Impact Litigation Docket

Along with DLA Piper LLP, The Legal Aid Society filed a petition for certiorari of an opinion of the New York Court of Appeals, which approved a practice by the NYC Department of Correction of sharing with prosecutors recorded telephone conversations between pre-trial detainees and their friends and family without notice to the detainee. The amicus brief was filed with the US Supreme Court. (Louis Sartori, Steven Wasserman)
Petition for a Writ of Certiorari

Plaintiffs challenge the Port Authority Police Department’s discriminatory practice of using plainclothes police officers in men’s bathrooms to target men they perceive to be attracted to other men for false accusations of public lewdness. This case is pending trial in the Southern District of New York. (Cynthia Conti–Cook)
Complaint

The ligation was brought by SLU in conjunction with Willkie Farr & Gallagher LLP, and Prisoners’ Legal Services of New York. On Sept. 25, 2019 oral argument was had on the State’s motion for summary judgment; we oppose that motion and are requesting an evidentiary hearing, following completion of depositions of 14 state officials or employees, and 2 of the petitioners.

SLU is litigating this case on behalf of sex offenders who are being held in prison beyond the expiration dates of their prison sentences and months into their periods of “post-release supervision,” solely because they cannot find a place to live that’s more than 1000 feet from “school grounds,” something that’s nearly impossible in densely-populated New York City. More specifically, SLU is arguing that the prisons which the N.Y. State Department of Corrections and Community Supervision has designated as “Residential Treatment Facilities,” as a device allowing the State to continue confining persons who are technically “released” to supervision, do not legally qualify as “RTFs” because, contrary to statutory requirements, they are not “community-based” residences “where employment, educational and training opportunities…directed toward the rehabilitation and total reintegration into the community…” are provided. (Robert Newman)

This lawsuit, brought on behalf of eight women, both cis- and transgender, sought to strike New York State Penal Law 240.37, which criminalized loitering for the purposes of prostitution, for being unconstitutionally vague and leaving marginalized New Yorkers vulnerable to discriminatory policing practices. The case settled for a revision of the Patrol Guide section related to policing loitering for the purposes of prostitution, related training and a limited period of auditing new arrests for compliance. (Kimberly Forte, William Donald Gibney, Sr., Cynthia Conti–Cook, Kate Mogulescu)
Complaint, Amended Complaint

In this First Amendment case for injunctive and declaratory relief, Mr. An fought for recognition of the right to record police encounters after he was falsely arrested in retaliation for refusing to stop recording a public police encounter. The case settled for the creation of a new Patrol Guide Section 203-29 “When A Member of the Service Encounters an Individual Observing, Photographing, and/or Recording Police Activity” that specifically instructs police that “[i]ndividuals have a right to lawfully observe and/or record police activity” in addition to related training and messaging alerts around the new Patrol Guide rule. (Cynthia Conti-Cook, Joshua Carrin)
Complaint, Opinion and Order on Motion to Dismiss, Amended Complaint, Opinion and Order

The first case to expose rape and sexual abuse of detainees/inmates by correctional staff at Rikers Island. Jane Doe 1 and Jane Doe 2 settled the case for $1.2 million. (William Gibney, Marlen Bodden, Barbara Hamilton)
Complaint

Along with Beldock, Levine and Hoffman, Legal Aid filed a class action that challenged an NYPD practice of suspicionless, unsystematic, and undocumented vehicle checkpoints, established at major highway interchanges in search of contraband and intoxicated drivers. The district court ruled that all vehicle inspections must conform to constitutional standards codified in an amended NYPD Patrol Guide. The parties are in the process of drafting the necessary amendments. (Steven Wasserman)
Decision

Is a Federal class action that was brought along with Paul, Weiss, Wharton, Rifkind and Garrison and the NAACP Legal Defense Fund, to end a longstanding practice of unconstitutional stops, searches and false arrests of NYC Public Housing residents and their guests. The action was settled in 2013 by placing the policing of NYCHA Housing under the supervision of a Federal Monitor.  The ongoing monitoring process has produced substantial revisions to NYPD training and regulations, including a requirement that all walk through patrols of NYCHA hallways be recorded on body cameras. (William Gibney, Steve Wasserman, Marlen Bodden, Cynthia Conti-Cook)
Decision

This is a federal class action brought by The Legal Aid Society. It challenged the practice of the New York City Police Department of seizing automobiles and impounding them on arrests for DWI and drug and gun possession arrests. Clients are now entitled under the Due Process Clause to a hearing at the Office of Administrative Trials and Hearings (OATH) at which to challenge the impoundment and accomplish return of the vehicle. The “Krimstock hearing” has been an institution in New York criminal practice since 2004. Hundreds of hearings have resulted in written decisions available on the OATH website. (Tom O’Brien of Special Lit litigated the case in the District Court and the Court of Appeals from 1999 through 2007 and continues to monitor OATH proceedings and counsel attorneys and litigants on retrieving their seized vehicles)

This is a federal class action brought by The Legal Aid Society on behalf of former sex offenders who were required to register and be subject to public notification under New York’s Sex Offender Registration Act, which became effective in 1996. The District Court initially enjoined enforcement of the law as violative of the Ex Post Facto Clause of the U.S. Constitution. After reversal on appeal, further litigation produced a decision by the District Court under the Due Process Clause, enjoining public notification until registrants were afforded hearings that complied with due process. State law was amended to comply with the ruling, and hundreds of rehearings were conducted after 2004. SORA litigation at the trial and appellate level has been a regular feature of sex offender representation in New York since the Doe v. Pataki decisions. (Tom O’Brien, Susan Hendricks, Laura Johnson)

A Federal class action brought in 1992 on behalf of pre-arraignment detainees concerning their conditions of confinement, including their access to medical attention, prescription medication, proper sanitation and ventilation, adequate food and water, and facilities for a private pre-arraignment interview with counsel. The final order provides for continuing jurisdiction, which is ongoing with co-counsel White & Case LLP and Lankler, Siffert & Wohl LLP. (William Gibney, Cynthia Conti-Cook)
Stipulation of Settlement

Challenge to New York State Department of Health’s policy refusing to provide essential dental care to Medicaid recipients with co-counsel Wilkie Farr and Gallagher LLP. Plaintiffs’ motion for class certification and the Department of Health’s made a motion to dismiss. The Department of Health’s Motion to Dismiss was almost entirely denied. The portion of the MTD that was granted was granted with leave to amend. We’ve filed an amended complaint. Discovery is ongoing. (Belkys Garcia, Rebecca Novick, Judith Goldiner)
Complaint, Amended Complaint

A challenge to the New York State Department of Health and a managed health care company, Healthfirst, was brought on behalf of Medicaid recipients who were denied a request for an increase in homecare services they needed in order to live in their homes and communities with with co-counsel Winston & Strawn The case was settled and monitoring of the defendants’ compliance with the settlement is ongoing. (Belkys Garcia, Rebecca Novick, Judith Goldiner)
Complaint

Newark sued New York City regarding homeless families being placed in Newark. We sought to intervene on behalf of a client who wants to move to Newark and a client who was placed in Newark in bad conditions. Our initial motion to intervene was denied, with leave to refile with a pleading. We refiled our motion to intervene with co-counsel Lowenstein Sandler LLP. (Josh Goldfein)

Case filed with co-counsel Paul, Weiss, Rifkind, Wharton & Garrison LLP against scatter site landlord on behalf of homeless residents and rent-regulated tenant against landlord and “social service provider” for violating the residents and tenants’ rights under rent regulation and failing to maintain decent conditions. Landlord’s motion to dismiss granted. Case is on appeal. (Sunny Noh, Judith Goldiner, Kat Meyers, Caryn Schreiber, Meghan Walsh, Shemori Corinthian, Perry McCall)

Class action case brought against the Department of Social Services for discriminating against homeless people with disabilities with co-counsel White & Case LLP. The case settled and monitoring of compliance with the settlement is ongoing. (Joshua Goldfein, Beth Hofmeister, Kathryn Kliff, Judith Goldiner)
Stipulation of Settlement 

Along with pro bono co-counsel Patterson Belknap Webb & Tyler LLP, the Civil Homeless Rights Project, the LGBT Law and Policy Initiative, and JRP SLLRU brought this federal class-action lawsuit alleging that NYC fails to provide adequate shelter and services for runaway & homeless youth (RHY) (ages 16-21) and to provide reasonable accommodations or mental health services to RHY with disabilities. Since filing the lawsuit, the City has increased the total number of youth-specific shelter beds from 253 in 2013 to 636 in July 2018, with a goal of 753 beds by the end of FY 2019. We have reached agreement in principle with the City on all remaining claims in the lawsuit and the final executed stipulation was filed. The case has been transferred to the magistrate judge to set a fairness hearing. (Beth Hofmeister, Judith Goldiner, Theresa Moser, Lisa Freeman)
Amended Complaint

Class action seeking relief for homeless families (with children and adult couples) who are denied shelter because of purported availability of other housing in housing with eligibility restrictions, including public housing, which is not available to them. (Joshua Goldfein, Beth Hofmeister, Judith Goldiner)

Case brought to ensure the right to shelter for homeless families. Case settled and is currently being monitored for compliance. (Judith Goldiner, Beth Hofmeister, Joshua Goldfein, Kathryn Kliff)
Judgment

Case brought to ensure the right to shelter for homeless men and women. Case settled with a consent order ensuring the right to shelter for homeless single adults. The settlement provides for monitoring by the Coalition for the Homeless. Monitoring continues. (Joshua Goldfein, Beth Hofmeister, Judith Goldiner)
Judgment

Landlords sued City and State alleging that rent stabilization is a taking and violates their due process. Tenant and homeless groups, with co-counsel Selendy & Gay PLLC, LSNYC, have intervened, and the motion to dismiss is pending. (Ellen Davidson)

Related matters:

• 74 Pinehurst et al. v. City et al., CV 06447 (EDNY)
  Group of landlords sued saying rent stabilization is an as-applied taking. We intervened, and the motion to dismiss is pending.
• Building & Realty Institute of Westchester and Putnam Counties et al v. State of New York and HCR, CV 11285 (SDNY)
  Group of landlords in Westchester sued saying rent stab is an as-applied taking. Our motion to intervene was granted. A motion to dismiss has been filed.
• G-Max Management et al v. State of New York et al, 20-cv-634 (SDNY)
  New group of landlords sued saying new rent stab law is a taking and violates fair housing law. Our motion to intervene was granted. A motion to dismiss has been filed.
• 335-7 et al v. State of New York et al., CV 01053 (SDNY)
  New group of landlords sued saying new rent stab law is a taking. Our motion to intervene was granted. A motion to dismiss has been filed.

Class action lawsuit brought with co-counsel Wilkie, Farr and Gallagher LLP against the New York City Housing Authority for failing to provide rent abatements due to NYCHA’s failure to provide heat and hot water in the winter of 2018. The trial court granted NYCHA’s motion to dismiss. On appeal, the First Department unanimously vacated the trial court’s judgment, reinstated the cause of action for breach of the warranty of habitability, and granted plaintiffs’ motion for certification of a “damages class.” The First Department noted that “NYCHA conceded that 80% of its housing units experienced heat and/or hot water outages during the relevant period, which demonstrates that the problems that affected each class member were system-wide,” and that “class action treatment is the most efficient method for adjudicating the claims of class members who lack the resources to bring individual actions for the small recovery they might obtain.” (Lucy Newman)
Decision

Class action filed, with co-counsel Milbank LLP, against landlord who failed to treat tenants as rent-stabilized while in receipt of J-51 tax benefits. The landlord’s motion to dismiss was denied. (Ellen Davidson, Amee Master)

Complaint filed against Parkash, a large landlord in Bronx, for refusing to accept our client’s Section 8 voucher. Currently in discovery. (Robert Desir)

Landlords brought a case against regulations promulgated by the New York State Department of Housing and Community Development. Motion to intervene on behalf of tenant organizations, filed with Patterson Belnap Webb & Tyler LLP and LSNYC, was granted. Decision to dismiss the landlords’ case was granted. Decision is currently on appeal to the Second Department. (Ellen Davidson)

Class action brought with co-counsel Skadden Arps against the New York City Housing Authority for failing to give due process and to accommodate tenants with mental disabilities in NYCHA’s termination of tenancy proceedings. Judge issued decision granted plaintiffs’ motion for summary judgement. Case settled requiring guardians ad litem to be appointed in appropriate cases at termination of tenancy proceedings and NYCHA to provide notice to housing court where the tenant lack competence. Counsel are monitoring compliance with settlement. (Lucy Newman, Judith Goldiner)

Complaint filed against ICE for making civil arrests against immigrants on their way to and from the NYS courts.  Filed with Cleary Gottlieb Steen and Hamilton as related to NY State and Brooklyn District Attorney v. ICE.  The court denied the defendants’ motion to dismiss. The case is ongoing. (Susan Cameron, Susan Welber)
Complaint

Along with co-counsel Paul, Weiss, Rifkind, Wharton & Garrison LLP and the Center for Constitutional Rights, we filed a complaint and motion for a preliminary injunction challenging the U. S. Dep’t of Homeland Security’s Public Charge Ground of Inadmissibility final rule. While the district court granted the Plaintiffs’ preliminary injunction, the injunction is currently stayed by the Supreme Court and is pending before the Second Circuit. Plaintiffs subsequently moved for a preliminary injunction for the duration of the Covid-19 pandemic emergency, which was granted, but stayed by the Second Circuit. That preliminary injunction is pending before the Second Circuit. The SDNY denied the Defendants’ MTD, and discovery is ongoing. (Susan Welber, Susan Cameron, Kathleen Kelleher)
Complaint, Motion for Preliminary Injection

Along with co-counsel Paul, Weiss, Rifkind, Wharton & Garrison LLP, the Center for Constitutional Rights, and the National Immigration Law Center, we filed a complaint and motion for a preliminary injunction challenging the Presidential Proclamation No. 9945 entitled “Presidential Proclamation on the Suspension of Entry of Immigrants Who Will Financially Burden the United States Healthcare System,” the U.S. Department of State’s interim final rule, Visas: Ineligibility Based on Pubic Charge Grounds, and the 2018 revisions to the Department of State’s Foreign Affairs Manual. The SDNY granted the plaintiffs’ motion for a preliminary injunction and denied the Defendants’ MTD. The litigation is ongoing. (Susan Welber, Susan Cameron)

Complaint filed with Bronx Defenders, Brooklyn Defenders, Wilmer Hale LLP, Debevoise & Plimpton LLP against ICE’s use of video conferencing which is interfering with attorney-client privilege.  Motion to dismiss by ICE granted.  After a motion under CLPR 59(e) to reinstate plaintiffs’ bond hearing and count six pending, the court declined to reconsider some of the claims and is staying a decision in others. (Jennifer Williams, Julia Dona)
Opinion and Order

A joint project of the Civil Law Reform Unit, the Immigration Law Unit, and the Juvenile Rights Special Litigation and Law Reform Unit, this federal class action lawsuit, brought with co-counsel Latham & Watkins LLP, successfully challenged the US Citizenship & Immigration Services’ (USCIS) change of policy that resulted in denials of Special Immigrant Juvenile Status (SIJS) petitions submitted by 18-21 year-olds in New York State. SIJS status provides a path to citizenship for some undocumented young people. As a result, thousands of SIJS petitions are being re-adjudicated. Monitoring of the judgment is ongoing. (Beth Krause, Julie Dona, Amy Pont, Christina Romero, Liz Rieser-Murphy, Theresa Moser, Lisa Freeman)
Amended Complaint, Opinion and Order, Amended Judgment

Along with Arnold & Porter LLP, we represent Intervenor Y.C.T. in this Hague Convention case filed by Y.C.T.’s father seeking her return to Guatemala. Plaintiff and intervenors’ motions to dismiss were granted, and the case was dismissed with prejudice by the District Court. Teller then filed an appeal, which was also dismissed. (Theresa Moser, Lisa Freeman)
Complaint, Judgement

Along with Davis, Polk and Wardwell LLP, and Lawyers For Children, JRP SLLRU brought and settled a state court class action lawsuit challenging the failure of the NYC Administration for Children’s Services (ACS) to ensure that youth aging out of foster care had stable housing and were not being discharged to homelessness. As a result of the settlement, ACS developed new policies extending the placement in foster care of some youth past the age of 21, increased training to its contract foster care agencies, developed new tracking practices, and took over supervision of youth discharged to independent living prior to their 21st birthday. Formal monitoring of compliance with the settlement ended in 2017. (Karen Gutheil, Beth Hofmeister, Lena McMahon, Courtney Camp, Jayne Cooper, Lisa Freeman)
The complaint, Approved Settlement Stipulation, Approved Order and Final Judgment

Along with Patterson, Belknap, Webb & Tyler LLP, SLLRU brought this federal class-action lawsuit challenging the failure of NYC Administration for Children’s Services (ACS) to provide children in its custody in acute care psychiatric hospitals with adequate discharge planning and prompt discharge to the least restrictive setting. The parties reached a settlement requiring the development of new policies and the creation of the ACS Mental Health Coordination Unit (MHCU) responsible for tracking these children and providing technical assistance to foster care agencies. Monitoring of compliance concluded in 2016. For more information, contact Lisa Freeman.
Complaint, Stipulation and Order of Settlement

Along with Orrick, Herrington & Sutcliffe LLP, LLP, JRP SLLRU brought and settled a federal class-action lawsuit on behalf of 14 named plaintiffs and the class of all youth adjudicated as juvenile delinquents and placed in certain facilities run by the Office of Children and Family Services (OCFS). The settlement provided damages to the named plaintiffs and required OCFS to implement policies to reduce the use of force and physical restraints against residents, including an end to the use of prone (face down on the floor restraints) and a requirement that restraints be used only as a last resort. The settlement also provided for comprehensive mental health services and the establishment of a quality assurance system to ensure that OCFS policies and procedures are in fact being followed. Monitoring of compliance with the settlement ended in 2018. (Christine Bella, Lisa Freeman, Theresa Moser)
Amended Complaint, Stipulation of Settlement

Along with Dewey Ballantine LLP and Advocates For Children, JRP SLLRU and CDP brought this federal class action lawsuit challenging educational practices of the NYC Department of Education (DOE) and the NYS Education Department for youth in or exiting court-ordered settings. The parties settled the claims, requiring that NYC DOE, among other things, the timely and appropriately re-enroll youth in school upon their return, including the timely development of an Individual Education Plan (IEP), and a review the transcripts of returning high school students to determine what credit will be awarded. Monitoring of the claims against NYC DOE terminated in 2016. For more information, contact Lisa Freeman.
Amended Complaint, Report and Recommendation, Amended Order

One of the most pressing problems undermining successful reentry after incarceration for people with serious mental health needs is the lack of housing and community-based mental health services and supports.  PRP and co-counsel Disability Rights New York and Paul, Weiss, Rifkind, Wharton & Garrison LLP brought this case on behalf of several homeless people with serious mental illness who are being held in New York state prison past their release dates because they require community-based mental health housing upon release, but none is available.  The suit seeks an injunction requiring New York State to provide these individuals with the supportive services they need.  (Robert Quackenbush, Stefen Short, Veronica Vela)
Complaint, Amended Complaint

This is a putative class action on behalf of all women incarcerated in the New York State prison system, filed together with Debevoise & Plimpton LLP.  It challenges sexual abuse by correction officers and the failure of prison authorities to investigate allegations of sexual abuse thoroughly and to discipline staff who have sexually abused incarcerated people.  The case seeks reform of the oversight and investigation of sexual abuse in prisons statewide.  We have also represented individuals in separate actions against their abusers for the injuries caused by the sexual assault.  (Dori Lewis, Veronica Vela)
Complaint

Jairo Polanco Muñoz, a 24-year-old homeless man with a long history of serious psychiatric illness, was jailed in New York City because he could not pay the $750 bail on charges for stealing a phone in a donut shop.    Within three days, he died by suicide, after medical and correctional authorities ignored their own suicide prevention protocols and knowledge of his serious risks and prior suicidal behavior in City jails.  Together with O’Melveny & Myers LLP and Myers and Skadden, Arps, Slate, Meagher & Flom LLP, PRP represents his surviving mother in a lawsuit against the City and the Health and Hospitals Corporation and in estate proceedings.  (Robert Quackenbush, Stefen Short, Veronica Vela)
Complaint

This suit under the Americans with Disabilities Act and the Rehabilitation Act sought to redress the New York State prisons’ failure to accommodate the disabilities of legally blind and severely visually impaired people in their custody. DOCCS made substantial improvements pursuant to a settlement agreement.  (Veronica Vela)

This class action challenging systemic brutality by staff against people incarcerated in New York City jails resulted in a landmark consent decree mandating significant reforms in the use of force practices in the City jails.  (Mary Lynne Werlwas, Kayla Simpson, with Emery Celli Brinckerhoff and Abady)
Complaint, Consent Decree, Monitor Report

PRP challenged the inadequate mental health care in the state prison system. Incarcerated people were being kept in 23-hour solitary confinement for behavior caused or aggravated by their mental illness, and a “revolving door” syndrome in which people who decompensated in isolated confinement were psychiatrically committed but then returned to solitary. Together with Disability Advocates, Inc. and Davis, Polk & Wardwell LLP, we crafted a settlement that expanded treatment programs and mitigated the use and severity of isolated confinement for people with mental illness. Many of the protections of the settlement agreement have been incorporated into state statutes. For more information, contact Stefen Short.
Complaint, Settlement

This class action challenged the failure to accommodate people with hearing disabilities who are incarcerated in New York state prisons.  The court entered a consent judgment spelling out measures to provide proper accommodations for class members.   PRP continues to enforce compliance with the judgment and ensure that people with hearing disabilities receive the services and accommodations they need in state prison.  (Stefen Short, Veronica Vela)

When PRP brought this lawsuit to secure high school education for youth incarcerated in New York City’s adult jails, only about 40% of the eligible youth attended school in jail.  After the federal court found that New York City was violating these children’s constitutional and statutory rights, it entered successive injunctions to force the City to provide these high schoolers with their education.  As a result of the litigation, school attendance increased to about 90%.  With Paul, Weiss, Rifkind, Wharton & Garrison LLP, we continue to enforce these decrees so that no child is deprived of a high school education due to incarceration in New York City. (Dori Lewis, Stefen Short, Mary Lynne Werlwas)
Complaint, Opinion 2000, Opinion 2002

The Prisoners’ Rights Project is regularly involved in litigation and non-litigation advocacy to ensure that mothers who give birth to children while incarcerated are not separated from their infants for at least the first year, if that is in the best interest of the child.  After PRP brought a class action in Earth v. Koch, Index No. 44549/83 (N.Y. Supreme Court), challenging New York City’s separation of newborn children from their mothers in violation of state correction law, the Department of Correction established a nursery facility on Rikers Island.  The State prison system also has a nursery program. We assist women in both City custody and in State prison in securing access to their nursery programs so they may parent their newborn children as the law provides.  (Dori Lewis)

This action challenged excessive force and violence against incarcerated people in the Correctional Institution for Men (now the Eric M. Taylor Center), the City’s jail for people serving misdemeanor sentences on Rikers Island.  After a lengthy trial, the court found that the pervasive violence violated the Cruel and Unusual Punishments Clause of the Eighth Amendment.  The lower court entered an injunction, affirmed on appeal.  In 2016, the parties agreed that the provisions of the Fisher judgment concerning use of force would be supplanted by the more stringent use of force relief in the Nunez litigation (see above).  Other provisions remain in effect.  (Veronica Vela, Dale Wilker)

These consolidated class actions challenge a broad range of inhumane conditions and practices in the entire New York City jail system, including overcrowding, fire risks, sanitation deficiencies and extreme temperatures.   They were resolved by comprehensive consent decrees, most of which became the basis for Department of Correction policy ever since.  Many of the decrees were terminated by the Prison Litigation Reform Act of 1996, which was upheld against PRP’s constitutional challenges.  An independent monitor, the Office of Compliance Consultants, was created, and PRP continues to enforce orders relating to sanitation, temperatures, lighting and fire safety in the jails.  (Robert Quackenbush, Veronica Vela, Mary Lynne Werlwas, Dale Wilker)

In this path-breaking complaint, PRP represents a transgender woman who was housed in male jails on Rikers Island following her shoplifting arrest, and sought placement instead in a women’s facility.   The complaint filed with the NYC Human Rights Commission alleges discrimination in her housing at Rikers Island in violation of the housing, public accommodation and disability protections in the NYC Human Rights Law. (Dori Lewis, Robert Quackenbush)

State court class-action was brought with co-counsel Kramer Levin on behalf of recipients of public assistance and food stamps who have been sanctioned based on inadequate notices alleging a failure to comply with employment-related requirements. Case settled and monitoring is ongoing. (Camille Zetner, Les Helfman)

Class action case was brought with co-counsel Milbank LLP concerning the rights of public assistance recipients with disabilities to access and maintain their benefits. Case settled and settlement was extended by 36 months by order dated July 9, 2019. Monitoring is ongoing. (Kathleen Kelleher, SusanWelber)
Amended Complaint, Settlement