Carter v. The City of Montgomery et al (JOINT ASSIGN)
Court Docket Sheet

2:2015-cv-00555 (almd)

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Description
1
08/03/2015
CLASS ACTION COMPLAINT against Branch D. Kloess, The City of Montgomery (Filing fee $ 400.00 receipt number 4602037820.), filed by Aldaress Carter.
1
Exhibit 1
2
Exhibit 2
3
Exhibit 3
4
Exhibit 4
5
Exhibit 5
6
Exhibit 6
7
Exhibit 7
8
Exhibit 8
9
fee receipt
9 Attachments
08/03/2015
DEMAND for Trial by Jury by Aldaress Carter. (NO PDF document attached to this notice-see Docket Entry 1). (Text entry; no document attached.)
2
08/03/2015
Corporate/Conflict Disclosure Statement by Aldaress Carter.
3
08/03/2015
Summons Issued as to Branch D. Kloess, The City of Montgomery and returned to counsel for personal service on defendant.
4
08/03/2015
SUMMONS Returned Executed by Aldaress Carter. The City of Montgomery served by process server on 8/3/2015 signed by Dennis Potter, answer due 8/24/2015.
5
08/03/2015
SUMMONS Returned Executed by Aldaress Carter. Branch D. Kloess served by process server on 8/3/2015 signed by Carol Kloess, answer due 8/24/2015.
08/05/2015
Case reassigned to Honorable Judge Wallace Capel, Jr. Honorable Judge Charles S. Coody no longer assigned to the case as referral judge. (NO PDF Document attached to this notice). (Text entry; no document attached.)
6
08/05/2015
Case reassigned to Chief Judge William Keith Watkins. Honorable Judge W. Harold Albritton, III no longer assigned to the case as presiding judge.
7
08/10/2015
NOTICE of Appearance by Maurine C. Evans on behalf of Aldaress Carter
8
08/24/2015
MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by The City of Montgomery.
9
08/24/2015
MOTION Motion for a Briefing Schedule on 8 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by The City of Montgomery. Modified on 8/25/2015 to clarify text to reflect as Motion for briefing schedule (qc/djy,).
10
08/24/2015
MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Branch D. Kloess.
11
08/24/2015
MOTION to Sever by Branch D. Kloess.
12
08/24/2015
MOTION for the court to enter a briefing schedule re 10 MOTION TO DISMISS, and 11 MOTION to Sever by Branch D. Kloess. Modified on 8/25/2015 to clarify text to reflect as a motion to enter briefing schedule (qc/djy,).
08/24/2015
***Attorney Robert David Segall,Joel Thomas Caldwell for The City of Montgomery added pursuant to 8 motion to dismiss (NO PDF document attached to this notice). (Text entry; no document attached.)
13
08/25/2015
Notice of Deficiency requiring filing of Corporate Disclosure/Conflict Statement sent to The City of Montgomery; Corporate Disclosures due by 9/4/2015.
1
standing order and format
1 Attachment
14
08/25/2015
Notice of Deficiency requiring filing of Corporate Disclosure/Conflict Statement sent to Branch D. Kloess; Corporate Disclosures due by 9/4/2015.
1
standing order and format
1 Attachment
15
08/25/2015
Corporate/Conflict Disclosure Statement by The City of Montgomery re 13 Notice of Deficiency requiring filing of Corporate Disclosure/Conflict Statement.
16
09/02/2015
Corporate/Conflict Disclosure Statement by Branch D. Kloess re 14 Notice of Deficiency requiring filing of Corporate Disclosure/Conflict Statement.
17
09/04/2015
ORDER GRANTING City of Montgomery's 9 MOTION for a Briefing Schedule as follows: (1) that, on or before 10/1/2015 def City of Montgomery shall file a brief in support of its 8 motion to dismiss, (2) that, no later than 21 days after def's intial brief is filed, plf shall file a brief in response the def City of Montgomery's motion to dismiss; and (3) def City of Montgomery shall file a brief in reply to plf's brief no later than 14 days after plf's response brief is filed; FURTHER ORDERING that def Kloess's 12 MOTION for briefing schedule is GRANTED as follows: (1) that, on or before 10/1/2015, def Kloess shall file a single brief in support of his 10 motion to dismiss and 11 motion to sever; (2) that, no later than 21 days after def Kloess's initial brief is filed, plf shall file a brief in response to Kloess's motion to dismiss and motion to sever; and (3) def Kloess hsall file a brief in reply to plf's brief no later than 14 days after plf's response brief is filed, as further set out in order; for all future motions to dismiss, motions for judgment on the pleadings, motions for summary judgment, and Daubert motions filed in this case, setting briefing schedule, as further set out in order. Signed by Chief Judge William Keith Watkins on 9/4/15.
18
09/14/2015
AMENDED COMPLAINT FIRST AMENDED COMPLAINT against Judicial Correction Services, Inc., Correctional Healthcare Companies, Inc., CHC Companies, Inc., filed by Aldaress Carter.
1
Supplement Part 2 of Amended Complaint
2
Supplement Park 3 of Amended Complaint
2 Attachments
09/14/2015
DEMAND for Trial by Jury by Aldaress Carter. (NO PDF Document attached to this notice-See Docket entry 18). (Text entry; no document attached.)
19
09/16/2015
ORDER directing (1) the 8 MOTION TO DISMISS filed by The City of Montgomery is DENIED without prejudice to file a motion to dismiss in response to the amended complaint; (2) that def Kloess's 10 MOTION TO DISMISS is DENIED without prejudice to file a motion to dismiss in response to the amended complaint; (3) that def Kloess's 11 MOTION to Sever is DENIED without prejudice; and (4) that the briefing deadlines on def City of Montgomery's 8 motion to dismiss, def Kloess's 10 motion to dismiss, and def Kloess's 11 motion to sever, which were previously set by the Court's 17 order are CANCELLED; all other provisions of the 17 Order including all briefing requirements for future motions filed in this case, remain in effect. Signed by Chief Judge William Keith Watkins on 9/16/15.
20
09/16/2015
MOTION for Extension of Time to File Response/Reply as to 18 Amended Complaint, by The City of Montgomery.
21
09/17/2015
Summons Issued as to Correctional Healthcare Companies, Inc. and mailed CMRRR with copy of amended complaint.
22
09/17/2015
TEXT ORDER GRANTING 20 MOTION for Extension of Time; EXTENDING time for The City of Montgomery to respond to the complaint to and including 10/15/2015. Signed by Chief Judge William Keith Watkins on 9/17/15. (NO PDF document attached to this notice).
23
09/15/2015
Summons Issued as to CHC Companies, Inc., Judicial Correctional Services, Inc. and returned to counsel for personal service on the defendants.
24
09/25/2015
MOTION for Extension of Time to File Response/Reply as to 18 Amended Complaint, by Branch D. Kloess.
25
09/28/2015
TEXT ORDER GRANTING 24 MOTION for Extension of Time to File Response; and extending the time for def Branch D. Kloess to respond to the amended complaint to and including 10/15/2015. Signed by Chief Judge William Keith Watkins on 9/28/15. (NO PDF Document attached to this notice).
26
09/28/2015
Return Receipt Card showing service of summons & amended complaint signed by (illegible) for Correctional Healthcare Companies, Inc. served on 9/21/2015, answer due 10/13/2015.
27
09/30/2015
SUMMONS Returned Executed by Aldaress Carter. Judicial Correctional Services, Inc. served on 9/24/2015, answer due 10/15/2015.
28
09/30/2015
SUMMONS Returned Executed by Aldaress Carter. CHC Companies, Inc. served on 9/24/2015, answer due 10/15/2015.
29
10/13/2015
MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Correctional Healthcare Companies, Inc., Judicial Correctional Services, Inc.
30
10/13/2015
MOTION for Briefing Schedule on Defendant Judicial Correction Services, Inc.'s and Correctional Healthcare Companies, Inc.'s Motion to Dismiss by Correctional Healthcare Companies, Inc., Judicial Correctional Services, Inc.
10/13/2015
***Attorney Wesley Kyle Winborn for Correctional Healthcare Companies, Inc.,Wesley Kyle Winborn for Judicial Correctional Services, Inc. added pursuant to 29 motion (NO PDF document attached to this notice). (Text entry; no document attached.)
31
10/14/2015
Corporate/Conflict Disclosure Statement by Correctional Healthcare Companies, Inc.
32
10/14/2015
Corporate/Conflict Disclosure Statement by Judicial Correctional Services, Inc.
33
10/15/2015
ORDER GRANTING 30 MOTION for Briefing Schedule as follows: (1) on or before 11/12/2015 defs Judicial Correction Services, Inc., and Correctional Healthcare Companies, Inc., shall file a brief in support of the 29 motion to dismiss; (2) no later than 21 days after defs' initial brief is file, plf shall file a brief in response to the 29 motion to dismiss; and (3) defs Judicial Correction Services, Inc., and Correctional Healthcare Companies, Inc., shall file a brief in reply to plf's brief no later than 14 days after plf's response brief is filed, as further set out in order; BRIEFING ORDER for all future motions to dismiss, motions for judgment on the pleadings, motions for summary judgment, and Daubert motions filed in this case, setting briefing scheduled as further set out in order. Signed by Chief Judge William Keith Watkins on 10/15/15.
34
10/15/2015
MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM [MOTION TO DISMISS FIRST AMENDED AND RESTATED COMPLAINT] by Branch D. Kloess.
35
10/15/2015
MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by The City of Montgomery.
36
10/15/2015
BRIEF/MEMORANDUM in Support re 35 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by The City of Montgomery.
37
10/27/2015
MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by CHC Companies, Inc.
38
10/27/2015
Corporate/Conflict Disclosure Statement by CHC Companies, Inc.
10/27/2015
***Attorney Brian C. Richardson for CHC Companies, Inc. added pursuant to 37 motion to dismiss (NO PDF Document attached to this notice). (Text entry; no document attached.)
39
11/05/2015
RESPONSE in Opposition re 34 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM [MOTION TO DISMISS FIRST AMENDED AND RESTATED COMPLAINT] PLAINTIFFS RESPONSE IN OPPOSITION TO KLOESS MOTION TO DISMISS FIRST AMENDED & RESTATED COMPLAINT filed by Aldaress Carter.
40
11/05/2015
RESPONSE in Opposition re 35 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM Plaintiff's Responsive Brief in Opposition to the City of Montgomerys Motion to Dismiss filed by Aldaress Carter.
41
11/12/2015
BRIEF/MEMORANDUM in Support re 29 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Correctional Healthcare Companies, Inc., Judicial Correctional Services, Inc.
42
11/12/2015
REPLY BRIEF re 40 Response in Opposition to Motion City's Brief in Opposition to Carter's Response to the City's Brief in Support of Its Motion to Dismiss filed by The City of Montgomery.
43
11/17/2015
(STRICKEN pursuant to 46 ORDER) BRIEF/MEMORANDUM in Support re 37 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by CHC Companies, Inc. Modified on 11/24/2015 (qc/djy,).
44
11/17/2015
MOTION to Strike 43 BRIEF/MEMORANDUM in Support MOTION TO STRIKE CHC COMPANIES, INC.S SUPPLEMENT TO MOTION TO DISMISS (DOC. 43) by Aldaress Carter.
45
11/17/2015
RESPONSE in Opposition re 37 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM PLAINTIFFS RESPONSE IN OPPOSITION TO CHC COMPANIES, INC.S MOTION TO DISMISS FIRST AMENDED COMPLAINT filed by Aldaress Carter.
11/17/2015
(STRICKEN pursuant to 46 ORDER) SUPPLEMENT to 37 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by CHC Companies, Inc. (No pdf attached to this entry - See doc 43 for pdf) Modified on 11/24/2015. (Text entry; no document attached.)
46
11/24/2015
ORDER directing : (1) that the 44 MOTION to Strike is GRANTED; (2) that CHC's 43 supplemental brief is STRICKEN; (3) that, on or before 12/7/2015, def CHC shall file a motion for leave to file a supplement to its motion to dismiss and shall show cause why the motion for leave to file should be granted; and (4) pending the court's ruling on CHC's forthcoming motion for leave to file, the deadline for CHC to file a reply to plf's response brief is suspended, as further set out in order. Signed by Chief Judge William Keith Watkins on 11/24/15.
47
11/25/2015
MOTION for Leave to File a Supplement to Motion to Dismiss by CHC Companies, Inc.
48
12/03/2015
RESPONSE in Opposition re 29 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM Plaintiffs Response in Opposition to Judicial Correction Services & Correctional Healthcare Companies, Inc.S Motion to Dismiss filed by Aldaress Carter.
49
12/07/2015
ORDER granting 47 Motion for Leave to File a supplement to the motion to dismiss; further ORDERING: (1) that on or before 12/9/2015 def CHC shall file a supplemental motion to dismiss; (2) that, no later than 21 days after def CHC's supplemental motion is filed, plf shall file a brief in response to thesupplemental motion; and (3) that, within 7 days of the filing of plf's response to the supplemental motion, def CHC may file a single reply to both of plfs' briefs, as further set out in order. Signed by Chief Judge William Keith Watkins on 12/7/15.
50
12/17/2015
REPLY BRIEF re 29 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM, 41 BRIEF/MEMORANDUM in Support filed by Correctional Healthcare Companies, Inc., Judicial Correctional Services, Inc.
51
12/21/2015
ORDERED that, on or before 12/29/2015, Dft CHC may file a reply to Plf's 45 response to Dft CHC's 37 motion to dismiss. Signed by Chief Judge William Keith Watkins on 12/21/2015.
52
12/29/2015
REPLY to plf's 45 Response to 37 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by CHC Companies, Inc. Modified on 12/30/2015 to clarify text to reflect as a REPLY to 45 response (qc/djy,).
53
01/05/2016
MOTION to Stay Discovery and Incorporated Brief in Support by CHC Companies, Inc.
54
01/06/2016
MOTION to Stay Discovery by Correctional Healthcare Companies, Inc., Judicial Correctional Services, Inc.
55
01/07/2016
ORDER directing that on or before 1/15/2016, plf and all other defs shall file responses to the 53 and 54 MOTIONS to Stay Discovery. Signed by Chief Judge William Keith Watkins on 1/7/16.
56
01/07/2016
MOTION to Stay re 53 MOTION to Stay Discovery and Incorporated Brief in Support by The City of Montgomery.
57
01/12/2016
CONSOLIDATED RESPONSE in Opposition re 54 MOTION to Stay Discovery, 56 MOTION to Stay re 53 MOTION to Stay Discovery and Incorporated Brief in Support, 53 MOTION to Stay Discovery and Incorporated Brief in Support Plaintiffs Consolidated Response in Opposition to Defendants Motions to Stay Discovery filed by Aldaress Carter. Modified on 1/13/2016 to clarify text to reflect as CONSOLIDATED RESPONSE (qc/djy,).
58
01/15/2016
RESPONSE to Motion re 54 MOTION to Stay Discovery, 53 MOTION to Stay Discovery and Incorporated Brief in Support filed by The City of Montgomery.
59
01/15/2016
RESPONSE to Motion re 54 MOTION to Stay Discovery, 56 MOTION to Stay re 53 MOTION to Stay Discovery and Incorporated Brief in Support, 53 MOTION to Stay Discovery and Incorporated Brief in Support [DEFENDANT BRANCH D. KLOESS'S RESPONSE TO MOTIONS TO STAY] filed by Branch D. Kloess.
60
02/09/2016
NOTICE of Additional Authority in support of defendant's 56 MOTION to Stay re 53 MOTION to Stay Discovery and Incorporated Brief in Support by The City of Montgomery.
1
Exhibit
2
https://ecf.almd.uscourts.gov/doc1/01712626599" onClick="goDLS{{'/doc1/01712626599','57991','245','','2','1','',''}};">2</a> Exhibit) Modified on 2/10/2016 to clarify text to reflect as a NOTICE not a MOTION document (qc/djy,)
2 Attachments
61
05/02/2016
ORDER (1) STAYING CASE, including all discovery, until further order; (2) the 53] MOTION to Stay discovery filed by def CHC Companies, Inc. is GRANTED; (2) the 54 MOTION to Stay filed by defs Correctional Healthcare Companies, Inc., and Judicial Correctional Services, Inc. is GRANTED; (4) the 56 motion to stay discovery filed by Def City of Montgomery is GRANTED, as further set out in order. Signed by Chief Judge William Keith Watkins on 5/2/16.
62
06/15/2016
Case reassigned to Honorable Judge Royce C. Lamberth. Chief Judge William Keith Watkins no longer assigned to the case as presiding judge. (Main Document 62 replaced on 7/22/2016 to correct erroneous main PDF document) (qc/djy,).
63
07/20/2016
ORDER Setting Motion Hearing re: 29, 34, 35, and 37 MOTIONS TO DISMISS for 8/18/2016 @ 10:00 AM before Honorable Judge Royce C. Lamberth, in Courtroom 2F ; advising counsel that the Court shall also be hearing similar motions in cases, as further set out in order; the cases shall be heard in the order in which they were filed; counsel should be present for all hearings. Signed by Honorable Judge Royce C. Lamberth on 7/20/16. Furnished to calendar group & AR.
64
07/22/2016
MOTION to Continue Hearing by The City of Montgomery.
65
07/22/2016
NOTICE of Correction re 62 Case Assigned to correct erroneous main PDF document previously attached
1
corrected main document to Docket Entry
62
https://ecf.almd.uscourts.gov/doc1/01712692205" onClick="goDLS{{'/doc1/01712692205','57991','256','','2','1','',''}};">62</a>)
2 Attachments
66
08/11/2016
ORDER GRANTING 64 MOTION to Continue; and the Hearing re: 29, 34, 35, & 37 MOTIONS TO DISMISS is rescheduled for 8/18/2016 @ 01:00 PM in Courtroom 2F before Honorable Judge Royce C. Lamberth. Signed by Honorable Judge Royce C. Lamberth on 8/11/16. Furnished to calendar group & AR (previously set for 8/18/2016 @ 10 AM).
67
08/17/2016
NOTICE of Appearance by Wilson F. Green on behalf of Correctional Healthcare Companies, Inc., Judicial Correctional Services, Inc.
68
08/18/2016
Minute Entry for proceedings held before Honorable Judge Royce C. Lamberth: Motion Hearing held on 8/18/2016 re 29 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Correctional Healthcare Companies, Inc., Judicial Correctional Services, Inc., 37 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by CHC Companies, Inc., 34 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM [MOTION TO DISMISS FIRST AMENDED AND RESTATED COMPLAINT] filed by Branch D. Kloess, 35 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by The City of Montgomery (PDF available for court use only). (Court Reporter Patricia G. Starkie.)
69
09/21/2016
MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT TO DECLARE THE CITY OF MONTGOMERYS PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL PROTECTION by Aldaress Carter.
70
09/21/2016
BRIEF/MEMORANDUM in Support re 69 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT TO DECLARE THE CITY OF MONTGOMERYS PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL PROTECTION filed by Aldaress Carter.
71
09/21/2016
MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT DECLARING THE CONTRACT BETWEEN JCS & MONTGOMERY VOID AB INITIO by Aldaress Carter.
72
09/21/2016
BRIEF/MEMORANDUM in Support re 71 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT DECLARING THE CONTRACT BETWEEN JCS & MONTGOMERY VOID AB INITIO filed by Aldaress Carter.
73
09/22/2016
Evidentiary Submission re 69 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT TO DECLARE THE CITY OF MONTGOMERYS PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL PROTECTION, 70 BRIEF/MEMORANDUM in Support, 71 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT DECLARING THE CONTRACT BETWEEN JCS & MONTGOMERY VOID AB INITIO, 72 BRIEF/MEMORANDUM in Support filed by Aldaress Carter.
1
Exhibit 1 - 4/1/14 Deposition of Kenneth Nixon and exhibits
2
Exhibit 2 - 4/29/14 Deposition of Les Hayes
3
Exhibit 3 - 6/20/14 Deposition of Colleen Ray and exhibits Part 1
4
Exhibit 3 - 6/20/14 Deposition of Colleen Ray Part 2
5
Exhibit 3 - 6/20/14 Deposition of Colleen Rayand exhibits and exhibits Part 3
6
Exhibit 3 - 6/20/14 Deposition of Colleen Rayand exhibits Part 4
7
Exhibit 3 - 6/20/14 Deposition of Colleen Ray and exhibits Part 5
8
Exhibit 4 - 4/14/15 Deposition of Colleen Ray and exhibits
9
Exhibit 5 - 6/25/14 Deposition of Lisha Kidd and exhibits Part 1
10
Exhibit 5 - 6/25/14 Deposition of Lisha Kidd Part 2
11
Exhibit 5 - 6/25/14 Deposition of Lisha Kidd and exhibits Part 3
12
Exhibit 6 - 4/20/15 Deposition of Lisha Kidd and Exhibits Part 1
13
Exhibit 6 - 4/20/15 Deposition of Lisha Kidd and exhibits Part 2
14
Exhibit 7 - 9/1/15 Deposition of Lisha Kidd and exhibits Part 1
15
Exhibit 7 - 9/1/15 Deposition of Lisha Kidd Part 2
16
Exhibit 8 - 9/12/16 Deposition of Don Houston
17
Exhibit 9 - JCS' Probation Order for Mr. Carter
18
Exhibit 10 - Petition for Revocation
19
Exhibit 11 - Email from Colleen Ray to Karen LLoyd
20
Exhibit 12 - Montomgery Municipal Code
21
SEALED- Exhibit 13 - Agreement and Plan of Merger filed under seal
22
https://ecf.almd.uscourts.gov/doc1/01712750189" onClick="goDLS{{'/doc1/01712750189','57991','300','','2','1','',''}};">22</a> Exhibit 14 - JCS Marketing Materials) (Attachment 21 replaced on 9/23/2016 to add SEALED EXHIBIT 13) (qc/djy,)
22 Attachments
74
09/22/2016
MOTION for leave to file exhibit under Seal by Aldaress Carter.
1
Exhibit 13
1 Attachment
75
09/26/2016
MOTION to Strike 69 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT TO DECLARE THE CITY OF MONTGOMERYS PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL PROTECTION, 71 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT DECLARING THE CONTRACT BETWEEN JCS & MONTGOMERY VOID AB INITIO by Correctional Healthcare Companies, Inc., Judicial Correctional Services, Inc.
76
09/26/2016
MOTION to Strike 73 Evidentiary Submission, 69 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT TO DECLARE THE CITY OF MONTGOMERYS PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL PROTECTION, 70 BRIEF/MEMORANDUM in Support, 72 BRIEF/MEMORANDUM in Support, 71 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT DECLARING THE CONTRACT BETWEEN JCS & MONTGOMERY VOID AB INITIO by The City of Montgomery.
77
09/28/2016
RESPONSE to Motion re 76 MOTION to Strike 73 Evidentiary Submission, 69 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT TO DECLARE THE CITY OF MONTGOMERYS PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL, 75 MOTION to Strike 69 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT TO DECLARE THE CITY OF MONTGOMERYS PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL PROTECTION, 71 MOTION for Pa filed by Aldaress Carter.
78
10/06/2016
MOTION for Extension of Time to File Response/Reply as to 69 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT TO DECLARE THE CITY OF MONTGOMERYS PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL PROTECTION, 71 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT DECLARING THE CONTRACT BETWEEN JCS & MONTGOMERY VOID AB INITIO (Unopposed) by Correctional Healthcare Companies, Inc., Judicial Correctional Services, Inc.
79
10/12/2016
RESPONSE in Opposition re 71 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT DECLARING THE CONTRACT BETWEEN JCS & MONTGOMERY VOID AB INITIO filed by CHC Companies, Inc.
1
Exhibit A
2
Exhibit B, Part I
3
Exhibit B, Part II
4
Exhibit C
5
Exhibit D) (Additional attachment(s) added on 10/27/2016: #
6
REDACTED Exhibit B, Part I
6 Attachments
80
10/12/2016
[SEE CORRECTED DOCKET ENTRY DOC. 81.] RESPONSE in Opposition re 69 MOTION for Partial Summary Judgment TO DECLARE THE CITY OF MONTGOMERY'S PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL PROTECTION filed by Judicial Correctional Services, Inc. Modified on 10/14/2016 to reflect that Doc. 81 replaces Doc. 80.
81
10/12/2016
RESPONSE (Correcting Doc. 80) in Opposition re 69 MOTION for Partial Summary Judgment TO DECLARE THE CITY OF MONTGOMERY'S PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL PROTECTION filed by Judicial Correctional Services, Inc. Modified on 10/14/2016 to reflect that this document is correcting Doc. 80.
82
10/12/2016
Evidentiary Submission in Support of JCS's Responses in Opposition to Plaintiff's Motions for Partial Summary Judgment (Docs. 69, 70, 71, & 72) filed by Judicial Correctional Services, Inc. Modified on 10/14/2016 to create links to additional documents.
1
Exhibit A
2
Exhibit B
3
Exhibit C
4
Exhibit D
5
Exhibit E
6
Exhibit F
7
Exhibit G
8
Exhibit H
9
Exhibit I
9 Attachments
83
10/12/2016
RESPONSE in Opposition to Plaintiff's MOTION for Partial Summary Judgment DECLARING THE CONTRACT BETWEEN JCS & MONTGOMERY VOID AB INITIO (Docs. 71 & 72) filed by Judicial Correctional Services, Inc. Modified on 10/14/2016 to clean up text.
84
10/12/2016
RESPONSE in Opposition to PLAINTIFFS 69 MOTION FOR PARTIAL SUMMARY JUDGMENT TO DECLARE THE CITY OF MONTGOMERYS PROBATION PRACTICE WITH JCS UNCONSTITUTIONAL AS A DENIAL OF EQUAL PROTECTION, 71 MOTION for Partial Summary Judgment PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT DECLARING THE CONTRACT BETWEEN JCS & MONTGOMERY VOID AB INITIO AND MEMORANDA IN SUPPORT (Docs. 70 and 72) filed by The City of Montgomery. Modified on 10/20/2016 to create actual links to Docs. 70 & 72.
85
10/19/2016
MOTION for Leave to File CORRECTED RESPONSE IN OPPOSITION TO PLAINTIFF'S MOTIONS FOR SUMMARY JUDGMENT AND MEMORANDA IN SUPPORT THEREOF (Docs. 69, 70, 71, 72) by The City of Montgomery. Modified on 10/20/2016 to create links to Docs. 69-72.
1
Exhibit 1
1 Attachment
86
10/19/2016
NOTICE of Filing Supplemental Support (Affidavit) in further support of Opposition to Plaintiff's Motions for Partial Summary Judgment (Docs. 69 & 71) by The City of Montgomery re 84 Opposition Modified on 10/20/2016 to create links to Docs. 69 & 71.
1
Affidavit
1 Attachment
87
10/26/2016
MOTION to Strike DEFENDANT CHC COMPANIES EXPERT REPORT OF BRAD BISHOP by Aldaress Carter.
1
Exhibit A - Deposition of Brad Bishop and Exhibits
1 Attachment
88
10/26/2016
REPLY BRIEF re 83 Response in Opposition to Motion, to Plaintiffs Motion for Summary Judgment Declaring the Contract Between JCS & Montgomery Void Ab Initio filed by Aldaress Carter.
89
10/26/2016
BRIEF/MEMORANDUM in Support re 81 Response in Opposition to Motion, to Plaintiffs Motion for Summary Judgment To Declare the City of Montgomerys Probation Practice with JCS Unconstitutional as a Denial of Equal Protection filed by Aldaress Carter.
1
Exhibit A - Transcript of 10/20/16 hearing in Ray & Woods cases) Modified on 10/27/2016 to correct link to docket entry
80
https://ecf.almd.uscourts.gov/doc1/01712761502" onClick="goDLS{{'/doc1/01712761502','57991','330','','2','1','',''}};">80</a> (qc/djy,)
81
which replaced docket entry
3 Attachments
90
10/26/2016
BRIEF/MEMORANDUM in Support re 79 Response in Opposition to Motion, Plaintiffs Motion for Summary Judgment Declaring the Contract Between JCS & Montgomery Void Ab Initio filed by Aldaress Carter.
91
10/26/2016
BRIEF/MEMORANDUM in Support re 84 Response in Opposition to Motion, PLAINTIFFS REPLY TO MONTGOMERY IN SUPPORT OF HIS MOTIONS FOR SUMMARY JUDGMENT filed by Aldaress Carter.
92
10/26/2016
NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Motion Hearing Proceedings (PDF ACCESS RESTRICTED FOR 90 DAYS) held on August 18, 2016, before Judge Lamberth. Court Reporter/Transcriber Starkie, Telephone number 334-262-1221. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. NOTICE OF INTENT TO REQUEST REDACTION DUE WITHIN 7 BUSINESS DAYS. Redaction Request due 11/16/2016. Redacted Transcript Deadline set for 11/28/2016. Release of Transcript Restriction set for 1/24/2017. (Main Document 92 replaced on 10/27/2016 to correct typographic error in date in reporter certificate from 2015 to 2016) (qc/djy,).
93
01/11/2017
NOTICE by Aldaress Carter OF SUPPLEMENTAL AUTHORITY
1
Exhibit A - JIC Complaint
2
Exhibit B - Agreement
3
Exhibit C - Final Judgment
3 Attachments
94
01/16/2017
BRIEF/MEMORANDUM in Opposition re 85 MOTION for Leave to File CORRECTED RESPONSE IN OPPOSITION TO PLAINTIFF'S MOTIONS FOR SUMMARY JUDGMENT AND MEMORANDA IN SUPPORT THEREOF SUPPLEMENTAL SUBMISSION filed by The City of Montgomery.
95
02/20/2017
NOTICE by The City of Montgomery re 35 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM OF FILING SUPPLEMENTAL AUTHORITY
1
Exhibit 1
2
Exhibit 2
3
Exhibit 3
3 Attachments
96
02/23/2017
Supplemental Conflict Disclosure Statement by Judicial Correctional Services, Inc. Modified on 2/24/2017 to reflect actual title.
97
03/10/2017
MEMORANDUM OPINION, as further set out. Signed by Honorable Judge Royce C. Lamberth on 3/10/17.
98
03/10/2017
ORDER granting in part and denying in part 29, 34, 35, and 37 Motions to Dismiss; as stated in the memorandum opinion issued on this date, defs' motions are GRANTED with respect to claims eleven through fourteen; defs' motions are DENIED with respect to the remaining claims. Signed by Honorable Judge Royce C. Lamberth on 3/10/17.
1
civil appeals checklist
1 Attachment
99
03/10/2017
ORDER TO SHOW CAUSE by the parties as to why this case should not be consolidated with McCullough vs. City of Montgomery, 2:15cv462-RCL, as further set out in order; the parties are ORDERED to file within 14 days a memorandum stating any reasons the Court should not order the cases consolidated; notice of this order will also be posted on the docket in McCullough vs. City of Montgomery, 2:15cv463. Signed by Honorable Judge Royce C. Lamberth on 3/10/17.
100
03/24/2017
ANSWER to [18] Amended Complaint, by Correctional Healthcare Companies, Inc., Judicial Correctional Services, Inc.
101
03/24/2017
ANSWER to Complaint [Dft Branch D. Kloess's Answer to Plaintiff's First Amended and Restated Complaint (Doc 18)] by Branch D. Kloess.
102
03/24/2017
Reply to response to order to show cause re [99] Order to Show Cause, PLAINTIFFS RESPONSE TO ORDER TO SHOW CAUSE filed by Aldaress Carter.
1
Exhibit 1 - A McCullough Case file Report
2
Exhibit 2 - C Mooney Case File Report
3
Exhibit 3 - L Agee Case File Report
4
Exhibit 4 - A Edwards & K Jones Case File Repor
5
Exhibit 5 - M Johnson Case File Report
6
Exhibit 6 - H Caldwell Case File Report
6 Attachments
103
03/24/2017
RESPONSE TO ORDER TO SHOW CAUSE by Branch D. Kloess re [99] Order to Show Cause.
104
03/24/2017
MOTION to Sever [DEFENDANT BRANCH D. KLOESS'S MOTION TO SEVER] by Branch D. Kloess.
105
03/24/2017
ANSWER to [18] Amended Complaint, by CHC Companies, Inc.
106
03/24/2017
RESPONSE TO ORDER TO SHOW CAUSE by Judicial Correctional Services, Inc. re [99] Order to Show Cause.
107
03/24/2017
ANSWER to Complaint (Amended Complaint (Doc. 18) by The City of Montgomery.
108
03/24/2017
RESPONSE TO ORDER TO SHOW CAUSE by The City of Montgomery re [99] Order to Show Cause.
109
03/24/2017
RESPONSE TO ORDER TO SHOW CAUSE by CHC Companies, Inc. re [99] Order to Show Cause.
110
04/07/2017
RESPONSE in Opposition re [104] MOTION to Sever [DEFENDANT BRANCH D. KLOESS'S MOTION TO SEVER] filed by Aldaress Carter.
111
04/25/2017
ORDER: In light of the notices of appeal filed in 2:15-cv-463 (RCL) McCullough (143,144), the Court finds that consolidation of the captioned cases would not be beneficial at this time. The Court will readdress consolidation as necessary at a later time. Signed by Honorable Judge Royce C. Lamberth on 4/25/2017.
112
04/25/2017
ORDER: The Court hereby ORDERS that the parties shall meet and confer within ten (10) days of this case; and it is further ORDERED that, within ten (10) days thereafter, a report shall be filed with the Court, along with a proposed scheduling order. Signed by Honorable Judge Royce C. Lamberth on 4/25/2017.
113
04/26/2017
NOTICE of Appearance by Kimberly Owen Fehl on behalf of The City of Montgomery
114
04/26/2017
NOTICE of Appearance by Michael D. Brymer on behalf of The City of Montgomery
115
05/01/2017
MOTION for Leave to File SECOND AMENDED AND RESTATED COMPLAINT AND MEMORANDUM OF LAW IN SUPPORT by Aldaress Carter.
1
Exhibit A - Second Amended & Restated Complaint
1 Attachment
116
05/02/2017
MOTION to Certify Class by Aldaress Carter.
117
05/02/2017
BRIEF/MEMORANDUM in Support re [116] MOTION to Certify Class filed by Aldaress Carter.
118
05/02/2017
Evidentiary Submission re [117] BRIEF/MEMORANDUM in Support, [116] MOTION to Certify Class filed by Aldaress Carter.
1
Exhibit 1 - Composite Summary
2
Exhibit 2- APT_Payment Types printed from JCS Table PaymentTypes
3
Exhibit 3 - APT_StatusCodes and StatusActions printed from JCS Tables
4
Exhibit 4 - Part 1 - JCS Modification of Termination Forms signed by Montgomery
5
Exhibit 4 - Part 2 - JCS Modification of Termination Forms signed by Montgomery
6
Exhibit 4 - Part 3 - JCS Modification of Termination Forms signed by Montgomery
7
Exhibit 4 - Part 4 - JCS Modification of Termination Forms signed by Montgomery
8
Exhibit 4 - Part 5 - JCS Modification of Termination Forms signed by Montgomery
9
Exhibit 4 - Part 6 - JCS Modification of Termination Forms signed by Montgomery
10
Exhibit 5 - APT Status Details Table - Status = T time served since August 28, 2
11
Exhibit 6 - Part 1 - JCS Termed Case report showing all probationers terminated
12
Exhibit 6 - Part 2 - JCS Termed Case report showing all probationers terminated
13
Exhibit 7 - APT_Employer table information
14
Exhibit 8 - Aldaress Carters JCS cases
15
Exhibit 9 - JCS Fees Collected in Montgomery since August 28, 2010
16
Exhibit 10 - Affidavit of Aldaress Carter
17
Exhibit 11 - Affidavit of G. Daniel Evans
18
Exhibit 12 - Affidavit of Alexandria Parrish
19
Exhibit 13 - Deposition of Wes Ennis taken in Ray v. JCS case
20
Exhibit 14 - Exhibits 109-114 to Deposition of Wes Ennis
21
Exhibit 15 - Exhibits 32-34 to Deposition of Presiding Judge Les Hayes
22
Exhibit 16 - Deposition Judge Milton Westry and Exhibits
23
Exhibit 17 - APT_StatusCodes
23 Attachments
119
05/08/2017
RESPONSE to Motion re [116] MOTION to Certify Class filed by Judicial Correctional Services, Inc.
120
05/11/2017
RESPONSE to Motion re [116] MOTION to Certify Class filed by The City of Montgomery.
121
05/11/2017
RESPONSE in Opposition re [116] MOTION to Certify Class filed by CHC Companies, Inc.
122
05/15/2017
REPLY BRIEF re [121] Response in Opposition to Motion, [120] Response to Motion, [119] Response to Motion FOR CLASS CERTIFICATION filed by Aldaress Carter.
123
05/16/2017
REPORT of Rule 26(f) Planning Meeting.
124
05/16/2017
MOTION to Stay by The City of Montgomery.
1
Exhibit 1
1 Attachment
125
05/18/2017
RESPONSE in Opposition re [124] MOTION to Stay filed by Aldaress Carter.
126
05/30/2017
REPLY BRIEF re [124] MOTION to Stay IN SUPPORT OF filed by The City of Montgomery.
127
06/20/2017
MOTION to Compel by Aldaress Carter.
1
Exhibit A - 4/27/17 ltr to counsel and discovery requests to Montgomery
2
Exhibit B - 5/10/17 to the City&#039;s counsel
3
Exhibit C -Montgomery&#039;s responses to discovery
4
Exhibit D - 6/9/17 ltr to Holliday
5
Exhibit E - 6/13/17 ltr from Holliday
5 Attachments
128
06/23/2017
MOTION for Protective Order AND RESPONSE TO MOTION TO COMPEL DOCUMENTS (DOC. 127) by The City of Montgomery.
129
06/28/2017
RESPONSE in Opposition re [128] MOTION for Protective Order AND RESPONSE TO MOTION TO COMPEL DOCUMENTS (DOC. 127) filed by Aldaress Carter.
130
07/05/2017
REPLY BRIEF re [129] Response in Opposition to Motion IN SUPPORT OF MOTION FOR PROTECTIVE ORDER filed by The City of Montgomery.
131
08/09/2017
ORDER GRANTING defs' [124] MOTION to Stay further proceedings in this case is GRANTED, pending action by the Eleventh Circuit to resolve the issues before it in The City of Montgomery, Alabama, et al. v. Angela McCullough, et al., Case No. 17-11554 (11th Cir.), and Les Hayes, III v. Angela McCullough, et al., Case No. 17-11555 (11th Cir.). Signed by Honorable Judge Royce C. Lamberth on 8/9/17.
132
08/17/2017
ORDER denying without prejudice plfs' [69] Motion for Partial Summary Judgment; denying without prejudice plfs' [71] Motion for Partial Summary Judgment; denying as moot plfs' [74] Motion to Seal, and that the proposed sealed material is to be returned to the plf and not be made available for public display on the Court's CM/ECF system; denying as moot defs' [75] Motion to Strike, [76] Motion to Strike, [78] Motion for Extension of Time, and [85] Motion for Leave; and denying without prejudice plfs' [87] Motion to Strike. Signed by Honorable Judge Royce C. Lamberth on 8/16/17.
133
01/05/2018
MOTION TO LIFT STAY by Aldaress Carter.
134
01/10/2018
BRIEF/MEMORANDUM in Opposition re [133] MOTION TO LIFT STAY filed by The City of Montgomery.
135
01/12/2018
MOTION to Withdraw as Attorney by The City of Montgomery.
136
01/23/2018
REPLY BRIEF re [134] BRIEF/MEMORANDUM in Opposition REPLY IN SUPPORT OF PLAINTIFFS MOTION TO LIFT STAY filed by Aldaress Carter.
137
01/30/2018
REPLY BRIEF re [136] Reply Brief, SUR-REPLY TO PLAINTIFF'S REPLY IN SUPPORT OF PLAINTIFF'S MOTION TO LIFT STAY filed by The City of Montgomery.
138
03/13/2018
ORDER denying as moot [127] Motion to Compel and [128] Motion for Protective Order, as further set out in order. Signed by Honorable Judge Wallace Capel, Jr on 3/13/18.
139
03/30/2018
ORDER denying def Branch D. Kloess's [104] Motion to Sever, as further set out in order. Signed by Honorable Judge Royce C. Lamberth on 3/29/18.
140
07/20/2018
Memorandum Opinion and Order
141
07/20/2018
Order on Motion to Withdraw as Attorney
07/20/2018
*** Attorney Joel Thomas Caldwell terminated pursuant to [141] order (NO PDF Document attached to this notice). (Text entry; no document attached.)
142
07/20/2018
~Util - Terminate Motions
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