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Civil Rights: Other | Georgia Southern
Response in Opposition to Motion
RESPONSE in Opposition re 95 MOTION for Summary Judgment filed by Amanda M. Oliveira. (Attachments: # 1 Stmt of Material Fact Plaintiff's Response to Undisputed Material Facts, # 2 Exhibit Ex. 01 - Policy 3.01 Receiving Intake Reports, # 3 Exhibit Ex. 02 - Policy 3.02 Making an Intake Decision, # 4 Exhibit Ex. 03 - Policy 3.18 - 3.18 Second Level Screen-Out Review and Approval Process, # 5 Exhibit Ex.. 04 - Notarized Affidavit - Michele Freeney-Washington Feb 2026, # 6 Exhibit Ex. 05 - 2012 Indictment Uncle Tony, Bond Order, Incident Report, # 7 Exhibit Ex. 06 - safety plan 2012, # 8 Exhibit Ex. 07 - Affidavit of Sara Hallowell - signed and notarized 05.19.2026, # 9 Exhibit Ex. 08 - MF Letters of Administration, # 10 Exhibit Ex. 09 - Elwyn Crocker Sr negotiated plea deal, # 11 Exhibit Ex. 10 - Notarized Affidavit - Michele Freeney-Washington Feb 2026, # 12 Exhibit Ex. 11 - Mark Wright Effingham_Superior_SUCR2019000436_Miscellaneous - Mark Wright Guilty Plea Transcript (reduced), # 13 Exhibit Ex. 12 - Roy Prater Effingham_Superior_SUCR2019000436_Plea hearing transcript (reduced), # 14 Exhibit Ex. 13- Candice Crocker - Transcript - Guilty Plea 10-21-2020, # 15 Exhibit Ex. 14 - Kim Wright Effingham_Superior_SUCR2019000435_Miscellaneous - Guilty Plea Transcript (reduced))(Pinckney, Kathryn)
RESPONSE in Opposition re 82 MOTION for Summary Judgment filed by Amanda M. Oliveira. (Attachments: # 1 Stmt of Material Fact Plaintiff's Response to Undisputed Material Facts, # 2 Exhibit Ex. 01 - depo - Edwards (02-4-25) (with exhibits), # 3 Exhibit Ex. 02 - depo - Hills (01-28-25) (no exhibits), # 4 Exhibit Ex. 03 - depo - Price (02-12-25) (with exhibits), # 5 Exhibit Ex. 04 - depo - Rawlings (02-17-25) (no exhibit), # 6 Exhibit Ex. 05 - depo - Snipes (01-28-25) (no exhibits), # 7 Exhibit Ex. 06 - safety plan - 03-04-12, # 8 Exhibit Ex. 07 - safety plan - 03-06-12, # 9 Exhibit Ex. 08 - family plan - 3-30-12, # 10 Exhibit Ex. 09 - Court Order, # 11 Exhibit Ex. 10 - 9-17-12 indictment, # 12 Exhibit Ex. 11 - parents say spanking is ok, # 13 Exhibit Ex.12 - jr reports spank- parents say spanking is ok, # 14 Exhibit Ex. 13 - missing home visits, # 15 Exhibit Ex. 14 - Georgia Impending Danger Safety Threat Assessment (from aldridge), # 16 Exhibit Ex. 15 - Georgia Safety Threats bizarre veiw of child), # 17 Exhibit Ex. 16 - 2010 Lexington Co Sheriff's Report Lewd Act with Child (redacted), # 18 Exhibit Ex. 17 - get records from sc, # 19 Exhibit Ex. 18 - 2012 DFCS Policy Manual - CPS - 90 day Case Reassessment, # 20 Exhibit Ex. 19 - 2012 Indictment Uncle Tony, Bond Order, Incident Report (Exhibit D to Jr.'s Complaint), # 21 Exhibit Ex. 20 - Abby Brown Testimony_bond-preliminary hearing transcript 3.5.2019 (ocr), # 22 Exhibit Ex. 21 - jr starving, # 2... (truncated)
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