`Circuit Court
`Sullivan County, Indiana
`
`IN THE SULLIVAN CIRCUIT COURT
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`CAUSE NO. 77C01-1904-CT-204
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`SS:
`
`) )
`
`)
`
`STATE OF INDIANA
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`COUNTYOF SULLIVAN
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`MICHAEL HICKINGBOTTOM,
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`Plaintiff,
`
`Vv.
`
`aieeeeee
`
`ROBERT CARTERJR., et al.,
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`Defendants.
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`DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT
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`Defendants, Robert Carter Jr., Jack Hendrix, Richard Brown, Jerry Snyder, Charles
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`Dugan, and Randall Purcell, by counsel, Zachary R. Griffin, Deputy Attorney General,
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`respectfully move the Court to grant summary judgmentin their favor on the basis that there is
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`no genuine issue of material fact and Defendants are entitled to judgmentas a matter of law.
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`DESIGNATION OF EVIDENCE
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`In support of their motion, Defendants designate the following evidence in support of the
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`instant motion:
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`Exhibit A:
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`Deposition Transcript of Michael Hickingbottom;
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`Exhibit B:
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`Plaintiff's Location History;
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`Exhibit C:
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`Report of Inter-Institutional Transfer;
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`Exhibit D:
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`30-day review forms dated October 2018 through April 2019;
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`Exhibit E:
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`Declaration of Charles Dugan;
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`Exhibit F:
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`Disciplinary Hearing Report;
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`Exhibit G:
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`December 2019 Classification Appeal and Response;
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`Exhibit H:
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`Declaration of Jerry Snyder;
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`
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`Exhibit I:
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`Declaration of Jack Hendrix;
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`ExhibitJ:
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`March 2019 Classification Appeal and Response.
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`The instant motion is supported by the arguments set forth in the accompanying
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`memorandum in support that is incorporated herein by reference.
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`WHEREFORE,Defendants respectfully move the Court to grant summary judgmentin
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`their favor, dismiss Plaintiff's claims, and grant all other relief deemed just and proper.
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`Respectfully submitted,
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`THEODORE E. ROKITA
`Indiana Attorney General
`Attorney No. 18852-49
`
`/s/ Zachary R. Griffin
`Zachary R. Griffin
`Deputy Attorney General
`Attorney No. 35769-49
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`
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`CERTIFICATE OF SERVICE
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`I certify that on February 11, 2021, the foregoing document was served upon the
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`following person(s) via IEFS, if Registered Users, or by depositing the foregoing documentin
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`the U.S. Mail, first class, postage prepaid, if exempt or non-registered user.
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`Michael Hickingbottom
`DOC#147099
`Wabash Valley Correctional Facility
`P.O. Box 1111
`Carlisle, IN 47838
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`OFFICE OF ATTORNEY GENERAL
`Indiana Government Center South, 5Floor
`302 West Washington Street
`Indianapolis, IN 46204-2770
`Telephone:
`(317) 232-4828
`Facsimile: (317) 232-7979
`E-mail: Zachary.Griffin@atg.in. gov
`
`/s/Zachary R. Griffin
`Zachary R. Griffin
`Deputy Attorney General
`
`
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