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PLN v. CCA, VT, Ltr from def counsel re. surrendered VDOC docs, 03-28, 2014

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LY\N, LYNN
&_ BLACK N, RC.
March 28, 2014

Dan Barrett, Esq.
ACLU Foundation of Vermont
137 Elm Street
Montpelier, VT 05602
Re:	PLN v. CCA, Docket No. 332-5-13 Wncv
Dear Dan:
I am writing in response to your public records request to CCA for documents regarding
matters filed by Vermont inmates resulting in judgment or settlement. As we have previously
discussed, we excluded matters resulting in payment of less than $500. We also excluded
matters that resulted in "payment in kind" settlements (i.e., settling a property claim for a
broken TV with a replacement TV).
There have been no judgments against CCA in excess of $500. We have settled the following
cases on the terms indicated:

Baker v. CCA, 31-2-05 Ancv 	
$11,000
Complaint, CCA 1- 3
Settlement documents and related unprivileged correspondence, CCA 4 - 9
Cruz v. CCA, 35-2-05 Ancv 	
$10,000
Complaint, CCA 10 - 12
Settlement documents and related unprivileged correspondence, CCA 13 - 17
LeClaire v. Hofmann, 648-10-05 Wncv 	
Complaint, CCA 18 - 22
Settlement documents and related unprivileged correspondence, CCA 23 - 28

$650

Louko v. VDOC, 287-7-05 Wmcv 	
Settlement documents and related unprivileged correspondence, CCA 29 - 31

$850

Pratt v. Hofmann, 228-4-05 Wncv 	
$3,410
Amended Complaint, CCA 32 - 39
Settlement documents and related unprivileged correspondence, CCA 40 - 42

76 St. Paul Street a Suite 400 a Burlington, VT 05401 a 802,860.1500 	FAX 802.860.1580

Lynn, Lynn & Blackman, P.C.
Dan Barrett, Esq.
March 28, 2014
Page 2
Glover v. CCA, 460-6-08 Wrcv 	
$10,000
Settlement documents and related unprivileged correspondence, CCA 43 - 44

Stutes v. Tip, 1:07-cv-66 	
Complaint, CCA 45 - 73
Karov v. CCA, United States District Court for the Eastern District of Kentucky,
5:08-cv-00407-KKC 	
Ingerson v. CCA, 12-1-07 Wmcv 	
Unexecuted documents related to settlement, CCA 74 - 76

$4,000

$45,000
$12,500

Downey v. CCA, 	
$25,000
Complaint, CCA 77 - 79
Settlement documents and related unprivileged correspondence, CCA 80 - 84
Michael Myers, resolved prior to litigation 	
$3,000
Statement of Claim, CCA 85 - 90
Settlement documents and related unprivileged correspondence, CCA 91 - 97
On Louko, I am continuing to work on isolating the Complaint. Mr. Louko was pro se and
hand wrote all his pleadings, so the file is a bit of a morass. On Glover, the pleadings file was
inexplicably missing from our closed file. I will find another way to get my hands on the
Complaint. On Stutes, the case started in Vermont, but was transferred to Oklahoma, where
it was settled. I am working on drumming up the settlement documents.

Karov was handled entirely in Kentucky by CCA's Kentucky counsel. I will provide the
complaint and settlement documents from that case as soon as I receive them.
I handled and settled Ingerson while working from my home office in Michigan, and I'm afraid
I did not duplicate the file for the Burlington office as I typically do. I am enclosing
unexecuted versions of the General Release and my correspondence with Plaintiff's counsel,
which I just printed from my computer. I believe I have some materials here and will continue
to look for them. As Mr. Ingerson was represented by Tom Costello, I can (and will, if need be)
reach out to him, as well. The case was a medical negligence claim.
Finally, there are two cases filed under pseudonyms that we resolved in 2005. These are the
cases I mentioned that are subject to bilateral confidentiality. I have a request in to plaintiffs'
counsel (both were represented by the same lawyer) to waive that confidentiality. I expect to
have an answer from him by the time I return from vacation on April 7.

Lynn, Lynn & Blackman, P.C.
Dan Barrett, Esq.
March 28, 2014
Page 3

Thank you for bearing with me. Please do not hesitate to call if you have any questions.
Very Truly Yours,
LYN LYNN & BLACKMAN, P.C.

G. Mihalich

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