Plata Documents

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2010

• Order denying State's appeal to both dismiss Receivership and terminate Receiver's construction plan, 04/30/10

2009

• Appeals Court Dismisses State Motion to Stop Contempt Proceedings, 03/25/09
• Order Denying Motion to Replace Receiver, 03/24/09
• MDI Appeal - Brief of Appellee Californa Department of Corrections and Rehabilitation, 03/09/09
• Order Denying Receiver's Motion to Set Date for Evidentiary Hearing and for Leave to Take Limited Discovery, 03/04/09
• Taxpayer's for a Safe Ventura County's Opposition to Defendants J. Clark Kelso and CPHCS Motion to Dismiss Complaint, 03/02/09
• Declaration of David A. Brewster in Support of Plaintiff's Opposition to Motion to Dismiss, 03/02/09
• MDI Appeal - Brief of Appellee J. Clark Kelso, 02/23/09
• Receiver's Opposition to Defendants' Motion to Terminate the Receivership and the Receiver's Construction Plans, 02/23/09
• Declaration of Richard Kirkland in Support of Receiver's Opposition to Defendant's Motion, 02/23/09
• Declaration of Steven Cambra in Support of Receiver's Opposition to Defendant's Motion, 02/23/09
• Declaration of Jared Goldman in Support of Receiver's Opposition to Defendant's Motion, 02/23/09
• Declaration of Theresa Kimura-Yip in Support of Receiver's Opposition to Defendant's Motion, 02/23/09
• Declaration of Stuart C. Plunkett in Support of Receiver's Opposition to Defendant's Motion, 02/23/09
• Declaration of Terry Hill in Support of Receiver's Opposition to Defendant's Motion, 02/23/09
• Declaration of John Hagar in Support of Receiver's Opposition to Defendant's Motion, 02/23/09
• Receiver's Supplemental Application No. 8 for Order Waiving State Contracting Statutes, Regulations and Procedures, 01/09/09
• Declaration of Martin H. Dodd in Support of Receiver's Supplemental Application No. 8, 01/09/09
• Declaration of Terry Hill, M.D. in Support of Receiver's Supplemental Application No. 8, 01/09/09
• [Proposed] Order Granting Receiver's Supplemental Application No. 8 for Order Waiving State Contracting Statutes, Regulations and Procedures, 01/09/09
• Apellee's Brief, 01/07/09

2008

• Receiver's Answer to Petition for Writ of Mandamus, 12/08/08
• Receiver and State Personnel Board's Further Joint Status Report RE Physician Clinical Competency Determination Policies and Procedures, 11/21/08
• Declaration of Linda Buzzini in Support of Receiver and State Personnel Board's Further Joint Status Report RE Physician Clinical Competency Determination Policies and Procedures, 11/21/08
• Declaration of Suzanne M. Ambrose in Support of Receiver's Second Supplemental Report RE Physician Clinical Competency Determination Policies and Procedures, 11/21/08
• Response of Receiver J. Clark Kelso to defendant's response to OSC RE: Transition, Activation, and Managment of Receiver's 10,000 Bed Project Coordination Agreement, 11/17/08
• Order Granting In Part Application To Shorten Time On Defendants Motion To Stay, 11/03/08
• Second Order for Further Proceedings Re: Receiver's Motion for Contempt, 10/27/08
• Order for Further Proceedings Re: Receiver's Motion for Contempt, 10/08/08
• Association of Counsel, 10/06/08
• [Proposed] Order Denying Defendants' Administrative Motion to Remove Confidential Material Designation from Receiver's Facility Program Statement, Second Draft, 09/29/08
• Receiver's Opposition to Defendants' Administrative Motion to Lift Confidentiality Designation on the Receiver's Facility Program Statement, Second Draft, 09/29/08
• Reply Memorandum of Receiver J. Clark Kelso in Support of Motion for Order Adjudging Defendants in Contempt for Failure to Fund Receiver’s Remedial Projects and/or for an Order Compelling Defendants to Fund Such Projects, 09/22/08
• Supplemental Declaration of Receiver J. Clark Kelso in Support of Motion, 09/22/08
• Declaration of John Hagar in Support of Receiver's Motion, 09/22/08
• Declaration of Steve Cambra in Support of Receiver's Motion, 09/22/08
• Supplemental Declaration of Martin H. Dodd in Support of Receiver's Motion, 09/22/08
• Exhibit A to Supplemental Declaration of Martin H. Dodd, 09/22/08
• Exhibit B to Supplemental Declaration of Martin H. Dodd, 09/22/08
• Exhibit C to Supplemental Declaration of Martin H. Dodd, 09/22/08
• Exhibits D-1 to D-3 to Supplemental Declaration of Martin H. Dodd, 09/22/08
• Exhibits E-1 to F-3 to Supplemental Declaration of Martin H. Dodd, 09/22/08
• Exhibits F to H to Supplemental Declaration of Martin H. Dodd, 09/22/08
• Receiver and State Personnel Board's Joint Status Report RE Physician Clinical Competency Determination Policies and Procedures, 09/19/08
• Declaration of Linda Buzzini in Support of Receiver and State Personnel Board's Joint Status Report RE Physician Clinical Competency Determination Policies and Procedures, 9/19/08
• Declaration of Suzanne M. Ambrose in Support of Receiver's Supplemental Report RE Physician Clinical Competency Determination Policies and Procedures, 09/19/08
• Declaration of Paul Ramsey in Support of Receiver's Supplemental Report RE Physician Clinical Competency Determination Policies and Procedures, 09/19/08
• Clinical Competency Court Ordered Process, 09/04/08
• [Proposed] Order Granting Receiver's Supplemental App No. 7 For Order Waiving State Contracting Statutes, Regulations and Procedures and Authorizing Receiver to Enter into Contract for Quality Measurement Technical Assistance, 09/02/08
• Declaration of Terry Hill, M.D. in Support of Receiver's Supplemental App No. 7 for Order Waiving State Contracting Statutes, Regulations and Procedures and Authorizing Receiver to Enter into Contract for Quality Mearuement Technical Assistance, 09/02/08
• Exhibit 1 to Declaration of Terry Hill, M.D., 09/02/08
• Exhibit 2 to Declaration of Terry Hill, M.D., 09/02/08
• Exhibit 3 to Declaration of Terry Hill, M.D., 09/02/08
• Receiver's Supplemental App No. 7 for Order Waiving State Contracting Statutes, Regulations and Procedures and Authorizing Receiver to Enter into Contract for Quality Measurement Technical Assistance, 09/02/08
• Notice and Motion of Receiver J. Clark Kelso for Order Adjudging Defendants in Contempt for Failure to Fund Receivers Remedial Projects and/or for an Order Compelling Defendants to Fund Such Projects, 08/13/08
• Declaration of Receiver J. Clark Kelso in Support of Receiver's Motion for Order Adjudging Defendants in Contempt for Failure to Fund Receiver's Remedial Projects and/or for an Order Compelling Defendants to Fund Such Projects, 08/13/08
• Declaration of William Proctor in Support of Motion of Receiver J. Clark Kelso for Order Adjudging Defendants in Contempt for Failure to Fund Receiver's Remedial Projects and/or for an Order Compelling Defendants to Fund Such Projects, 08/13/08
• Declaration of Martin H. Dodd in Support of Motion of Receiver J. Clark Kelso for Order Adjudging Defendants in Contempt for Failure to Fund Receiver's Remedial Projects and/or for an Order Compelling Defendants to Fund Such Projects, 08/13/08
• Exhibits 1 to 3 to Declaration of Martin H. Dodd, 08/13/08
• Exhibit 4 to Declaration of Martin H. Dodd, 08/13/08
• [Proposed] Order Granting Motion of Receiver J. Clark Kelso for Order Adjudging Defendants in Contempt for Failure to Fund Receiver's Remedial Projects and/or for an Order Compelling Defendants to Fund Such Projects, 08/13/08
• Receiver's Statement Regarding Discovery Dispute, 07/09/08
• Declaration of Martin H. Dodd in Support of Receiver's Statement Regarding Discovery Dispute, 07/09/08
• Reply Memorandum of Receiver J. Clark Kelso in Support of Motion to Add State Controller as Party-Defendant and for Discovery in Aid of Enforcement of Order Appointing Receiver, 07/08/08
• Receiver's Reply in Support of Supplemental Application No.5 for Order Waiving State Contracting Statutes, Regulations and Procedures, Approving Receiver's Substitute Procedure for Bidding and Award of Contracts, 06/30/08
• Receiver's Application for Leave to File Response to SPB's Objections to Physician Clinical Competency Policies and Procedures, 06/27/08
• Receiver's Report Re: Physician Clinical Competency Determination Policies and Procedures, 06/20/08
• Declaration of Linda Buzzini in Support of Receiver's Report Re: Physician Clinical Competency Determination Policies and Procedures, 06/20/08
• [Proposed] Order Re: Waiver of State Law Re: Physician Clinical Competency Determination, 06/20/08
• Notice and Motion of Receiver J. Clark Kelso to add State Controller as Party-Defendant, 06/19/08
• Declaration of Receiver J. Clark Kelso in Support of Motion to add State Controller as Party-Defendant, 06/19/08
• Exhibits 1-10 to Declaration in Support of Receiver's Motion to add State Controller as Party-Defendant, 06/19/08
• Exhibits 11-20 to Declaration in Support of Receiver's Motion to add State Controller as Party-Defendant, 06/19/08
• Proposed Order granting motion of Receiver J. Clark Kelso to add State Controller as Party-Defendant, 06/19/08
• Order Re: Asthma Initiative Waiver, 01/25/08
• Order Appointing New Receiver, 01/23/08
• State Personnel Board opposition to Receiver's supplemental memo on physician clinical competency, 01/22/08
• Plaintiffs supplemental opposition to Receiver's waiver Re: physician clinical competency, 01/22/08
• Order Re: Physician Clinical Competency Motion, 01/11/08
• Defendant's supplemental statement Re: Receiver's response Re: Construction coordination agreement, 01/08/08
• Receiver's Report and Supplemental Memo Re: Physician Clinical Competency, 01/07/08
• Proposed Order Re: Physician Clinical Competency, 01/07/08
• Alternate Proposed Order Re: Physician Clinical Competency, 01/07/08
• Declaration of Linda Buzzini Re: Physician Clinical Competency, 01/07/08
• Notice of stipulation between Receiver and DPA Re: LVN Salary Administration, 01/04/08

2007

• Receiver's Reply Memo Re: Asthma Waiver, 12/21/07
• Declaraction of Terry Hill Re: Asthma Waiver, 12/21/07
• Declaraction of John Hagar Re: Asthma Waiver, 12/21/07
• Receiver's 90-day RCEA Report, 12/21/07
• Order Approving Avenal Waiver, 12/20/07
• Receiver's Response Re: Construction Coordination Agreement, 12/17/07
• Plaintiffs' Non-Opposition Re: Avenal Waiver, 12/14/07
• Plaintiffs' Opposition to Asthma Iinitiative, 12/14/07
• Receiver's Supplemental Contracting Waiver Application Re: Avenal State Prison, 11/27/07
• Declaration of Joe McGrath Re: Avenal State Prison Waiver, 11/27/07
• Proposed Order Re: Avenal State Prison Waiver, 11/27/07
• Receiver's Waiver Application Re: Asthma Initiative, 11/20/07
• Proposed Order Re: Asthma Initiative, 11/20/07
• Declaration of Terry Hill in support of Asthma Initiative Waiver, 11/20/07
• Plata, Coleman, Perez, Armstrong Coordinating Order, 11/13/07
• Order Approving Agreement between Receiver and State Personnel Board, 09/11/07
• Order Re: Plan of Action and Modification of Injunction, 09/06/07
• Joint Report and Stipulation between Receiver and State Personnel Board, 08/20/07
• Order Re: Receiver's supplemental contract waiver application, 08/13/07
• Receiver's reply in support of motion for order modifying stipulated injunction, 07/31/07
• Declaration of John Hagar in support of Receiver's Reply, 07/31/07
• Plata order denying defendant's motion for stay of three judge panel, 07/31/07.pdf
• Joint Order Re: Three judge court, 07/31/07
• Receiver's Reply Re: Plaintiff's Response to Plan of Action, 07/30/07
• Declaration of Betsy Chang Ha Re: Receiver's Reply, 07/30/07
• Declaration of Terry Hill in Support of Receiver's Reply, 07/30/07
• Order Re: Appointment of 3-judge panel, 07/26/07
• Receiver's opposition to plaintiff motion Re: Compliance, 07/23/07
• Declaration of John Hagar in support of Receiver's opposition, 07/23/07
• Order Re: Three-judge panel on overcrowding, 07/23/07
• Receiver's Reply Re: Supplemental application for contracting order, 07/17/07
• Declaration of John Hagar Re: Receiver's reply on Contracting, 07/17/07
• Receiver's April 2007 Waiver Requests Fact Sheet, April 2007 (updated 10/08/07)
• Order Re: Receiver's Career Executive Assignment positions, 07/03/07
• Order approving coordination agreements in Plata Perez and Coleman, 06/28/07
• Receiver's Supplemental Contracting Waiver Application, 06/27/07
• Receiver's Reply Memorandum Re: Physician Clinical Competency, 06/15/07
• Order Re: Joint Hearing on Three-Judge Panel, 06/06/07
• Order Re: Master Waiver, 06/04/07
• Receiver's Reply to responses of plaintiffs and state personnel board to motion for waiver of State law Re: Receiver career executive assignments, 05/25/07
• Declaration of John Hagar in Support of Receiver's motion for Waiver of State law Re: Receiver career executive assignments, 05/25/07
• Receiver's Reply to response of state personnel board to Master application for order waiving state contracting statues, regulations and procedures, etc., 05/25/07
• Supplemental Declaration of John Hagar in support of Receiver's Master Application for order waiving state contracting statues, regulations and procedures, etc., 05/25/07
• Order Re: SPB Motion, 05/08/07
• Receiver's Opposition to SPB request for additional time to respond to Master Application, 05/07/07
• Order Setting Schedule Re: Motion For Waiver of State Law Re Physician Clinical Competency, 05/01/07
• Order Granting Receiver's Motion For One Time Limited Waiver of CA Gov Code Sec 19080.3, 04/25/07
• Order Setting Schedule Re: Master Application, 04/25/07
• Receiver's Motion For Waiver of State Law Re: Physician Clinical Competency Determinations; Exhibits, 04/25/07
• Order Setting Schedule Re: CEA Motion, 04/19/07
• Receiver's Notice of Filing Amended Motion for Waiver of State Law Re: Receiver Career Executive Assignment Positions, 04/18/07
• Receiver's Master Application for Order Waiving State Contracting Statutes, 04/17/07
• Hagar Declaration, 04/17/07
• Exhibits to Hagar Declaration, 04/17/07
• Proposed Order Granting Receiver's Master Application, 04/17/07
• Proof of Service, Contracting Waiver, 04/17/07
• Order Denying MDI Motion to Shorten time, 04/16/07
• Plaintiff's Statement of Non-Opposition to the Receiver's Motion For One-Time Limited Waiver of Gov Code Section 19080.3, 04/12/07
• Order Re: Pharm Tech Motion, 04/11/07
• Notice of Filing of Exhibit in Support of Waiver of Gov Code Section 19080.3, 04/10/07
• Receiver's Motion For One Time Limited Waiver of CA Gov Code Sec 19080.3, 04/06/07
• Response to MDI Motion: Receiver's Opposition to Motion, 04/06/07
• Response to MDI Motion: Hagar Declaration, 04/06/07
• Response to MDI Motion: Dodd Declaration, 04/06/07
• Response to MDI Motion: Certificate of Service, 04/06/07
• Order RE: Receiver's Application for Order Nunc Pro Tunc, 03/30/07
• Plata Order RE: Three Judge Panel, 02/15/07
• Order Coleman, Plata, Perez, 01/26/07
• Order RE:Public Health Services Bureau Notice of Motion, 01/25/07
• Judge Henderson letter to PHSB, 01/25/07

2006

• Receiver's Memorandum of Points and Authorities RE:Public Health Services Bureau Notice of Motion, 12/29/06
• Plata Order RE: Receiver's Motion for an Extension, 12/19/06
• Plaintiff's Response to Receiver's Motion for an Extension, 11/30/06
• Receiver's Motion for an Extension, 11/13/06
• Supplemental Order RE: State Contracts, 11/08/06
• Request for Clarification or Order RE: State Contracts, 10/26/06
• Order RE: Receiver's Motion for a Waiver of State Law, 10/17/06
• Plaintiff's Response to Receiver's Motion for a Waiver of State Law, 09/26/06
• Defendant's Response to Receiver's Motion for a Waiver of State Law, 09/26/06
• Appendix of Exhibits supporting Receiver's Motion for Waiver of State Law, 09/12/06
• Receiver's Motion for a Waiver of State Law, 09/12/06
• Plata Order RE: Joint Hearing, 05/10/06
• Plata Order RE: State Contracts and Contract Payments Relating to Service Providers for CDCR Inmate/Patients, 03/30/06
• Plata Order Appointing Receiver, 02/14/06

2005

• Plata Findings of Fact and Conclusions of Law RE: Appointment of Receiver, 10/03/05