Case: Strickland v. Delaware County

Strickland v. Delaware County et al.

Strickland v. Delaware County et al.

Strickland v. Delaware County et al.

Strickland v. Delaware County et al.

COMPLAINT against All Defendants ( Filing fee $ 402 receipt number APAEDC-15415330.), filed by SHAWN STRICKLAND. (Attachments: # 1 Civil Cover Sheet, # 2 Designation Form)(ABNER, ADRIENNE) (Entered: 09/17/2021)

1 Civil Cover Sheet

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2 Designation Form

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NOTICE of Appearance by SU MING YEH on behalf of SHAWN STRICKLAND (YEH, SU MING) (Entered: 09/20/2021)

Summons Issued

Summons Issued as to JOHN CHRISTAKIS, DELAWARE COUNTY, KRISTEN GRAY, LEE TATUM, THE GEO GROUP, INC.. E-MAILED To: COUNSEL on 9/20/21 (bw, )

MOTION for Temporary Restraining Order, MOTION for Preliminary Injunction filed by SHAWN STRICKLAND.Memorandum, Declaration. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12)(YEH, SU MING) (Entered: 09/21/2021)

NOTICE by SHAWN STRICKLAND of Withdrawal re 3 MOTION for Temporary Restraining Order and MOTION for Preliminary Injunction. (ABNER, ADRIENNE) Modified on 9/28/2021 (md, ). (Entered: 09/27/2021)

NOTICE of Appearance by SHELLEY R. SMITH on behalf of DELAWARE COUNTY, LEE TATUM with Certificate of Service(SMITH, SHELLEY) (Entered: 09/27/2021)

STIPULATION AND ORDER THAT TIME WITHIN WHICH DEFENDANTS DELAWARE COUNTY AND WARDEN LEE TATUM MAY RESPOND OR OTHERWISE PLEAD TO PLAINTIFFS COMPLAINT IS EXTENDED THROUGH 12/1/21. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 9/28/21. 9/28/21 ENTERED AND COPIES E-MAILED.(rf, ) (Entered: 09/28/2021)

STIPULATION AND ORDER THAT PLAINTIFF MAY FILE AN AMENDED COMPLAINT ON OR BEFORE 12/16/21. DEFENDANTS DELAWARE COUNTY AND WARDEN LEE TATUM MAY RESPOND OR OTHERWISE PLEAD TO PLAINTIFF'S AMENDED COMPLAINT BY 2/14/22. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 11/19/21. 11/19/21 ENTERED & E-MAILED.(fdc) (Entered: 11/19/2021)

WAIVER OF SERVICE Returned Executed by SHAWN STRICKLAND. DELAWARE COUNTY waiver sent on 11/29/2021, answer due 1/28/2022; LEE TATUM waiver sent on 11/29/2021, answer due 1/28/2022. (ABNER, ADRIENNE) (Entered: 12/16/2021)

AMENDED COMPLAINT against All Defendants All Defendants., filed by SHAUN STRICKLAND. (Attachments: # 1 Certificate of Service)(ABNER, ADRIENNE) Modified on 12/17/2021 (lisad, ). (Entered: 12/16/2021)

Summons Issued as to JOHN CHRISTAKIS, KRISTEN GRADY, KRISTEN GRAY, RONALD B. PHILLIPS, THE GEO GROUP, INC., Jeff Withelder. Forwarded To: Adrienne R. Abner on 12/17/21. (fdc)

Summons Issued

NOTICE of Appearance by MATTHEW H. FRY on behalf of KRISTEN GRAY, THE GEO GROUP, INC. with Certificate of Service(FRY, MATTHEW) (Entered: 12/22/2021)

WAIVER OF SERVICE Returned Executed by KRISTEN GRAY, THE GEO GROUP, INC.. KRISTEN GRAY waiver sent on 11/29/2021, answer due 1/28/2022; THE GEO GROUP, INC. waiver sent on 11/29/2021, answer due 1/28/2022. (FRY, MATTHEW) (Entered: 12/22/2021)

NOTICE of Appearance by ROBERT M. DIORIO on behalf of KRISTEN GRAY, THE GEO GROUP, INC. with Certificate of Service(DIORIO, ROBERT) (Entered: 12/22/2021)

STIPULATION To Extend Time by SHAUN STRICKLAND. (ABNER, ADRIENNE) (Entered: 01/18/2022)

STIPULATION AND ORDER THAT TIME TO RESPOND TO PLAINTIFFS AMENDED COMPLAINT IS EXTENDED TO 2/22/22. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 1/20/22. 1/20/22 ENTERED AND COPIES E-MAILED.(rf, ) (Entered: 01/20/2022)

NOTICE by SHAUN STRICKLAND Notice of Filing of Certificates of Merit (ABNER, ADRIENNE) (Entered: 02/01/2022)

AFFIDAVIT of Service by Sharline Rojo Reyes re: served Amended Complaint and Summons upon John Christakis, MD by Certified Mail on 02/07/2022, answer due 2/28/2022. (ABNER, ADRIENNE) Modified on 3/1/2022 (md). (Entered: 02/16/2022)

NOTICE of Appearance by MATTHEW H. FRY on behalf of JOHN CHRISTAKIS with Certificate of Service(FRY, MATTHEW) (Entered: 02/18/2022)

NOTICE of Appearance by ROBERT M. DIORIO on behalf of JOHN CHRISTAKIS with Certificate of Service(DIORIO, ROBERT) (Entered: 02/18/2022)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by DELAWARE COUNTY, LEE TATUM.Certificate of Service. (Attachments: # 1 Memorandum, # 2 Text of Proposed Order)(SMITH, SHELLEY) (Entered: 02/22/2022)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by JOHN CHRISTAKIS, KRISTEN GRADY, RONALD B. PHILLIPS, THE GEO GROUP, INC., Jeff Withelder.Memorandum, Certificate of Service.(FRY, MATTHEW) (Entered: 02/22/2022)

STIPULATION AND ORDER THAT PLAINTIFF MAY FILE A CONSOLIDATED RESPONSE TO THE MOTIONS TO DISMISS BY 3/22/22. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 3/3/22. 3/3/22 ENTERED AND COPIES E-MAILED.(rf, ) (Entered: 03/03/2022)

RESPONSE in Opposition re 20 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM, 19 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by SHAUN STRICKLAND. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit 1, # 3 Exhibit 2)(ABNER, ADRIENNE) (Entered: 03/22/2022)

MEMORANDUM AND/OR OPINION. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 4/19/22. 4/19/22 ENS TERED AND COPIES E-MAILED.(rf, ) (Entered: 04/19/2022)

MEMORANDUM AND ORDER THAT MOTIONS ARE DENIED. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 4/19/22. 4/19/22 ENTERED AND COPIES E-MAILED.(rf, ) (Entered: 04/19/2022)

ANSWER to 9 Amended Complaint by JOHN CHRISTAKIS, KRISTEN GRADY, RONALD B. PHILLIPS, THE GEO GROUP, INC., Jeff Withelder.(FRY, MATTHEW) (Entered: 05/03/2022)

NOTICE of Hearing:PRELIMINARY PRETRIAL TELEPHONE CONFERENCE SET FOR 5/24/2022 AT 11:30 AM BEFORE HONORABLE MICHAEL M. BAYLSON. COUNSEL FOR PLAINTIFF WILL INITIATE THE CALL AND WHEN ALL COUNSEL ARE ON THE LINE, CALL CHAMBERS AT 267-299-7520. (Attachments: # 1 Trial Procedures, # 2 Conference Info Sheet)(ahf) (Entered: 05/05/2022)

ANSWER to 9 Amended Complaint with Affirmative Defenses by DELAWARE COUNTY, LEE TATUM.(SMITH, SHELLEY) (Entered: 05/09/2022)

STIPULATION AND ORDER THAT COUNSEL FOR PLAINTIFF HAS AN EXTENSION UNTIL 5/17/22 TO ANSWER AMENDED COMPLAINT. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 5/10/22. 5/10/22 ENTERED AND COPIES E-MAILED.(rf, ) (Entered: 05/10/2022)

NOTICE of Appearance by SARAH BLEIBERG on behalf of SHAUN STRICKLAND with Certificate of Service(BLEIBERG, SARAH) (Entered: 05/13/2022)

Minute Entry for proceedings held before HONORABLE MICHAEL M. BAYLSON Pretrial Conference held on 5/24/22. (rf, ) (Entered: 05/24/2022)

ORDER THAT MAGISTRATE JUDGE STRAWBRIDGE WILL CONTACT COUNSEL AS TO WHETHER SETTLEMENT DISCUSSIONS HAVE TAKEN PLACE, ETC. DISCOVERY DUE BY 11/30/2022., MOTIONS DUE BY 12/22/2022., MOTION TO COMPEL DUE BY 8/1/2022. PLAINTIFF PRETRIAL MEMO DUE BY 1/10/2023., DEFENDANT PRETRIAL MEMO DUE BY 1/10/2023., TRIAL POOL SET FOR 2/15/2023. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 5/25/22. 5/25/22 ENTERED AND COPIES E-MAILED.(rf, ) (Entered: 05/25/2022)

NOTICE of Withdrawal of Appearance by ADRIENNE R. ABNER on behalf of SHAUN STRICKLAND(ABNER, ADRIENNE) (Entered: 05/27/2022)

ORDER THAT IT HAS BEEN STIPULATED AND AGREED TO EXTEND DEADLINES, HEREBY STIPULATE AS FOLLOWS: THE COURT HELD A RULE 16 CONFERENCE IN THIS MATTER ON MAY 24, 2022. THE COURT ISSUED A SCHEDULING ORDER WITH THE FOLLOWING DEADLINES (ECF NO. 31): DISCOVERY REQUESTS PURSUANT TO RULES 33 AND 34. SERVED BY JUNE 15, 2022; EXCHANGE OF DOCUMENTS BY JULY 15, 2022; PLAINTIFFS EXPERT REPORT PROVIDED TO DEFENDANTS BY SEPTEMBER 15, 2022; AND DEFENDANTS' EXPERT REPORT PROVIDED TO PLAINTIFF BY OCTOBER 17, 2022. DEFENDANTS SERVED DISCOVERY REQUESTS ON PLAINTIFF ON MAY 27, 2022. PLAINTIFF SERVED DISCOVERY REQUESTS ON DEFENDANT ON JUNE 15, 2022. AFTER REQUESTING ADDITIONAL TIME DUE TO WORK ON OTHER MATTERS AND PLAINTIFFS COUNSEL CONTRACTING COVID-19, PLAINTIFF PROVIDED RESPONSES TO DEFENDANTS' DISCOVERY REQUESTS ON JULY 15, 2022. DEFENDANTS' COUNSEL HAS INDICATED THAT DUE TO DISCUSSIONS BETWEEN DEFENDANTS, THEY REQUIRE AN ADDITIONAL 30 DAYS TO PROVIDE DISCOVERY RESPONSES. COUNSEL FOR PLAINTIFF HAS AGREED TO THIS EXTENSION, MAKING DEFENDANTS' RESPONSES TO PLAINTIFFS DISCOVERY REQUESTS DUE ON AUGUST 15, 2022. PLAINTIFF STRICKLAND AND DEFENDANTS DELAWARE COUNTY, TATUM, GEO GROUP, GRADY, CHRISTAKIS, PHILLIPS, AND WITHELDER AGREE THAT THE REMAINING DISCOVERY DEADLINES ARE TO BE AMENDED AS FOLLOWS: THE PARTIES MAY FILE A MOTION TO COMPEL REGARDING RULE 33 AND 34 BY SEPTEMBER 15, 2022; PLAINTIFFS EXPERT REPORT IS DUE OCTOBER 31, 2022; AND DEFENDANT'S EXPERT REPORT IS DUE NOVEMBER 30, 2022. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 8/3/22. 8/3/22 ENTERED AND COPIES E-MAILED.(bw) (Entered: 08/03/2022)

NOTICE of Withdrawal of Appearance by ROBERT M. DIORIO on behalf of JOHN CHRISTAKIS, KRISTEN GRAY, THE GEO GROUP, INC.(DIORIO, ROBERT) (Entered: 08/04/2022)

NOTICE of Appearance by MATTHEW H. FRY on behalf of DELAWARE COUNTY, LEE TATUM with JURY TRIAL DEMAND AND CERTIFICATE OF SERVICE(FRY, MATTHEW) (Entered: 08/26/2022)

NOTICE of Withdrawal of Appearance by SHELLEY R. SMITH on behalf of DELAWARE COUNTY, LEE TATUM(SMITH, SHELLEY) (Entered: 08/26/2022)

STIPULATION AND ORDER THAT MOTION TO COMPEL DUE BY 10/14/2022. PLAINTIFFS EXPERT REPORTS DUE 1/27/23. DEFENDANTS EXPERT REPORTS DUE 2/28/23. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 9/15/22. 9/16/22 ENTERED AND COPIES E-MAILED.(rf, ) (Entered: 09/16/2022)

STIPULATION AND ORDER THAT MOTION TO COMPEL DUE BY 11/18/22. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 10/27/22. 10/31/22 ENTERED AND COPIES E-MAILED.(rf, ) (Entered: 10/31/2022)

Set Deadlines/Hearings

MOTION TO COMPEL DUE BY 11/18/2022. (rf, )

Set Deadlines/Hearings

MOTION to Compel filed by SHAUN STRICKLAND.Brief, Certificate of Service. (Attachments: # 1 Brief Brief, # 2 Text of Proposed Order Proposed Order, # 3 Exhibit Exhibit 1, # 4 Exhibit Exhibit 2, # 5 Exhibit Exhibit 3, # 6 Exhibit Exhibit 4, # 7 Exhibit Exhibit 5, # 8 Exhibit Exhibit 6, # 9 Exhibit Exhibit 7, # 10 Exhibit Exhibit 8)(Bellos, Sarah) (Entered: 11/18/2022)

MOTION for Leave to File Second Amended Complaint filed by SHAUN STRICKLAND.Brief, Certificate of Service. (Attachments: # 1 Brief, # 2 Text of Proposed Order, # 3 Exhibit Exhibit A - Second Amended Complaint)(Bellos, Sarah) (Entered: 11/23/2022)

NOTICE of Hearing on Motion 39 MOTION to Compel : TELEPHONE CONFERENCE ON 11/29/2022 AT 3:00 PM IN Telephone Conference BEFORE HONORABLE MICHAEL M. BAYLSON. COUNSEL FOR PLAINTIFF WILL INITIATE THE CALL AND WHEN ALL COUNSEL ARE ON THE LINE, CALL CHAMBERS AT 267-299-7520.(ahf) (Entered: 11/28/2022)

AMENDED NOTICE of Hearing on Motion 39 MOTION to Compel : TELEPHONE CONFERENCE RESCHEDULED FOR 11/30/2022 AT 4:00 PM IN BEFORE HONORABLE MICHAEL M. BAYLSON. COUNSEL FOR PLAINTIFF WILL INITIATE THE CALL AND WHEN ALL COUNSEL ARE ON THE LINE, CALL CHAMBERS AT 267-299-7520.(ahf) (Entered: 11/28/2022)

NOTICE re: Cancellation of Hearing - Telephone Conference re: Motion to Compel, rescheduled for 11/30/2022, notice to follow.(ahf)

Notice re: Cancellation of Hearing

RESPONSE to Motion re 39 MOTION to Compel filed by DELAWARE COUNTY, KRISTEN GRADY, KRISTEN GRAY, RONALD B. PHILLIPS, THE GEO GROUP, INC., Jeff Withelder. (FRY, MATTHEW) (Entered: 11/29/2022)

Minute Entry for proceedings held before HONORABLE MICHAEL M. BAYLSON Motion Hearing held on 11/30/22 re 39 MOTION to Compel filed by SHAUN STRICKLAND (rf, ) (Entered: 12/01/2022)

ORDER granting in part and denying in part 39 MOTION TO COMPEL AS OUTLINED HEREIN. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 12/1/22.12/2/22 ENTERED AND COPIES E-MAILED.(rf, ) (Entered: 12/02/2022)

ORDER granting 40 MOTION FOR LEAVE TO FILE AS OUTLINED HEREIN. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 12/1/22.12/2/22 ENTERED AND COPIES E-MAILED.(rf, ) (Entered: 12/02/2022)

SECOND AMENDED COMPLAINT against JOHN CHRISTAKIS, DELAWARE COUNTY, GEO SECURE SERVICES, LLC, KRISTEN GRADY, RONALD B. PHILLIPS, LEE TATUM, THE GEO GROUP, INC., Jeff Withelder, filed by SHAUN STRICKLAND.(rf, ) Modified on 12/2/2022 (md). (Entered: 12/02/2022)

SECOND AMENDED COMPLAINT against JOHN CHRISTAKIS, DELAWARE COUNTY, GEO SECURE SERVICES, LLC, KRISTEN GRADY, RONALD B. PHILLIPS, LEE TATUM, THE GEO GROUP, INC., Jeff Withelder, filed by SHAUN STRICKLAND.(rf, ) Modified on 12/2/2022 (md). (Entered: 12/02/2022)

Summons Issued as to THE GEO GROUP, INC.. (rf, ) (Entered: 12/05/2022)

ANSWER to 47 Amended Complaint [DEFENDANTS, DELAWARE COUNTY, THE GEO GROUP, INC., GEO SECURE SERVICES, LLC, LEE TATUM, KRISTEN GRADY (INCORRECTLY IDENTIFIED AS KRISTEN GRAY), JOHN CHRISTAKIS, D.O. RONALD PHILLIPS, AND JEFF WITHELDERS ANSWER WITH AFFIRMATIVE DEFENSES TO PLAINTIFFS SECOND AMENDED COMPLAINT] by JOHN CHRISTAKIS, DELAWARE COUNTY, GEO SECURE SERVICES, LLC, KRISTEN GRADY, KRISTEN GRAY, RONALD B. PHILLIPS, LEE TATUM, THE GEO GROUP, INC., Jeff Withelder. (Attachments: # 1 Certificate of Service to Defendants' Answer with Affirmative Defenses to Plaintiff's Second Amended Complaint)(FRY, MATTHEW) (Entered: 12/12/2022)

MOTION for Extension of Time to Complete Discovery filed by SHAUN STRICKLAND.Certificate of Service. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5)(Bellos, Sarah) (Entered: 02/13/2023)

RESPONSE in Opposition re 50 MOTION for Extension of Time to Complete Discovery filed by JOHN CHRISTAKIS, DELAWARE COUNTY, KRISTEN GRADY, RONALD B. PHILLIPS, LEE TATUM, THE GEO GROUP, INC., Jeff Withelder. (Attachments: # 1 Certificate of Service to Defendants Opposition to Plaintiff's Motion for Extension of Time, # 2 Text of Proposed Order to Defendants Opposition to Plaintiff's Motion for Extension of Time)(FRY, MATTHEW) (Entered: 02/21/2023)

REPLY to Response to Motion re 50 MOTION for Extension of Time to Complete Discovery filed by SHAUN STRICKLAND. (Attachments: # 1 Exhibit 1)(Bellos, Sarah) (Entered: 02/22/2023)

ORDER granting 50 MOTION FOR EXTENSION OF TIME TO COMPLETE DISCOVERY. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 2/24/23.2/24/23 ENTERED AND COPIES E-MAILED.(rf, ) (Entered: 02/24/2023)

MOTION for Protective Order filed by JOHN CHRISTAKIS, DELAWARE COUNTY, GEO SECURE SERVICES, LLC, KRISTEN GRADY, KRISTEN GRAY, RONALD B. PHILLIPS, LEE TATUM, THE GEO GROUP, INC., Jeff Withelder.MEMORANDUM, CERTIFICATE OF SERVICE. (Attachments: # 1 Text of Proposed Order PROPOSED ORDER, # 2 Memorandum MEMORANDUM OF LAW, # 3 Certificate of Service CERTIFICATE OF SERVICE, # 4 Exhibit EXHIBITS A-B)(FRY, MATTHEW) (Entered: 03/07/2023)

RESPONSE in Opposition re 54 MOTION for Protective Order filed by SHAUN STRICKLAND. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4)(Bellos, Sarah) (Entered: 03/08/2023)

RESPONSE in Support re 54 MOTION for Protective Order filed by JOHN CHRISTAKIS, DELAWARE COUNTY, GEO SECURE SERVICES, LLC, KRISTEN GRADY, KRISTEN GRAY, RONALD B. PHILLIPS, LEE TATUM, THE GEO GROUP, INC., Jeff Withelder. (FRY, MATTHEW) (Entered: 03/10/2023)

NOTICE of Hearing on Motion 54 MOTION for Protective Order :TELEPHONE CONFERENCE SET FOR 4/20/2023 AT 3:30 PM BEFORE HONORABLE MICHAEL M. BAYLSON. COUNSEL FOR PLAINTIFF WILL INTIIATE THE CALL AND WHEN ALL COUNSEL ARE ON THE LINE, CALL CHAMBERS AT 267-299-7520.(ahf) (Entered: 04/18/2023)

Minute Entry for proceedings held before HONORABLE MICHAEL M. BAYLSON Motion Hearing held on 4/20/23 re 54 MOTION for Protective Order filed by DELAWARE COUNTY, KRISTEN GRADY, LEE TATUM, Jeff Withelder, THE GEO GROUP, INC., JOHN CHRISTAKIS, KRISTEN GRAY, RONALD B. PHILLIPS, GEO SECURE SERVICES, LLC (JL) (Entered: 04/21/2023)

ORDER THAT THE DEFENDANTS MOTION FOR PROTECTIVE ORDER 54 IS GRANTED IN PART AND DENIED IN PART. THE DEPOSITION OF DR. CHRISTAKIS SHALL BE TAKEN BY VIDEO TAPE FOR UP TO ONE (1) HOUR, WITHIN FOURTEEN (14) DAYS, ASSUMING HE IS AVAILABLE DURING THIS TIME PERIOD. DEFENDANTS SHALL SERVE THEIR EXPERT REPORT BY MAY 30, 2023. EXPERT DEPOSITIONS SHALL BE COMPLETED BY JUNE 15, 2023. DISPOSITIVE MOTIONS SHALL BE FILED BY JUNE 30, 2023, WITH RESPONSES WITHIN THIRTY (30) DAYS AND REPLY BRIEF WITHIN FOURTEEN (14) DAYS THEREAFTER. TRIAL POOL DATE IS SET FOR SEPTEMBER 15, 2023, TO BE CONTINUED IF DISPOSITIVE MOTIONS ARE NOT DECIDED. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 4/21/23.4/21/23 ENTERED AND COPIES E-MAILED.(bw) (Entered: 04/21/2023)

Set/Reset Scheduling Order Deadlines

Set/Reset Scheduling Order Deadlines: MOTIONS DUE BY 6/30/2023. TRIAL POOL SET FOR 9/15/2023. (bw)

STIPULATION for Extension of Time Pursuant to Local Rule 7.4(b)(2) by JOHN CHRISTAKIS, DELAWARE COUNTY, GEO SECURE SERVICES, LLC, KRISTEN GRADY, RONALD B. PHILLIPS, LEE TATUM, THE GEO GROUP, INC., Jeff Withelder. (FRY, MATTHEW) (Entered: 06/23/2023)

STIPULATION AND ORDER THAT DISPOSITIVE MOTIONS DUE BY 8/30/2023; TRIAL POOL SET FOR 11/15/2023. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 6/23/23. 6/23/23 ENTERED AND COPIES E-MAILED.(rf, ) (Entered: 06/23/2023)

ORDER THAT CASE IS REFERRED TO COURT APPOINT MEDIATION. FURTHER ORDERED THAT RICHARD GLAZER, ESQ. IS DESIGNATED AS THE MEDIATOR FOR PURPOSES OF COURT ANNEXED MEDIATION AND IS AUTHORIZED TO PROCEED AS THE COURT APPOINTED MEDIATOR IN THIS CASE, ETC. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 6/30/23. 6/30/23 ENTERED AND COPIES E-MAILED.(rf, ) (Entered: 06/30/2023)

STIPULATION for Extension of Time Pursuant to Local Rule 7.4(b)(2) by JOHN CHRISTAKIS, DELAWARE COUNTY, KRISTEN GRADY, RONALD B. PHILLIPS, LEE TATUM, THE GEO GROUP, INC., Jeff Withelder. (FRY, MATTHEW) (Entered: 08/24/2023)

STIPULATION AND ORDER THAT DISPOSITIVE MOTIONS DUE 10/20/23, WITH ANY RESPONSES DUE 11/20/23. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 9/6/23. 9/6/23 ENTERED AND COPIES E-MAILED.(rf, ) (Entered: 09/06/2023)

STIPULATION for Extension of Time Pursuant to Local Rule 7.4(b)(2) by JOHN CHRISTAKIS, DELAWARE COUNTY, KRISTEN GRADY, RONALD B. PHILLIPS, THE GEO GROUP, INC., Jeff Withelder. (FRY, MATTHEW) (Entered: 10/12/2023)

STIPULATION AND ORDER THAT DISPOSITIVE MOTIONS DUE BY 11/10/2023., TRIAL POOL SET FOR 1/15/2024. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 10/18/23. 10/18/23 ENTERED AND COPIES E-MAILED.(rf, ) (Entered: 10/18/2023)

MOTION for Summary Judgment filed by JOHN CHRISTAKIS, DELAWARE COUNTY, GEO SECURE SERVICES, LLC, KRISTEN GRADY, KRISTEN GRAY, RONALD B. PHILLIPS, LEE TATUM, THE GEO GROUP, INC., Jeff Withelder.MEMORANDUM, CERTIFICATE OF SERVICE.(FRY, MATTHEW) (Entered: 11/10/2023)

RESPONSE in Support re 67 MOTION for Summary Judgment STATEMENT OF UNDISPUTED MATERIAL FACTS FOR SUMMARY JUDGMENT filed by JOHN CHRISTAKIS, DELAWARE COUNTY, GEO SECURE SERVICES, LLC, KRISTEN GRADY, KRISTEN GRAY, RONALD B. PHILLIPS, LEE TATUM, THE GEO GROUP, INC., Jeff Withelder. (FRY, MATTHEW) (Entered: 11/10/2023)

STIPULATION for Extension of Time by SHAUN STRICKLAND. (YEH, SU MING) (Entered: 12/05/2023)

STIPULATION AND ORDER RE 67 MOTION for Summary Judgment filed by DELAWARE COUNTY, KRISTEN GRADY, LEE TATUM, Jeff Withelder, THE GEO GROUP, INC., JOHN CHRISTAKIS, KRISTEN GRAY, RONALD B. PHILLIPS, GEO SECURE SERVICES, LLC RESPONSES DUE BY 12/20/2023., REPLIES DUE BY 1/12/2024; TRIAL POOL SET FOR 3/15/2024. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 12/6/23. 12/6/23 ENTERED AND COPIES E-MAILED.(rf, ) (Entered: 12/06/2023)

Statement of Interest by UNITED STATES OF AMERICA. (DEBRUICKER, LAUREN) (Entered: 12/11/2023)

NOTICE of Appearance by Evangeline Wright on behalf of SHAUN STRICKLAND (Wright, Evangeline) (Entered: 12/20/2023)

Statement Of Material Facts, Response to Ds Statement of Material Facts by SHAUN STRICKLAND. (Attachments: # 1 Exhibit Table of Contents, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14, # 16 Exhibit 15, # 17 Exhibit 16, # 18 Exhibit 17, # 19 Exhibit 18, # 20 Exhibit 19, # 21 Exhibit 20, # 22 Exhibit 21, # 23 Exhibit 22, # 24 Exhibit 23, # 25 Exhibit 24, # 26 Exhibit 25, # 27 Exhibit 26, # 28 Exhibit 27, # 29 Exhibit 28, # 30 Exhibit 29, # 31 Exhibit 30, # 32 Exhibit 31, # 33 Exhibit 32, # 34 Exhibit 33, # 35 Exhibit 34, # 36 Exhibit 35, # 37 Exhibit 36, # 38 Exhibit 37, # 39 Exhibit 38, # 40 Exhibit 39)(YEH, SU MING) (Entered: 12/20/2023)

RESPONSE in Opposition re 67 MOTION for Summary Judgment filed by SHAUN STRICKLAND. (Attachments: # 1 Text of Proposed Order)(YEH, SU MING) (Entered: 12/20/2023)

STIPULATION of Dismissal (Partial) for Ds Christakis, Grady, Phillips, Withelder by SHAUN STRICKLAND. (Attachments: # 1 Text of Proposed Order)(YEH, SU MING) (Entered: 01/17/2024)

1 Text of Proposed Order

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STIPULATION AND ORDER THE PARTIES AGREED FOR THE DISMISSAL, WITH PREJUDICE, OF ALL CLAIMS AGAINST NAMED DEFENDANTS JOHN CHRISTAKIS, KRISTEN GRADY, RONALD PHILLIPS, AND JEFF WITHELDER, IT IS HEREBY SO ORDERED. DEFENDANTS CHRISTAKIS, GRADY, PHILLIPS, AND WITHELDER ARE DISMISSED FROM THIS ACTION WITH PREJUDICE AND THE CLERK SHALL DULY TERMINATE THESE DEFENDANTS FROM THE DOCKET. THIS CASE SHALL PROCEED AS TO ALL OTHER REMAINING NAMED DEFENDANTS. SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 1/17/24. 1/17/24 ENTERED AND COPIES E-MAILED.(bw) (Entered: 01/17/2024)

ORDER DISMISSING ACTION WITH PREJUDICE PURSUANT TO LOCAL RULE 41.1(b). SIGNED BY HONORABLE MICHAEL M. BAYLSON ON 1/18/24. 1/18/24 ENTERED AND COPIES E-MAILED.(rf, ) (Entered: 01/18/2024)