Case: Pappas v. Metropolitan Police Department of the District of Columbia

COMPLAINT against All Defendants with Jury Demand ( Filing fee $ 400 receipt number 0090-6384851) filed by STEVE PAPPAS. (Attachments: # 1 Civil Cover Sheet, # 2 Summons, # 3 Summons, # 4 Summons)(Eardley, Ellen) (Attachment 1 replaced on 9/20/2019) (zeg). (Entered: 09/18/2019)

1 Civil Cover Sheet

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2 Summons

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3 Summons

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4 Summons

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Case Assigned/Reassigned

Case Assigned to Judge Rudolph Contreras. (zeg)

SUMMONS (3) Issued Electronically as to METROPOLITAN POLICE DEPARTMENT OF THE DISTRICT OF COLUMBIA, PETER NEWSHOM and District of Columbia Attorney General,. (Attachment: # 1 Notice and Consent)(zeg) (Entered: 09/20/2019)

1 Notice and Consent

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NOTICE of Appearance by Lauren M Nussbaum on behalf of All Plaintiffs (Nussbaum, Lauren) (Entered: 09/24/2019)

NOTICE of Appearance by Cyrus Mehri on behalf of All Plaintiffs (Mehri, Cyrus) (Entered: 09/24/2019)

NOTICE of Appearance by Eve L. Hill on behalf of STEVE PAPPAS (Hill, Eve) (Entered: 09/24/2019)

NOTICE of Appearance by Andrew David Levy on behalf of STEVE PAPPAS (Levy, Andrew) (Entered: 09/24/2019)

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Emily L. Levenson, :Firm- Brown, Goldstein & Levy LLP, :Address- 120 E. Baltimore Street, Suite 1700, Baltimore, MD 21202. Phone No. - (410) 962-1030. Fax No. - (410) 385-0869 Filing fee $ 100, receipt number ADCDC-6445804. Fee Status: Fee Paid. by STEVE PAPPAS (Attachments: # 1 Declaration)(Hill, Eve) (Entered: 10/14/2019)

Order on Motion for Leave to Appear Pro Hac Vice

MINUTE ORDER granting 7 Motion for Leave to Appear Pro Hac Vice: Pursuant to Local Civil Rule 83.2, it is hereby ORDERED that Emily L. Levenson is admitted to represent Plaintiff pro hac vice in this case. However, the Court notes that the motion did not include (a) the meet-and-confer statement required for all non-dispositive motions or (b) a proposed order. See LCvR 7(c), (m). The parties are reminded for future reference that all motions must comply with the Local Rules. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). For instructions visit: https://www.dcd.uscourts.gov/sites/dcd/files/NextGEN_Tutorial_for_Registering_for_E-filing.pdf. SO ORDERED. Signed by Judge Rudolph Contreras on 10/16/2019. (lcrc1)

AMENDED COMPLAINT against DISTRICT OF COLUMBIA, METROPOLITAN POLICE DEPARTMENT OF THE DISTRICT OF COLUMBIA, PETER NEWSHOM with Jury Demand filed by STEVE PAPPAS, Tawana Lindsay, Nichole Mathies, Malachi Malik. (Attachments: # 1 Summons District of Columbia, # 2 Summons Metropolitan Police Department, # 3 Summons Chief of Police Peter Newsham)(Eardley, Ellen) (Entered: 12/12/2019)

1 Summons District of Columbia

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2 Summons Metropolitan Police Department

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3 Summons Chief of Police Peter Newsham

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NOTICE of Supplemental Summonses by Tawana Lindsay, Malachi Malik, Nichole Mathies, STEVE PAPPAS (Eardley, Ellen) (Entered: 12/12/2019)

SUMMONS (3) Issued Electronically as to DISTRICT OF COLUMBIA (District of Columbia Attorney General), METROPOLITAN POLICE DEPARTMENT OF THE DISTRICT OF COLUMBIA, PETER NEWSHOM, District of Columbia Attorney General. (jf) (Entered: 12/13/2019)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the District of Columbia Attorney General. Date of Service Upon District of Columbia Attorney General 12/16/2019. Answer due for ALL D.C. DEFENDANTS by 1/6/2020. (Eardley, Ellen) (Entered: 12/16/2019)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. METROPOLITAN POLICE DEPARTMENT OF THE DISTRICT OF COLUMBIA served on 12/16/2019 (Eardley, Ellen) (Entered: 12/16/2019)

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. PETER NEWSHOM served on 12/16/2019 (Eardley, Ellen) (Entered: 12/16/2019)

First MOTION for Extension of Time to Move for Class Certification Under Local Civil Rule 23.1(b) by TAWANA LINDSAY, MALACHI MALIK, NICHOLE MATHIES, STEVE PAPPAS (Attachments: # 1 Text of Proposed Order Proposed Order)(Eardley, Ellen) (Entered: 12/17/2019)

1 Text of Proposed Order Proposed Order

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NOTICE of Appearance by Micah Ian Bluming on behalf of All Defendants (Bluming, Micah) (Entered: 12/19/2019)

Consent MOTION for Extension of Time to Respond to Complaint by DISTRICT OF COLUMBIA, METROPOLITAN POLICE DEPARTMENT OF THE DISTRICT OF COLUMBIA, PETER NEWSHOM (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Bluming, Micah) (Entered: 12/20/2019)

MINUTE ORDER granting 16 Consent Motion for Extension of Time to Respond to Plaintiffs' Complaint. It is hereby ORDERED that Defendants shall have up to and including February 7, 2020, to file an an Answer or otherwise respond to Plaintiffs' Complaint. SO ORDERED. Signed by Judge Rudolph Contreras on 12/23/2019. (lcrc2)

Order on Motion for Extension of Time to

Set/Reset Deadlines

MINUTE ORDER granting 14 Motion for Extension of Time to Move for Class Certification Under Local Civil Rule 23.1(b). It is hereby ORDERED that Plaintiffs shall have until the end of class discovery to move for class certification. SO ORDERED. Signed by Judge Rudolph Contreras on 12/23/2019. (lcrc2)

NOTICE Notice of Defense Counsel's Consent To Plaintiffs' Motion to Extend Local Civil Rule 23.1(b) Deadline by TAWANA LINDSAY, MALACHI MALIK, NICHOLE MATHIES, STEVE PAPPAS (Eardley, Ellen) (Entered: 12/23/2019)

Set/Reset Deadlines: Answer due by 2/7/2020, (tj)

NOTICE of Appearance by Michael A. Tilghman on behalf of DISTRICT OF COLUMBIA, METROPOLITAN POLICE DEPARTMENT OF THE DISTRICT OF COLUMBIA, PETER NEWSHOM (Tilghman, Michael) (Entered: 02/07/2020)

MOTION to Dismiss Plaintiffs' Amended Complaint by DISTRICT OF COLUMBIA, METROPOLITAN POLICE DEPARTMENT OF THE DISTRICT OF COLUMBIA, PETER NEWSHOM (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Text of Proposed Order)(Bluming, Micah) (Entered: 02/07/2020)

Consent MOTION for Extension of Time to by TAWANA LINDSAY, MALACHI MALIK, NICHOLE MATHIES, STEVE PAPPAS (Eardley, Ellen) Modified text at the request of counsel on 2/19/2020 (ztth). (Entered: 02/19/2020)

Order on Motion for Extension of Time to

MINUTE ORDER granting 20 Consent Motion for Extension of time. It is hereby ORDERED that the following schedule shall govern further briefing on 19 the Defendants' Motion to Dismiss: Plaintiffs shall respond to the motion on or before March 6, 2020, and Defendants shall file a reply on or before March 20, 2020. SO ORDERED. Signed by Judge Rudolph Contreras on 2/20/2020. (lcrc2)

Set/Reset Deadlines

Set/Reset Deadlines: Responses due by 3/6/2020; Replies due by 3/20/2020. (tj)

Memorandum in opposition to re 19 MOTION to Dismiss Plaintiffs' Amended Complaint filed by TAWANA LINDSAY, MALACHI MALIK, NICHOLE MATHIES, STEVE PAPPAS. (Attachments: # 1 Proposed Order, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D)(Eardley, Ellen) (Entered: 03/06/2020)

1 Proposed Order

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2 Exhibit A

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3 Exhibit B

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4 Exhibit C

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5 Exhibit D

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REPLY to opposition to motion re 19 MOTION to Dismiss Plaintiffs' Amended Complaint filed by DISTRICT OF COLUMBIA, METROPOLITAN POLICE DEPARTMENT OF THE DISTRICT OF COLUMBIA, PETER NEWSHOM. (Bluming, Micah) (Entered: 03/20/2020)

NOTICE OF WITHDRAWAL OF APPEARANCE as to DISTRICT OF COLUMBIA, METROPOLITAN POLICE DEPARTMENT OF THE DISTRICT OF COLUMBIA, PETER NEWSHOM. Attorney Michael A. Tilghman terminated. (Tilghman, Michael) (Entered: 04/30/2020)

NOTICE OF WITHDRAWAL OF APPEARANCE as to TAWANA LINDSAY, MALACHI MALIK, NICHOLE MATHIES, STEVE PAPPAS. Attorney Lauren M Nussbaum terminated. (Nussbaum, Lauren) (Entered: 09/11/2020)

ORDER granting in part and denying in part 19 Defendants' Motion to Dismiss. See document for details. Signed by Judge Rudolph Contreras on 1/12/2021. (lcrc2) (Entered: 01/12/2021)

MEMORANDUM OPINION: granting in part and denying in part 19 Defendants' Motion to Dismiss. See document for details. Signed by Judge Rudolph Contreras on 1/12/2021. (lcrc2)

Order on Motion for Extension of Time to

Consent MOTION for Extension of Time to Respond to Plaintiffs' Complaint by DISTRICT OF COLUMBIA, PETER NEWSHOM. (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Bluming, Micah) (Entered: 01/22/2021)

MINUTE ORDER: granting 27 Defendants' Consent Motion for Extension of Time to Respond to Complaint. It is hereby ORDERED that Defendants shall respond to the Complaint by March 12, 2021. SO ORDERED. Signed by Judge Rudolph Contreras on 1/22/2020. (lcrc2)

Set/Reset Deadlines

Set/Reset Deadlines: Answer due by 3/12/2021. (tj)

AMENDED COMPLAINT (SECOND) against DISTRICT OF COLUMBIA, METROPOLITAN POLICE DEPARTMENT OF THE DISTRICT OF COLUMBIA, ROBERT J. CONTEE with Jury Demand filed by STEVE PAPPAS, NICHOLE MATHIES, MALACHI MALIK, TAWANA LINDSAY. (Attachments: # 1 Exhibit A - Second Amended Complaint (Redline))(Hill, Eve) (Entered: 02/11/2021)

ANSWER to 28 Amended Complaint, by ROBERT J. CONTEE, DISTRICT OF COLUMBIA.(Bluming, Micah) (Entered: 03/12/2021)

MINUTE ORDER: It is hereby ORDERED that the parties shall meet, confer, and submit a joint report in accordance with Local Civil Rule 16.3 on or before March 29, 2021. SO ORDERED. Signed by Judge Rudolph Contreras on 3/13/2021. (lcrc2)

Order

.Order

Set/Reset Deadlines

Set/Reset Deadlines: Meet & Confer Statement due by 3/29/2021. (tj)

NOTICE of Appearance by Richard P. Sobiecki on behalf of All Defendants (Sobiecki, Richard) (Entered: 03/16/2021)

Joint MOTION for Extension of Time to File Joint Motion to Extend the Case Management Plan Deadline by TAWANA LINDSAY, MALACHI MALIK, NICHOLE MATHIES, STEVE PAPPAS. (Attachments: # 1 Text of Proposed Order)(Levy, Andrew) (Entered: 03/29/2021)

Order on Motion for Extension of Time to File

MINUTE ORDER: granting 31 the parties' Joint Motion for Extension of Time to File Case Management Plan. It is hereby ORDERED that the parties shall submit a case management plan on or before April 5, 2021. SO ORDERED. Signed by Judge Rudolph Contreras on 3/30/2021. (lcrc2)

Set/Reset Deadlines

Set/Reset Deadlines: Case Management Plan due by 4/5/2021. (tj)

MEET AND CONFER STATEMENT. (Attachments: # 1 Proposed Order)(Eardley, Ellen) (Entered: 04/05/2021)

1 Proposed Order

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SCHEDULING ORDER: See document for details. Signed by Judge Rudolph Contreras on 4/5/2021. (lcrc2) (Entered: 04/05/2021)

NOTICE of Appearance by Desiree Langley (Sholes) on behalf of All Plaintiffs (Langley (Sholes), Desiree) (Entered: 04/13/2021)

Joint MOTION to Clarify the Scheduling Order - ECF No. 33 by TAWANA LINDSAY, MALACHI MALIK, NICHOLE MATHIES, STEVE PAPPAS. (Attachments: # 1 Text of Proposed Order)(Levy, Andrew) (Entered: 05/07/2021)

1 Text of Proposed Order

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MINUTE ORDER: granting 35 Motion to Clarify the Scheduling Order. See document for details. Signed by Judge Rudolph Contreras on 5/7/2021. (lcrc2) (Entered: 05/07/2021)

Set/Reset Hearings

Set/Reset Hearings: Status Conference set for 3/14/2022 at 10:00 AM in Courtroom 23A before Judge Rudolph Contreras. (tj)

Joint MOTION for Protective Order by DISTRICT OF COLUMBIA. (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order (Protective Order), # 3 Exhibit A (Acknowledgement of Confidentiality))(Bluming, Micah) (Entered: 07/01/2021)

ORDER: granting 37 Motion for Protective Order. See document for details. Signed by Judge Rudolph Contreras on 7/1/2021. (lcrc2) (Entered: 07/01/2021)

MINUTE ORDER: It is hereby ORDERED that the parties shall appear before the Court by telephone for a status conference on August 12, 2021 at 10:00 am. SO ORDERED. Signed by Judge Rudolph Contreras on 8/6/2021. (lcrc2)

Order

NOTICE of Appearance by James Strawbridge on behalf of TAWANA LINDSAY, MALACHI MALIK, NICHOLE MATHIES, STEVE PAPPAS (Strawbridge, James) (Entered: 08/06/2021)

.Order

Minute Entry for proceedings held before Judge Rudolph Contreras: Telephone Conference held on 8/12/2021. Discovery issues addressed by the court. Parties shall meet and confer on details regarding gathering docs, search terms and custodians. Parties shall appear for another telephone status conference on August 20, 2021 @ 10am before Judge Rudolph Contreras. (Court Reporter: Nancy Meyer.) (tj)

Telephone Conference

~Util - Set/Reset Hearings AND Telephone Conference

Minute Entry for proceedings held before Judge Rudolph Contreras: Telephone Status Conference held on 8/20/2021. Parties inform the court of the status of this action. Deadline of 9/30/2021 is VACATED. Next Telephone Conference set for 9/20/2021 at 3:00 PM before Judge Rudolph Contreras. (Court Reporter: Nancy Meyer) (tj)

Status Conference

~Util - Set/Reset Hearings AND Status Conference

Joint MOTION to Stay Class Discovery Deadlines by DISTRICT OF COLUMBIA. (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Bluming, Micah) (Entered: 08/31/2021)

Order on Motion to Stay

MINUTE ORDER granting 40 the parties' joint motion to stay class discovery deadlines. The Parties' deadlines to serve interrogatories, requests for admission, and requests for production are STAYED pending further order of the Court. SO ORDERED. Signed by Judge Rudolph Contreras on 09/19/2021. (lcrc2)

Status Conference

Minute Entry for proceedings held before Judge Rudolph Contreras: Status Conference held on 9/20/2021. The court adopts the proposed schedule addressed in the joint status report. The court also imposes a deadline (over objection) for defendants production of documents responsive to plaintiffs first request for documents. The court will issue an order. (Court Reporter Nancy Meyer) (tj

Order

Joint STATUS REPORT by TAWANA LINDSAY, MALACHI MALIK, NICHOLE MATHIES, STEVE PAPPAS. (Eardley, Ellen) (Entered: 09/20/2021)

MINUTE ORDER: Upon consideration of 41 the parties' Joint Status Report and for the reasons stated at today's status hearing, it is hereby ORDERED that the following schedule shall govern class discovery: the deadline for Defendants' Production of Documents responsive to Plaintiffs' First Requests for Documents is October 29, 2021; the deadline to serve written discovery requests is December 30, 2021; Non-expert Class Discovery closes January 31, 2022; Plaintiffs' Class Expert Disclosures are due January 31, 2022; Defendants' Rebuttal Class Expert Disclosures are due March 1, 2022; the deadline for Completion of Expert Depositions is April 1, 2022. It is FURTHER ORDERED that the deadline for Plaintiffs to file a motion for class certification is May 2, 2022; the deadline for Defendants' Opposition to class certification is June 1, 2022; and the deadline for Plaintiffs to file a Reply in support of class certification is June 15, 2022. SO ORDERED. Signed by Judge Rudolph Contreras on 09/20/2021. (lcrc2)

.Order

Order on Motion for Extension of Time to

Consent MOTION for Extension of Time to File Motion to Quash by PFC ASSOCIATES, LLC. (Attachments: # 1 Text of Proposed Order)(Gunderson, Eric) (Entered: 09/30/2021)

MINUTE ORDER granting 42 Consent Motion to Extend Deadline for Filing a Motion to Quash: It is hereby ORDERED that the deadline for Non-Party Witness PFC Associates, LLC to file a motion to quash shall be extended to October 7, 2021. SO ORDERED. Signed by Judge Rudolph Contreras on 09/30/2021. (lcrc2)

Order on Motion for Extension of Time to Complete Discovery

Joint MOTION for Extension of Time to Complete Discovery Joint Motion to Extend Class Discovery Deadlines by TAWANA LINDSAY, MALACHI MALIK, NICHOLE MATHIES, STEVE PAPPAS. (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Levy, Andrew) (Entered: 12/13/2021)

MINUTE ORDER: Upon consideration of 43 the parties' Joint Motion for an Extension of Time to Complete Discovery, it is hereby ORDERED that the following schedule shall govern class discovery: non-expert class discovery will close on March 31, 2022; all interrogatories must be served by March 1, 2022; all requests for production of documents must be served by March 1, 2022; Requests for admission must be served by March 1, 2022; Plaintiffs' class expert disclosures must be served by March 31, 2022; Defendants' rebuttal class expert disclosures must be served by May 1, 2022; Expert depositions must be completed by June 1, 2022; Plaintiffs are to file their Motion for Class Certification on or before July 1, 2022; Defendants are to file their Opposition to Class Certification on or before August 1, 2022; Plaintiffs are to file a Reply in Support of Their Motion for Class Certification on or before August 15, 2022. It is FURTHER ORDERED that the Class Certification Motion hearing currently scheduled for March 14, 2022 at 10:00 is hereby VACATED to be rescheduled at a later date. SO ORDERED. Signed by Judge Rudolph Contreras on 12/13/2021. (lcrc2)

Set/Reset Deadlines/Hearings AND Order on Motion for Extension of Time to Complete Discovery

Order on Motion for Extension of Time to Complete Discovery

Joint MOTION for Extension of Time to Complete Discovery by TAWANA LINDSAY, MALACHI MALIK, NICHOLE MATHIES, STEVE PAPPAS. (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Eardley, Ellen) (Entered: 03/24/2022)

MINUTE ORDER: Upon consideration of 44 the parties' Joint Motion for an Extension of Time to Complete Discovery, it is hereby ORDERED that the following schedule shall govern class discovery: non-expert class discovery will close on May 31, 2022; Plaintiffs' class expert disclosures must be served by May 31, 2022; Defendants' rebuttal class expert disclosures must be served by July 1, 2022; Expert depositions must be completed by August 1, 2022; Plaintiffs are to file their Motion for Class Certification on or before September 1, 2022; Defendants are to file their Opposition to Class Certification on or before October 3, 2022; Plaintiffs are to file a Reply in Support of Their Motion for Class Certification on or before October 17, 2022. SO ORDERED. Signed by Judge Rudolph Contreras on 3/24/22. (lcrc2)

Set/Reset Deadlines AND Order on Motion for Extension of Time to Complete Discovery

MOTION to Compel Discovery by TAWANA LINDSAY, MALACHI MALIK, NICHOLE MATHIES, STEVE PAPPAS. (Attachments: # 1 Exhibit List, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Exhibit N, # 16 Exhibit O, # 17 Exhibit P, # 18 Exhibit Q, # 19 Exhibit R, # 20 Exhibit S, # 21 Text of Proposed Order)(Langley (Sholes), Desiree) (Entered: 04/25/2022)

1 Exhibit List

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2 Exhibit A

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3 Exhibit B

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4 Exhibit C

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5 Exhibit D

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6 Exhibit E

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7 Exhibit F

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8 Exhibit G

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9 Exhibit H

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10 Exhibit I

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11 Exhibit J

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12 Exhibit K

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13 Exhibit L

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14 Exhibit M

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15 Exhibit N

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16 Exhibit O

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17 Exhibit P

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18 Exhibit Q

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19 Exhibit R

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20 Exhibit S

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21 Text of Proposed Order

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Memorandum in opposition to re 45 MOTION to Compel Discovery filed by ROBERT J. CONTEE, DISTRICT OF COLUMBIA. (Attachments: # 1 Exhibit List, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Exhibit N, # 16 Exhibit O, # 17 Exhibit P, # 18 Exhibit Q, # 19 Exhibit R, # 20 Exhibit S, # 21 Exhibit T, # 22 Exhibit U, # 23 Exhibit V, # 24 Exhibit W, # 25 Exhibit X, # 26 Exhibit Y, # 27 Text of Proposed Order)(Sobiecki, Richard) (Entered: 05/09/2022)

1 Exhibit List

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2 Exhibit A

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3 Exhibit B

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4 Exhibit C

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5 Exhibit D

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6 Exhibit E

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7 Exhibit F

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8 Exhibit G

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9 Exhibit H

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10 Exhibit I

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11 Exhibit J

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12 Exhibit K

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13 Exhibit L

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14 Exhibit M

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15 Exhibit N

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16 Exhibit O

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17 Exhibit P

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18 Exhibit Q

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19 Exhibit R

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20 Exhibit S

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21 Exhibit T

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22 Exhibit U

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23 Exhibit V

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24 Exhibit W

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25 Exhibit X

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26 Exhibit Y

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27 Text of Proposed Order

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REPLY to opposition to motion re 45 MOTION to Compel Discovery filed by TAWANA LINDSAY, MALACHI MALIK, NICHOLE MATHIES, STEVE PAPPAS. (Attachments: # 1 Exhibit T, # 2 Exhibit U, # 3 Exhibit V, # 4 Exhibit W)(Langley (Sholes), Desiree) (Entered: 05/16/2022)

MOTION to Modify Class Discovery Scheduling Order by ROBERT J. CONTEE, DISTRICT OF COLUMBIA. (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Bluming, Micah) (Entered: 06/28/2022)