Mou v. City of San Jose et al

Filing 2277

Mou v. City of San Jose et al

Doc. 2277

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Geri Lynn Green (SBN 127709) LAW OFFICES OF GERI LYNN GREEN 5214-F Diamond Hts. Blvd., #332 San Francisco, CA 94131-2118 T: [phone] F: [phone] Attorneys for Plaintiffs SHANELL RENEE STEWART, MARY PAYNE, HERLINDA ARROYO-DE HERNANDEZ and CAROL BIRDSONG

IN THE UNITED STATES DISTRICT COURT IN AND FOR THE NORTHERN DISTRICT OF CALIFORNIA

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DECL. OF GREEN IN SUPPORT OF PLAINTIFFS' OPP. TO MO. FOR SUM. JUDG., Case No.: C-01-4058 MJJ (JCS)

SHANELL RENEE STEWART, MARY PAYNE, HERLINDA ARROYO-DE HERNANDEZ and CAROL BIRDSONG,

) ) ) ) ) Plaintiffs, ) v. ) KATHLEEN HAWK SAWYER, ROBERT M. ) ) HARO, MICHAEL BENOV, PAUL SCHULT Z, JOHNSIE DONALDSON, SHEILA) CLARK, FEDERAL BUREAU OF PRISONS, ) ) and Does 1-100, inclusive. ) ) Defendants. ) ) I, Geri Lynn Green, declare:

Case No.: C 01-4058 MJJ (JCS) E-FILING CASE DECLARATION OF GERI LYNN GREEN IN SUPPORT OF PLAINTIFFS' OPPOSITION TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT

I am an attorney licensed to practice in all the courts of this state. I represent Plaintiffs Shanell Renee Stewart, Mary Payne, Herlinda Arroyo-De Hernandez and Carol Birdsong in this action. I have personal knowledge of the matters set forth herein and could competently testify to them if called as a witness.

Dockets.Justia.com

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Attached hereto as Exhibit A is a true and correct copy of materials from the Bureau of Prisons section PS 1330.13, entitled Administrative Remedy Program, Change Notice Number CN-03, dated 10/7/97, signed by Director, Kathleen M.

4 5 6 7 8 9 10 submitted as Exhibit 7 to the deposition of Warden Paul Schultz, taken on May 11 12 13 14 15 16 17 18 19 20 21 22 23 6. 24 25 26 27 28
DECL. OF GREEN IN SUPPORT OF PLAINTIFFS' OPP. TO MO. FOR SUM. JUDG., Case No.: C-01-4058 MJJ (JCS)

Hawk; 2. Attached hereto as Exhibit B is a true and correct copy of the Federal Bureau of Prisons' Program Statement, Number 5324.04, dated 12/31/97, entitled Sexual Abuse/Assault Prevention and Intervention Programs, signed by Director, Kathleen M. Hawk, Bates stamped USA03893-03892. Said exhibit was

26, 2004; 3. Attached hereto as Exhibit C is a true and correct copy of the Federal Bureau of Prisons FCI/FPC/FDC Dublin, California, document, entitled, Pat Search Evaluation, dated 4/23/01, re: Plaintiff Carol Ann Birdsong, Bates stamped USA02139-02141. Said exhibit was submitted as an exhibit to Dr. Formanski, taken on May 26, 2004; 4. Attached hereto as Exhibit D is a true and correct copy of excerpts from the deposition of Linda R. Thomas, taken on September 8, 2004; 5. Attached hereto as Exhibit E is a true and correct copy of excerpts from the deposition of Warden Paul Schultz, taken on May 26, 2004; Attached hereto as Exhibit F is a true and correct copy of the Federal Correctional Institution, Dublin, California, entitled Institution Supplement, Number DUB 5324.04(C), dated June 15, 2004, subject: Sexual Abuse/Assault Prevention and Intervention Programs, signed by Warden, Paul M. Schultz, Bates stamped

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USA03912-03915. Said exhibit was submitted as Exhibit 8 to the deposition of Warden Paul Schultz, taken on May 26, 2004; Attached hereto as Exhibit G is a true and correct copy of the Federal Bureau of Prisonsf' materials from the Introductory Correctional Training Program Manual; entitled, Search Procedures; Conducting a Pat Search and Visual Search, Bates stamped USA00020-00029. Said exhibit was submitted as Exhibit 5 to the deposition of Warden Paul Schultz, taken on May 26, 2004; Attached hereto as Exhibit H is a true and correct copy of the Federal Bureau of Prisons' Sexual Abuse/Assault Prevention and Intervention training manual, Bates

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DECL. OF GREEN IN SUPPORT OF PLAINTIFFS' OPP. TO MO. FOR SUM. JUDG., Case No.: C-01-4058 MJJ (JCS)

Stamped USA00001-00019. Said exhibit was submitted as Exhibit 9 to the deposition of Warden Paul Schultz, taken on May 26, 2004; I declare under the penalty of perjury under the laws of the State of California that the foregoing is true and correct. DATED this 12th day of October 2004 Respectfully submitted, LAW OFFICES OF GERI LYNN GREEN

-SGeri Lynn Green (SBN 127709) 5214-F Diamond Hts. Blvd., #332 San Francisco, CA 94131-2118 Attorney for Plaintiffs Shanell Renee Stewart, Mary Payne, Herlinda Arroyo-De Hernandez, Carol Birdsong

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