Document 48 - Emergency Motion To Stay Proceedings

Case 1:17-cv-00761-CMH-TCB Document 48 Filed 01/24/18 Page 1 of 7 PageID# 872
filed
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Alexandria Division ?Lj H- S3
EDWARD RICHARDSON, CLERK VI ni3TR!CT CC'jnT
^ LLAI^1I .i,-, 'f 11 V<_i i1ji
Plaintiff,
V. Civil Action No. l:17-cv-761-CMH-TCB
PRINCE WILLIAM COUNTY

GOVERNMENT, Mai,
Defendants.
PLAINTIFF'S EMERGENCY MOTION TO STAY PROCEEDINGS
Plaintiff Edward Richardson, Pro hereby file this Emergency Motion to Stay the
Proceedings in the instant cause ofaction due to judicial prejudice and racial bias toward a Black
male pro se litigant, in favor of the all defendants'. Plaintiff seeks to stay the proceedings
pending outcome of his appeal of this Court's January 22, 2018 Order staying discovery.
Plaintiff further seeks to stay the proceedings pending a ruling on Plaintiffs Consolidated
Motions for the Recusal of the Honorable U.S. District Court Judge Claude M. Hilton and U.S.
Magistrate Judge Theresa C. Buchanan, and for Change of Venue to the Norfolk Division.
Plaintiff seeks a ruling on all other pending motions outside of Division of this Court. In support
of his Motion, Plaintiff states as follows:
BACKGROUND
Plaintiff commenced this action against the defendants on July 6, 2017, naming the
Prince William County Government ("County") and Barry M. Barnard, Chief of Police, Prince
William County Police Department (the "Department") each in their official-capacities.
Defendants' Scott A. Vago, Charlie T. Deane, Stephan M. Hudson, Michael A. Femald, Jay
Lanham and Timothy Rudy each are named as individual-capacity defendants'. See Dkt. 1. The
defendants' filed a Joint Motion to Dismiss on October 23, 2017 (Dkt. 8), which was met by
Plaintiffs November 13, 2017 Opposition and Cross-Motion for Disqualification of Municipal
Government Counsel as to the Individual-Capacity Defendants'. Dkt. 12. The Defendants' filed
an Opposition to Plaintiffs Cross-Motion on November 17, 2017 but proffered no further

supportive briefing on their joint dispositive motion. See Dkt. 15. On November 16, 2017,
Plaintiff filed a Motion for Temporary Restraining Order and Preliminary Injunction against all
defendants' in the instant cause of action. On December 4, 2017, Plaintiff filed his Motion to file
a Rule 15(c) Amendment to which the Defendants' opposed during conferral with Plaintiff, but
failed to opposeon the docket in entirety. See Dkt, 24.
On December 5, 2017, the parties were notified by way of the Court's Order of inter alia,
discovery scheduling, and initial and final pretrial conferences. At the request of defendants'
counsel and without Plaintiffs opposition, the initial pretrial conference set for December 27,
2017 was rescheduled for January 3, 2018 before the Honorable Theresa C. Buchanan. Prior to
the Court had ordered that the parties both submit proposed discovery plans by December 20,
2017. The defendants' submitted their joint discovery plan on December 19, 2017 falsely
alleging they conferred with Plaintiff on various areas of discovery, which was brought to the
Court's attention by the Plaintiff in his own discovery plan filed on December 20, 2017. During
the January 3, 2018 initial pretrial conference, the Court adopted the defendants' Joint Discovery
Plan. S^ Exhibits A and B. The parties exchanged initial disclosures on January 10, 2018,
identifying any and all witnesses needed for trial. S^ Exhibit C. Therefore, the parties had
engaged in discovery. However, it was only after Plaintiff had exposed his witnesses in his initial
disclosures, and had begun serving the defendants' with Requests for Admissions, Production of
Documents and Interrogatories did the defendants seek to file a motion to stay discovery, and
they did so exhibiting Plaintiff's discovery requests to the Court so as to guide the Court's
decision on what claims of Plaintiffs to dismiss, if not all claims.'
Moreover, the Court has allowed this action to proceed without making any rulings on
Plaintiffs pending Cross-Motion for the Disqualification of Municipal Government Counsel as

to Individual Capacity-Defendants' and Plaintiffs Motion for Temporary Restraining Order and
Preliminary Injunction and therefore the individual-capacity defendants each have enjoyed the
comforts of municipal government representation, which is a direct conflict of interest as the
County is also a defendant. Plaintiff seeks the immediate Recusal of U.S. District Court Judge
Claude M. Hilton and U.S. Magistrate Judge Theresa C. Buchanan, and a change of venue to the
Norfolk Division racial discrimination and bias toward a Black male pro se litigant in favor of
the defendants. On January 3, 2018 during initial pretrial conference, the Buchanan Court made
reference that Plaintiff had made late filings with the Court. After thorough examination of the
Docket, Plaintiff identifies no instance where he has made any late filing with the Court and
remains extremely diligent in his filings with the Court.
ARGUMENT
Plaintiffhas been sevierely prejudiced and biased in this cause of action by both the Court
and the defendants and the current circumstances surrounding the conductalleged calls for a stay
of the proceedings in this action. By no stretch of the imagination can a defendant seek stay
protections as a safeguard fi"om producing discovery after the commencement of discovery and
' Exhibit D displays the Joint Discovery Plan of the parties in Small v. Cranmer, et al., 12-cv-
989-LO-IDD where the Prince William County Government is named as a defendant. Plaintiff
Sylvester L. Small is represented by legal counsel. Jeff Notz represents the defendants.
Examination of the case proves that the parties engaged in discovery pending a ruling on the
dispositive motion and minus a motion to stay discovery.
as a tactical measure, and the courts validate that point. In the defendants Motion, they allege
that no ruling has been made on their dispositive Motion. The courts have held that a motion to
dismiss is not dispositive, so as to warrant stayof discovery. Feldman v. Flood. 176 F.R.D. 651,
WL 820946 (M.D. Fla. 1997), see also Hovermale v. School BoardofHillsborouzh County Fla.,
128 F.R.D. 287, WL 139173 (M.D. Fla. 1989)("it would be improper and an abuse of discretion
to stay general discovery in this case pending a determination on defendants' motion for
summary judgment."). Due to the fact that discovery had actually commenced and the
defendants motion to stay was filed only after Plaintiff began making discovery requests.
Plaintiff was due the opportunity to file his opposition to the defendants motion, which was in
lack of a Roseboro Notice in violation of EDVA Local Rule 7(K). The defendants motion also
lacked a proposed order. The defendants have never filed a proposed order with any previous
motion or opposition to either of Plaintiffs motions, but the defendants filed a proposed order
the day after separate fi*om the motion on January 19, 2018 exhibiting specific wording that has
been copied verbatim in the Court's January 22, 2018 OrderSta)dng Discovery.
The Court's highly prejudicial January 22, 2018 Order has now placed the defendants' at
a clear advantage because now they are explicitly aware of Plaintiffs witnesses and what
documents and other information the Plaintiff is seeking. The identities of Plaintiff s witnesses
have been compromised as a result. The defendants were not entitled to stay fi*om active in-
progress discovery. United States v. Honeywell International. Inc.. 20 F.Supp.3d 129, WL
6405776 (D.D.C. 2013); Wolfv. United States. 157 F.R.D. 494, WL 542050 (D. Kan. 1994)
denying motion to stay civil discovery. The Court's Stay of discovery was to protect the
defendants. During conferral at the January 3, 2018 initial pretrial conference, defendants
counsel Jeff Notz stated to Plaintiff "we want Judge Hihon to preside over the case." Plaintiff
had never heard an attorney mention a judge specifically by name as wanting him or her to
preside over a case, even when the Judge was already assigned to the case. Examination shows
that Judge Hilton has a history of dismissing discrimination claims brought against the Prince
William County Government, and one such ruling byJudge Hilton was vacated and remanded by
th
the Fourth Circuit under Williams v. Prince William County. Virsinia. 645 Fed. Appx. 243 (4
Cir. 2016). In addition to the prejudice that Plaintiff is experiencing in this cause of action.
Plaintiff exhibits evidence of similar statements that support the grant of Plaintiffs Motion to
Stay the Proceedings.
Due to the intentional and deliberate bias Plaintiff is experiencing from the defendants
and the Court, staying the proceeding is the only proper action pending the outcome ofPlaintiffs
appeal on the Court's January 22, 2018 Order, as well as pending the outcome of Plaintiffs
Consolidated Motions for Recusal and Change of Venue, Cross-Motion to Disqualify Counsel,
and the Motion for Temporary Restraining Order. Even the Court's Order denying Plaintiffs
Motion to Strike is prejudicial and biased in various regards. Case law dictates that no defendant
canconsolidate the claims of a plaintiffs complaint and provide a one sentence response to those
claims. Plaintiff is not the "Dumb Nigger" as the defendants have alleged and Plaintiff is very
well aware that the defendants are receiving favor in this litigation. Plaintiffhas been subjected
to cormiving trickery, racial discrimination, bias and prejudice by the defendants' and this Court.
CONCLUSION
For the foregoing reasons. Plaintiff respectfully requests that this Honorable Court grant
his Emergency Motion to Stay Proceedings.
A proposed order is attached.

Dated: January 24, 2018 Respectfully submitted.
/s/ Edward Richardson

Edward Richardson, Plainti:^ro Se
Anti-Corruption Investigator / Paralegal
1819 Meadow Drive
Fredericksburg, Virginia 22405
P. 540/207-1666
E. edwardrichardson27@yahoo.com
CERTIFICATE OF SERVICE
I HEREBY DECLARE that on this 24*'' Day of January 2018,1 served the foregoing on
the following by FedEx; United States Postal Service; electronic mail, and / or hand delivery:
MICHELLE R. ROBL, ESQ.

Prince William County Attorney
JEFFREY R.B. NOTZ, ESQ.

Asst. Prince William County Attorney
1 County Complex Court
Suite 240
Prince William, Virginia 22192
Legal Counselfor the Defendants^
Prince William County, BaiTy M.
Barnard, Stephan M. Hudson,
Timothy Rudy, Scott A. Vago,
Jay Lanham, Michael A. Femald,
Charlie T. Deane
/s/ Edward Richardson

Edward Richardson, Plalnti^

Alexandria Division
EDWARD RICHARDSON,
Plaintiff,
V. Civil Action No. 1:17-cv-761 -CMH-TCB
PRINCE Vv'ILLIAM COUNTY

GOVERNMENT, âL,
Defendants.
fPROPOSEDI ORDER
Plaintiff has filed an Emergency Motion to Stay Proceedings.
Whereas the Court has considered the parties Motions, THE COURT FINDS that
Plaintiff has demonstrated that good cause exist and justice requires the grant of the Motion.
Therefore, Plaintiffs Motion is GRANTED.
SO ORDERED, this day of 2018
United States District Court Judge

Case 1:17-cv-00761-CMH-TCB Document 48-1 Filed 01/24/18 Page 1 of 46 PageID# 879
/ .
Exhibit A
Case l:17-cv-00761-CMH-TCB Document 26 Filed 12/01/17 Page 1 of 1 PagelD# 747
"j
IN THE I'.MTEl) S'l ATES DISTRICT COUR

FOR THE EASTERN DISTRICT OF VIRGINlW - s mi (L:
Ale.xandrin Division
L-.d\vard Richard.son. CLERK. U.S. DISTRICT COURT
PlainlifT. ALEXANDRIA. VIRf^lM/A
V.
Prince William County Government, Civil Action No. 1:17CV761
Defendant.
ORDER
A l ed. K. Ci\ . P. 16(h) PKl: IRIAL. CONI'liRI-'NCB will be held on Wednesday . December 27.
—11:00 a.m. belore Mauistrale .ludgc Uuchaiian . The parties shall confer prior to this conference
to consider the claims, delenses. possibilities ol a prompt settlement or resolution of the case, trial before
the mauistrale Judue. to airanue lor the disclosures required b) Rule 26(a)( I). and develop a discover}'
plan which will complete disciner> by i-rida\. .April 13. 20 KS . .A pari\ ma\ not e.\ceed five 1,5) non-
part). non-expen witness depositions nor ser\e on an> other pari\ more tiian tiiirty (30) interrogatories,
including parts and subparts. without leave ol court. Proposed discover) plans must be filed b\ the
\\ ednesda\ one week before the Rule l()(b) pretrial conference.
All parties shall llle an answer within twcnt) (20) davs,
1he MNAl. PRh IRIAL CONI l-Rl-NCl; will be held on fhursdax. April 19. 2018 at 10:00 a.m.
fhe parties nui.st electronicaIK file on or before the final pretrial conference the Rule 26(a)(3)
disclosures and a list ol the e.xhibits to be used at trial, a list of the witnesses to becalled at trial and a
written stipulation of uncontested lacts. 1he e.xhibits themselves or a copy should be e.xchanued with
opposing counsel before the conference. Objections to exhibits must be filed within 10 days after the
conference: otherwise the exhibits shall stand admitted in e\ idence. The original exhibits .shall be
delivered to the clerk as provided b> Local Rule 70(A). Non-expert witnesses and exhibits not so
disclosed and listed will not be oermitted at trial except for impeachment or rebuttal, and no person mav
testih whose identits. beinu subjeci to di.sclosiue or limeK recuiested in discoveiv. was not disclo-sed in
time to be deposed or to permit the substance of his knowledtie and opinions to be asceilained. The trial
ol this case will be set for a day certain, within 'l-S weeks ol the final pretrial conference.
Discovery may begin upon receipt of this Order.
PERSONAL IDENTIFIERS MUST BE RKDACTEI) FROM ALL PUBLICLY FILED

PLEADINGS AND EXHIBITS IN ACCORDANCE WITH LOCAL RULE 7(C).
CLAUDII M. HILTON
I NITLD S I ATHS DISTRICT .lUDGE
December / .2017
.Alexandria. Virginia
1his virder is being mailed or e-mailed to local cminsel onh.

(Alexandria Division)
EDWARD RICHARDSON,
Plaintiff,
V. Civil Action No. I:17cv761 (CMH/TCB)
PRINCE WILLIAM COUNTY,

BARRY M. BARNARD,
STEPHAN M. HUDSON
CHARLIE T. DEANE
TIMOTHY RUDY
SCOTT A. VAGO
JAY LANHAM
MICHAEL A. FERNALD
Defendants.
JOINT DISCOVERY PLAN OF ALL DEFENDANTS
Pursuant to Rule 26(f)(3) of the Federal Rules of Civil Procedure, Rule 26(A) of the
Local Rules of the United States District Court for the Eastern District of Virginia, and this
Court's Order of December 1, 2017, the parties conferred prior to the conference date to consider
claims, defenses, possibilities of a prompt settlement, and a trial before a magistrate judge as
required by Rule 26 and the defendants submit the following proposed Discovery Plan:
1. Initial Disclosures. The initial disclosures required by the Fed. R. Civ. P. 26(a)(1)
will be exchanged on or before January 10, 2018.
2. Claims. Defenses and Settlement. The parties have conferred as to the nature and
basis of their claims. No settlement has been reached.
3. Discovery Schedule.
a. In accordance with this Court's Order of December 1, 2017, all discovery
will be completed no later than April 13, 2018.
b. The Local Rules should not be altered and all requests for written
discovery should beserved so that answers thereto shall be due to be served not later than 3
weeks before the April 13, 2018, discovery cut-off date.
c. Discovery should not be conducted in phases or limited
in advance to particular issues, butshall be subject to the right ofany party to object to particular
discovery requests in accordance with the applicable rules and this Court's Order of December 1,
2017.
d. Subject to any future motions to amend this Discovery Plan for good
cause, the limitations on discovery set forth in the Court's Order of December 1, 2017, shall be
incorporated herein. These limitations include no morethan 5 non-party, non-expert witness
depositions and no more than 30 interrogatories, including parts and sub-parts per party without
leave of Court.
e. Should any party believe that additional depositions or interrogatories may
be necessary, the parties will confer and endeavor to reach an agreement with regard to any
additional discovery requests. If the parties cannot agree on such an issue any party may ask that
the issue be decided by the court.
4. The parties shall identify the witnesses they are designating to testify as their
30(b)(6) witness at least 5 days in advance of any such deposition.
5. The parties should produce electronically stored information in ".pdf format.
Any material withheld from production on the basis of any claim of privilege or immunity from
disclosure should be listed in a schedule provided to the party requesting the information. The
schedule should describe thematerial withheld from production with sufficient particularity as to
allow the requesting party to make an informed decision as to the privileged or mimune nature of
the information ormaterial, and should comply with Fed. R. Civ. P. 26(b)(5). Communications
between counsel and client need not be identified or listed on a scheduleof withheld documents.
6. The parties may serve discovery requests by electronic mail (as opposed to United
States Mail), Monday through Friday, during regular business hours 8:00 a.m. to 5:30 p.m. and,
ifpracticable, may respond to those requests by electronic means. Such request and responses
shall be deemed to have been served by ECF delivery.
7.. Discovery of Electronicallv Stored Information. Disclosure or discovery of
electronically stored information shall first beproduced inhard copy form. However, the
producing party shall maintain the electronically stored information inits original format.
Thereafter, either party may request the production ofelectronically stored mformation in its
native format.
8. Claims of Privilege or Protection of Trial Preparation Material. The parties will
adhere to the procedure setforth in Fed. R. Civ. P. 26(b)(5)(B) with respect to privileged
information.
9. Protective Order. A protective order under Fed. R. Civ. P.
26(c) will be appropriate in this case. The parties should endeavor to work cooperatively onthe
terms of a stipulated protective order tobe submitted to the Court for consideration. Inadvertent
production of privileged material will not constitute a waiver ofprivilege. Upon any inadvertent
production ofprivileged material, the parties should resolve such claims inaccordance with Fed.
R. Civ. P. 26(b)(5).
10. Expert Discovery.
a. Pursuant to Local Rule 26(D)(3), the plaintiff shall identify expert
witnesses, ifany, and provide the required report by such witnesses, no later than February 16,
2018; defendants shall identify expert witness, if any, and provide the required report bysuch
witnesses, no later than March 16, 2018; and any rebuttal expert witnesses and required report by
such witnesses, shall be made no laterthan March 30,2018. Theparties shall consult to ensure
that each party has a fair opportunity to timely depose another party's expert witness.
b. Discovery shall be conducted and expert disclosures made, if any, in
accordance with Fed. R. Civ. P. 26 and the Local Rules, except as indicated herein.
11. Subjects of Discovery. Discovery relevant to the claims anddefenses contained
in the pleadings will beappropriate, subject to all objections permitted bythe applicable rules.
12. The parties understand and agree that discovery may beneeded onthe following
subjects: (a) the facts and allegations underlying thecauses of theaction described in the
pleadings; (b) the defense asserted in the pleadings; and (c) damages.
13. Trial bv Magistrate. The Defendants respectfully do not consent to trial by a
magistrate judge.
The Defendants respectfully request that the Court adopt this discovery plan.
Respectfully submitted,
PRINCE WILLIAM COUNTY, BARRY M.

BARNARD, STEPHAN M. HUDSON,
CHARLIE T. DEANE, TIMOTHY RUDY,
SCOTT A. VAGO, JAY LANHAM,
MICHAEL A. FERNALD
By Counsel
MICHELLE R. ROBL
County Attorney
/s/
JEFFREY R.B. NOTZ, VSB# 41755
Assistant County Attorney
One County Complex Court
Prince William, VA 22192-9201
Telephone: (703) 792-6620
Telefax: (703)792-6633
jnotz@pwcgov.org
Counsel for Defendants
CERTIFICATE OF FILING AND SERVICE
I hereby certify that on this 19'^ day ofDecember, 2017,1 emailed the foregoing to the
following non-filing user, and sent a copy byU.S. mail, first-class postage pre-paid:
Edward Richardson
1819 Meadow Drive
Fredericksburg, VA 22405
540-207-1666
Email: edwardrichardson27@yahoo.com
PRO SB
MICHELLE R. ROBL
County Attorney
/s/
JEFFREY R. B. NOTZ, VSB# 41755
One Count)' Complex Court
Telephone; (703) 792-6620
Telefax; (703)792-6633
jnotz@pwcgov.org
Coimsel for Defendants
Exhibit B
rNfTlAL PRETRiAL CONPBRJENCE
MAGFSTtlATE JUDGE
CA- ll/lVjial
DATE: Mn
TIME: ir.lUftrv^ TO 1\ : g5\ Aoq
APPEARANCES COUNSEL FOR:
( ) PLANTIFF (X) defendant (/ ) PRO SB PLAINTIFF ( ) PRO SE DEFENDANT
DISCOVERY PLAN: TijepT'S
()(,) APPROVED ( ) APPROVED AS AMENDED ( ) FILE BY
CONSENT TO PROCEED BEFORE A MAGISTRATE JUDGE:
( )YES
( ) CONSENT SIGNED
ADR/SETTLEMENT:
( ) PENDING ( ) WILL DISCUSS ( ) OTHER
()() ORDER TO ISSUE
CASE CONTINUED TO FOR 16(B) CONFERENCE
THE UNITED STATES DISTRICT COURT JAN - 3 2018

FOR THE EASTERN DISTRICT OF VIRGINIA I
Alexandria Division .'..i
Edward Richardson,
Plaintiff,
V . Civil Action No,l:17cv761
Prince William County, et al.,
Defendants.
SCHEDULING ORDER
1. Upon consideration of the representations made by the

parties in submissions presented, the Court makes the following
rulings;
a. The proposed Joint Discovery Plan of All Defendants
(Doc. 30) is approved and shall control discovery to the extent
of its application unless modified by the Court.
2. The following provisions shall apply to the filing and
noticing of all motions:
(a) All motions must contain a statement that a good-faith
effort to narrow the area of disagreement has been made in
accordance with Local Civil Rule 7(E) and Local Civil Rule 37(E)
for discovery motions. All motions must adhere to the page
limits and font requirements set in Local Civil Rule 7(F) (3) .
An appropriate number of paper copies of any motion and all
pleadings relating to that motion shall be delivered directly to
the clerk's office within one day of the electronic filing. See
"Civil and Criminal Motions Procedures and other Alexandria
Specific Information" on the Alexandria page of the Coiirt's

website located at www.vaed.uscourts.gov.
(b) All motions, except for summary judgment and consent
motions, shall be noticed for a hearing on the earliest possible
Friday before the final pretrial conference consistent with the

briefing schedules discussed below. A consent motion should be
filed in accordance with the procedures provided on the
Alexandria page of the Court's website referenced above. Any
motion to amend the pleadings or to join a party must be made as
soon as possible after counsel or the party becomes aware of the

grounds for the motion.
(c) Dispositive motions shall be filed and briefed in
accordance with the schedule set forth in Local Civil Rule
7(F)(1) and (K). Local Civil Rule 7(F)(1) provides that a
response brief is due 14 days after service of the motion and a
reply brief may be filed 6 days after service of the response.
The periods for filing a response brief and a reply shall apply
without regard to the mode of service used for those briefs,
notwithstanding the provisions of Fed. R. Civ. P. 6(d). Any
dispositive motion against a pro se party must contain the
notice set forth in Local Civil Rule 7(K) and provide the pro se
party with at least 21 days to file a response opposing the
motion.
(d) In order to provide for the prompt resolution of non-

dispositive matters, a non-dispositive motion may be filed by no
later than 5:00 p.m. on a Friday and noticed for a hearing at
10:00 a.m. on the following Friday. Under this expedited
schedule, a response must be filed by no later than 5:00 p.m.
the Wednesday before the hearing and any reply should be filed
as early as possible on Thursday to give the Court time to
review all pleadings before the hearing. At the moving party's
discretion, a non-dispositive motion may also be filed and
noticed for a hearing in accordance with the briefing schedule
provided in Local Civil 7(F)(1) discussed above in order to
provide additional time for briefing and consideration by the
Court.
(e) All summary judgment issues shall be presented in the
same pleading unless leave of court is first obtained. As
required by Local Civil Rule 56, each brief in support of a
motion for summary judgment must include a separately captioned
section within the brief listing, in numbered-paragraph form,
each material fact that the movant contends is undisputed with
appropriate citations to the record. A brief in opposition to a
motion for summary judgment must include a separately captioned
section within the brief addressing, in numbered-paragraph form
corresponding to the movants section, each of the movants
enumerated facts and indicating whether the non-movant admits or

disputes the fact with appropriate citations to the record. The
Court may assume that any fact identified by the movsmt as
undisputed in the movants brief that is not specifically
controverted in the non-movants brief in the manner set forth
above is admitted for the purpose of deciding the motion for
summary j udgment.
(f) Any motion to file a document under seal, including a
motion for entry of a protective order containing provisions for
filing documents under seal, must comply with Local Civil Rule
5. Local Civil Rule 5 has recently been amended. The amended
version of Local Civil Rule 5 alleviates the need to file a
notice of hearing. The motion must state sufficient facts
supporting the action sought, and each proposed order must
include specific findings. Where a party moves to file material
under seal because the opposing party has designated that
material as confidential, the opposing party must file a
response to the motion and a proposed order that meet the
requirements of Local Civil Rule 5. Only the particular
material found to meet the required standard may be sealed, wi1:h
the remainder filed in the public record. An \insealed, redacted
version of the filing in issue shall be filed with the motion to
seal. Filings under seal are disfavored and discouraged. See
Va. Dep't of State Police v, Washington Post, 386 F.3d 567, 575-
76 (4th Cir. 2004) .

3. To the extent either party intends to assert a claim
of privilege or protection as trial preparation material, any
such claim must be made in a timely manner and in accordance
with Fed. R. Civ. P. 26(b)(5).
4. Disclosures under Fed. R. Civ. P. 26(a)(1) and (2),
depositions, interrogatories, requests for documents and

admissions, and answers thereto shall not be filed except on
order of the court, or for use in a motion or at trial.
5. In the event this case is tried before a jury, each
party shall file their proposed jury instructions and voir dire
five (5) business days prior to trial in accordance with Local
Civil Rule 51. Violation of this Rule will constitute a waiver
of objections to any instructions given. In the event the case
is tried without a jury, counsel shall file written proposed
findings of fact and conclusions of law prior to the beginning
of trial.
It is so ORDERED.
Is!
hsiesa Carroll Buclianan
niied States Magistrate Judge
Theresa Carroll Buchanan

United States Magistrate Judge
Date: January 3, 2018

Alexandria, Virginia
Exhibit C

EDWARD RICHARDSON,
Plaintiff,
V. Civil Action No. I :17cv761 (CMH/TCB)

BARRY M. BARNABUD,
STEPHAN M. HUDSON
CHARLIE T. DEANE
TIMOTHY RUDY
SCOTT A. VAGO
JAY LANHAM
MICHAEL A. FERNALD
Defendants.
DEFENDANTS' RULE 26(A>(1^ DISCLOSURES
COME NOW, THE DEFENDANTS, Prince William County, BarryBarnard,
Stephan Hudson, Charlie Deane, Timothy Rudy, Scott Vago, Jay Lanham and Michael
Femald, by Counsel, pursuant to Fed. R. Civ. P. 26(a)(1), and propound the following
disclosures:
A. Names and addresses(ifknown) ofpersons likely to have discoverable information,

along with the subjects ofthat information:
1. Chief Barry M. Barnard
c/o Jeffrey R. B. Notz, Prince William CountyAttorney's Office

One County Complex Court, Suite 240
Telephone: (703) 792-6620
Facsimile: (703) 792-6633
Information includes Plaintiff's work history and performance

2. Stephan M. Hudson
c/o Jeffrey R. B. Notz, Prince William County Attorney's Office

One County Con^lex Court, Suite 240
Telephone: (703) 792-6620
Facsimile: (703) 792-6633
Information includes Plaintiffs work history and performance
3. Charlie T. Deane

Telephone: (703) 792-6620
Facsimile: (703) 792-6633
Information includes Plaintiffs work histor>' and performance
4. Tiraothy Rudy

Telephone: (703) 792-6620
Facsimile: (703) 792-6633
5. Captain Scott A. Vago

Orie County Complex Court, Suite 240
Telephone: (703) 792-6620
Facsimile: (703) 792-6633
Information includes Plaintiffs work history and performance, internal affairs

investigations
6. Jay Lanham

Telephone: (703) 792-6620
Facsimile: (703) 792-6633
Information includes Plaintiffs workhistory andperformance, internal affair

investigations
7. Michael A. Femald

• Telephone: (703) 792-6620
Facsimile: (703) 792-6633
Information includes search of Plaintiff s residence
8. Captain Bryan W. Simms (Commander Office of Professional Standards)

Prince William County Police Department
Telephone: (703) 792-6650
Facsimile: (703) 792-7056
Information includes internal affairs investigations, keeping of investigatory

and Police Department disciplinary files, contents of investigatory and Police
Department disciplinary files, information disclosure procedures
9. Andrea R. Brenner (Piince William County Human Resources Custodian of

Records)
Prince William County Human Resources

4380 Ridgewood Center Drive
Telephone: (703) 792-6640
Facsimiles: (703) 792-6156
Information includes keeping of employment files, contents of employment

files, human resoiu-ces and information disclosure procedures
10. Lieutenant Eileen M. Welsh (Commander Police Department Personnel)
Prince William County PoHce Personnel Bureau

9540 Center Street, Suite 101
Manassas, Virginia 20110
Telephone: (703) 792-6580
Facsimile: (703) 792-4205
Infonnation includes keeping of police persormel records, contents of police

personnel files. Plaintiffs work history and performance, human resources
and information disclosure procedures
11. Kimberly Himmelberger, Administrative Support Assistant (Custodian Police

Personnel Records)
Prince William .County Police Personnel Bureau
9540 Center Street, Suite 101
Telephone: (703) 792-6580
Facsimile: (703) 792-4205
Infonnation includes keeping of police personnel files, contents of files, and

information disclosure procedures
12. Phyllis B. Aggrey (Current Executive Director of Human Rights Commission)
Human Rights Commission

15941 Donald Curtis Drive, Suite 125
Woodbridge, Virginia 22191
Telephone: (703) 792-4680
Facsimile: (703) 792-6944
Information includes investigating complaints of employment discrimination,

keeping of files concerning suchcomplaints and investigations, contents of
such files, and processing of EEOC claims
13. PatraE. Wright (Current EEO and Diversity Directorfor Prince William County)
Office of Executive Management

4360 Ridgewood Center Drive
Telephone: (703) 792-4665
Facsimile: (703) 792-6491
Information includes investigating internal complaints of employment

discrimination, keeping of files concerning such complaints and
investigations, contents of such files, and processing of EEOC claims
14. Michael R. Lewis (Current Police Officer with Prince William County)

8900 Freedom Center Boulevard
Telephone: (703) 792-5000
Facsimile: (703) 792-6510
Information includes Plaintiffs work histoiy and performance

15. Jeffrey L. King
13512 Photo Drive

Woodbfidge, Virginia 22193
16. Louis A. Marshall
17 St. Albans Boulevard

Stafford, Virginia 22556
17. Melvin C. Quattlebaum
4752 Hickory Nut Place

Montclair, Virginia 22025
Information includes Plaintiffs work histor>' and performance
18. Gregory Litts
Information includes Plaintiffs excessive use of force in January 2009
19. Detective Daniel A. Do\vney

15948 Donald Curtis Drive
Woodbridge, Virginia 22191
Telephone: (703) 792-7200
Facsiiriile: (703) 792-7578
Information includes Plaintiffs excessive use of force in January 2009
20. Lieutenant Carlos J. Robles
Prince William County Police Special Operations

5017 Prince William Parkway
Tsiephone: (703) 792-7254
Facsiiiiile: (703) 792-4555
Information includes Plaintiffs work history and performance, internal affairs

investigations
21. Lieutenant Craig S. Lawhead
Prmce William County Police Department

89G.0 Freedom Center Boulevard
Manassas," Virginia 20110
Telephone: (703) 792-5000,
Facsimile: (7Q3) 792-6510
22. Matthew D, Estes, Esquire. •
Alan Lescht & Associates, P.C.

1825 K Street, NW, Suite 750
Washington, DC 20006
Telephone: (202)315-1730
Facsimile: (202) 463-6067
Information includes terms and proposed settlement of Plaintiffs separation

from PWC Police Department
23. The following persons have not yet been identified with specificitybut
are expected to have discoverable information:
Custodian of records for Edward Richardson's medical, mental health, and

healthcê providers, other employment records, tax records, and financial
records
All individuals named or identified in any document listed in Plaintiff s

disclosure or otherwise identified iii discovery, depositions or subpoenaed
documents
Independent experts, to be identified if retained

B. Description ofdocuments andother tangible items currently in Defendants' possession

thai may be used to support defenses, and their location:
Prince William County Personnel Manual. Copies are located at Prince

William County Human Resources, 4380 Ridgewood Center Drive, Prince
William, Virginia22192
Prince William County Police Department standard operating procedures,

rules and regulations as they relate to this lawsuit. Copies are located at
Prince William County Police Department, One County Complex Court, Suite
155, Prince William, Virginia 22192
Employment, police personnel, and disciplinary records held by Prince William

County Human Resources, Prince William County Police Personnel Bureau, and
Office of Professional Standards. Copies are located with records' custodians,
who are identified in section A, above.
Records of EEOC complaints andcomplaints of employment discrimination filed

by Plaintiff and processed by Human Rights Commission and Office of Executive
Management. Copies are located with records' custodians, who are identified in
section A, above.
Copies of EEOC charges of employment discrimination filed by Plaintiffand the

correisponding responsive dismissals and notices of rights. Copies were attached
to the Complaint and Memo in Support of Motion to Dismiss. Copies are also
located with undersigned coimsel.
C. Not applicable to defendant.
D. Insurance:
PrinceWilliam Countyand its employees are insured by the Prince William Self-
Insurance Group up to a retained amoimt of $750,000 and maintain excess insurance in
the amount of $10 million through Genesis Reinsurance. Contact: Johnnie Winslow,
Claims Manager and Lori Gray, Risk Manager, 4361 Ridgewood Center Drive,
Woodbridge, VA 22192. Telephone: (703)792-6741.
Respectfully submitted,

BARRY M. BARNARD, STEPHAN
M. HUDSON, CHARLIE T.
DEANE, TIMOTHY RUDY,
SCOTT A. VAGO, JAY LANHAM,
MICHAEL A. FERNALD
By Counsel
iMICKELLE R. ROBL
County Attorney
/s/
JEFFREY R.B. NOTZ, VSB# 41755
Telephone: (703) 792-6620
Telefax: (703) 792-6633
jnotz@p\A'cg6v.org •
Coi-insei for Defendants
CERTIFICATE OF FILING AND SERVICE
I hereby certify thaton this 10^" dayof Januaiy, 2018,1 sent the foregoing by U.S.
mail, first-class postage pre-paid, to the following non-filing user:
Edward Richardson
1819 Meadow Drive
Fredericksburg, VA 22405
540-207-1666
Email: edwardrichardson27@yahoo.com
PROSE
MICHELLE R. ROBL
County Attorney
/si
JEFFREY R. B. NOTZ, VSB?M1755
Pribce William, VA 22192-9201
Telephone: (703) 792-6620
Telefax: (703) 792-6633
jnotz@pwcgov.org
Coxmsel for Defendants
Exhibit D
Case I:12-Cv-O0989-L0-IDD Document 13 Filed 12/21/12 Page 1 of 5 PagelD# 53

Alexandria Division
SYLVESTER L. SMALL,
Plaintiff,
vs.
I:12cv989 (LO-IDD)
JENNIFER M. CRANMER,
and
PRINCE WILLIAM COUNTY;
Defendants.
TOTNT DISCOVERY PLAN
Pursuant to Rule 26(f)(3) of the Federal Rules of Civil Procedure, Rule 26(a) of the
Local Rules of the United States District Court for the Eastern District of Virginia, and this
Court's Order of December 4, 2012, the parties conferred and submit the following proposed
Discovery Plan:
1. Initial Disclosures. The parties have conferred about initial disclosures
required by the Federal Rule of Civil Procedure 26(a)(1). The defendants made their
disclosures onDecember 5, 2012. Theplaintiff agrees to make his mitial disclosures before the
January 9, 2013, pretrial conference.
2. Claims. Defenses and Settlement. The parties have conferred as to the nature
and basis of their claims. At this time, although no settlement has been reached, the parties
intend to have further discussions.

3. Discovery Schedule.
a. The parties agree that, pursuant to this Court's Order of December 4,2012, all
discovery will be completed no later than April 12,2013.
b. The parties believe that the Local Rules should not be altered and that all
requests for written discovery should be served so that answers thereto shall be due to be
served not later than 3 weeks before thediscovery cut-off date.
c. The parties agree that discovery should not be conducted in phases or
limited in advance to particular issues, but shall be subject to the right of any party
to object to particular discovery requests in accordance with the applicable rules and
this Court's Order of December 4, 2012.
d. Subject to any future motions to amend this Discovery Plan for good cause,
the parties incorporate the limitations on discovery as set forth in the Court sOrder of
December 4, 2012, Order, as amended by this Discovery Plan.
4. The parties agree to not more than five non-party depositions in this case.
The parties agree that they shall identify the witnesses they are designating to testify as
their 30(b)(6) witness atleast 5 days in advance of any such deposition.
5 Discovery of Electronicallv Stored Information. The parties agree that
disclosure or discovery of electronically stored information shall first be produced in hard

copy form. However, the producing party shall maintain the electronically stored
information in its original format. Thereafter, either party may request the production of
electronically stored information ui its nativeformat.
6. Claims of Privilege or Protection ofTrial Preparation Material. The parties
will adhere to the procedure set forth in Fed. R. Civ. P. 26(b)(5)(B) with respect to privileged
Case l:12-cv-00989-LO-IDD Document 13 Filed 12/21/12 Page 3 of 5 PagelD# 55
information.
7. Protective Order. The parties believe that aprotective order under Fed. R.
Civ. P. 26(c) will be appropriate in this case. The parties will work cooperatively on the
terms of astipulated protective order to be submitted to the Court for consideration.
Inadvertent production of privileged material will not constitute awaiver of privilege. Upon
any inadvertent production of privileged material, the parties have agreed to resolve such
claims in accordance with Rule 26(b)(5).
8. Expert Discoverv.
a. Pursuant toLocal Rule 26(D)(3), the parties agree that Plaintiff shaU make its
expert disclosures, if any, no later than February 11,2013; that Defendant shall make its expert
disclosures, ifany, no later than March 4, 2013; and that any rebuttal expert disclosures shall
be made no later than March 19, 2013.
b. The parties agree to conduct expert discovery and to make their expert
disclosures, ifany, in accordance with Rule 26 of the Federal Rules of Civil Procedure and the
Local Rules, except as indicated herein.
9. Subjects of Discovery. The parties agree that discovery relevant to die claims
and defenses contained in the pleadings will be appropriate, subject to all objections
permitted by the applicable rules.
10. Trial bv Magistrate. The parties respectfully do not consent to trial by a
magistrate judge.
Theparties respectfully request that the Court adopt this discovery plan.
Dated: December 21st, 2012 Respectfully ^toitted,

—
Benjamin G. Chew
Gregory Louer
Caroline A. Davidson-Hood
PATTON BOGGS LLP
2550 M Street, N,W.
Washington, DC 20037
Telephone: 202-457-6000
Facsimile: 202-457-6315
Email: bchew @pattonboggs.com
glouer@pattonboggs.com
cdavidsonhood©pattonboggs.com
Counsel for PlaintiffSylvester Small
/s/
Jeffrey R.B. Notz
Robert P. Skoff
Assistant County Attomeys
Phone: 703 792-6620
Facsimile: 703 792-6633
Email: jnotz@pwcgov.org
rskoff@pwcgov.org
Attorneysfor Defendants
Case I;12-Cv-O0989-L0-IDD Document 13 Filed 12/21/12 Page 5 of 5 PagelD# 57
TFRTTFICATE of service
Ihereby certify that on the 21st day of December, 2012,1 will electronically file the
foregoing with the Clerk of Court using the CM/ECF system, which will then send a
notification of such filing to the following:
Jeffrey R.B.Notz
Robert P. Skoff
Assistant County Attorneys
Phone: 703 792-6620
Facsimile: 703 792-6633
Email: jnotz@pwcgov.org
rskoff@pwcgov.org
Attorneysfor Defendants
{'XOs-Ut-aSL
Carla Hellwig
Exhibit E

EDWARD RICHARDSON,
Plaintiff,
V. Civil Action No. I:17cv761 (CMH/TCB)

et al..
Defendants.
PROPOSED ORDER STAYING DISCOVERY
THIS MATTER comes before the Court on Defendants' Motion to Stay Discovery(Dkt.
42). Upon review ofthe pleadings, the Court finds that a stay ofdiscovery isappropriate
pending the Court's ruling on the Defendant's Motion to Dismiss (Dkt.7). Therefore, itis hereby
ORDERED that the Defendant's Motion to StayDiscovery (Dkt. 42) is GRANTED.
IT IS FURTHER ORDERED that if any of the Plaintiffsclaims remain after the ruling
on the Motion to Dismiss, the parties shall submit a revised discovery plan tailored to address the
remaining claims.
IT IS FURTHER ORDERED that the parties shallrefi-ain from propounding discovery
until the ruling on the motion to dismiss is issued and a revised discovery plan is entered.
IT IS FURTHER ORDERED that any existing discovery requests are without effect.
SO ORDERED, this day of , 2018.
Theresa Carroll Buchanan

Case l:17-cv-00761-CMH-TCB Document 47 Filed 01/22/18 Page 1 of1 PagelD# 871

EDWARD RICHARDSON.
Plaintifi;
V. Civil Action No. I:i7cv761 (CMH/TCB)

ei al..
Defendants.
ORDER STAYING DISCOVERY
THIS MATTER comes before the Court on Dafendants' Motion to Stay Discovery (Dkt.
42). Upon review ofthe pleadings, the Court finds that a stay ofdiscovery is appropriate
pending the Court s ruling on the Defendant's Motion to Dismiss (Dkt.7). Therefore, it is hereby
ORDERED that the Defendant's Motion to Stay Discovery (Dkt. 42) is GRANTED.
IT IS FURTHER ORDERED that if any of the Plaintiffs claims remain after the ruling
on the Motion to Dismiss, the parties shall submit a revised discovery plan tailored to address the
remaining claims.
IT IS FURTHER ORDERED that the parties shall refrain from propounding discovery
until the ruling on the motion lo dismiss is issued and a revised discovery plan is entered.
IT IS FURTHER ORDERED that any existing discover)' requests are without effect.
/s/
SO ORDERED, this dayof _ i , 2018. Theresa Carroll Buchanan
Carroll Buchanan
United Slates Magistrate Judge
Exhibit F
Case 1:17-cv-00761-CMH-TCB Document 48-1
11/27/2017 Filed
The Robing 01/24/18 Page 35 of 46 PageID# 913
Room
where judges are judged

Home
SfiR Rating Details

Hon. Claude M. Hilton
Contact District Judge See Comments
Privacy Notice E.D.Va.

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Average Rating:3.9 - 23 rating(s)
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Occupation ; Criminal Defense Lawyer
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Ratings
'Temperament: . No Opinion ^; (i=Awfui.io=ExceDem)

•Scholarship: j No Opinion*'! {l=Awful.lO=Exceneni)
"Industriousness: INoOpinion • i(l=Noi atall industrious.lO=Highly industrious)
'Ability to Handle Complex : No Opinion "! (l=Awful.lO=Excenent)
Litigation:
'Punctuality: •No Opinion (l=Chronic"y Laie.lO=Always on Time)
'Evenhandedness in Ovil Utigation:, Opjî (l=Demonstrates Bias.lO=Entire^ Evenhanded)

•Evenhandedness in Criminal
' No Opinion • 1(l=Demonstrates Bias.lO=Entirely Evenhanded)
Litigation:
Flexibility InScheduling ;No Opinion •! (i=Compieiety inflexible,io=very Flexible)
General Inclination Regarding Bail ; NoOpinion* i (i=pro-Defense.io=pro-Government)
General Inclination in Criminal
No Opinion • l (l=Pro-Defense.lO=Pro-Government)
Cases, Pre-Triai:
Involvement in Qvil Settlement
: No Opinion * j (l=Leastlnvolved.lO=Most Involved)
Discussions:
NoOpinion *! (l=Pro-Defense.lO=Pro-Governmem)
Cases, Trial:
iNoOpinion*! {l=Most Lenient.10=Most Harsh)
Cases, Sentencing:
Typical Discount Off Guidelines for ;mo opinion* (i=io%.io=ioo%)
Cooperators: '
Items marked with (*) are averaged intothe displayed overall rating
Comments
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Privacy & Terms
http://www.therobingroom,com/Judge.aspx?ID=842#comments 1/6
Case
11/27/2017 1:17-cv-00761-CMH-TCB Document 48-1 FiledRoom
Send e-maa to this roster 7/24/201510:23:00 AM
- Other
Comment it-. 21840
Rating:Not Rated
Comments:
This judgefell asleep more than onceon Terrell Roberson's court case. Did not appear to
be interested at all regarding the case. In 2010, thejudge, the state prosecutors, and the
public defender were all in on making sure that Roberson received a harshsentence.
Anotheryoung black man sentence unfairly.
Send e-maa to this coster 6/2172014 10:14:42 PM
' Civil Litigation - Private

Comment #: 21571
Rating:9.4
Comments:
While this judgepresents a laid-back persona, he is very bright, and he is able to "cut to
the chase," which sometimes causes less experienced counsel to believe wrongly that
he is not fully engaged.
Send e-mail to this poster 2/24/201412:06:36 PM
Civil Litigation - Private

Comment #: 21536
Rating:3.7
Comments:
Judge Hilton is almost unabashedly biased against individual litigants. Ifyou have a
case on behalf of a plaintiff in a civil rights or employment case, or a little-guy-versus-
big-guy case of any kind, you will lose. His decisions lack cohesiveness, and ignoreany
law that is "inconvenient."
Send e-mail to this poster 2/18/2014 2:26:21 PM
Criminal Defense Lawyer

Comment #: 21114
Rating:2.3
Comments:
This judge lacks knowledge, and is not a scholar, nor a reasonable individual. He is quite
mediocre in fact, both as a judge and as a human being.
Send e-mail to this poster lO/U/2013 8:30:58 AM

Comment #: 20946
Rating:9.0 ☆☆☆☆☆☆
Comments:
Judge Hilton is very bright and is able to cut to the chase quickly, but his demeanor
sometimes belies this fact. He is a very good and fair judge.
Send e-mail to this poster 8/9/201311:21:51 AM
:-'Other
http://www.therobingroom.com/Judge.aspx?ID=842#comments 3/6
Case
Comment #: 11935
Rating:1.0
Comments:
I am a reporterwho has sat in on many trials in the Alexandria VA courthouse. IVeseen
; Judge Brinkema, Judge Lee, and others including Hilton. Judge Hilton is a real disgrace
to the position. He falls asleep during argument and testimony, he is completely pro-
• government, and he is very unabashedly anti-Muslim.
T
Send 6-mail to this poster 1/28/2011 5;58;19 PM
- Civil Litigation - Private

Comment #; 10189
Rating:1.6
Comments:
The bottom of the barrel in terms of intellect and fairness.
Send e-mail to this poster 5/17/2010 9:23:35 AM
Litigant
Comment #: 7395
Rating:1.0
Comments:
I, as most of the other people who were solely the customer for Judge Hilton judgments,
believe that he is lazy and shallow. Now, if you are wondering why there is this one
person who left two lovely comments (5681 and 6703) about this judge, then check him
out here: http://www.wcsr.com/defauit.asp?id=86&objld=614 Turns out that he has
worked for Judge Hilton. Surprised now? The U.S. judiciary needs a real shakeout.
Send e-mail to this poster Wni2008 3:41:11 PM
' Civil Litigation - Private

Comment #: 6703
Rating:8.9
Comments:
Judge Hilton is a breath of fresh air. He brooks no nonsense and makes the parties get
to the point. Discovery will not be abused, and trial time will not be wasted in his court.
His opinions are well-reasoned. He knows the law.
^Civil Litigation - Private

Comment #: 6535
Rating:3.5
Comments:
The commentator who mentioned Judge Hilton's pro-government and pro-corporate
defendant bias is exactly correct. I had a civil claim representing a government
employee against the government which the good judge threw out on summary
judgment. His opinion was a cut-and-paste of the government's facts, and did not
mention, even in passing, any of the substantial amount of evidence which I marshaled
that contradicted the government's case. That case was one of my career
disappointments in that the client didnt want to appeal it to the Fourth Circuit - the
decision w£is so very ripe for reversal. If you represent an individual or non-big business
plaintiff, my tip is to non-suit your case if it is assigned to his docket, re-file, and try your
luck of the draw a second time around. He will not give your client the time of day unless
his bank account has seven or eight figures in it.
Sende-mailiothis poster 7/24/2008 8:31:55 AM
http://www.therobingroom.conn/Judge.aspx?ID=842#comments 4/6
Case
Comment #; 6241
Rating:4.0
Comments:
• I believe post4100 is incorrect about his appointment, my recollection is that he was
appointed by Reagan and hewasat theend ofa very long list of potential appointees
I who were not interested. Judge Hilton isa decent and civil man but no one ever accused
him ofbeing the brightest guy in theroom andhe is farfrom being considered a hard
" worker. More often thannothe just doesnt understand the issue before him resulting in
bad and incorrect rulings.
With respectto post5681's comment about JudgeHilton making the rocket docket what
it is today, this demonstrates a total lack of knowledge ofthe history ofthat court. There
were generations ofjudges who sat onthat bench long before Hilton thatfomied the
practices and procedures whichmake the EDVA unique.
Send e-maiUo this poster 5/29/2008 8:07:47 AM

Comment #: 5681
Rating:9.9
Comments:
A great man and a great judge. Hetruly understands that the job of a judgeis to be
neiitral and not intervene unless required to do so. However, he is not scared to dismiss
a bad case earlyon, and is most often correctwhen he does so. Judge Hilton made the
"rocket docket" what it is today: quick and just.

Comment #: 4920
Rating:1.7
Comments:
Incrediblylazy and unwilling to do any actual work. Weints to end each and every case
with ^ little work as possible. Dumb as a rock.WSil come up with any justification to
end a case early, usually siding withthe defense in civil cases for this purpose. Not so
much pro-defense as he is lazy.
- Criminal Defense Lawyer

Comment #: 4508
Rating:2.5
Comments;
1 had a sex discrimination case in front of him, and it had been scheduled for 2 days. We
had a lot of history to talk about. Based on that, I had told my psychiatrist to be our first
witness on the second day (and our last witness for the case). We walked in and Judge
Hiltonannounced that this seemed like a one-day case to him. i spluttered that my
expert couldnt be there that day; he said, in essence, "tough." At 5:001 had finished all
other witnesses, and I asked to recess untilthe next day. He refused the request, and
added, "I guess you rest." He then granted summary judgment to the defense. He was
right - it WAS just a one-day case.
Send e-mail to this poster 8/9/200712:02:55 AM

Comment #: 4100
Rating:2.8
Comments:
This conservative judge who was installed by Bush, has the least sympathy towand civil
litigants; he totally takes the government's side, and very easily rules to dismiss pro se
http://www.therobingroom.com/Judge.aspx?ID=842#comments _ ^ 5/6
Case
civilian complaints to obstruct justice. Heis flexible inscheduling. His ruling in mycase
was very shallowand not present much legal context in it.
Plsnri e-mail to this poster 5/14/2007 10:02:51 AM
- Criminal Defense Lawyer

Comment #: 2194
Raiing:1.3
Comments:
He's cranky,-dim, and purely result-driven. Litigants representing non-corporate clients
shudder when they ieam Claude's been assigned to their cases.
Send e-mail to this poster 9/8/200610:46:13 PM

Comment #: 1933
Rating:2.4
Comments:
As far as I can tell, he just signs one party's briefor the other. IVeseen him do things
like re-dismiss one defendant who was already dismissed voluntarily. IVe always wanted
to submit my briefon disk to see ifthat'll make a difference in the judgment. Very right-
wing, pro-civil-defendant. IVe also seen him nodding off duringargument.
http;//www.therobingroom.com/Judge.aspx?ID=842#comments 6/6
Exhibit G
Case
1/23/2018 1:17-cv-00761-CMH-TCB Document 48-1
Print Filed
Window 01/24/18 Page 41 of 46 PageID# 919
; Subject: Richardson v. Prince William County Government, et al, 17-761 - Plaintiff's Initial
Disclosures
From: edwardricharclson27@yahoo.com
To; jnotz@pwcgov.org
Date: Wednesday, January 10, 2018, 5:43:41 PM EST
Dear Mr. Notz, please see attached.
Regards,
Edward Richardson
ACI / Paralegal
1819 Meadow Drive
P. 540/207-1666
20180110 Plaintiff's Initial Disclosures.pdf

\X 524.2kB
171
Case
1/22/2018 1:17-cv-00761-CMH-TCB Document 48-1 Filed 01/24/18 Page 42 of 46 PageID# 920
Print Window
i Subject: Richardson v. Prince William County Government, et al, 17-761 - First Request for
Production of Documents
To; jnot2@pwcgov.org: ssaunders@pwcgov.org
Date: Thursday, January 18, 2018, 3:22:47 PM EST
Dear Mr. Notz, Please see attached.
Regards,
Edward Richardson
1819 Meadow Drive
P. 540/207-1666
20180118 Plaintiffs First Request for Production of Documents.pdf

'ijti 452kB
1/1
Subject: Re: RE: Richardson v. Prince William County Government, et al -17-761 Requests for
Admission
To: jnotz@pwcgov.org
Date: Thursday. January 18. 2018,12:24:59 PM EST
Dear Mr. Notz, I will not consent to a motion to stay discovery, nor will I appear for a hearing next friday on the
defendants highly improper motion as Itviolates the Court's January 4, 2017 Order, the Court's 30 day hearing notice
requirement, as well as my Roseboro Notice Rights. There is absolutely no reason to stay discovery. Additionally, I will
be in travels over the next several weeks and will be unavailable to appear Court on next Friday in any regard.
Also, have you or the defendants to this action engaged in or seek to engage in confen-al with chambers of either Judge
behind my back and without my knowledge regarding previous, pending and upcoming mlings, legal strategy, or
otherwise in this cause of action? In this regard, there is no claim to privilege and you must answer my question to the
fullest extent.
Regards,
Edward Richardson
Anti-Comjption Investigator / Paralegal
1819 Meadow Drive
P. 540/207-1666
On Thursday, January 18, 2018, 10:52:34 AM EST, Notz, Jeffrey R. <jnotz@pwcgov.org> wrote:
Mr. Richardson,
I will be filing a motion to stay discovery until the court resolves the motion to dismiss and set for hearing
next Friday. Will you agree or consent to a stay of discovery until the Court rules on the dismissal
motions?
Thank you,
Jeff Notz
From: EDWARD RICHARDSON [mailto:edwardrichardson27@yahoo.com]

Sent: Wednesday, January 17, 2018 4:16 PM
To: Notz, Jeffrey R. <jnotz@pwcgov.org>
Subject: Richardson v. Prince William County Government, etal -17-761 Requests for Admission
Regards,
Edward Richardson
1819 Meadow Drive
P. 540/207-1666
E. edwardrichardson27@vahoo.com
Case
1/22/2018 1:17-cv-00761-CMH-TCB Document 48-1 Filed 01/24/18 Page 44 of 46 PageID# 922
Print Window
. Subject; Richardson v. Prince William County Government, et al, 17-761 - First Request for
i Production of Documents
B , , _ ^ - , - -
From; edwardrichardson27@yahoo.com
To; jnotz@pwcgov.org; ssaunders@pwcgov.org
Date; Thursday, January 18, 2018, 3:22:47 PM EST
Regards,
Edward Richardson
1819 Meadow Drive
P. 540/207-1666
20180118 Plaintiffs First Request for Production of Documents.pdf

ICJ 452kB
1/1
Case
1/22/2018 1:17-cv-00761-CMH-TCB Document 48-1 Window
Filed 01/24/18 Page 45 of 46 PageID# 923
4 Subject:Richardson v. Prince William County Government, et al, 17-7611 Interrogatories on

I Defendants Deane eind Hudson
^ From: edwardrichardson27@yahoo.com
To: jnotz(5)pwcgov.org: ssaunders@pwcgov.org
Date: Friday, January 19, 2018, 10:06:26 AM EST
Regards,
Edward Richardson
1819 Meadow Drive
R 540/207-1666
20180119 Interrogatories Charlie T Deane.pdf 20180119 Interrogatories Stephan M Hudson.pdf

L
422.7I<B 425k B
1/1
Case 1:17-cv-00761-CMH-TCB Document 48-1
1/22/2018 Filed 01/24/18 Page 46 of 46 PageID# 924
Print Window
^ subject:Richardson v. Prince William County Government, et al, 17-761 - Interrogatories on

V Defs' Lanham, Vago, Fernald, and Rudy
From edwardricharclson27@yahoo.com
To jnotz(g) pwcgov.org; ssaunders@pwcgov.org
Date Monday, January 22, 2018, 10:41:11AM EST
Regards,
Edward Richardson
Anti-Corruption Investigator I Paralegal
1819 Meadow Drive.
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Document 48 - Emergency Motion To Stay Proceedings

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Document 48 - Emergency Motion To Stay Proceedings

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Case 1:17-cv-00761-CMH-TCB Document 48 Filed 01/24/18 Page 1 of 7 PageID# 872

V. Civil Action No. l:17-cv-761-CMH-TCB

PRINCE WILLIAM COUNTY

PLAINTIFF'S EMERGENCY MOTION TO STAY PROCEEDINGS

of his Motion, Plaintiff states as follows:

an Opposition to Plaintiffs Cross-Motion on November 17, 2017 but proffered no further

Plaintiffs pending Cross-Motion for the Disqualification of Municipal Government Counsel as

remains extremely diligent in his filings with the Court.

progress discovery. United States v. Honeywell International. Inc.. 20 F.Supp.3d 129, WL

Stay the Proceedings.

his Emergency Motion to Stay Proceedings.

A proposed order is attached.

Dated: January 24, 2018 Respectfully submitted.

/s/ Edward Richardson

MICHELLE R. ROBL, ESQ.

JEFFREY R.B. NOTZ, ESQ.

/s/ Edward Richardson

IN THE UNITED STATES DISTRICT COURT

V. Civil Action No. 1:17-cv-761 -CMH-TCB

PRINCE Vv'ILLIAM COUNTY

Plaintiff has filed an Emergency Motion to Stay Proceedings.

Therefore, Plaintiffs Motion is GRANTED.

SO ORDERED, this day of 2018

United States District Court Judge

Case l:17-cv-00761-CMH-TCB Document 26 Filed 12/01/17 Page 1 of 1 PagelD# 747

IN THE I'.MTEl) S'l ATES DISTRICT COUR

All parties shall llle an answer within twcnt) (20) davs,

PERSONAL IDENTIFIERS MUST BE RKDACTEI) FROM ALL PUBLICLY FILED

IN THE UNITED STATES DISTRICT COURT

V. Civil Action No. I:17cv761 (CMH/TCB)

PRINCE WILLIAM COUNTY,

JOINT DISCOVERY PLAN OF ALL DEFENDANTS

will be exchanged on or before January 10, 2018.

basis of their claims. No settlement has been reached.

a. In accordance with this Court's Order of December 1, 2017, all discovery

will be completed no later than April 13, 2018.

weeks before the April 13, 2018, discovery cut-off date.

c. Discovery should not be conducted in phases or limited

incorporated herein. These limitations include no morethan 5 non-party, non-expert witness

e. Should any party believe that additional depositions or interrogatories may

the issue be decided by the court.

30(b)(6) witness at least 5 days in advance of any such deposition.

5. The parties should produce electronically stored information in ".pdf format.

7.. Discovery of Electronicallv Stored Information. Disclosure or discovery of

8. Claims of Privilege or Protection of Trial Preparation Material. The parties will

9. Protective Order. A protective order under Fed. R. Civ. P.

10. Expert Discovery.

a. Pursuant to Local Rule 26(D)(3), the plaintiff shall identify expert

11. Subjects of Discovery. Discovery relevant to the claims anddefenses contained

13. Trial bv Magistrate. The Defendants respectfully do not consent to trial by a

PRINCE WILLIAM COUNTY, BARRY M.

Case l:17-cv-00761-CMH-TCB Document 30 Filed 12/19/17 Page 5 of 6 PagelD# 761

Case l:17-cv-00761-CMH-TCB Document 30 Filed 12/19/17 Page 6 of 6 PagelD# 762

CERTIFICATE OF FILING AND SERVICE

THE UNITED STATES DISTRICT COURT JAN - 3 2018

V . Civil Action No,l:17cv761

Prince William County, et al.,

1. Upon consideration of the representations made by the

a. The proposed Joint Discovery Plan of All Defendants

(Doc. 30) is approved and shall control discovery to the extent

of its application unless modified by the Court.

2. The following provisions shall apply to the filing and

noticing of all motions: