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Legal Mail Suit Dismissed, Administrative Exhaustion is Affirmative Defense

Once again, a SDNY judge applies the New York State grievance regulations
to a claim that arose in the NYC jails. At 625:

In the instant action, plaintiff filed at least two complaints to the
IGRC in 1998. When he received no response, he appealed directly to NYCDOC
Commissioner Kerick ...

 

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