Case: Hussein v. County of St. Louis

COMPLAINT against defendant City of Ferguson, Missouri,, County of Saint Louis, Missouri, Ronald K. Replogle with receipt number 0865-4450503, in the amount of $400 Non-Jury Demand,, filed by Mustafa Hussein. (Attachments: # 1 Civil Cover Sheet, # 2 Original Filing Form, # 3 Summons, # 4 Summons, # 5 Summons)(Rothert, Anthony) (Attachment 1 replaced on 8/15/2014) (DLT). (Attachment 2 replaced on 8/15/2014) (DLT). (Entered: 08/14/2014)

1 Civil Cover Sheet

View on PACER

2 Original Filing Form

View on PACER

3 Summons

View on PACER

4 Summons

View on PACER

5 Summons

View on PACER

NOTICE OF PROCESS SERVER by Plaintiff Mustafa Hussein Process Server: Brian Lilley (Rothert, Anthony) (Main Document 2 replaced on 8/15/2014) (DLT). (Entered: 08/14/2014)

3 Summons Issued as to defendants Ferguson, Missouri, City of, Ronald K. Replogle, St. Louis, Missouri, County of. The summons were emailed to trothert@aclu-mo.org. (DLT) (Entered: 08/15/2014)

MOTION for Temporary Restraining Order by Plaintiff Mustafa Hussein. (Attachments: # 1 Exhibit Affidavit, # 2 Text of Proposed Order)(Rothert, Anthony) (Entered: 08/15/2014)

1 Exhibit Affidavit

View on PACER

2 Text of Proposed Order

View on PACER

NOTICE of Filing Exhibit with the Clerk's Office in paper format by Plaintiff Mustafa Hussein re 4 MOTION for Temporary Restraining Order (Rothert, Anthony) (Entered: 08/15/2014)

MEMORANDUM in Support of Motion re 4 MOTION for Temporary Restraining Order filed by Plaintiff Mustafa Hussein. (Attachments: # 1 Department of Justice Letter re Constitutionality of Filming Police in Public)(Rothert, Anthony) (Entered: 08/15/2014)

1 Department of Justice Letter re Constitutionality of Filming Police in Public

View on PACER

AGREEMENT: Parties acknowledge and agree that the media and members of thepublic have a right to record public events without abridgement unless it obstructs the activity or threatens the safety of others, or physically interferes with the ability of law enforcement officers to perform their duties. (Signed by all Parties) (ARL) (Entered: 08/15/2014)

ORAL MOTION to Withdraw Temporary Restraining Order made by Plaintiff Mustafa Hussein. (ARL) (Entered: 08/15/2014)

ORDER: On his oral motion, Plaintiffs Motion to Withdraw his Motion for Temporary Restraining Order is GRANTED. Signed by District Judge John A. Ross on 8/15/14. (ARL) (Entered: 08/15/2014)

Minute Entry for proceedings held before District Judge John A. Ross: Motion Hearing held on 8/15/2014 re 4 MOTION for Temporary Restraining Order filed by Mustafa Hussein. (FTR Gold Operator initials:ARL.) (FTR Gold: Yes.) (ARL) (Entered: 08/19/2014)

EXHIBIT Received: Exhibit 1 by Plaintiff Mustafa Hussein.(DVD exhibit maintained by Clerk's Office) (ARL) (Entered: 08/19/2014)

Case Opening Notification

Remark

Case Opening Notification: Judge Assigned: U.S. District Judge John A. Ross. (DLT).

***REMARK - Please note Copy of Agreement was distributed to all parties in courtroom. (ARL)

SUMMONS Returned Executed filed by Mustafa Hussein. Ferguson, Missouri, City of served on 6/18/2014, answer due 7/9/2014. (Rothert, Anthony) (Entered: 08/18/2014)

SUMMONS Returned Executed filed by Mustafa Hussein. St. Louis, Missouri, County of served on 8/15/2014, answer due 9/5/2014. (Rothert, Anthony) (Entered: 08/18/2014)

ANSWER to 1 Complaint, by St. Louis, Missouri, County of.(Shuman, Michael) (Entered: 09/03/2014)

ENTRY of Appearance by Michael A. Shuman for Defendant St. Louis, Missouri, County of. (Shuman, Michael) (Entered: 09/03/2014)

ENTRY of Appearance by Stephanie E. Karr for Defendant Ferguson, Missouri, City of. (Karr, Stephanie) (Entered: 09/04/2014)

Defendant City of Ferguson, Missouri ANSWER to 1 Complaint, by Ferguson, Missouri, City of.(Karr, Stephanie) (Entered: 09/04/2014)

ENTRY of Appearance by Grant R. Doty for Plaintiff Mustafa Hussein. (Doty, Grant) (Entered: 09/08/2014)

ENTRY of Appearance by Gillian R. Wilcox for Plaintiff Mustafa Hussein. (Wilcox, Gillian) (Entered: 09/09/2014)

ENTRY of Appearance by James R. Layton for Defendant Ronald K. Replogle. (Layton, James) (Entered: 09/12/2014)

ENTRY of Appearance by Robert J. Isaacson for Defendant Ronald K. Replogle. (Isaacson, Robert) (Entered: 09/12/2014)

ANSWER to 1 Complaint, by Ronald K. Replogle.(Isaacson, Robert) (Entered: 09/30/2014)

ORDER: Telephone Status Conference set for 10/14/2014 03:00 PM in Chambers before District Judge John A. Ross. The Court will initiate the call with counsel.. Signed by District Judge John A. Ross on 10/714. (LGK) (Entered: 10/07/2014)

ORDER: IT IS HEREBY ORDERED that the parties are directed to meet and confer on the following:...SEE ORDER...IT IS FURTHER ORDERED that counsel shall file with the Clerk of the Court a joint proposed scheduling plan no later than Friday, October 24, 2014, at which time the Court will enter a Case Management Order in the case. The parties joint proposed scheduling plan shall include:...SEE ORDER.... Signed by District Judge John A. Ross on 10/14/14. (LGK) (Entered: 10/14/2014)

JOINT SCHEDULING PLAN by Plaintiff Mustafa Hussein. and all Defendants. (Doty, Grant) (Entered: 10/23/2014)

CASE MANAGEMENT ORDER This case is assigned to Track: 2 Motion to Join Parties due by 12/19/2014. Discovery Completion due by 5/8/2015. ADR Future Reference 12/15/2014. Dispositive Motions due by 6/12/2015. Jury Trial set for 11/9/2015 09:00 AM in Courtroom 12N before District Judge John A. Ross. Motion in Limine due by 10/26/2015. SO ORDERED. Signed by District Judge John A. Ross on 10/27/14. (JWD) (Entered: 10/27/2014)

MOTION for Leave to file first amended complaint by Plaintiff Mustafa Hussein. (Attachments: # 1 Proposed Amended Complaint)(Rothert, Anthony) (Entered: 11/12/2014)

1 Proposed Amended Complaint

View on PACER

MEMORANDUM in Support of Motion re 27 MOTION for Leave to file first amended complaint filed by Plaintiff Mustafa Hussein. (Rothert, Anthony) (Entered: 11/12/2014)

Docket Text ORDER: Re: 27 MOTION for Leave to file first amended complaint by Plaintiff Mustafa Hussein. (Attachments: # 1 Proposed Amended Complaint) ORDERED GRANTED. Signed by District Judge John A. Ross on 11/12/14. (JWD) (Entered: 11/12/2014)

FIRST AMENDED COMPLAINT against defendant All Defendants Amendment to 1 Complaint, filed by Mustafa Hussein. Related document: 1 Complaint, filed by Mustafa Hussein.(JWD) (Entered: 11/12/2014)

MOTION for Preliminary Injunction by Plaintiff Mustafa Hussein. (Rothert, Anthony) (Entered: 11/14/2014)

MEMORANDUM in Support of Motion re 31 MOTION for Preliminary Injunction filed by Plaintiff Mustafa Hussein. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I)(Rothert, Anthony) (Entered: 11/14/2014)

1 Exhibit A

View on PACER

2 Exhibit B

View on PACER

3 Exhibit C

View on PACER

4 Exhibit D

View on PACER

5 Exhibit E

View on PACER

6 Exhibit F

View on PACER

7 Exhibit G

View on PACER

8 Exhibit H

View on PACER

9 Exhibit I

View on PACER

ANSWER to 30 Amended Complaint by St. Louis, Missouri, County of.(Shuman, Michael) (Entered: 11/18/2014)

ENTRY of Appearance by Andrew J. McNulty for Plaintiff Mustafa Hussein. (McNulty, Andrew) (Entered: 11/20/2014)

Joint MOTION to Approve Consent Judgment (Joint Motion of Plaintiff and Defendant Ronald K. Replogle ONLY) by Plaintiff Mustafa Hussein. (Attachments: # 1 Text of Proposed Order)(Rothert, Anthony) (Entered: 11/20/2014)

1 Text of Proposed Order

View on PACER

Joint MOTION to Approve Consent Judgment (Joint Motion of Plaintiff and Defendant City of Ferguson, Missouri, only) by Plaintiff Mustafa Hussein. (Attachments: # 1 Text of Proposed Order)(Rothert, Anthony) (Entered: 11/20/2014)

1 Text of Proposed Order

View on PACER

Joint MOTION to Approve Consent Judgment of plaintiff and defendant st. louis county by Plaintiff Mustafa Hussein. (Attachments: # 1 Text of Proposed Order)(Rothert, Anthony) (Entered: 11/21/2014)

1 Text of Proposed Order

View on PACER

ORDER: IT IS HEREBY ORDERED that Defendant Replogle, his successors, officers, agents, servants, employees, attorneys, and all persons under their supervision, or within their control, are permanently enjoined from enforcing a policy or custom of interfering with individuals who are photographing or recording at public places but who are not threatening the safety of others or physically interfering with the ability of law enforcement to perform their duties; IT IS FURTHER ORDERED that this Order resolves all claims asserted by Plaintiff in the First Amended Complaint against Defendant Replogle and, thus, he is terminated from this case. IT IS FINALLY ORDERED that this Court retains jurisdiction to enforce this order. Signed by District Judge John A. Ross on 11/21/14. (LGK) (Entered: 11/21/2014)

ORDER: IT IS HEREBY ORDERED that Defendant the City of Ferguson, Missouri, its officers, employees, or agents, and those acting on its behalf, shall not enforce or threaten to enforce any rule, policy, or practice that grants law enforcement officers the authority or discretion to arrest, threaten to arrest, or interfere with any individual, including any member of the media or member of the public photographing or recording in public places unless that person is threatening the safety of others or physically interfering with the ability of law enforcement to perform their duties. IT IS FURTHER ORDERED that this Order grants the full extent of relief to be afforded Plaintiff herein against the City of Ferguson, and any and all other claims set forth in Plaintiff's Amended Complaint against the City of Ferguson are hereby dismissed. IT IS FINALLY ORDERED that this Court retains jurisdiction to enforce this order. Signed by District Judge John A. Ross on 11/21/14. (LGK) (Entered: 11/21/2014)

ORDER: IT IS HEREBY ORDERED that Defendant County of St. Louis, Missouri, its officers, agents, servants, employees, attorneys, and all persons under their supervision, or within their control, are permanently enjoined from interfering with individuals who are photographing or recording at public places but who are not threatening the safety of others or physically interfering with the ability of law enforcement to perform their duties; IT IS FURTHER ORDERED that this Order resolves all claims asserted by Plaintiff in the First Amended Complaint against Defendant County of St. Louis, Missouri and, thus, County of St. Louis, Missouri, is terminated from this case. IT IS FINALLY ORDERED that this Court retains jurisdiction to enforce this order. Signed by District Judge John A. Ross on 11/21/14. (LGK) (Entered: 11/21/2014)

MOTION for Order to Show Cause by Plaintiff Mustafa Hussein. (Attachments: # 1 United States Department of Justice Civil Rights Division, "Investigation of Ferguson Police Department" March 4, 2015)(Rothert, Anthony) (Entered: 03/06/2015)

1 United States Department of Justice Civil Rights Division, "Investigation

View on PACER

ENTRY of Appearance by Carl J. Lumley for Defendant Ferguson, Missouri, City of. (Lumley, Carl) (Entered: 03/12/2015)

RESPONSE TO ORDER TO SHOW CAUSE re 41 MOTION for Order to Show Cause by Defendant Ferguson, Missouri, City of filed by Defendant Ferguson, Missouri, City of. (Attachments: # 1 Attachment)(Lumley, Carl) (Entered: 03/12/2015)

REPLY to Response to Motion re 41 MOTION for Order to Show Cause filed by Plaintiff Mustafa Hussein. (Rothert, Anthony) (Entered: 03/19/2015)

MOTION to Supplement 41 MOTION for Order to Show Cause by Plaintiff Mustafa Hussein. (Attachments: # 1 Exhibit Declaration of Singleton, # 2 Exhibit Declaration of Kampas, # 3 Exhibit Declaration of McCoy)(Rothert, Anthony) (Entered: 04/27/2015)

1 Exhibit Declaration of Singleton

View on PACER

2 Exhibit Declaration of Kampas

View on PACER

3 Exhibit Declaration of McCoy

View on PACER

NOTICE of Filing Exhibit with the Clerk's Office in paper format by Plaintiff Mustafa Hussein re 45 MOTION to Supplement 41 MOTION for Order to Show Cause (Rothert, Anthony) (Entered: 04/27/2015)

NOTICE of Filing Exhibit with the Clerk's Office in paper format by Plaintiff Mustafa Hussein re 45 MOTION to Supplement 41 MOTION for Order to Show Cause (Rothert, Anthony) (Entered: 04/27/2015)

NOTICE of Filing Exhibit with the Clerk's Office in paper format by Plaintiff Mustafa Hussein re 45 MOTION to Supplement 41 MOTION for Order to Show Cause (Rothert, Anthony) (Entered: 04/27/2015)

SUPPLEMENTAL (DISC OF DECLARATION OF ALLEN SINGLETON) re 45 MOTION to Supplement 41 MOTION for Order to Show Cause by Plaintiff Mustafa Hussein. (LGK) (Entered: 04/27/2015)

SUPPLEMENTAL (DISC OF DECLARATION OF JENNIFER MCCOY) re 45 MOTION to Supplement 41 MOTION for Order to Show Cause by Plaintiff Mustafa Hussein. (LGK) (Entered: 04/27/2015)

SUPPLEMENTAL (DISC OF DECLARATION OF SCOTT KAMPAS) re 45 MOTION to Supplement 41 MOTION for Order to Show Cause by Plaintiff Mustafa Hussein. (LGK) (Entered: 04/27/2015)

ORDER: IT IS HEREBY ORDERED that Plaintiff's Motion to Supplement Plaintiff's Motion for Order to Show Cause Why Defendant City of Ferguson, Missouri, Should not be Held in Contempt for Failing to Comply with Consent Judgment 45 is GRANTED. IT IS FURTHER ORDERED that Plaintiff's Motion for Order to Show Cause 41 is GRANTED. Defendant City of Ferguson, Missouri shall show cause in writing, within ten (10) days of the date of this Order, why this matter should not be set for a hearing on whether it should be held in contempt for failing to comply with the November 21, 2014 consent judgment. Signed by District Judge John A. Ross on 4/27/15. (LGK) (Entered: 04/27/2015)

Remark

Supplemental (NON-MOTION EVENT)

Supplemental (NON-MOTION EVENT)

***REMARK - 3 DISCS REFERRED TO IN DOCUMENT NOS. 49, 50, AND 51 ARE BEING KEPT IN THE CLERK'S OFFICE (LGK)

RESPONSE TO ORDER TO SHOW CAUSE re 52 Order,, by Defendant Ferguson, Missouri, City of. (Attachments: # 1 Affidavit, # 2 Attachment, sealed # 3 Attachment, sealed # 4 Attachment) (Lumley, Carl) Modified on 5/8/2015 to seal attachments 3 & 4 (ARL). (Entered: 05/06/2015)

1 Affidavit

View on RECAP

2 Attachment

View on RECAP

3 *Restricted*

View on PACER

4 *Restricted*

View on PACER

First MOTION to Seal Document 53 Response to Order to Show Cause by Defendant Ferguson, Missouri, City of. (Lumley, Carl) (Entered: 05/07/2015)

Docket Text ORDER: Re: 54 First MOTION to Seal Document 53 Response to Order to Show Cause by Defendant Ferguson, Missouri, City of ORDERED GRANTED. Signed by District Judge John A. Ross on 5/7/15. (JWD) (Entered: 05/07/2015)

A Docket Text Order

MOTION to Withdraw as Attorney ;attorney/firm Grant R. Doty by Plaintiff Mustafa Hussein. (Doty, Grant) (Entered: 05/12/2015)

Docket Text ORDER: Re: 56 MOTION to Withdraw as Attorney ;attorney/firm Grant R. Doty by Plaintiff Mustafa Hussein ORDERED GRANTED, Attorney Grant R. Doty terminated. Signed by District Judge John A. Ross on 5/12/15. (JWD) (Entered: 05/12/2015)

~Util - Add and Terminate Attorneys AND A Docket Text Order

ENTRY of Appearance by Jessie M. Steffan for Plaintiff Mustafa Hussein. (Steffan, Jessie) (Entered: 07/09/2015)

ENTRY of Appearance by Stephen M. Ryals for Movant Cachet Currie. (Ryals, Stephen) (Entered: 10/20/2015)

MOTION for Order to Show Cause by Movant Cachet Currie. (Attachments: # 1 Attachment Complaint)(Ryals, Stephen) (Entered: 10/20/2015)

1 Attachment Complaint

View on PACER

ENTRY of Appearance by Peter J. Dunne for Defendant Ferguson, Missouri, City of. (Dunne, Peter) (Entered: 10/27/2015)

ENTRY of Appearance by Robert T. Plunkert for Defendant Ferguson, Missouri, City of. (Plunkert, Robert) (Entered: 10/27/2015)

ENTRY of Appearance by Ida S. Shafaie for Defendant Ferguson, Missouri, City of. (Shafaie, Ida) (Entered: 10/27/2015)

RESPONSE to Motion re 60 MOTION for Order to Show Cause filed by Defendant Ferguson, Missouri, City of. (Dunne, Peter) (Entered: 10/27/2015)

ENTRY of Appearance by Chelsea Kay Merta for Movant Cachet Currie. (Merta, Chelsea) (Entered: 11/03/2015)

MOTION for Extension of Time to File Response/Reply by Movant Cachet Currie. (Merta, Chelsea) (Entered: 11/03/2015)

Docket Text ORDER Re: 66 MOTION for Extension of Time to File Response/Reply by Movant Cachet Currie ; ORDERED GRANTED, ( Response to Court due by 11/9/2015.) Signed by District Judge John A. Ross on 11/4/2015. (KMS) (Entered: 11/04/2015)

~Util - Set Deadlines/Hearings AND A Docket Text Order

Consent MOTION to Amend/Correct 64 Response to Motion by Defendant Ferguson, Missouri, City of. (Attachments: # 1 Attachment Amended Response)(Dunne, Peter) (Entered: 11/05/2015)

1 Attachment Amended Response

View on PACER

Docket Text ORDER: GRANTING 68 Consent MOTION to Amend/Correct 64 Response to Motion by Defendant Ferguson, Missouri, City of.. Signed by District Judge John A. Ross on 11/5/15. (KKS) (Entered: 11/05/2015)

AMENDED RESPONSE TO MOTION TO SHOW CAUSE by Defendant the City of Ferguson and Ferguson Police Officer Harry Dilworth 64 (KKS) (Entered: 11/05/2015)

MOTION to Stay re 60 MOTION for Order to Show Cause by Movant Cachet Currie. (Ryals, Stephen) (Entered: 11/05/2015)

A Docket Text Order

ORDER: IT IS HEREBY ORDERED that the parties shall provide the Court with a status update no later than February 12, 2016. Should the parties fail to provide an update, the Court will rule on all pending matters. Signed by District Judge John A. Ross on 1/13/2016. (KMS) (Entered: 01/13/2016)

MOTION for Order to Show Cause by Movants Christopher Phillips, DeAndre Blue, Heather De Mian, Brian Lohmann, Jerome Tolliver, Ebony Williams. (Attachments: # 1 Exhibit A)(Wyrsch, James) (Entered: 01/22/2016)

1 Exhibit A

View on PACER

RESPONSE to Motion re 73 MOTION for Order to Show Cause filed by Defendant Ferguson, Missouri, City of. (Dunne, Peter) (Entered: 01/29/2016)

MOTION to Withdraw as Attorney ;attorney/firm Stephen M. Ryals by Movant Cachet Currie. (Ryals, Stephen) (Entered: 02/03/2016)

Docket Text ORDER Re: 75 MOTION to Withdraw as Attorney ;attorney/firm Stephen M. Ryals by Movant Cachet Currie; ORDERED GRANTED. Signed by District Judge John A. Ross on 2/4/2016. (KMS) (Entered: 02/04/2016)

A Docket Text Order

REPLY to Response to Motion re 73 MOTION for Order to Show Cause filed by Movant Christopher Phillips. (Hall, Edward) (Entered: 02/08/2016)

ENTRY of Appearance by Edward James Hall for Movant Christopher Phillips, Deandre Blue, Heather De Mian, Brian Lohmann, Jerome Tolliver, Jr, Ebony Williams. (Hall, Edward) Modified text on 2/10/2016 (JAB). (Entered: 02/09/2016)

RESPONSE TO COURT ORDER re 72 Scheduling Order, by Plaintiff Mustafa Hussein. (Rothert, Anthony) (Entered: 02/09/2016)

ENTRY of Appearance by Thomas B. Harvey for Movant Cachet Currie. (Harvey, Thomas) (Entered: 02/12/2016)

MOTION to Withdraw Motion for Show Cause Order by Movant Cachet Currie. (Attachments: # 1 Text of Proposed Order Granting Movant's Motion to Withdraw Motion for Show Cause Order)(Harvey, Thomas) (Entered: 02/12/2016)

1 Text of Proposed Order Granting Movant's Motion to Withdraw Motion for Show

View on PACER

Joint MOTION for Hearing by Plaintiff and movants by Movants DeAndre Blue, Heather De Mian, Brian Lohmann, Christopher Phillips, Jerome Tolliver, Ebony Williams, Plaintiff Mustafa Hussein. (Rothert, Anthony) (Entered: 02/25/2016)

ORDER: IT IS HEREBY ORDERED that Cachet Curries Unopposed Motion to Withdraw Motion for Order to Show Cause (Doc. No. 81) is GRANTED. IT IS FURTHER ORDERED that Cachet Curries Motion for Order to Show Cause (Doc. No. 60) is DENIED without prejudice as moot. IT IS FINALLY ORDERED that the parties Consent Motion to Stay Motion for Show Cause Order (Doc. No. 71) is DENIED as moot. Signed by District Judge John A. Ross on 2/25/2016. (KMS) (Entered: 02/25/2016)

ORDER: IT IS HEREBY ORDERED that Defendants shall respond to the Joint Motion of Plaintiff and Movants for Evidentiary Hearing (Doc. No. 82) on or before March 7, 2016. Signed by District Judge John A. Ross on 2/26/2016. (KMS) (Entered: 02/26/2016)

RESPONSE to Motion re 82 Joint MOTION for Hearing by Plaintiff and movants filed by Defendant Ferguson, Missouri, City of. (Dunne, Peter) (Entered: 03/07/2016)

ENTRY of Appearance by Javad M. Khazaeli for Movants DeAndre Blue, Heather De Mian, Brian Lohmann, Christopher Phillips, Jerome Tolliver, Ebony Williams. (Khazaeli, Javad) (Entered: 04/22/2016)

MEMORANDUM AND ORDER: IT IS HEREBY ORDERED that the Joint Motion of Plaintiff and Movants for Evidentiary Hearing (Doc. No. 82 ) is DENIED without prejudice. IT IS FURTHER ORDERED that the Motion for Show Cause Order (Doc. No. 73 ) filed by purported "non-party beneficiaries" of the Court's Order of November 21, 2014, is DENIED without prejudice. Signed by District Judge John A. Ross on 4/27/16. (JAB)