Case: Agnew v. New York City Department of Corrections

Agnew v. New York City Department of Correction

Agnew v. New York City Department of Correction

Agnew v. New York City Department of Correction

Agnew v. New York City Department of Correction

New York state trial court

Agnew v. New York City Department of Correction

New York state trial court

PETITION Petition

ORDER TO SHOW CAUSE - ACCOMPANYING COMMENCEMENT DOC(S) (PROPOSED) (Motion #1) *Corrected*

ORDER ( PROPOSED ) Proposed Order Granting Petitioners' Mandamus Relief

AFFIDAVIT OR AFFIRMATION IN SUPPORT Kelsey De Avila Affidavit In Support of Petition

AFFIDAVIT OR AFFIRMATION IN SUPPORT Ronald Schneider Affidavit In Support of Petition

MEMORANDUM OF LAW IN SUPPORT Memorandum of Law in Support of Article 78 Mandamus to Compel and Motion for Class Certification

AFFIDAVIT OR AFFIRMATION IN SUPPORT Affirmation Of Micaela D. Manley In Support Of Petitioners Article 78 Mandamus To Compel And Motion ... show more

EXHIBIT(S) - 1 New York City Roadmap to Closing Rikers web page titled New York is leading a historic decarceration ... show more

EXHIBIT(S) - 2 December 18, 2014 Department of Justice press release titled Department Of Justice Takes Legal Actio ... show more

EXHIBIT(S) - 3 2017 Independent Commission on New York City Criminal Justice and Incarceration Reform Final Report

EXHIBIT(S) - 4 October 17, 2019 ABC News article titled Plan to close notorious Rikers jail complex by 2026 approve ... show more

EXHIBIT(S) - 5 June 2020 New York City Department of Correction Monthly Report on Medical Appointment Non-Productio ... show more

EXHIBIT(S) - 6 Eleventh Report of the Nunez Independent Monitor for the period of July 1, 2020 December 31, 2020

EXHIBIT(S) - 7 July 2020 New York City Department of Correction Monthly Report on Medical Appointment Non-Productio ... show more

EXHIBIT(S) - 8 August 2020 New York City Department of Correction Monthly Report on Medical Appointment Non-Product ... show more

EXHIBIT(S) - 9 November 30, 2020 New York Times article titled Prisons Are COVID-19 Hotbeds. When Should Inmates Ge ... show more

EXHIBIT(S) - 10 December 2020 New York City Department of Correction Monthly Report on Medical Appointment Non-Produ ... show more

EXHIBIT(S) - 11 January 2021 New York City Department of Correction Monthly Report on Medical Appointment Non-Produc ... show more

EXHIBIT(S) - 12 June 2021 New York City Department of Correction Monthly Report on Medical Appointment Non-Productio ... show more

EXHIBIT(S) - 13 July 10, 2021 New York Post article titled City probing death of Rikers Island inmate after guard le ... show more

EXHIBIT(S) - 14 August 2021 New York City Department of Correction Monthly Report on Medical Appointment Non-Product ... show more

EXHIBIT(S) - 15 August 12, 2021 Gothamist article titled Twenty-Five Year Old Detainee Found Dead At Rikers

EXHIBIT(S) - 16 August 13, 2021 New York Daily News article titled Staten Island detainee hangs himself in NYC jail ... show more

EXHIBIT(S) - 17 August 15, 2021 New York Daily News article titled NYC jails medical staff fear for safety, blame st ... show more

EXHIBIT(S) - 18 August 20, 2021 Twitter thread by user Rachael Bedard, MD

EXHIBIT(S) - 19 August 24, 2021 Letter to Judge Swain from the Office of the Monitor filed in Nuez v. City of New Yo ... show more

EXHIBIT(S) - 20 August 26, 2021 New York Focus article titled Rikers Staffing Crisis Limits Access to Medical Care

EXHIBIT(S) - 21 September 1, 2021 Department of Criminal Justice Services Jail Population Report

EXHIBIT(S) - 22 September 1, 2021 Board of Corrections Statement on Recent Suicides in the New York City Jail

EXHIBIT(S) - 23 September 1, 2021 New York Daily News article titled Two Rikers units go more than 24 hours without ... show more

EXHIBIT(S) - 24 September 2, 2021 Letter to Judge Swain from the Office of the Monitor filed in Nuez v. City of New ... show more

EXHIBIT(S) - 25 September 7, 2021 The City article titled Self-Harm Is Exploding In New York City Jails, Internal Nu ... show more

EXHIBIT(S) - 26 September 9, 2021 New York Post article titled NYC jails boss admits serious problems at Rikers Isla ... show more

EXHIBIT(S) - 27 September 10, 2021 letter from Ross MacDonald, MD, to New York City Council

EXHIBIT(S) - 28 September 10, 2021 New York Daily News article titled Rikers prisoner dies after NYC jailers wouldnt ... show more

EXHIBIT(S) - 29 September 13, 2021 New York City Board of Correction Weekly COVID-19 Update Week of September 4 Sep ... show more

EXHIBIT(S) - 30 NYC Board of Correction Public Meeting Materials webpage for the September 14, 2021 Board of Correct ... show more

EXHIBIT(S) - 31 September 14, 2021 Twitter thread by user Emily Gallagher

EXHIBIT(S) - 32 September 14, 2021 New York Times article titled With Rikers in Crisis, Critics Wonder: Where is Bil ... show more

EXHIBIT(S) - 33 September 15, 2021 New York Times article titled 10 Deaths, Exhausted Guards, Rampant Violence: Why ... show more

EXHIBIT(S) - 34 The New York City Council webpage for the September 15, 2021 Meeting of Committee on Criminal Justic ... show more

EXHIBIT(S) - 35 September 15, 2021 Testimony before the New York City Council, Committee on Criminal Justice

EXHIBIT(S) - 36 September 15, 2021 Gothamist article titled COVID Is Surging Back Into Rikers and NYC Jails

EXHIBIT(S) - 37 September 15, 2021 City of New Yorks Declaration of Local State Emergency Executive Order No. 241

EXHIBIT(S) - 38 September 16, 2021 Twitter thread by user Daniel Dromm

EXHIBIT(S) - 39 September 17, 2021 CBS News article titled Cockroaches, rotting food and garbage: Lawmakers say Rike ... show more

EXHIBIT(S) - 40 September 17, 2021 New York Governor press release titled Governor Hochul Announces Major Actions To ... show more

EXHIBIT(S) - 41 September 17, 2021 New York Times article titled Hochul Orders Release of 191 Detainees as Rikers Cr ... show more

EXHIBIT(S) - 42 September 19, 2021 PIX 11 article titled People sleeping in filth, in feces: Jumaane Williams talks ... show more

EXHIBIT(S) - 43 September 20, 2021 Verified Complaint, in City of New York v. Corr. Officers Benevolent Assn., Inc, ... show more

EXHIBIT(S) - 44 September 20, 2021 Memorandum of Law in Support of Temporary Restraining Order and Preliminary Injun ... show more

EXHIBIT(S) - 45 September 20, 2021 New York Times article titled N.Y.C. Sues Jail Officers, Saying Illegal Strike Wo ... show more

EXHIBIT(S) - 46 September 21, 2021 New York Attorney General Letitia James's Statement on Visit to Rikers Island

EXHIBIT(S) - 47 September 21, 2021 NY1 article titled Mayor says Rikers will shorten intake time after latest inmate ... show more

EXHIBIT(S) - 48 September 21, 2021 NY1 article titled Rikers Island detainees expose lack of medical care while in c ... show more

EXHIBIT(S) - 49 September 22, 2021 New York Times article titled 12th Death in Custody This Year Signals Growing Cri ... show more

EXHIBIT(S) - 50 September 22, 2021 Associated Press article titled 12th inmate dies as New York Citys jail crisis in ... show more

EXHIBIT(S) - 51 September 22, 2021 Decision and Order on Motion, in City of New York v. Corr. Officers Benevolent As ... show more

EXHIBIT(S) - 52 September 22, 2021 New York City Board of Correction Weekly COVID-19 Update Week of September 11 Se ... show more

EXHIBIT(S) - 53 September 22, 2021 Complex article titled Rikers Island Inmate Becomes 12th Person to Die in Custody ... show more

EXHIBIT(S) - 54 September 23, 2021 Letter to Judge Swain from the Office of the Monitor filed in Nuez v. City of New ... show more

EXHIBIT(S) - 55 September 28, 2021 Executive Order No. 5 (Declaration of a Disaster Emergency in the Counties of the ... show more

EXHIBIT(S) - 56 NYC Board of Correction website titled About NYC Board of Direction

AFFIDAVIT OR AFFIRMATION IN SUPPORT Affirmation of Veronica Vela in Support of Petitioners' Motion for Class Certification

AFFIDAVIT OR AFFIRMATION IN SUPPORT Affirmation of Brooke Menschel in Support of Petitioners' Motion for Class Certification

AFFIDAVIT OR AFFIRMATION IN SUPPORT Affirmation of Sean M. Murphy in Support of Petitioners' Motion for Class Certification

RJI -RE: ORDER TO SHOW CAUSE *Corrected*

NO FEE AUTHORIZATION (LETTER/ORDER/AFFIRMATION)

NO FEE AUTHORIZATION (LETTER/ORDER/AFFIRMATION)

ORDER TO SHOW CAUSE (Motion #1) DATED: OCTOBER 6,, 2021

EXHIBIT(S) - 20 (Motion #1) Corrected Exhibit to Affirmation of Micaela D. Manley (August 26, 2021 New York Focus article titled ... show more

EXHIBIT(S) - 29 (Motion #1) Corrected Exhibit to Affirmation of Micaela D. Manley (September 13, 2021 New York City Board of Cor ... show more

EXHIBIT(S) - 52 (Motion #1) Corrected Exhibit to Affirmation of Micaela D. Manley (September 22, 2021 New York City Board of Cor ... show more

AFFIRMATION/AFFIDAVIT OF SERVICE (Motion #1)

ANSWER IN SPECIAL PROCEEDING (Motion #1) Verified Answer

MEMORANDUM OF LAW IN SUPPORT (Motion #1) Memorandum of Law in support of Respondent's Verified Answer to the Verified Petition

ORDER ( PROPOSED ) (Motion #1) Proposed Order Granting Class Certification

MEMORANDUM OF LAW IN REPLY (Motion #1) Reply Memorandum of Law in Support of Article 78 Mandamus to Compel Petition and Motion for Class Ce ... show more

APPENDIX (Motion #1) Copy of Monitor Letter from Nunez

SUR-REPLY (Motion #1)

ORDER TO SHOW CAUSE (Motion #1) Short Form Order & Order Granting Class Certification & Order Granting Petitioners' Mandamus Relief ... show more

NOTICE OF ENTRY (Motion #1)

LETTER / CORRESPONDENCE TO JUDGE Cover Letter -Proposed Order

ORDER ( PROPOSED ) Proposed Order

ADJOURNMENT OF MOTION -REQUEST (Motion #1) Respondent's Request for an Extension of Time for Compliance

ORDER TO SHOW CAUSE ( PROPOSED ) (Motion #2) *Corrected*

AFFIDAVIT OR AFFIRMATION IN SUPPORT OF PROPOSED OSC/EXPARTE APP (Motion #2) *Corrected* Fell Affirmation

EXHIBIT(S) - 1 (Motion #2) 12.13.2021 - Letter from A. Yacyshyn

EXHIBIT(S) - 2 (Motion #2) 12.21.2021 - Letter from K. Fell et al

EXHIBIT(S) - 3 (Motion #2) 1.3.2022 - Letter from K. Fell to C. ORsland, B. Krist, and A. Yacyshyn

EXHIBIT(S) - 4 (Motion #2) 1.26.2022 Production [Cover Letter, Aff., Report]

EXHIBIT(S) - 5 (Motion #2) 1.31.2022 - Letter to Respondent DOC

EXHIBIT(S) - 6 (Motion #2) June 2020 Non-Production Report

EXHIBIT(S) - 7 (Motion #2) Dec. 2020 Non-Production Report

EXHIBIT(S) - 8 (Motion #2) June 2021 Non-Production Report

EXHIBIT(S) - 9 (Motion #2) Sept. 2021 Non-Production Report

EXHIBIT(S) - 10 (Motion #2) Oct. 2021 Non-Production Report

EXHIBIT(S) - 11 (Motion #2) Nov. 2021 Non-Production Report

EXHIBIT(S) - 12 (Motion #2) Dec. 2021 Non-Production Report

EXHIBIT(S) - 13 (Motion #2) 1.11.2022 NYTimes Article