Document 50 - Consolidated-Motion For Recusal Transfer of Venue

Case 1:17-cv-00761-CMH-TCB Document 50 Filed 01/24/18 Page 1 of 10 PageID# 928
FILED
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Alexandria Division fti nt, a o
Iliit ^
EDWARD RICHARDSON, 0! cT"/ 11" H'SirJC '• CO-RT

ALL;;Art--:A. Vuû;:::A
Plaintiff,
V. Civil Action No. l:17-cv-761-CMH-TCB
PRINCE WILLIAM COUNTY

GOVERNMENT, mm.,
Defendants.
PLAINTIFF'S CONSOLIDATED MOTION TO RECUSE HONORABLE CLAUDE M

HILTON AND HONORABLE THERESA C BUCHANAN AND FOR A
CHANGE OF VENUE TO THE NORFOLK DIVISION
Plaintiff Edward Richardson, Pro hereby files this consolidated Motion seeking the
recusals of United States District Court Judge, Claude M. Hilton, and United States Magistrate
Judge, Theresa C. Buchanan, pursuant to Sections 455(a) and 144 of Title 28, and for a change
of venue to this District's Norfolk Division pursuant to Sections 1404(a)(b), 1391(b), and 1331
of Title 28. In support of his Motion, the Plaintiff states as follows:
BACKGROUND
On July 6, 2017, the Plaintiff filed this action against the defendants who had engaged in
a continuous onslaught of constitutional and state law torts all while engaged in a furtive and
maliciously conniving criminal conspiracy, using the Prince William County Police Department
(the "Department") as a storefront while scapegoating the Department's own minority officer
population under unlawfully systemic and serial conditions where the Plaintiff was a targeted
victim of ongoing racial discrimination, profiling, harassment and retaliation.

This case entered discovery on December 5, 2017 upon receipt by the parties of the
Court's December 1, 2017 Order. Dkt, 25 - Court's Scheduling Order. Pursuant to the
Court's Order, the parties filed discovery plans with the Court adopting the joint discovery plan
of the defendants (Dkt. 30) at the January 3, 2018 initial pretrial conference. Dkt 38, 39 -
Initial Pretrial Conference and Rule 16(b) Scheduling Order.
In controlling the order of discovery, the defendants' joint discovery plan requested that
the parties exchange Rule 26(a)(1) initial disclosures on orbefore January 10, 2018, to which the
parties did in fact exchange initial disclosures on said date, therefore, placing discovery into full
effect. The defendants discovery plan further states as follows:
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 be served 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, 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 1, 2017.
The Plaintiff began serving the defendants with discovery requests on January 17, 2018
in the form of requests for admissions, requests for production of documents, and interrogatories
exposing all witness and any and all production requests to the defendants. That appears to have
been the defendants' and the Court's strategy. On January 18, 2018, the defendants almost
immediately engaged in conferral seeking Plaintiffs consent to stay discovery in an all out effort
to escape discovery admissions and production with a proposed hearing date of January 26,
2018, which is an uncharacteristically short period of time to prepare for a hearing. Plaintiff did
not pro-vide his consent due to the fact that discovery was in full effect and because Plaintiff
would notbe in the State during the proposed date. The Plaintiff also asked defendant counsel if
he or the defendants' had engaged in conferral with either Judge assigned to this case, to which
the Plaintiff has not received a response.
In turn, the defendants' filed a motion to stay discovery on January 18, 2018, exhibiting
Plaintiffs discovery requests and e-mail correspondence, which appeared to serve as a tactical
maneuver for guiding the Court on the defendants' motion to dismiss. On January 19, 2018, the
defendants' filed a proposed order to the motion to stay which immediately caught the Plaintiffs
attention because the defendants' have never filed a proposed order with any filing under this
cause of action. On January 22, 2018, the Court granted the defendants' motion to stay discovery
without the Plaintiffs response even though full-blown discovery was in effect. The Court also
adopted the defendants' proposed order verbatim.
The Plaintiff, as a Black man, representing himself pro se is being unlawfully
discriminated against by the Court due to the Plaintiffs race and pro se status. The Plaintiffis
subjected to deaf and obvious bias and prejudice where the Court has favored the defendants'
from the onset. It is based on Plaintiffs reasonable belief and through the defendants' legal
representation refusal to answer Plaintiffs question regarding one-sided conferral that Plaintiff
believes that the Court and the defendants' have engaged in one-sided conferral regarding
strategy and rulings of the case behind the Plaintiffs back and without his knowledge. The
Honorable Claude M. Hilton and Honorable Theresa C. Buchanan must recuse themselves and
this case must be transfen-ed to the Norfolk Division.
ARGUMENT
A change of venue in the interest of justice is proper considering the severely

discriminatory, biased and prejudicial circumstances surrounding this case. Section 1404(a) of
Title 28 provides that: "for the convenience of parties and witnesses, in the interest ofjustice, a
district may transfer any civil action to any other district where it might have been brought." Any
party, including plaintiff, may move for a transfer under 28 U.S.C. § 1404(a). I-T-E- Circuit
Breaker Co. v. Regan, 348 F.2d 403 (8^*^ Cir. 1965); American Standard. Inc. v. Bendix Corp..
487 F. Supp. 254, 260 (W.D. Mo. 1980). A party may move for transfer, even if it has waived
any objection to venue. Montgomery Ward & Co. v. Anderson MotorService. Inc., 339 P. Supp.
713, 718 n.3 (W.D. Mo. 1971). The courtmay also transfer an action sua sponte. LeadIndustries
Association. Inc. v. Occupational Safety and Health Administration, 610 F.2d 70, 79 n.l7 (2d
Cir. 1979); Mobil Corp. v. S.E.C., 550 F. Supp. 67, 69 (S.D.N.Y. 1982). The Plaintiff will be
denied his right to a fair and unbiased trial.
Exhibit D displays the Joint Discovery Plan of the parties in Smallv. Cranmer. etal, 12-
CV-989-LO-IDD where the Prince William County Government is named as a defendant.
PlaintiffSylvester L. Small was represented by legal counsel. Jeff Notz represents the defendants
in that case. Examination of that case proves that the parties had engaged in discovery pending a
ruling on the dispositive motion and minus a motion to stay discovery. Jeff Notz never filed a
motion to stay discovery after the commencement of discovery as he had in this case. History
proves that the Hilton Court has a devote history of one-sided justice in favor of the Prince
William County Government as well as for co-defendant Charlie T. Deane. Plaintiff found not a
single case that made it into trial in the Hilton Court.
4
ONLY SOME OF THE DEFENDANT PRINCE WILLIAM COUNTY CASES

DISMISSED BY THE HONORABLE CLAUDE M. HILTON
1. Hobbs. et al v. Prince William County - Case No. 97-cv-538-CMH - DISMISSED
2. Henry's Wrecker v. Prince William County, et al —Case No. 03-cv-671-CMH -
DISMISSED
3. Williams v. Prince William, et al —Case No. 00-cv-159-CMH —DISMISSED
4. Mian v. Prince William, et al —Case No. 02-cv-l 840-CMH —DISMISSED
5. Cox V. Prince William, et al - Case No. 99-cv-l 880-CMH - DISMISSED
6. Berser v. Prince William County —Case No. 98-cv-00424-CMH —DISMISSED
7. Moorins v. Prince William County Community Serys. et al - Case No. 98-cv-l 151-
CMH - DISMISSED
8. Graham v. Robbins. et al - Case No. 02-cv-l619-CMH - DISMISSED (Prince
William County is listed as a defendant)
9. Williams v. Prince William County —Case No. 99-cv-981 -CMH —DISMISSED
10. Moore v. Prince William Counts/ Jail —Case No. 12-cv-1432-CMH —DISMISSED
11. Moore v. Prince William County Jail - Case No. 12-cv-760-CMH-TCB -
DISMISSED
12. Moore v. Prince William County Jail - Case No. 14-cv-1432-CMH-TCB -
DISMISSED
13. Collins "v. Prince William County, et al —Case No. 03-cv-1455-CMH - DISMISSED
14. Cdllahari v. Prince William County School Board - Case No. 16-cv-167-CMH-MSN
-DISMISSED
15. Williams v. Prince William County DSS, - Case No. 14-cv-1247-CMH-IDD
DISMISSED (Sexual Harassment Case) (Judge Hilton's Dismissal Order vacated by

the Fourth Circuit)
Section 144 requires the moving party to submit a timely and sufficient affidavit of
personal bias and prejudice. Si^ Green v. Branson, 108 F.3d 1296, 1305 (10^^ Cir. 1997). The
Plaintiffs Motion and exhibits attached herewith shall serve as such. Plaintiffs case is ripe for
transfer to another Division. Plaintiff and his associates are now burdened with protecting
witnesses who may be contacted by the defendants. And because the defendants are now aware
of what materials the Plaintiff is now seeking through discovery, they have any and every
opportunity to destroy and or fabricate documents, files and any other materials to offset
discovery. Additionally, the defendants can now tailor their own discovery requests around that
of the Plaintiffs since they have succeeded in sabotagingactive discovery.
"Recusal is required whenever there exists a genuine question concerning a judge's
impartiality, and not merely when the question arises from an extrajudicial source." Litekv v.
United States, 114 S. Ct. 1147 (1994). Here, the matter of impartiality is without question and
Plaintiff is the victim of the Court's ongoing biased, partial and prejudicial conduct. Plaintiff is a
clear target of pretextual judicial misconduct on the basis Plaintiffs race, pro se litigant status
and for Overt favoritism toward the defendants. The Court's and the defendants' reliance on the
Plaintiffs skin color and status of self representation as of determinant of ignorance belies both
the Court and the defendants as the Plaintiff is very well versed in civil rights, constitutional and
employment law. Canons 1 through 5 of the Code of Conduct for United States Judges are
prohibitory of the conduct alleged within this Consolidated-Motion. With respect to venue
considerations, the Plaintiff does not have to show extraordinary change in circumstances before
Plaintiff could obtain a change in venue. Lake City Stevedores v. Steamship Lumber Queen, 343
F.Supp. 933, A.M.C. 445 (S.D. Tex. 1972).
The Norfolk Division has subject matter jurisdiction over Plaintiffs case pursuant to 28
U.S.C. § 1391. The only party subject to any inconvenience would be the Plaintiff due to the fact
that he does not have electronic filing capabilities. The defendants would not be prejudiced.
Credit Alliance Corp. v. Nationwide Mutual Ins. Co., 433 F. Supp. 688 (S.D.N.Y. 1977).
Plaintiff currently has a pending Cross-Motion for Disqualification of Municipal

Government Counsel regarding the individual-capacity defendants, pending rulings on the
Motions for Temporary Restraining Order and Rule 15(c) Amendment, a pending ruling on the
defendants Joint Motion to Dismiss, as well as an appeal of the Court's January 22, 2018 Order
to stay discovery. Plaintiff hereby files an Emergency Motion to Stay the Proceedings pending
disposition of his appeal on the defendants' motion to stay discovery and this Consolidated-
Motion. Plaintiff seeks to have his Cross-Motion, Motions for TRO and Rule 15(c) Amendment,
as well asthe defendants' jointmotion to dismiss all heard bythe Norfolk Division.
As a direct result of the biased, prejudicial and outright racist conduct the Plaintiff has
been subject to by the defendants and the Court, the Plaintiff seeks, recusal ofboth Judge Claude
M. Hilton and Magistrate Judge Theresa C. Buchanan. Plaintiff seeks transferral of this case to
the Norfolk Division of the District where he will seek a fair trial and unimposed discovery of
materials already requested fi'om the defendants'. For the convenience of the parties and
witnesses, and in the interest of justice, the Plaintiff seeks to have this case transferred to the
Norfolk Division.
CONCLUSION
For the foregoing reasons, Plaintiff respectfully requests that this Honorable Court grant
his Consolidated-Motion.
A proposed order is attached.
Dated: January 24, 2018
Respect&lly submitted,
/s/ Edward Richardson

Edward Richardson, Plainti^Pro ^
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, I served the foregoing on
the following by FedEx; United States Postal Service; electronic mail, and / orhand 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, Barry M.
Barnard, Stephan M. Hudson,
Timothy Rudy, Scott A. Vago,
Jay Lanham, Michael A. Femald,
Charlie T. Deane
/s/ Edward Richardson

Edward Richardson, PlaintifiB^ro ^

Alexandria Division
EDWARD RICHARDSON,
Plaintiff,
• V. Civil Action No. r.l7-cv-761-CMH-TCB
PRINCE WILLIAM COUNTY

GOVERNMENT, MaL,
Defendants.
[PROPOSED! ORDER
Plaintiff has filed a Consolidated-Motion for Recusal and for Change of Venue.
Whereas the Court has considered theparties Motions, THE COURT FINDS that
Plaintiffhas 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 50-1 Filed 01/24/18 Page 1 of 48 PageID# 938
Exhibit A
Case l:17-cv-00761-CMH-TCB Document 26 Filed 12/01/17 Page 1 of 1 PagelD# 747
IN THE UNrrKl) STATES DISTRICT COUR^

FOR THE EASTERN DISTRICT OF VIRGIN f DK-S
Alexandria Division
lidward Richardson. CLERK, U.S. DISTRICT COURT
PlainlilT. ALEXANDRIA. VIRfiiMiA '
V.
I^riiice William Coiinly Government, Civil Action No. I:17CV761
Defendant.
ORDER
A l-ed. R. Ci\ . P. 16(b) PRh 1RIAL CGNM'.RI'.NCil will be held on Wedncsdav . December 27.
2017 at II:00 a.m. belore Magistrate Judge Buchanan . The parties shall confer prior to this conference
to consider the claims, defenses, possibilities of a prompt settlement or resolution of the case, trial before
the magistrate judge, to arrange for the disclosures required b\ Rule 26{a)( 1). and develop a discover)
plan which will complete discovers In I'ridav. .April 13. 2018 . .A parly mas not e.vceed five (5) non-
part). non-expert witness depositions nor ser\e on an\ other pan> more than liiiny (30) interrogatories,
including parts and subparts. without lease ol court. Proposed discover) plans must be filed bv the
Wednesdas one week before the Rule 16(b) pretrial conference.
All parties shall llle an answer within twcni> (20) days.
1he I IN.AL PRl". IRI.AL CONI KRIiNCl: will be held on fhursdas. April 19. 2018 at 10:00 a.m.
fhe panics nni.st electronically file on or before the final pretrial conference the Rule 26(a)(3)
disclosures and a list ol the exhibits to be used at trial, a list of the witnesses to be called at trial and a
written stipulation of uncontested lacts. Ihe exhibits themselves ora copy should be e.xchanged with
opposing counsel before the conference. Objections to exhibits must be filed within 10 days after the
conference; otherw ise the exhibits shall stand admitted in e\ idence. Ihe original exhibits shall be
delivered to the clerk as provided by Local Rule 79(A). Non-expert witnesses and exhibits not so
disclo.scd and listed will m)l be permittetl at triiil except for impeachment or rebuttal, and no person mav
jestily w'ho.sc identits, being subject to di.sclosure or timelv requested in di.scoverv, was not disclosed in
time to be deposed or to permit the substance ol his knowledge and opinions to be ascertained. The trial
ofthis ca.se will be set for a day certain, within 4-8 weeks ofthe final pretrial conference.
Discovery may begin upon receipt of this Order.
PERSONAL IDEN'ITFIEUS MUST BE RICDACTF.I) FROM ALL PUBLICLY FILED

PLEADINGS AND EXHIBITS IN ACCORDANCE WITH LOCAL RULE 7(C).
C l.AUDr. M. MILTON
I 'Ni ri:i) S I A ri;s distric t .luixjii
December / .2017
.Alexandria. Virginia
Ihis order is being mailed or e-mailed to locjil ci>unsel onK.

(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, possibilitiesof a prompt settlement, and a trial before a magistratejudge 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. Discover/ 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 be served 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, but shall be subject to the right of any party to objectto 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 more than 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 discoveryrequests. 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 the material withheld from production with sufficient particularity as to
allow the requesting party to make an informed decision as to the privileged orimmune nature of
the information or material, and should comply with Fed. R. Civ. P. 26(b)(5). Communications
between counsel and client need not be identified or listed on a schedule of 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,
if practicable, may respond to those requests by electronic means. Such request and responses
shall be deemed to have been served by ECF delivery.
7., Discoverv of Electronically Stored Information. 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 itsoriginal format.
Thereafter, either party may request theproduction of electronically stored information in its
native format.
8. Claims of Privilege or Protection of Trial Preparation Material. The parties will
adhere to the procedure set forth 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 on the
terms of a stipulated protective order to be submitted to the Court for consideration. Inadvertent
production of privileged material will not constitute a waiver of privilege. Upon anyinadvertent
production of privileged material, the parties should resolve such claims in accordance 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 later than 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 and defenses contained
in the pleadings will beappropriate, subject to all objections permitted bythe applicable rules.
12. The parties understand and agree that discovery may be needed on the following
subjects: (a) the facts and allegations underlying the causes of the action 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 of December, 2017,1 emailed the foregoing to the
following non-filing user, and sent a copy by U.S. mail, first-class postage pre-paid:
Edward Richardson
1819 Meadow Drive
Fredericksburg, VA 22405
540-207-1666
Email: edwardrichardson27@yahoo.com
PROSE
MICHELLE R. ROBL
County Attorney
/s/
JEFFREY R. B. NOTZ, VSB# 41755
Assistant County Attomey
Telephone: (703) 792-6620
Telefax: (703) 792-6633
jnotz@pwcgov.org
Exhibit B
fNITlAL PR£TRiAL CONPEfUENCE
MAGrSTRATE JUDGE
CA- n^v7^/
DATE: I
TIME: H.IUftn-i TO
APPEARANCES COUNSEL FOR;
( )PLANT[FF (X) defendant •(;() PROSE PLAINTIFF ( ) PRO SE DEFENDANT
DISCOVERY PLAN: T>eT=T"S
(X) APPROVED ( ) APPROVED AS AMENDED ( ) FILE BY
CONSENT TO PROCEED BEFORE A MAGISTRATE JUDGE;
( )YES
( ) CONSENT SIGNED
ADR/SETTLEMENT;
( ) PENDING ( ) WILL DISCUSS ( )OTIiER
()() ORDER TO ISSUE
CASE CONTINUED TO FOR 16(B) CONFERENCE
Case l:17-cv-00761-CMH-TCB Document 39 Filed 01/03/18 Page 1 of 5 Page!D# 809
THE UNITED STATES DISTRICT COURT ^ JAN - 3 2018 •

FOR THE EASTERN DISTRICT OF VIRGINIA I
Alexandria Division -'..t
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 Court'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 thcui 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 movant 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 judgment.
(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. Itocal 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, with
the remainder filed in the public record. An unsealed, 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.
/s/
iieiesa Carroll Bucfianan
nited Stales Magistrate Judge
Theresa Carroll Buchanan

United States Magistrate Judge
Date: January 3, 2 018

Alexandria, Virginia
Exhibit C

EDWARD RICHARDSON,
Plaintiff,

BARRY M. BARNARD,
STEPHAN M. HUDSON
CHARLIE T. DEANE
TIMOTHY RUDY
SCOTT A. VAGO
JAY LANHAM
MICHAEL A. FERNALD
Defendants.
DEFENDANTS* RULE 26rAHn DISCLOSURES
COME NOW, THE DEFENDANTS, Prince WilliamCounty, BarryBarnard,
Stephan Hudson, Charlie Deane, Timothy Rudy, Scott Vago, Jay Lanham and Michael
Femald, byCounsel, 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
do Jeflrey R. B. Notz, Prince William County Attorney's Office

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

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

Telephone: (703) 792-6620
Facsimile: (703) 792-6633
3. Charlie T. Deane
c/o Jeffrey R. B. Notz, Prince William County Attorney's Office

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

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

Telephone: (703) 792-6620
Facsimile: (703) 792-6633
Information includes Plaintiffs work history and performance, internal affairs

uivestigations
6. Jay Lanham

Telephone: (703) 792-6620
Facsimile: (703) 792-6633
Information includes Plaintiffs work history and performance, 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, contentsof investigatory and Police
Department disciplinary files, information disclosure procedures
9. Andrea R. Brenner (Piince William CountyHuman 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 resources and information disclosure procedures
10. Lieutenant Eileen M. Welsh (Commander Police Departm.ent Personnel)
Prince William County Police Personnel Bureau

9540 Center Street, Suite 101
Manassas, Virginia 20110
Telephone: (703) 792-6580
Facsimile: (703) 792-4205
InfoiTnation includes keeping of police personnel 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
Information 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 such complaints and investigations, contents of
such files, and processing of EEOC claims
13. PatraE. Wright (Current EEO and Diversity Director for 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
Facscnile: (703) 792-6510

15. Jeffrey L. King
13512 Photo Drive

Information includes Plaintiffs work history and perfonnance
16. Louis A. Marshall
17 St. Albans Boulevard

Stafford, Virginia 22556

17. Melvin C. Quattlebaum
4752 Hickory Nut Place

Montclair, V irginia 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. Downey

15948 Donald Curtis Drive
Telephone: (703) 792-7200
Facsimile: (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 Princs WiUiam Parkway
Telephone: (703) 792-7254
Facsimile: (703) 792-4555
Information includes Plaintiffs work history and performance, internal affairs

investigations
21. Lieutenant Craig S. Lawhead

89G0 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 specificity but
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 m Plaintiffs

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

B. Description ofdocuments and other tangible items currently in Defendants' possession

that may be used to support defenses, and their location:
Prince William CountyPersonnel Manual. Copies are located at Prince

William County Human Resources, 4380 Ridgewood Center Drive, Prince
William, Virginia 22192
Prince William County Police Department standard operating procedures,

rules and regulations as they relate to this lawsuit. Copies arelocated at
Prince William County Police Department, OneCounty 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 and complaints 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 m
section A, above.
i Copies of EEOC charges of employment discrimination filed byPlaintiff and the

coiTesponding 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 counsel.
C. Not applicable to defendant.
D. Insurance:
Prince William Countyand its employees are insured by the Prince William Self-
Insurance Group up to a retained amount of $750,000 and maintain excess insurance in
the amount of$10 million through Genesis Reinsurance. Contact: Johmiie 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
MICHELLE R. ROBL
County Attorney
/s/
JEFFREY R.B. NOTZ, VSB# 41755
Telephone: (703) 792-6620
Telefax: (703) 792-6633
inotz@pwcgov.org
Counsel f:>r Defendants
CERTIFICATE OF FILING AND SERVICE
I hereby certify thaton this 10'" dayof Januaiy, 2018,1 sentthe 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
PRO SE
MICHELLE R. ROBL
County Attorney
/s/
JEFFREY R. B. NOTZ, VSB#41755
Telephone: (703) 792-6620
Telefax: (703) 792-6633
jnotz@pwcgov.org
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.
l:12cv989(LO-IDD)
JENNIFER M. CRANMER,
and
PRINCE WILLIAM COUNTY;
Defendants.
lOINT 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 on December 5, 2012. Theplaintiff agrees to make his initial 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 ofany 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 in its native format.
6. Claims of Privilege or Protection of Trial Preparation Material. Theparties
will adhere to the procedure set forth in Fed. R. Civ. P. 26(b)(5)(B) with respect to privileged
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 shall make its
expert disclosures, if any, no later than February 11,2013; that Defendant shall make its expert
disclosures, if any, 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, if any, in accordance with Rule 26 of the Federal Rules of Civil Procedure and the
Local Rules, except as indicated herein.
9. Subjects ofDiscoverv. The parties agree that discovery relevant to the 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.
The parties respectfully request that the Court adopt this discovery plan.
Dated: December 21st, 2012 Resprctfully
Benjamin G. Chew
Gregory Louer
Caroline A. Davidson-Hood
PATTON BOGGS LLP
2550 M Street, N.W.
Wasliington, DC 20037
Telephone: 202-457-6000
Facsimile: 202-457-6315
Email: bchew@pattonboggs.com
glouer@pattonboggs.com
cdavidsonhood@pattonboggs.com
Counselfor 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
PFRTTFirATE 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
Carla Hellwig
Exhibit E

EDWARD RICHARDSON,
Plaintiff,

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 is appropriate
pending the Court's ruling on the Defendant's Motion to Dismiss (Dkt.7). Therefore, itis hereby
ORDERED that the Defendant's Motionto Stay Discovery (Dkt. 42) is GRANTED.
IT IS FURTHER ORDERED thatif any of the Plaintiffs claims remain afterthe ruling
onthe Motion to Dismiss, the parties shall submit a revised discovery plan tailored to address the
remaining claims.
IT IS FURTHERORDERED that the parties shall refrain from propoundingdiscovery
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 withouteffect.
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,
Plaintiff,
V. Civil Action No. I:l7cv761 (CMH/TCB)

el a!..
Defendanis. )
ORDER STAYING DISCOVERY
THIS MA ITER comes before the Court on Defendants' Motion to Slay Discovery (Dkt.
42). Upon review ofthe pleadings, ihe 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 Slay 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 lhat any existing discovery requests arc without effect.
1^ /s/
SO ORDERED, this day of Al ,2018. Theresa Carroll Buchanan
Tneresa Carroll Buchanan

Exhibit F
Case 1:17-cv-00761-CMH-TCB Document 50-1
n/27/2017 Filed
The Robing 01/24/18 Page 35 of 48 PageID# 972
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What others have said about Hoit. Qaude M. Hilton
Comments
-Civil Litigation - Private

Comment #: 23511
Rating:1.0 ☆☆☆☆☆☆☆☆☆☆
Comments:
Themostprejudice judge with regard to average and below average income United
States citizens that I have ever observed. This judge has no sense whatsoever of the
search for Truth and Justice and he clearly avoids any reasonable search for Truthand
Justice, especially ifa large corporation orthe federal government is the defendant! If
there is an obscure aile or law that he can cite to dismiss an otherwise valid complaint
against large corporations orthe federal govemment, he will go to no endto searchfor
and locate such and, once found, he will immediately dismiss the case in-espective of
the facts presented by the average income United States citizenknowing full well that
the average cind belowaverage income United States citizen has no recourse
whatsoeverforthe wrongs perpetrated upon himor her by the Corporation or the federal
agency before Oaude M Hilton's court!
Send e-maa to this poster 6/2/2016 2:13:47 PM
Litigant
Comment #: 23006
Rating:1.0
Comments;
Judge Hilton's reputation, as articulatedon this page, is very sadly accurate. Neither
case facts, recent case law, nor case evidence appear to be as valued as his pro-
government stance. I agree with comments #6535and #22996; runfrom Hilton unless
you represent govemment.
send e-mail to this poster 9/1/2015 6:00:01 PM
"^Litigant
Comment #: 22996
Rating:1.0
Comments:
My observations are in line with the majority of commenters and particularly #6535. He
dismissed case oh summary judgment, and his opinion was full of factual en-ors. It was
clear he did not read the plaintiffs evidence. Shameful. I cant stress this enough: if you
draw Hilton, re-file.
send e-mail to this poster 8/25/2015 7:41:00 PM
-Criminal Defense Lawyer

Comment #: 22951
Rating:2.7
Comments:
Judge Hilton is the bottom of the judicial barrel. He refuses to give defense counsel a full
hearing of issues, he steamrolls through the process. He is not thoughtful or intelligent or
in any way curious, he's just doing the job for a paycheck even though he's already in
his mid 70s. There were four blatantly reversible errors in the one day trial we had before
him - most egregiously, refusing counsel the right to make a record - and he issued
summary denials of all pretrial motions without argument. He fell asleep six times in the
one-day trial. He has no business on the federal bench.
http://www,therobingroom.com/Judge.aspx?ID=842#comments 2/6
Case
Send e-maD to this poster 7/24/201510:23:00 AM
-Other
Comment #: 21840
Rating;Not Rated
Comments:
Thisjudgefell asleep morethan once on Terrell Roberson's courtcase. Did not appearto
be interestedat allregarding the case. In 2010, the judge, the state prosecutors, and the
public defender wereall in on making sure that Roberson received a harsh sentence.
Anotheryoung black man sentence unfairly.
Send e-mail to this poster 6/21/2014 10:14:42 PM
OCivll Litigation - Private

Comment #: 21571
Rating:9.4
Comments:
While this judge presents 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
3Civil 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 plaintiffin a civil rights or employment case, or a little-guy-versus-
big-guycase of any kind, you will lose. His decisions lack cohesiveness, and ignore any
law that is "inconvenient."
Sende-mailtothis 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 10 this poster 10/11/2013 8:30:58 AM
Criminal Defense Lawyer

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
COther
Case
Comment #; 11935
Rating:1.0
Comments:
i 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
* totheposition. He falls asleep during argument and testimony, heis completely pro-
' government, and he is veryunabashedly anti-Muslim.
^ Send e-mail tothis poster 1728/20115;58.19 PM
-Civil Litigation - Private

Comment #: 10189
Rating:1.6
Comments:
The bottom of the barrel in temis 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 Hiltonjudgments,
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/default.asp?id=86&objld=614 Tums out that he has
worked for Judge Hilton. Surprised now? The U.S. judiciary needs a real shakeout.
Send e-mail to this poster 11/11/2008 3:41:U 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 willnot 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 cut on summary
judgment. His opinion was a cut-and-paste of the govemment's facts, and did not
mention, even in passing, any of the substantial amount of evidence which I marshaled
that contradicted the govemment'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 was 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.
ggnîg-TOilWthiSpo^l^r 7/24/2008 8:31:55 AM
Case
r^Criminal Defense Lawyer
Comment #: 6241
Rating:4.0 ☆☆☆☆☆☆
' Comments:
i I believe post 4100is incon-ect abouthis appointment, my recollection is that he was
a appointed by Reagan andhe was at the endofa very long listof potential appointees
whowere not interested. Judge Hilton is a decent and civil man but no one ever accused
- him of being the brightest guyin the room and he is farfrom being considered a hard
worker. More oftenthan not he just doesnt understand the issue before him resulting in
bad and incorrect rulings.
With respect to post 5681'scomment about Judge Hilton making the rocketdocketwhat
it is today, this demonstratesa total lack of knowledge of the history of that court. There
weregenerations of judgeswhosat on that bench long before Hilton that formed the
practices and procedures whichmake the EDVA unique.
- Civil Litigation - Private

Comment ft: 5681
Rating:9.9
Comments:
A great man and a great judge. He truly understands that the job of a judge is to be
neutral and not intervene unless required to do so. However, he is not scared to dismiss
a bad case early on, and is most often correct when he does so. Judge Hilton made the
"rocket docket" what it is today: quick and just.
'Civil Litigation - Private

Comment #: 4920
Rating:i.7
Comments:
Incredibly lazy and unwilling to do any actual work. Wants to end each and every case
with ^ littlework as possible. Dumb as a rock. Will come up withany 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;
I 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
Hilton announced that this seemed like a one-day case to him. I spluttered that my
expert couldn't be there that day; he said, in essence, "tough." At 5:001 had finished all
other witnesses, and I asked to recess until the 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 ths poster 8/9/2007 12:02:55 AM
Xivil Litigation - Private

Comment #: 4100
Rating:2.8
Comments:
This conservative judge who was installed by Bush, has the least sympathy toward civil
litigants: he totally takes the government's side, and very easily rules to dismiss pro se
11/27/2017
Case The Robing
1:17-cv-00761-CMH-TCB Document 50-1 FiledRoom
01/24/18 Page 40 of 48 PageID# 977
civilian complaints to obstruct justice. He is flexible in scheduling. His ruling in my case
was very shallow and not present much legal context in it.
SgntI 9-m?il to this 5/14/200710:02:51 AM
- Criminal Defense Lawyer

Comment .#: 2194
Rating:1.3
Comments:
He's cranky,-dim, and purely result-driven. Litigants representing non-corporateclients
shudder when they iesm aaude's been assigned to their cases.
Send e-mailtoths poster 9/8/2006 10:46:13 PM
- Civil Litigation - Private

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. I've always wanted
to submit my briefon disk to see ifthat'll make a differencein the judgment. Very right-
wing. pro-civil-defendant. IVe also seen him nodding off duringargument.
http://www.therobingroom.com/Judge.aspx?ID=842#comnrients 6/6
Exhibit G
Case
1/23/2018 1:17-cv-00761-CMH-TCB Document 50-1 Filed
Window01/24/18 Page 42 of 48 PageID# 979
5 Subject: Richardson v. Prince William County Government, et al, 17-761 - Plaintiff's Initial
t Disclosures
From; edwardrichardson27@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
ACII Paralegal
1819 Meadow Drive
P. 540/207-1666
20180110 Plaintiff's Initial Disclosures.pdf

524.2kB
1/1
Subject: Re: RE: Richardson v. Prince William County Government, et al -17-761 Requests for
Admission
From: edwardrichardson27@yahoo.com
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 it violates 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 conferral with chambers of either Judge
behind my back and without my knowledge regarding previous, pending and upcoming rulings, legal strategy, or
othenwise 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-Cormption 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, et al -17-761 Requests for Admission
Regards,
Edward Richardson
Antl-Conuption Investigator / Paralegal
1819 Meadow Drive
P. 540/207-1666
E. edwardrichardson27@vahoo.com
Case
1/22/2018 1:17-cv-00761-CMH-TCB Document 50-1
P''int Filed
Window 01/24/18 Page 44 of 48 PageID# 981
7 Subject; Richardson v. Prince William County Government, et al, 17-761 - First Request for
* Production of Documents
From: edwardricharcison27(5)yahoo. com

To: jnotz@pwcgov.org: ssaunciers@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

452kB
1/1
Case
1/22/2018 1:17-cv-00761-CMH-TCB Document 50-1 Filed 01/24/18 Page 45 of 48 PageID# 982
PrintWindow
I Subject: Richardson v. Prince William County Government, et al, 17-761 - First Request for
* Production of Documents
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

452kB
1/1
Case
1/22/2018 1:17-cv-00761-CMH-TCB Document 50-1 Filed 01/24/18 Page 46 of 48 PageID# 983
Pi'intWindow
^ Subject;Richardson v. Prince William County Government, et al, 17-7611 Interrogatories on

i Defendants Deane and Hudson
From; edwardrichardson27@yahoo.com
To; jnotz@pwcgov.org: ssaunders@pwcgov.org
Date; Friday. January 19, 2018, 10:06:26 AM EST
Regards,
Edward Richardson
1819 Meadow Drive
P. 540/207-1666
20180119 Interrogatories Charlie T Deane.pdf 20180119 Inten-ogatories Stephan M Hudson.pdf

422.7kB 425kB
1/1
Case 1:17-cv-00761-CMH-TCB Document 50-1
1/22/2018 Print Filed
Window 01/24/18 Page 47 of 48 PageID# 984
( subject:Richardson v. Prince William County Government, et al, 17-761 - Interrogatories on

i Defs' Lanham, Vago, Fernald, and Rudy
To: jnotz@pwcgov.org: ssaunders@pwcgov.org
Date: Monday, January 22, 2018, 10:41:11 AM EST
Regards,
Edward Richardson
1819 Meadow Drive
P. 540/207-1666
E.edwardrichardson27@yahoo.com
20180122 Interrogatories Jay Lanham.pdf 20180122 Interrogatories Michael Fernald.pdf

421.6kB 423. IkB
20180122 Inten-ogatories ScottAVago.pdf 20180122 Interrogatories Timothy Rudy.pdf

431.4kB 429.7k B
1/1
UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF VIRIGINIA
DIVISION
njc4a L
PlaintifF(s),
V.
Civil Action Number: / 7'C
;fendant(s)
Defendant(s).
LOCAL RULE 83.1(M) CERTIFICATION
I declare under penalty ot perjury that:

; -HrTtd^ A.^dlfo^cc^he,Th^jhsS^Cr,
No attorney has prepared, or assisted in the preparation /LaâP
îtle ofDûmei^)
of Document)
Name
Sigp^re ofVro Se Party

Executed on: (Date)
OR
The following attorney(s) prepared or assisted me in preparation of

(Title of Document)
(Name of Attomey)
(Address of Attomey)
(Telephone Number ofAttomey)

Prepared, or assisted inthe preparation of, this document
(Name ofProSe Party (Print orType)
Signature ofPro Se Party

Executed on: (Date)

Document 50 - Consolidated-Motion For Recusal Transfer of Venue

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Document 50 - Consolidated-Motion For Recusal Transfer of Venue

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Case 1:17-cv-00761-CMH-TCB Document 50 Filed 01/24/18 Page 1 of 10 PageID# 928

EDWARD RICHARDSON, 0! cT"/ 11" H'SirJC '• CO-RT

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

PRINCE WILLIAM COUNTY

PLAINTIFF'S CONSOLIDATED MOTION TO RECUSE HONORABLE CLAUDE M

of Title 28. In support of his Motion, the Plaintiff states as follows:

victim of ongoing racial discrimination, profiling, harassment and retaliation.

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

will be completed no later than April 13,2018.

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

c. Discovery should not be conducted in phases or limited in advance to

the Plaintiff has not received a response.

adopted the defendants' proposed order verbatim.

The Plaintiff, as a Black man, representing himself pro se is being unlawfully

this case must be transfen-ed to the Norfolk Division.

A change of venue in the interest of justice is proper considering the severely

denied his right to a fair and unbiased trial.

CV-989-LO-IDD where the Prince William County Government is named as a defendant.

single case that made it into trial in the Hilton Court.

ONLY SOME OF THE DEFENDANT PRINCE WILLIAM COUNTY CASES

1. Hobbs. et al v. Prince William County - Case No. 97-cv-538-CMH - DISMISSED

2. Henry's Wrecker v. Prince William County, et al —Case No. 03-cv-671-CMH -

3. Williams v. Prince William, et al —Case No. 00-cv-159-CMH —DISMISSED

4. Mian v. Prince William, et al —Case No. 02-cv-l 840-CMH —DISMISSED

5. Cox V. Prince William, et al - Case No. 99-cv-l 880-CMH - DISMISSED

6. Berser v. Prince William County —Case No. 98-cv-00424-CMH —DISMISSED

8. Graham v. Robbins. et al - Case No. 02-cv-l619-CMH - DISMISSED (Prince

William County is listed as a defendant)

9. Williams v. Prince William County —Case No. 99-cv-981 -CMH —DISMISSED

11. Moore v. Prince William County Jail - Case No. 12-cv-760-CMH-TCB -

12. Moore v. Prince William County Jail - Case No. 14-cv-1432-CMH-TCB -

15. Williams v. Prince William County DSS, - Case No. 14-cv-1247-CMH-IDD

DISMISSED (Sexual Harassment Case) (Judge Hilton's Dismissal Order vacated by

"Recusal is required whenever there exists a genuine question concerning a judge's

F.Supp. 933, A.M.C. 445 (S.D. Tex. 1972).

Plaintiff currently has a pending Cross-Motion for Disqualification of Municipal

A proposed order is attached.

Dated: January 24, 2018

/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. r.l7-cv-761-CMH-TCB

PRINCE WILLIAM COUNTY

SO ORDERED, this day of 2018

United States District Court Judge

IN THE UNrrKl) STATES DISTRICT COUR^

All parties shall llle an answer within twcni> (20) days.

PERSONAL IDEN'ITFIEUS MUST BE RICDACTF.I) 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

claims, defenses, possibilitiesof a prompt settlement, and a trial before a magistratejudge as

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

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

the issue be decided by the court.