throbber
Plaintiff,
`
`Defendants.
`
`No. 2:19-cv-00322-JRS-MG
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`v.
`
`
`
`
`RICHARD BROWN,
`JERRY SNYDER,
`RANDY PURCELL,
`DAVIS,
`ANDREA STROUP,
`
`
`
`
`Case 2:19-cv-00322-JRS-MG Document 64 Filed 09/03/21 Page 1 of 13 PageID #: 388
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF INDIANA
`TERRE HAUTE DIVISION
`
`
`TIMOTHY WAYNE ROBERTSON,
`
`
`ORDER GRANTING IN PART AND DENYING IN PART
`MOTION FOR SUMMARY JUDGMENT
` 
`Plaintiff Timothy Wayne Robertson, an Indiana inmate, brought this action under 42
`
`U.S.C. § 1983 alleging that the defendants held him in segregation in violation of his Eighth and
`
`Fourteenth Amendment rights and that defendant Brown was deliberately indifferent to his hand
`
`injury in violation of his Eighth Amendment rights. The defendants have moved for summary
`
`judgment. Dkt. 54. For the reasons discussed in this Order, the defendants' motion for summary
`
`judgment, dkt. [54], is denied as to Robertson's Fourteenth Amendment claims against defendants
`
`Snyder, Purcell, and Stroup and granted as to all other claims.
`
`I.
`Summary Judgment Standard
`
`Summary judgment shall be granted "if the movant shows that there is no genuine dispute
`
`as to any material fact and the movant is entitled to judgment as a matter of law." Fed. R. Civ. P.
`
`56(a). A "material fact" is one that "might affect the outcome of the suit." Anderson v. Liberty
`
`Lobby, Inc., 477 U.S. 242, 248 (1986). The moving party must inform the court "of the basis for
`
`

`

`Case 2:19-cv-00322-JRS-MG Document 64 Filed 09/03/21 Page 2 of 13 PageID #: 389
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`its motion" and specify evidence demonstrating "the absence of a genuine issue of material
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`fact." Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). Once the moving party meets this
`
`burden, the nonmoving party must "go beyond the pleadings" and identify "specific facts showing
`
`that there is a genuine issue for trial." Id. at 324.
`
`In ruling on a motion for summary judgment, the Court views the evidence "in the light
`
`most favorable to the non-moving party and draw[s] all reasonable inferences in that party's
`
`favor." Zerante v. DeLuca, 555 F.3d 582, 584 (7th Cir. 2009) (citation omitted). It cannot weigh
`
`evidence or make credibility determinations on summary judgment because those tasks are left to
`
`the fact-finder. See O'Leary v. Accretive Health, Inc., 657 F.3d 625, 630 (7th Cir. 2011). The Court
`
`need only consider the cited materials, Fed. R. Civ. P. 56(c)(3), and the Seventh Circuit
`
`has repeatedly assured the district courts that they are not required to "scour every inch of the
`
`record" for evidence that is potentially relevant to the summary judgment motion before
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`them. Grant v. Trustees of Ind. Univ., 870 F.3d 562, 573-74 (7th Cir. 2017).
`
`A dispute about a material fact is genuine only "if the evidence is such that a reasonable
`
`jury could return a verdict for the nonmoving party." Anderson, 477 U.S. at 248. If no reasonable
`
`jury could find for the non-moving party, then there is no "genuine" dispute. Scott v. Harris, 550
`
`U.S. 372, 380 (2007).
`
`II.
`Facts and Background
`
`At the times relevant to the complaint, Robertson was housed at Wabash Valley
`
`Correctional Facility (WVCF). Richard Brown was the Warden of WVCF. Jerry Snyder was Unit
`
`Team Manager. Randy Purcell was a Case Manager. Travis Davis worked in Internal Affairs. And
`
`Andrea Stroup was Classification Supervisor. Dkt. 17.
`
`
`
`2
`
`

`

`Case 2:19-cv-00322-JRS-MG Document 64 Filed 09/03/21 Page 3 of 13 PageID #: 390
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`In late February 2018, prison officials suspected that Robertson was passing drugs to
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`another inmate. Robertson tested negative for drug usage, but the inmate he was suspected of
`
`supplying with drugs tested positive for meth. Dkt. 54-3.
`
`On March 8, 2018, Robertson was involved in an altercation with another inmate and his
`
`hand was injured. Robertson Deposition, dkt. 54-1 at 48-49. Robertson was moved to
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`administrative segregation on March 14, 2018. Dkt. 17 at 2. Defendant Travis Davis, an internal
`
`investigator, told Robertson he was being placed in administrative restrictive status housing for his
`
`own safety after the altercation and because Davis suspected Robertson was involved in "some
`
`sort of scheme." Dkt. 54-2. Davis also asked Robertson if he wanted to stay in segregation until he
`
`"talked." Dkt. 54-1 at 16. The record confirms that Davis hoped that the placement would motivate
`
`Robertson to confess to drug trafficking. Dkt. 54-2. Through Robertson's time in segregation,
`
`defendants Purcell, Snyder, and Stroup signed off on his classification review and appeal forms.
`
`Dkt. 54-1 at 34-41; dkt. 1-1; dkt. 60-1 at 15-19.
`
`
`
`On May 14, 2018, Robertson submitted a formal grievance complaining that his hand still
`
`hurt from the injury he received on March 8, 2018, and that he had not been sent to a hand specialist.
`
`Dkt. 54-1 at 29-30. In response, a medical provider examined him on May 14, 2018. Id. at 50; dkt. 54-
`
`4. Robertson filed a grievance appeal on May 28, 2018, and defendant Warden Brown responded on
`
`June 1, 2018. Brown stated that he had reviewed the grievance appeal and related documents and that
`
`Robertson could file a healthcare request form if he was still experiencing hand pain. Dkt. 54-4 at 2;
`
`dkt. 54-1 at 30-31. Robertson believes he was then given the form that he needed and that he submitted
`
`it and was subsequently seen by medical staff. Dkt. 54-1 at 33-34.
`
`On January 7, 2019, Robertson wrote an informal grievance to Warden Brown complaining
`
`that he had been denied an appointment with an outside hand specialist because he was in restricted
`
`
`
`3
`
`

`

`Case 2:19-cv-00322-JRS-MG Document 64 Filed 09/03/21 Page 4 of 13 PageID #: 391
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`housing. In response, Brown informed Robertson that no medical provider had referred Robertson
`
`to an outside hand specialist and that Robertson could submit a healthcare request if he was still
`
`experiencing issues with his hand. Dkt. 17-1.
`
`Robertson was transferred out of administrative segregation on February 5, 2019. Dkt. 17
`
`at 2. During his time in administrative segregation, he received 30-day reviews and could file
`
`classification appeals. Dkt. 54-1 at 20-23. But the 30-day reviews appear to be identical print outs
`
`of the same boilerplate language denying a change in placement every month. Id. at 21-22.
`
`While in segregation, Robertson had access to showers, but the water was cold. His food
`
`was also served cold on most occasions. Id. at 73-74. He was not allowed to attend group religious
`
`services and could not attend law library. Id. at 43-44.
`
`
`A. Fourteenth Amendment Due Process Claim
`
`III.
`Analysis
`
`"The Supreme Court held in Hewitt [v. Helms, 459 U.S. 460 (1983)] that the Due Process
`
`Clause mandates that prison officials periodically review whether an inmate placed in
`
`administrative segregation continues to pose a threat." Isby v. Brown, 856 F.3d 508, 524 (7th Cir.
`
`2017). "[A] meaningful review ... is one that evaluates the prisoner's current circumstances and
`
`future prospects, and, considering the reason(s) for his confinement to the program, determines
`
`whether that placement remains warranted." Id. at 527 (internal quotation omitted).
`
`1. Personal Involvement
`
`The defendants first argue that § 1983 liability requires personal involvement in the alleged
`
`constitutional violation. Dkt. 5 at 5-6. "For constitutional violations under § 1983 or Bivens, a
`
`government official is only liable for his or her own misconduct." Locke v. Haessig, 788 F.3d 662,
`
`669 (7th Cir. 2015) (citation and quotation marks omitted). Thus "[a] damages suit under § 1983
`
`
`
`4
`
`

`

`Case 2:19-cv-00322-JRS-MG Document 64 Filed 09/03/21 Page 5 of 13 PageID #: 392
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`requires that a defendant be personally involved in the alleged constitutional deprivation." Matz
`
`v. Klotka, 769 F.3d 517, 528 (7th Cir. 2014); see Minix v. Canarecci, 597 F.3d 824, 833 (7th Cir.
`
`2010) ("[I]ndividual liability under § 1983 requires 'personal involvement in the alleged
`
`constitutional deprivation.'“) (citation and quotation marks omitted).
`
`The record reveals that defendants Purcell, Snyder, and Stroup were personally involved
`
`in either preparing reviews of Robertson's placement, reviewing his classification appeals and
`
`grievances, or signing off on such reviews. Dkt. 54-1 at 34-41; dkt. 1-1; dkt. 60-1 at 15-19. These
`
`facts demonstrate sufficient personal involvement for these defendants to be liable for the alleged
`
`constitutional violation.
`
`But the record does not reflect similar personal involvement by defendants Davis or Brown.
`
`Although Davis was responsible for Robertson's initial placement in segregation, there is no
`
`evidence that he was involved in, or was responsible for, reviewing Robertson's continued
`
`placement. Robertson testified at his deposition that defendant Purcell told Robertson to complain
`
`to Davis about Robertson's continued placement in segregation, but there is no evidence that
`
`Robertson did so. Dkt. 54-1 at 39-40. Similarly, there is no evidence that Warden Brown was
`
`involved in the review process. Robertson testified that he addressed one request for interview to
`
`Warden Brown, but defendant Snyder intercepted it and responded in place of Brown. Dkt. 54-1
`
`at 29-34; dkt. 60-1 at 14.
`
`Robertson mainly argues that Brown should be liable for the alleged Fourteenth
`
`Amendment violation because, as warden, he was responsible for what happened at the prison.
`
`Dkt. 60 at 1, 9. But there is no supervisory liability under § 1983. Locke, 788 F.3d at 669. For
`
`these reasons, defendants Davis and Brown are entitled to summary judgment on Robertson's
`
`Fourteenth Amendment claim.
`
`
`
`5
`
`

`

`Case 2:19-cv-00322-JRS-MG Document 64 Filed 09/03/21 Page 6 of 13 PageID #: 393
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`2. Liberty Interest
`
`The defendants argue that Robertson had no liberty interest in being placed in general
`
`population because he was held in segregation for less than a year. Thus, defendants argue, he was
`
`not entitled to periodic reviews of his placement in segregation. The defendants rely on Marion v.
`
`Columbia Corr. Inst., 559 F.3d 693, 698 (7th Cir. 2009), for the proposition that "six months of
`
`segregation is not an extreme term and, standing alone, would not trigger due process." But
`
`Robertson was held in segregation for nearly eleven months. And the Marion court held that
`
`Marion's confinement of nearly eight months "may implicate a liberty interest [depending on the
`
`conditions]." Id. at 699. The Seventh Circuit confirmed that eight months in segregation was
`
`sufficient to create a liberty interest in Williams v. Brown, No. 20-1858, 2021 WL 1124048, at *3
`
`(7th Cir. Mar. 24, 2021). Furthermore, Marion and Williams involved finite sentences in
`
`segregation following disciplinary proceedings while Robertson was placed in administrative
`
`segregation for an indefinite period of time.
`
`Both Marion and Williams discussed the standard applied in Wilkinson v. Austin, 545 U.S.
`
`209, 224 (2005), which considers whether the duration and conditions "taken together [] impose
`
`an atypical and significant hardship within the correctional context." The defendants argue that
`
`Robertson's conditions in confinement were not harsh enough to trigger a protected liberty interest.
`
`But a reasonable juror could conclude that the duration of Robertson's confinement combined with
`
`the restrictive and inhospitable conditions of segregation triggered his right to periodic review of
`
`his classification.
`
`The defendants argue alternatively that Robertson received sufficient due process through
`
`the 30-day reviews and the availability of a classification appeal. But the record reveals that the
`
`30-day reviews completed by defendant Purcell mirror the types of perfunctory reviews found to
`
`
`
`6
`
`

`

`Case 2:19-cv-00322-JRS-MG Document 64 Filed 09/03/21 Page 7 of 13 PageID #: 394
`
`be meaningless in Isby. Dkt. 60-1 at 15-19. There remains a genuine issue of material fact as to
`
`whether these reviews were "meaningful" for purposes of due process.
`
`For these reasons, defendants Snyder, Purcell, and Stroup are not entitled to summary
`
`judgment on Robertson's Fourteenth Amendment claim.
`
`3. Qualified Immunity
`
`The defendants argue alternatively that they are entitled to qualified immunity on this claim
`
`because it is not clearly established that periodic reviews in which an inmate in restricted housing
`
`has the opportunity to challenge his placement in writing but not to appear in person violate the
`
`inmate's procedural due process rights or that ten to eleven months in restrictive status housing is
`
`sufficiently long as to trigger a liberty interest thus even implicating the Fourteenth Amendment.
`
`"Qualified immunity attaches when an official's conduct does not violate clearly
`
`established statutory or constitutional rights of which a reasonable person would have known."
`
`White v. Pauly, 137 S. Ct. 548, 551 (2017) (citation and internal quotation marks omitted). To
`
`overcome an assertion of qualified immunity, a plaintiff must show that "(1) the defendant violated
`
`a constitutional right, and (2) that [the] right was clearly established at the time of the alleged
`
`violation." Sinn v. Lemmon, 911 F.3d 412, 418 (7th Cir. 2018). In other words, qualified immunity
`
`is appropriate when the clearly established law, as applied to the facts, "would have left objectively
`
`reasonable officials in a state of uncertainty." Horshaw v. Casper, 910 F.3d 1027, 1030 (7th Cir.
`
`2018).
`
`Reasonable prison officials should have known in 2018 that inmates in segregation are
`
`entitled to meaningful periodic reviews. See Hewitt v. Helms, 459 U.S. 460, 477 n.9 (1983),
`
`abrogated in part on other grounds by Sandin v. Conner, 515 U.S. 472 (1995); Isby, 856 F.3d at
`
`530 ("[P]rison officials have been on notice since Hewitt that periodic reviews of administrative
`
`
`
`7
`
`

`

`Case 2:19-cv-00322-JRS-MG Document 64 Filed 09/03/21 Page 8 of 13 PageID #: 395
`
`segregation are constitutionally required, and it is self-evident that they cannot be a sham."). And
`
`reasonable prison officials should have known that ten to eleven months in segregation at WVCF,
`
`the same facility at issue in Isby, was sufficient to trigger a liberty interest. See Marion, 559 F.3d
`
`at 699; Isby, 856 F.3d at 512.
`
`Under some "extraordinary circumstances," an official may be entitled to qualified
`
`immunity based on reasonable ignorance of clearly established law governing the official's
`
`conduct. Harlow v. Fitzgerald, 457 U.S. 800, 819 (1982); see also Amore v. Navarro, 624 F.3d
`
`522, 535 (2d Cir. 2010) (officer entitled to qualified immunity despite arresting plaintiff under
`
`statute that had been held unconstitutional). But the defendants provide no evidence of such
`
`extraordinary circumstances.
`
`Because it was clearly established by 2018 that ten to eleven months in segregation at
`
`WVCF was sufficient to trigger a liberty interest and because a genuine issue of fact remains as to
`
`whether Robertson received the process required by Hewitt, summary judgment on the grounds of
`
`qualified immunity is not appropriate. Isby, 856 F.3d at 530. Accordingly, defendants Snyder,
`
`Purcell, and Stroup are not entitled to judgment as a matter of law based on qualified immunity.
`
`B. Conditions of Confinement Claim
`
`Robertson claims that the conditions of confinement in segregation are significantly worse
`
`than the conditions in general population. The defendants argue that Robertson's complaints about
`
`cold showers and food, and lack of access to group religious activities and the law library are
`
`insufficient to support an Eighth Amendment conditions of confinement claim.
`
`
`
`The Eighth Amendment's proscription against cruel and unusual punishment protects
`
`prisoners from the "unnecessary and wanton infliction of pain" by the state. Hudson v. McMillian,
`
`503 U.S. 1, 5 (1992) (citation and internal quotations omitted). Pursuant to the Eighth Amendment,
`
`
`
`8
`
`

`

`Case 2:19-cv-00322-JRS-MG Document 64 Filed 09/03/21 Page 9 of 13 PageID #: 396
`
`prison officials have the duty to provide humane conditions of confinement: "prison officials must
`
`ensure that inmates receive adequate food, clothing, shelter, and medical care, and must take
`
`reasonable measures to guarantee the safety of the inmates." Farmer v. Brennan, 511 U.S. 825,
`
`832 (1994) (internal quotation omitted).
`
`To succeed on a conditions-of-confinement claim under the Eighth Amendment, a plaintiff
`
`must demonstrate that 1) he was incarcerated under conditions that posed a substantial risk of
`
`objectively serious harm, and 2) the defendants were deliberately indifferent to that risk, meaning
`
`they were aware of it but ignored it or failed "to take reasonable measures to abate it." Townsend
`
`v. Cooper, 759 F.3d 678, 687 (7th Cir. 2014); Pyles v. Fahim, 771 F.3d 403, 409 (7th Cir. 2014);
`
`Townsend v. Fuchs, 522 F.3d 765, 773 (7th Cir. 2008) (citing cases). This standard is different that
`
`the "atypical and significant hardship" standard applied in the Fourteenth Amendment context.
`
`The objective showing requires "that the conditions are sufficiently serious—i.e., that they
`
`deny the inmate the minimal civilized measure of life's necessities, creating an excessive risk to
`
`the inmate's health and safety." Giles v. Godinez, 914 F.3d 1040, 1051 (7th Cir. 2019) (internal
`
`quotation omitted). "According to the Supreme Court, … 'extreme deprivations are required to
`
`make out a conditions-of-confinement claim.'" Id. (quoting Hudson, 503 U.S. at 9). "If under
`
`contemporary standards the conditions cannot be said to be cruel and unusual, then they are not
`
`unconstitutional, and [t]o the extent that such conditions are restrictive and even harsh, they are
`
`part of the penalty that criminal offenders pay for their offenses against society." Id. (internal
`
`quotation omitted).
`
`After showing the objective component, a plaintiff must next establish "a subjective
`
`showing of a defendant's culpable state of mind," and "the state of mind necessary to establish
`
`liability is deliberate indifference to the inmate's health or safety." Id. (internal quotation omitted).
`
`
`
`9
`
`

`

`Case 2:19-cv-00322-JRS-MG Document 64 Filed 09/03/21 Page 10 of 13 PageID #: 397
`
`In addition, negligence or even gross negligence is not sufficient to support a § 1983 claim. See
`
`Huber v. Anderson, 909 F.3d 201, 208 (7th Cir. 2018).
`
`
`
`The record shows that Robertson was subjected to cold showers and cold food in
`
`segregation and that he could not physically attend law library or religious services. These
`
`conditions do not constitute extreme deprivations that could be described as cruel and unusual.
`
`While they may be harsher and more restrictive than conditions experienced in general population,
`
`no juror could conclude that they are sufficiently serious to violate the Eighth Amendment.
`
`Therefore, the defendants are entitled to summary judgment on this claim.
`
`C. Deliberate Indifference Claim Against Brown
`
`Robertson alleges that Brown was deliberately indifferent to his hand injury in violation of
`
`his Eighth Amendment rights. Brown responded to Robertson's grievance appeal in June 2018 and
`
`to Robertson's informal grievance in January 2019. The first response stated that Robertson could
`
`submit a healthcare request form if his hand still hurt. Dkt. 54-4 at 2. The second response informed
`
`Robertson that no medical provider had referred Robertson to an outside hand specialist and that
`
`Robertson could submit a healthcare request if he was still experiencing issues with his hand.
`
`Dkt. 17-1.
`
`As noted above, Robertson's treatment and the conditions of his confinement are evaluated
`
`under standards established by the Eighth Amendment's proscription against the imposition of
`
`cruel and unusual punishment. See Helling v. McKinney, 509 U.S. 25, 31 (1993) ("It is undisputed
`
`that the treatment a prisoner receives in prison and the conditions under which he is confined are
`
`subject to scrutiny under the Eighth Amendment.").
`
`
`
`The Eighth Amendment "protects prisoners from prison conditions that cause the wanton
`
`and unnecessary infliction of pain." Pyles v. Fahim, 771 F.3d 403, 408 (7th Cir. 2014). "To
`
`
`
`10
`
`

`

`Case 2:19-cv-00322-JRS-MG Document 64 Filed 09/03/21 Page 11 of 13 PageID #: 398
`
`determine if the Eighth Amendment has been violated in the prison medical context, [the Court]
`
`perform[s] a two-step analysis, first examining whether a plaintiff suffered from an objectively
`
`serious medical condition, and then determining whether the individual defendant was deliberately
`
`indifferent to that condition." Petties v. Carter, 836 F.3d 722, 727-28 (7th Cir. 2016) (en banc).
`
`
`
`"[D]eliberate indifference may be found where an official knows about unconstitutional
`
`conduct and facilitates, approves, condones, or 'turn[s] a blind eye' to it." Perez v. Fenoglio, 792
`
`F.3d 768, 781 (7th Cir. 2015) (quoting Vance v. Peters, 97 F.3d 987, 992-93 (7th Cir. 1996)). An
`
`inmate's correspondence to a prison official may provide sufficient knowledge of a constitutional
`
`deprivation. Id. at 781-82. "[O]nce an official is alerted to an excessive risk to inmate safety or
`
`health through [an inmate's] correspondence, refusal or declination to exercise the authority of his
`
`or her office may reflect deliberate disregard." Id. at 782.
`
`
`
`In contrast, if, upon learning of an inmate's complaints, a prison official reasonably
`
`responds to those complaints, he lacks a "sufficiently culpable state of mind" to be deliberately
`
`indifferent. See Johnson v. Doughty, 433 F.3d 1001, 1010-11 (7th Cir. 2006) (finding grievance
`
`counselor did not violated the Eighth Amendment where he researched inmate's complaint, learned
`
`that medical professionals had seen and diagnosed inmate with medical condition and determined
`
`that surgery was not required).
`
`
`
`Defendant Brown is entitled to summary judgment because the undisputed facts establish
`
`that he reasonably responded to Robertson's grievance appeal in 2018 and informal grievance in
`
`2019. Brown facilitated Robertson's access to healthcare by providing him with the appropriate
`
`forms to request such care. No reasonable juror could conclude that Brown exhibited deliberate
`
`indifference with respect to Robertson's grievances. See Johnson, 433 F.3d at 1010-11. Brown is
`
`therefore entitled to summary judgment.
`
`
`
`11
`
`

`

`Case 2:19-cv-00322-JRS-MG Document 64 Filed 09/03/21 Page 12 of 13 PageID #: 399
`
`D. Qualified Immunity
`
`The Court addressed the defendants' qualified immunity argument as to Robertson's
`
`Fourteenth Amendment claim in Section III-A above. The Court does not address the defendants'
`
`qualified immunity argument as to Robertson's Eighth Amendment claims because the Court found
`
`that Robertson's Eighth Amendment rights had not been violated.
`
`IV. Conclusion
`
`The defendants' motion for summary judgment, dkt. [54], is granted as to Robertson's
`
`Fourteenth Amendment claim against Brown and Davis, his Eighth Amendment deliberate
`
`indifference claim against Brown, and his Eighth Amendment conditions of confinement claim
`
`against all defendants. The motion is denied as to Robertson's Fourteenth Amendment due process
`
`claim against defendants Snyder, Purcell, and Stroup.
`
`The clerk is directed to terminate Brown and Davis as defendants on the docket because
`
`all claims against them have been dismissed. No partial final judgment shall issue at this time.
`
`If Robertson wishes to be represented by counsel for trial or any potential settlement
`
`conference, but his efforts to secure representation have been unsuccessful, he may seek the Court's
`
`assistance. Robertson shall have through September 29, 2021, in which to file a motion for
`
`recruitment of counsel or notify the Court that he wishes to proceed pro se. The clerk is directed to
`
`include the motion for counsel form with Robertson's copy of this Order.
`
`IT IS SO ORDERED.
`
`
`
`Date: 9/3/2021
`
`
`
`
`
`
`
`
`
`12
`
`

`

`Case 2:19-cv-00322-JRS-MG Document 64 Filed 09/03/21 Page 13 of 13 PageID #: 400
`
`Distribution:
`
`TIMOTHY WAYNE ROBERTSON
`943020
`MIAMI - CF
`MIAMI CORRECTIONAL FACILITY
`Inmate Mail/Parcels
`3038 West 850 South
`Bunker Hill, IN 46914-9810
`
`Brandyn Lee Arnold
`INDIANA ATTORNEY GENERAL
`brandyn.arnold@atg.in.gov
`
`Douglass R. Bitner
`KATZ KORIN CUNNINGHAM, P.C.
`dbitner@kkclegal.com
`
`Brandon Carothers
`INDIANA ATTORNEY GENERAL
`bcarothers@atg.in.gov
`
`Mollie Ann Slinker
`INDIANA ATTORNEY GENERAL
`mollie.slinker@atg.in.gov
`
`Samantha May Sumcad
`INDIANA ATTORNEY GENERAL
`samantha.sumcad@atg.in.gov
`
`Jarod M. Zimmerman
`KATZ KORIN CUNNINGHAM, P.C.
`jzimmerman@kkclegal.com
`
`
`
`
`13
`
`

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