Brown v. Venettozi

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

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