In Re

Case 6:12-bk-28006-MJ
Doc 208 Filed 10/24/12 Entered 10/25/12 10:59:31 Main Document Page 1 of 22
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ALTHEIA TAYLOR P . 0 . BOX 3 0 0 8 2 SAN BERNARDINO CA 92413 909 429-2656
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JAMES F. PENMAN
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CASE N0:6:12-bk-28006-mj OPPOSITION OBJECTION DAMAGE SETTLEMENT CHAPTER 9 NOTICE OF COMMENCEMENT OF CHAPTER 9 CASE LAW SUITE /CITY OF SAN BERNARDINO
CITY ATTORNEY
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ATTORNEYS FOR DEBTOR

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CITY OF SAN BERNARDINO

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IN RE
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CALIFORNIA
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DEBTOR
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JAMES F. PENMAN
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CITY ATTORNEY
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ATTORNEYS FOR DEBTOR

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Summary of Pleading - 1
Case 6:12-bk-28006-MJ
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DAMAGES
SETTLEMENT AMOUNT 5000.00 TO 6000.00
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GENERAL LIABILITY SPECITIC LIABILITY GENERAL INJURY SPECIFIC INJURY TYPE OF AWARD TRAIL COURTS
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TOTAL AWARD COMPENSATORY PAST MEDICAL PAIN AND SUFFERINGS APPELLATE COURTS CITATION COURT DEFENSE
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INVESTIGATION OF CLAIM
APPELEE ATTORNEYS: FEMALE
PLAINTIFF'S SEX:
EMOTIONAL DISTRESS POST TRAUMATC STRESS DISORDER GUN DRAWNDAMAGE EXCESSIVE FORCE PHYSICAL BRUTALITY PRISONERS POLICE MOTORCYCLE
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Case 6:12-bk-28006-MJ
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STOCKING VEHICLE HARASSMENT ( WHITE GRAY RED YELLOW BURGENCY GREEN ORANGE BLACK ) TRUCK METRO RED LINE METROLINK STOCKING FAMILY DISCRIMINATION FUTURE PAIN AND SUFFERING STOCKING HER FROM A LAW LIBRARARY 301 WEST FIRST STREET LOS ANGLES CA 90028 SLEEP ON CONCRETE IN COLD (HARASSMENT LIGHT BLUE) SLEEP UNION STATION 06/30/2011 /YELLOW SLEEP CONCRETE 06/01/2011-06/30/2011 COMPUTER / CONFIDENTIAL COPY DOCUMENT DAMAGE CAR / WINDOW / COMPUTER ( WINDSHIELD GUN SHOOT ) GUN / WINDSHIELD/ OFFICE CASAREZ S . INTERMITTEMENT SERVE EXCESSIVENSS ADEQUACY OF DAMAGES
A~ED
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FOR INJURIES TO HEAD OR
BRAIN/ HEADACHES INTERMITTENT SEVERE HEADACHES EXCESSIVENESS OR ADEQUACY OF DAMAGES

A~ED
FOR INJURIES TO NERVES OR NERVOUS
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SYSTEM EVERY DATE STOCKING GAME IN CAR /BUS PLAINTIFF VERY NERVOUS INJURIES BATHROOM
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Case 6:12-bk-28006-MJ
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DAMAGES CLAIMS DAMAGES PROPERTY / WINDOW VEHICLES DAMAGE TO CAR (MIRROR) COST OF REPLACEMENT OR REPAIR ( WINDSHIELD) LOSS OF EMPLOYMENT 50 TO 100 STATE EMPOYMENT LOS ANGLES POLICE DEPARTMENT PASADENA POLICE DEPARTMENT RIALTO POLICE DEPARTMENT/ 128 N WILLOW AVE RIALTO CA 92376 BODILY INJURY MAIN PHYSICAL INJURY SICKNESS DAMAGES MADE ASSAULT AND BATTERY STOLEN EVIDENCE / AUTO CAR BODILY INJURY / MEAN PHYSICAL INJURY SICKNESS DAMAGES MADE/ PSYCHOLOGICAL DAMAGES ASSAULT AND BATTERY STOLEN EVIDENCE / AUTO CAR LIKELY TO SUFFER INTERMITTENT PAIN FOR REST OF LIFE; OF MENTAL PAIN EMOTIONAL TRAUMA AND DISTRESS SUFFERING WAS INADEQUATE FOR HER PAST AND FUTURE PAIN AND RAISED THE AWARD TO $ 6,000 FOR PAIN AND SUFFERING
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ALTHEIA TAYLOR EXPERIENCED STOCKING EMOTIONAL TRAUMA CONSTANT EMOTIONAL STRESS BOTH SIDE OF HER LEG SLEEP ON CONCRETE
Case 6:12-bk-28006-MJ
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POINTS
AUTHORITIES
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Case 6:12-bk-28006-MJ
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THE APPELLATE COURT RULED THAT THE JURY'S $7,500 AWARD FOR PHYSICAL AND MENTAL PAIN AND SUFFERING WES INADEQUATE FOR HER PAST AND FURORE PAIN, AND RAISED THE AWARD TO $6,000 FOR PAIN AND SUFFERING.
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(DAMAGES 5, 000) FALSE ARREST AND FALSE IMPRISONMENT FALSE ARREST ARE DEFINED AS THE INTENDED AND UNJUSTIFIED PHYSICAL RES
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RAINT OF THE PERSON. THESE TORTS MAY BE COMMITTED BY A PRIVATE PARTY, SUCH AS MERCHANT OR SECURITY GUARD, BY A PRIVATE PARTY, SUCH AS MERCHANT OR SECURITY GUARD, OR BY A LAW ENFORCEMENT OFFICE. GOOD FAITH DOES NOT NECESSARITY NEGATE THE UNDERLYING TORT. HOWEVER, GOOD FAITH WILL NEGATE MAILICE OR WANTONESS, THUS PRECLUDING RECOVERY OF PUNITIVE DAMAGES SOME COURT EQUATE LACK OF PROBABLE CAUSE TO DETAIN THE PLAINTIFF WITH MALICE IN THE SENSE OF ILL-WILL OR INTENT TO INVADE THE PLAIN-
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TIFF'S RIGHTS CAUSE UNJURY. THE MANNER IN WHICH THE DEFENDANT TREATS THE PLAINTIFF MAY ESTABLISH AGGRAVATED CIRCUMSTANCES, INCLUDING EMPLOYING EXCESSIVE FORCOR INTRASIVE SEARCH TECHNIQUES, OR ACCUSING THE PLATIFF OF CRIMINAL
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Case 6:12-bk-28006-MJ
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OF THE STATES OF THE UNITED STATES THAT THE FORGOING ISW TRUE AND CORRECT.
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EXECUTED ON OCT 23, 2012 AT LOS ANGLES, CALIFORNIA.
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ALTHEIA TAYLOR
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I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE STATES OF THE UNITED STATES THAT THE FORGOINTG IS TRUE AND CORRECT.
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EXECUTED ON OCT 23, 2012 AT LOS ANGLES CALIFORNIA
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ALTHEIA TAYLOR
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PROOF OF SERVICE I, ALTHEIA TAYLOR, DECLARE AS FOLLOWS. I AM OVER THE AGE YEARS AND NOT A PARTY TO THIS PROCEEDING. MY ADDRESS IS P.O. BOX 30082 SAN BERNARDINO CA 92413
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ICase 6:12-bk-28006-MJ I I
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FILED
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ALTHEIA TAYLOR P.O. BOX 30082 SAN BERNARDINO CA 92413 909 429-2656
2012 AUG 13 PH 3: 34
UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA
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ALTHEIA TAYLOR
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) CASE NO: EDCV 09-240 MMM

) (MAN)
Plaintiff,
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) FINAL PRETRIAL CONFERENCE. ORDER
vs.
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SAN BERNARDINO POLICE

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OFFICES
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s.
CASAREZ HIS
INDIVIDUAL CAPACITY
Defendant
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FOLLOWING PRETAIL PROCEEDING, PURSUANT TO RULE 16,

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F.RCIV.P. AND L.R. 16, IT IS ORDERED:

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1. THE PARTIES ARE: LIST SAN BERNARDINO POLICE

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OFFICES S. CASAREZ HIS INDIVIDUAL CAPACITY

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EACH
OF THESE PARTIES HAS BEEN SERVED AND HAS APPEARED. THE PLEADING WHICH RAISE THE ISSUES ARE:
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2. FEDERAL JURISDICTION AND VENUE ARE INVOKED. ARE

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INVOKED UPON THE GROUNDS:

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(GIVE A CONCISE STATEMENT
OF FACTS NECESSARY TO CONFER FEDERAL JUURISDICTION AND VENUE. STATE WHETHER THE FACTS REQUISITE TO
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LETTER REQUEST BY ALTHEIA TAYLOR - 1
Case 6:12-bk-28006-MJ
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FEDERAL JURISICTION ARE DENIED OR ADMITTED.)
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3. THE TRAIL IS ESTIMATED TO TAKE 5-7 DAYS.
( WHERE
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COUNSEL CANNOT AGREE SET FORTH SIDE'S ESTIMATE.) 4. THE TRAIL IS TO BE A JURY TRAIL. (IF A JURY ADD: AT LEAT FIVE (5) COURT DAYS PRIOR TO THE TRAIL DATE EACH PARTY SHALL FILE AND SERVE BY E-MAIL, FAX, OR PERSONAL DELIVERY: (A) PROPOSED
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JURY INSTRUCTIONS AS REQUIRED BY L.R. 51-1 AND (B) ANY SPECIAL QUESTIONS TO REQUESTED TO BE ASKED ON VOIR DIRE.) (IF A NON-JURY TRAIL ADD: AT LEAST FIVE (5) COURT DAYS PRIOR TO PRIOR TRAIL DATE EACH PARTY SHALL L0DGE AND SERVE BY A E-MAIL, FAX, OR PERSONAL DELIVERY THE FINDING OF FACT AND CONCLUSIONS OF LAW THE PARTY EXPERTS THE COURT TO MAKE UPON PROOF AT THE TIME OF TRIAL AS REQUIRED BY L.R. 52-1)
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5. THE FOLLOWING FACTS ARE ADMITTED AND REQUIRE NO PROOF: 6. THE FOLLOWING FACTS, THOUGH STIPULATED SHALL BE WITHOUT PREJUDICE TO ANY EVIDENTIARY OBJECTION: 7. (THIS SECTION OF THE FINAL PRETRIAL CONFERENCE
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ORDER IS INTENDED IS FINALIZE, IN ADVANCE OF TRAIL, THE CLAIM AND DEFENSES TO BE PRESENTED AT TRAIL. IN
Entered .I Case 6:12-bk-28006-MJ Doc 208 Filed 10/24/12 10 of 22 10/25/12 10:59:31 Desc Main Document Page !
ACCORDANCE WITH F.R.CIV.P. 16 (C), PARTIES WILL BE PRECLUDED FROM PRESENTING CLAIMS OR DEFENSES NOT SET FORTH IN THIS ORDER, IN THE MANNER REQUIRED BY THIS ORDER, UNLESS THE ORDER IS MODIFIED TO prevent MAN!FEST INJUSTICE. ONLY CLAIMS OR DEFENSES CONTAINED IN THE COMPLAINT AND ANSWER AND ANY COURT AUTHORIZED AMENDMENT OR SUPPLEMENT MAY BE INCLUDED IN THIS FINAL PRETRIAL CONFERENCE ORDER. IF A PARTY CHOOSES T
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ABANDON A CLAIM OR DEFENSE PREVIOSLY ALLEGED, SO BY NOT INCLUDING IT THIS ORDER, AND THE FAILU TO INCLUDE ANY PLEADED CLAIM OR DEFENSE WILL BE DEEMED TO EFFORT SUCH A WAIVER. BE EMPLOYED: PLAINTIFF(S): (A) PLAINTIFF PLANS TO PURSUE THE FOLLOWING CLAIMS THE FOLLOWING FORMAT MUS
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AGAINST THE FOLLOWING DEFENDANTS: CLAIM 1 :CIVIL RIGHT UNDER THE 4TH AND 14TH AMENDMENT CLAIM 2:EXCESSIVE FORCE VIOLATED
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(B)
THE ELEMENTS REQUIRED TO ESTABLISH PLAINTIFF'S
CLAIMS ARE: THE PARTIES SHOULD STRIVE TO AGREE ON THE ELEMENTS. IF THE PARTIES CANNOT AGREE ON AN ELEMENT, THEN EACH PARTY MAY STATE ITS VERSION OF THE ELEMENTS.
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Case 6:12-bk-28006-MJ
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) IN BRIEF, THE KEY EVIDENCE PLAINTIFF RELIES
ON FOR EACH OF THE CLAIMS ITS: DEFENDANT( S) (A) DEFENDANT PLANS TO PURSUE THE FOLLOWIN
COUNTERCLAIMS AND AFFIRMATIVE DEFENSE: INSOFAR AS DEFENSES ARE CONCERNED, DEFENDANT SHOUL IDENTIFY MATTERS ONLY AFFIRMATIVE THE DEFENSES, WHICH THE ARE THOS 0
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ON WHICH
DEFENDANT
BEARS
BURDEN
PROOF. THEY ARE MATTERS WHICH WOULD DEFEAT PLAINTIFF'S CLAIM EVEN IF PLAINTIFF ESTABLISHED THE ELEMENTS OF THE CLAIM. EXAMPLES OF SUCH AFFIRMATIVE DEFENSESWHICH MUST HAVE BEEN PLEADED IN DEFENDANT'S ANSWERAPPEAR IN F.C.R. CIV.P 8 9 As counterclaims are (
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) . INSOFAR Defendean t shoul
concerned.
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follow the SAME FORMAT As plaintiff in listing claims.
(b) the elements required to DEFENDANT'S COUNTERCLAIMS AND AFFIRMATIVE DEFENSE ARE: LIST THE ELEMENTS SEPARATELY FOR EACH COUNTERCLAIM OR AFFIRMATIVE DEFENSE AS FOUND IN SWTANDARD JURY INSTRUCTIONS 0 CASE LAW. ELEMENTS. THE PARTIES SHOULD STRIVE TO AGREE ON TH
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IF THE PARTIES CANNOT AGREE ON AN ELEMENT,
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THEN EACH PARTY MAY STATE ITS VERSION OF THE ELEMENTS.

(
) IN BRIEF, THE KEY EVIDENCE DEFENDANT RELIES
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ON FOR EACH COUNTERCLAIM AND AFFIRNATIVE DEFENSE IS:
Case 6:12-bk-28006-MJ
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CLAIM AMENDMENT
CIVIL
RIGHT
UNDER
THE
4TH
AND
14T
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CLAIM
EXCESSIVE FORCE VIOLATION
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(C
) IN BRIEF, THE KEY EVIDENCE DEFENDANT RELIES
ON FOR EACH COUNTERCLAIM AND AFFIRMATIVE DEFENSE IS: THIRD PARTY PLAINTIFFS AND DEFENDANTS: (CLAIMS AND DEFENSES IN THIRD-PARTY CASES SHOULD BE ANALYZED AND SET FORTH IN THE SAME WAY AS THOSE OF PLAINTIFFS AND DEFENDANTS. SEPARTE PROPOSED PRETRIAL CONFERENCE ORDERS WILL NOT BE ACCEPTED.
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IN VIEW OF THE ADMITTED FACTS AND THE ELEMENTS TO ESTABLISH THE CLAIMS, COUNTERCLAIMS AND
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REQUIRED
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AFFIRMATIVE DEFENSES, THE FOLLOWING ISSUES REMAIN TO BE TRIED:
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9. ALL DISCOVERY IS COMPLETE 10. ALL DISCLOSURES UNDER F.R.CIV.P. 26 ( A ) HAVE BEEN MADE. ( 3 )
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THE JOINT EXHIBIT LIST OF THE PARTIES HAS BEEN FILED UNDER SEPARATE COVER AS REQUIRED BY L. R.
16-15.
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UNLESS ALL PARTIES AGREE THAT AN EXHIBIT SHALL BE WITH
ICase 6:12-bk-28006-MJ
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DRAWN,
ALL
EXHIBITS
WILL
BE
ADMITTED
WITHOU
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OBJECTION AT TRIAL, EXCEPT THOSE EXHIBITS LISTED BELOW:
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PLAINTIFF OBJECTS TO EXHIBIT NOS. DEFENDANT OBJECTS TO EXHIBIT NOS.
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THE OBJECTIONS AND GROUND THEREFOR ARE: GROUND OBJECTIONS SEPARATLY AS TO EACH EXHIBIT
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11. WITNESS LIST OF THE PARTIES HAVE BEEN FILED WITH THE COURT.
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ONLY THE WITNESSES IDDENTIFIED IN THE LISTS WILL BE PERMITTED TO TESTIY
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EACH PARTY INTENDING TO PRESENT EVIDENCE BY WAY OF DEPOSTION TESTIMONY HAS MARKED SUCH DEPOSITIONS I ACCORDANCE WITH L.R. 16-27., FOR THIS PURPOSE, THE FOLLOWING DEPOSITIONS SHALL LODGED WITH CLARK AS REQUIRED BY L.R. 32-1 PLAINTIFF OBJECTS TO THE PRESENTATION OF TESTIMONY BY DEPOSTION OF FOLLOWING WITNESSES:
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12. THE FOLLOWING LAW AND MOTION MATTERS AND MOTIONS IN ILLMINE, AND NO OTHERS, ARE PENDING OR CONTEMPL-
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ATED:
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13. BIFURCASTION OF THE FOLLOWING ISSUES FOR TRAIL IS ORDERD. STATE IDENTIFY THOSE ISSUES TO BE TRIED DURING THE FIRST STAGE OF THE TRAIL AND THOSES TO BE TRIED LATER.
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14. THE FORGEGOING ADMISSIONS HAVING BEEN MADE BY THE PARTIES HAVING SPECIFIED THE FORGEGOING ISSUES REMAINING TO BE LITIGATED, THIS FINAL PRETRAIL CONFERENCE ORDER SHALL SUPERSEDE THE PKEADING AND GOVERN THE COURSE OF THE TRAIL OF THIS CAUSE, UNLESS
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MODIFIED TO PREVENT MANIFEST INJUSTICE.
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Case 6:12-bk-28006-MJ
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UNITED STATES DISTRICT JUDGE
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APPROVED AS TO FORM AND CONTEBT
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ATTORNEY FOR PLAINTIFF ALTHEIA TAYLOR
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Case 6:12-bk-28006-MJ
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VANDALIZE
GLASS WINDOW
CAR I TRAIL DATE I
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BROKE GLAS BACK
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Case 6:12-bk-28006-MJ Print Report
Doc 208 Filed 10/24/12 Entered 10/25/12 10:59:31 Desc Page 1 of 1 Main Document Page 17 of 22
This incident has been reported to the Pasadena Police Department and is pending approval
Pasadena Police Department 207 North Garfield Ave Pasadena, CA 91101 626-744-4501
General Information
Incident Type Tracking Number Report Date Harassing Phone Call T12000889 0712412012 10:23 AM
Reporting Person Information

Name Home Address Home Phone Email Employer Name Work Address Work Phone Race Sex DOB Driver License No Licensing State SMITH I LYNN BUS I 7331210, Pasadena, CA 90012, US 555-555-5555 JOHN@YAHOO.COM POLIICE HAARASSING STOCKING UP DOWN STREET I GREEN, CCCCCCCC/ YYYYYYYYYY, CA 90012, us 444-444-4444 Hispanic/Latin/Mexican Female 01/23/1984 GRAY CA
Incident Information
Incident Location Incident Time (start) Incident Time (end) Location Type CCCCCCCC/YYYYYYYY/, Pasadena, CA 90012 07/01/2012 10:15 AM 07/24/2012 10:15 AM Vehicle; Auto, Truck, Bus, Motorcycle STOCKING IN GREEN I PURPLE / LIGHT PURPLE/ YELLOW I RED I BLACKING VAMDALIZE CAR /10 10 10 10 10 10 10 10 10 10 10 VANDALIZE/ WHITE VAN MEXCIO VANDALIZE LYNN IN LOS ANGLES VANDALIZE PURPOSE/ SAN BERNARDINO POLICE Harassment offices s. casarez his cAPACITY VANDALIZE PURPOSE/ TERA WYNN/ GROUP OF POLICE OFFICE VANDALIZE CAR 20 TO 50 OFF STOCKING DAILY/
Incident Description
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https :/Isecure. cop 1 gi c. corn/dorsi enlfi 1 sh owprin tab 1 port o ing/ ere
7/24/2012
Case 6:12-bk-28006-MJ
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PROOF OF SERVICE
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I AM OVER THE AGE OF 18 YEARS AND NOT A PARTY TO THIS PROCEEDING MY ADDRESS P.O. BOX 30082 SAN BERNARDINO CA 92413
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ON JULY 06, 2012, I SERVEED THE FOREGOING DESCRIBED AS:
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FINAL PRETAIL CONFERENCE ORDER
JAMES F. PENMAN, CITY ATTORNEY 300 NORTH "D" STREET SAN BERNARDINO CA 92418
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ON ALL INTERESTED PARTIES IN THIS ACTION BY TRUE AND CORRECT COPY THEREOF IN A SEALED ENVELOPE, WITH FIRSTCLASS POSTAGE PREPAID THEREON, AND DEPOSITEF SAID ENVELOPE IN THE UNITED STATES MAIL LOS ANGLES CALIFORNIA ADDRESS TO:
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I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE STATES OF THE UNITED STATES THAT THE FORGOING IS
Case 6:12-bk-28006-MJ
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TRUE AND CORRECT .
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EXECUTED ON JULY 06, 2012, AT DATE:
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ALTHEIA TAYLOOR________________________________________
Ol\I?J_\ lt>\l)
~S
;\GLES, CALIFORNIA
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DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS
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OF THE STATES OF THE UNITED STATES THAT THE FORGOING ISW TRUE AND CORRECT.
EXECUTED ON OCT 23 2012 AT
CALIFORNIA.
ALTHEIA TAYLOR
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Case 6:12-bk-28006-MJ
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ALTHEIA TAYLOR
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PROOF OF SERVICE I, ALTHEIA TAYLOR, DECLARE AS FOLLOWS. I AM OVER THE AGE YEARS AND NOT A PARTY TO THIS PROCEEDING. MY ADDRESS IS P.O. BOX 30082 SAN BERNARDINO CA 92413
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ON OCT
23,2012 I SERVED THE FORGOING DOCUMENT
DESCRIBED AS: PROOF OF SERVICE OF SUMMONS TO: PAUL R. GLASSMAN (STATE BAR NO. 76536 LAURA L. BUCHANAN ( STATE BAR NO. 156261 KATHLEEN D DEVANEY ( STATE BAR NO. 156444) STRADLING YOCCA CARLSON & RAUTH A PROFESSIONAL CORPORATION 100 WILSHIRE BLVD., SUITE 440
SANTA MONICA CA 90401
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EXCESSIVFE FORCE STOCKING VEHICLE HARASSMENT
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I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS

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Case 6:12-bk-28006-MJ

ALTHEIA TAYLOR P . 0 . BOX 3 0 0 8 2 SAN BERNARDINO CA 92413 909 429-2656

ATTORNEYS FOR DEBTOR

CITY OF SAN BERNARDINO

CITY OF SAN BERNARDINO

ATTORNEYS FOR DEBTOR

CITY OF SAN BERNARDINO

SETTLEMENT AMOUNT 5000.00 TO 6000.00

APPELEE ATTORNEYS: FEMALE

FOR INJURIES TO HEAD OR

BRAIN/ HEADACHES INTERMITTENT SEVERE HEADACHES EXCESSIVENESS OR ADEQUACY OF DAMAGES

FOR INJURIES TO NERVES OR NERVOUS

EXECUTED ON OCT 23, 2012 AT LOS ANGLES, CALIFORNIA.

EXECUTED ON OCT 23, 2012 AT LOS ANGLES CALIFORNIA

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

) CASE NO: EDCV 09-240 MMM

) FINAL PRETRIAL CONFERENCE. ORDER

SAN BERNARDINO POLICE

FOLLOWING PRETAIL PROCEEDING, PURSUANT TO RULE 16,

F.RCIV.P. AND L.R. 16, IT IS ORDERED:

1. THE PARTIES ARE: LIST SAN BERNARDINO POLICE

OFFICES S. CASAREZ HIS INDIVIDUAL CAPACITY

2. FEDERAL JURISDICTION AND VENUE ARE INVOKED. ARE

INVOKED UPON THE GROUNDS:

(GIVE A CONCISE STATEMENT

LETTER REQUEST BY ALTHEIA TAYLOR - 1

FEDERAL JURISICTION ARE DENIED OR ADMITTED.)

3. THE TRAIL IS ESTIMATED TO TAKE 5-7 DAYS.

LETTER REQUEST BY ALTHEIA TAYLOR - 2

THE ELEMENTS REQUIRED TO ESTABLISH PLAINTIFF'S

LETTER REQUEST BY ALTHEIA TAYLOR - 3

) IN BRIEF, THE KEY EVIDENCE PLAINTIFF RELIES

) . INSOFAR Defendean t shoul

follow the SAME FORMAT As plaintiff in listing claims.

IF THE PARTIES CANNOT AGREE ON AN ELEMENT,

THEN EACH PARTY MAY STATE ITS VERSION OF THE ELEMENTS.

) IN BRIEF, THE KEY EVIDENCE DEFENDANT RELIES

ON FOR EACH COUNTERCLAIM AND AFFIRNATIVE DEFENSE IS:

LETTER REQUEST BY ALTHEIA TAYLOR - 4

EXCESSIVE FORCE VIOLATION

) IN BRIEF, THE KEY EVIDENCE DEFENDANT RELIES

AFFIRMATIVE DEFENSES, THE FOLLOWING ISSUES REMAIN TO BE TRIED:

UNLESS ALL PARTIES AGREE THAT AN EXHIBIT SHALL BE WITH

LETTER REQUEST BY ALTHEIA TAYLOR - 5

OBJECTION AT TRIAL, EXCEPT THOSE EXHIBITS LISTED BELOW:

PLAINTIFF OBJECTS TO EXHIBIT NOS. DEFENDANT OBJECTS TO EXHIBIT NOS.

ONLY THE WITNESSES IDDENTIFIED IN THE LISTS WILL BE PERMITTED TO TESTIY

LETTER REQUEST BY ALTHEIA TAYLOR - 6

MODIFIED TO PREVENT MANIFEST INJUSTICE.

LETTER REQUEST BY ALTHEIA TAYLOR - 7

UNITED STATES DISTRICT JUDGE

APPROVED AS TO FORM AND CONTEBT

ATTORNEY FOR PLAINTIFF ALTHEIA TAYLOR

LETTER REQUEST BY ALTHEIA TAYLOR - 8

CAR I TRAIL DATE I

BROKE GLAS BACK

Case 6:12-bk-28006-MJ Print Report

Reporting Person Information

lPrint This Report I Close Window I

ON JULY 06, 2012, I SERVEED THE FOREGOING DESCRIBED AS:

FINAL PRETAIL CONFERENCE ORDER

LETTER REQUEST BY ALTHEIA TAYLOR - 9