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    Offer of Judgment For Small v. DOCCS/State of NY

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    Rachel Silberstein
    The document is an offer of judgment from the New York State Department of Corrections and Community Supervision in a civil case brought by Pamela Small. The offer allows judgment to be entered against the department and its employees for $600,000, plus attorney's fees and costs, to resolve all claims in the action. The offer is not an admission of liability or wrongdoing by the defendants.

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    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd

    Offer of Judgment For Small v. DOCCS/State of NY

    Uploaded by

    Rachel Silberstein
    172 views3 pages
    The document is an offer of judgment from the New York State Department of Corrections and Community Supervision in a civil case brought by Pamela Small. The offer allows judgment to be entered against the department and its employees for $600,000, plus attorney's fees and costs, to resolve all claims in the action. The offer is not an admission of liability or wrongdoing by the defendants.

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    Offer of judgment for Small v. DOCCS/State of NY

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    Offer of judgment for Small v. DOCCS/State of NY

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    The document is an offer of judgment from the New York State Department of Corrections and Community Supervision in a civil case brought by Pamela Small. The offer allows judgment to be entered against the department and its employees for $600,000, plus attorney's fees and costs, to resolve all claims in the action. The offer is not an admission of liability or wrongdoing by the defendants.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    172 views3 pages

    Offer of Judgment For Small v. DOCCS/State of NY

    Uploaded by

    Rachel Silberstein
    The document is an offer of judgment from the New York State Department of Corrections and Community Supervision in a civil case brought by Pamela Small. The offer allows judgment to be entered against the department and its employees for $600,000, plus attorney's fees and costs, to resolve all claims in the action. The offer is not an admission of liability or wrongdoing by the defendants.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 3

    Case 1:12-cv-01236-WMS-MJR Document 144 Filed 08/28/17 Page 1 of 3

    UNITED STATES DISTRICT COURT


    WESTERN DISTRICT OF NEW YORK
    ___________________________________

    PAMELA S. SMALL,

    Plaintiff, 12-CV-01236
    -vs-

    THE STATE NEW YORK, THE NEW YORK OFFER OF JUDGMENT


    STATE DEPARTMENT OF CORRECTIONS
    AND COMMUNITY SUPERVISION, CARL CUER,
    individually and as a Corrections Officer for the New
    York State Department of Corrections and
    Community Supervision, JAMES CONWAY,
    Individually and as Superintendent for Attica
    Correctional Facility, SANDRA DOLCE,
    individually and as Deputy Superintendent of
    Programs for Attica Correctional Facility,

    Defendants.
    ___________________________________

    Defendant State of New York Department of Corrections and Community

    Supervision in this action offers to allow judgment to be taken against it and its past and

    present employees in their official capacities in this action by the plaintiff Pamela Small

    for the sum of six-hundred thousand dollars ($600,000), together with attorney fees and

    costs accrued to this date. This offer is made pursuant to Rule 68 of the Federal Rules

    of Civil Procedure, and evidence of this offer is not admissible except in a proceeding to

    determine attorney fees and costs. This offer of judgment is neither to be construed as

    an admission of liability and wrongdoing on the part of any of the defendants and the

    State of New York Department of Corrections and Community Supervision and its

    employees, nor as an admission that the plaintiff has suffered any damages caused by

    the wrongdoing of the defendants and the State of New York Department of Corrections

    and Community Supervision and its employees.

    1
    Case 1:12-cv-01236-WMS-MJR Document 144 Filed 08/28/17 Page 2 of 3

    This offer of judgment represents an award in compensation for all claims

    asserted by Plaintiff in this action against the defendants in their official and individual

    capacities and all the relief available to plaintiff in this action against the defendants in

    their official and individual capacities.

    ERIC T. SCHNEIDERMAN
    Attorney General of the State of New York
    Attorney General for the State of New York
    Attorney for Defendants NYS DOCCS, Conway &
    Dolce

    /s/ J. Richard Benitez


    J. RICHARD BENITEZ
    Assistant Attorney General, of Counsel
    NYS Office of the Attorney General
    144 Exchange Boulevard, Suite 200
    Rochester, New York 14614
    Telephone: (585) 546-7430
    [email protected]

    2
    Case 1:12-cv-01236-WMS-MJR Document 144 Filed 08/28/17 Page 3 of 3

    CERTIFICATE OF SERVICE

    I certify that on August 28, 2017, I electronically filed the foregoing Offer of

    Judgment with the Clerk of the District Court using CM/ECF system, which sent

    notification of such filing to the following:

    1. David Hunt Nelson [email protected],


    [email protected], [email protected]

    2. Jennifer A. Shoemaker [email protected],


    [email protected], [email protected]

    3. Jennifer M. Wilkinson [email protected],


    [email protected], [email protected]

    4. James M. Wujcik [email protected],


    [email protected], [email protected]

    5. Alina Nadir [email protected],


    [email protected], [email protected]

    ERIC T. SCHNEIDERMAN
    Attorney General of the State of New York
    Attorney for Defendants NYS DOCCS, Conway &
    Dolce

    /s/ J. Richard Benitez


    J. RICHARD BENITEZ
    Assistant Attorney General of Counsel
    NYS Office of the Attorney General
    144 Exchange Boulevard, Suite 200
    Rochester, New York 14614
    Telephone: (585) 546-7430
    [email protected]

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