Free Supplement/Amendment - District Court of Colorado - Colorado

Case 1:02-cv-00651-RPM

Document 112

Filed 07/26/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 02-cv-0651-RPM-MJW MARK SHOOK and DENNIS JONES, on behalf of themselves and all others similarly situated, Plaintiffs, and JAMES VAUGHAN, SHIRLEN MOSBY, THOMAS REINIG, LOTTIE ELLIOTT, and VICTOR SIEGRIST, Intervenor-Plaintiffs, v. THE BOARD OF COUNTY COMMISSIONERS OF THE COUNTY OF EL PASO and TERRY MAKETA, in his official capacity as Sheriff of El Paso County, Defendants. SUPPLEMENT TO PLAINTIFFS' RESPONSE TO DEFENDANTS' MOTION TO DISMISS

On June 30, 2006, plaintiffs and intervenor-plaintiffs filed their Notice of Mootness of Individual Claims for Injunctive and Declaratory Relief, advising the Court that none of the party plaintiffs was incarcerated at the time in the El Paso County Jail. However, on July 25, 2006, after Plaintiffs' Response to Defendants' Motion to Dismiss was filed, counsel for plaintiffs and

Case 1:02-cv-00651-RPM

Document 112

Filed 07/26/2006

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intervenor-plaintiffs learned that on or about July 20, 2006 plaintiff-intervenor Victor Siegriest once again became an inmate in the Jail. Respectfully submitted July 26, 2006. David C. Fathi Senior Staff Counsel The National Prison Project of the ACLU Foundation, Inc. 915 15th Street NW, 7th Floor Washington, D.C. 20005 Telephone: (202) 548-6609 E-mail: [email protected] Mark Silverstein Legal Director American Civil Liberties Union of Colorado 400 Corona Street Denver, Colorado 80218 Telephone: (303) 777-5482 E-mail: [email protected]

s/ Thomas S. Nichols Thomas S. Nichols DAVIS GRAHAM & STUBBS LLP In cooperation with the American Civil Liberties Union Foundation of Colorado 1550 Seventeenth Street, Suite 500 Denver, Colorado 80202 DC BOX 03 Telephone: (303) 892-9400 FAX: (303) 893-1379 E-mail: [email protected] Attorneys for Plaintiffs and Intervenor-Plaintiffs

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Case 1:02-cv-00651-RPM

Document 112

Filed 07/26/2006

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CERTIFICATE OF SERVICE I hereby certify that on this 26th day of July, 2006, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Gordon L. Vaughan [email protected] Jay Allen Lauer [email protected] David C. Fathi [email protected] Mark Silverstein [email protected]

s/ Thomas S. Nichols Thomas S. Nichols Attorneys for Plaintiffs and Intervenor-Plaintiffs DAVIS GRAHAM & STUBBS LLP In cooperation with the American Civil Liberties Union Foundation of Colorado 1550 Seventeenth Street, Suite 500 Denver, Colorado 80202 DC BOX 03 Telephone: (303) 892-9400 FAX: (303) 893-1379 E-mail: [email protected]