motionApril 17, 2022
Continued motion notes: Deliberate Indifference and Access to Basics
Continuation page (sections 4-6) of the change-of-venue / conditions outline. Argues deliberate indifference, requests injunctive relief, and itemizes deprivation of basics like haircuts (13 mo), shower (5 days), worship/communion (never), family contact.
Source: J6 Scan 10 folder / Drive
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