USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 1 of 37
CLOSED,DISCREF,PROTO
U.S. District Court U.S. District Court for the Northern District of Oklahoma (Tulsa)
CIVIL DOCKET FOR CASE #: 4:09−cv−00407−JHP−tlw

England et al v. Delaware County Sheriff Assigned to: Judge James H Payne Referred to: Magistrate Judge T Lane Wilson Cause: 42:1981 Civil Rights
Plaintiff
Sherry England an individual

Date Filed: 06/24/2009 Date Terminated: 12/01/2011 Jury Demand: Plaintiff Nature of Suit: 440 Civil Rights: Other Jurisdiction: Federal Question
represented by Anthony Lee Allen Allen & Garrett 106 S OKMULGEE AVE OKMULGEE, OK 74447 844−255−0000 Fax: 888−397−3643 Email: anthony@allengarrett.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
David Mitchell Garrett , Jr Garrett Law Center PLLC 320 S BOSTON AVE STE 825 TULSA, OK 74103 918−978−2226 Fax: 918−409−2999 Email: mitchell@garrettlawcenter.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gregory Peter Williams Garrett Law Office (Tulsa) 111 W 5TH ST STE 800 TULSA, OK 74103 918−948−6171 Fax: 800−460−3446 Email: greg@lawtulsa.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
R Thomas Seymour Seymour Law Firm 1811 S BALTIMORE AVE TULSA, OK 74119 918−583−5791 Fax: 918−583−9251 Email: Rtseymour1@aol.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Scott Alan Graham Federal Public Defender's Office (Tulsa) 1 W 3RD ST STE 1225 TULSA, OK 74103 918−581−7656 Fax: 918−581−7630 Email: scott_graham@fd.org LEAD ATTORNEY ATTORNEY TO BE NOTICED
David Mitchell Garrett

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 2 of 37

Garrett Law Office (Tulsa) 111 W 5TH ST STE 800 TULSA, OK 74103 918−549−6743 Fax: 918−549−6741 Email: david@glopc.com TERMINATED: 08/05/2011

Plaintiff
Katrina Rogers an individual

represented by Anthony Lee Allen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Gregory Peter Williams (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

R Thomas Seymour (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Scott Alan Graham (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett (See above for address) TERMINATED: 08/05/2011

Plaintiff
Cynthia Craig an individual

represented by Anthony Lee Allen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Gregory Peter Williams (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

R Thomas Seymour (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Scott Alan Graham (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 3 of 37

David Mitchell Garrett (See above for address) TERMINATED: 08/05/2011

Plaintiff
Marie Watson an individual

represented by Anthony Lee Allen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Gregory Peter Williams (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

R Thomas Seymour (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Scott Alan Graham (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett (See above for address) TERMINATED: 08/05/2011

Plaintiff
Jessica Rodas an individual

represented by Anthony Lee Allen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Gregory Peter Williams (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

R Thomas Seymour (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Scott Alan Graham (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett (See above for address) TERMINATED: 08/05/2011

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 4 of 37

Plaintiff Laurice Anderson an individual
Plaintiff Melissa Nelson an individual TERMINATED: 09/16/2011
Plaintiff

represented by Anthony Lee Allen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
David Mitchell Garrett , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gregory Peter Williams (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
R Thomas Seymour (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Scott Alan Graham (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
David Mitchell Garrett (See above for address) TERMINATED: 08/05/2011 ATTORNEY TO BE NOTICED
represented by Anthony Lee Allen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
David Mitchell Garrett , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gregory Peter Williams (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
R Thomas Seymour (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Scott Alan Graham (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
David Mitchell Garrett (See above for address) TERMINATED: 08/05/2011

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 5 of 37

Rebecca Blossom an individual

represented by Anthony Lee Allen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Gregory Peter Williams (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

R Thomas Seymour (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Scott Alan Graham (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett (See above for address) TERMINATED: 08/05/2011

Plaintiff
Stacey Buskirk an individual TERMINATED: 02/08/2011

represented by Anthony Lee Allen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Gregory Peter Williams (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

R Thomas Seymour (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Scott Alan Graham (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett (See above for address) TERMINATED: 08/05/2011

Plaintiff
Kimberly Bledsoe an individual

represented by Anthony Lee Allen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 6 of 37

Plaintiff Tamela Taylor an individual
Plaintiff Katherine Buck an individual TERMINATED: 06/06/2011

David Mitchell Garrett , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gregory Peter Williams (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
R Thomas Seymour (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Scott Alan Graham (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
David Mitchell Garrett (See above for address) TERMINATED: 08/05/2011
represented by Anthony Lee Allen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
David Mitchell Garrett , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Gregory Peter Williams (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
R Thomas Seymour (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Scott Alan Graham (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
David Mitchell Garrett (See above for address) TERMINATED: 08/05/2011
represented by Anthony Lee Allen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
David Mitchell Garrett , Jr (See above for address) LEAD ATTORNEY

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 7 of 37

ATTORNEY TO BE NOTICED

Gregory Peter Williams (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

R Thomas Seymour (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Scott Alan Graham (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett (See above for address) TERMINATED: 08/05/2011

Plaintiff
Billie Jo Gandert an individual

represented by Anthony Lee Allen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Gregory Peter Williams (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

R Thomas Seymour (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Scott Alan Graham (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett (See above for address) TERMINATED: 08/05/2011

Plaintiff
Amy Johnson an individual

represented by Anthony Lee Allen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Gregory Peter Williams (See above for address)

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 8 of 37

LEAD ATTORNEY ATTORNEY TO BE NOTICED

R Thomas Seymour (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Scott Alan Graham (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett (See above for address) TERMINATED: 08/05/2011

Plaintiff
Jacquelyn Blossom an individual

represented by Anthony Lee Allen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Gregory Peter Williams (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

R Thomas Seymour (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Scott Alan Graham (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett (See above for address) TERMINATED: 08/05/2011

Plaintiff All Plaintiffs

represented by Anthony Lee Allen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Gregory Peter Williams (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

R Thomas Seymour

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 9 of 37

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Scott Alan Graham (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett (See above for address) TERMINATED: 08/05/2011

Plaintiff Tammy Beavers

represented by Anthony Lee Allen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Gregory Peter Williams (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

R Thomas Seymour (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Scott Alan Graham (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett (See above for address) TERMINATED: 08/05/2011

Plaintiff Debbie Back James

represented by Anthony Lee Allen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett , Jr (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Gregory Peter Williams (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

R Thomas Seymour (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 10 of 37

Scott Alan Graham (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett (See above for address) TERMINATED: 08/05/2011

Plaintiff Jamie Dale Fry Cook

represented by Gregory Peter Williams (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

R Thomas Seymour (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

David Mitchell Garrett (See above for address) TERMINATED: 08/05/2011

V. Defendant Delaware County Sheriff in his official capacity
Third Party Defendant Delaware County E911 Trust Authority

represented by Ambre Camille Gooch Collins Zorn & Wagner 429 NE 50TH ST 2ND FLR OKLAHOMA CITY, OK 73105−1815 405−524−2070 Fax: 405−524−2078 Email: acg@czwlaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Christopher James Collins Collins Zorn & Wagner 429 NE 50TH ST 2ND FLR OKLAHOMA CITY, OK 73105−1815 405−524−2070 Fax: 405−524−2078 Email: cjc@czwlaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Philip Wayne Anderson Collins Zorn & Wagner 429 NE 50TH ST 2ND FLR OKLAHOMA CITY, OK 73105−1815 405−524−2070 Fax: 405−524−2078 Email: panderson@czwglaw.com ATTORNEY TO BE NOTICED
represented by Betty Outhier Williams Betty Outhier Williams Law Office P O BOX 87 MUSKOGEE, OK 74402 918−687−5425

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 11 of 37
Fax: 918−687−0761 Email: bowlaw@sbcglobal.net LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 06/24/2009 06/24/2009 06/24/2009 06/24/2009 07/02/2009 07/02/2009 07/18/2009 07/20/2009 07/23/2009 07/31/2009 08/07/2009 10/08/2009 10/09/2009 10/09/2009
10/13/2009 10/15/2009

# Docket Text
1 CIVIL COVER SHEET by Marie Watson, Sherry England, Katrina Rogers, Cynthia Craig (s−srb, Dpty Clk) (Entered: 06/25/2009)
2 COMPLAINT with Jury Demand against Delaware County Sheriff by Marie Watson, Sherry England, Katrina Rogers, Cynthia Craig (s−srb, Dpty Clk) (Entered: 06/25/2009)
3 SUMMONS Issued by Court Clerk as to Delaware County Sheriff , County Commissioners and Delaware County Clerk (s−srb, Dpty Clk) (Entered: 06/25/2009)
4 FILING FEES Paid in Full by Marie Watson, Sherry England, Katrina Rogers, Cynthia Craig (s−srb, Dpty Clk) (Entered: 06/25/2009)
5 ATTORNEY APPEARANCE by Christopher James Collins on behalf of Delaware County Sheriff (Collins, Christopher) (Entered: 07/02/2009)
6 ATTORNEY APPEARANCE by Ambre Camille Gooch on behalf of Delaware County Sheriff (Gooch, Ambre) (Entered: 07/02/2009)
7 Unopposed MOTION for Extension of Time to Answer (Re: 2 Complaint ) by Delaware County Sheriff (Gooch, Ambre) (Entered: 07/18/2009)
8 ANSWER (Re: 2 Complaint ) by Delaware County Sheriff (Collins, Christopher) (Entered: 07/20/2009)
9 MINUTE ORDER by Judge James H Payne : Granting Defendant until 7/27/09 to answer the complaint ; granting 7 Motion for Extension of Time to Answer (Re: 2 Complaint ) (pll, Dpty Clk) (Entered: 07/23/2009)
10 ATTORNEY APPEARANCE by Gregory Peter Williams on behalf of Marie Watson, Sherry England, Katrina Rogers, Cynthia Craig (Williams, Gregory) (Entered: 07/31/2009)
11 ATTORNEY APPEARANCE by David Mitchell Garrett, Jr on behalf of Marie Watson, Sherry England, Katrina Rogers, Cynthia Craig (Garrett, David) (Entered: 08/07/2009)
12 Unopposed MOTION to Amend Complaint (Re: 2 Complaint ) by Marie Watson, Sherry England, Katrina Rogers, Cynthia Craig (With attachments) (Seymour, R) (Entered: 10/08/2009)
13 MINUTE ORDER by Judge James H Payne : Granting Plaintiff's Motion to amend the complaint ; granting 12 Motion to Amend (Re: 2 Complaint ) (pll, Dpty Clk) (Entered: 10/09/2009)
14 First AMENDED COMPLAINT with Jury Demand against Delaware County Sheriff (Re: 2 Complaint ) by Marie Watson, Sherry England, Katrina Rogers, Cynthia Craig, Jessica Rodas, Laurice Anderson, Melissa Nelson, Rebecca Blossom, Stacey Buskirk, Kimberly Bledsoe, Tamela Taylor, Katherine Buck, Billie Jo Gandert, Amy Johnson, Jacquelyn Blossom (Seymour, R) Modified on 10/13/2009 to add filers (tjc, Dpty Clk). (Entered: 10/09/2009)
NOTICE of Docket Entry Modification; Error: Not all filers were selected when filed; Correction: Edited docket text to add filers (Re: 14 Amended Complaint, ) (tjc, Dpty Clk) (Entered: 10/13/2009)
15 MOTION for Extension of Time to Answer to Submit Responsive Pleading (Re: 14 Amended Complaint, ) by Delaware County Sheriff (Gooch, Ambre) (Entered: 10/15/2009)

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10/19/2009 10/21/2009 10/22/2009 10/22/2009 11/02/2009 01/04/2010 01/11/2010
01/11/2010
02/11/2010 02/19/2010 02/22/2010 02/25/2010 02/25/2010
03/01/2010 03/02/2010 03/22/2010 03/24/2010

16 MINUTE ORDER by Judge James H Payne : Granting Defendant until 10/29/09 to answer the Amended Complaint ; granting 15 Motion for Extension of Time to Answer (Re: 14 Amended Complaint, ) (pll, Dpty Clk) (Entered: 10/19/2009)
17 Unopposed MOTION to Amend First Amended Complaint by All Plaintiffs (With attachments) (Graham, Scott) (Entered: 10/21/2009)
18 MINUTE ORDER by Judge James H Payne : Granting Plaintiff's Motion to amend complaint ; granting 17 Motion to Amend (Re: 14 Amended Complaint, ) (pll, Dpty Clk) (Entered: 10/22/2009)
19 Second AMENDED COMPLAINT with Jury Demand against all defendants (Re: 14 Amended Complaint, ) by All Plaintiffs (Graham, Scott) (Entered: 10/22/2009)
20 ANSWER (Re: 19 Amended Complaint ) by Delaware County Sheriff (Gooch, Ambre) (Entered: 11/02/2009)
21 MINUTE ORDER by Court Clerk, setting/resetting deadline(s)/hearing(s): ( Status Report due by 1/22/2010, Scheduling Conference set for 1/26/2010 at 01:30 PM before Judge James H Payne) (pll, Dpty Clk) (Entered: 01/04/2010)
22 Joint MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s) Scheduling Conference (Re: 21 Minute Order, Setting/Resetting Deadline(s)/Hearing(s) ) by Marie Watson, All Plaintiffs, Tammy Beavers, Debbie Back James, Delaware County Sheriff, Sherry England, Katrina Rogers, Jessica Rodas, Laurice Anderson, Melissa Nelson, Rebecca Blossom, Stacey Buskirk, Kimberly Bledsoe, Tamela Taylor, Katherine Buck, Billie Jo Gandert, Amy Johnson, Jacquelyn Blossom, Cynthia Craig (Graham, Scott) (Entered: 01/11/2010)
23 MINUTE ORDER by Judge James H Payne : Granting the Joint Motion to Reset Scheduling Conference ; setting/resetting deadline(s)/hearing(s): ( Status Report due by 2/19/2010, Scheduling Conference set for 2/26/2010 at 10:00 AM before Judge James H Payne); granting 22 Motion to Accelerate/Extend/Reset Hearing(s)/Deadline(s) (pll, Dpty Clk) (Entered: 01/11/2010)
24 MINUTE ORDER by Judge James H Payne : Due to the Court's schedule, setting/resetting deadline(s)/hearing(s): ( Scheduling Conference set for 2/25/2010 at 03:00 PM before Judge James H Payne) (pll, Dpty Clk) (Entered: 02/11/2010)
25 JOINT STATUS REPORT by All Plaintiffs, Delaware County Sheriff (Graham, Scott) Modified on 2/22/2010 to add filer (tjc, Dpty Clk). (Entered: 02/19/2010)
NOTICE of Docket Entry Modification; Error: Not all filers were selected when filed; Correction: Edited docket text to add filer (Re: 25 Joint Status Report per Local Rule 16.1 ) (tjc, Dpty Clk) (Entered: 02/22/2010)
26 MINUTES of Proceedings − held before Judge James H Payne: Scheduling Conference held on 2/25/2010 (pll, Dpty Clk) (Entered: 02/25/2010)
27 SCHEDULING ORDER by Judge James H Payne (initial), setting/resetting scheduling order date(s): ( Dispositive Motions due by 7/14/2011, Discovery due by 7/21/2011, Proposed Pretrial Order due by 8/18/2011, Pretrial Conference set for 8/25/2011 at 10:30 AM before Judge James H Payne, Jury Trial set for 9/19/2011 at 09:30 AM before Judge James H Payne) (pll, Dpty Clk) (Entered: 02/25/2010)
28 NOTICE Defendant's Initial Disclosures by Delaware County Sheriff (Gooch, Ambre) Modified on 3/2/2010−This is discovery and should not be filed (lml, Dpty Clk). (Entered: 03/01/2010)
NOTICE of Docket Entry Modification; Error: This is discovery and should not be filed per Local Rule 26.3 and General Order 01−02; Correction: Notified counsel that this is discovery (Re: 28 Notice (Other) ) (lml, Dpty Clk) (Entered: 03/02/2010)
29 Unopposed MOTION to Amend 2nd Amended Complaint (Re: 19 Amended Complaint ) by All Plaintiffs (With attachments) (Seymour, R) (Entered: 03/22/2010)
30 MINUTE ORDER by Judge James H Payne : Granting Plaintiffs until 3/26/10 to file their 3rd Amended Complaint ; granting 29 Motion to Amend (Re: 19 Amended Complaint ) (pll, Dpty Clk) (Entered: 03/24/2010)

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03/26/2010 04/06/2010 04/19/2010 07/02/2010 07/02/2010 07/02/2010 07/02/2010 07/02/2010 07/02/2010 07/02/2010 07/02/2010 07/02/2010 07/02/2010 07/02/2010 07/02/2010

31 Third AMENDED COMPLAINT with Jury Demand against Delaware County Sheriff (Re: 19 Amended Complaint ) by Jamie Dale Fry Cook, All Plaintiffs (Seymour, R) (Entered: 03/26/2010)
32 ANSWER (Re: 31 Amended Complaint ) by Delaware County Sheriff (Gooch, Ambre) (Entered: 04/06/2010)
33 ATTORNEY APPEARANCE by Philip Wayne Anderson on behalf of Delaware County Sheriff (Anderson, Philip) (Entered: 04/19/2010)
34 NOTICE Subpoena Duces Tecum by Delaware County Sheriff (Gooch, Ambre) Modified on 7/6/2010 to seal this pdf as this is discovery material and pursuant to FRCP 5(d)(1) and Local Rule 26.3, discovery material is not to be filed (sac, Dpty Clk). (Entered: 07/02/2010)
35 NOTICE Subpoena Duces Tecum by Delaware County Sheriff (Gooch, Ambre) Modified on 7/6/2010 to seal this pdf as this is discovery material and pursuant to FRCP 5(d)(1) and Local Rule 26.3, discovery material is not to be filed (sac, Dpty Clk). (Entered: 07/02/2010)
36 NOTICE Subpoena Duces Tecum by Delaware County Sheriff (Gooch, Ambre) Modified on 7/6/2010 to seal this pdf as this is discovery material and pursuant to FRCP 5(d)(1) and Local Rule 26.3, discovery material is not to be filed (sac, Dpty Clk). (Entered: 07/02/2010)
37 NOTICE Subpoena Duces Tecum by Delaware County Sheriff (Gooch, Ambre) Modified on 7/6/2010 to seal this pdf as this is discovery material and pursuant to FRCP 5(d)(1) and Local Rule 26.3, discovery material is not to be filed (sac, Dpty Clk). (Entered: 07/02/2010)
38 NOTICE Subpoena Duces Tecum by Delaware County Sheriff (Gooch, Ambre) Modified on 7/6/2010 to seal this pdf as this is discovery material and pursuant to FRCP 5(d)(1) and Local Rule 26.3, discovery material is not to be filed (sac, Dpty Clk). (Entered: 07/02/2010)
39 NOTICE Subpoena Duces Tecum by Delaware County Sheriff (Gooch, Ambre) Modified on 7/6/2010 to seal this pdf as this is discovery material and pursuant to FRCP 5(d)(1) and Local Rule 26.3, discovery material is not to be filed (sac, Dpty Clk). (Entered: 07/02/2010)
40 NOTICE of Change of Address by Ambre Camille Gooch by on behalf of Delaware County Sheriff (Gooch, Ambre) Modified on 7/6/2010; wrong event used and to seal this pdf as this is discovery material and pursuant to FRCP 5(d)(1) and Local Rule 26.3, discovery material is not to be filed (sac, Dpty Clk). (Entered: 07/02/2010)
41 NOTICE Subpoena Duces Tecum by Delaware County Sheriff (Gooch, Ambre) Modified on 7/6/2010 to seal this pdf as this is discovery material and pursuant to FRCP 5(d)(1) and Local Rule 26.3, discovery material is not to be filed (sac, Dpty Clk). (Entered: 07/02/2010)
42 NOTICE Subpoena Duces Tecum by Delaware County Sheriff (Gooch, Ambre) Modified on 7/6/2010 to seal this pdf as this is discovery material and pursuant to FRCP 5(d)(1) and Local Rule 26.3, discovery material is not to be filed (sac, Dpty Clk). (Entered: 07/02/2010)
43 NOTICE Subpoena Duces Tecum by Delaware County Sheriff (Gooch, Ambre) Modified on 7/6/2010 to seal this pdf as this is discovery material and pursuant to FRCP 5(d)(1) and Local Rule 26.3, discovery material is not to be filed (sac, Dpty Clk). (Entered: 07/02/2010)
44 NOTICE Subpoena Duces Tecum by Delaware County Sheriff (Gooch, Ambre) Modified on 7/6/2010 to seal this pdf as this is discovery material and pursuant to FRCP 5(d)(1) and Local Rule 26.3, discovery material is not to be filed (sac, Dpty Clk). (Entered: 07/02/2010)
45 NOTICE Subpoena Duces Tecum by Delaware County Sheriff (Gooch, Ambre) Modified on 7/6/2010 to seal this pdf as this is discovery material and pursuant to FRCP 5(d)(1) and Local Rule 26.3, discovery material is not to be filed (sac, Dpty Clk). (Entered: 07/02/2010)

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07/02/2010 07/02/2010 07/02/2010 07/02/2010 07/02/2010 07/02/2010 07/02/2010 07/06/2010
07/07/2010 07/09/2010
07/13/2010 07/15/2010 07/16/2010

46 NOTICE Subpoena Duces Tecum by Delaware County Sheriff (Gooch, Ambre) Modified on 7/6/2010 to seal this pdf as this is discovery material and pursuant to FRCP 5(d)(1) and Local Rule 26.3, discovery material is not to be filed (sac, Dpty Clk). (Entered: 07/02/2010)
47 NOTICE Subpoena Duces Tecum by Delaware County Sheriff (Gooch, Ambre) Modified on 7/6/2010 to seal this pdf as this is discovery material and pursuant to FRCP 5(d)(1) and Local Rule 26.3, discovery material is not to be filed (sac, Dpty Clk). (Entered: 07/02/2010)
48 NOTICE Subpoena Duces Tecum by Delaware County Sheriff (Gooch, Ambre) Modified on 7/6/2010 to seal this pdf as this is discovery material and pursuant to FRCP 5(d)(1) and Local Rule 26.3, discovery material is not to be filed (sac, Dpty Clk). (Entered: 07/02/2010)
49 NOTICE Subpoena Duces Tecum by Delaware County Sheriff (Gooch, Ambre) Modified on 7/6/2010 to seal this pdf as this is discovery material and pursuant to FRCP 5(d)(1) and Local Rule 26.3, discovery material is not to be filed (sac, Dpty Clk). (Entered: 07/02/2010)
50 NOTICE Subpoena Duces Tecum by Delaware County Sheriff (Gooch, Ambre) Modified on 7/6/2010 to seal this pdf as this is discovery material and pursuant to FRCP 5(d)(1) and Local Rule 26.3, discovery material is not to be filed (sac, Dpty Clk). (Entered: 07/02/2010)
51 NOTICE Subpoena Duces Tecum by Delaware County Sheriff (Gooch, Ambre) Modified on 7/6/2010 to seal this pdf as this is discovery material and pursuant to FRCP 5(d)(1) and Local Rule 26.3, discovery material is not to be filed (sac, Dpty Clk). (Entered: 07/02/2010)
52 NOTICE Subpoena Duces Tecum by Delaware County Sheriff (Gooch, Ambre) Modified on 7/6/2010 to seal this pdf as this is discovery material and pursuant to FRCP 5(d)(1) and Local Rule 26.3, discovery material is not to be filed (sac, Dpty Clk). (Entered: 07/02/2010)
NOTICE of Docket Entry Modification; Error: these documents are discovery material; Correction: sealed pdfs and notified counsel that pursuant to FRCP 5(d)(1) and Local Rule 26.3, discovery material is not to be filed (Re: 34 Notice (Other), 47 Notice (Other), 50 Notice (Other), 51 Notice (Other), 46 Notice (Other), 40 Notice of Change of Address, 38 Notice (Other), 35 Notice (Other), 52 Notice (Other), 45 Notice (Other), 44 Notice (Other), 39 Notice (Other), 48 Notice (Other), 36 Notice (Other), 37 Notice (Other), 42 Notice (Other), 41 Notice (Other), 49 Notice (Other), 43 Notice (Other) ) (sac, Dpty Clk) (Entered: 07/06/2010)
53 MOTION to Compel AND BRIEF FOR ORDER REQUIRING RELEASE OF PLAINTIFFS MEDICAL/MENTAL HEALTH AND COUNSELING RECORDS by Delaware County Sheriff (With attachments) (Gooch, Ambre) (Entered: 07/07/2010)
54 MINUTE ORDER by Magistrate Judge T Lane Wilson (EXPEDITING RESPONSE AND REPLY DEADLINES), setting/resetting deadline(s)/hearing(s): (Magistrate Courtroom No. 2, Third Floor) ( Responses due by 7/15/2010, Replies due by 7/16/2010, Motion Hearing set for 7/20/2010 at 01:30 PM before Magistrate Judge T Lane Wilson) (Re: 53 MOTION to Compel AND BRIEF FOR ORDER REQUIRING RELEASE OF PLAINTIFFS MEDICAL/MENTAL HEALTH AND COUNSELING RECORDS ) (crp, Dpty Clk) (Entered: 07/09/2010)
55 MOTION for Protective Order by All Plaintiffs (With attachments) (Williams, Gregory) (Entered: 07/13/2010)
56 RESPONSE in Opposition to Motion (Re: 53 MOTION to Compel AND BRIEF FOR ORDER REQUIRING RELEASE OF PLAINTIFFS MEDICAL/MENTAL HEALTH AND COUNSELING RECORDS ) by All Plaintiffs ; (With attachments) (Williams, Gregory) (Entered: 07/15/2010)
57 MINUTE ORDER by Magistrate Judge T Lane Wilson (EXPEDITING RESPONSE AND REPLY DEADLINES), setting/resetting deadline(s)/hearing(s): (Magistrate Courtroom No. 2, Third Floor) ( Responses due by 7/22/2010, Replies due by 7/26/2010, Motion Hearing set for 7/28/2010 at 09:30 AM before Magistrate Judge T

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 15 of 37

07/16/2010 07/19/2010 07/20/2010
07/30/2010 08/02/2010 08/02/2010 08/02/2010 08/03/2010 08/06/2010 08/18/2010 08/19/2010
08/23/2010 08/24/2010 08/24/2010

Lane Wilson) (Re: 55 MOTION for Protective Order ) (crp, Dpty Clk) (Entered: 07/16/2010)
58 REPLY to Response to Motion (Re: 53 MOTION to Compel AND BRIEF FOR ORDER REQUIRING RELEASE OF PLAINTIFFS MEDICAL/MENTAL HEALTH AND COUNSELING RECORDS ) by Delaware County Sheriff ; (With attachments) (Gooch, Ambre) (Entered: 07/16/2010)
59 RESPONSE in Opposition to Motion (Re: 55 MOTION for Protective Order ) by Delaware County Sheriff ; (Gooch, Ambre) (Entered: 07/19/2010)
60 MINUTES of Proceedings − held before Magistrate Judge T Lane Wilson: Motion Hearing held on 7/20/2010 ; striking/terminating deadline(s)/Hearing(s); granting in part and denying in part 53 Motion to Compel; finding as moot 55 Motion for Protective Order (Re: 55 MOTION for Protective Order, 53 MOTION to Compel AND BRIEF FOR ORDER REQUIRING RELEASE OF PLAINTIFFS MEDICAL/MENTAL HEALTH AND COUNSELING RECORDS ) (Court Reporter: C2) (crp, Dpty Clk) (Entered: 07/20/2010)
61 Joint MOTION for Protective Order by Delaware County Sheriff, All Plaintiffs (Gooch, Ambre) Modified on 8/2/2010 to add filer (lml, Dpty Clk). (Entered: 07/30/2010)
NOTICE of Docket Entry Modification; Error: Not all filers were selected when filed; Correction: Edited docket entry and added filer (Re: 61 Joint MOTION for Protective Order ) (lml, Dpty Clk) (Entered: 08/02/2010)
62 Joint MOTION Order To Release Plaintiffs' Medical Records by All Plaintiffs, Delaware County Sheriff (Williams, Gregory) Modified on 8/3/2010 to correct filers (tjc, Dpty Clk). (Entered: 08/02/2010)
63 PROTECTIVE ORDER by Magistrate Judge T Lane Wilson ; granting 61 Motion for Protective Order (crp, Dpty Clk) (Entered: 08/02/2010)
64 ORDER by Magistrate Judge T Lane Wilson ; granting 62 Motion for Miscellaneous Relief (Re: 55 MOTION for Protective Order, 53 MOTION to Compel AND BRIEF FOR ORDER REQUIRING RELEASE OF PLAINTIFFS MEDICAL/MENTAL HEALTH AND COUNSELING RECORDS ) (crp, Dpty Clk) (Entered: 08/03/2010)
65 SETTLEMENT CONFERENCE ORDER by Magistrate Judge Frank H McCarthy, setting/resetting deadline(s)/hearing(s): ( Settlement Conference set for 7/6/2011 at 01:30 PM before Magistrate Judge Frank H McCarthy) (jcm, Dpty Clk) (Entered: 08/06/2010)
66 MOTION to Compel Discovery Responses from Certain Plaintiffs by Delaware County Sheriff (With attachments) (Gooch, Ambre) (Entered: 08/18/2010)
67 MINUTE ORDER by Magistrate Judge T Lane Wilson, setting/resetting deadline(s)/hearing(s): (Magistrate Courtroom No. 1, Third Floor) ( Responses due by 8/25/2010, Replies due by 8/27/2010, Motion Hearing set for 8/30/2010 at 10:30 AM before Magistrate Judge T Lane Wilson) (Re: 66 MOTION to Compel Discovery Responses from Certain Plaintiffs ) (crp, Dpty Clk) (Entered: 08/19/2010)
68 Unopposed MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s) (Re: 66 MOTION to Compel Discovery Responses from Certain Plaintiffs ) by All Plaintiffs (Williams, Gregory) (Entered: 08/23/2010)
***Motion(s) Referred to Magistrate Judge Wilson (Re: 68 Unopposed MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s) ) (crp, Dpty Clk) (Entered: 08/24/2010)
69 MINUTE ORDER by Magistrate Judge T Lane Wilson the hearing scheduled for 8/30/10 is rescheduled for 9/8/10 ; setting/resetting deadline(s)/hearing(s): ( Motion Hearing set for 9/8/2010 at 09:30 AM before Magistrate Judge T Lane Wilson); granting 68 Motion to Accelerate/Extend/Reset Hearing(s)/Deadline(s) (Re: 66 MOTION to Compel Discovery Responses from Certain Plaintiffs ) (crp, Dpty Clk) (Entered: 08/24/2010)

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 16 of 37

08/25/2010 08/26/2010 09/08/2010
09/17/2010 10/14/2010
11/05/2010 12/15/2010 12/16/2010
12/17/2010
12/17/2010
12/20/2010 12/20/2010 12/20/2010 12/20/2010

70 RESPONSE in Opposition to Motion (Re: 66 MOTION to Compel Discovery Responses from Certain Plaintiffs ) by All Plaintiffs ; (With attachments) (Williams, Gregory) (Entered: 08/25/2010)
71 REPLY to Response to Motion (Re: 66 MOTION to Compel Discovery Responses from Certain Plaintiffs ) by Delaware County Sheriff ; (Gooch, Ambre) (Entered: 08/26/2010)
72 MINUTES of Proceedings − held before Magistrate Judge T Lane Wilson: Motion Hearing held on 9/8/2010 ; setting/resetting deadline(s)/hearing(s): The Court will initiate the 9/17/10 telephone conference. ( Miscellaneous Hearing set for 9/17/2010 at 10:00 AM before Magistrate Judge T Lane Wilson); granting in part and denying in part 66 Motion to Compel (Re: 66 MOTION to Compel Discovery Responses from Certain Plaintiffs ) (Court Reporter: C1) (crp, Dpty Clk) (Entered: 09/08/2010)
73 MINUTES of Proceedings − held before Magistrate Judge T Lane Wilson: Discovery Hearing held on 9/17/2010, setting/resetting deadline(s)/hearing(s): ( Discovery Hearing set for 10/15/2010 at 10:00 AM before Magistrate Judge T Lane Wilson) (Court Reporter: C1) (crp, Dpty Clk) (Entered: 09/17/2010)
74 MINUTE ORDER by Magistrate Judge T Lane Wilson per advice of the parties that this issue has been resolved, the telephone conference scheduled for 10/15/10 is stricken, striking/terminating deadline(s)/Hearing(s) (Re: 73 Minutes of Discovery Hearing,, Setting/Resetting Deadline(s)/Hearing(s), Setting/Resetting Deadline(s)/Hearing(s) ) (crp, Dpty Clk) (Entered: 10/14/2010)
75 NOTICE of Attorney's Lien by All Plaintiffs (Garrett, David) (Entered: 11/05/2010)
76 MOTION to Compel Deposition Testimony of Certain Plaintiffs' Attorneys by Delaware County Sheriff (With attachments) (Gooch, Ambre) (Entered: 12/15/2010)
77 MINUTE ORDER by Magistrate Judge T Lane Wilson a telephone conference is scheduled for 12/17/10 at 9:30 a.m. (Court will initiate conference call), setting/resetting deadline(s)/hearing(s): A response does not need to be filed ( Motion Hearing set for 12/17/2010 at 09:30 AM before Magistrate Judge T Lane Wilson) (Re: 76 MOTION to Compel Deposition Testimony of Certain Plaintiffs' Attorneys ) (crp, Dpty Clk) (Entered: 12/16/2010)
78 MINUTE ORDER by Magistrate Judge T Lane Wilson TIME CHANGE ONLY for Telephone Conference (see #77), setting/resetting deadline(s)/hearing(s): ( Motion Hearing set for 12/17/2010 at 01:30 PM before Magistrate Judge T Lane Wilson) (Re: 76 MOTION to Compel Deposition Testimony of Certain Plaintiffs' Attorneys ) (kjp, Dpty Clk) (Entered: 12/17/2010)
79 MINUTES of Proceedings − held before Magistrate Judge T Lane Wilson: Motion Hearing held on 12/17/2010, setting/resetting deadline(s)/hearing(s): (Response due by 1/05/2011), ( Replies due by 1/10/2011, Motion Hearing set for 1/13/2011 at 02:00 PM before Magistrate Judge T Lane Wilson) (Re: 76 MOTION to Compel Deposition Testimony of Certain Plaintiffs' Attorneys ) (Court Reporter: C1) (kjp, Dpty Clk) (Entered: 12/17/2010)
80 NOTICE Notice of Deposition for Danny Littlefield by Delaware County Sheriff (Gooch, Ambre) Modified on 12/21/2010−This is discovery and should not be filed (lml, Dpty Clk). (Entered: 12/20/2010)
81 NOTICE Notice of Deposition for Lee Eberle by Delaware County Sheriff (Gooch, Ambre) Modified on 12/21/2010−This is discovery and should not be filed (lml, Dpty Clk). (Entered: 12/20/2010)
82 NOTICE Notice of Deposition for Michael Lewis by Delaware County Sheriff (Gooch, Ambre) Modified on 12/21/2010−This is discovery and should not be filed (lml, Dpty Clk). (Entered: 12/20/2010)
83 NOTICE Notice of Deposition for Rick Yohn by Delaware County Sheriff (Gooch, Ambre) Modified on 12/21/2010−This is discovery and should not be filed (lml, Dpty Clk). (Entered: 12/20/2010)

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 17 of 37

12/20/2010 12/21/2010
01/03/2011 01/04/2011
01/05/2011 01/05/2011
01/05/2011
01/06/2011 01/07/2011
01/12/2011 01/12/2011 01/14/2011 01/17/2011 01/17/2011 01/17/2011 01/17/2011 01/18/2011

84 NOTICE Notice of Deposition for Susa Hopper by Delaware County Sheriff (Gooch, Ambre) Modified on 12/21/2010−This is discovery and should not be filed (lml, Dpty Clk). (Entered: 12/20/2010)
NOTICE of Docket Entry Modification; Error: These are discovery documents and should not be filed per FRCP 5(d)(1) and Local Rule 26.3; Correction: Notified counsel that these are discovery and should not have been filed (Re: 82 Notice (Other), 84 Notice (Other), 81 Notice (Other), 80 Notice (Other), 83 Notice (Other) ) (lml, Dpty Clk) (Entered: 12/21/2010)
85 MOTION to Quash by Richard L Yohn (sdc, Dpty Clk) (Entered: 01/04/2011)
86 MOTION for Protective Order regarding Plaintiffs' Fed. R. Civ. P. 30(b)(6) Deposition Notice by Delaware County Sheriff (With attachments) (Gooch, Ambre) Modified on 1/10/2011−WITHDRAWN PER MINUTE ORDER #91 (lml, Dpty Clk). (Entered: 01/04/2011)
87 Unopposed MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s) to January 14, 2011 by All Plaintiffs (Seymour, R) (Entered: 01/05/2011)
88 MINUTE ORDER by Magistrate Judge T Lane Wilson (EXPEDITING RESPONSE AND REPLY DEADLINES). The hearing scheduled for 1/13/11 is rescheduled for 1/25/11 ; setting/resetting deadline(s)/hearing(s): (Magistrate Courtroom No. 2, Third Floor) ( Responses due by 1/14/2011, Replies due by 1/21/2011, Motion Hearing set for 1/25/2011 at 09:30 AM before Magistrate Judge T Lane Wilson); granting 87 Motion to Accelerate/Extend/Reset Hearing(s)/Deadline(s) (Re: 76 MOTION to Compel Deposition Testimony of Certain Plaintiffs' Attorneys, 85 MOTION to Quash ) (crp, Dpty Clk) (Entered: 01/05/2011)
89 MINUTE ORDER by Magistrate Judge T Lane Wilson (EXPEDITING RESPONSE DEADLINE), setting/resetting deadline(s)/hearing(s): ( Responses due by 1/7/2011) (Re: 86 MOTION for Protective Order regarding Plaintiffs' Fed. R. Civ. P. 30(b)(6) Deposition Notice ) (crp, Dpty Clk) (Entered: 01/05/2011)
90 MOTION to Withdraw Document(s) (Re: 86 MOTION for Protective Order regarding Plaintiffs' Fed. R. Civ. P. 30(b)(6) Deposition Notice ) by Delaware County Sheriff (Gooch, Ambre) (Entered: 01/06/2011)
91 MINUTE ORDER by Magistrate Judge T Lane Wilson ; striking/withdrawing document(s); granting 90 Motion to Withdraw Documents(s) (Re: 86 MOTION for Protective Order regarding Plaintiffs' Fed. R. Civ. P. 30(b)(6) Deposition Notice ) (Documents Terminated: 86 MOTION for Protective Order regarding Plaintiffs' Fed. R. Civ. P. 30(b)(6) Deposition Notice ) (crp, Dpty Clk) (Entered: 01/07/2011)
92 MOTION to Quash by Michael D Lewis (s−srt, Dpty Clk) (Entered: 01/12/2011)
93 RESPONSE in Opposition to Motion (Re: 85 MOTION to Quash ) by Delaware County Sheriff ; (Gooch, Ambre) (Entered: 01/12/2011)
94 RESPONSE in Opposition to Motion (Re: 76 MOTION to Compel Deposition Testimony of Certain Plaintiffs' Attorneys ) by All Plaintiffs ; (Seymour, R) (Entered: 01/14/2011)
95 RESPONSE in Opposition to Motion (Re: 92 MOTION to Quash ) by Delaware County Sheriff ; (Gooch, Ambre) (Entered: 01/17/2011)
96 RESPONSE (Re: 85 MOTION to Quash ) by Delaware County Sheriff (Gooch, Ambre) (Entered: 01/17/2011)
97 MOTION to Compel Plaintiffs Counsel To Comply with LCvR 37.1, 83.7, and 83.8 by Delaware County Sheriff (With attachments) (Gooch, Ambre) (Entered: 01/17/2011)
98 Amended MOTION to Compel Plaintiffs Lead Counsel To Comply with LCvR 37.1, 83.7, and 83.8 by Delaware County Sheriff (With attachments) (Gooch, Ambre) (Entered: 01/17/2011)
99 MOTION to depose inmate plaintiff Cynthia Craig by Delaware County Sheriff (Gooch, Ambre) (Entered: 01/18/2011)

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 18 of 37

01/18/2011 01/18/2011 01/18/2011 01/19/2011 01/19/2011 01/19/2011 01/20/2011 01/24/2011
01/25/2011
02/02/2011 02/02/2011 02/03/2011 02/07/2011
02/07/2011 02/08/2011 02/08/2011 02/08/2011

100 RESPONSE in Opposition to Motion (Re: 98 Amended MOTION to Compel Plaintiffs Lead Counsel To Comply with LCvR 37.1, 83.7, and 83.8 ) by All Plaintiffs ; (With attachments) (Seymour, R) (Entered: 01/18/2011)
101 MOTION to Amend Third Amended Complaint (Re: 31 Amended Complaint ) by All Plaintiffs (Williams, Gregory) (Entered: 01/18/2011)
102 ERRATA/CORRECTION (Re: 101 MOTION to Amend Third Amended Complaint ) by All Plaintiffs (With attachments) (Williams, Gregory) (Entered: 01/18/2011)
103 REPLY to Response to Motion (Re: 76 MOTION to Compel Deposition Testimony of Certain Plaintiffs' Attorneys ) by Delaware County Sheriff ; (With attachments) (Gooch, Ambre) (Entered: 01/19/2011)
104 REPLY to Response to Motion (Re: 98 Amended MOTION to Compel Plaintiffs Lead Counsel To Comply with LCvR 37.1, 83.7, and 83.8 ) by Delaware County Sheriff ; (Gooch, Ambre) (Entered: 01/19/2011)
105 RESPONSE in Opposition to Motion (Re: 101 MOTION to Amend Third Amended Complaint ) by Delaware County Sheriff ; (With attachments) (Gooch, Ambre) (Entered: 01/19/2011)
106 ORDER by Magistrate Judge T Lane Wilson ; denying 97 Motion to Compel; denying 98 Motion to Compel (crp, Dpty Clk) (Entered: 01/20/2011)
107 MINUTE ORDER by Magistrate Judge T Lane Wilson, setting/resetting deadline(s)/hearing(s): ( Motion Hearing set for 1/25/2011 at 09:30 AM before Magistrate Judge T Lane Wilson) (Re: 92 MOTION to Quash ) (crp, Dpty Clk) (Entered: 01/24/2011)
108 MINUTES of Proceedings − held before Magistrate Judge T Lane Wilson: Motion Hearing held on 1/25/2011 ; striking/terminating deadline(s)/Hearing(s); denying 76 Motion to Compel; finding as moot 85 Motion to Quash; finding as moot 92 Motion to Quash (Re: 92 MOTION to Quash, 85 MOTION to Quash, 76 MOTION to Compel Deposition Testimony of Certain Plaintiffs' Attorneys ) (Court Reporter: C2) (crp, Dpty Clk) (Entered: 01/25/2011)
109 REPLY to Response to Motion (Re: 101 MOTION to Amend Third Amended Complaint ) by All Plaintiffs ; (Seymour, R) (Entered: 02/02/2011)
110 MOTION to Compel Production of Documents by All Plaintiffs (Seymour, R) (Entered: 02/02/2011)
111 MOTION to Compel Answers to Plaintiffs' First Set of Interrogatories by All Plaintiffs (Seymour, R) (Entered: 02/03/2011)
112 MINUTE ORDER by Magistrate Judge T Lane Wilson (EXPEDITING RESPONSE AND REPLY DEADLINES). A telephone conference is scheduled for 2/15/11 at 9:30 a.m. (Court will initiate conference call), setting/resetting deadline(s)/hearing(s): ( Responses due by 2/9/2011, Replies due by 2/11/2011, Motion Hearing set for 2/15/2011 at 09:30 AM before Magistrate Judge T Lane Wilson) (Re: 110 MOTION to Compel Production of Documents, 111 MOTION to Compel Answers to Plaintiffs' First Set of Interrogatories ) (crp, Dpty Clk) (Entered: 02/07/2011)
113 MINUTE ORDER by Judge James H Payne : Granting plaintiffs leave to file a 4th Amended Complaint by 2/11/2011 ; granting 101 Motion to Amend (Re: 31 Amended Complaint ) (pll, Dpty Clk) (Entered: 02/07/2011)
114 Fourth AMENDED COMPLAINT with Jury Demand against All Defendants (Re: 31 Amended Complaint ) by All Plaintiffs (Williams, Gregory) (Entered: 02/08/2011)
115 RESPONSE in Opposition to Motion (Re: 111 MOTION to Compel Answers to Plaintiffs' First Set of Interrogatories ) by Delaware County Sheriff ; (With attachments) (Gooch, Ambre) (Entered: 02/08/2011)
116 RESPONSE in Opposition to Motion (Re: 110 MOTION to Compel Production of Documents ) by Delaware County Sheriff ; (Anderson, Philip) (Entered: 02/08/2011)

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 19 of 37

02/10/2011
02/11/2011 02/11/2011 02/14/2011
02/15/2011
02/15/2011 02/16/2011 02/17/2011 02/18/2011 02/23/2011 02/23/2011 02/23/2011
02/23/2011
02/23/2011 02/23/2011

117 Unopposed MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s) Motion to Change Time of Court's Telephone Conference (Re: 112 Minute Order,,, Setting/Resetting Deadline(s)/Hearing(s), Setting/Resetting Deadline(s)/Hearing(s), Setting/Resetting Deadline(s)/Hearing(s) ) by All Plaintiffs (Williams, Gregory) (Entered: 02/10/2011)
118 REPLY to Response to Motion (Re: 110 MOTION to Compel Production of Documents ) by All Plaintiffs ; (Seymour, R) (Entered: 02/11/2011)
119 REPLY to Response to Motion (Re: 111 MOTION to Compel Answers to Plaintiffs' First Set of Interrogatories ) by All Plaintiffs ; (Seymour, R) (Entered: 02/11/2011)
120 MINUTE ORDER by Magistrate Judge T Lane Wilson (TIME CHANGE ONLY). The telephone conference scheduled for 2/15/11 at 9:30 a.m. is rescheduled for 2/15/11 at 1:00 p.m ; setting/resetting deadline(s)/hearing(s): (Court will initiate conference call) ( Motion Hearing set for 2/15/2011 at 01:00 PM before Magistrate Judge T Lane Wilson); granting 117 Motion to Accelerate/Extend/Reset Hearing(s)/Deadline(s) (Re: 110 MOTION to Compel Production of Documents, 111 MOTION to Compel Answers to Plaintiffs' First Set of Interrogatories ) (crp, Dpty Clk) (Entered: 02/14/2011)
121 MINUTE ORDER by Magistrate Judge T Lane Wilson the telephone conference scheduled for 2/15/11 at 1:00 p.m. is stricken. The Court will enter a written order regarding these motions., striking/terminating deadline(s)/Hearing(s) (Re: 111 MOTION to Compel Answers to Plaintiffs' First Set of Interrogatories, 110 MOTION to Compel Production of Documents ) (crp, Dpty Clk) (Entered: 02/15/2011)
122 ORDER by Magistrate Judge T Lane Wilson ; granting in part and denying in part 110 Motion to Compel; granting in part and denying in part 111 Motion to Compel (crp, Dpty Clk) (Entered: 02/15/2011)
123 ANSWER (Re: 114 Amended Complaint ) by Delaware County Sheriff (Gooch, Ambre) (Entered: 02/16/2011)
124 MINUTE ORDER by Judge James H Payne, referring motion(s) to Magistrate Wilson (Re: 99 MOTION to depose inmate plaintiff Cynthia Craig ) (pll, Dpty Clk) (Entered: 02/17/2011)
125 MINUTE ORDER by Magistrate Judge T Lane Wilson noting that a response has not been filed ; granting 99 Motion for Miscellaneous Relief (crp, Dpty Clk) (Entered: 02/18/2011)
126 MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s) by All Plaintiffs (Seymour, R) (Entered: 02/23/2011)
127 SUPPLEMENT (Re: 126 MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s) ) by All Plaintiffs (Seymour, R) (Entered: 02/23/2011)
128 MOTION to Compel Plaintiffs Appearance at Agreed Upon and Noticed Depositions, MOTION for Hearing for Expedited Ruling Since Next Deposition is February 25, 2011 by Delaware County Sheriff (With attachments) (Gooch, Ambre) Modified on 2/24/2011; THIS ENTRY WAS MADE IN ERROR − see 129 for Amended Motion to Compel (sac, Dpty Clk). (Entered: 02/23/2011)
129 Amended MOTION to Compel Plaintiffs Appearance at Agreed Upon and Noticed Depositions, MOTION for Hearing for Expedited Ruling Since Next Deposition is February 25, 2011 (Re: 128 MOTION to Compel Plaintiffs Appearance at Agreed Upon and Noticed Depositions MOTION for Hearing for Expedited Ruling Since Next Deposition is February 25, 2011 ) by Delaware County Sheriff (With attachments) (Gooch, Ambre) (Entered: 02/23/2011)
130 MOTION for Protective Order by All Plaintiffs (Williams, Gregory) Modified on 2/24/2011; this is a three−part motion of which only one part was efiled − see 133 for Motion to Quash and Motion for Hearing (sac, Dpty Clk). (Entered: 02/23/2011)
133 MOTION to Quash, MOTION for Hearing (both parts submitted as part of 130 ) (Re: 130 MOTION for Protective Order to Quash Deposition of Tammy Beavers, Et Al ) by All Plaintiffs (sac, Dpty Clk) (Entered: 02/24/2011)

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 20 of 37

02/24/2011 02/24/2011 02/24/2011
02/24/2011 02/24/2011 02/24/2011 02/24/2011 02/25/2011 02/27/2011 02/28/2011 02/28/2011 03/01/2011 03/01/2011 03/01/2011 03/21/2011 03/21/2011

131 RESPONSE in Opposition to Motion (Re: 129 Amended MOTION to Compel Plaintiffs Appearance at Agreed Upon and Noticed Depositions MOTION for Hearing for Expedited Ruling Since Next Deposition is February 25, 2011 ) by All Plaintiffs ; (Seymour, R) (Entered: 02/24/2011)
132 REPLY to Response to Motion (Re: 128 MOTION to Compel Plaintiffs Appearance at Agreed Upon and Noticed Depositions MOTION for Hearing for Expedited Ruling Since Next Deposition is February 25, 2011 ) by Delaware County Sheriff ; (Gooch, Ambre) (Entered: 02/24/2011)
NOTICE of Docket Entry Modification; Error: incomplete pdf attached; Correction: marked as Entered in Error − see 129 for Amended Motion to Compel (Re: 128 MOTION to Compel Plaintiffs Appearance at Agreed Upon and Noticed Depositions MOTION for Hearing for Expedited Ruling Since Next Deposition is February 25, 2011 ) (sac, Dpty Clk) (Entered: 02/24/2011)
NOTICE of Docket Entry Modification; Error: this is a three−part motion of which only one part was efiled; Correction: see 133 for Motion to Quash and Motion for Hearing (Re: 130 MOTION for Protective Order ) (sac, Dpty Clk) (Entered: 02/24/2011)
134 MOTION for Attorney Fees and Costs Resulting From Defendant's Fabricated Representation to the Court Concerning What the Handwritten Dispatch Logs Contain by All Plaintiffs (Seymour, R) (Entered: 02/24/2011)
135 RESPONSE in Opposition to Motion (Re: 126 MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s) ) by Delaware County Sheriff ; (With attachments) (Gooch, Ambre) (Entered: 02/24/2011)
136 REPLY to Response to Motion (Re: 126 MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s) ) by All Plaintiffs ; (Seymour, R) (Entered: 02/24/2011)
***Motion(s) Referred to Magistrate Judge Wilson (Re: 133 MOTION to Quash MOTION for Hearing (both parts submitted as part of 130 ) ) (lml, Dpty Clk) (Entered: 02/25/2011)
137 RESPONSE in Opposition to Motion (Re: 130 MOTION for Protective Order, 133 MOTION to Quash MOTION for Hearing (both parts submitted as part of 130 ) ) by Delaware County Sheriff ; (With attachments) (Gooch, Ambre) (Entered: 02/27/2011)
138 REPLY to Response to Motion (Re: 130 MOTION for Protective Order, 133 MOTION to Quash MOTION for Hearing (both parts submitted as part of 130 ) ) by All Plaintiffs ; (Seymour, R) (Entered: 02/28/2011)
139 RESPONSE in Opposition to Motion (Re: 134 MOTION for Attorney Fees and Costs Resulting From Defendant's Fabricated Representation to the Court Concerning What the Handwritten Dispatch Logs Contain ) by Delaware County Sheriff ; (Gooch, Ambre) (Entered: 02/28/2011)
140 REPLY to Response to Motion (Re: 134 MOTION for Attorney Fees and Costs Resulting From Defendant's Fabricated Representation to the Court Concerning What the Handwritten Dispatch Logs Contain ) by All Plaintiffs ; (Seymour, R) (Entered: 03/01/2011)
141 ORDER by Magistrate Judge T Lane Wilson ; granting 129 Motion to Compel; denying 129 Motion for Hearing; denying 130 Motion for Protective Order; denying 133 Motion to Quash; denying 133 Motion for Hearing (kah, Chambers) (Entered: 03/01/2011)
145 MOTION to Withdraw Document(s) (submitted as part of (dkt. # 140) (Re: 134 MOTION for Attorney Fees and Costs Resulting From Defendant's Fabricated Representation to the Court Concerning What the Handwritten Dispatch Logs Contain ) by All Plaintiffs (crp, Dpty Clk) (Entered: 03/25/2011)
142 Unopposed MOTION And Brief to Depose Inmate Plaintiff Tammy Beavers by Delaware County Sheriff (Anderson, Philip) (Entered: 03/21/2011)
143 MINUTE ORDER by Judge James H Payne, referring motion(s) to Magistrate Wilson (Re: 126 MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s), 134 MOTION

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 21 of 37

03/23/2011
03/25/2011 03/25/2011 03/25/2011 03/25/2011 03/30/2011
03/31/2011 04/01/2011 04/09/2011 04/13/2011
04/14/2011 05/06/2011 05/09/2011 05/12/2011

for Attorney Fees and Costs Resulting From Defendant's Fabricated Representation to the Court Concerning What the Handwritten Dispatch Logs Contain ) (pll, Dpty Clk) (Entered: 03/21/2011)
144 MINUTE ORDER by Magistrate Judge T Lane Wilson a telephone conference is scheduled for 3/25/11 at 9:30 a.m. on Dkt. # 126, and to discuss procedural issues related to Dkt. # 134. (Court will initiate conference call), setting/resetting deadline(s)/hearing(s): ( Motion Hearing set for 3/25/2011 at 09:30 AM before Magistrate Judge T Lane Wilson) (Re: 126 MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s), 134 MOTION for Attorney Fees and Costs Resulting From Defendant's Fabricated Representation to the Court Concerning What the Handwritten Dispatch Logs Contain ) (crp, Dpty Clk) (Entered: 03/23/2011)
***Motion(s) Referred to Magistrate Judge Wilson Motion to Withdraw Document(s) (dkt. # 145) (crp, Dpty Clk) Modified on 3/25/2011 to create link (crp, Dpty Clk). (Entered: 03/25/2011)
146 MINUTE ORDER by Magistrate Judge T Lane Wilson the telephone conference scheduled for 3/25/11 will now be only as to the Motion to Accelerate/Extend/Reset Hearing(s)/Deadline(s) (dkt. # 126) ; granting 145 Motion to Withdraw Documents(s) (crp, Dpty Clk) (Entered: 03/25/2011)
147 MINUTES of Proceedings − held before Magistrate Judge T Lane Wilson: Motion Hearing held on 3/25/2011, striking/terminating deadline(s)/Hearing(s), taking motion(s) under advisement (Re: 126 MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s) ) (Court Reporter: C1) (crp, Dpty Clk) (Entered: 03/25/2011)
148 MINUTE ORDER by Magistrate Judge T Lane Wilson a Revised Scheduling Order will be entered ; granting 126 Motion to Accelerate/Extend/Reset Hearing(s)/Deadline(s) (crp, Dpty Clk) (Entered: 03/25/2011)
149 SCHEDULING ORDER by Judge James H Payne (Amended), setting/resetting scheduling order date(s): ( Dispositive Motions due by 11/17/2011, Discovery due by 11/25/2011, Proposed Pretrial Order due by 12/14/2011, Pretrial Conference set for 12/21/2011 at 01:30 PM before Judge James H Payne, Jury Trial set for 1/23/2012 at 09:30 AM before Judge James H Payne) (pll, Dpty Clk) (Entered: 03/30/2011)
150 MINUTE ORDER by Judge James H Payne, referring motion(s) to Magistrate Wilson (Re: 142 Unopposed MOTION And Brief to Depose Inmate Plaintiff Tammy Beavers ) (pll, Dpty Clk) (Entered: 03/31/2011)
151 MINUTE ORDER by Magistrate Judge T Lane Wilson ; granting 142 Motion for Miscellaneous Relief (crp, Dpty Clk) (Entered: 04/01/2011)
152 Unopposed MOTION to Dismiss Party Katherine Buck Without Prejudice by Katherine Buck (Allen, Anthony) (Entered: 04/09/2011)
153 MINUTE ORDER by Magistrate Judge T Lane Wilson counsel for each of the parties is directed to meet and confer in compliance with LCvR 37.1 on or before 4/19/11 (Re: 60 Minutes of Motion Hearing, Striking/Terminating Deadline(s)/Hearing(s), Ruling on Motion to Compel, Ruling on Motion for Protective Order,, Striking/Terminating Deadline(s)/Hearing(s),, ) (crp, Dpty Clk) (Entered: 04/13/2011)
154 MOTION for Relief From Plaintiffs' Designation of All Deposition Testimony To−Date As "Highly Confidential" by Delaware County Sheriff (With attachments) (Anderson, Philip) (Entered: 04/14/2011)
155 MOTION To Submit Sealed Exhibits Pursuant to LCvR 79.1 and Brief in Support by Delaware County Sheriff (Gooch, Ambre) (Entered: 05/06/2011)
156 MOTION For An Order That "All Deposition Testimony" In This Case Shall Not Be Designated "Highly Confidential" by Delaware County Sheriff (With attachments) (Gooch, Ambre) (Entered: 05/09/2011)
157 MINUTE ORDER by Judge James H Payne, referring motion(s) to Magistrate Wilson (Re: 156 MOTION For An Order That "All Deposition Testimony" In This Case Shall Not Be Designated "Highly Confidential", 155 MOTION To Submit Sealed Exhibits Pursuant to LCvR 79.1 and Brief in Support, 154 MOTION for Relief From Plaintiffs'

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 22 of 37

05/17/2011
05/17/2011 05/18/2011 05/18/2011 05/18/2011 05/20/2011 05/23/2011
05/23/2011 05/23/2011 05/23/2011 05/23/2011 05/23/2011 05/24/2011 05/24/2011 05/24/2011 05/25/2011

Designation of All Deposition Testimony To−Date As "Highly Confidential" ) (pll, Dpty Clk) (Entered: 05/12/2011)
158 MINUTE ORDER by Magistrate Judge T Lane Wilson (EXPEDITING RESPONSE AND REPLY DEADLINES). The response is due by 5:00 p.m. on 5/20/11. The reply is due by 5/23/11. A telephone conference is scheduled for 5/26/11 at 3:00 p.m. Counsel Philip Anderson is to arrange the conference call and notify the parties and the Court of the conference call number ; setting/resetting deadline(s)/hearing(s): ( Responses due by 5/20/2011, Replies due by 5/23/2011, Motion Hearing set for 5/26/2011 at 03:00 PM before Magistrate Judge T Lane Wilson); granting 155 Motion for Miscellaneous Relief (Re: 154 MOTION for Relief From Plaintiffs' Designation of All Deposition Testimony To−Date As "Highly Confidential" ) (crp, Dpty Clk) (Entered: 05/17/2011)
159 ORDER by Magistrate Judge T Lane Wilson on or before 5/23/11, defendant shall amend its motion. The response is due on or before 6/1/11. (Re: 156 MOTION For An Order That "All Deposition Testimony" In This Case Shall Not Be Designated "Highly Confidential" ) (crp, Dpty Clk) (Entered: 05/17/2011)
160 MOTION And Brief For Order That Plaintiff Johnson Has Waived The Attorney Client Privilege With Attorney Susa Hopper On A Limited Basis by Delaware County Sheriff (With attachments) (Gooch, Ambre) (Entered: 05/18/2011)
161 SEALED DOCUMENT (Gooch, Ambre) (Entered: 05/18/2011)
162 Unopposed MOTION to Dismiss Party Stacey Buskirk by Stacey Buskirk (Williams, Gregory) (Entered: 05/18/2011)
163 RESPONSE in Support of Motion (Re: 154 MOTION for Relief From Plaintiffs' Designation of All Deposition Testimony To−Date As "Highly Confidential" ) by All Plaintiffs ; (Allen, Anthony) (Entered: 05/20/2011)
164 Amended MOTION For An Order That "All Deposition Testimony" In This Case Shall Not Be Designated "Highly Confidential" (Re: 156 MOTION For An Order That "All Deposition Testimony" In This Case Shall Not Be Designated "Highly Confidential" ) by Delaware County Sheriff (Gooch, Ambre) Modified on 5/24/2011 to correct event (tjc, Dpty Clk). (Entered: 05/23/2011)
165 MOTION to Seal Document Exhibits Pursuant to LCvR 79.1 and Brief In Support by Delaware County Sheriff (Gooch, Ambre) (Entered: 05/23/2011)
166 ERRATA/CORRECTION (Re: 165 MOTION to Seal Document Exhibits Pursuant to LCvR 79.1 and Brief In Support ) by Delaware County Sheriff (Gooch, Ambre) (Entered: 05/23/2011)
167 MOTION to Compel Plaintiff Bledsoe to Reappear for Deposition and Answer Certain Questions She was Instructed Not to Answer at Her Deposition by Delaware County Sheriff (With attachments) (Gooch, Ambre) Modified on 5/24/2011 to correct event (tjc, Dpty Clk). (Entered: 05/23/2011)
168 SEALED DOCUMENT (Gooch, Ambre) (Entered: 05/23/2011)
***Motion(s) Referred to Magistrate Judge Wilson (Re: 167 MOTION to Compel ) (tjc, Dpty Clk) (Entered: 05/24/2011)
NOTICE of Docket Entry Modification; Error: This was filed using the incorrect event (Motion to Amend); Correction: Edited docket text to reflect the correct event (Re: 164 MOTION For An Order That "All Deposition Testimony" In This Case Shall Not Be Designated "Highly Confidential" ) (tjc, Dpty Clk) (Entered: 05/24/2011)
NOTICE of Docket Entry Modification; Error: This was filed using the incorrect event (Motion for Miscellaneous Relief); Correction: Edited docket text to reflect the correct event (Re: 167 MOTION to Compel ) (tjc, Dpty Clk) (Entered: 05/24/2011)
169 MINUTE ORDER by Magistrate Judge T Lane Wilson ; granting 165 Motion to Seal Document(s) (crp, Dpty Clk) (Entered: 05/24/2011)
170 MINUTE ORDER by Magistrate Judge T Lane Wilson the telephone conference scheduled for 5/26/11 is rescheduled for 6/1/11 at 9:30 a.m., setting/resetting

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 23 of 37

05/25/2011 05/26/2011
05/26/2011 05/26/2011 05/26/2011 05/26/2011 05/26/2011 05/26/2011 05/27/2011
05/27/2011 05/31/2011
06/01/2011
06/01/2011

deadline(s)/hearing(s): Counsel Philip Anderson is to arrange the conference call and notify the parties and the Court of the conference call number ( Motion Hearing set for 6/1/2011 at 09:30 AM before Magistrate Judge T Lane Wilson) (Re: 154 MOTION for Relief From Plaintiffs' Designation of All Deposition Testimony To−Date As "Highly Confidential" ) (crp, Dpty Clk) (Entered: 05/25/2011)
171 MOTION To File Under Seal A Motion For Protective Order by All Plaintiffs (Seymour, R) Modified on 5/26/2011 to correct filer (lml, Dpty Clk). (Entered: 05/25/2011)
172 MINUTE ORDER by Magistrate Judge T Lane Wilson the Motion to Compel (dkt. # 167) is denied without prejudice because it does not comply with LCvR 37.1. ; striking/withdrawing document(s); denying 167 Motion to Compel (Re: 167 MOTION to Compel ) (Documents Terminated: 167 MOTION to Compel ) (crp, Dpty Clk) (Entered: 05/26/2011)
NOTICE of Docket Entry Modification; Error: Not all filers were selected when filed; Correction: Edited docket text and added "All Plaintiffs" as the filer (Re: 171 MOTION To File Under Seal A Motion For Protective Order ) (lml, Dpty Clk) (Entered: 05/26/2011)
173 MOTION to Compel and Brief to Compel Plaintiff Bledsoe To Appear For Deposition And Answer Certain Questions She Was Instructed Not To Answer At Her Deposition (Renewed) by Delaware County Sheriff (With attachments) (Gooch, Ambre) (Entered: 05/26/2011)
174 SEALED DOCUMENT (Gooch, Ambre) (Entered: 05/26/2011)
***Motion(s) Referred to Magistrate Judge Wilson (Re: 171 MOTION To File Under Seal A Motion For Protective Order ) (crp, Dpty Clk) (Entered: 05/26/2011)
175 MINUTE ORDER by Magistrate Judge T Lane Wilson ; granting 171 Motion for Miscellaneous Relief (crp, Dpty Clk) (Entered: 05/26/2011)
176 ORDER by Magistrate Judge T Lane Wilson ; granting 154 Motion for Relief (crp, Dpty Clk) (Entered: 05/26/2011)
177 MINUTE ORDER by Magistrate Judge T Lane Wilson per Minute Order (dkt. # 170), the telephone conference scheduled for 6/1/11 is stricken (Re: 170 Minute Order,,, Setting/Resetting Deadline(s)/Hearing(s), Setting/Resetting Deadline(s)/Hearing(s), Setting/Resetting Deadline(s)/Hearing(s), 176 Order, Ruling on Motion for Relief ) (crp, Dpty Clk) (Entered: 05/27/2011)
178 MOTION to Quash Depositions by All Plaintiffs (With attachments) (Seymour, R) (Entered: 05/27/2011)
179 MINUTE ORDER by Magistrate Judge T Lane Wilson (EXPEDITING RESPONSE AND REPLY DEADLINES). The response is due by 4:00 p.m. on 6/3/11. The reply is due by 5:00 p.m. on 6/6/11. A telephone conference is scheduled for 6/8/11 at 9:30 a.m. Counsel, Tom Seymour, is to arrange the conference call and notify all parties and the Court with the contact information, setting/resetting deadline(s)/hearing(s): ( Responses due by 6/3/2011, Replies due by 6/6/2011, Motion Hearing set for 6/8/2011 at 09:30 AM before Magistrate Judge T Lane Wilson) (Re: 178 MOTION to Quash Depositions ) (crp, Dpty Clk) (Entered: 05/31/2011)
180 MINUTE ORDER by Magistrate Judge T Lane Wilson (EXPEDITING RESPONSE AND REPLY DEADLINES), setting/resetting deadline(s)/hearing(s): ( Responses due by 6/8/2011, Replies due by 6/10/2011) (Re: 173 MOTION to Compel and Brief to Compel Plaintiff Bledsoe To Appear For Deposition And Answer Certain Questions She Was Instructed Not To Answer At Her Deposition (Renewed) ) (crp, Dpty Clk) (Entered: 06/01/2011)
181 RESPONSE in Opposition to Motion (Re: 156 MOTION For An Order That "All Deposition Testimony" In This Case Shall Not Be Designated "Highly Confidential", 164 MOTION For An Order That "All Deposition Testimony" In This Case Shall Not Be Designated "Highly Confidential" ) by All Plaintiffs ; (Allen, Anthony) (Entered: 06/01/2011)

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 24 of 37

06/02/2011 06/03/2011 06/03/2011 06/06/2011 06/06/2011 06/06/2011 06/06/2011 06/07/2011 06/07/2011 06/07/2011 06/07/2011
06/08/2011 06/08/2011 06/08/2011 06/08/2011 06/08/2011

182 REPLY to Response to Motion (Re: 164 MOTION For An Order That "All Deposition Testimony" In This Case Shall Not Be Designated "Highly Confidential" ) by Delaware County Sheriff ; (Anderson, Philip) (Entered: 06/02/2011)
183 RESPONSE in Opposition to Motion (Re: 178 MOTION to Quash Depositions ) by Delaware County Sheriff ; (With attachments) (Anderson, Philip) (Entered: 06/03/2011)
184 SEALED MOTION (Seymour, R) (Entered: 06/03/2011)
185 MINUTE ORDER by Judge James H Payne : Granting Plaintiff Buck's Motion to dismiss party ; terminating party Katherine Buck ; granting 152 Motion to Dismiss Party (pll, Dpty Clk) (Entered: 06/06/2011)
186 MOTION to Seal Document And Brief For Leave To Submit Response To Plaintiffs' Motion For Protective Order Regarding The Deposition Of Plaintiff Cynthia Craig Under Seal (Re: 184 SEALED MOTION ) by Delaware County Sheriff (Gooch, Ambre) (Entered: 06/06/2011)
187 REPLY to Response to Motion (Re: 178 MOTION to Quash Depositions ) by All Plaintiffs ; (With attachments) (Seymour, R) Modified on 6/7/2011; ENTERED IN ERROR − wrong PDF attached − See Doc # 188 for correct entry (tjc, Dpty Clk). (Entered: 06/06/2011)
188 REPLY to Response to Motion (Re: 178 MOTION to Quash Depositions ) by All Plaintiffs ; (With attachments) (Seymour, R) (Entered: 06/06/2011)
NOTICE of Docket Entry Modification; Error: Incorrect PDF attached; Correction: Edited docket text to reflect entered in error (Re: 187 Reply to Response to Motion ) (tjc, Dpty Clk) (Entered: 06/07/2011)
***Motion(s) Referred to Magistrate Judge Wilson (Re: 184 SEALED MOTION ) (crp, Dpty Clk) (Entered: 06/07/2011)
189 MINUTE ORDER by Magistrate Judge T Lane Wilson (EXPEDITING RESPONSE AND REPLY DEADLINES), setting/resetting deadline(s)/hearing(s): ( Responses due by 6/10/2011, Replies due by 6/13/2011) (Re: 184 SEALED MOTION ) (crp, Dpty Clk) (Entered: 06/07/2011)
190 MINUTE ORDER by Magistrate Judge T Lane Wilson the telephone conference scheduled for 6/8/11 is stricken., setting/resetting deadline(s)/hearing(s): All pending motions will be heard on 7/19/11. (Magistrate Courtroom No. 1, Third Floor) ( Motion Hearing set for 7/19/2011 at 09:30 AM before Magistrate Judge T Lane Wilson) (Re: 178 MOTION to Quash Depositions, 173 MOTION to Compel and Brief to Compel Plaintiff Bledsoe To Appear For Deposition And Answer Certain Questions She Was Instructed Not To Answer At Her Deposition (Renewed), 156 MOTION For An Order That "All Deposition Testimony" In This Case Shall Not Be Designated "Highly Confidential", 184 SEALED MOTION, 179 Minute Order, Setting/Resetting Deadline(s)/Hearing(s),, Setting/Resetting Deadline(s)/Hearing(s),, Setting/Resetting Deadline(s)/Hearing(s) ) (crp, Dpty Clk) (Entered: 06/07/2011)
191 MOTION to Seal Document And Brief For Leave To File Under Seal Motion To Strike by Delaware County Sheriff (Gooch, Ambre) (Entered: 06/08/2011)
192 MINUTE ORDER by Judge James H Payne : Because Plaintiff Stacey Buskirk was not included in the Fourth Amended Complaint and was therefore dismissed at that time, the Motion to dismiss party (#162) is MOOT ; finding as moot 162 Motion to Dismiss Party (pll, Dpty Clk) (Entered: 06/08/2011)
***Motion(s) Referred to Magistrate Judge Wilson (Re: 186 MOTION to Seal Document And Brief For Leave To Submit Response To Plaintiffs' Motion For Protective Order Regarding The Deposition Of Plaintiff Cynthia Craig Under Seal ) (crp, Dpty Clk) (Entered: 06/08/2011)
193 MINUTE ORDER by Magistrate Judge T Lane Wilson ; granting 186 Motion to Seal Document(s) (crp, Dpty Clk) (Entered: 06/08/2011)
194 MINUTE ORDER by Magistrate Judge T Lane Wilson ; striking/terminating deadline(s)/Hearing(s); granting in part 178 Motion to Quash (crp, Dpty Clk) Modified

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 25 of 37

06/08/2011 06/08/2011
06/09/2011 06/09/2011
06/09/2011 06/09/2011
06/10/2011 06/10/2011 06/13/2011 06/13/2011
06/13/2011 06/13/2011 06/13/2011 06/14/2011 06/14/2011 06/14/2011 06/14/2011 06/14/2011 06/14/2011

on 6/23/2011; Document STRICKEN per Minute Order # 228 (tjc, Dpty Clk). (Entered: 06/08/2011)
195 MOTION to Alter Order/Judgment (Re: 194 Minute Order) by All Plaintiffs (Seymour, R) Modified on 6/9/2011 to correct event title and create link to Doc #194 (lml, Dpty Clk). (Entered: 06/08/2011)
196 RESPONSE in Opposition to Motion (Re: 173 MOTION to Compel and Brief to Compel Plaintiff Bledsoe To Appear For Deposition And Answer Certain Questions She Was Instructed Not To Answer At Her Deposition (Renewed) ) by All Plaintiffs ; (Allen, Anthony) (Entered: 06/08/2011)
197 SEALED DOCUMENT (Gooch, Ambre) (Entered: 06/09/2011)
198 REPLY to Response to Motion (Re: 173 MOTION to Compel and Brief to Compel Plaintiff Bledsoe To Appear For Deposition And Answer Certain Questions She Was Instructed Not To Answer At Her Deposition (Renewed) ) by Delaware County Sheriff ; (With attachments) (Gooch, Ambre) (Entered: 06/09/2011)
199 SEALED DOCUMENT (Gooch, Ambre) (Entered: 06/09/2011)
NOTICE of Docket Entry Modification; Error: This was filed using the incorrect event (Motion for Miscellaneous Relief); Correction: Edited docket text to reflect correct event (Re: 195 MOTION to Alter Order/Judgment ) (lml, Dpty Clk) (Entered: 06/09/2011)
200 SEALED DOCUMENT (Gooch, Ambre) (Entered: 06/10/2011)
201 SEALED DOCUMENT (Gooch, Ambre) (Entered: 06/10/2011)
202 SEALED DOCUMENT (sdc, Dpty Clk) (Entered: 06/13/2011)
203 MOTION to Compel And Brief To Compel Plaintiff Craig to Comply With Rule 26 To Provide Supplemental Discovery Responses by Delaware County Sheriff (With attachments) (Gooch, Ambre) Modified; WITHDRAWN per 226 on 6/21/2011 (sac, Dpty Clk). (Entered: 06/13/2011)
204 SEALED DOCUMENT (Gooch, Ambre) (Entered: 06/13/2011)
205 Opposed MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s) by All Plaintiffs (Seymour, R) (Entered: 06/13/2011)
206 RESPONSE in Opposition to Motion (Re: 205 Opposed MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s) ) by Delaware County Sheriff ; (Gooch, Ambre) (Entered: 06/13/2011)
207 REPLY to Response to Motion (Re: 205 Opposed MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s) ) by All Plaintiffs ; (Seymour, R) (Entered: 06/14/2011)
208 Second MOTION for Protective Order by Cynthia Craig (Seymour, R) (Entered: 06/14/2011)
209 Amended MOTION to Seal Document (Re: 191 MOTION to Seal Document And Brief For Leave To File Under Seal Motion To Strike ) by Delaware County Sheriff (Gooch, Ambre) (Entered: 06/14/2011)
210 RESPONSE in Opposition to Motion (Re: 203 MOTION to Compel And Brief To Compel Plaintiff Craig to Comply With Rule 26 To Provide Supplemental Discovery Responses ) by Cynthia Craig ; (Seymour, R) (Entered: 06/14/2011)
***Motion(s) Referred to Magistrate Judge Wilson (Re: 205 Opposed MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s) ) (crp, Dpty Clk) (Entered: 06/14/2011)
211 MINUTE ORDER by Magistrate Judge T Lane Wilson ; setting/resetting deadline(s)/hearing(s): ( Replies due by 6/17/2011); granting 205 Motion to Accelerate/Extend/Reset Hearing(s)/Deadline(s) (Re: 184 SEALED MOTION ) (crp, Dpty Clk) (Entered: 06/14/2011)

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 26 of 37

06/14/2011 06/15/2011 06/15/2011 06/16/2011 06/17/2011 06/17/2011 06/17/2011 06/17/2011 06/17/2011 06/17/2011 06/20/2011
06/20/2011 06/20/2011
06/20/2011
06/20/2011

212 REPLY to Response to Motion (Re: 203 MOTION to Compel And Brief To Compel Plaintiff Craig to Comply With Rule 26 To Provide Supplemental Discovery Responses ) by Delaware County Sheriff ; (Gooch, Ambre) (Entered: 06/14/2011)
213 MOTION to Seal Document by Cynthia Craig (Seymour, R) (Entered: 06/15/2011)
214 MOTION For Fees Under Rule 37(a)(5) by All Plaintiffs (With attachments) (Seymour, R) Modified on 6/21/2011; WITHDRAWN per 226 (sac, Dpty Clk). (Entered: 06/15/2011)
215 MOTION to Seal Document And Brief For Leave To File Under Seal Its Response To Plaintiffs' Second Motion For Protective Order As To Cynthia Craig (Re: 208 Second MOTION for Protective Order ) by Delaware County Sheriff (Gooch, Ambre) (Entered: 06/16/2011)
216 MOTION to Withdraw Document(s) His Motion to Compel Filed June 13, 2011 At Doc. 203 (Re: 203 MOTION to Compel And Brief To Compel Plaintiff Craig to Comply With Rule 26 To Provide Supplemental Discovery Responses ) by Delaware County Sheriff (Gooch, Ambre) (Entered: 06/17/2011)
217 MOTION to Withdraw Document(s) (Re: 214 MOTION For Fees Under Rule 37(a)(5) ) by All Plaintiffs (Seymour, R) (Entered: 06/17/2011)
218 MOTION to Compel Production of Documents by All Plaintiffs (Seymour, R) (Entered: 06/17/2011)
***Motion(s) Referred to Magistrate Judge Wilson (Re: 213 MOTION to Seal Document ) (crp, Dpty Clk) (Entered: 06/17/2011)
219 MINUTE ORDER by Magistrate Judge T Lane Wilson ; granting 213 Motion to Seal Document(s) (crp, Dpty Clk) (Entered: 06/17/2011)
220 SEALED DOCUMENT (Seymour, R) (Entered: 06/17/2011)
***Motion(s) Referred to Magistrate Judge Wilson (Re: 191 MOTION to Seal Document And Brief For Leave To File Under Seal Motion To Strike, 160 MOTION And Brief For Order That Plaintiff Johnson Has Waived The Attorney Client Privilege With Attorney Susa Hopper On A Limited Basis, 216 MOTION to Withdraw Document(s) His Motion to Compel Filed June 13, 2011 At Doc. 203 MOTION to Withdraw Document(s) His Motion to Compel Filed June 13, 2011 At Doc. 203, 195 MOTION to Alter Order/Judgment, 214 MOTION For Fees Under Rule 37(a)(5), 164 MOTION For An Order That "All Deposition Testimony" In This Case Shall Not Be Designated "Highly Confidential", 209 Amended MOTION to Seal Document, 215 MOTION to Seal Document And Brief For Leave To File Under Seal Its Response To Plaintiffs' Second Motion For Protective Order As To Cynthia Craig, 217 MOTION to Withdraw Document(s) ) (crp, Dpty Clk) (Entered: 06/20/2011)
221 MINUTE ORDER by Magistrate Judge T Lane Wilson ; granting 191 Motion to Seal Document(s); granting 209 Motion to Seal Document(s) (crp, Dpty Clk) (Entered: 06/20/2011)
222 MINUTE ORDER by Magistrate Judge T Lane Wilson ; striking/withdrawing document(s); finding as moot 203 Motion to Compel; finding as moot 214 Motion for Miscellaneous Relief (Re: 214 MOTION For Fees Under Rule 37(a)(5), 203 MOTION to Compel And Brief To Compel Plaintiff Craig to Comply With Rule 26 To Provide Supplemental Discovery Responses ) (Documents Terminated: 203 MOTION to Compel And Brief To Compel Plaintiff Craig to Comply With Rule 26 To Provide Supplemental Discovery Responses, 214 MOTION For Fees Under Rule 37(a)(5) ) (crp, Dpty Clk) (Entered: 06/20/2011)
223 MINUTE ORDER by Magistrate Judge T Lane Wilson (EXPEDITING REPLY DEADLINE), setting/resetting deadline(s)/hearing(s): ( Responses due by 7/5/2011, Replies due by 7/13/2011, Motion Hearing set for 7/19/2011 at 09:30 AM before Magistrate Judge T Lane Wilson) (Re: 208 Second MOTION for Protective Order ) (crp, Dpty Clk) (Entered: 06/20/2011)
224 MINUTE ORDER by Magistrate Judge T Lane Wilson (EXPEDITING RESPONSE AND REPLY DEADLINES), setting/resetting deadline(s)/hearing(s): ( Responses due by 7/6/2011, Replies due by 7/14/2011, Motion Hearing set for 7/19/2011 at 09:30 AM

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 27 of 37

06/20/2011 06/20/2011
06/21/2011 06/22/2011
06/23/2011 06/23/2011 06/23/2011 06/24/2011
06/28/2011
06/28/2011 06/30/2011 06/30/2011 07/01/2011 07/05/2011 07/06/2011 07/06/2011 07/07/2011
07/07/2011 07/07/2011

before Magistrate Judge T Lane Wilson) (Re: 218 MOTION to Compel Production of Documents ) (crp, Dpty Clk) (Entered: 06/20/2011)
225 MINUTE ORDER by Magistrate Judge T Lane Wilson ; granting 215 Motion to Seal Document(s) (crp, Dpty Clk) (Entered: 06/20/2011)
226 MINUTE ORDER by Magistrate Judge T Lane Wilson ; granting 216 Motion to Withdraw Documents(s); granting 217 Motion to Withdraw Documents(s) (Re: 222 Minute Order,,, Striking/Withdrawing Document(s), Striking/Withdrawing Document(s), Striking/Withdrawing Document(s), Ruling on Motion to Compel,,, Ruling on Motion for Miscellaneous Relief,, ) (crp, Dpty Clk) (Entered: 06/20/2011)
227 SEALED MOTION (Gooch, Ambre) (Entered: 06/21/2011)
228 MINUTE ORDER by Magistrate Judge T Lane Wilson the Motion to Quash (dkt. # 178) is now moot ; striking/withdrawing document(s); granting 195 Motion to Alter Order/Judgment (Re: 194 Minute Order, Striking/Terminating Deadline(s)/Hearing(s), Ruling on Motion to Quash ) (Documents Terminated: 194 Minute Order, Striking/Terminating Deadline(s)/Hearing(s), Ruling on Motion to Quash ) (crp, Dpty Clk) (Entered: 06/22/2011)
229 Unopposed MOTION to Strike Hearing(s)/Deadline(s) by All Plaintiffs (Allen, Anthony) (Entered: 06/23/2011)
230 Fifth MOTION to Amend Complaint by All Plaintiffs (With attachments) (Allen, Anthony) (Entered: 06/23/2011)
***Motion(s) Referred to Magistrate McCarthy (Re: 229 Unopposed MOTION to Strike Hearing(s)/Deadline(s) ) (sac, Dpty Clk) (Entered: 06/24/2011)
231 SETTLEMENT CONFERENCE ORDER by Magistrate Judge Frank H McCarthy ; setting/resetting deadline(s)/hearing(s): ( Settlement Conference set for 11/9/2011 at 01:30 PM before Magistrate Judge Frank H McCarthy); granting 229 Motion to Strike Hearing(s)/Deadline(s) (jcm, Dpty Clk) (Entered: 06/24/2011)
232 MOTION to Seal Document And Brief for Leave to Submit Response and Reply Briefs Under Seal (Re: 230 Fifth MOTION to Amend Complaint ) by Delaware County Sheriff (Gooch, Ambre) (Entered: 06/28/2011)
233 MOTION to Seal Document by Jacquelyn Blossom (Seymour, R) (Entered: 06/28/2011)
234 MINUTE ORDER by Judge James H Payne, referring motion(s) to Magistrate Wilson (Re: 233 MOTION to Seal Document ) (pll, Dpty Clk) (Entered: 06/30/2011)
235 MINUTE ORDER by Magistrate Judge T Lane Wilson ; granting 233 Motion to Seal Document(s) (crp, Dpty Clk) (Entered: 06/30/2011)
236 SEALED DOCUMENT (Seymour, R) (Entered: 07/01/2011)
237 SEALED DOCUMENT (Gooch, Ambre) (Entered: 07/05/2011)
238 MOTION to Compel Production of Documents by All Plaintiffs (With attachments) (Seymour, R) (Entered: 07/06/2011)
239 RESPONSE in Opposition to Motion (Re: 218 MOTION to Compel Production of Documents ) by Delaware County Sheriff ; (Gooch, Ambre) (Entered: 07/06/2011)
240 BRIEF in Support of Motion (Re: 218 MOTION to Compel Production of Documents ) by All Plaintiffs ; (Seymour, R) Modified on 7/8/2011 to delete prefix text of "preliminary"(sac, Dpty Clk). (Entered: 07/07/2011)
241 MOTION to Seal Document by Cynthia Craig (Seymour, R) (Entered: 07/07/2011)
242 MINUTE ORDER by Judge James H Payne, referring motion(s) to Magistrate Wilson (Re: 230 Fifth MOTION to Amend Complaint, 232 MOTION to Seal Document And Brief for Leave to Submit Response and Reply Briefs Under Seal, 241 MOTION to Seal Document, 227 SEALED MOTION ) (pll, Dpty Clk) (Entered: 07/07/2011)

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 28 of 37

07/07/2011
07/07/2011
07/08/2011 07/08/2011 07/08/2011
07/11/2011 07/12/2011 07/12/2011
07/12/2011 07/13/2011 07/13/2011 07/14/2011 07/14/2011

243 MINUTE ORDER by Magistrate Judge T Lane Wilson (EXPEDITING RESPONSE AND REPLY DEADLINES). The response is due by 4:00 p.m. on 7/13/11. The reply is due by 4:00 p.m. on 7/15/11, setting/resetting deadline(s)/hearing(s): ( Responses due by 7/13/2011, Replies due by 7/15/2011, Motion Hearing set for 7/19/2011 at 09:30 AM before Magistrate Judge T Lane Wilson) (Re: 238 MOTION to Compel Production of Documents ) (crp, Dpty Clk) (Entered: 07/07/2011)
244 MINUTE ORDER by Magistrate Judge T Lane Wilson (Re: 223 Minute Order,, Setting/Resetting Deadline(s)/Hearing(s), Setting/Resetting Deadline(s)/Hearing(s), 224 Minute Order,, Setting/Resetting Deadline(s)/Hearing(s), Setting/Resetting Deadline(s)/Hearing(s), 190 Minute Order,,,, Setting/Resetting Deadline(s)/Hearing(s), Setting/Resetting Deadline(s)/Hearing(s), Setting/Resetting Deadline(s)/Hearing(s), Setting/Resetting Deadline(s)/Hearing(s),,,, 243 Minute Order,, Setting/Resetting Deadline(s)/Hearing(s), Setting/Resetting Deadline(s)/Hearing(s) ) (crp, Dpty Clk) (Entered: 07/07/2011)
245 MINUTE ORDER by Magistrate Judge T Lane Wilson ; granting 241 Motion to Seal Document(s) (crp, Dpty Clk) (Entered: 07/08/2011)
246 SEALED DOCUMENT (Seymour, R) (Entered: 07/08/2011)
247 MINUTE ORDER by Magistrate Judge T Lane Wilson the Motion to Seal Document(s) (dkt. # 232) is granted. The remaining listed motions will be heard on 7/19/11 at 9:30 a.m. ; setting/resetting deadline(s)/hearing(s): (Magistrate Courtroom No. 1, Third Floor) ( Motion Hearing set for 7/19/2011 at 09:30 AM before Magistrate Judge T Lane Wilson); granting 232 Motion to Seal Document(s) (Re: 164 MOTION For An Order That "All Deposition Testimony" In This Case Shall Not Be Designated "Highly Confidential", 184 SEALED MOTION, 208 Second MOTION for Protective Order, 227 SEALED MOTION, 173 MOTION to Compel and Brief to Compel Plaintiff Bledsoe To Appear For Deposition And Answer Certain Questions She Was Instructed Not To Answer At Her Deposition (Renewed), 238 MOTION to Compel Production of Documents, 218 MOTION to Compel Production of Documents, 156 MOTION For An Order That "All Deposition Testimony" In This Case Shall Not Be Designated "Highly Confidential" ) (crp, Dpty Clk) (Entered: 07/08/2011)
248 NOTICE of Joint Argument Schedule by Delaware County Sheriff, All Plaintiffs (Gooch, Ambre) Modified on 7/12/2011 to add filers (tjc, Dpty Clk). (Entered: 07/11/2011)
NOTICE of Docket Entry Modification; Error: Not all filers were selected when filed; Correction: Edited docket text to add filers (Re: 248 Notice (Other) ) (tjc, Dpty Clk) (Entered: 07/12/2011)
249 MOTION to Supplement And Brief For Leave To Supplement Response to Plaintiffs' Motion For Protective Order Regarding The Deposition of Plaintiff Cynthia Craig And To Submit Supplementation Under Seal (Re: 200 Sealed Document ) by Delaware County Sheriff (Gooch, Ambre) Modified on 7/13/2011; this is a two−part motion of which only one part was efiled − see 250 for Motion to Seal Document(s) (sac, Dpty Clk). (Entered: 07/12/2011)
250 MOTION to Seal Document (submitted as part of 249 ) by Delaware County Sheriff (sac, Dpty Clk) (Entered: 07/13/2011)
NOTICE of Docket Entry Modification; Error: this is a two−part motion of which only one part was filed; Correction: efiled Motion to Seal Document(s) − see 250 (Re: 249 MOTION to Supplement And Brief For Leave To Supplement Response to Plaintiffs' Motion For Protective Order Regarding The Deposition of Plaintiff Cynthia Craig And To Submit Supplementation Under Seal ) (sac, Dpty Clk) (Entered: 07/13/2011)
251 SEALED DOCUMENT (Gooch, Ambre) (Entered: 07/13/2011)
252 SEALED DOCUMENT (Gooch, Ambre) (Entered: 07/14/2011)
253 MINUTE ORDER by Magistrate Judge T Lane Wilson ; granting 249 Motion to Supplement; granting 250 Motion to Seal Document(s) (crp, Dpty Clk) (Entered: 07/14/2011)

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 29 of 37

07/14/2011 07/14/2011 07/15/2011 07/15/2011 07/18/2011 07/18/2011 07/19/2011 07/19/2011 07/19/2011
07/20/2011 07/20/2011 07/20/2011 07/20/2011

254 SEALED DOCUMENT (Gooch, Ambre) (Entered: 07/14/2011)
255 SUPPLEMENT (Re: 200 Sealed Document ) by Delaware County Sheriff (Gooch, Ambre) (Entered: 07/14/2011)
256 REPLY to Response to Motion (Re: 218 MOTION to Compel Production of Documents ) by All Plaintiffs ; (Seymour, R) Modified on 7/18/2011 to change text to reflect correct event (sac, Dpty Clk). (Entered: 07/15/2011)
257 SEALED DOCUMENT (sdc, Dpty Clk) (Entered: 07/15/2011)
NOTICE of Docket Entry Modification; Error: wrong event selected (Brief in Support of Motion); Correction: changed text to reflect correct event (Reply to Response to Motion) (Re: 256 Brief in Support of Motion ) (sac, Dpty Clk) (Entered: 07/18/2011)
258 Unopposed MOTION for Leave to Appear By Telephone by All Plaintiffs (Williams, Gregory) (Entered: 07/18/2011)
259 MINUTE ORDER by Magistrate Judge T Lane Wilson the Court will initiate call ; granting 258 Motion for Leave to Appear (crp, Dpty Clk) (Entered: 07/19/2011)
260 ATTORNEY APPEARANCE by David Mitchell Garrett on behalf of All Plaintiffs (sdc, Dpty Clk) (Entered: 07/19/2011)
262 MINUTES of Proceedings − held before Magistrate Judge T Lane Wilson: Motion Hearing held on 7/19/2011 the Motion to Compel (dkt. # 238) is granted in part; denied in part and taken under advisement ; striking/terminating deadline(s)/Hearing(s); taking motion(s) under advisement; finding as moot 156 Motion for Miscellaneous Relief; granting 160 Motion for Miscellaneous Relief; finding as moot 164 Motion for Miscellaneous Relief; denying 184 Sealed Motion; denying 208 Motion for Protective Order; finding as moot 218 Motion to Compel; denying 227 Sealed Motion (Re: 173 MOTION to Compel and Brief to Compel Plaintiff Bledsoe To Appear For Deposition And Answer Certain Questions She Was Instructed Not To Answer At Her Deposition (Renewed), 156 MOTION For An Order That "All Deposition Testimony" In This Case Shall Not Be Designated "Highly Confidential", 160 MOTION And Brief For Order That Plaintiff Johnson Has Waived The Attorney Client Privilege With Attorney Susa Hopper On A Limited Basis, 238 MOTION to Compel Production of Documents, 218 MOTION to Compel Production of Documents, 164 MOTION For An Order That "All Deposition Testimony" In This Case Shall Not Be Designated "Highly Confidential", 261 Oral MOTION For Leave to Depose Inmate Plaintiff Craig, 184 SEALED MOTION, 227 SEALED MOTION, 208 Second MOTION for Protective Order ) (Court Reporter: C1) (crp, Dpty Clk) Modified on 7/20/2011 to correct the date of hearing (crp, Dpty Clk). (Entered: 07/20/2011)
261 Oral MOTION For Leave to Depose Inmate Plaintiff Craig by Delaware County Sheriff (crp, Dpty Clk) (Entered: 07/20/2011)
263 Unopposed MOTION for Appointment of Honorable Claire V. Eagan as Settlement Judge by All Plaintiffs (Seymour, R) (Entered: 07/20/2011)
264 ORDER by Magistrate Judge T Lane Wilson ; granting 261 Motion for Miscellaneous Relief (crp, Dpty Clk) (Entered: 07/20/2011)
265 ORDER by Magistrate Judge T Lane Wilson (Re: 160 MOTION And Brief For Order That Plaintiff Johnson Has Waived The Attorney Client Privilege With Attorney Susa Hopper On A Limited Basis, 262 Minutes of Motion Hearing, Striking/Terminating Deadline(s)/Hearing(s), Taking Motion(s) Under Advisement, Ruling on Motion for Miscellaneous Relief,,, Ruling on Sealed Motion, Ruling on Motion for Protective Order, Ruling on Motion to Compel,,, Striking/Terminating Deadline(s)/Hearing(s), Taking Motion(s) Under Advisement,,,,,,,,, Striking/Terminating Deadline(s)/Hearing(s), Taking Motion(s) Under Advisement,,,,,,,,, Striking/Terminating Deadline(s)/Hearing(s), Taking Motion(s) Under Advisement,,,,,,,,, Striking/Terminating Deadline(s)/Hearing(s), Taking Motion(s) Under Advisement,,,,,,,,, Striking/Terminating Deadline(s)/Hearing(s), Taking Motion(s) Under Advisement,,,,,,,,, Striking/Terminating Deadline(s)/Hearing(s), Taking Motion(s) Under Advisement,,,,,,, ) (crp, Dpty Clk) (Entered: 07/20/2011)

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 30 of 37

07/20/2011 07/26/2011 07/26/2011 08/04/2011 08/05/2011 08/05/2011 08/09/2011 08/10/2011 08/11/2011 08/11/2011 08/12/2011 08/12/2011 08/12/2011 08/16/2011
08/18/2011 08/18/2011

266 MOTION to Withdraw Attorney(s) by All Plaintiffs (Garrett, David) (Entered: 07/20/2011)
267 BRIEF in Support of Motion (Re: 238 MOTION to Compel Production of Documents ) by All Plaintiffs ; (Seymour, R) (Entered: 07/26/2011)
268 RESPONSE in Opposition to Motion (Re: 238 MOTION to Compel Production of Documents ) by Delaware County Sheriff ; (Anderson, Philip) (Entered: 07/26/2011)
269 MINUTE ORDER by Judge James H Payne ; referring Settlement Conference to Judge Eagan ; granting 263 Motion for Appointment (pll, Dpty Clk) (Entered: 08/04/2011)
270 MINUTE ORDER by Judge James H Payne : Following the entry of the Order (#269) referring this case to Judge Eagan for Settlement Conference, the 11/9/11 Settlement Conference in front of Judge McCarthy is hereby stricken, striking/terminating deadline(s)/Hearing(s) (pll, Dpty Clk) (Entered: 08/05/2011)
271 MINUTE ORDER by Judge James H Payne : Granting Plaintiff's Motion to withdraw attorney David Garrett ; terminating attorney David Mitchell Garrett ; granting 266 Motion to Withdraw Attorney(s) (pll, Dpty Clk) (Entered: 08/05/2011)
272 SETTLEMENT CONFERENCE ORDER by Magistrate Judge Paul J Cleary, setting/resetting deadline(s)/hearing(s): ( Settlement Conference set for 10/13/2011 at 09:30 AM before Chief Judge Claire V Eagan) (kjp, Dpty Clk) (Entered: 08/09/2011)
273 MOTION Anti−Hectoring Protective Order by All Plaintiffs (With attachments) (Seymour, R) (Entered: 08/10/2011)
274 MOTION to Compel Compliance With Court's Directive At The July 19, 2011 Hearing by Delaware County Sheriff (With attachments) (Gooch, Ambre) (Entered: 08/11/2011)
275 RESPONSE in Opposition to Motion (Re: 273 MOTION Anti−Hectoring Protective Order ) by Delaware County Sheriff ; (With attachments) (Gooch, Ambre) (Entered: 08/11/2011)
276 MOTION For Parties To Submit Sealed Filings Pursuant to LCvR 79.1 by Delaware County Sheriff (Gooch, Ambre) (Entered: 08/12/2011)
277 MINUTE ORDER by Magistrate Judge T Lane Wilson ; denying 273 Motion for Miscellaneous Relief (crp, Dpty Clk) (Entered: 08/12/2011)
278 MINUTE ORDER by Magistrate Judge T Lane Wilson denying as moot the Motion to Compel (dkt. # 274) in light of Minute Order (dkt. # 277) ; denying 274 Motion to Compel (crp, Dpty Clk) (Entered: 08/12/2011)
279 ORDER by Magistrate Judge T Lane Wilson defendant is to submit in camera documents on or before 9/9/11 (Re: 238 MOTION to Compel Production of Documents, 262 Minutes of Motion Hearing,,,,,,, Striking/Terminating Deadline(s)/Hearing(s), Striking/Terminating Deadline(s)/Hearing(s), Striking/Terminating Deadline(s)/Hearing(s), Striking/Terminating Deadline(s)/Hearing(s), Striking/Terminating Deadline(s)/Hearing(s), Striking/Terminating Deadline(s)/Hearing(s), Striking/Terminating Deadline(s)/Hearing(s), Taking Motion(s) Under Advisement, Taking Motion(s) Under Advisement, Taking Motion(s) Under Advisement, Taking Motion(s) Under Advisement, Taking Motion(s) Under Advisement, Taking Motion(s) Under Advisement, Taking Motion(s) Under Advisement, Ruling on Motion for Miscellaneous Relief,,,,,,,,,,,,,,,,,,,,, Ruling on Sealed Motion,,,,,,, Ruling on Motion for Protective Order,,,,,,, Ruling on Motion to Compel,,,,,,,,,,,,, ) (crp, Dpty Clk) (Main Document 279 replaced on 8/18/2011) (crp, Dpty Clk). Modified on 8/18/2011 to attach complete PDF (crp, Dpty Clk). (Entered: 08/16/2011)
280 NOTICE by Delaware County Sheriff (Gooch, Ambre) (Entered: 08/18/2011)
281 NOTICE of Docket Entry Modification; Error: The PDF was incomplete; Correction: Attached complete PDF (Re: 279 Order,,,,,,,,, ) (crp, Dpty Clk) (Entered: 08/18/2011)

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 31 of 37

08/26/2011 08/29/2011 08/29/2011 08/31/2011 09/07/2011 09/09/2011 09/09/2011 09/09/2011 09/12/2011 09/12/2011 09/12/2011
09/13/2011
09/13/2011 09/14/2011
09/14/2011 09/14/2011

282 MINUTE ORDER by Judge James H Payne, referring motion(s) to Magistrate Wilson (Re: 276 MOTION For Parties To Submit Sealed Filings Pursuant to LCvR 79.1 ) (pll, Dpty Clk) (Entered: 08/26/2011)
283 Unopposed MOTION to Compel Deposition Testimony by Delaware County Sheriff (With attachments) (Gooch, Ambre) (Entered: 08/29/2011)
284 MINUTE ORDER by Magistrate Judge T Lane Wilson ; granting 276 Motion for Miscellaneous Relief (crp, Dpty Clk) (Entered: 08/29/2011)
285 ORDER by Magistrate Judge T Lane Wilson ; granting 283 Motion to Compel (crp, Dpty Clk) (Entered: 08/31/2011)
286 ORDER by Magistrate Judge T Lane Wilson ; granting in part 173 Motion to Compel (jcm, Dpty Clk) (Entered: 09/07/2011)
287 MOTION Relief from Settlement Conference Requirement by All Plaintiffs (Seymour, R) (Entered: 09/09/2011)
288 Unopposed MOTION to Accelerate/Extend/Reset Settlement Deadline(s)/Conference by All Plaintiffs (Seymour, R) (Entered: 09/09/2011)
***Motion(s) Referred to Judge Eagan (Re: 287 MOTION Relief from Settlement Conference Requirement, 288 Unopposed MOTION to Accelerate/Extend/Reset Settlement Deadline(s)/Conference ) (sac, Dpty Clk) (Entered: 09/12/2011)
289 RESPONSE in Opposition to Motion (Re: 288 Unopposed MOTION to Accelerate/Extend/Reset Settlement Deadline(s)/Conference ) by Delaware County Sheriff ; (Gooch, Ambre) (Entered: 09/12/2011)
290 RESPONSE in Opposition to Motion (Re: 287 MOTION Relief from Settlement Conference Requirement ) by Delaware County Sheriff ; (Gooch, Ambre) (Entered: 09/12/2011)
291 REPLY to Response to Motion (Re: 288 Unopposed MOTION to Accelerate/Extend/Reset Settlement Deadline(s)/Conference ) by All Plaintiffs ; (Seymour, R) Modified on 9/13/2011 to correct title of event (lml, Dpty Clk). (Entered: 09/12/2011)
NOTICE of Docket Entry Modification; Error: This was filed using the incorrect event (Brief in Support); Correction: Edited docket text to reflect correct event (Reply to Response to Motion) (Re: 291 Brief in Support of Motion ) (lml, Dpty Clk) (Entered: 09/13/2011)
292 REPLY to Response to Motion (Re: 287 MOTION Relief from Settlement Conference Requirement ) by All Plaintiffs ; (Seymour, R) (Entered: 09/13/2011)
293 MINUTE ORDER by Magistrate Judge T Lane Wilson a telephone conference is scheduled for 9/15/11 at 11:00 a.m. Defendant's counsel, Ambre Gooch, is directed to arrange the conference call and notify the Court and parties of the conference call information, setting/resetting deadline(s)/hearing(s): ( Miscellaneous Hearing set for 9/15/2011 at 11:00 AM before Magistrate Judge T Lane Wilson) (crp, Dpty Clk) (Entered: 09/14/2011)
294 Unopposed MOTION for an Order Directing Dr. Roberson to Testify at his Deposition by Delaware County Sheriff (Gooch, Ambre) (Entered: 09/14/2011)
295 MINUTE ORDER by Chief Judge Claire V Eagan that Dkt. # 288 to reset the settlement conference is granted; Settlement Conference is reset for 11/1/11 at 9:30 a.m.; Dkt. # 287 motion for relief from attendance requirement is granted in part and denied in part: Plaintiffs incarcerated on that date are excused from personal attendance but should be available by phone; all other plaintiffs should appear in person. ; setting/resetting deadline(s)/hearing(s): ( Settlement Conference set for 11/1/2011 at 09:30 AM before Chief Judge Claire V Eagan); granting in part and denying in part 287 Motion for Miscellaneous Relief; granting 288 Motion to Accelerate/Extend/Reset Settlement Deadline(s)/Conference (Re: 272 Settlement Conference Order, Setting/Resetting Deadline(s)/Hearing(s) ) (RGG, Chambers) (Entered: 09/14/2011)

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 32 of 37

09/15/2011 09/15/2011 09/16/2011
09/16/2011 09/16/2011 09/16/2011 09/19/2011 09/20/2011 09/20/2011 09/20/2011 09/20/2011 09/29/2011 09/29/2011 09/29/2011 09/30/2011
09/30/2011
09/30/2011 10/01/2011 10/03/2011

296 MOTION to Expedite Ruling, MOTION to Seal Document by Delaware County Sheriff (Gooch, Ambre) (Entered: 09/15/2011)
304 MINUTES of Proceedings − held before Magistrate Judge T Lane Wilson: Miscellaneous Hearing held on 9/15/2011 (Court Reporter: C1) (crp, Dpty Clk) (Entered: 09/22/2011)
297 MINUTE ORDER by Judge James H Payne, referring motion(s) to Magistrate Wilson (Re: 296 MOTION to Expedite Ruling MOTION to Seal Document, 294 Unopposed MOTION for an Order Directing Dr. Roberson to Testify at his Deposition ) (pll, Dpty Clk) (Entered: 09/16/2011)
298 STIPULATION of Dismissal, dismissing Melissa Nelson, by Delaware County Sheriff, Melissa Nelson (Gooch, Ambre) (Entered: 09/16/2011)
299 MOTION to Strike Document(s) (Re: 296 MOTION to Expedite Ruling MOTION to Seal Document ) by All Plaintiffs (Seymour, R) (Entered: 09/16/2011)
305 MINUTES of Proceedings − held before Magistrate Judge T Lane Wilson: Miscellaneous Hearing held on 9/16/2011 (Court Reporter: C1) (crp, Dpty Clk) (Entered: 09/22/2011)
300 RESPONSE in Opposition to Motion (Re: 299 MOTION to Strike Document(s) ) by Delaware County Sheriff ; (Gooch, Ambre) (Entered: 09/19/2011)
301 REPLY to Response to Motion (Re: 299 MOTION to Strike Document(s) ) by All Plaintiffs ; (Seymour, R) (Entered: 09/20/2011)
302 ORDER by Magistrate Judge T Lane Wilson ; granting 294 Motion for Miscellaneous Relief (crp, Dpty Clk) (Entered: 09/20/2011)
***Motion(s) Referred to Magistrate Judge Wilson (Re: 299 MOTION to Strike Document(s) ) (crp, Dpty Clk) (Entered: 09/20/2011)
303 MINUTE ORDER by Magistrate Judge T Lane Wilson ; granting 296 Motion to Expedite Ruling; granting 296 Motion to Seal Document(s); denying 299 Motion to Strike Document(s) (crp, Dpty Clk) (Entered: 09/20/2011)
306 MOTION Restraining Order and For Sanctions by All Plaintiffs (With attachments) (Seymour, R) (Entered: 09/29/2011)
307 MOTION for Sanctions by All Plaintiffs (With attachments) (Seymour, R) (Entered: 09/29/2011)
308 MOTION for Hearing on 30(B)(6) Deposition by All Plaintiffs (With attachments) (Seymour, R) Modified on 9/30/2011 to correct typographical error in free text box (lml, Dpty Clk). (Entered: 09/29/2011)
309 MINUTE ORDER by Magistrate Judge T Lane Wilson a telephone conference is scheduled for 9/30/11 at 2:15 p.m. Counsel, Tom Seymour, is directed to arrange the conference call and notify the Court and all parties with the conference call number, setting/resetting deadline(s)/hearing(s): ( Discovery Hearing set for 9/30/2011 at 02:15 PM before Magistrate Judge T Lane Wilson) (crp, Dpty Clk) (Entered: 09/30/2011)
310 MINUTE ORDER by Magistrate Judge T Lane Wilson per advice from counsel that the discovery issue has been resolved, the telephone conference scheduled for 9/30/11 is stricken, striking/terminating deadline(s)/Hearing(s) (crp, Dpty Clk) (Entered: 09/30/2011)
311 MOTION to Amend Settlement Conference Statement Requirements by All Plaintiffs (Seymour, R) (Entered: 09/30/2011)
312 RESPONSE in Opposition to Motion (Re: 307 MOTION for Sanctions, 306 MOTION Restraining Order and For Sanctions ) by Delaware County Sheriff ; (With attachments) (Gooch, Ambre) (Entered: 10/01/2011)
313 MOTION for Protective Order Regarding Abusive, Oppressive Behavior By Mr. Seymour by Delaware County Sheriff (With attachments) (Gooch, Ambre) (Entered: 10/03/2011)

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 33 of 37

10/03/2011 10/03/2011 10/04/2011
10/04/2011 10/06/2011 10/11/2011 10/11/2011 10/11/2011 10/11/2011 10/11/2011 10/11/2011 10/12/2011 10/12/2011
10/13/2011
10/13/2011 10/17/2011 10/17/2011

314 RESPONSE in Opposition to Motion (Re: 311 MOTION to Amend Settlement Conference Statement Requirements ) by Delaware County Sheriff ; (Gooch, Ambre) (Entered: 10/03/2011)
316 MINUTES of Proceedings − held before Magistrate Judge T Lane Wilson: Miscellaneous Hearing held on 10/3/2011 re: deposition dispute (crp, Dpty Clk) (Entered: 10/04/2011)
315 MINUTE ORDER by Chief Judge Claire V Eagan that the motion 311 is granted in part and denied in part: granted as to extension of time; denied as to simultaneous submission. Plaintiffs' settlement conference statement is due 10/17/11; defendant's statement is due 10/25/11 ; granting in part and denying in part 311 Motion for Miscellaneous Relief (RGG, Chambers) (Entered: 10/04/2011)
317 MINUTES of Proceedings − held before Magistrate Judge T Lane Wilson: Miscellaneous Hearing held on 10/4/2011 parties to file simultaneous briefs no later than 5:00 p.m. on 10/11/11 (crp, Dpty Clk) (Entered: 10/04/2011)
318 REPLY to Response to Motion (Re: 307 MOTION for Sanctions, 306 MOTION Restraining Order and For Sanctions ) by All Plaintiffs ; (Seymour, R) (Entered: 10/06/2011)
319 MOTION to Strike Document(s) (Re: 313 MOTION for Protective Order Regarding Abusive, Oppressive Behavior By Mr. Seymour ) by All Plaintiffs (Seymour, R) (Entered: 10/11/2011)
320 MINUTE ORDER by Magistrate Judge T Lane Wilson per advice from counsel, Tom Seymour, that this issue has been resolved, the briefing schedule is stricken (Re: 317 Minutes of Miscellaneous Hearing ) (crp, Dpty Clk) (Entered: 10/11/2011)
321 ATTORNEY APPEARANCE by Betty Outhier Williams on behalf of Delaware County E911 Trust Authority (Williams, Betty) (Entered: 10/11/2011)
322 OBJECTION to Subpoena by Delaware County E911 Trust Authority (With attachments) (Williams, Betty) (Entered: 10/11/2011)
323 OBJECTION to Subpoena by Delaware County E911 Trust Authority (With attachments) (Williams, Betty) (Entered: 10/11/2011)
***Motion(s) Referred to Magistrate Wilson (Re: 319 MOTION to Strike Document(s) ) (sac, Dpty Clk) (Entered: 10/12/2011)
324 RESPONSE in Opposition to Motion (Re: 319 MOTION to Strike Document(s) ) by Delaware County Sheriff ; (Gooch, Ambre) (Entered: 10/12/2011)
325 MINUTE ORDER by Magistrate Judge T Lane Wilson (EXPEDITING RESPONSE AND REPLY DEADLINES). The response is due 10/17/11; Reply is due 10/18/11. A telephone conference is scheduled for 10/20/11 at 9:30 a.m. (Court will initiate conference call), setting/resetting deadline(s)/hearing(s): ( Discovery Hearing set for 10/20/2011 at 09:30 AM before Magistrate Judge T Lane Wilson) (Re: 322 Objection to Subpoena, 323 Objection to Subpoena ) (crp, Dpty Clk) (Entered: 10/12/2011)
326 MINUTE ORDER by Court Clerk, directing Delaware County E911 Trust Authority to file a Corporate Disclosure Statement pursuant to FRCvP 7.1 within seven (7) days of this order, if they have not already done so. The parties shall use the form entitled Corporate Disclosure Statement available on the Courts website (please do not refile if already filed on non−court form unless directed to do so). If you have already filed your Corporate Disclosure Statement in this case, you are reminded to file a Supplemental Corporate Disclosure Statement within a reasonable time of any change in the information that the statement requires. (s−srt, Dpty Clk) (Entered: 10/13/2011)
327 CORPORATE DISCLOSURE STATEMENT by Delaware County E911 Trust Authority (Williams, Betty) (Entered: 10/13/2011)
328 MOTION for Leave to Appear Telephonically by Sherry England (With attachments) (Williams, Gregory) (Entered: 10/17/2011)
329 RESPONSE in Opposition to Motion (Re: 328 MOTION for Leave to Appear Telephonically ) by Delaware County Sheriff ; (With attachments) (Gooch, Ambre)

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 34 of 37

10/17/2011 10/17/2011 10/18/2011 10/18/2011 10/18/2011
10/18/2011
10/19/2011
10/19/2011
10/19/2011 10/19/2011
10/20/2011 10/20/2011 10/20/2011 10/20/2011 10/21/2011 10/21/2011
10/24/2011

(Entered: 10/17/2011)
330 RESPONSE (Re: 323 OBJECTION to Subpoena) by All Plaintiffs (With attachments) (Williams, Gregory) Modified on 10/18/2011 to create link to Doc #323 (lml, Dpty Clk). (Entered: 10/17/2011)
331 RESPONSE (Re: 322 OBJECTION to Subpoena) by All Plaintiffs (With attachments) (Williams, Gregory) Modified on 10/18/2011 to create link to Doc #322 (lml, Dpty Clk). (Entered: 10/17/2011)
***Motion(s) Referred to Chief Judge Claire V Eagan (Re: 328 MOTION for Leave to Appear Telephonically ) (lml, Dpty Clk) (Entered: 10/18/2011)
332 REPLY to Response to Motion (Re: 328 MOTION for Leave to Appear Telephonically ) by Sherry England ; (Seymour, R) (Entered: 10/18/2011)
333 REPLY (Re: 322 OBJECTION to Subpoena, [331)RESPONSE) by Delaware County E911 Trust Authority (With attachments) (Williams, Betty) Modified on 10/19/2011 to correct event and add links to Doc # 322 and 331 (tjc, Dpty Clk). (Entered: 10/18/2011)
334 REPLY (Re: 323 OBJECTION to Subpoena, 330 RESPONSE) by Delaware County E911 Trust Authority (With attachments) (Williams, Betty) Modified on 10/19/2011 to correct event and add links to Doc # 323 and 330 (tjc, Dpty Clk). (Entered: 10/18/2011)
335 MINUTE ORDER by Chief Judge Claire V Eagan as ordered earlier, all non−incarcerated plaintiffs shall appear in person at the 11/1/11 settlement conference ; denying 328 Motion for Leave to Appear (RGG, Chambers) (Entered: 10/19/2011)
NOTICE of Docket Entry Modification; Error: These were filed using the incorrect events (Objection to Subpoena); Correction: Edited docket text to reflect the correct events (Reply) (Re: 333 Objection to Subpoena, 334 Objection to Subpoena ) (tjc, Dpty Clk) (Entered: 10/19/2011)
336 Unopposed MOTION to Strike Hearing(s)/Deadline(s) Telephonic Hearing Scheduled for 10−20−11 at 9:30 by All Plaintiffs (Williams, Gregory) (Entered: 10/19/2011)
337 MINUTE ORDER by Magistrate Judge T Lane Wilson the telephone conference scheduled for 10/20/11 is stricken ; striking/terminating deadline(s)/Hearing(s); granting 336 Motion to Strike Hearing(s)/Deadline(s) (Re: 322 Objection to Subpoena, 323 Objection to Subpoena ) (crp, Dpty Clk) (Entered: 10/19/2011)
338 MOTION to Seal Document Plaintiffs' Motion to File Briefs on Motion for Jury Instruction on Spoliation and Deliberate Withholding of Documents by All Plaintiffs (Seymour, R) (Entered: 10/20/2011)
339 SEALED MOTION (Gooch, Ambre) (Entered: 10/20/2011)
340 MOTION to Seal Document by Delaware County Sheriff (Gooch, Ambre) (Entered: 10/20/2011)
341 MOTION to Compel by All Plaintiffs (With attachments) (Seymour, R) (Entered: 10/20/2011)
***Motion(s) Referred to Magistrate Judge Wilson (Re: 340 MOTION to Seal Document, 339 SEALED MOTION ) (lml, Dpty Clk) (Entered: 10/21/2011)
342 MINUTE ORDER by Magistrate Judge T Lane Wilson (EXPEDITING RESPONSE AND REPLY DEADLINES), setting/resetting deadline(s)/hearing(s): (Magistrate Courtroom No. 2, Third Floor) ( Responses due by 10/27/2011, Replies due by 10/28/2011, Motion Hearing set for 11/3/2011 at 10:00 AM before Magistrate Judge T Lane Wilson) (Re: 341 MOTION to Compel ) (crp, Dpty Clk) (Entered: 10/21/2011)
343 MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s) (Re: 149 Scheduling Order, Setting/Resetting Scheduling Order Date(s),, Setting/Resetting Scheduling Order Date(s) ) by All Plaintiffs (Seymour, R) (Entered: 10/24/2011)

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 35 of 37

10/24/2011 10/24/2011 10/24/2011 10/24/2011 10/26/2011
10/27/2011 10/27/2011 10/27/2011 10/27/2011 10/28/2011 10/28/2011 10/31/2011
11/01/2011
11/01/2011
11/02/2011 11/04/2011 11/07/2011

344 RESPONSE in Opposition to Motion (Re: 343 MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s) ) by Delaware County Sheriff ; (Gooch, Ambre) (Entered: 10/24/2011)
345 ORDER by Magistrate Judge T Lane Wilson ; granting 340 Motion to Seal Document(s) (crp, Dpty Clk) (Entered: 10/24/2011)
346 Unopposed MOTION to Seal Document by All Plaintiffs (Seymour, R) (Entered: 10/24/2011)
347 SEALED MOTION (Gooch, Ambre) (Entered: 10/24/2011)
348 MINUTE ORDER by Judge James H Payne : Denying Plaintiffs' Motion for extension of time to file witness and exhibit lists. Witness and Exhibit Lists are to be filed by noon on October 27, 2011 ; denying 343 Motion to Accelerate/Extend/Reset Hearing(s)/Deadline(s) (pll, Dpty Clk) (Entered: 10/26/2011)
349 FINAL EXHIBIT LIST by Delaware County Sheriff (Gooch, Ambre) (Entered: 10/27/2011)
350 FINAL WITNESS LIST by Delaware County Sheriff (Gooch, Ambre) (Entered: 10/27/2011)
351 FINAL WITNESS LIST by All Plaintiffs (Seymour, R) (Entered: 10/27/2011)
352 RESPONSE in Opposition to Motion (Re: 341 MOTION to Compel ) by Delaware County Sheriff ; (Gooch, Ambre) (Entered: 10/27/2011)
353 FINAL EXHIBIT LIST by All Plaintiffs (Seymour, R) (Entered: 10/28/2011)
354 REPLY to Response to Motion (Re: 341 MOTION to Compel ) by All Plaintiffs ; (Seymour, R) (Entered: 10/28/2011)
355 MINUTE ORDER by Magistrate Judge T Lane Wilson (TIME CHANGE ONLY), setting/resetting deadline(s)/hearing(s): (Magistrate Courtroom No. 2, Third Floor) ( Motion Hearing set for 11/3/2011 at 11:00 AM before Magistrate Judge T Lane Wilson) (Re: 341 MOTION to Compel ) (crp, Dpty Clk) (Entered: 10/31/2011)
356 ORDER by Magistrate Judge T Lane Wilson the Motion to Compel (dkt. # 238) was previously granted in part ; granting in part and denying in part 238 Motion to Compel (Re: 262 Minutes of Motion Hearing, Striking/Terminating Deadline(s)/Hearing(s), Taking Motion(s) Under Advisement, Ruling on Motion for Miscellaneous Relief,,, Ruling on Sealed Motion, Ruling on Motion for Protective Order, Ruling on Motion to Compel,,, Striking/Terminating Deadline(s)/Hearing(s), Taking Motion(s) Under Advisement,,,,,,,,, Striking/Terminating Deadline(s)/Hearing(s), Taking Motion(s) Under Advisement,,,,,,,,, Striking/Terminating Deadline(s)/Hearing(s), Taking Motion(s) Under Advisement,,,,,,,,, Striking/Terminating Deadline(s)/Hearing(s), Taking Motion(s) Under Advisement,,,,,,,,, Striking/Terminating Deadline(s)/Hearing(s), Taking Motion(s) Under Advisement,,,,,,,,, Striking/Terminating Deadline(s)/Hearing(s), Taking Motion(s) Under Advisement,,,,,,, In Camera Documents Received ) (crp, Dpty Clk) (Entered: 11/01/2011)
357 MINUTE ORDER by Magistrate Judge T Lane Wilson the hearing scheduled for 11/3/11 is stricken at the parties' request and the motion will be deemed moot if the parties do not notify chambers otherwise within 30 days, striking/terminating deadline(s)/Hearing(s) (Re: 341 MOTION to Compel ) (crp, Dpty Clk) (Entered: 11/01/2011)
358 MINUTE ORDER by Judge James H Payne : All deadlines are stayed until November 9, 2011, at which time the schedule will be reinstated, if necessary (pll, Dpty Clk) (Entered: 11/02/2011)
359 Unopposed MOTION To Unseal Certain Depositions and Documents by All Plaintiffs (Seymour, R) (Entered: 11/04/2011)
360 MOTION to Enforce Settlement Agreement and to Enter Judgment by All Plaintiffs (With attachments) (Seymour, R) Modified on 11/8/2011 to seal PDF − see Minute Order #362 striking this document (a−hc, Dpty Clk). (Entered: 11/07/2011)

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 36 of 37

11/07/2011 11/08/2011
11/08/2011
11/16/2011 11/17/2011 11/17/2011 12/01/2011 12/01/2011
12/01/2011 12/07/2011
12/15/2011
12/16/2011
12/16/2011 12/19/2011 12/19/2011 12/20/2011 12/20/2011

361 MINUTE ORDER by Judge James H Payne, referring motion(s) to Judge Eagan (Re: 360 MOTION to Enforce Settlement Agreement and to Enter Judgment ) (pll, Dpty Clk) (Entered: 11/07/2011)
362 MINUTE ORDER by Chief Judge Claire V Eagan that Dkt. # 360 is stricken as inappropriately containing confidential settlement discussions; counsel to jointly call the settlement judge to arrange additional settlement meeting, striking/withdrawing document(s) (Re: 360 MOTION to Enforce Settlement Agreement and to Enter Judgment ) (Documents Terminated: 360 MOTION to Enforce Settlement Agreement and to Enter Judgment ) (RGG, Chambers) (Entered: 11/08/2011)
NOTICE of Docket Entry Modification; Error: Document contains confidential settlement discussions; Correction: Document is stricken and the PDF has been sealed (Re: 360 MOTION to Enforce Settlement Agreement and to Enter Judgment ) (lml, Dpty Clk) (Entered: 11/08/2011)
363 Joint MOTION to Approve Journal Entry of Judgment by Delaware County Sheriff (Gooch, Ambre) (Entered: 11/16/2011)
364 Unopposed MOTION to Unseal All But Two Depositions by Delaware County Sheriff (Gooch, Ambre) (Entered: 11/17/2011)
365 RESPONSE in Opposition to Motion (Re: 364 Unopposed MOTION to Unseal All But Two Depositions ) by All Plaintiffs ; (Seymour, R) (Entered: 11/17/2011)
366 JUDGMENT by Judge James H Payne ; entering judgment in favor of Plaintiffs against Defendant (terminates case) ; granting 363 Motion for Miscellaneous Relief (pll, Dpty Clk) (Entered: 12/01/2011)
367 MINUTE ORDER by Judge James H Payne, referring motion(s) to Magistrate Wilson (Re: 359 Unopposed MOTION To Unseal Certain Depositions and Documents, 364 Unopposed MOTION to Unseal All But Two Depositions ) (pll, Dpty Clk) (Entered: 12/01/2011)
***Civil Case Terminated (see document number 366 ) (tjc, Dpty Clk) (Entered: 12/02/2011)
368 MINUTE ORDER by Magistrate Judge T Lane Wilson ; setting/resetting deadline(s)/hearing(s): ( Miscellaneous Deadline set for 12/16/2011); denying 359 Motion for Miscellaneous Relief; granting 364 Motion for Miscellaneous Relief (crp, Dpty Clk) (Entered: 12/07/2011)
369 Joint MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s) (Re: 368 Minute Order, Setting/Resetting Deadline(s)/Hearing(s), Ruling on Motion for Miscellaneous Relief, ) by Delaware County Sheriff, All Plaintiffs (Gooch, Ambre) Modified on 12/16/2011 to add all plaintiffs as filer (sac, Dpty Clk). (Entered: 12/15/2011)
NOTICE of Docket Entry Modification; Error: not all filers were selected; Correction: added all plaintiffs as filers (Re: 369 Joint MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s)Joint MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s) ) (sac, Dpty Clk) (Entered: 12/16/2011)
370 NOTICE Notice of Assignment of Lien on Judgment by BOKF, NA (Higgins, James) (Entered: 12/16/2011)
371 SUPPLEMENT to Notice of Assignment of Lien on Judgment (Re: 370 Notice (Other) ) by BOKF, NA (With attachments) (Higgins, James) Modified on 12/20/2011 to reflect correct event (tjc, Dpty Clk). (Entered: 12/19/2011)
372 Joint MOTION to notify court of agreement on redacted depositions by All Plaintiffs, Delaware County Sheriff (Allen, Anthony) Modified on 12/20/2011 to add filer (tjc, Dpty Clk). (Entered: 12/19/2011)
NOTICE of Docket Entry Modification; Error: This was filed using the incorrect event (Notice (Other)); Correction: Edited docket text to reflect correct event (Supplement) (Re: 371 Notice (Other) ) (tjc, Dpty Clk) (Entered: 12/20/2011)
373 MINUTE ORDER by Court Clerk, directing BOKF, NA to file a Corporate Disclosure Statement pursuant to FRCvP 7.1 within seven (7) days of this order, if they have not

USDC ND/OK Case: 4:09-cv-407 As of: 02/01/2019 06:04 PM CST Page 37 of 37

12/20/2011 12/23/2011
12/27/2011 12/27/2011 12/28/2011 01/06/2012 01/10/2012 01/23/2012
02/02/2012 05/23/2012 05/24/2012

already done so. The parties shall use the form entitled Corporate Disclosure Statement available on the Courts website (please do not refile if already filed on non−court form unless directed to do so). If you have already filed your Corporate Disclosure Statement in this case, you are reminded to file a Supplemental Corporate Disclosure Statement within a reasonable time of any change in the information that the statement requires. (s−srt, Dpty Clk) (Entered: 12/20/2011)
NOTICE of Docket Entry Modification; Error: Not all filers were selected when filed; Correction: Edited docket text to add filer (Re: 372 Joint MOTION to notify court of agreement on redacted depositions ) (tjc, Dpty Clk) (Entered: 12/20/2011)
374 MINUTE ORDER by Judge James H Payne, referring motion(s) to Magistrate Wilson (Re: 369 Joint MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s)Joint MOTION to Accelerate/Extend/Reset Hearing(s)/Deadline(s), 372 Joint MOTION to notify court of agreement on redacted depositions ) (pll, Dpty Clk) (Entered: 12/23/2011)
375 MOTION for Court's Assistance by Delaware County Sheriff (Gooch, Ambre) Modified on 12/28/2011 to correct title of event (lml, Dpty Clk). (Entered: 12/27/2011)
376 MINUTE ORDER by Magistrate Judge T Lane Wilson ; granting 372 Motion for Miscellaneous Relief (crp, Dpty Clk) (Entered: 12/27/2011)
NOTICE of Docket Entry Modification; Error: This was filed using the incorrect event (Notice−Other); Correction: Edited docket text to reflect correct event (Motion for Miscellaneous Relief) (Re: 375 MOTION for Court's Assistance ) (lml, Dpty Clk) (Entered: 12/28/2011)
377 MINUTE ORDER by Magistrate Judge T Lane Wilson ; granting 369 Motion to Accelerate/Extend/Reset Hearing(s)/Deadline(s) (crp, Dpty Clk) (Entered: 01/06/2012)
378 MINUTE ORDER by Judge James H Payne, referring motion(s) to Magistrate Wilson (Re: 375 MOTION for Court's Assistance ) (pll, Dpty Clk) (Entered: 01/10/2012)
379 MINUTE ORDER by Magistrate Judge T Lane Wilson a telephone conference is scheduled for 2/9/12 at 11:00 a.m. Defendant's counsel, Ambre Gooch, is directed to arrange the conference call and notify the Court and parties of the contact number. No later than 2/3/12, counsel is directed to provide for the court's use, all exhibits they intend to rely upon., setting/resetting deadline(s)/hearing(s): ( Motion Hearing set for 2/9/2012 at 11:00 AM before Magistrate Judge T Lane Wilson) (Re: 375 MOTION for Court's Assistance ) (crp, Dpty Clk) (Entered: 01/23/2012)
380 MINUTE ORDER by Magistrate Judge T Lane Wilson per advice from counsel, Ambre Gooch, that the parties have resolved this issue ; striking/terminating deadline(s)/Hearing(s); finding as moot 375 Motion for Miscellaneous Relief (crp, Dpty Clk) (Entered: 02/02/2012)
381 RELEASE AND SATISFACTION of Judgment (Re: 366 JUDGMENT) by Delaware County Sheriff (Gooch, Ambre) Modified on 5/24/2012 to correct event and add link to Doc # 366 (tjc, Dpty Clk). (Entered: 05/23/2012)
NOTICE of Docket Entry Modification; Error: This was filed using the incorrect event (Notice (Other)); Correction: Edited docket text to reflect the correct event Release and Satisfaction of Judgment (Re: 381 Notice (Other) ) (tjc, Dpty Clk) (Entered: 05/24/2012)

 Case 4:09-cv-00407-JHP-tlw Document 2 Filed in USDC ND/OK on 06/24/09 Page 1 of 16

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OKLAHOMA

1. SHERRY ENGLAND,

)

2. KATRINA ROGERS,

)

3. CYNTHIA CRAIG, and

)

4. MARIE WATSON, all individuals, )

)

Plaintiffs,

)

vs.

)

)

SHERIFF OF DELAWARE COUNTY, )

in his official capacity,

)

)

Defendant.

)

CASEQ~ cv- 4 0 7 JHP TLW
JURY TRIAL DEMANDED ATTORNEY'S LIEN CLAIMED

COMPLAINT

Plaintiffs Sherry England, Katrina Rogers, Cynthia Craig, and Marie Watson (herein referred

to individually by name or collectively as "Plaintiffs"), by and through their attorneys, R.

Thomas Seymour and Scott A. Graham of Seymour & Graham, LLP, and Gregory Williams and

D. Mitchell Garrett of Garrett Law Office, P.C., and for their claims against the Defendant,

allege and state as follows:

1. At all material times Jay Blackfox has been the Sheriti of Delaware County, Oklahoma

(hereafter "Sheriff').

2. Delaware County, Oklahoma 1s a political subdivision of the State of Oklahoma

(hereafter "County").

3. Except as otherwise indicated, all acts and omissions referred to herein occurred within

the two years prior to the filing of this Complaint.

4. This Complaint arises under the Civil Rights statutes of the United States, specifically 42

U.S.C. § 1983.

5. Pursuant to 42 U.S.C. § 1983, this Court has jurisdiction.

Case 4:09-cv-00407-JHP-tlw Document 2 Filed in USDC ND/OK on 06/24/09 Page 2 of 16
6. All material allegations herein occurred within the Northern District of Oklahoma, thereby making venue proper in this Court. 7. The Sheriff is the final policy maker for all material conduct of the Sheriff of Delaware County and of the Sheriffs Office of Delaware County. There is no person who has authority over the Sheriff of Delaware County, acting in his capacity as sheriff. Both as to his own conduct and as to the conduct of his employees, because of his position as Sheriff of Delaware County, the Sheriff of Delaware County's acts, customs, policies, practices, failure to train and failure to supervise his employees alleged herein are attributable to the County as well as to the Sheriff in his official capacity. 8. Sheriff Blackfox is sued herein in his official capacity, for his own acts. and those of his predecessor, if any, in his official capacity. 9. All of the conduct alleged herein of the Sheriff of Delaware County and of his identified employees was the exercise of state authority within the meaning of 42 U.S.C. § 1983. 10. Recognizing the extraordinary vulnerability of persons who are inmates of a county jail for any reason and the extraordinary opportunities of sheriffs and of employees of sheriffs to prey upon the vulnerability of such persons, the statutes of the State of Oklahoma specifically protect such persons by mandating that any state, federal, county, municipal or political subdivision employee who has sexual intercourse with a person under the supervision of the Sheriff's Office of Delaware County is guilty of the crime of rape. 21 O.S. § 1111 (A) (7). Just as is the case for sexual intercourse with underage persons, consent is no defense to the crime of rape as described therein. 11. Recognizing the extraordinary vulnerability of persons who are inmates of a county jail for any reason and the extraordinary opportunities of sheriffs and of employees of sheriffs to
2

Case 4:09-cv-00407-JHP-tlw Document 2 Filed in USDC ND/OK on 06/24/09 Page 3 of 16
prey upon the vulnerability of such persons, the statutes of the State of Oklahoma specifically protect such persons by mandating that any state, federal, county, municipal or political subdivision employee who commits sodomy on a person under the supervision of the Sheriff's Office of Delaware County is guilty of the crime of forcible sodomy. 21 O.S. § 888 (B) (4). Just as is the case for sexual intercourse with underage persons, consent is no defense to the crime of forcible sodomy as described herein. 12. Recognizing the extraordinary vulnerability of persons who are inmates of a county jail for any reason, as well as of persons under the supervision of the Drug Court, and the extraordinary opportunities of sheriffs and employees of sheriffs to prey upon the vulnerability of such persons, the statutes of the State of Oklahoma specifically protect such persons by mandating that any state, federal, county, municipal or political subdivision employee who commits sexual battery on a person under the supervision of the Sheriffs Office of Delaware County is guilty of the crime of sexual battery. 21 O.S. § 1123 (B). Just as is the case for sexual intercourse with underage persons, consent is no defense to the crime of sexual battery as described herein. 13. Sheriff Blackfox has established as the policy, custom, usage and practice of (a) the Sheriff of Delaware County, (b) the Sheriffs Office of Delaware County, and (c) (by virtue of his position as Sheriff of Delaware County) Delaware County, Oklahoma, that the employees of the Sheriff of Delaware County are permitted to engage in rape, sodomy, sexual battery and blackmail as described herein, as the policy, custom, usage and practice of the Sheriff of Delaware County, the Sheriff's Office of Delaware County, and of Delaware County, Oklahoma. 14. Sheriff Blackfox has further established as the policy, custom, usage and practice of (a) the SheriffofDelaware County, (b) the Sheriffs Otlice ofDelaware County, and (c) (by virtue
3

Case 4:09-cv-00407-JHP-tlw Document 2 Filed in USDC ND/OK on 06/24/09 Page 4 of 16
of his position as Sheriff of Delaware County), Delaware County, Oklahoma, that the employees of the Sheriff's Office of Delaware County may, as a matter of the policy, custom, usage and practice of the Sheriff of Delaware County and of Delaware County, Oklahoma and/or as a matter of Sheriff Blackfox's failure to train and failure to supervise those employees, commit sexual battery on inmates of the Delaware County jail as well as commit all of the outrageous sexual advances, sexual harassment and sexual humiliation described herein. 15. These acts of rape, sodomy, sexual battery and blackmail described herein and committed by employees of the Sheriff of Delaware County deprived the identified Plaintiffs of their rights under the Fourth and Fourteenth Amendments to the Constitution of the United States to be free from unreasonable searches and seizures, their rights under the Fifth and Fourteenth Amendments to the Constitution of the United States to be afforded due process oflaw, and their rights under the Fifth and Fourteenth Amendments to the Constitution of the United States to have equal protection of the law and thereby not suffer the sexual degradation described herein. A reasonable person would have known that these acts of rape, sodomy, sexual battery and blackmail described herein deprived the identified Plaintiffs of their Constitutional rights as set forth in the preceding sentence. 16. The acts of sexual battery, outrageous sexual advances, sexual harassment and sexual humiliation committed by Sheriff Blackfox's employees as described herein deprived the identified Plaintiffs of their rights under the Fourth and Fourteenth Amendments to the Constitution of the United States to be free from unreasonable searches and seizures, and their rights under the Fifth and Fourteenth Amendments to the Constitution of the United States to be afforded equal protection and due process of law. A reasonable person would have known that Sheriff Blackfox's employees' acts of sexual battery, outrageous sexual advances, sexual
4

Case 4:09-cv-00407-JHP-tlw Document 2 Filed in USDC ND/OK on 06/24/09 Page 5 of 16
harassment and sexual humiliation described herein and/or his failure to train and failure to supervise his employees deprived the identified Plaintiffs of their Constitutional rights as set forth in the preceding sentence. 17. The identified employees' sexually degrading acts described herein were committed with deliberate indifference to the Constitutional rights of Plaintiffs set forth herein, and were the direct and proximate cause of Plaintiffs' damages. A reasonable person would have known these Constitutional rights were being violated as a result ofthe alleged conduct. 18. Plaintiff Sherry England was incarcerated in the Delaware County Jail from June 25, 2007 through July 7, 2007 on a charge of public intoxication. 19. During this time, she was housed in a cell block designed to hold lO inmates, having only 3 cells and I0 beds. At times, there were as many as 20 women held in the cell block. It was summertime, and the conditions were hot, crowded and deplorable. 20. Also during this time, the Delaware County jailers would "bargain" with the female inmates to show their breasts in exchange tor cigarettes, cupcakes, snacks, candy, personal items, and other things they could not obtain for themselves while in the Delaware County jail. 21. The jailers would listen over the intercom and when they knew female inmates were in the showers or using the toilet, the jailers would come in and watch the women come out of the shower and/or using the toilet. 22. While Ms. England was taking a shower, the jailers would just come in. The jailers would "bargain" with the female inmates to drop their towels to the floor in exchange for being taken outside for cigarettes and other favors. Ms. England began taking her clothes with her and getting dressed in the shower. 23. There were no female jailers at night. At night, the jailers would come into the cells in
5

Case 4:09-cv-00407-JHP-tlw Document 2 Filed in USDC ND/OK on 06/24/09 Page 6 of 16
the pods and grope the female inmates. Almost all of the male jailers were involved, including but not limited to, Bill Sanders, "Head Jailer Lonnie", "Leon", "Damen", "Don", "Carlos", "Lane", and a policeman from the City of Spavinaw who worked part-time at night as a Delaware County jailer. 24. At night the male jailers would bring T-shirts and boxer shorts into the pods for the female inmates to wear in the hot cells in exchange for "favors". 25. Sometimes when female inmates would be called out of their cells to go to the front to get their medications, the jailers would grope and/or kiss them. 26. Ms. England refused to show her breasts and rejected the jailers' advances. In retaliation and with deliberate indifference to her medical needs, the jailers withheld her medications and would not let her see the doctor. 27. Ms. England is an epileptic and requires prescription medication to prevent seizures. Ms. England had her prescription medication with her when she was booked into the Delaware County Jail and the jailers took it away from her. Due to the jailers' deliberate indifference to Ms. England's medical needs and refusing her medication, Ms. England began suffering bad seizures while in the Delaware County Jail. 28. Ms. England repeatedly asked to see the doctor and her requests were ignored by the jailers with deliberate indifference to her medical needs. The jailers told Ms. England that she didn't have any rights because she was in jail. 29. Ms. England had at least 5 bad seizures during those 18 days she was in the Delaware County Jail. 30. The depravity set forth in Paragraphs 18 through 29 violated Ms. England's Constitutional rights as set forth herein.
6

Case 4:09-cv-00407-JHP-tlw Document 2 Filed in USDC ND/OK on 06/24/09 Page 7 of 16
31. The depravity set forth in Paragraphs 18 through 29 subjected Ms. England to severe emotional distress and/or psychological damage and/or significant pain and suffering and/or personal humiliation. 32. Plaintiff Katrina Rogers was an inmate in the Delaware County Jail from January 11, 2008 through January 23, 2008. 33. Ms. Rogers was housed in the women's pod where there were only 2 cells with 4 beds per cell. Female inmates were sleeping in the shower because it was so crowded in the cells. There were at least 12-13 women in a cell at one time. There were cameras in the shower and Ms. Rogers knew the male jailers watched the female inmates while they showered. 34. Ms. Rogers was 5 months pregnant during this time so she put in a medical request to see the doctor. Deputy Bill Sanders ("Sanders") came to her cell personally within 2 hours of her request for a doctor. Sanders told Ms. Rogers that he had gotten her an appointment with a doctor the following day and would take her to the appointment himself. 35. The following morning as Ms. Rogers and Sanders were getting in the car at the Sheriff's office in Jay, Oklahoma, Sanders asked her, "Would you like to go see your mom?" Ms. Rogers indicated that she would as her mother's home was close to Dr. Hopper's office in Grove. As the car pulled away from the Sheriff's office, Sanders began groping Ms. Rogers' breasts as he was driving. Sanders also attempted to put his hand down Ms. Rogers' pants and kiss her. Sanders grabbed Ms. Rogers' hand and tried to put it on his penis. 36. Ms. Rogers was afraid to tell the doctor because she was terrified of the retaliation that Sanders threatened. After the doctor's appointment, Sanders stopped on the way back to the jail at the S&S Stop gas station on Highway 59 to get them something to eat. Sanders then said, "Since I did this for you, then you can pay me back" Sanders began rubbing Ms. Rogers' again,
7

Case 4:09-cv-00407-JHP-tlw Document 2 Filed in USDC ND/OK on 06/24/09 Page 8 of 16
and again attempted to put her hand on his penis. Sanders did this throughout the drive back, including stopping at the smoke shop to buy cigarettes for the female inmates. 37. Sanders told Ms. Rogers that he needed her mother's phone number so that he could call her about her doctor's appointments. Ms. Rogers gave Sanders the phone number. 38. Sanders told Ms. Rogers that she could not tell anybody about anything he did, because if she did, he could make her time in jail worse and that once she got out ofjail, he would see to it that Ms. Rogers got into more trouble. Sanders told Ms. Rogers, "[w]hen you get out, you need to come to my house and do this for me---I need to be with a woman. I need to have an orgasm and I want you to be the one to do it. You need to promise you're going to do this." Ms. Rogers did promise because she was intimidated into doing so. Ms. Rogers felt like she didn't have a choice. Sanders told Ms. Rogers that he only wanted oral sex from her because she was pregnant. 39. While Ms. Rogers was in her cell at the Delaware County Jail, she heard Sanders ask another female inmate, Kori White, to show him her breasts and her crotch. Ms. White did show Sanders her breasts. Other female inmates saw this as well. Ms. Rogers spoke with Ms. White about telling on Sanders. Ms. White said that probably wasn't a very good idea because she didn't want Ms. Rogers to get into any more trouble and didn't want anything to happen to Ms. Rogers. 40. Sanders told a female inmate that he would let her show him herself but he wouldn't touch her because she was too fat. This inmate was so embarrassed and hurt that she cried. 41. Sanders kept telling Ms. Rogers, "I'm trying to get you out of here quicker. I've been talking to the Sheriff. But if I get you out of here, you need to make sure you come to my house and orgasm."
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42. After Ms. Rogers was released from the Delaware County Jail on January 23, 2008, Sanders would call her every day, telling her that he loved her and he wanted her to love him. Sanders continually asked her, "[w]hen are you going to come and do those things you promised me you would do when you were in jail?" 43. Sanders began not only calling Ms. Rogers every day, but began coming to her house repeatedly and offering her things. Approximately four or five days after her release, Sanders showed up at Ms. Rogers' house and demanded she go with him. Ms. Rogers' 3 year-old protested so Ms. Rogers said her daughter had to go with her if she was going anywhere. The daughter fell asleep sitting between them in Sanders' truck. Sanders then began to grope Ms. Rogers, trying to kiss her and making her grope him over her daughter. Sanders drove around the county roads for an hour and a half telling Ms. Rogers never to say anything about the incident because if he got into trouble, he would make sure she got into trouble at least as bad. Finally Ms. Rogers' daughter woke up and had to go potty, which made Sanders take them home. 44. Sanders continued to show up at Ms. Rogers house (she lived with her mother) and if Ms. Rogers wasn't home, he would sit and wait. Sanders would wait for long periods of time talking to Ms. Rogers' mother. Sanders brought gifts to the mother, Ms. Rogers' children and Ms. Rogers. 45. As a result of the conduct of Deputy Sanders set forth above, Ms. Rogers has suffered severe emotional distress and/or psychological damage and/or significant pain and suffering and/or personal humiliation. 46. Plaintiff Cynthia Craig was an inmate at the Delaware County Jail from April23, 2008 through July 15, 2008. Ms. Craig is mentally disabled.
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47. Ms. Craig was held in a holding tank for 2-3 days, then put in general population. 48. Sanders told Ms. Craig that she looked good, that he liked her, and he wanted her to be "daddy's girl". Ms. Craig said she wasn't interested and Sanders then began to come to her cell, get "handsy" with her and ask to see her crotch. Sanders would insert a finger inside Ms. Craig's vagina and she would push him away. 49. Sanders took Ms. Craig to doctor appointments and wanted her to "play with him" when he was driving his patrol car in uniform. Ms. Craig would fight him off of her and Sanders would unzip his zipper and show his penis while he was driving. He told Ms. Craig to fondle him but she refused. On two occasions, Sanders pulled off the road in secluded areas and made Ms. Craig kiss him and then he began masturbating while he kissed her. These episodes lasted about a half an hour each, both on the way to the doctor's office and on the way back to the jail. 50. Sanders told Ms. Craig that if she told anyone about it, that she would regret it and he would make sure she would go to the penitentiary by making up stories that she tried to escape or he had problems with her. 51. When Sanders returned to the Delaware County Jail, he forced Ms. Craig to answer questions like "nothing happened, right?; You know I was good to you?" Only later did Ms. Craig realize the reason Sanders was doing this was he was recording it. 52. Sometime between April 23, 2008 and June 2, 2008, Ms. Craig went to the Oklahoma Forensic Center for about 2 weeks for mental evaluation. There she was diagnosed as having Post Traumatic Stress Disorder. When she returned to the Delaware County Jail, she was placed into a protective holding cell after she had demanded to talk to Sheriff Blackfox. Sanders then entered the protective cell, put Ms. Craig in the shower, turned it on so that nobody could bear her, made her take her clothes off and put his fingers inside her vagina. Sanders started kissing
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Ms. Craig and then raped her vaginally and anally several times alternately. Ms. Craig was terrified to scream because Sanders told her he would send her down the river. When he was finished, Sanders made Ms. Craig scrub herself in front of him and he took her clothes with him and brought her back a new regulation orange jumpsuit. Sanders came back for more but Ms. Craig refused, saying she didn't care what happened to her but he was not going to touch her again. 53. As a result of Sanders' conduct set forth above, Ms. Craig has suffered severe emotional distress and/or psychological damage and/or significant pain and suffering and/or personal humiliation. 54. Plaintiff Marie Watson was an inmate at the Delaware County Jail from May 20, 2008 through July 11, 2008. 55. During this time, the jail was overcrowded. At one time, there were 26 female inmates housed in a 2 cell pod with one toilet in each cell. The toilets were so overused that they backed up and the women were forced to stand in ankle-deep raw sewage for hours. This made some of the female inmates succumb to the jailers' demands to show their breasts or be groped in order to get out of the hot, grotesque conditions for any amount of time. 56. Sanders began approaching Ms. Watson after watching her get out of the shower. One Sunday, Sanders came to Ms. Watson and asked if she would like to go see her sister. She said she would and Sanders took her. On the way back to the jail, Sanders said, "every once in awhile, show me", while motioning tor her to lift her shirt. He told he would give her cigarettes if she flashed him.
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57. Sometime after that incident, Ms. Watson requested a doctor's visit for a bad ear infection. Sanders showed up to take Ms. Watson to the Indian Clinic in Jay, Oklahoma. On that occasion, Sanders rubbed her leg and tried to hold her hand. 58. Suddenly whereas it used to take up to one month to secure a doctor visit, Ms. Watson found herself with a doctor's appointment more and more frequently until she was actually going twice a week. Each time, Sanders would take her, then he would pull off the road in a secluded area and grope her, lift up her shirt, and kiss and suck on her breasts. This would go on for an hour or more at a time. Sanders was always in his uniform and driving a white "police car" when these acts occurred. 59. The last time Sanders did this to Ms. Watson, he had tobacco juice all around his mouth and he tried to kiss her. When Ms. Watson refused the kiss, Sanders grabbed her by the hair, violently pulled her over to him and shoved his tongue down her throat. He then put his hands down her pants and inserted his finger into her, hurting her really badly. Ms. Watson was in leg shackles and couldn't run and couldn't fight him so she began screaming that she would tell everyone. Sanders then threatened Ms. Watson that he would have sent her to prison or killed if she ever mentioned what happened. 60. Sanders told Ms. Watson that she better not tell anyone because he knew where she lived and showed her a copy of her booking sheet with her address on it. Sanders told her that he had the last girl sent to prison and could have her sent there too. Sanders also told Ms. Watson that his family was in law enforcement in Disney or Langley and if she said a word, they would get rid of her. Sanders took the booking sheet and told Ms. Watson that he would carry it with him just in case.
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61. Each time they would return from one of these "visits", Sanders would have Ms. Watson talk into his microphone and tell the dispatcher that nothing happened between them. Ms. Watson asked Sanders why he did this and he said another girl had turned him in before so he was protecting himself. 62. Ms. Watson told SheriffBlaekfox about Sanders' threat on her life. SheriffBlackfox promised to get the booking sheet back ifMs. Watson wrote out a statement. Ms. Watson wrote a statement but Sheriff Blackfox did not get the booking sheet back. This is why Ms. Watson lives in fear for her life in an undisclosed location. 63. As a result of Sanders' conduct and that ofSheriffBlackfox set forth above, Ms. Watson has sufiered severe emotional distress and/or psychological damage and/or significant pain and suffering and/or personal humiliation. 64. Sheriff Blackfox and his identified employees were deliberately indifferent to the Constitutional rights of Plaintiffs set forth herein, by and through their identified acts and omissions. 65. Upon infonnation and belief, Sanders had been previously either fired or suspended for sexual improprieties with female inmate. 66. Despite such prior conduct Sanders was re-hired and/or re-engaged by SheriffBlackfox. 67. Female inmates wrote a letter or letters to Sheriff Blackfox complaining of Sanders' conduct in approximately June, 2007. The Sheriff then had the women write out separate statements and promised confidentiality. 68. The jailers then retaliated against the female inmates by screaming at them using terms directly from their "confidential" statements, putting 15 women in a four-person cell, turning the air-conditioning system off during the day and turning it on full blast at night, and turning off the
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. '
water so that the women couldn't shower and denying access to medication all with deliberate indifference to the Plaintiffs Constitutional rights. 69. The Sheriff told the female inmates that they had been investigating Sanders for sexual improprieties with female inmates and his conduct for nine months already at the time their statements were written. 70. Despite the Sheriff's knowledge of Sanders' conduct pnor to Sheriff Blackfox's administration and after it began, Sanders was allowed to remain employed at the Delaware County Jail until he died in November 2008. 71. Pursuant to 57 O.S. § 47, a Sheriff"shall have charge ofthe county jail ofhis county and of all persons by law confined herein..." It is the Sheriffs duty both statutorily and under the Constitution of the United States to make sure that the Constitutional rights of those whom he imprisons are not violated. Sheriff Blackfox violated this duty owed to Plaintiffs with deliberate indifference to their Constitutional rights by hiring, failing to train and failing to supervise and/or Sanders and other employees. 72. Pursuant to 57 O.S. § 54, "[t]he Sheriff shall in all cases be liable tor the negligence and misconduct of the jailers as of other deputies..." 73. SheriffBlackfox failed to train Sanders and other jailers and deputies how to treat female inmates. This policy, custom, and usage of the Sheriff of Delaware County to fail to train the jailers and deputies was deliberately indifferent to Plaintiffs' Constitutional rights and was a proximate cause ofthe violation of Plaintiffs' Constitutional rights and the damages therefrom. 74. Sheriff Blackfox failed to properly supervise Sanders and other jailers and deputies while they were in charge of female inmates. This policy, custom, and usage of the Sheriff of Delaware County to fail to properly supervise and/or control the jailers and deputies was
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. '
deliberately indifferent to Plaintiffs' Constitutional rights and was a proximate cause of the violation of Plaintiffs' Constitutional rights and the damages therefrom.
FIRST CAUSE OF ACTION 75. Paragraphs 1-74 are re-alleged. 76. Pursuant to 42 U.S.C. § 1983 the Sheriff of Delaware County is liable for damages to each of the Plaintiffs, as detennined by a jury, as well as for attorney fees, costs of this action, interest as provided by law, and such other relief as is just and proper.
WHEREFORE, Plaintiffs pray for judgment against the Defendant, as follows: A. For an award of compensatory damages in an amount to be determined by
B. For reasonable attorney fees, the costs of this action, interest as provided by law and for al] other relief this Court deems just and proper.
. homas Seymour, OBA No. 8099 Scott A. Graham, OBA No. 19817 Anthony L. Allen, OBA No. 19738 SEYMOUR & GRAHAM LLP 100 West Fifth, Suite 550 Tulsa, OK 74103-4288 Telephone (918) 583-5791 Facsimile (918) 583-9251 and
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Gregory P. Williams, OBA No. 9647 D. Mitchell Garrett, OBA No. 20704 GARRETT LAW OFFICE, P.C. Ill W. 51h Street, Suite 800 Tulsa, OK 74103 Telephone (918) 549-6743 Facsimile (918) 549-6741 ATTORNEYS FOR PLAINTIFFS
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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OKLAHOMA

1. SHERRY ENGLAND,

)

2. KATRINA ROGERS,

)

3. CYNTHIA CRAIG,

)

4. MARIE WATSON,

)

5. JESSICA RODAS,

)

6. LAURICE ANDERSON,

)

7. MELISSA NELSON,

)

8. REBECCA BLOSSOM,

)

9. KIMBERLY BLEDSOE,

)

10. TAMELA TAYLOR,

)

11. KATHERINE BUCK,

)

12. BILLIE JO GANDERT,

)

13. AMY JOHNSON,

)

14. JACQUELYN BLOSSOM,

)

15. TAMMY BEAVERS,

)

16. DEBBIE BACK JAMES,

)

17. JAMIE DALE FRY COOK,

)

all individuals,

)

)

Plaintiffs,

)

vs.

)

)

SHERIFF OF DELAWARE COUNTY, )

in his official capacity,

)

)

Defendant.

)

CASE NO. 09-CV-407-JHP-TLW
JURY TRIAL DEMANDED ATTORNEY’S LIEN CLAIMED

FOURTH AMENDED COMPLAINT

Plaintiffs Sherry England, Katrina Rogers, Cynthia Craig, Marie Watson, Jessica Rodas,

Laurice Anderson, Melissa Nelson, Rebecca Blossom, Kimberly Bledsoe, Tamela Taylor,

Katherine Buck, Billie Jo Gandert, Amy Johnson, Jacquelyn Blossom, Tammy Beavers, Debbie

Back James, and Jamie Dale Fry Cook (herein referred to individually by name or collectively as

“Plaintiffs”), by and through their attorneys, R. Thomas Seymour and Scott A. Graham of

Seymour & Graham, LLP, and Gregory Williams and D. Mitchell Garrett of Garrett Law Office,

P.C., and for their claims against the Defendant, allege and state as follows:

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1. At all material times Jay Blackfox has been the Sheriff of Delaware County, Oklahoma (hereafter “Sheriff”). 2. Delaware County, Oklahoma is a political subdivision of the State of Oklahoma (hereafter “County”). 3. Except as otherwise indicated, all acts and omissions referred to herein occurred within the two years prior to the filing of this Complaint. 4. This Complaint arises under the Civil Rights statutes of the United States, specifically 42 U.S.C. § 1983. 5. Pursuant to 42 U.S.C. § 1983, this Court has jurisdiction. 6. All material allegations herein occurred within the Northern District of Oklahoma, thereby making venue proper in this Court. 7. The Sheriff is the final policy maker for all material conduct of the Sheriff of Delaware County and of the Sheriff’s Office of Delaware County. There is no person who has authority over the Sheriff of Delaware County, acting in his capacity as sheriff. Both as to his own conduct and as to the conduct of his employees, because of his position as Sheriff of Delaware County, the Sheriff of Delaware County’s acts, customs, policies, practices, failure to train and failure to supervise his employees alleged herein are attributable to the County as well as to the Sheriff in his official capacity. 8. Sheriff Blackfox is sued herein in his official capacity, for his own acts and those of his predecessor, if any, in his official capacity. 9. All of the conduct alleged herein of the Sheriff of Delaware County and of his identified employees was the exercise of state authority within the meaning of 42 U.S.C. § 1983.
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10. Recognizing the extraordinary vulnerability of persons who are inmates of a county jail for any reason and the extraordinary opportunities of sheriffs and of employees of sheriffs to prey upon the vulnerability of such persons, the statutes of the State of Oklahoma specifically protect such persons by mandating that any state, federal, county, municipal or political subdivision employee who has sexual intercourse with a person under the supervision of the Sheriff’s Office of Delaware County is guilty of the crime of rape. 21 O.S. § 1111 (A) (7). Just as is the case for sexual intercourse with underage persons, consent is no defense to the crime of rape as described therein. 11. Recognizing the extraordinary vulnerability of persons who are inmates of a county jail for any reason and the extraordinary opportunities of sheriffs and of employees of sheriffs to prey upon the vulnerability of such persons, the statutes of the State of Oklahoma specifically protect such persons by mandating that any state, federal, county, municipal or political subdivision employee who commits sodomy on a person under the supervision of the Sheriff’s Office of Delaware County is guilty of the crime of forcible sodomy. 21 O.S. § 888 (B) (4). Just as is the case for sexual intercourse with underage persons, consent is no defense to the crime of forcible sodomy as described herein. 12. Recognizing the extraordinary vulnerability of persons who are inmates of a county jail for any reason, as well as of persons under the supervision of the Drug Court, and the extraordinary opportunities of sheriffs and employees of sheriffs to prey upon the vulnerability of such persons, the statutes of the State of Oklahoma specifically protect such persons by mandating that any state, federal, county, municipal or political subdivision employee who commits sexual battery on a person under the supervision of the Sheriff’s Office of Delaware County is guilty of the crime of sexual battery. 21 O.S. § 1123 (B). Just as is the case for sexual
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intercourse with underage persons, consent is no defense to the crime of sexual battery as described herein. 13. Sheriff Blackfox has established as the policy, custom, usage and practice of (a) the Sheriff of Delaware County, (b) the Sheriff’s Office of Delaware County, and (c) (by virtue of his position as Sheriff of Delaware County) Delaware County, Oklahoma, that the employees of the Sheriff of Delaware County are permitted to engage in rape, sodomy, sexual battery and blackmail as described herein, as the policy, custom, usage and practice of the Sheriff of Delaware County, the Sheriff’s Office of Delaware County, and of Delaware County, Oklahoma. 14. Sheriff Blackfox has further established as the policy, custom, usage and practice of (a) the Sheriff of Delaware County, (b) the Sheriff’s Office of Delaware County, and (c) (by virtue of his position as Sheriff of Delaware County), Delaware County, Oklahoma, that the employees of the Sheriff’s Office of Delaware County may, as a matter of the policy, custom, usage and practice of the Sheriff of Delaware County and of Delaware County, Oklahoma and/or as a matter of Sheriff Blackfox’s failure to train and failure to supervise those employees, commit sexual battery on inmates of the Delaware County jail as well as commit all of the outrageous sexual advances, sexual harassment and sexual humiliation described herein. 15. These acts of rape, sodomy, sexual battery and blackmail described herein and committed by employees of the Sheriff of Delaware County deprived the identified Plaintiffs of their rights under the Fourth and Fourteenth Amendments to the Constitution of the United States to be free from unreasonable searches and seizures, their rights under the Fifth and Fourteenth Amendments to the Constitution of the United States to be afforded due process of law, and their rights under the Fifth and Fourteenth Amendments to the Constitution of the United States to have equal protection of the law and thereby not suffer the sexual degradation described herein.
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A reasonable person would have known that these acts of rape, sodomy, sexual battery and blackmail described herein deprived the identified Plaintiffs of their Constitutional rights as set forth in the preceding sentence. 16. The acts of sexual battery, outrageous sexual advances, sexual harassment and sexual humiliation committed by Sheriff Blackfox’s employees as described herein deprived the identified Plaintiffs of their rights under the Fourth and Fourteenth Amendments to the Constitution of the United States to be free from unreasonable searches and seizures, and their rights under the Fifth and Fourteenth Amendments to the Constitution of the United States to be afforded equal protection and due process of law. A reasonable person would have known that Sheriff Blackfox’s employees' acts of sexual battery, outrageous sexual advances, sexual harassment and sexual humiliation described herein and/or his failure to train and failure to supervise his employees deprived the identified Plaintiffs of their Constitutional rights as set forth in the preceding sentence. 17. The identified employees' sexually degrading acts described herein were committed with deliberate indifference to the Constitutional rights of Plaintiffs set forth herein, and were the direct and proximate cause of Plaintiffs' damages. A reasonable person would have known these Constitutional rights were being violated as a result of the alleged conduct.
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18. Plaintiff Sherry England was incarcerated in the Delaware County Jail from June 25, 2007 through July 7, 2007 on a charge of public intoxication. 19. During this time, she was housed in a cell block designed to hold 10 inmates, having only 3 cells and 10 beds. At times, there were as many as 20 women held in the cell block. It was summertime, and the conditions were hot, crowded and deplorable. 20. Also during this time, the Delaware County jailers would “bargain” with the female inmates to show their breasts in exchange for cigarettes, cupcakes, snacks, candy, personal items, and other things they could not obtain for themselves while in the Delaware County jail. 21. The jailers would listen over the intercom and when they knew female inmates were in the showers or using the toilet, the jailers would come in and watch the women come out of the shower and/or using the toilet. 22. While Ms. England was taking a shower, the jailers would just come in. The jailers would “bargain” with the female inmates to drop their towels to the floor in exchange for being taken outside for cigarettes and other favors. Ms. England began taking her clothes with her and getting dressed in the shower. 23. There were no female jailers at night. At night, the jailers would come into the cells in the pods and grope the female inmates. Almost all of the male jailers were involved, including but not limited to, Bill Sanders, “Head Jailer Lonnie”, “Leon”, “Damen”, “Don”, “Carlos”, “Lane”, and a policeman from the City of Spavinaw who worked part-time at night as a Delaware County jailer. 24. At night the male jailers would bring T-shirts and boxer shorts into the pods for the female inmates to wear in the hot cells in exchange for “favors”.
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25. Sometimes when female inmates would be called out of their cells to go to the front to get their medications, the jailers would grope and/or kiss them. 26. Ms. England refused to show her breasts and rejected the jailers’ advances. In retaliation and with deliberate indifference to her medical needs, the jailers withheld her medications and would not let her see the doctor. 27. Ms. England is an epileptic and requires prescription medication to prevent seizures. Ms. England had her prescription medication with her when she was booked into the Delaware County Jail and the jailers took it away from her. Due to the jailers’ deliberate indifference to Ms. England’s medical needs and refusing her medication, Ms. England began suffering bad seizures while in the Delaware County Jail. 28. Ms. England repeatedly asked to see the doctor and her requests were ignored by the jailers with deliberate indifference to her medical needs. The jailers told Ms. England that she didn’t have any rights because she was in jail. 29. Ms. England had at least 5 bad seizures during those 18 days she was in the Delaware County Jail. 30. The depravity set forth in Paragraphs 18 through 29 violated Ms. England’s Constitutional rights as set forth herein. 31. The depravity set forth in Paragraphs 18 through 29 subjected Ms. England to severe emotional distress and/or psychological damage and/or significant pain and suffering and/or personal humiliation. 32. Plaintiff Katrina Rogers was an inmate in the Delaware County Jail from January 11, 2008 through January 23, 2008.
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33. Ms. Rogers was housed in the women’s pod where there were only 2 cells with 4 beds per cell. Female inmates were sleeping in the shower because it was so crowded in the cells. There were at least 12-13 women in a cell at one time. There were cameras in the shower and Ms. Rogers knew the male jailers watched the female inmates while they showered. 34. Ms. Rogers was 5 months pregnant during this time so she put in a medical request to see the doctor. Deputy Bill Sanders (“Sanders”) came to her cell personally within 2 hours of her request for a doctor. Sanders told Ms. Rogers that he had gotten her an appointment with a doctor the following day and would take her to the appointment himself. 35. The following morning as Ms. Rogers and Sanders were getting in the car at the Sheriff’s office in Jay, Oklahoma, Sanders asked her, “Would you like to go see your mom?” Ms. Rogers indicated that she would as her mother’s home was close to Dr. Hopper’s office in Grove. As the car pulled away from the Sheriff’s office, Sanders began groping Ms. Rogers’ breasts as he was driving. Sanders also attempted to put his hand down Ms. Rogers’ pants and kiss her. Sanders grabbed Ms. Rogers’ hand and tried to put it on his penis. 36. Ms. Rogers was afraid to tell the doctor because she was terrified of the retaliation that Sanders threatened. After the doctor’s appointment, Sanders stopped on the way back to the jail at the S&S Stop gas station on Highway 59 to get them something to eat. Sanders then said, “Since I did this for you, then you can pay me back” Sanders began rubbing Ms. Rogers’ again, and again attempted to put her hand on his penis. Sanders did this throughout the drive back, including stopping at the smoke shop to buy cigarettes for the female inmates. 37. Sanders told Ms. Rogers that he needed her mother’s phone number so that he could call her about her doctor’s appointments. Ms. Rogers gave Sanders the phone number.
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38. Sanders told Ms. Rogers that she could not tell anybody about anything he did, because if she did, he could make her time in jail worse and that once she got out of jail, he would see to it that Ms. Rogers got into more trouble. Sanders told Ms. Rogers, “[w]hen you get out, you need to come to my house and do this for me---I need to be with a woman. I need to have an orgasm and I want you to be the one to do it. You need to promise you’re going to do this.” Ms. Rogers did promise because she was intimidated into doing so. Ms. Rogers felt like she didn’t have a choice. Sanders told Ms. Rogers that he only wanted oral sex from her because she was pregnant. 39. While Ms. Rogers was in her cell at the Delaware County Jail, she heard Sanders ask another female inmate, Kori White, to show him her breasts and her crotch. Ms. White did show Sanders her breasts. Other female inmates saw this as well. Ms. Rogers spoke with Ms. White about telling on Sanders. Ms. White said that probably wasn’t a very good idea because she didn’t want Ms. Rogers to get into any more trouble and didn’t want anything to happen to Ms. Rogers. 40. Sanders told a female inmate that he would let her show him herself but he wouldn’t touch her because she was too fat. This inmate was so embarrassed and hurt that she cried. 41. Sanders kept telling Ms. Rogers, “I’m trying to get you out of here quicker. I’ve been talking to the Sheriff. But if I get you out of here, you need to make sure you come to my house and orgasm.” 42. After Ms. Rogers was released from the Delaware County Jail on January 23, 2008, Sanders would call her every day, telling her that he loved her and he wanted her to love him. Sanders continually asked her, “[w]hen are you going to come and do those things you promised me you would do when you were in jail?”
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43. Sanders began not only calling Ms. Rogers every day, but began coming to her house repeatedly and offering her things. Approximately four or five days after her release, Sanders showed up at Ms. Rogers’ house and demanded she go with him. Ms. Rogers’ 3 year-old protested so Ms. Rogers said her daughter had to go with her if she was going anywhere. The daughter fell asleep sitting between them in Sanders’ truck. Sanders then began to grope Ms. Rogers, trying to kiss her and making her grope him over her daughter. Sanders drove around the county roads for an hour and a half telling Ms. Rogers never to say anything about the incident because if he got into trouble, he would make sure she got into trouble at least as bad. Finally Ms. Rogers’ daughter woke up and had to go potty, which made Sanders take them home. 44. Sanders continued to show up at Ms. Rogers' house (she lived with her mother) and if Ms. Rogers wasn’t home, he would sit and wait. Sanders would wait for long periods of time talking to Ms. Rogers’ mother. Sanders brought gifts to the mother, Ms. Rogers’ children and Ms. Rogers. 45. As a result of the conduct of Deputy Sanders set forth above, Ms. Rogers has suffered severe emotional distress and/or psychological damage and/or significant pain and suffering and/or personal humiliation. 46. Plaintiff Cynthia Craig was an inmate at the Delaware County Jail from April 23, 2008 through July 15, 2008. Ms. Craig is mentally disabled. 47. Ms. Craig was held in a holding tank for 2-3 days, then put in general population. 48. Sanders told Ms. Craig that she looked good, that he liked her, and he wanted her to be “daddy’s girl”. Ms. Craig said she wasn’t interested and Sanders then began to come to her cell,
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get “handsy” with her and ask to see her crotch. Sanders would insert a finger inside Ms. Craig’s vagina and she would push him away. 49. Sanders took Ms. Craig to doctor appointments and wanted her to “play with him” when he was driving his patrol car in uniform. Ms. Craig would fight him off of her and Sanders would unzip his zipper and show his penis while he was driving. He told Ms. Craig to fondle him but she refused. On two occasions, Sanders pulled off the road in secluded areas and made Ms. Craig kiss him and then he began masturbating while he kissed her. These episodes lasted about a half an hour each, both on the way to the doctor’s office and on the way back to the jail. 50. Sanders told Ms. Craig that if she told anyone about it, that she would regret it and he would make sure she would go to the penitentiary by making up stories that she tried to escape or he had problems with her. 51. When Sanders returned to the Delaware County Jail, he forced Ms. Craig to answer questions like “nothing happened, right?; You know I was good to you?” Only later did Ms. Craig realize the reason Sanders was doing this was he was recording it. 52. Sometime between April 23, 2008 and June 2, 2008, Ms. Craig went to the Oklahoma Forensic Center for about 2 weeks for mental evaluation. There she was diagnosed as having Post Traumatic Stress Disorder. When she returned to the Delaware County Jail, she was placed into a protective holding cell after she had demanded to talk to Sheriff Blackfox. Sanders then entered the protective cell, put Ms. Craig in the shower, turned it on so that nobody could hear her, made her take her clothes off and put his fingers inside her vagina. Sanders started kissing Ms. Craig and then raped her vaginally and anally several times alternately. Ms. Craig was terrified to scream because Sanders told her he would send her down the river. When he was finished, Sanders made Ms. Craig scrub herself in front of him and he took her clothes with him
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and brought her back a new regulation orange jumpsuit. Sanders came back for more but Ms. Craig refused, saying she didn’t care what happened to her but he was not going to touch her again. 53. As a result of Sanders’ conduct set forth above, Ms. Craig has suffered severe emotional distress and/or psychological damage and/or significant pain and suffering and/or personal humiliation. 54. Plaintiff Marie Watson was an inmate at the Delaware County Jail from May 20, 2008 through July 11, 2008. 55. During this time, the jail was overcrowded. At one time, there were 26 female inmates housed in a 2 cell pod with one toilet in each cell. The toilets were so overused that they backed up and the women were forced to stand in ankle-deep raw sewage for hours. This made some of the female inmates succumb to the jailers’ demands to show their breasts or be groped in order to get out of the hot, grotesque conditions for any amount of time. 56. Sanders began approaching Ms. Watson after watching her get out of the shower. One Sunday, Sanders came to Ms. Watson and asked if she would like to go see her sister. She said she would and Sanders took her. On the way back to the jail, Sanders said, “every once in awhile, show me”, while motioning for her to lift her shirt. He told he would give her cigarettes if she flashed him. 57. Sometime after that incident, Ms. Watson requested a doctor’s visit for a bad ear infection. Sanders showed up to take Ms. Watson to the Indian Clinic in Jay, Oklahoma. On that occasion, Sanders rubbed her leg and tried to hold her hand. 58. Suddenly whereas it used to take up to one month to secure a doctor visit, Ms. Watson found herself with a doctor’s appointment more and more frequently until she was actually going
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twice a week. Each time, Sanders would take her, then he would pull off the road in a secluded area and grope her, lift up her shirt, and kiss and suck on her breasts. This would go on for an hour or more at a time. Sanders was always in his uniform and driving a white “police car” when these acts occurred. 59. The last time Sanders did this to Ms. Watson, he had tobacco juice all around his mouth and he tried to kiss her. When Ms. Watson refused the kiss, Sanders grabbed her by the hair, violently pulled her over to him and shoved his tongue down her throat. He then put his hands down her pants and inserted his finger into her, hurting her really badly. Ms. Watson was in leg shackles and couldn’t run and couldn’t fight him so she began screaming that she would tell everyone. Sanders then threatened Ms. Watson that he would have sent her to prison or killed if she ever mentioned what happened. 60. Sanders told Ms. Watson that she better not tell anyone because he knew where she lived and showed her a copy of her booking sheet with her address on it. Sanders told her that he had the last girl sent to prison and could have her sent there too. Sanders also told Ms. Watson that his family was in law enforcement in Disney or Langley and if she said a word, they would get rid of her. Sanders took the booking sheet and told Ms. Watson that he would carry it with him just in case. 61. Each time they would return from one of these “visits”, Sanders would have Ms. Watson talk into his microphone and tell the dispatcher that nothing happened between them. Ms. Watson asked Sanders why he did this and he said another girl had turned him in before so he was protecting himself. 62. Ms. Watson told Sheriff Blackfox about Sanders’ threat on her life. Sheriff Blackfox promised to get the booking sheet back if Ms. Watson wrote out a statement. Ms. Watson wrote
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a statement but Sheriff Blackfox did not get the booking sheet back. This is why Ms. Watson lives in fear for her life in an undisclosed location. 63. As a result of Sanders’ conduct and that of Sheriff Blackfox set forth above, Ms. Watson has suffered severe emotional distress and/or psychological damage and/or significant pain and suffering and/or personal humiliation. 64. Plaintiff, Jessica Rodas, was an inmate at the Delaware County Jail from October 3, 2007 through October 23, 2007. 65. During this time, on at least two (2) separate occasions, she was assaulted and sexually molested by Sanders while being transported for medical treatment in Delaware County. 66. On one occasion, on or about October 12, 2007, while being transported back to the Delaware County Jail from a doctor's visit in Grove, Oklahoma, Sanders left the main highway and took a back road through Zena, leading to the Delaware County Jail in Jay, Oklahoma. Along the way, Sanders pulled the Sheriff's vehicle over, and made Ms. Rodas get into the front seat. While she was handcuffed, Sanders proceeded to grope her and sexually assaulted her. 67. This assault was observed by two (2) other female inmates in the back seat who were also being transported in the police vehicle at the time. Ms. Rodas and the other two (2) female inmates were threatened by Sanders that if they said anything, he would "deny it" and "make sure they were in more trouble." 68. About October 22, 2007, while being transported to the Indian Clinic in Jay, Oklahoma, Ms. Rodas was similarly assaulted by Sanders again. Sanders then gave her cigarettes, and again threatened to "cause big trouble for her" if she reported the incident to anyone. 69. Upon her return, Ms. Rodas did confide in cellmates what had happened to her while being transported by Sanders.
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70. As a result of the conduct of Deputy Sanders set forth above, Ms. Rodas has suffered severe emotional distress and/or psychological damage and/or significant pain and suffering and/or personal humiliation and degradation. 71. Plaintiff, Laurice Anderson, was an inmate in the Delaware County Jail from August 2007 through December 2007. 72. During this time, Ms. Anderson was housed in a single cell built for four (4) inmates, which at times would have as many as fourteen (14) female inmates in the cell. 73. Ms. Anderson was housed in "C Pod," where the conditions were deplorable. Because of the overcrowding, the sewer would back up into the cells, and the female inmates would be standing in raw sewage for long periods of time before any attempt was made to clean up the filth and stench. 74. On one occasion, while being transported back from the hospital after having chest pains, Ms. Anderson was groped and assaulted by Deputy Sanders. 75. On other occasions, while being transported to and from the doctor's office with other female inmates, Sanders would take a secluded back road to return to the jail. Along the way, he would pull the police vehicle over and require female inmates to get out of the back seat and sit next to him in the front seat of the vehicle. While they were still handcuffed, he would proceed to grope and sexually assault them. Each time the victim and witnesses were warned or were threatened that if they attempted to report the incident, he would "deny it occurred," and "make a lot of trouble for them." 76. On numerous occasions, Ms. Anderson and others would be denied over-the-counter pain medications like Tylenol. Ms. Anderson also observed other inmates being denied their requests for their prescription pain medications like Seroquel.
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77. During this time, Ms. Anderson was aware of at least one (1) jailer named "John," having sexual intercourse with one of the inmates in the bathroom off the bubble where the control room was, or in the isolation room. 78. As a result of the conduct of Deputy Sanders set forth above, Ms. Anderson has suffered severe emotional distress and/or psychological damage and/or significant pain and suffering and/or personal humiliation and degradation. 79. Plaintiff, Melissa Nelson, was an inmate in the Delaware County Jail from November 2007 through December 2007. 80. During this time, Sanders would make lewd propositions to her and comment about the size of her breasts. Sanders would demand that she show him her breasts, but she refused to do so. 81. In early December 2007, while being transported back from a doctor's appointment in Grove, Oklahoma, Sanders pulled off on a back road on the return trip to the jail and sexually assaulted and molested Ms. Nelson. This occurred on a dirt road between Grove and Jay. There were dumpsters on the left-hand side of the road, not too far from a church with a white fence around it. The attack lasted approximately ten (10) minutes, during which time Ms. Nelson became increasingly upset and crying, as she tried to fight off Sanders. Sanders had locked the doors so she could not get out. When she begged him to stop, he said, "No! I'm in charge, and I have authority over you!" 82. Sanders was wearing a Delaware County Sheriff's shirt and driving a Delaware County Sheriff's vehicle at the time. Ms. Nelson kept trying to push him away, and began crying so hard that Sanders finally stopped the assault.
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83. Sanders told Ms. Nelson that if she said anything to anybody, he would "kill her kids and her husband." She believed he would do that, since he worked in the Sheriff's Office, and said he "could find out anything." 84. On the way back to the jail, Sanders stopped at a convenience store and got Ms. Nelson some cigarettes. He told her to "smoke a couple of cigarettes before we get back to the jail, to calm you down." 85. Because of the threat against the lives of her children and her husband, Ms. Nelson did not report the incident when she returned to the jail. 86. Thereafter, Ms. Nelson had an allergic reaction to a prescription pain medication during which her blood pressure became dangerously elevated. Ms. Nelson repeatedly asked to see a doctor, and her requests were ignored by Jailer Holly, with deliberate indifference to her lifethreatening medical needs. 87. Jailer Holly accused her of faking symptoms and refused her request for medical treatment. As a result of the failure to provide timely medical treatment, Ms. Nelson's condition proceeded to deteriorate, and she had a seizure. She then had to be rushed to the hospital by ambulance when she finally received medical treatment. 88. Before Ms. Nelson was released from the Delaware County Jail, Jailer Harvey Claunts propositioned her to have sex with him when she got out. He then told her where he lived and told her she needed to come by his house. 89. As a result of the conduct of Deputy Sanders and Jailers, Holly and Harvey Claunts, set forth above, Ms. Nelson has suffered severe emotional distress and/or psychological damage and/or significant pain and suffering and/or personal humiliation and degradation.
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90. Plaintiff, Rebecca Blossom, was an inmate in the Delaware County Jail from January 2008 through March 2008. 91. During her incarceration in the Delaware County Jail, Ms. Blossom was housed with up to seven (7) other female inmates in a two-person cell. 92. During this time, Ms. Blossom was molested and sexually assaulted by Deputy Sanders no less than eight (8) times. 93. As with other Plaintiffs, the assaults would occur when Sanders was transporting Ms. Blossom to or from doctor's appointments, and in her case, a dental appointment as well. 94. The acts committed by Sanders included sodomy and sexual battery. 95. The assaults would usually occur on a remote rural road by an Indian Smoke Shop in Delaware County. 96. Sanders threatened Ms. Blossom with bodily harm to herself or her family, or having her sent to prison, if she said anything to anybody. Sanders said he had two (2) other girls sent to prison who had tried to tell on him. Sanders also told her he "had access to the jail computer," and "it would be easy to find out where she was." 97. These assaults caused Ms. Blossom to have increasing anxiety, and she could not sleep. As a consequence, she needed to be transported to the doctor on even more occasions, resulting in more attacks by Sanders. 98. By the time she was released from the Delaware County Jail, Ms. Blossom was on five (5) or six (6) different medications for anxiety, blood pressure and other complications caused by her ordeal in the Delaware County Jail. 99. Sanders told Ms. Blossom that she "needed to come see him after she got out of jail," because he "wanted to have sex with her."
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100. In June 2008, Ms. Blossom was returned to the Delaware County Jail for failure to timely pay her fines. At this time, despite the prior threats from Sanders, Ms. Blossom and four (4) other inmates filed a formal, written complaint against Sanders regarding the sexual assaults that had been occurring. Nothing came of the grievances. Rather than terminating Sanders from duty, Sheriff Blackfox simply transferred Sanders to be in charge of the juvenile inmates in Delaware County. 101. As a result of Sanders's conduct, and that of Sheriff Blackfox set forth above, Ms. Blossom has suffered severe emotional distress and/or psychological damage and/or significant pain and suffering and/or personal humiliation and degradation. 102. BUSKIRK DELETED. 103. BUSKIRK DELETED. 104. BUSKIRK DELETED. 105. Plaintiff, Kimberly Bledsoe, was an inmate in the Delaware County Jail during the month of March 2008. 106. Ms. Bledsoe had been arrested and jailed on a charge of DUI. She had been drinking and was in a car wreck after learning of the death of her grandmother. 107. Ms. Bledsoe was incarcerated in the Delaware County Jail for approximately ten (10) days. During that period of time, her jail cell was so crowded that she had to sleep the entire time on the concrete floor, despite having experienced an injury to her ribs in the car accident. 108. While she was in the jail cell, Deputy Sanders began making comments about her breasts and how he "sure wanted to see them." 109. When Ms. Bledsoe told Sanders to leave her alone because she was in a lot of pain due to the injury to her ribs, Sanders told her he could arrange to take her to the emergency room that
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day. Sanders then came back to the cell and transported her to the emergency room in Grove. In route, Sanders told her, "I did you a favor, now you need to do me a favor," and demanded that she show him her breasts, while driving to the emergency room. When she refused, he began groping her, which was severely painful because of her injured ribs, so she finally complied with his request. At the emergency room, Sanders threatened her not to say anything about what had happened, or he would "make trouble for her" when they got back to the jail. On the way back to the jail, Sanders took a rural road where Ms. Bledsoe again was groped and sexually assaulted. Sanders only stopped molesting Ms. Bledsoe because she was crying so hard and becoming hysterical. 110. After the assault, Sanders stopped at a convenience store and bought Ms. Bledsoe a Dr. Pepper. Then, while driving to the jail, he asked if he could come see her after she got out of jail, so he "could have sex with her." 111. Ms. Bledsoe thought, "How can this be happening? How can this be happening?" She stated she felt helpless and it just devastated her to think she had been put in a position where "someone like that could do something like that" against her will. 112. When they got back to the jail, Sanders threatened her not to tell anyone because "it would be bad for her, and they wouldn't believe her." After she got out of jail, Ms. Bledsoe told the lawyer who was representing her what Bill Sanders had done. 113. As a result of the conduct of Deputy Sanders set forth above, Ms. Bledsoe has suffered severe emotional distress and/or psychological damage and/or significant pain and suffering and/or personal humiliation and degradation. 114. Plaintiff, Tamela Taylor, was incarcerated in the Delaware County Jail from April 2008 through June 2008.
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115. During this time, on at least five (5) occasions, Ms. Taylor was molested and sexually assaulted by Deputy Sanders. 116. On one occasion, while being transported to the doctor's office, Sanders began groping Ms. Taylor's breasts as he was driving. Sanders also attempted to put his hand down Ms. Taylor's pants and kiss her. 117. On another occasion, while Ms. Taylor was handcuffed in a doctor's office, actually waiting to be seen by the doctor, Sanders began groping and rubbing on her leg in the exam room. This continued for about ten (10) minutes until Sanders could hear the doctor coming toward the room. 118. Ms. Taylor also observed Sanders coming to the female inmates' cells and demanding that they flash their breasts to him, on the threat that he would withhold their allotted cigarettes or canteen items. 119. While in the Delaware County Jail, Ms. Taylor learned that Deputy Sanders had previously been terminated because of complaints by female inmates of sexual misconduct. However, he was later allowed to come back again by Sheriff Blackfox. 120. While incarcerated in the Delaware County Jail, Ms. Taylor learned that some jailers were having sex with inmates after they were released, for favors that were granted while they were in jail. Before she was released, Sanders told Ms. Taylor how beautiful she was and said he was going to "come by and see her" after she was released. 121. As a result of the conduct of Deputy Sanders set forth above, Ms. Taylor has suffered severe emotional distress and/or psychological damage and/or significant pain and suffering and/or personal humiliation and degradation.
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122. Plaintiff, Katherine Buck, was incarcerated in the Delaware County Jail between May 2008 through July 2008. 123. During this time, Ms. Buck was held in a cellblock designed to hold four (4) inmates, having only four (4) bunks. At times there were as many as twenty-eight (28) women held in the cellblock. It was summertime, and the conditions were hot, crowded and deplorable. 124. During her time in the Delaware County Jail, she was aware of at least one (1) jailer named "John" who was having sexual relations with an inmate in the jail. 125. Ms. Buck also observed women being required to flash jailers in exchange for cigarettes and other items. 126. On one occasion, while she and Marie Watson were being transported to a dentist's office, she observed Ms. Watson being sexually molested by Deputy Sanders in the front seat of the Sheriff's vehicle. Ms. Buck was in the back seat. 127. On several occasions after Plaintiff, Marie Watson, was returned to the pod after being taken by Sanders to doctors' appointments, Ms. Buck would observe Ms. Watson taking four (4) and five (5) showers in a row. 128. During her incarceration in the Delaware County Jail, Ms. Buck learned that Deputy Bill Sanders had previously been suspended for complaints of sexual misconduct with female inmates, but he was hired back again before her incarceration in May 2008. 129. In July 2008, Ms. Buck joined several other female inmates in writing a letter about the sexual misconduct occurring between female inmates and Deputy Sanders during transport to medical visits.
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130. After the letter was written and surreptitiously delivered to a person outside the jail, the jailers began turning the heat way up or turning the heat way down, adding to the misery of the appalling and crowded conditions in the Delaware County Jail. 131. The letter resulted in an investigation by the Sheriff. Despite these grievances against Sanders for a second time, Sheriff Blackfox did not terminate Sanders from duty. Instead, he transferred Sanders to oversee Delaware County juvenile inmates. 132. When no action on the letter was taken, Plaintiff, Marie Watson, told Ms. Buck that she was going to recant her statement against Deputy Sanders for fear of retaliation against her. 133. During her incarceration, a jailer named Leon constantly flirted with Ms. Buck and would do her unsolicited favors. On at least one occasion, he put money on her books without being asked to do so. After her release from the custody of the Delaware County Jail, Jailer Leon then began stalking her incessantly. He would be waiting outside her house when she got home from work. One time, when she had just gotten out of the shower, she looked out the window of her home and saw him standing there looking in at her. For a long time thereafter, Jailer Leon continued to follow her and would not leave her alone. 134. As a result of the conduct of Deputy Sanders, Jailer Leon, and Sheriff Blackfox, as set forth above, Ms. Buck has suffered severe emotional distress and/or psychological damage and/or significant pain and suffering and/or personal humiliation and degradation. 135. Plaintiff, Billie Jo Gandert, was an inmate in the Delaware County Jail from June 2008 through December 2008. 136. In August 2008, while being transported back from a doctor's office, Deputy Sanders began groping and molesting Ms. Gandert as he was driving. Sanders then attempted to make a deal with Ms. Gandert that he would give her cigarettes if she would allow him to see and touch
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her. Ms. Gandert declined the invitation and refused to ever be transported by Sanders again. Thereafter, she was taken to doctor visits by a jailer named "Al." 137. Ms. Gandert told other female inmates about what had occurred with Bill Sanders. She learned from other female inmates that the same thing had happened with them. 138. In June or July 2008, Ms. Gandert participated in signing a grievance letter against Deputy Bill Sanders. Ms. Gandert had personal knowledge of sexual battery by Deputy Sanders on other female inmates. 139. Ms. Gandert learned that in response to her grievance, Sanders was not terminated, but transferred to supervising juveniles in the Delaware County facility. 140. As a result of Sanders's conduct in the occurrences set forth above, Ms. Gandert has suffered severe emotional distress and/or psychological damage and/or significant pain and suffering and/or personal humiliation and degradation. 141. Plaintiff, Amy Johnson, was incarcerated in the Delaware County Jail from August 2008 through October 2008. 142. During this time, Ms. Johnson was housed in the women's pod where there were only two (2) cells and eight (8) beds. At times, there were over twenty (20) female inmates packed into the small pod. Inmates were sleeping in the shower and on the floor because it was so overcrowded in the cells. 143. During this time, Deputy Sanders solicited Ms. Johnson to allow him to feel and touch her in exchange for cigarettes. When she told him she did not smoke, he then offered to let her use his cell phone if she would let him touch her. 144. Ms. Johnson declined the solicitation.
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145. In October 2007, on at least two (2) occasions while she was being transported for doctors' appointments, she was sexually molested, assaulted, and raped by instrumentation by Deputy Sanders. These assaults would occur when Sanders would leave the main highway and park along a back road in route to the jail. 146. Despite threats from Sanders not to tell anyone, Ms. Johnson told her attorney, Susa Hopper, about the incidents with Deputy Sanders, which were ignored. 147. Ms. Johnson wrote contemporaneous letters to her mother. 148. When she tried to file a written grievance, the jailer just tore it up right in front of her. 149. As a result of the conduct of Deputy Sanders, the jailers, and the Sheriff of the Delaware County Jail set forth above, Ms. Johnson has suffered severe emotional distress and/or psychological damage and/or significant pain and suffering and/or personal humiliation and degradation. 150. Plaintiff, Jacquelyn Blossom, was incarcerated in the Delaware County Jail from January 21, 2009 through January 29, 2009. She was previously incarcerated in the jail on several occasions between 1998 and 2007, and was familiar with the conditions, treatment, sexual improprieties of deputies and jailers involving female inmates during those times. 151. During the last time she was in the Delaware County jail in January 2009, once again, the only female jail pod was extremely overcrowded. 152. DELETED. 153. Sometimes it would take two (2) or three (3) days before requests for sanitary napkins and other female toiletries were provided, and then in grossly insufficient quantities. 154. Male jailers would solicit the female inmates to expose their breast to them in exchange for cigarettes, phone calls, extra food, and other inducements.
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155. During the time of Ms. Blossom’s last incarceration, head jailer “Lonnie" took her out of the B-Pod purportedly “to allow her to make a phone call. Instead, he took her down the hallway to the conference room which has no windows or cameras. There he began groping and molesting her grabbing her breasts under her shirt and shoving his hands down into her pants feeling her “there.” Head Jailer “Lonnie” had similarly molested her during previous times she in the Delaware County Jail 156. DELETED. 157. When Jacquelyn Blossom thinks of the Delaware County Jail, it makes her skin crawl. She says, "When I think about their jailers and their deputies, it just makes me sick, because I know how they are, whether I have the proof, or whether somebody else has the proof. I know what they do." 158. As a result of the conduct of the jailers, Head Jailer “Lonnie”, and the Sheriff of the Delaware County Jail, as set forth, Ms. Blossom has suffered severe emotional distress and/or psychological damage and/or significant pain and suffering and/or personal humiliation and degradation. 159. Plaintiff, Tammy Beavers, was incarcerated in the Delaware County Jail from September 2007 through November 2007, and from February 2008 through March 2008. 160. During this time, the jail pod where she and other female inmates were kept was extremely overcrowded. 161. At times there were 28 female inmates housed in a two-cell pod with only four (4) beds and only two (2) toilets.
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162. During this time, she observed jailers requiring female inmates to flash their breasts in order to receive prescription and over-the-counter medications. If female inmates did not comply, medications were not given. 163. On one occasion, while being transported to the Indian Clinic in Jay, Oklahoma for medical treatment, Deputy Bill Sanders began groping her and molesting her while she was handcuffed in the front seat. On the return trip from the clinic to the jail, Deputy Sanders then groped and attempted to sexually assault Ms. Beavers again. 164. Thereafter, Ms. Beavers would not ask for any more medical appointments, though she needed to change her medications, for fear of being molested by Deputy Sanders while being transported again. 165. Ms. Beavers, who had asthma and other medical problems, then tried to alleviate her symptoms with requests for over-the-counter medications from the jailers. On many occasions, her requests were denied because she refused to flash her breasts to Sanders or the jailers. 166. During this time Ms. Beavers observed other female inmates would not be given their prescription medications upon request. They would be told their prescriptions were out, even though they may have been refilled just a few days earlier. 167. During her incarceration in the Delaware County Jail, Jailer, J.R. would make lewd and lascivious comments and sexual innuendoes to Ms. Beavers. 168. Ms. Beavers also had knowledge that Jailer, J.R. would make arrangements to bond out some female inmates in exchange for sexual encounters after their release. 169. As a result of the conduct of Deputy Sanders, the jailers, and the Sheriff of the Delaware County Jail, as set forth above, Ms. Beavers has suffered severe emotional distress, and/or
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psychological damage and/or significant pain and suffering and/or personal humiliation and degradation. 170. Plaintiff, Debbie Back James, was incarcerated in the Delaware County Jail from October 2007 through November 2007. 171. During this time, she observed and had personal knowledge of numerous incidents where female inmates were requested to expose their breasts and were preyed upon and treated like sexual objects by the jailers. 172. When Deputy Bill Sanders would take Ms. James and other female inmates outside to wash cars and smoke, he would continually make lewd comments about her breasts and her body. On several occasions, he would rub his arm or hands across her breasts and ask her to participate in specific sex acts. 173. On one occasion, when Sanders was transporting Ms. James to a doctor's appointment in Grove along with two other female inmates in the car, he insisted that she and another female inmate in the back seat "make out with each other," so he could watch them in the rear view mirror. They pretended to do so by simply whispering to each other. Deputy Sanders later stopped at a convenience store and bought them pop and cigarettes. 174. Before her release from the Delaware County Jail, Sanders stated his grandson had Down's Syndrome, and offered Ms. James $500 a month and free rent at his house after she got out of jail, if she would provide sexual services for him as well. 175. As a result of the conduct of Deputy Sanders and Sheriff Blackfox's failure to monitor, control, or stop this depraved treatment of female inmates in the Delaware County Jail, Ms. James has suffered severe emotional distress, and/or psychological damage and/or significant pain and suffering and/or personal humiliation and degradation.
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176. Plaintiff, Jamie Dale Fry Cook, was an inmate at the Delaware County Jail from June 23, 2008 to July 17, 2008. 177. During this time, she was assaulted and sexually molested by Deputy Sanders while being transported for medical treatment in Delaware County. 178. On one occasion, while being transported in a Delaware County Sheriff’s vehicle from the jail to the Indian Clinic in Jay, Oklahoma, Deputy Sanders groped and sexually assaulted Ms. Cook as she was handcuffed and shackled in the front seat. Sanders was wearing a Delaware County Sheriff’s uniform and badge at the time, and remained with Ms. Cook during her medical appointment at the clinic. 179. On the way back to the Delaware County jail from the clinic, Deputy Sanders took Ms. Cook to a pharmacy in Jay to fill the prescriptions given her at the clinic. After filling the prescriptions at the drive-thru window, Sanders proceeded to drive into an alley behind the pharmacy. While Ms. Cook was still handcuffed and shackled, he again sexually assaulted her, and raped her by instrumentation.
180. Ms. Cook was threatened by Sanders that if she said anything to anyone, he would "deny it" and "I know who your family is." 181. Upon arriving back at the jail, Deputy Sanders made Ms. Cook talk into a small tape recorder he had, stating nothing had happened between him and her during the transport. 182. Upon being locked back into jail, Ms. Cook confided in cellmates what had just happened to her while being transported by Sanders. 183. Several of the other women inmates in the pod then confessed the same things had happened to them while being transported on other occasions by Deputy Sanders.
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184. Ms. Cook demanded to speak to Sheriff Jay Blackfox. Ms. Cook told Sheriff Blackfox what Deputy Sanders had done to her during the transport and that she wanted to file a complaint against him. She also told Blackfox that Sanders had similarly sexually assaulted several other female inmates in the jail at that time. 185. Sheriff Blackfox took Ms. Cook and the other female inmates who had been sexually assaulted by Sanders out of their cell into a separate room. Each was told to write out statements about what Sanders had done to them during the medical transports. They were told the statements would be held in strictest confidence. They were not. 186. Within days, the female inmates who had written out complaints against Deputy Sanders were all being retaliated against by the jailers. Even male inmate trusties were taunting them with details of the information they had described in their “confidential” complaints. 187. Ms. Cook learned that other complaints had previously been made months earlier by other female inmates about sexual assaults during transports by Deputy Sanders, but Sheriff Blackfox continued to allow Sanders to transport female inmates for the Sheriff’s office. 188. In response to the retaliation, the women who came forward with the complaints wrote a letter, which they all signed, begging for help from the outside. The letter was smuggled out of the jail to a former jailer-nurse, who began an inquiry into the matter. The inquiry came to an abrupt halt when she was found hung in her chicken coop. 189. As a result of the conduct of Deputy Sanders set forth above, Ms. Cook has suffered severe emotional distress and/or psychological damage and/or significant pain and suffering and/or personal humiliation and degradation.
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190. Sheriff Blackfox and his identified employees were deliberately indifferent to the Constitutional rights of Plaintiffs set forth herein, by and through their identified acts and omissions. 191. Upon information and belief, Sanders had been previously either fired or suspended for sexual improprieties with female inmate. 192. Despite such prior conduct Sanders was re-hired and/or re-engaged by Sheriff Blackfox. 193. Female inmates wrote a letter or letters to Sheriff Blackfox complaining of Sanders’ conduct in approximately June, 2007. The Sheriff then had the women write out separate statements and promised confidentiality. 194. The jailers then retaliated against the female inmates by screaming at them using terms directly from their “confidential” statements, putting 15 women in a four-person cell, turning the air-conditioning system off during the day and turning it on full blast at night, and turning off the water so that the women couldn’t shower and denying access to medication all with deliberate indifference to the Plaintiffs Constitutional rights. 195. The Sheriff told the female inmates that they had been investigating Sanders for sexual improprieties with female inmates and his conduct for nine months already at the time their statements were written. 196. Despite the Sheriff’s knowledge of Sanders’ conduct prior to Sheriff Blackfox’s administration and after it began, Sanders was allowed to remain employed at the Delaware County Jail until he died in November 2008. 197. Pursuant to 57 O.S. § 47, a Sheriff “shall have charge of the county jail of his county and of all persons by law confined herein…” It is the Sheriff’s duty both statutorily and under the Constitution of the United States to make sure that the Constitutional rights of those whom he
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imprisons are not violated. Sheriff Blackfox violated this duty owed to Plaintiffs with deliberate indifference to their Constitutional rights by hiring, failing to train and failing to supervise and/or Sanders and other employees. 198 Pursuant to 57 O.S. § 54, “[t]he Sheriff shall in all cases be liable for the negligence and misconduct of the jailers as of other deputies…” 199. Sheriff Blackfox failed to train Sanders and other jailers and deputies how to treat female inmates. This policy, custom, and usage of the Sheriff of Delaware County to fail to train the jailers and deputies was deliberately indifferent to Plaintiffs’ Constitutional rights and was a proximate cause of the violation of Plaintiffs’ Constitutional rights and the damages therefrom. 200. Sheriff Blackfox failed to properly supervise Sanders and other jailers and deputies while they were in charge of female inmates. This policy, custom, and usage of the Sheriff of Delaware County to fail to properly supervise and/or control the jailers and deputies was deliberately indifferent to Plaintiffs’ Constitutional rights and was a proximate cause of the violation of Plaintiffs’ Constitutional rights and the damages therefrom.
FIRST CAUSE OF ACTION 201. Paragraphs 1-186 are re-alleged. 202. Pursuant to 42 U.S.C. § 1983 the Sheriff of Delaware County is liable for damages to each of the Plaintiffs, as determined by a jury, as well as for attorney fees, costs of this action, interest as provided by law, and such other relief as is just and proper.
WHEREFORE, Plaintiffs pray for judgment against the Defendant, as follows: A. For an award of compensatory damages in an amount to be determined by a jury.
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B. For reasonable attorney fees, the costs of this action, interest as provided
by law and for all other relief this Court deems just and proper.
s/ Gregory P. Williams, OBA No. 9647 for R. Thomas Seymour with permission R. Thomas Seymour, OBA No. 8099 SEYMOUR LAW FIRM Philtower Building, Suite 1030 427 S. Boston Avenue Tulsa, OK 74103 Telephone (918) 948-6171 Facsimile (800) 460-3446
And
s/Gregory P. Williams, OBA No. 9647 Gregory P. Williams, OBA No. 9647 GREG WILLIAMS LAW OFFICE, PLLC Philtower Building, Suite 355 427 South Boston Avenue Tulsa, Oklahoma 74103 (918) 948-6171 (800) 460-3446 Of Counsel GARRETT LAW OFFICE, P.C. 111 W. 5th Street, Suite 800 Tulsa, OK 74103 Telephone (918) 549-6743 Facsimile (918) 549-6741
And
s/ Gregory P. Williams, OBA No. 9647 for Scott A. Graham, OBA No. 19817 and Anthony L. Allen, OBA No. 19738 with permission GRAHAM, ALLEN & BROWN, PLLC PHILTOWER BUILDING, SUITE 355 427 SOUTH BOSTON AVENUE TULSA, OKLAHOMA 74103 (918) 948-6171 (800) 460-3446
ATTORNEYS FOR PLAINTIFFS
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CERTIFICATE OF SERVICE
I hereby certify that on the 8th day of February 2011, I electronically transmitted the foregoing document to the Clerk of the Court using the ECF System for filing and transmittal of a Notice of Electronic Filing to the following ECF registrants:

Chris Collins, Esq. Ambre Gooch, Esq. Phil Anderson, Esq. Collins, Zorn & Wagner, P.C. 429 N.E. 50th, Second Floor Oklahoma City, Oklahoma 73105 cjc@czwglaw.com Attorneys for Defendant

s/Greg Williams Greg Williams

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 Case 4:09-cv-00407-JHP-tlw Document 366 Filed in USDC ND/OK on 12/01/11 Page 1 of 7

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OKLAHOMA

SHERRY ENGLAND, et al, Plaintiffs,
vs. SHERIFF OF DELAWARE COUNTY, in his official capacity,
Defendant.

) ) ) ) ) Case No. 09-CV-407-JHP TLW ) ) ) ) )

JOURNAL ENTRY OF JUDGMENT UPON AGREED SETTLEMENT

THIS MATTER comes before the Court on the Joint Motion for Entry of Judgment Upon

Agreed Settlement (Dkt. 363). Plaintiffs appear by and through their lead attorneys of record, R.

THOMAS SEYMOUR and GRAHAM, ALLEN & BROWN, PLLC. Defendant, Sheriff of Delaware

County, in his official capacity, appears by and through its lead attorney of record, COLLINS, ZORN

& WAGNER, P.C. Upon being advised that the parties have reached a full and final settlement of this

action, and that the Board of County Commissioners for Delaware County has authorized entry of

a consent judgment in the amount of Thirteen Million Five Hundred Thousand Dollars

($13,500,000), the Court finds as follows:

1. That the Court has subject matter jurisdiction of this lawsuit and the parties.

2. That the parties have reached a full and final settlement of this lawsuit with no liability

admitted on behalf of Defendant Sheriff of Delaware County in his Official Capacity, or the

Board of County Commissioners of Delaware County or Delaware County.

3. That the Board of County Commissioners of Delaware County has formally authorized

settlement of Plaintiffs’ lawsuit in the amount of Thirteen Million Five Hundred Thousand

Dollars ($13,500,000), and all Plaintiffs have agreed to the terms of the settlement, which

Case 4:09-cv-00407-JHP-tlw Document 366 Filed in USDC ND/OK on 12/01/11 Page 2 of 7
are set forth and reduced to judgment herein, hereby settling all claims that were brought or could have or should have been brought against the Defendant Sheriff of Delaware County in his Official Capacity, or the Board of County Commissioners of Delaware County or Delaware County, and all other Releasees as defined below, arising from or relating in any way to the conduct alleged in the original Complaint, or in the First, Second, Third, Fourth or proposed Fifth Amended Complaint or any related conduct of the Releasees alleged to have occurred since the filing of the original Complaint, or the First, Second, Third, Fourth or proposed Fifth Amended Complaint, as those claims exist as of the filing of this JOURNAL ENTRY OF JUDGMENT UPON AGREED SETTLEMENT. 4. That Plaintiffs, on behalf of themselves, their heirs, successors and assigns, hereby release and forever discharge the Defendant, Sheriff of Delaware County in his Official Capacity, and the Board of County Commissioners of Delaware County, and Delaware County, office holders whether state or county, and their past or present board members, employees, agents, representatives, affiliates, successors, assigns and all other persons, firms, corporations that are or may be liable to any extent for any or all claims of any kind or character whatsoever (herein individually “Releasee” and collectively “Releasees”), arising from or relating in any way to the conduct alleged in the proposed Fifth Amended Complaint or any related conduct of the Releasees alleged to have occurred since the filing of the original Complaint, or the First, Second, Third, Fourth or proposed Fifth Amended Complaint, which Plaintiffs, individually and in all other capacities, now have or under any circumstances could or might have had against any Releasee as of the filing of this JOURNAL ENTRY OF JUDGMENT UPON AGREED SETTLEMENT (herein the “Released Claims).
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5. That payment of Thirteen Million Five Hundred Thousand Dollars ($13,500,000) is inclusive of all attorneys fees, liens, and costs, and all medical, dental, doctor, chiropractic, mental health, attorney, hospital and health care provider liens.
6. That if this Judgment were against an individual, it would be payable in full immediately. Because of the Statutes of the State of Oklahoma, the paying entity, the Board of Commissioners for Delaware County, will pay the Judgment in three (3) equal annual installments, by April 30 of each year, beginning in 2013. Post judgment interest rate is fixed at 2.5 percent per annum, and shall begin to accrue the date this Journal Entry of Judgment is filed. IT IS THEREFORE ORDERED, ADJUDGED AND DECREED that the Joint Motion for
Judgment Upon Agreed Settlement of the parties is hereby granted. Judgment is hereby entered against the Defendant in the amount of Thirteen Million Five Hundred Thousand Dollars ($13,500,000), and payable as follows:
a. Cynthia Craig, for her alleged injuries, damages, retaliation, and claim for wrongful incarceration, shall receive Three Million Three Hundred Seventy Five Thousand Dollars ($3,375,000).
b. Jacquelyn Blossom (now Cheek), for her alleged injuries and damages, shall receive Two Million One Hundred Sixty Thousand Dollars ($2,160,000).
c. Marie Watson, for her alleged injuries and damages, shall receive Two Million One Hundred Sixty Thousand Dollars ($2,160,000).
d. Amy Johnson, or her alleged injuries and damages, shall receive One Million Six Hundred Twenty Thousand Dollars ($1,620,000).
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e. Rebecca Blossom, for her alleged injuries and damages, shall receive One Million Six Hundred Twenty Thousand Dollars ($1,620,000).
f. Jamie Dale Fry-Cook, for her alleged injuries and damages, shall receive One Million Two Hundred Fifteen Thousand Dollars ($1,215,000).
g. Kimberly Bledsoe, for her alleged injuries and damages, shall receive Four Hundred Five Thousand Dollars ($405,000).
h. Katrina Rogers (now Hardegree), for her alleged injuries and damages, shall receive Two Hundred Seventy Thousand Dollars ($270,000).
i. Jessica Rodas (now Hurtado), for her alleged injuries and damages, shall receive Two Hundred Two Thousand Five Hundred Dollars ($202,500).
j. Billie Jo Gandert, for her alleged injuries and damages, shall receive One Hundred One Thousand Two Hundred Fifty Dollars ($101,250).
k. Tamela Taylor, for her alleged injuries and damages, shall receive One Hundred One Thousand Two Hundred Fifty Dollars ($101,250).
l. Sherry England, for her alleged injuries and damages, shall receive Sixty Seven Thousand Five Hundred Dollars ($67,500).
m. Debbie Back James, for her alleged injuries and damages, shall receive Sixty Seven Thousand Five Hundred Dollars ($67,500).
n. Tammy Beavers, for her alleged injuries and damages, shall receive Sixty Seven Thousand Five Hundred Dollars ($67,500).
o. Laurice Anderson, for her alleged injuries and damages, shall receive Sixty Seven Thousand Five Hundred Dollars ($67,500).
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IT IS FURTHER ORDERED, ADJUDGED AND DECREED, that, in consideration of this consent judgment and the payments to be made hereunder, Plaintiffs, on behalf of themselves, their heirs, successors and assigns, release and forever discharge Releasees from any liability for the Released Claims as of the filing of this JOURNAL ENTRY OF JUDGMENT UPON AGREED SETTLEMENT.
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that payment of Thirteen Million Five Hundred Thousand Dollars ($13,500,000) is inclusive of all attorneys fees, liens and costs and all medical, dental, doctor, chiropractic, mental health, attorney, hospital and health care provider liens.
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that this Judgment shall bear a fixed interest rate of 2.5 percent per annum, and interest shall begin to accrue the date this Journal Entry of Judgment is filed.
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that no liability has been admitted by or found against Defendant Sheriff of Delaware County in his Official Capacity, or the Board of County Commissioners of Delaware County or Delaware County, and they have advised the Court they have consented to the entry of this Judgment and agreed to its terms in order to avoid the risk of further time, expense, and monetary exposure associated with this case.
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that the Board of County Commissioners of Delaware County will pay the Judgment in accordance with Oklahoma Statutes Title 62 Section 365.5 in three equal annual payments, by April 30 each year, beginning in 2013 to the trust account of Seymour Law Firm (or any successor thereof as directed by R. Thomas Seymour). Upon payment of any portion of this Judgment to the trust account of Seymour Law Firm (or any successor thereof as directed by R. Thomas Seymour), Releasees shall be released from any
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and all claims under this Judgment as to that portion of the Judgment paid to such trust account.
IT IS SO ORDERED this 1st day of December, 2011.
APPROVED AND AGREED TO ON BEHALF OF ALL PLAINTIFFS: Attorneys for Plaintiffs:
S/R. Thoomas Seymour R. THOMAS SEYMOUR, OBA #8099 SEYMOUR LAW FIRM Philtower Building 427 S. Boston Ave., Ste. 1030 Tulsa, OK 74103 918-948-6171 T 800-460-3446 F rtseymour1@aol.com
ANTHONY L. ALLEN, OBA #19738 SCOTT A. GRAHAM, OBA #19817 GRAHAM, ALLEN & BROWN, P.L.L.C. Philtower Building 427 S. Boston Ave., Ste. 355 Tulsa, OK 74103 918-948-6171 T 800-460-3446 F tony@lawtulsa.com scott@lawtulsa.com
GREGORY P. WILLIAMS, OBA #9647 Of Counsel Philtower Building 427 S. Boston Ave., Ste. 1030 Tulsa, OK 74103 918-948-6171 T 800-460-3446 F greg@lawtulsa.com
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Case 4:09-cv-00407-JHP-tlw Document 366 Filed in USDC ND/OK on 12/01/11 Page 7 of 7 APPROVED AND AGREED TO ON BEHALF OF DEFENDANT: Attorneys for Defendant: S/Ambre C. Gooch CHRIS J. COLLINS, OBA #1800 AMBRE C. GOOCH, OBA #16586 COLLINS, ZORN & WAGNER, P.C. 429 NE 50th Street, Second Floor Oklahoma City, Oklahoma 73105 405-524-2070 T 405-524-2078 F
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Lawsuit by former Delaware County Jail inmates alleging sexual abuse and blackmail ended in settlement with no liability (N.D. Okla.)