2:15-cv-00606-wkw: 156-main.pdf
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Case 2:15-cv-00606-WKW-SMD Document 156 Filed 07/30/18 Page 1 of 3
UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION
RECEIVED 1018 JUL 30 P 5: 01
JOHN DOE #1; JOHN DOE #3; JOHN DOE #7; JOHN DOE #9; and, JOHN DOE #10;
CFE3A P.:HACKETT. CLK COURT LiJSTEICi ALA
Plaintiffs, v. STEVEN T. MARSHALL, Attorney General ofthe State of Alabama in his official capacity;
No. 2:15-cv-606-WKW
HAL TAYLOR,Secretary ofthe Alabama Law Enforcement Agency, in his official capacity; and, CHARLES WARD,Director ofthe Alabama Department ofPublic Safety, in his official capacity Defendants. EVIDENTIARY SUBMISSION IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT Defendants Steve Marshall, Hal Taylor, and Charles Ward submit the following materials in support oftheir motion for summaryjudgment in this case:1 1.
Deposition ofJohn Doe #3 and Exhibits 1 through 7 thereto(UNDER SEAL).
2
Deposition ofJohn Doe #3's Niece and Exhibits 1 through 3 theretO(UNDER
SEAL). 3.
Declaration ofJeremy Bolton(UNDER SEAL).
4.
Deposition ofJohn Doe #7 and Exhibits 1 through 6 thereto(UNDER SEAL).
5.
Joint Stipulation ofthe Parties(UNDER SEAL).
I Pursuant to the Protective Order entered in this case,(doc. 73), certain designated materials are submitted under seal.
Case 2:15-cv-00606-WKW-SMD Document 156 Filed 07/30/18 Page 2 of 3
6.
Deposition ofJohn Doe #7's Sister and Exhibits 1 through 2 thereto(UNDER
SEAL). 7..
Deposition ofJohn Doe #7's Niece and Exhibits 1 through 4 thereto(UNDER
SEAL). 8.
Declaration of Nicholas Scurich.
9.
Deposition ofJeremy Jones and Exhibits A and C through F thereto.
10.
Deposition of Leigh Persky.
11.
Deposition of Derrick Bone and Exhibits A through B and D through E thereto
(UNDER SEAL). 12.
Deposition ofJeremy Bolton and EXhibits A and C through E thereto.
Respectfully submitted this 30th day ofJuly, 2018.
s/ Brad A. Chynoweth Brad A. Chynoweth(ASB-0030-S63K) Winfield J. Sinclair (ASB-1750-S81W) Assistant Attorneys General James R. Houts(ASB-1321-T77J) Deputy Attorney General State of Alabama Office ofthe Attorney General 501 Washington Avenue Montgomery, Alabama 36130 (334)242-7300 (334)353-8440(fax) [email protected] [email protected] [email protected] Counsel for Defendants
2
Case 2:15-cv-00606-WKW-SMD Document 156 Filed 07/30/18 Page 3 of 3
CERTIFICATE OF SERVICE I certify that on July 30, 2018, I filed the foregoing, including all exhibits with the Clerk of the Court. I further certify that the foregoing will be hand-delivered on July 31, 2018 to the offices of Plaintiffs' counsel:
Joseph Mitchell McGuire Bar No. ASB-8317-S69M McGuire & Associates, LLC 31 Clayton Street Montgomery, Alabama 36104 (334) 507-1000 phone (334) 517-1327 fax [email protected]
Of Counsel
3
UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION
RECEIVED 1018 JUL 30 P 5: 01
JOHN DOE #1; JOHN DOE #3; JOHN DOE #7; JOHN DOE #9; and, JOHN DOE #10;
CFE3A P.:HACKETT. CLK COURT LiJSTEICi ALA
Plaintiffs, v. STEVEN T. MARSHALL, Attorney General ofthe State of Alabama in his official capacity;
No. 2:15-cv-606-WKW
HAL TAYLOR,Secretary ofthe Alabama Law Enforcement Agency, in his official capacity; and, CHARLES WARD,Director ofthe Alabama Department ofPublic Safety, in his official capacity Defendants. EVIDENTIARY SUBMISSION IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT Defendants Steve Marshall, Hal Taylor, and Charles Ward submit the following materials in support oftheir motion for summaryjudgment in this case:1 1.
Deposition ofJohn Doe #3 and Exhibits 1 through 7 thereto(UNDER SEAL).
2
Deposition ofJohn Doe #3's Niece and Exhibits 1 through 3 theretO(UNDER
SEAL). 3.
Declaration ofJeremy Bolton(UNDER SEAL).
4.
Deposition ofJohn Doe #7 and Exhibits 1 through 6 thereto(UNDER SEAL).
5.
Joint Stipulation ofthe Parties(UNDER SEAL).
I Pursuant to the Protective Order entered in this case,(doc. 73), certain designated materials are submitted under seal.
Case 2:15-cv-00606-WKW-SMD Document 156 Filed 07/30/18 Page 2 of 3
6.
Deposition ofJohn Doe #7's Sister and Exhibits 1 through 2 thereto(UNDER
SEAL). 7..
Deposition ofJohn Doe #7's Niece and Exhibits 1 through 4 thereto(UNDER
SEAL). 8.
Declaration of Nicholas Scurich.
9.
Deposition ofJeremy Jones and Exhibits A and C through F thereto.
10.
Deposition of Leigh Persky.
11.
Deposition of Derrick Bone and Exhibits A through B and D through E thereto
(UNDER SEAL). 12.
Deposition ofJeremy Bolton and EXhibits A and C through E thereto.
Respectfully submitted this 30th day ofJuly, 2018.
s/ Brad A. Chynoweth Brad A. Chynoweth(ASB-0030-S63K) Winfield J. Sinclair (ASB-1750-S81W) Assistant Attorneys General James R. Houts(ASB-1321-T77J) Deputy Attorney General State of Alabama Office ofthe Attorney General 501 Washington Avenue Montgomery, Alabama 36130 (334)242-7300 (334)353-8440(fax) [email protected] [email protected] [email protected] Counsel for Defendants
2
Case 2:15-cv-00606-WKW-SMD Document 156 Filed 07/30/18 Page 3 of 3
CERTIFICATE OF SERVICE I certify that on July 30, 2018, I filed the foregoing, including all exhibits with the Clerk of the Court. I further certify that the foregoing will be hand-delivered on July 31, 2018 to the offices of Plaintiffs' counsel:
Joseph Mitchell McGuire Bar No. ASB-8317-S69M McGuire & Associates, LLC 31 Clayton Street Montgomery, Alabama 36104 (334) 507-1000 phone (334) 517-1327 fax [email protected]
Of Counsel
3
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