IN THE UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF ALABAMA 

NORTHERN DIVISION 

JEREMIAH W. GREEN, ) 

 ) 

 Plaintiff, ) 

 ) 

v. ) CIVIL ACTION NO. 2:06-cv-667-WKW-WC 

 ) 

ELMORE COUNTY JAIL, et al., ) 

 ) 

 Defendants. ) 

MOTION TO SUPPLEMENT DEFENDANT’S SPECIAL REPORT

COMES NOW Elmore County, Alabama Jail Warden Sue Roberts, Defendant in the 

above-styled cause, and submits this Motion to Supplement her Special Report as ordered by this 

Court. As grounds for so moving the Defendant states as follows: 

1. Defendant Roberts filed her Special Report on October 25, 2006. 

2. On November 13, 2006, Plaintiff filed, inter alia, a Motion to Stay Proceedings 

and Motion to Compel Defendant Sue Roberts to Comply with the Court’s Order of August 17, 

2006. 

3. In an Order issued November 15, 2006, the Court denied Plaintiff’s Motion to 

Stay Proceedings and granted in part and denied in part Plaintiff’s Motion to Compel Defendant 

Roberts to fully comply with the Court’s August 17, 2006 Order of procedure. Order (Doc. #27). 

4. Defendant Roberts, in an effort to comply with the Court’s November 15, 2006 

Order, now submits copies of the policy, guidelines, and/or regulations which concern the 

policies referenced in Defendant Roberts’s affidavit filed in support of her Special Report, along 

with any and all documents, records, guidelines, etc., which are maintained and/or kept by the 

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Elmore County Jail in the ordinary course of business which concern matters pertaining to the 

care and housing of inmates/detainees with communicable diseases. 

5. Defendant Roberts wishes to clarify in advance any potential confusion that may 

arise from the policies, guidelines and/or regulations accompanying this Motion. The Court 

ordered Defendant to submit copies of the policy, guidelines, and/or regulations which concern 

the policies referenced in Defendant Roberts’ affidavit filed in support of her Special Report, 

which Defendant Roberts does via this Motion. Order (Doc. #27). However, the print version of 

the Elmore County Jail Policy and Procedure Manual has not recently been revised and republished so as to reflect the current Elmore County Jail Policy and Procedure Statement 

regarding “Special Clothing.” For that reason, the Elmore County Jail Policy and Procedure 

Statement regarding “Special Clothing” submitted with this Motion does not reflect the current 

policy and procedure of the Elmore County Jail as to the specific color of uniform to be worn by 

designated classes of inmates. 

6. The current policy and procedure of the Elmore County Jail regarding the color of 

uniform to be worn by federal inmates/detainees was set out in Defendant Roberts’ affidavit and 

provides that federal inmates/detainees at the Elmore County Jail are required to wear a red 

uniform. Affidavit of Sue Roberts (Doc. #19), ¶ 6. The current policy and procedure is the same 

as the policy and procedure in effect at the Elmore County Jail at the time of the Plaintiff’s 

incarceration in late February, 2006: both require federal inmates/detainees to wear a red 

uniform. 

WHEREFORE, PREMISES CONSIDERED, Defendant Sue Roberts respectfully 

requests this Honorable Court grant her Motion to Supplement Defendant’s Special Report with 

copies of the policy, guidelines, and/or regulations which concern the policies referenced in 

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Defendant Roberts’ affidavit filed in support of her Special Report and any and all documents, 

records, guidelines, etc., maintained or kept by the Elmore County Jail concerning the care and 

housing of inmates/detainees with communicable diseases, as ordered by this Court. 

RESPECTFULLY SUBMITTED, this the 12th day of December, 2006. 

 s/C. Richard Hill, Jr. 

 C. RICHARD HILL, JR. (HIL045) 

 DANIEL D. FORDHAM (FOR055) 

 Attorneys for Defendants 

 WEBB & ELEY, P.C. 

 7475 Halcyon Pointe Drive (36117) 

 Post Office Box 240909 

 Montgomery, Alabama 36124 

 Telephone: (334) 262-1850 

 Fax: (334) 262-1889 

 E-mail: rhill@webbeley.com 

CERTIFICATE OF SERVICE

 I hereby certify that on this the 12th day of December, 2006, I electronically filed this 

Motion to Supplement Defendant’s Special Report with the Clerk of the Court using the 

CM/ECF system, and that I have mailed by United States Mail, postage prepaid, to the following 

non-CM/ECF participant: 

Jeremiah W. Green 

Federal Prison Camp – Atlanta 

Post Office Box 150160 

Atlanta, Georgia 30315-0160 

 s/C. Richard Hill, Jr. 

OF COUNSEL

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