Case: Dunn v. Cuyahoga County

Adam Ferrise

Class Action Complaint with jury demand against All Defendants. Filing fee paid $ 402, Receipt number AOHNDC-11857802. Filed by Alanna Dunn. (Attachments: # 1 Civil Cover Sheet, # 2 Summons). (Legando, Drew) (Entered: 02/23/2023)

Judge Bridget Meehan Brennan assigned to case. (L,MI)

Random Assignment of Magistrate Judge pursuant to Local Rule 3.1. In the event of a referral, case will be assigned to Magistrate Judge Jonathan D. Greenberg. (L,MI)

Original Summons and Magistrate Consent Form issued to counsel for service upon Cuyahoga County. (Attachments: # 1 Magistrate Consent Form). (L,MI) (Entered: 02/24/2023)

Initial Standing Order. Judge Bridget Meehan Brennan on 2/24/2023. (L,MI) (Entered: 02/24/2023)

Motion for attorney Akeeb Dami Animashaun to Appear Pro Hac Vice. Filing fee $ 120, receipt number AOHNDC-11864034, filed by Plaintiff Alanna Dunn. (Attachments: # 1 Affidavit)(Legando, Drew) (Entered: 02/28/2023)

Motion for attorney Lucy B. Bansal to Appear Pro Hac Vice. Filing fee $ 120, receipt number AOHNDC-11864043, filed by Plaintiff Alanna Dunn. (Attachments: # 1 Affidavit)(Legando, Drew) (Entered: 02/28/2023)

Motion for attorney Kate Schwartz to Appear Pro Hac Vice. Filing fee $ 120, receipt number AOHNDC-11864048, filed by Plaintiff Alanna Dunn. (Attachments: # 1 Affidavit)(Legando, Drew) (Entered: 02/28/2023)

Motion for attorney Emily R. Brown to Appear Pro Hac Vice. Filing fee $ 120, receipt number AOHNDC-11864055, filed by Plaintiff Alanna Dunn. (Attachments: # 1 Affidavit)(Legando, Drew) (Entered: 02/28/2023)

Motion for attorney Janet Herold to Appear Pro Hac Vice. Filing fee $ 120, receipt number AOHNDC-11864063, filed by Plaintiff Alanna Dunn. (Attachments: # 1 Affidavit)(Legando, Drew) (Entered: 02/28/2023)

Motion for attorney Caryn C. Lederer to Appear Pro Hac Vice. Filing fee $ 120, receipt number AOHNDC-11864082, filed by Plaintiff Alanna Dunn. (Attachments: # 1 Affidavit)(Legando, Drew) (Entered: 02/28/2023)

1 Affidavit

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Supplement to Motion for attorney Akeeb Dami Animashaun to Appear Pro Hac Vice. Filing fee $ 120, receipt number AOHNDC-11864034, - Animashaun Declaration (Original Signature), filed by Alanna Dunn. Related document(s) 4 . (Legando, Drew) (Entered: 03/06/2023)

Supplement to Motion for attorney Emily R. Brown to Appear Pro Hac Vice. Filing fee $ 120, receipt number AOHNDC-11864055, - Brown Declaration (Original Signature), filed by Alanna Dunn. Related document(s) 7 . (Legando, Drew) (Entered: 03/06/2023)

Supplement to Motion for attorney Lucy B. Bansal to Appear Pro Hac Vice. Filing fee $ 120, receipt number AOHNDC-11864043, - Bansal Declaration (Original Signature), filed by All Plaintiffs. Related document(s) 5 . (Legando, Drew) (Entered: 03/06/2023)

Supplement to Motion for attorney Janet Herold to Appear Pro Hac Vice. Filing fee $ 120, receipt number AOHNDC-11864063, - Herold Declaration (Original Signature), filed by All Plaintiffs. Related document(s) 8 . (Legando, Drew) (Entered: 03/06/2023)

Supplement to Motion for attorney Caryn C. Lederer to Appear Pro Hac Vice. Filing fee $ 120, receipt number AOHNDC-11864082, - Lederer Declaration (Original Signature), filed by Alanna Dunn. Related document(s) 9 . (Legando, Drew) (Entered: 03/06/2023)

Supplement to Motion for attorney Kate Schwartz to Appear Pro Hac Vice. Filing fee $ 120, receipt number AOHNDC-11864048, - Schwartz Declaration (Original Signature), filed by All Plaintiffs. Related document(s) 6 . (Legando, Drew) (Entered: 03/06/2023)

Order on Motion to appear pro hac vice

Order [non-document] granting Attorney Akeeb Dami Animashaun's motion for appearance pro hac vice. (Doc. No. 4 .) Local Rule 5.1(c) requires that attorneys register for NextGen CM/ECF and file and receive all documents electronically. NextGen CM/ECF registration can be done online at www.pacer.gov. Login with your PACER credentials, go to the Maintenance tab, click Attorney Admissions/E-File Registration, select Ohio Northern District Court and then select Pro Hac Vice. If you were previously granted pro hac vice status and are already registered to file electronically, it is not necessary to register again. Judge Bridget Meehan Brennan on 3/7/2023. (H,AR)

Order [non-document] granting Attorney Lucy B. Bansal's motion for appearance pro hac vice. (Doc. No. 5 .) Local Rule 5.1(c) requires that attorneys register for NextGen CM/ECF and file and receive all documents electronically. NextGen CM/ECF registration can be done online at www.pacer.gov. Login with your PACER credentials, go to the Maintenance tab, click Attorney Admissions/E-File Registration, select Ohio Northern District Court and then select Pro Hac Vice. If you were previously granted pro hac vice status and are already registered to file electronically, it is not necessary to register again. Judge Bridget Meehan Brennan on 3/7/2023. (H,AR)

Order [non-document] granting Attorney Kate Schwartz's motion for appearance pro hac vice. (Doc. No. 6 .) Local Rule 5.1(c) requires that attorneys register for NextGen CM/ECF and file and receive all documents electronically. NextGen CM/ECF registration can be done online at www.pacer.gov. Login with your PACER credentials, go to the Maintenance tab, click Attorney Admissions/E-File Registration, select Ohio Northern District Court and then select Pro Hac Vice. If you were previously granted pro hac vice status and are already registered to file electronically, it is not necessary to register again. Judge Bridget Meehan Brennan on 3/7/2023. (H,AR)

Order [non-document] granting Attorney Emily R. Brown's motion for appearance pro hac vice. (Doc. No. 7 .) Local Rule 5.1(c) requires that attorneys register for NextGen CM/ECF and file and receive all documents electronically. NextGen CM/ECF registration can be done online at www.pacer.gov. Login with your PACER credentials, go to the Maintenance tab, click Attorney Admissions/E-File Registration, select Ohio Northern District Court and then select Pro Hac Vice. If you were previously granted pro hac vice status and are already registered to file electronically, it is not necessary to register again. Judge Bridget Meehan Brennan on 3/7/2023. (H,AR)

Order [non-document] granting Attorney Janet Herold's motion for appearance pro hac vice. (Doc. No. 8 .) Local Rule 5.1(c) requires that attorneys register for NextGen CM/ECF and file and receive all documents electronically. NextGen CM/ECF registration can be done online at www.pacer.gov. Login with your PACER credentials, go to the Maintenance tab, click Attorney Admissions/E-File Registration, select Ohio Northern District Court and then select Pro Hac Vice. If you were previously granted pro hac vice status and are already registered to file electronically, it is not necessary to register again. Judge Bridget Meehan Brennan on 3/7/2023. (H,AR)

Order [non-document] granting Attorney Caryn C. Lederer's motion for appearance pro hac vice. (Doc. No. 9 .) Local Rule 5.1(c) requires that attorneys register for NextGen CM/ECF and file and receive all documents electronically. NextGen CM/ECF registration can be done online at www.pacer.gov. Login with your PACER credentials, go to the Maintenance tab, click Attorney Admissions/E-File Registration, select Ohio Northern District Court and then select Pro Hac Vice. If you were previously granted pro hac vice status and are already registered to file electronically, it is not necessary to register again. Judge Bridget Meehan Brennan on 3/7/2023. (H,AR)

Waiver of Service Returned Executed by Alanna Dunn. Cuyahoga County waiver sent on 3/8/2023, answer due 5/7/2023 filed on behalf of Alanna Dunn (Legando, Drew) (Entered: 03/08/2023)

Answer to 1 Complaint with Jury Demand filed by Cuyahoga County. (Healy, Brendan) (Entered: 05/08/2023)

Case Management Conference Scheduling Order signed by Judge Bridget Meehan Brennan on 5/9/2023. A telephonic Case Management Conference is set for 6/27/2023 at 9:00 a.m. The Court will host the conference call and inform counsel by way of email of the telephone number for the conference. The parties shall dial into the Court's bridge line at least five minutes prior to the scheduled hearing time. (Attachments: # 1 Report of Parties' Planning Meeting, # 2 Letter from Chief Judge Gaughan, # 3 Magistrate Consent Form, # 4 Standard for Discovery of Electronically Stored Information, # 5 Rule 30.1) (H,AR) (Entered: 05/09/2023)

Report of Parties' Planning Meeting - parties do not consent to this case being assigned to the magistrate judge, filed by All Plaintiffs. (Legando, Drew) (Entered: 06/13/2023)

Preliminary Estimate/Budget of Amount of Fees and Expenses filed by All Plaintiffs. (Legando, Drew) (Entered: 06/26/2023)

Minute Order _ Case Management Conference

Minute Order [non-document]: A telephonic Case Management Conference was held on 6/27/2023 before Judge Bridget Meehan Brennan. Attorneys Akeeb Animashaun, Caryn Lederer, and Drew Legando participated on behalf of Plaintiff. Attorney Brendan Healy participated on behalf of Defendant Cuyahoga County. Counsel for both parties represented that initial disclosures have been exchanged. Counsel discussed the scope of discovery, including records not in the County's custody or control. The Court ORDERED the County to send a preservation request to all entities that used the Cuyahoga County Jail to detain or incarcerate individuals on their behalf, with the request specifically requesting the preservation of all records related to any individuals that were placed (or ordered to be placed) in the custody of the Cuyahoga County Jail between March or May 2019 to present. The Court adopted the parties' e-discovery plan and established deadlines as stated in the Court's Case Management Order. Judge Bridget Meehan Brennan on 6/27/2023. (Court Reporter: none) Time: 45 minutes. (H,AR)

Case Management Conference Order: The parties are instructed to review the attached Order in its entirety. Case is assigned to the standard track, and deadlines have been established. Amend pleadings/joinder of parties: 10/5/2023; non-expert discovery: 2/2/2024; Plaintiff's statement identifying experts and general nature of testimony: 2/2/2024; expert reports for party bearing the burden of proof: 3/1/2024; responsive expert reports: 4/2/2024; expert discovery: 5/2/2024; dispositive motions: 6/5/2024; and class certification motion: 6/5/2024. A telephonic Status Conference is set for 10/27/2023, at 10:00 a.m. The Court will host the conference call and inform the parties by way of email of the telephone number for the conference. The parties shall dial into the Court's bridge line at least five minutes prior to the hearing. Judge Bridget Meehan Brennan on 6/27/2023. (H,AR) (Entered: 06/27/2023)

Status Report RE: RETENTION AGREEMENT filed by Alanna Dunn. (Animashaun, Akeeb) (Entered: 07/27/2023)

Joint Proposed Stipulation for Electronic Discovery filed by Cuyahoga County. (Healy, Brendan) (Entered: 08/09/2023)

Notice of Withdrawal of Lucy B. Bansal as Counsel for Plaintiff filed by All Plaintiffs. (Legando, Drew) (Entered: 10/05/2023)

Order

Order [non-document] adopting the parties' Electronic Discovery Stipulation. (Doc. No. 23 .) Judge Bridget Meehan Brennan on 10/5/2023. (H,AR)

Joint Status Report filed by Alanna Dunn. (Attachments: # 1 Exhibit Pl's ESI Letter)(Animashaun, Akeeb) (Entered: 10/23/2023)

Minutes of proceedings [non-document] before Judge Bridget Meehan Brennan. A telephonic status conference was held on 10/27/2023. Attorneys Akeeb Animashaun and Kate Schwartz participated on behalf of Plaintiff. Attorneys Brendan Healy and Jake Elliott participated on behalf of Defendant. The Court discussed the parties' joint status report (Doc. No. 25 ) with counsel. The Court expressed its appreciation for the parties' diligence and cooperation in discovery. A telephonic status conference with lead counsel is set for 1/5/2024 at 12:00 p.m. At the conference, counsel should be prepared to discuss the parties' preferred ADR method, outstanding discovery, and any requests for reasonable deadline extensions. The Court will host the conference call and inform the parties by way of email of the telephone number for the conference. The parties shall dial into the Court's bridge line at least five minutes prior to the hearing. (Court Reporter: none.) Time: 10 minutes. (H,AR)

IMPORTANT: Notice [non-document]: The telephonic Status Conference set for January 5, 2024, at 12:00 p.m. is rescheduled to January 11, 2024, at 10:30 a.m. (H,AR)

Joint Status Report regarding Settlement and Discovery filed by Alanna Dunn. (Schwartz, Kate) (Entered: 01/09/2024)

IMPORTANT: Notice [non-document]: In light of the parties' detailed status report (Doc. No. 26 ), the Court is sufficiently informed about the status of discovery and settlement discussions. The January 11, 2024 telephonic status conference is continued until March 14, 2024, at 11:00 a.m. (H,AR)

Joint Status Report regarding Settlement and Discovery filed by All Plaintiffs. (Schwartz, Kate) (Entered: 03/11/2024)

IMPORTANT: Notice [non-document]: In light of the parties' detailed status report (Doc. No. 27 ), the March 14, 2024, status conference is continued until September 17, 2024, at 9:00 a.m. (H,AR)

Joint Motion to extend case management deadlines filed by Plaintiff Alanna Dunn. Related document(s) 21 . (Schwartz, Kate) Modified docket text on 3/22/2024 (H,Ch). (Entered: 03/14/2024)

Order on Motion to extend deadlines

Order [non-document] granting the parties' Joint Motion to Extend Case Management Deadlines. (Doc. No. 28 .) The new deadlines are as follows: non-expert discovery: 12/16/2024; expert discovery: 3/17/2025; dispositive motions: 4/17/2025; and class certification motion: 4/17/2025. IT IS SO ORDERED. Judge Bridget Meehan Brennan on 3/15/2024. (H,AR)

Attorney Appearance by Dylan F. Ford filed by on behalf of City of Cleveland. (Ford, Dylan) (Entered: 07/03/2024)

Order

Order [non-document]: The Court is in receipt of Plaintiff Dunn's and non-party City of Cleveland's letters regarding a discovery dispute. The Court will hold a telephonic Status Conference to discuss the dispute. A telephonic Status Conference is set for July 22, 2024 at 10:30 a.m. The Court will host the conference call and inform the parties via email of the telephone number for the conference. The parties shall dial into the Court's bridge line at least five minutes prior to the hearing. IT IS SO ORDERED. Judge Bridget Meehan Brennan on 7/17/2024. (H,Ch)

Minutes of proceedings[non-document] before Judge Bridget Meehan Brennan. A telephonic Status Conference was held on 7/22/2024. Attorney Akeeb Animashaun and Kate Schwartz participated on behalf of Plaintiff. Attorney Brendan Healy participated on behalf of the Defendant. Attorney Dylan Ford participated on behalf of non-party City of Cleveland. The Court heard from all parties regarding Plaintiff's assertion that the City of Cleveland's subpoena responses are deficient, namely Municipal Court records and orders. Consistent with the discussions during the status conference on this issue, the Court ORDERS the parties to meet and confer regarding search terms, codes, and fields, and submit a joint status report on or before July 26, 2024 detailing what dispute, if any, remains. The joint submission is not to exceed five (5) pages. IT IS SO ORDERED. Judge Bridget Meehan Brennan on 7/23/2024. (Court Reporter: None.) Time: 45 minutes. (H,Ch)

Joint Status Report Re: Cleveland Subpoena Dispute filed by All Plaintiffs. (Attachments: # 1 Exhibit A-List of Codes to July 2024 Joint Status Report)(Schwartz, Kate) (Entered: 07/26/2024)

Motion for leave to file First Amended Complaint filed by Plaintiff Alanna Dunn. (Attachments: # 1 Proposed First Amended Complaint, # 2 Blacklined Proposed First Amended Complaint)(Animashaun, Akeeb) (Entered: 08/02/2024)

1 Exhibit Proposed First Amended Complaint

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2 Exhibit Blacklined Proposed First Amended Complaint

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Brief in Opposition to Plaintiff's Motion to Amend Complaint with Exhibit 1 - discovery requests filed by Cuyahoga County. Related document(s) 31 . (Healy, Brendan) (Entered: 08/16/2024)

Reply in support of 31 Motion for leave to file First Amended Complaint filed by Alanna Dunn. (Attachments: # 1 Exhibit Cuyahoga County Clerk Overdetention Email)(Animashaun, Akeeb) (Entered: 08/19/2024)

Motion for leave to Submit a Surreply with Exhibit 1 - Letter, Exhibit 2 - spreadsheet, Exhibit 3 - Email and Exhibit 4- Sur-Reply filed by Defendant Cuyahoga County. (Healy, Brendan) (Entered: 08/23/2024)

Response to 34 Motion for leave to Submit a Surreply filed by Alanna Dunn. (Animashaun, Akeeb) (Entered: 08/26/2024)

Attorney Appearance by Bridget E. Dever filed by on behalf of Cuyahoga County. (Dever, Bridget) (Entered: 08/30/2024)

Reply in support 34 Motion for leave to Submit a Surreply filed by Cuyahoga County. (Healy, Brendan) (Entered: 09/03/2024)

Order: For the reasons stated herein, the Plaintiff's motion for leave to file an amended complaint (Doc. 31 ) is GRANTED, and the Defendant's motion for a surreply (Doc. 34 ) is also GRANTED. Judge Bridget Meehan Brennan on 9/4/2024. (F,AW) (Entered: 09/04/2024)

First Amended complaint with jury demand against All Defendants and adding new party plaintiff(s) Reginald Haymon, Adam Day, Eric Zeider, Cameron Leonard, and Jason Wilson. Filed by Alanna Dunn. (Animashaun, Akeeb) (Entered: 09/04/2024)

Joint Status Report re Settlement and Discovery filed by All Plaintiffs. (Schwartz, Kate) (Entered: 09/12/2024)

Answer to 39 Amended complaint filed by Cuyahoga County. (Healy, Brendan) (Entered: 09/17/2024)

Minutes Order[non-document] before Judge Bridget Meehan Brennan. A telephonic status conference was held on 9/17/2024. Attorneys Akeeb Animashaun and Kate Schwartz participated on behalf of Plaintiffs. Attorneys Brendan Healy, Bridget Dever, and Jake Elliot participated on behalf of Defendant. The Court addressed the parties' joint status report (Doc. No. 40 ), which the Court construed as a motion for extension of deadlines and to bifurcate class certification and stay non-class certification related deadlines. The motion was GRANTED as to an extension of present deadlines and DENIED as to the delayed request to bifurcate class certification and stay "final and oral written and fact discovery deadlines and dispositive motion deadlines... until after the Court rules on class certification." (Doc. 40 at 293.) The following deadlines are now established: responses to any pending written discovery: 10/15/2024; class certification related depositions (namely the referenced deposition to occur on 9/25/2024 and approximately six fact witness depositions needed for plaintiffs' class certification motion): 12/16/2024; propounding any new written discovery, whether requests for production, interrogatories, requests for admission, or third-party subpoenas: 1/31/2025; class certification motion: any time before but no later than 4/17/2025; non-expert discovery: 5/21/2025; expert reports for party bearing the burden of proof: 6/20/2025; responsive expert reports: 7/21/2025; expert discovery: 8/21/2025; and dispositive motions: 9/19/2025. Additionally, if Plaintiffs intend to utilize an expert witness in connection with their motion for class certification, they are ordered to notify Defendant on or before 12/20/2024 of their intent to do so and provide a proposed timeline for production of reports or related discovery. Any disputes related to expert witnesses utilized for class certification must promptly be raised in accordance with LR 37.1(a) in so far as a proper meet-and-confer and notification to the Court. If a meet-and-confer does not resolve any dispute on expert matters relative to class certification, it must be brought to the Court's attention (see LR 37.1(a)(1), (2)) within two (2) business days. Late notifications will not be considered. Counsel for all parties acknowledged the Court's statement that any further requests for an extension of these deadlines will likely be denied. IT IS SO ORDERED. Judge Bridget Meehan Brennan on 9/18/2024. (Court Reporter: None.) Time: 40 minutes. (H,Ch)

Attorney Appearance by Stephen W. Funk and David Sporar filed on behalf of Cuyahoga County. (Funk, Stephen) (Entered: 01/24/2025)

Exceed page limitations

Order on Motion to exceed page limitations

Motion for class certification filed by Adam Day, Alanna Dunn, Reginald Haymon, Cameron Leonard, Jason Wilson, Eric Zeider. (Schwartz, Kate) (Entered: 04/17/2025)

Brief Plaintiffs' Memorandum in Support of Motion for Class Certification filed by Adam Day, Alanna Dunn, Cameron Leonard, Jason Wilson, Eric Zeider. Related document(s) 44 . (Attachments: # 1 Exhibit 01 - Agreement Between Cleveland and County, # 2 Exhibit 02 - Deposition of Lisa Scafidi, # 3 Exhibit 03 - August 15, 2018, email from Carroll to Mills (52-day OD), # 4 Exhibit 04 - Animashaun Decl. re. Discovery + Exs A-G, # 5 Exhibit 05 - Deposition of Russell Jaenke, # 6 Exhibit 06 - Deposition of Leah Palagyi, # 7 Exhibit 07 - Deposition of Krystal Lawyer, # 8 Exhibit 08 - January 21, 2022, email from Byrd to Gibson (Bond Report), # 9 Exhibit 09 - D's Supp. Responses to Ps' First Set RFA, # 10 Exhibit 10 - Deposition of Michelle Henry, # 11 Exhibit 11 - Deposition of Amanda Brewer, # 12 Exhibit 12 - Deposition of Kevin Boll (Part 1), # 13 Exhibit 13 - Deposition of Janiese Cage, # 14 Exhibit 14 - Deposition of Steven Boardman, # 15 Exhibit 15 - D's Response to P Dunns 3rd Set Interrogatories, # 16 Exhibit 16 - Deposition of Ronald Tabor, # 17 Exhibit 17 - Deposition of Countys Rule 30(b)(6) Representative, # 18 Exhibit 18 - Deposition of Kevin ODonnell, # 19 Exhibit 19 - Deposition of Kevin Boll (Part 2), # 20 Exhibit 20 - Release Desk Post Orders, # 21 Exhibit 21 - Clev. Muni. Ct. Admin. Order No. 2011-003, # 22 Exhibit 22 - Jailer Post Orders, # 23 Exhibit 23 - CCSD Release Clerk Duties and Responsibilities, # 24 Exhibit 24 - October 29, 2020, email from Henry (Action Plan), # 25 Exhibit 25 - January 5, 2021, email from Henry (Corrective Plan), # 26 Exhibit 26 - January 10, 2022, email from Henry (Corrective Measures), # 27 Exhibit 27 - Standard Schedule of Discipline, # 28 Exhibit 28 - Deposition of Kathleen Belle, # 29 Exhibit 29 - Supp. Keller Expert Report, March 24, 2025, # 30 Exhibit 30 - Keller Expert Report, January 31, 2025, # 31 Exhibit 31 - CCSD IMACS Data Entry for Pl. Dunn, # 32 Exhibit 32 - CCSD Paper File for Pl. Dunn, # 33 Exhibit 33 - Excerpt of CCSD Analysis of February 2022 Cleveland OD Report, # 34 Exhibit 34 - February 11, 2022, email from Moore to Jaenke re. Adam Day, # 35 Exhibit 35 - Cleveland Data Production - Entry for Pl. Day, # 36 Exhibit 36 - CCSD Paper File for Pl. Wilson, # 37 Exhibit 37 - Excerpt of CCSD Analysis of May 2022 Clv. OD Report, # 38 Exhibit 38 - CCSD Paper File for Pl. Leonard, # 39 Exhibit 39 - Excerpt of CCSD Analysis of July 2022 Clv. OD Report, # 40 Exhibit 40 - Excerpt of CCSD Analysis of April 2022 Clv. OD Report, # 41 Exhibit 41 - April 2022 Clv. OD Report and Email, # 42 Exhibit 42 - Franklin Co. Jail Ops. Review Email & Attachment, # 43 Exhibit 43 - Def's Supp. Response to Pl's Rog 23, # 44 Exhibit 44 - Release of Inmate Policy, # 45 Exhibit 45 - Keller Declaration, # 46 Exhibit 46 - Pls' Counsel Declarations re. Adequacy) (Schwartz, Kate) (Entered: 04/17/2025)

1 Exhibit 01 - Agreement Between Cleveland and County

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2 Exhibit 02 - Deposition of Lisa Scafidi

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3 Exhibit 03 - August 15, 2018, email from Carroll to Mills (52-day OD)

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4 Exhibit 04 - Animashaun Decl. re. Discovery + Exs A-G

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5 Exhibit 05 - Deposition of Russell Jaenke

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6 Exhibit 06 - Deposition of Leah Palagyi

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7 Exhibit 07 - Deposition of Krystal Lawyer

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8 Exhibit 08 - January 21, 2022, email from Byrd to Gibson (Bond Report)

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9 Exhibit 09 - D's Supp. Responses to Ps' First Set RFA

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10 Exhibit 10 - Deposition of Michelle Henry

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11 Exhibit 11 - Deposition of Amanda Brewer

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12 Exhibit 12 - Deposition of Kevin Boll (Part 1)

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13 Exhibit 13 - Deposition of Janiese Cage

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14 Exhibit 14 - Deposition of Steven Boardman

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15 Exhibit 15 - D's Response to P Dunns 3rd Set Interrogatories

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16 Exhibit 16 - Deposition of Ronald Tabor

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17 Exhibit 17 - Deposition of Countys Rule 30(b)(6) Representative

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18 Exhibit 18 - Deposition of Kevin ODonnell

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19 Exhibit 19 - Deposition of Kevin Boll (Part 2)

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20 Exhibit 20 - Release Desk Post Orders

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21 Exhibit 21 - Clev. Muni. Ct. Admin. Order No. 2011-003

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22 Exhibit 22 - Jailer Post Orders

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23 Exhibit 23 - CCSD Release Clerk Duties and Responsibilities

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24 Exhibit 24 - October 29, 2020, email from Henry (Action Plan)

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25 Exhibit 25 - January 5, 2021, email from Henry (Corrective Plan)

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26 Exhibit 26 - January 10, 2022, email from Henry (Corrective Measures)

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27 Exhibit 27 - Standard Schedule of Discipline

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28 Exhibit 28 - Deposition of Kathleen Belle

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29 Exhibit 29 - Supp. Keller Expert Report, March 24, 2025

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30 Exhibit 30 - Keller Expert Report, January 31, 2025

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31 Exhibit 31 - CCSD IMACS Data Entry for Pl. Dunn

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32 Exhibit 32 - CCSD Paper File for Pl. Dunn

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33 Exhibit 33 - Excerpt of CCSD Analysis of February 2022 Cleveland OD Report

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34 Exhibit 34 - February 11, 2022, email from Moore to Jaenke re. Adam Day

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35 Exhibit 35 - Cleveland Data Production - Entry for Pl. Day

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36 Exhibit 36 - CCSD Paper File for Pl. Wilson

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37 Exhibit 37 - Excerpt of CCSD Analysis of May 2022 Clv. OD Report

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38 Exhibit 38 - CCSD Paper File for Pl. Leonard

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39 Exhibit 39 - Excerpt of CCSD Analysis of July 2022 Clv. OD Report

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40 Exhibit 40 - Excerpt of CCSD Analysis of April 2022 Clv. OD Report

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41 Exhibit 41 - April 2022 Clv. OD Report and Email

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42 Exhibit 42 - Franklin Co. Jail Ops. Review Email & Attachment

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43 Exhibit 43 - Def's Supp. Response to Pl's Rog 23

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44 Exhibit 44 - Release of Inmate Policy

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45 Exhibit 45 - Keller Declaration

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46 Exhibit 46 - Pls' Counsel Declarations re. Adequacy

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Motion for leave to Depose Four Additional Witnesses, and Motion to Extend the Close of Fact Discovery by Four Weeks filed by Adam Day, Alanna Dunn, Reginald Haymon, Cameron Leonard, Jason Wilson, Eric Zeider. (Attachments: # 1 Exhibit 1 - 2024.11.18 - Dunn - 2nd Amended Supplemental Initial Disclosures, # 2 Exhibit 2 - Email re Outstanding issues)(Schwartz, Kate). AddedMotion for extension of time on 4/23/2025 (B,Ch). (Entered: 04/22/2025)

1 Exhibit 1 - 2024.11.18 - Dunn - 2nd AMENDED Supplemental Initial Disclosures

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2 Exhibit 2 - Email re Outstanding issues

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Order

Order [non-document]: Defendant's opposition to Plaintiffs' Motion for Leave to Depose Four Additional Witnesses and Motion for Extension of Time (Doc. 46 ), if any, must be filed on or before May 1, 2025. IT IS SO ORDERED. Judge Bridget Meehan Brennan on 4/28/25. (T,A)

Strike

1 Exhibit

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Opposition to 44 Motion for class certification filed by Cuyahoga County. (Attachments: # 1 Declaration of Kevin O'Donnell, # 2 Declaration of Kevin Boll, # 3 Declaration of Ronald Tabor, # 4 Declaration of Joseph H. Baskin, M.D., # 5 Declaration of Sean T. Malone, Ph.D., # 6 Malone Decl. Ex. 1 - Malone Expert Report, dated March 3, 2025, # 7 Malone Decl. Ex. 2 - Malone Supplemental Expert Report, dated March 19, 2025, # 8 Malone Decl. Ex. 3 - Malone Curriculum Vitae, # 9 Deposition of Lacey R. Keller)(Funk, Stephen) (Entered: 05/01/2025)

Order on Motion for extension of time (other) AND Order on Motion for leave

Motion in limine to Preclude the Use of Lacey R. Keller's Expert Reports and Declaration to Prove the Time to Release or for Determining the Members of Proposed Class filed by Defendant Cuyahoga County. (Attachments: # 1 Deposition of Lacey R. Keller, # 2 Declaration of Sean T. Malone, Ph.D., # 3 Malone Decl. Ex. 1 - Malone Expert Report, dated March 3, 2025, # 4 Malone Decl. Ex. 2 - Malone Supplemental Expert Report, dated 3.19.2025, # 5 Malone Decl. Ex. 3 - Malone CV, # 6 Deposition of Sean T. Malone, Ph.D., # 7 Declaration of Janice Smith, # 8 Declaration of Kristal Lawyer)(Funk, Stephen) (Entered: 05/01/2025)

1 Deposition of Lacey R. Keller

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2 Declaration of Sean T. Malone, Ph.D.

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3 Malone Decl. Ex. 1 - Malone Expert Report, dated March 3, 2025

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4 Malone Decl. Ex. 2 - Malone Supplemental Expert Report, dated 3.19.2025

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5 Malone Decl. Ex. 3 - Malone CV

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6 Deposition of Sean T. Malone, Ph.D.

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7 Declaration of Janice Smith

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8 Declaration of Kristal Lawyer

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Protective Order

1 Exhibit 1 - Proposed order

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Opposition to 50 Motion in limine to Preclude the Use of Lacey R. Keller's Expert Reports and Declaration to Prove the Time to Release or for Determining the Members of Proposed Class filed by Adam Day, Alanna Dunn, Cameron Leonard, Jason Wilson, Eric Zeider. (Attachments: # 1 Exhibit 1-Declaration of Dami Animashaun, # 2 Exhibit 2-Declaration of Lacey R. Keller)(Schwartz, Kate) (Entered: 05/15/2025)

Motion to strike Expert Reports of Dr. Sean Malone filed by Adam Day, Alanna Dunn, Cameron Leonard, Jason Wilson, Eric Zeider. (Schwartz, Kate) (Entered: 05/15/2025)

Reply in support of 48 Motion to strike Declaration of Plaintiffs' Counsel Dami Animashaun filed by Cuyahoga County. (Healy, Brendan) (Entered: 05/15/2025)

Brief Plaintiffs' Memorandum in Support of Motion to Exclude Expert Reports of Dr. Sean Malone filed by Adam Day, Alanna Dunn, Cameron Leonard, Jason Wilson, Eric Zeider. Related document(s) 56 . (Schwartz, Kate) (Entered: 05/15/2025)

Protective Order. Judge Bridget Meehan Brennan on 5/16/25. (T,A) (Entered: 05/16/2025)

Reply in support of 50 Motion in limine to Preclude the Use of Lacey R. Keller's Expert Reports and Declaration to Prove the Time to Release or for Determining the Members of Proposed Class filed by Cuyahoga County. (Funk, Stephen) (Entered: 05/22/2025)

Opposition to 56 Motion to strike Expert Reports of Dr. Sean Malone filed by Cuyahoga County. (Funk, Stephen) (Entered: 05/23/2025)

Reply in support of 56 Motion to strike Expert Reports of Dr. Sean Malone filed by Adam Day, Alanna Dunn, Cameron Leonard, Jason Wilson, Eric Zeider. (Schwartz, Kate) (Entered: 05/30/2025)