Case: Knipp v. Perdue

Affidavit in Support of Request to Proceed IFP by Lars Knipp. (Attachments: # 1 Complaint, # 2 Civil Cover Sheet, # 3 Certificate of Interested Persons and Corporate Disclosure Statement, # 4 Motion to Exceed Page Limits, # 5 Motion for Preliminary Injunction, # 6 Brief re Preliminary Injunction, # 7 Exhibit 1 re Preliminary Injunction, # 8 Exhibit 2 re Preliminary Injunction, # 9 Exhibit 3 re Preliminary Injunction, # 10 Exhibit 4 re Preliminary Injunction, # 11 Exhibit 5 re Preliminary Injunction, # 12 Exhibit 6 re Preliminary Injunction, # 13 Exhibit 7 re Preliminary Injunction, # 14 Exhibit 8 re Preliminary Injunction, # 15 Exhibit 9 re Preliminary Injunction, # 16 Exhibit 10 re Preliminary Injunction, # 17 Exhibit 11 re Preliminary Injunction, # 18 Exhibit 12 re Preliminary Injunction, # 19 Exhibit 13 re Preliminary Injunction, # 20 Exhibit 14 re Preliminary Injunction, # 21 Exhibit 15 re Preliminary Injunction, # 22 Exhibit 16 re Preliminary Injunction, # 23 Exhibit 17 re Preliminary Injunction, # 24 Exhibit 18 re Preliminary Injunction, # 25 Exhibit 19 re Preliminary Injunction, # 26 Exhibit 20 re Preliminary Injunction, # 27 Exhibit 21 re Preliminary Injunction, # 28 Exhibit 22 re Preliminary Injunction, # 29 Exhibit 23 re Preliminary Injunction, # 30 Exhibit 24 re Preliminary Injunction, # 31 Exhibit 25 re Preliminary Injunction)(alc) (Entered: 09/09/2010)

Affidavit in Support of Request to Proceed IFP by James Kim. (alc) (Entered: 09/09/2010)

Affidavit in Support of Request to Proceed IFP by Susannah Trogdon. (alc) (Entered: 09/09/2010)

Affidavit in Support of Request to Proceed IFP by Ambi Heard. (alc) (Entered: 09/09/2010)

Affidavit in Support of Request to Proceed IFP by Shaun Mitchell. (alc) (Entered: 09/09/2010)

Submission of 1 , 2 , 3 , 4 , 5 , and 6 Affidavits in Support of Request to Proceed IFP, submitted to Magistrate Judge Janet F. King. (alc) (Entered: 09/09/2010)

ORDER GRANTING the Plaintiffs' respective requests for leave to proceed in forma pauperis. The Clerk is DIRECTED to submit this action to the appropriate District Court Judge for a frivolity determination pursuant to 28 USC § 1915A. Signed by Magistrate Judge Janet F. King on 9/10/2010. (alc) (Entered: 09/10/2010)

COMPLAINT filed by Lars Knipp, James Kim, Susannah Trogdon, Shaun Mitchell, Ambi Heard, Robert Chaffin. (Attachments: # 1 Civil Cover Sheet)(alc) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. (Entered: 09/10/2010)

Certificate of Interested Persons and Corporate Disclosure Statement by Robert Chaffin, Ambi Heard, James Kim, Lars Knipp, Shaun Mitchell, Susannah Trogdon. (alc) (Entered: 09/10/2010)

MOTION to Exceed Page Limits re 11 Motion for Preliminary Injunction, filed by Robert Chaffin, Ambi Heard, James Kim, Lars Knipp, Shaun Mitchell, Susannah Trogdon. (alc) (Entered: 09/10/2010)

MOTION for Preliminary Injunction with Brief In Support by Robert Chaffin, Ambi Heard, James Kim, Lars Knipp, Shaun Mitchell, Susannah Trogdon. (Attachments: # 1 Brief in Support, # 2 Exhibit 1 − Declaration of Seema Mason, # 3 Exhibit 2 − Level of Care James Kim, # 4 Exhibit 3 − Level of Care Ambi Heard, # 5 Exhibit 4 − SOURCE Manual, # 6 Exhibit 5 − CCSP Manual ALS, # 7 Exhibit 6 − Declaration of Samuel Trogdon, # 8 Exhibit 7 − Declaration of Debra Stone, # 9 Exhibit 8 − Declaration of Betty Ushe, # 10 Exhibit 9 − Declaration of Ray Johnson, # 11 Exhibit 10 − Declaration of Dr. Richard Elliott, # 12 Exhibit 11 − Cost of Care Georgia Regional Hospital Atlanta (per diem), # 13 Exhibit 12 − Copy of Affidavit of Catherine Ivey, # 14 Exhibit 13 − Declaration of Dr. Frank Shelp, # 15 Exhibit 14 − Knipp Medical Records, # 16 Exhibit 15 − Declaration of Patrick Wooten, # 17 Exhibit 16 − Declaration of Grace Kim, # 18 Exhibit 17 − Medical Records of James Kim, # 19 Exhibit 18 − 1992 Psychological Addendum Susannah Trogdon, # 20 Exhibit 19 − 2000 Vineland Assessment for Susannah Trogdon, # 21 Exhibit 20 − August 2010 Report of Psychological Evaluation, # 22 Exhibit 21 − Medical Records for Ambi Heard, # 23 Exhibit 22 − Medical Records for Shaun Mitchell, # 24 Exhibit 23 − July 19, 2010 Reasonable Accommodation Letter to Defendants, # 25 Exhibit 24 − June 19, 2010 Reasonable Accommodation Letter to DBHDD, # 26 Exhibit 25 − Reasonable Accommodation Letter to DCH)(alc) (Entered: 09/10/2010)

Submission of 8 Complaint for frivolity determination, 10 MOTION for Leave to File Excess Pages, and 11 MOTION for Preliminary Injunction, submitted to District Judge Timothy C. Batten, Sr. (alc) (Entered: 09/10/2010)

INSTRUCTIONS TO PARTIES AND COUNSEL. Signed by Judge Timothy C. Batten, Sr. on 09/13/10. (fap) Modified on 9/13/2010 to correct docket text (fap). (Entered: 09/13/2010)

ORDER allowing the action to proceed, as the allegations contained in Plaintiffs' 8 Complaint do not appear to be frivolous, nor do they fail to state a claim upon which relief can be granted. Signed by Judge Timothy C. Batten, Sr. on 9/13/2010. (alc) (Entered: 09/14/2010)

Notification of Docket Correction re 12 Instructions to Parties and Counsel. Redockted to correct event type and signature of Judge. (fap) (Entered: 09/13/2010)

Summons Issued as to George Ervin Sonny Perdue, III, Clyde L. Reese, III, Frank E. Shelp. (alc) (Entered: 09/16/2010)

Return of Service Executed by Susannah Trogdon, James Kim, Lars Knipp, Robert Chaffin, Ambi Heard, Shaun Mitchell. Clyde L. Reese, III served on 9/15/2010,

Return of Service Executed by Susannah Trogdon, James Kim, Lars Knipp, Robert Chaffin, Ambi Heard, Shaun Mitchell. George Ervin Sonny Perdue, III served on 9/15/2010, answer due 10/6/2010. (Wells, Charles) (Entered: 09/16/2010)

CERTIFICATE OF SERVICE re 10 MOTION for Leave to File Excess Pages, 11 MOTION for Preliminary Injunction, 9 Certificate of Interested Persons Served on Each of Defendants with Complaint and Summons , filed by Robert Chaffin, Ambi Heard, James Kim, Lars Knipp, Shaun Mitchell, Susannah Trogdon (Wells, Charles) (Entered: 09/16/2010)

NOTICE of Hearing on Motion re: 10 MOTION for Leave to File Excess Pages, 11 MOTION for Preliminary Injunction Motion Hearing set for 10/7/2010 at 10:00 AM in ATLA Courtroom 1708 before Judge Timothy C. Batten Sr. (Plaintiff's counsel to serve Defense counsel with notice). (jgs) (Entered: 09/16/2010)

CERTIFICATE OF SERVICE re Notice of Hearing on Motion, filed by Robert Chaffin, Ambi Heard, James Kim, Lars Knipp, Shaun Mitchell, Susannah Trogdon (Wells, Charles) (Entered: 09/17/2010)

NOTICE of Appearance by Michelle Townes on behalf of George Ervin Sonny Perdue, III, Clyde L. Reese, III, Frank E. Shelp (Townes, Michelle) (Entered: 09/22/2010)

NOTICE of Appearance by Penny Hannah on behalf of George Ervin Sonny Perdue, III, Clyde L. Reese, III, Frank E. Shelp (Hannah, Penny) (Entered: 09/22/2010)

NOTICE Of Filing Supplemental Declarations in Support of 11 MOTION for Preliminary Injunction, filed by Robert Chaffin, Ambi Heard, James Kim, Lars Knipp, Susannah Trogdon, Shaun Mitchell. (Attachments: # 1 Second Declaration of Ray Johnson, # 2 Second Declaration of Sam Trogdon, # 3 August 30, 2010 Psychological Report for Susannah Trogdon)(Wells, Charles) Modified on 10/3/2010 accurately reflect title of e−filed documents. (dfb) Modified on 10/7/2010 to add filer info (alc). (Entered: 09/30/2010)

RESPONSE re 11 MOTION for Preliminary Injunction, filed by George Ervin Sonny Perdue, III, Clyde L. Reese, III, Frank E. Shelp. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Hannah, Penny) Modified on 10/7/2010 to remove duplicative text (alc). (Entered: 10/04/2010)

REPLY BRIEF re 11 MOTION for Preliminary Injunction filed by Robert Chaffin, Ambi Heard, James Kim, Lars Knipp, Shaun Mitchell, Susannah Trogdon. (Attachments: # 1 Exhibit: Second SOURCE Termination, Appeal, Denial for Ambi Heard, # 2 Exhibit: State Planning Initiative on Mental Health, # 3 Exhibit: SOURCE Assessments for Plaintiffs)(Wells, Charles) Modified on 10/7/2010 to remove Johnson, and add Trogdon, as filers (alc). (Entered: 10/06/2010)

STATEMENT of Interest of the United States re 11 MOTION for Preliminary Injunction, filed by United States of America. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Rhee, Mina) (Entered: 10/06/2010)

Minute Entry for proceedings held before Judge Timothy C. Batten, Sr.: Motion Hearing held on 10/7/2010. Plaintiff's 10 Motion to Exceed Page Limits GRANTED and their 11 Motion for Preliminary Injunction GRANTED for 60 days. The injunction shall expire on 12/6/2010. Status quo pending the expiration of the 60 day period. The Court directed the Parties to attempt to settle this action. The Parties are also directed to investigate if this case is related to actions pending before Judge Charles Pannell of this Court. Should the Parties fail to reach a settlement, the time for the State to file a motion to dismiss is extended to 12/16/2010. The Dept. of Justice shall have until 12/16/2010 to file a brief regarding the constitutionality of the termination of the program. (Court Reporter Elise Smith−Evans)(alc) (Entered: 10/07/2010)

CONSENT ORDER to Extend Preliminary Injunction. The deadline for the preliminary injunction to end is EXTENDED an additional 60 days, through and including 2/3/2011, and the time for Defendants to file any defensive pleadings is extended up to and through 2/14/2011. The Department of Justice shall have up to and through 2/14/2011 to file their brief regarding the constitutionality of the SOURCE program. Signed by Judge Timothy C. Batten, Sr. on 11/18/2010. (alc) (Entered: 11/18/2010)

Clerk's Certificate of Mailing as to atty Anne S. Raish re 28 Consent Order and 12 Instructions to Parties and Counsel. (alc) (Entered: 11/18/2010)

PROPOSED CONSENT ORDER To Extend Preliminary Injunction re: 28 Order,. (Hannah, Penny) (Entered: 01/21/2011)

CONSENT ORDER to extend 28 Preliminary Injunction Order. The deadline for the preliminary injunction to end is EXTENDED an additional 60 days, through and including 4/4/2011, and the time for Defendants to file any defensive pleadings is extended up to and through 4/15/2011. The Department of Justice shall have up to and through 4/15/2011 to file their brief regarding the constitutionality of the SOURCE program. Signed by Judge Timothy C. Batten, Sr. on 1/26/11. (pdw) (Entered: 01/26/2011)

PROPOSED CONSENT ORDER To Extend Preliminary Injunction. (Hannah, Penny) (Entered: 03/15/2011)

CONSENT ORDER to Extend Preliminary Injunction. The deadline for the preliminary injunction to end is EXTENDED an additional 60 days, through and including 6/6/2011, and the time for Defendants to file any defensive pleadings is extended up to and through 6/20/2011. The Department of Justice shall have up to and through 6/20/2011 to file their brief regarding the constitutionality of the SOURCE program. Signed by Judge Timothy C. Batten, Sr. on 3/16/2011. (acm) (Entered: 03/16/2011)

Mail Returned as Undeliverable. Mail sent to Anne S. Raish re 32 Consent Order Extending Preliminary Injunction. (hfm) (Entered: 04/15/2011)

Notice for Leave of Absence for the following date(s): 05/30/11, 05/31/11, 06/01/11, 06/02/11, 06/03/11, 06/06/11, 06/07/11, by Michelle Townes. (Attachments: # 1 Exhibit A)(Townes, Michelle) (Entered: 05/05/2011)

PROPOSED CONSENT ORDER to Extend Preliminary Injunction. (Hannah, Penny) (Entered: 05/20/2011)

CONSENT ORDER to Extend Preliminary Injunction. The deadline for the preliminary injunction to end is hereby EXTENDED through and including 8/08/2011, and the time for Defendants to file any defensive pleadings is extended up to and through 08/22/2011. The Department of Justice shall have up to and through 08/22/2011 to file its brief regarding the constitutionality of the SOURCE program. Signed by Judge Timothy C. Batten, Sr. on 05/23/2011. (rvb) (Entered: 05/23/2011)

Request for Leave of Absence for the following date(s): 7/11/11, 7/12/11, 7/13/11, 7/14/11, 7/15/11, 7/18/11, 8/1/11, 8/2/11, 8/3/11, 8/4/11, 8/5/11, by Charles Talley Wells. (Wells, Charles) (Entered: 06/09/2011)

PROPOSED CONSENT ORDER to Extend Preliminary Injunction. (Hannah, Penny) (Entered: 07/28/2011)

ORDER EXTENDING deadline through and including 10/10/2011 for the preliminary injunction to end. Time for dfts to file any defensive pleadings is extended up to and through 10/31/11. Dept of Justice shall have up to and through 10/31/11 to file its brief regarding the constitutionality of the SOURCE program. Signed by Judge Timothy C. Batten, Sr on 8/1/11. (jlm) (Entered: 08/02/2011)

PROPOSED CONSENT ORDER To Extend Preliminary Injunction re: 39 Order filed by George Ervin Sonny Perdue, III, Clyde L. Reese, III, Dr. Frank E. Shelp. (Hannah, Penny) Modified on 10/5/2011 to add filers (rej). (Entered: 10/04/2011)

CONSENT ORDER granting Parties' request to extend deadline for the preliminary injunction an additional sixty days, through and including December 12, 2011, and the time for Defendants to file any defensive pleadings is extended up to and through January 9, 2012. Further the Department of Justice shall have up to and through January 9, 2012 to file its brief regarding the constitutionality of the SOURCE program. Signed by Judge Timothy C. Batten, Sr on 10/4/11. (rsh) (Entered: 10/04/2011)

PROPOSED CONSENT ORDER To Extend Preliminary Injunction re: 41 Order, Set Deadlines/Hearings, Set Submission Deadline,,,. (Hannah, Penny) (Entered: 12/12/2011)

CONSENT ORDER extending the preliminary injunction through and including 2/13/12; extending time up to and through 3/12/12 for dfts to file any defensive pleadings and the DOJ shall have up to and through 3/12/12 to file its brief regarding the constitutionality of the SOURCE program. Signed by Judge Timothy C. Batten, Sr on 12/14/11. (jlm) (Entered: 12/14/2011)

PROPOSED CONSENT ORDER To Extend Preliminary Injunction re: 43 Order,. (Hannah, Penny) (Entered: 02/07/2012)

CONSENT ORDER GRANTING Parties' requests to extend deadline for the preliminary injunction to end, granting an additional sixty days, through and including April 16, 2012, and the time for Defendants to file any defensive pleadings is extended up to and through May 21, 2012. Further the Department of Justice shall have up to and through May 21, 2012 to file its brief regarding the constitutionality of the SOURCE program. Signed by Judge Timothy C. Batten, Sr on 2/7/12. (rsh) (Entered: 02/07/2012)

PROPOSED CONSENT ORDER Consent Order to Extend Preliminary Injunction. (Hannah, Penny) (Entered: 04/13/2012)

ORDER: Parties' requests are hereby GRANTED, the deadline for the preliminary injunction to end is hereby EXTENDED an additional sixty days, through and including June 18, 2012, and the time for Defendants to file any defensive pleadings is extended up to and through July 23,2012. Further the Department of Justice shall have up to and through July 23, 2012 to file its brief regarding the constitutionality of the SOURCE program. Signed by Judge Timothy C. Batten, Sr on 4/13/12. (rsh) (Entered: 04/13/2012)

STIPULATION of Dismissal Without Prejudice by Ambi Heard. (Wells, Charles) (Entered: 04/28/2012)

PROPOSED CONSENT ORDER To Extend Preliminary Injunction re: 47 Order,. (Hannah, Penny) (Entered: 06/13/2012)

CONSENT ORDER EXTENDING PRELIMINARY INJUNCTION an additional 90 days, through September 18, 2012. Time for Defendants to file any defensive pleadings is extended up to and through October 22,2012. Further the Department of Justice shall have up to and through October 22, 2012, to fle its brief regarding the constitutionality of the SOURCE program. Signed by Judge Timothy C. Batten, Sr on 6/13/12. (rsh) (Entered: 06/13/2012)

Notice for Leave of Absence for the following date(s): 7/2/12,7/3/12,7/4/12,7/5/12,7/6/12, by Michelle Townes. (Townes, Michelle) (Entered: 06/15/2012)

PROPOSED CONSENT ORDER Proposed Consent Order Extending Injunction Through November 17, 2012 and Related Extensions re: 50 Order,. (Wells, Charles) (Entered: 09/17/2012)

Final MOTION for Settlement by Robert Chaffin, James Kim, Lars Knipp, Shaun Mitchell, Susannah Trogdon. (Attachments: # 1 Text of Proposed Order Consent Order Approving Settlement Agreement, # 2 Exhibit Settlement Agreement)(Wells, Charles) (Entered: 12/17/2012)

PROPOSED CONSENT ORDER Consent Order Approving Settlement Agreement re: 54 Final MOTION for Settlement . (Attachments: # 1 Exhibit Settlement Agreement)(Wells, Charles) (Entered: 12/17/2012)

CONSENT ORDER APPROVING Settlement Agreement. Signed by Judge Timothy C. Batten, Sr on 12/18/12. (jlm) (Entered: 12/18/2012)

Civil Case Terminated. (jlm) (Entered: 12/18/2012)