017 (CBD). (Entered: 04/05/2017)

NOTICE by Correct Care Solutions, LLC Notice of Intent by Defendant to Obtain Inmate Medical Records Via SDT of Brian Woodcock (Attachments: # 1 Exhibit 1 - Subpoena for Medical Records)(O'Reilly, Megan) Modified text on 4/5/2017 (CBD). (Entered: 04/05/2017)

NOTICE by Correct Care Solutions, LLC Notice of Intent by Defendant to Obtain Inmate Grievance Records Via SDT of Brian Woodcock (Attachments: # 1 Exhibit 1 - Subpoena For Grievance Records)(O'Reilly, Megan) Modified text on 4/5/2017 (CBD). (Entered: 04/05/2017)

ORDER VACATING DEFAULT: Dr. Kemen's Mtn to Vacate the Entry of Default 17 against him is GRANTED. Dr. Kemen shall have until 4/5/17 in which to file responsive pleadings. Signed by Judge Gregory F. VanTatenhove on 4/5/2017.(AKR)cc: COR (Entered: 04/05/2017)

ORDER FOR MEETING AND REPORT: 1. No later than thirty (30) days from the date of entry and service of this order, counsel for the parties shall conduct the meeting of parties required by Rule 26(f). 2. At the time of the meeting, counsel for the parties shall exchange the disclosures required by Rule 26(a)(1) and, in the future, shall make supplemental disclosures when required by Rule 26(e). 3. No later than ten (10) days after the meeting, counsel for the parties shall file a written joint report outlining the proposed discovery plan. Signed by Judge Gregory F. VanTatenhove on 4/6/2017. (Attachments: # 1 Consent Form)(CBD)cc: COR (Entered: 04/06/2017)

NOTICE by Correct Care Solutions, LLC Notice of Intent by Defendant to Obtain Inmate Grievance Records Via SDT (Attachments: # 1 Exhibit 1 - Subpoena For Grievance Records)(O'Reilly, Megan) (Entered: 05/09/2017)

JOINT REPORT of Rule 26(f) Planning Meeting. (Belzley, Gregory) (Entered: 05/15/2017)

SCHEDULING ORDER: DISCOVERY Parties exchange initial Rule 26(a)(1) disclosures by 5/30/17. Plfs expert witness i.d. by 11/1/17. Dfts expert witness i.d. by 1/10/18. Discovery due by 4/1/2018. Plfs file their mtn for class certification by 11/1/17. DISPOSITIVE MOTIONS Motions to Join Add'l parties and to amended pleadings due from both parties by 8/1/2017. Dispositive Motions due by 6/1/2018. FINAL PRETRIAL CONFERENCE set for Tuesday, 9/4/2018 at 11:00 AM in Courtroom of US Courthouse in FRANKFORT, KY. Pretrial Filings due by 8/28/2018. JURY TRIAL set for Tuesday, 9/18/2018 at 10:00 AM in Courtroom of US Courthouse in FRANKFORT, KY, with counsel to arrive by 9:30 a.m. Case referred to Magistrate Judge Edward B. Atkins for purpose of discovery and pretrial proceedings. (SEE Order for completeness). Signed by Judge Gregory F. VanTatenhove on 5/16/2017.(AKR)cc: COR, diary (Entered: 05/16/2017)

File Submitted

***FILE SUBMITTED TO CHAMBERS of Judge Van Tatenhove for review: 29 Report of Rule 26(f) Planning Meeting. (AKR)

NOTICE by Correct Care Solutions, LLC Compliance (O'Reilly, Megan) (Entered: 05/30/2017)

NOTICE by Rodney Ballard, Doug Crall, MD, Cookie Crews, LaDonna Thompson Compliance (Keeton, Linda) (Entered: 05/30/2017)

MOTION to Intervene by Jessica Lawrence Motions referred to Edward B. Atkins. (Attachments: # 1 Exhibit A, Intervening Complaint, # 2 Summons James Erwin)(Bentley, Aaron) (Additional attachment(s) added on 8/21/2017: # 3 Proposed Order) (AKR). (Entered: 08/18/2017)

NOTICE OF FILING by Jessica Lawrence re 33 MOTION to Intervene by Jessica Lawrence (Attachments: # 1 Proposed Order)(Bentley, Aaron) (Entered: 08/18/2017)

Notice of Deficiency

NOTICE OF DEFICIENCY TO Aaron Bentley re 33 MOTION to Intervene by Jessica Lawrence; attorney failed to submit a proposed order as an electronic attachment to the motion. Entry by attorney; within 7 calendar days, prepare a document entitled "Notice of Filing" (with a certificate of service), file the Notice using the event "Notice of Filing," attach the proposed order, and create a link to the related docket entry. cc: COR (AKR)

ORDER: Jessica Lawrence's Motion to Intervene 33 is GRANTED. The Clerk of the Court is DIRECTED to file Lawrences Intervening Complaint [ 33 -1] in the record as of the date of entry of this Order. Signed by Judge Gregory F. VanTatenhove on 9/25/2017. (CBD)cc: COR (Entered: 09/25/2017)

Intervenor COMPLAINT, filed by Jessica Lawrence. Filed per Order 35 (CBD) Modified on 12/12/2018 (CBD). (Entered: 09/25/2017)

Summons Issued as to James Erwin; Summons issued and returned to counsel electronically (CBD) (Entered: 09/25/2017)

FIRST MOTION to Dismiss for failure to state a claim by Rodney Ballard, Rodney Ballard, Doug Crall, MD, Doug Crall, MD, Cookie Crews, Cookie Crews, James Erwin, LaDonna Thompson, LaDonna Thompson, LaDonna Thompson (Attachments: # 1 Proposed Order Proposed Order granting Motion to Dismiss for Plaintiff's Failure to State a Claim)(Keeton, Linda) (Entered: 10/26/2017)

MOTION for Extension of Time to Complete Discovery by Keath Bramblett, Jessica Lawrence, Ruben Rios Salinas, Brian Woodcock Motions referred to Edward B. Atkins. (Attachments: # 1 Exhibit Email re depositions, # 2 Exhibit Email forwarding discovery requests, # 3 Exhibit Email re status of responses to discovery requests, # 4 Proposed Order)(Belzley, Gregory) Modified removing term date on 11/8/2017 (AKR). (Entered: 10/31/2017)

ORDER: ON OR BEFORE WEDNESDAY, NOVEMBER 8, 2017, Defendants may respond to Plaintiffs' Motion 39 for 120-Day Extension of Deadlines. Signed by Magistrate Judge Edward B. Atkins on 11/1/2017. (CBD)cc: COR (Entered: 11/02/2017)

RESPONSE to 40, 38 to Plaintiff's Mtn for 120 Day Extension of Deadlines filed by Correct Care Solutions, LLC, Frederick Kemen, MD. (O'Reilly, Megan) (Entered: 11/07/2017)

Motion Submitted

***MOTION SUBMITTED TO CHAMBERS of Judge Atkins for review: re 39 MOTION for Extension of Time to Complete Discovery by Keath Bramblett, Jessica Lawrence, Ruben Rios Salinas, Brian Woodcock & 41 Response to Motion. (AKR)

NOTICE by Correct Care Solutions, LLC of Intent by Defendant to Obtain Medical Records Via Subpoena Duces Tecum (Attachments: # 1 Exhibit 1 - Subpoena Medical Records)(O'Reilly, Megan) (Entered: 11/09/2017)

MOTION to Stay re 38 FIRST MOTION to Dismiss for failure to state a claim by Rodney Ballard, Rodney Ballard, Doug Crall, MD, Doug Crall, MD, Cookie Crews, Cookie Crews, James Erwin, LaDonna Thompson, LaDonna Thompson, LaDonna Thompson by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock PENDING DISCOVERY Motions referred to Edward B. Atkins. (Attachments: # 1 Exhibit Emails re depositions, # 2 Exhibit Emails re discovery requests, # 3 Exhibit Discovery requests, # 4 Proposed Order)(Belzley, Gregory) (Entered: 11/11/2017)

ORDER: This matter comes before the Court on Plaintiffs' Motion for 120-Day Extension of Deadlines. [R. 39]. IT IS ORDERED AS FOLLOWS: 1. Plaintiffs will file their motion for class certification and identify their expert witness(es) by 3/1/2018. 2. Defendants will identify their expert witness by 5/1/2018 3. Discovery due by 8/1/2018. 4. Dispositive and Daubert Motions due by 10/1/2018. 5. FINAL PRETRIAL CONFERENCE set for 1/16/2019 at 10:00 AM in FRANKFORT, KY 6.-9. pretrial filings ddls 10. JURY TRIAL set for 1/28/2019 at 10:00 AM in FRANKFORT, KY with counsel to arrive by 9:30 AM. Signed by Judge Gregory F. VanTatenhove on 11/13/2017.(CBD)cc: COR, D (Entered: 11/13/2017)

MOTION for Entry of HIPPA Qualified Protective Order by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock Motions referred to Edward B. Atkins. (Attachments: # 1 Exhibit Defendants' responses to Plaintiffs' discovery requests, # 2 Proposed Order)(Belzley, Gregory) (Entered: 02/08/2018)

ORDER: that, on or before Friday, 2/23/2018, Dfts may file their response to Plfs' Mtn for Production of HIPAA-Protected Inmate Documents (R. 45 ). Signed by Magistrate Judge Edward B. Atkins on 2/9/2018.(AKR)cc: COR (Entered: 02/09/2018)

RESPONSE to Motion re 45 MOTION for Entry of HIPPA Qualified Protective Order by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock filed by Correct Care Solutions, LLC, CorrectCare Solutions, Inc.. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit)(O'Reilly, Megan) (Entered: 02/23/2018)

ORDER: On or before March 5, 2018, Plaintiffs may file their reply to Defendant Correct Care Solutions, LLC's Response to Plaintiffs' Mtn for Production of HIPAA-Protected Inmate Documents 47 . Signed by Magistrate Judge Edward B. Atkins on 2/26/2018.(AKR)cc: COR (Entered: 02/26/2018)

Notice of Docket Modification

NOTICE OF DOCKET MODIFICATION TO Megan O'Reilly re 47 Response to Motion; Error: attachments were insufficiently described as "Exhibit," "Exhibit." Entry by attorney; Correction: the Clerk renamed the attachments. Attachments must be adequately described. Example: Exhibit A (incorrect); Exhibit A Affidavit of John Doe (correct). No further action required by counsel. cc: COR (AKR)

MOTION to Certify Class by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock (Attachments: # 1 Exhibit KDOC HCV Plan, # 2 Exhibit FBOP Guidelines, # 3 Exhibit Current inmate count, # 4 Exhibit Order certifying class in Hoffer v. Jones, # 5 Proposed Order)(Belzley, Gregory) (Entered: 03/01/2018)

MOTION to Certify Class by Jessica Lawrence (Attachments: # 1 Proposed Order Granting Intervening Plaintiff's Motion)(Bentley, Aaron) (Entered: 03/01/2018)

MOTION to Vacate by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock Expert Deadlines (Attachments: # 1 Exhibit Emails re deposiition of Dr. Kemen, # 2 Exhibit Email forwarding first discovery requests, # 3 Exhibit Email re status of responses to discovery, # 4 Exhibit Email re status of responses to discovery, # 5 Exhibit CCS's responses to discovery, # 6 Exhibit Current KDOC HCV Plan, # 7 Exhibit FBOP Guidelines, # 8 Proposed Order)(Belzley, Gregory) (Entered: 03/01/2018)

ORDER: that ON OR BEFORE MONDAY, 3/12/2018, Dfts may file a resonse to Plfs' Mtn to Vacate Expert Dealines (R. 51 ). Signed by Magistrate Judge Edward B. Atkins on 3/2/2018.(AKR)cc: COR (Entered: 03/02/2018)

REPLY to Response to Motion re 45 MOTION for Entry of HIPPA Qualified Protective Order by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock filed by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock. (Attachments: # 1 Proposed Order)(Belzley, Gregory) (Entered: 03/03/2018)

ORDER: 1. Plaintiff's Motion to Stay [R. 43] is DENIED; and 2. The Plaintiffs are DIRECTED to file a Response to Defendants' Motion to Dismiss [R. 38] within twenty-one (21) days of the entry of this Order. Signed by Judge Gregory F. VanTatenhove on 3/5/2018.(AKR)cc: COR (Entered: 03/05/2018)

Motion Submitted

***MOTION SUBMITTED TO CHAMBERS of Judge Atkins for review: re 45 MOTION for Entry of HIPPA Qualified Protective Order by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock . (AKR)

Motion Submitted

***MOTION SUBMITTED TO CHAMBERS of Judge Atkins for review: re 45 MOTION for Entry of HIPPA Qualified Protective Order by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock . (AKR)

RESPONSE to Motion re 51 MOTION to Vacate by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock Expert Deadlines to Plaintiff's Motion to Extend Expert Discovery Deadlines filed by Correct Care Solutions, LLC, Frederick Kemen, MD. (O'Reilly, Megan) (Entered: 03/12/2018)

Motion Submitted

***MOTION SUBMITTED TO CHAMBERS of Judge Atkins for review: re 51 MOTION to Vacate by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock Expert Deadlines. (AKR)

ORDER: 1. Plaintiffs' Motion to Vacate Expert Deadlines [R. 51] is DENIED; 2. Plaintiffs shall have until May 1, 2018 to identify their expert witness (es); 3. Defendants shall have until July 2, 2018 to identify their expert witness (es); 4. Absent a showing of good cause, no further extensions will be granted; and 5. On April 2, 2018, May 1, 2018, June 1, 2018, and July 2, 2018, the Parties shall submit Joint Status Reports detailing their efforts to conduct discovery. Signed by Magistrate Judge Edward B. Atkins on 3/14/2018.(AKR)cc: COR (Entered: 03/14/2018)

NOTICE OF FILING by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock OF DEPOSITION OF FREDERICK KEMEN, MD (Attachments: # 1 Exhibit Kemen Deposition dated February 28, 2018)(Belzley, Gregory) Modified text on 3/20/2018 (CBD). (Entered: 03/19/2018)

MOTION for Extension of Time to File Response/Reply as to 49 MOTION to Certify Class by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock by Correct Care Solutions, LLC, Frederick Kemen, MD Motions referred to Edward B. Atkins. (Attachments: # 1 Proposed Order)(O'Reilly, Megan) (Entered: 03/21/2018)

RESPONSE to Motion re 58 MOTION for Extension of Time to File Response/Reply as to 49 MOTION to Certify Class by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock by Correct Care Solutions, LLC, Frederick Kemen, MD filed by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock. (Belzley, Gregory) (Entered: 03/21/2018)

ORDER: CCS and Dr. Kemen's Motion is GRANTED. CCS and Dr. Kemen shall have until March 30, 2018, in which to file a Response to Plfs' Mtn for Cert of Class for Injunctive Relief. Signed by Magistrate Judge Edward B. Atkins on 3/22/2018.(AKR)cc: COR (Entered: 03/22/2018)

Motion Submitted

***MOTION SUBMITTED TO CHAMBERS of Judge Van Tatenhove for review: re 58 MOTION for Extension of Time to File Response/Reply as to 49 MOTION to Certify Class by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock by Correct Care Solutions, LLC, Frederick Kemen, MD ; Response 59 no objection to motion. (AKR)

RESPONSE in Opposition re 38 FIRST MOTION to Dismiss for failure to state a claim by Rodney Ballard, Rodney Ballard, Doug Crall, MD, Doug Crall, MD, Cookie Crews, Cookie Crews, James Erwin, LaDonna Thompson, LaDonna Thompson, LaDonna Thompson filed by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock. (Attachments: # 1 Exhibit State Summons, # 2 Exhibit State Green Cards, # 3 Exhibit KDOC HCV Treatment Plan, # 4 Exhibit 9/8/17 email, # 5 Exhibit 10/27/17 email, # 6 Exhibit Email re April 2 depositions, # 7 Exhibit FBOP Guidelines, # 8 Exhibit Woodcock Grievance, # 9 Exhibit Response to Grievance, # 10 Exhibit Grievance Committee Decision, # 11 Exhibit Final Decision, # 12 Exhibit Hoffer order certifying class, # 13 Proposed Order)(Belzley, Gregory) (Entered: 03/26/2018)

RESPONSE to Motion re 38 FIRST MOTION to Dismiss for failure to state a claim by Rodney Ballard, Rodney Ballard, Doug Crall, MD, Doug Crall, MD, Cookie Crews, Cookie Crews, James Erwin, LaDonna Thompson, LaDonna Thompson, LaDonna Thompson filed by Jessica Lawrence. (Attachments: # 1 Exhibit A - Signed Green Card, # 2 Proposed Order Denying motion to dismiss)(Bentley, Aaron) (Entered: 03/26/2018)

RESPONSE to Motion re 49 MOTION to Certify Class by Keath Bramblett, Ruben Rios Salinas, Brian Woodcock filed by Correct Care Solutions, LLC, Frederick Kemen, MD. (Attachments: # 1 Exhibit EX A - Kemen condensed transcript)(O'Reilly, Megan) (Entered: 03/30/2018)