Brown v. Venettozi

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK MOTION FOR INITIAL DISCLOSURE, REPLY TO RESPONDENT ANSWER TO JOHNNY B.BROWN 96b2223 AMENDED COMPLAINT PLAINTIFF, No. 18-CV-2628(KMK) -Y-

ra MEMO ENDORSED DEFENDANTS. a KENNETH M.KARAS,HON.DIS. JUDGE JOHNNY B.BROWN PRO SE PLAINTIFF,currently incarcerated at ORLEANS CORR. FAC. is filing this motion for Initial Disclosure and as a reply to Respondent motion replying to allege THIRD AMENDED COMPLAINT which PLAINTIFF never filed. 1.)FIRST AND FOREMOST Plaintiff is requesting that Respondent motion be denied as a matter of law where here the Respondent ask that 8 defendants that are not a part of this proceeding be dismissed.One look at Respondent motion will established that Respondent have clearly mixed up defendants from two different cases.At this moment I am currently under Quarantine in G-1 dorm here at ORLEANS CORR.FAC. so I have no access to law library to produce copys of Respondent motion so I am asking your HON. to review motion that Respondent submitted as proof of such motion having no merit. 2.)PLAINTIFF is requesting documents(copys) of the following documents: the actual tape of SUPT.Hearing,all transcripts of said hearing,All documents concerning Artcle 78 proceeding,any/all legal pending or settled litigation against all defendants, any/all preivances or disclinary actions filed,reviewed,or pending against all defendants.PLAINTIFF is requesting copies of all documents that RESPONDENT have access to concerning this matter before

YOUR HONOR:SUPT. HEARING,ARTICLE 78,and the current Action under 42 U.S.C. .1983. 3.)In closing PLAINTIFF is requesting that YOUR HONOR will reconsider Plaintiff motion for counsel as this proceeding _move forward to more complex,and Plaintiff have much less access to the law library and no access to legal assistance. WHEREFORE, PLAINTIFF request that Respondent motion be denied as it is clear it has no merit,also request that Respondent be ORDERED to produce Documents Plaintiff have requested.MAY GOD BLESS YOUR HONOR , RESPONDENTS jgand all the Staff of the Court! RESPECTFULLY SUBMITTED, JOHNNY B.BROWN 96b2223 GB □□□ — dated: 4-7-21 cc: JOHNNY B.BROWN 9662223 JENNIFER ROSE GASHT,ESQ. HON. KENNETH M.KARAS JOHNNY B. BROWN. 96b2223 □ ORLEANS CORR.FAC. 3531 GAINES BASIN RD. ALBION, NY, 14411-9199

No.18-CV-2628 Plaintiff's request that the Court deny Defendants’ motion is denied, because Defendants have no pending motions. Plaintiffs request for initial disclosure is denied without prejudice, because these requests should be directed to Defendants in the first instance. Plaintiff's request that the Court appoint counsel is denied withor prejudice, because Plaintiff does not explain what efforts have been made thus far to get counsel. See Justice v. Kuhnapfel, 982 F. Supp. 2d 233, 235 (E.D.N.Y. 2013) (“A plaintiff requesting appointment of counsel must □□□ that she is unable to obtain counsel before appointment will even be considered.” (citation and quotation mar omitted)). 4/14/21 80 0 ‘D ? . The Clerk of the Court is directed'to. be my mail a copy of this Order to the Plaintiff NNEBTH 4. AGIISHT

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