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1
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PETITION Verified Petition for a Judgment Pursuant to Article 78 Redacted per 22 NYCRR §202.5(e)
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June 24, 2025
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June 24, 2025
Clearinghouse
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2
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ORDER TO SHOW CAUSE ( PROPOSED ) (Motion #001) *Corrected* Proposed Order to Show Cause By Danberg Biggs, R.Related ARTICLE 78 (BODY OR OFFICER) Documents: 38, 41, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55.+ Related
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June 24, 2025
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June 24, 2025
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3
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AFFIDAVIT OR AFFIRMATION IN SUPPORT Affirmation of Rubin Danberg Biggs in Support of Verified Petition for a Judgment Pursuant to Articl ... show more
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June 24, 2025
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June 24, 2025
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4
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EXHIBIT(S) - 1 Memorandum of Agreement between NCPD and ICE regarding 287(g) Task Force Model
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June 24, 2025
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June 24, 2025
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5
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EXHIBIT(S) - 2 Delegation of Immigration Authority Section 287(g) Immigration and Nationality Act, Immigration and ... show more
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June 24, 2025
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June 24, 2025
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6
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EXHIBIT(S) - 3 ERO Facts 287(g) Task Force Model, Immigration and Customs Enforcement [Mar 2025]
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June 24, 2025
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June 24, 2025
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7
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EXHIBIT(S) - 4 N.J. Attorney General Law Enforcement Directive No. 2018-6 v2.0 [Sept 27, 2019]
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June 24, 2025
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June 24, 2025
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8
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EXHIBIT(S) - 5 Office of the New York State Attorney General, Guidance Concerning Local Authorities Participation i ... show more
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June 24, 2025
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June 24, 2025
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9
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EXHIBIT(S) - 6 Nassau County Admin. Order 20-003
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June 24, 2025
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June 24, 2025
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10
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EXHIBIT(S) - 7 Geoff Dempsey, Nassau Police Stop Detaining Immigrants for ICE: Report, Patch, March 12, 2020
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June 24, 2025
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June 24, 2025
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11
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EXHIBIT(S) - 8 Letter of Findings, United States Investigation of the Maricopa County Sheriffs Office [Dec. 15, 201 ... show more
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June 24, 2025
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June 24, 2025
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12
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EXHIBIT(S) - 9 Independent Monitor for the Maricopa County Sheriffs Office: Third Quarter 2024 [Mar. 31, 2025]
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June 24, 2025
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June 24, 2025
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13
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EXHIBIT(S) - 10 Letter of Findings, United States Investigation of the Alamance County Sheriffs Office [Sept. 18, 20 ... show more
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June 24, 2025
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June 24, 2025
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14
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EXHIBIT(S) - 11 Mai Thi Nguyen and Hannah Gill, The 287(g) Program: The Costs and Consequences of Local Immigration ... show more
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June 24, 2025
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June 24, 2025
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15
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EXHIBIT(S) - 12 Huyen Pham & Pham H. Van, Sheriffs, State Troopers, and the Spillover Effects of Immigration Policin ... show more
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June 24, 2025
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June 24, 2025
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16
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EXHIBIT(S) - 13 FY 2012: ICE announces year-end removal numbers, highlights focus on key priorities and issues new n ... show more
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June 24, 2025
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June 24, 2025
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17
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EXHIBIT(S) - 14 Thomas Maier & Ann Choi, Unequal justice: Racial disparity in arrests, sentencings on LI, Newsday (O ... show more
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June 24, 2025
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June 24, 2025
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18
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EXHIBIT(S) - 15 Michael OKeeffe, Black people and Latinos in Nassau arrested at significantly higher rates than whit ... show more
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June 24, 2025
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June 24, 2025
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19
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EXHIBIT(S) - 16 Kevin Vesey, Nassau County Executive Bruce Blakeman affirms support for mass deportation policy, vow ... show more
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June 24, 2025
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June 24, 2025
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20
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EXHIBIT(S) - 17 Kiran Dhillon & Matthew Euzarraga, Nassau County Executive confirms cooperation with ICE for migrant ... show more
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June 24, 2025
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June 24, 2025
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21
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EXHIBIT(S) - 18 Erin Pflaumer & Arrianee LeBaeu, Nassau police to help ICE detain undocumented immigrants accused of ... show more
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June 24, 2025
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June 24, 2025
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22
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EXHIBIT(S) - 19 Bruce Blakeman, ICE partnership targets criminals to keep Nassau safe, LI Herald [Mar 7, 2025]
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June 24, 2025
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June 24, 2025
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23
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EXHIBIT(S) - 20 Brandon Cruz et. al., Inside Nassau Countys anti-sanctuary deal with Trump where local cops will cra ... show more
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June 24, 2025
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June 24, 2025
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24
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EXHIBIT(S) - 21 Nassau County Police Department Strat-Com Comparison Report
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June 24, 2025
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June 24, 2025
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25
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EXHIBIT(S) - 22 Steven Ross Johnson, The Safest Communities in America, U.S. News and World Report [Aug. 6, 2024]
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June 24, 2025
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June 24, 2025
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26
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EXHIBIT(S) - 23 Facebook Post of Nassau County Executive Bruce Blakeman [Apr 29, 2025]
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June 24, 2025
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June 24, 2025
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27
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EXHIBIT(S) - 24 Debunking the Myth of Immigrants and Crime, American Immigration Council [Oct. 2024]
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June 24, 2025
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June 24, 2025
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28
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EXHIBIT(S) - 25 Brianna Seid, Rosemary Nidiry, and Ram Subramanian, Debunking the Myth of the Migrant Crime Wave, Br ... show more
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June 24, 2025
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June 24, 2025
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29
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EXHIBIT(S) - 26 Affidavit of Jessica Greenberg
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June 24, 2025
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June 24, 2025
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30
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EXHIBIT(S) - 27 Affidavit of John Christopher Ballard
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June 24, 2025
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June 24, 2025
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31
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EXHIBIT(S) - 28 Affidavit of Maryse Lamercie Emmanuel-Garcy
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June 24, 2025
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June 24, 2025
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32
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EXHIBIT(S) - 29 Affidavit of Marie A. Tatro
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June 24, 2025
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June 24, 2025
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33
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EXHIBIT(S) - 30 Affidavit of Marc Soto
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June 24, 2025
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June 24, 2025
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34
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EXHIBIT(S) - 31 Affidavit of John Doe Redacted per 22 NYCRR §202.5(e)
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June 24, 2025
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June 24, 2025
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35
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MEMORANDUM OF LAW IN SUPPORT Memorandum of Law in Support of Petitioners' Motion for a Preliminary Injunction
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June 24, 2025
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June 24, 2025
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36
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SUPPORTING PLEADINGS Application for Index Number
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June 24, 2025
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June 24, 2025
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37
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RJI -RE: ORDER TO SHOW CAUSE *Corrected*
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June 24, 2025
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June 24, 2025
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38
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ORDER TO SHOW CAUSE (Motion #001) By Danberg Biggs, R.Related ARTICLE 78 (BODY OR OFFICER) Documents: 2, 41, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55.+ Related
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June 30, 2025
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June 30, 2025
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39
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NOTICE OF APPEARANCE (POST RJI)
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June 30, 2025
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June 30, 2025
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40
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NOTICE OF APPEARANCE (POST RJI)
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July 1, 2025
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July 1, 2025
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41
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AFFIRMATION/AFFIDAVIT OF SERVICE (Motion #001) By Danberg Biggs, R.Related ARTICLE 78 (BODY OR OFFICER) Documents: 2, 38, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55.+ Related
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July 8, 2025
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July 8, 2025
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42
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LETTER / CORRESPONDENCE TO JUDGE Danberg Biggs Letter of Withdrawal - Attorney Appearance
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July 21, 2025
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July 21, 2025
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43
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NOTICE OF APPEARANCE (POST RJI)
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July 22, 2025
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July 22, 2025
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44
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NOTICE OF APPEARANCE (POST RJI) Notice of Appearance of John McEntee
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Aug. 7, 2025
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Aug. 7, 2025
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45
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NOTICE OF APPEARANCE (POST RJI) Notice of Appearance of Kathryn Cole
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Aug. 7, 2025
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Aug. 7, 2025
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46
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ANSWER IN SPECIAL PROCEEDING (Motion #001) Verified Answer to Verified Petition By Danberg Biggs, R.Related ARTICLE 78 (BODY OR OFFICER) Documents: 2, 38, 41, 47, 48, 49, 50, 51, 52, 53, 54, 55.+ Related
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Aug. 29, 2025
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Aug. 29, 2025
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47
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AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO ORDER TO SHOW CAUSE (Motion #001) Christopher Todd Affirmation in Opposition to Verified Petition By Danberg Biggs, R.Related ARTICLE 78 (BODY OR OFFICER) Documents: 2, 38, 41, 46, 48, 49, 50, 51, 52, 53, 54, 55.+ Related
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Aug. 29, 2025
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Aug. 29, 2025
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48
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AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO ORDER TO SHOW CAUSE (Motion #001) Affirmation of John P. McEntee in Opposition to the Verified Petition and request for a preliminary ... show more By Danberg Biggs, R.Related ARTICLE 78 (BODY OR OFFICER) Documents: 2, 38, 41, 46, 47, 49, 50, 51, 52, 53, 54, 55.+ Related
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Aug. 29, 2025
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Aug. 29, 2025
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49
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EXHIBIT(S) - A (Motion #001) Exhibit A-Proposed Legislation in the NYS Legislature entitled the "Dignity Not Detention Act" By Danberg Biggs, R.Related ARTICLE 78 (BODY OR OFFICER) Documents: 2, 38, 41, 46, 47, 48, 50, 51, 52, 53, 54, 55.+ Related
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Aug. 29, 2025
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Aug. 29, 2025
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50
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EXHIBIT(S) - B (Motion #001) Exhibit B-Proposed Legislation in the NYS Legislature entitled the "New York for All Act" By Danberg Biggs, R.Related ARTICLE 78 (BODY OR OFFICER) Documents: 2, 38, 41, 46, 47, 48, 49, 51, 52, 53, 54, 55.+ Related
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Aug. 29, 2025
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Aug. 29, 2025
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51
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EXHIBIT(S) - C (Motion #001) Exhibit C-Transcript of New York Civil Liberties Union Podcast By Danberg Biggs, R.Related ARTICLE 78 (BODY OR OFFICER) Documents: 2, 38, 41, 46, 47, 48, 49, 50, 52, 53, 54, 55.+ Related
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Aug. 29, 2025
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Aug. 29, 2025
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52
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MEMORANDUM OF LAW IN OPPOSITION (Motion #001) Respondent's Memorandum of Law in Opposition to Verified Petition and Motion for Preliminary Injunct ... show more By Danberg Biggs, R.Related ARTICLE 78 (BODY OR OFFICER) Documents: 2, 38, 41, 46, 47, 48, 49, 50, 51, 53, 54, 55.+ Related
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Aug. 29, 2025
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Aug. 29, 2025
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53
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MEMORANDUM OF LAW IN REPLY (Motion #001) Reply Memorandum of Law in Support of Petitioners' Motion for a Preliminary Injunction By Danberg Biggs, R.Related ARTICLE 78 (BODY OR OFFICER) Documents: 2, 38, 41, 46, 47, 48, 49, 50, 51, 52, 54, 55.+ Related
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Sept. 5, 2025
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Sept. 5, 2025
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54
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LETTER / CORRESPONDENCE TO JUDGE (Motion #001) By Danberg Biggs, R.Related ARTICLE 78 (BODY OR OFFICER) Documents: 2, 38, 41, 46, 47, 48, 49, 50, 51, 52, 53, 55.+ Related
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Sept. 5, 2025
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Sept. 5, 2025
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55
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LETTER / CORRESPONDENCE TO JUDGE (Motion #001) Letter Opposing Oral Argument Request By Danberg Biggs, R.Related ARTICLE 78 (BODY OR OFFICER) Documents: 2, 38, 41, 46, 47, 48, 49, 50, 51, 52, 53, 54.+ Related
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Sept. 8, 2025
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Sept. 8, 2025
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