Between a Stonegarden & a Hard Place

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[PCSD Deputy Ryan Roher]
  • Defendant’s Reply To Plaintiff’s Response to Defendant’s Partial Motion To Dismiss16 August 2019
  • Plaintiff’s Response To Defendant’s Partial Motion To Dismiss – 02 August 2019
  • Defendant’s Answer – 05 July 2019:
    Pima County’s response  to plaintiff’s Second Amended Complaint. Here’s a document that combines the Second Amended Complaint with the County’s response. The County’s response appears in red.
  • Court Order – 01 July 2019:
    Court order denying Pima County’s Motion for a time extension to file an answer to plaintiff’s Second Amended Complaint.
  • Defendant’s Partial Motion To Dismiss – 25 June 2019:
    Pima County’s motion to dismiss the retaliatory arrest and unlawful seizure claims along with several of the official and individual capacity failure to supervise/train claims and unlawful policy and practices claim
  • Plaintiff’s Second Amended Complaint – 11 June 2019:
    An amended complaint that adds the DHS, USCBP, USBP, DHS Secretary Kirstjen Nielsen, USCBP Commissioner Kevin McAleenan, USBP Chief Carla Provost & Tucson Sector Chief Patrol Agent Rodolfo Karisch as defendants  to the lawsuit for purposes of declaratory and injunctive relief and brings a claim of false imprisonment against the United States of America.
  • Court order authorizing the filing of the 2nd Amended Complaint – 05 June 2019:
    After several months of failed settlement negotiations with the Pima County defendants,  the Tucson District Court grants permission to file the 2nd Amended complaint that adds several federal defendants to the lawsuit.
  • Defendants’ Response To Plaintiff’s Motion To File 2nd Amended Complaint14 January 2019:
    Defendants response indicating they have no objections to the filing of an amended complaint
  • Motion For Leave To Amend Complaint31 December 2018:
    A request to file an amended complaint that adds federal defendants to the lawsuit. Exhibit A contains the proposed changes to the current complaint.
  • Joint Case Management Report Court Order19 November 2018:
    The court order setting out the initial schedule and discovery timeline for the lawsuit.
  • Settlement Conference Court Order19 November 2018:
    A court order referring the lawsuit for a settlement conference in late January 2019.
  • Joint Case Management Plan – 06 November 2018:
    A case management plan filed with the court by both parties that lays out the outstanding legal issues in the case from the perspective of both sides and a rough timeline for motions, discovery and trial.
  • Defendant’s Initial Disclosure Statement28 September 2018:
    The defendant’s mandatory initial disclosure statement indicating the legal basis for their defense, along with known witnesses and material documents
  • CBP Denial of Federal Tort Claim24 September 2018:
    As expected, USCBP formally denies the federal tort claim filed against them six months ago. This opens the  door to file a lawsuit against the federal agency.
  • Plaintiff’s Initial Disclosure Statement10 September 2018:
    The plaintiff’s mandatory initial disclosure statement indicating the legal basis for their defense, along with known witnesses and material documents
  • Answer to Amended Complaint – 31 August 2018:
    The defendant’s response to the amended complaint.
  • Affidavit of Service10 July 2018:
    Amended affidavit of service to the Pima County Board of Supervisors by a licensed process server. Very similar documents were served on the remaining defendants.
  • Summons03 July 2018:
    Amended summons served on the Pima County Board of Supervisors by a licensed process server. Similar documents were served on the remaining defendants.
  • First Amended Complaint02 July 2018:
    A fine tuning of the factual allegations, the cause of action and a dropping of the Bivens Claim against the federal agents in their individual capacity
  • Lawsuit Complaint09 April 2018:
    With legal assistance, Checkpoint USA has filed a lawsuit against various government agencies and employees in Pima County, Arizona and U.S. Customs and Border Protection for violations of his rights associated with Operation Stonegarden and the federal roadblock that’s been operating along SR-86 in Southern Arizona near milepost 145 for over ten years.
  • Federal Tort Claim22 March 2018:
    Before filing a lawsuit against the United States government for a federal tort, claimants are required by the Federal Tort Claim Act to first give notice of the incidents giving rise to the federal tort  to the offending agency. As can be seen in the federal tort claim that Checkpoint USA recently filed with the Tucson Sector Headquarters of U.S. Customs & Border Protection, Checkpoint USA has quite a few incidents to discuss that give rise to this particular federal tort.
  • Notice of Claim24 September 2017:
    AZ law requires individuals to give government agencies/agents a 60 day heads up regarding any legal claims they have against them before being allowed to file a lawsuit. This is CPUSA’s legally mandated  Notice of Claim regarding his unlawful detention and arrest by PCSD Deputy Ryan Roher at a USCBP roadblock on April 10, 2017 along with similar incidents dating back several years.
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