United States District Court in the Eastern District of Michigan Southern Division
Case 2:20-cv-11053-MAG-RSW ECF No. 22 filed 05/04/20 PageID.825 Page 1 of 34 UNITED STATES DISTRICT COURT IN THE EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION ELLIOTT ABRAMS, CRAIG SEEGMILLER, VINCENT GLASS, ROBERT REEVES, and LAMONT HEARD, individually, and on behalf of all others similarly situated, Plaintiffs, -v- Case No. 2:20-cv-11053-MAG-RSW Hon. Mark A. Goldsmith WILLIS CHAPMAN, Warden, Macomb Maj. Judge R. Steven Whalen Correctional Facility; NOAH NAGY, Warden at G. Robert Cotton Correctional Facility (JCF); MELINDA BRAMAN, Warden, Parnall Correctional Facility (SMT); BRYAN MORRISON, Warden Lakeland Correctional Facility (LCF); HEIDI WASHINGTON, Director of the Michigan Department of Corrections, sued in their official capacities only, Defendants. PLAINTIFFS’ EMERGENCY MOTION FOR TEMPORARY RESTRAINING ORDER & INJUNCTIVE RELIEF AND BRIEF IN SUPPORT Plaintiffs, Elliott Abrams, Craig Seegmiller, Vincent Glass, Robert Reeves, and Lamont Heard, on behalf of themselves and all others similarly situated, by and through their counsel, Daniel E. Manville, Michigan State University Clinical Law Professor, hereby move this Court, pursuant to Fed. R. Civ. P. 65, for entry of a Temporary Case 2:20-cv-11053-MAG-RSW ECF No. 22 filed 05/04/20 PageID.826 Page 2 of 34 Restraining Order and Injunctive Relief. As demonstrated in the following brief, Defendants have violated the Eighth Amendment to the U.S. Constitution by failing to provide Plaintiffs with reasonably safe living conditions in the face of the current COVID- 19 pandemic. As a result, Plaintiffs seek entry of a temporary restraining order requiring Defendants to take additional precautions to stem the spread of the virus.
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