Lloyd et al v. School Board of Palm Beach County et al
| Dustin Lloyd, William O'Connor Jr., Amber Santamarina, Shana Borowski, Emily Matchica, Joyce Van Etten, Lindsay Pasquale, Victor Nin, P. L., G. L., E. L., T. O., B. S., K. B., S. M., C. S., E. C., J. C., J. N., P. C., L. S., W. S., Landon Swan, Rebecca Disney and W. S.(2) |
| School Board of Palm Beach County, Michael Burke and Frank Barbieri, Jr. |
| 9:2021cv81715 |
| September 12, 2021 |
| US District Court for the Southern District of Florida |
| William P Dimitrouleas |
| William Matthewman |
| K Michael Moore |
| Civil Rights: Other |
| 28 U.S.C. § 1331 |
| None |
Docket Report
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Filing 29
ORDER GRANTING Defendants' Motion to Dismiss #23 . Plaintiffs' Amended Complaint #16 is DISMISSED WITH PREJUDICE. The Clerk of Court is INSTRUCTED to CLOSE this case. All pending motions, if any, are DENIED AS MOOT. Signed by Judge K. Michael Moore on 10/29/2021. See attached document for full details. (thn)
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Filing 28
PAPERLESS ORDER OF REFERRAL TO MEDIATION. Trial having been set in this matter for the two week trial period beginning June 20, 2022, at 9:00 a.m. pursuant to Rule 16 of the Federal Rule of Civil Procedure and Rule 16.2 of the Local Rules of the United States District Court for the Southern District of Florida, it is hereby ORDERED AND ADJUDGED as follows: 1. All parties are required to participate in mediation. The mediation shall be completed no later than eighty (80) days before the scheduled trial date. 2. Plaintiff's counsel, or another attorney agreed upon by all counsel of record and any unrepresented parties, shall be responsible for scheduling the mediation conference. The parties are encouraged to avail themselves of the services of any mediator on the List of Certified Mediators, maintained in the office of the Clerk of this Court, but may select any other mediator. The parties shall agree upon a mediator and file a Notice of Mediator Selection within fifteen (15) days from the date of this Order. If there is no agreement, lead counsel shall file a request for the Clerk of Court to appoint a mediator in writing within fifteen (15) days from the date of this Order, and the Clerk shall designate a mediator from the List of Certified Mediators. Designation shall be made on a blind rotation basis. 3. The parties shall agree upon a place, date, and time for mediation convenient to the mediator, counsel of record, and unrepresented parties and file a Notice of Scheduling Mediation no later than one hundred and ten (110) days prior to the scheduled trial date. If the parties cannot agree to a place, date, and time for the mediation, they may motion the Court for an order dictating the place, date, and time. 4. The physical presence of counsel and each party or representatives of each party with full authority to enter in a full and complete compromise and settlement is mandatory. If insurance is involved, an adjuster with authority up to the policy limits or the most recent demand, whichever is lower, shall attend. 5. All discussions, representations and statements made at the mediation conference shall be confidential and privileged. 6. At least ten (10) days prior to the mediation date, all parties shall present to the mediator a brief written summary of the case identifying issues to be resolved. Copies of those summaries shall be served on all other parties. 7. The Court may impose sanctions against parties and/or counsel who do not comply with the attendance or settlement authority requirements herein, or who otherwise violate the terms of this Order. The mediator shall report non-attendance and may recommend imposition of sanctions by the Court for non-attendance. 8. The mediator shall be compensated in accordance with the standing order of the Court entered pursuant to Rule 16.2.B.6, or on such basis as may be agreed to in writing by the parties and the mediator selected by the parties. The cost of mediation shall be shared equally by the parties unless otherwise ordered by the Court. All payments shall be remitted to the mediator within 30 days of the date of the bill. Notice to the mediator of cancellation or settlement prior to the scheduled mediation conference must be given at least two (2) full business days in advance. Failure to do so will result in imposition of a fee for one hour. 9. If a full or partial settlement is reached in this case, counsel shall promptly notify the Court of the settlement in accordance with Local Rule 16.2.F, by filing a notice of settlement signed by the counsel of record within ten (10) days of the mediation conference. Thereafter, the parties shall forthwith submit an appropriate pleading concluding the case. 10. Within five (5) days following the mediation conference, the mediator shall file a Mediation Report indicating whether all required parties were present. The report shall also indicate whether the case settled (in full or in part), was continued with the consent of the parties, or whether the mediator declared an impasse. 11. If mediation is not conducted, the case may be stricken from the trial calendar, and other sanctions may be imposed. Signed by Judge K. Michael Moore on 10/22/2021. (thn)
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Filing 27
PAPERLESS ORDER SCHEDULING TRIAL IN WEST PALM BEACH. This case is now set for trial commencing the two week trial period of June 20, 2022, at 1 p.m. at the United States District Courthouse, 701 Clematis Street, West Palm Beach, Florida. All parties are directed to report to the calendar call on June 16, 2022, at 2 p.m., at which time all matters relating to the scheduled trial date may be brought to the attention of the Court. A final pretrial conference as provided for by Rule 16, Fed. R. Civ. P., and Rule 16.1(C), S.D. Fla. L.R., is scheduled for June 7, 2022, at 11 a.m. The calendar call and the final pretrial conference will take place in Courtroom 13-1 (thirteenth floor), United States District Courthouse, 400 North Miami Avenue, Miami, Florida. A bilateral pretrial stipulation and all other pretrial preparations shall be completed NO LATER THAN FIVE DAYS PRIOR TO THE PRETRIAL CONFERENCE. All motions to amend the pleadings or to join additional parties must be filed by the later of forty-five (45) days after the date of entry of this Order, or forty-five (45) days after the first responsive pleading by the last responding defendant. Any and all pretrial motions, including motions for summary judgment, Daubert motions, and motions in limine must be filed no later than eighty (80) days prior to the trial date. Responses to summary judgment motions must be filed no later than fourteen (14) days after service of the motion, and replies in support of the motion must be filed no later than seven (7) days after service of the response, with both deadlines computed as specified in Rule 6, Fed. R. Civ. P. Each party is limited to one Daubert motion. If all evidentiary issues cannot be addressed in a 20-page memorandum, the parties must file for leave to exceed the page limit. Each party is also limited to one motion in limine (other than Daubert motions). If all evidentiary issues cannot be addressed in a 20-page memorandum, the parties must file for leave to exceed the page limit. Rule 26(a)(2) expert disclosures shall be completed one hundred thirty (130) days prior to the date of trial. All discovery, including expert discovery, shall be completed one hundred (100) days prior to the date of trial. The failure to engage in discovery pending settlement negotiations shall not be grounds for continuance of the trial date. All exhibits must be pre-marked, and a typewritten exhibit list setting forth the number and description of each exhibit must be submitted at the time of trial. Plaintiff's exhibits shall be marked numerically with the letter "P" as a prefix. Defendant's exhibits shall be marked numerically with the letter "D" as a prefix. For a jury trial, counsel shall prepare and submit proposed jury instructions to the Court. The Parties shall submit their proposed jury instructions and verdict form jointly, although they do not need to agree on each proposed instruction. Where the parties do not agree on a proposed instruction, that instruction shall be set forth in bold type. Instructions proposed only by a plaintiff should be underlined. Instructions proposed only by a defendant should be italicized. Every instruction must be supported by citation to authority. The parties should use the Eleventh Circuit Pattern Jury Instructions for Civil Cases as a guide, including the directions to counsel contained therein. The parties shall jointly file their proposed jury instructions via CM/ECF, and shall also submit their proposed jury instructions to the Court via e-mail at moore@flsd.uscourts.gov in WordPerfect or Word format. For a non-jury trial, the parties shall prepare and submit to the Court proposed findings of fact and conclusions of law fully supported by the evidence, which counsel expects the trial to develop, and fully supported by citations to law. The proposed jury instructions or the proposed findings of fact and conclusions of law shall be submitted to the Court no later than five (5) business days prior to the scheduled trial date. Pursuant to Administrative Order 2016-70 of the Southern District of Florida and consistent with the Court of Appeals for the Eleventh Circuit's Local Rules and Internal Operating Procedures, within three days of the conclusion of a trial or other proceeding, parties must file via CM/ECF electronic versions of documentary exhibits admitted into evidence, including photographs of non-documentary physical exhibits. The Parties are directed to comply with each of the requirements set forth in Administrative Order 2016-70 unless directed otherwise by the Court. THE FILING BY COUNSEL OF A NOTICE OF UNAVAILABILITY BY MOTION OR OTHERWISE IS NOT PROVIDED FOR UNDER THE LOCAL RULES AND SHALL NOT BE PRESUMED TO ALTER OR MODIFY THE COURT'S SCHEDULING ORDER. Signed by Judge K. Michael Moore on 10/22/2021. (thn) #Pattern Jury Instruction Builder - To access the latest, up to date changes to the 11th Circuit Pattern Jury Instructions go to https://pji.ca11.uscourts.gov or click here.
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| Filing 26 Joint SCHEDULING REPORT - Rule 16.1 by K. B., Shana Borowski, E. C., J. C., P. C., Rebecca Disney, E. L., G. L., P. L., Dustin Lloyd, S. M., Emily Matchica, J. N., Victor Nin, William O'Connor Jr., T. O., Lindsay Pasquale, B. S., C. S., L. S., W. S., W. S.(2), Amber Santamarina, Landon Swan, Joyce Van Etten (Leo, Louis) |
| Filing 25 REPLY to Response to Motion re #23 MOTION to Dismiss #16 Amended Complaint/Amended Notice of Removal, filed by Frank Barbieri, Jr., Michael Burke, School Board of Palm Beach County. (Fahey, Sean) |
| Filing 24 RESPONSE in Opposition re #23 MOTION to Dismiss #16 Amended Complaint/Amended Notice of Removal, filed by K. B., Shana Borowski, E. C., J. C., P. C., Rebecca Disney, E. L., G. L., P. L., Dustin Lloyd, S. M., Emily Matchica, J. N., Victor Nin, William O'Connor Jr., T. O., Lindsay Pasquale, B. S., C. S., L. S., W. S., W. S.(2), Amber Santamarina, Landon Swan, Joyce Van Etten. Replies due by 10/20/2021. (Leo, Louis) |
| Filing 23 MOTION to Dismiss #16 Amended Complaint/Amended Notice of Removal, by Frank Barbieri, Jr., Michael Burke, School Board of Palm Beach County. Responses due by 10/25/2021 (Fahey, Sean) |
| Filing 22 Notice of Supplemental Authority re #13 Plaintiff's EXPEDITED MOTION Preliminary Injunction by K. B., Shana Borowski, E. C., J. C., P. C., Rebecca Disney, E. L., G. L., P. L., Dustin Lloyd, S. M., Emily Matchica, J. N., Victor Nin, William O'Connor Jr., T. O., Lindsay Pasquale, B. S., C. S., L. S., W. S., W. S.(2), Amber Santamarina, Landon Swan, Joyce Van Etten (Attachments: #1 Exhibit "1" (Oct. 4, 2021 Memorandum By Commissioner of Education to State Board of Education), #2 Exhibit "2" (Commissioner of Education's Findings Published Oct. 7, 2021 By Florida Department of Education)) (Leo, Louis) |
| Filing 21 Amended REPLY to Response to Motion re #13 Plaintiff's EXPEDITED MOTION Preliminary Injunction filed by K. B., Shana Borowski, E. C., J. C., P. C., Rebecca Disney, E. L., G. L., P. L., Dustin Lloyd, S. M., Emily Matchica, J. N., Victor Nin, William O'Connor Jr., T. O., Lindsay Pasquale, B. S., C. S., L. S., W. S., W. S.(2), Amber Santamarina, Landon Swan, Joyce Van Etten. (Attachments: #1 Exhibit "1" (Complaint Filed Against Defendant School Board on October 4, 2021))(Leo, Louis) |
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Filing 20
PAPERLESS ORDER. THIS CAUSE came before the Court upon Defendants Motion for Leave to File Excess Pages. #17 . On September 17, 2021, Plaintiffs filed a Motion for Preliminary Injunction. #16 . On October 1, 2021, Defendants filed a thirty-two (32) page response to Plaintiffs' Motion for Preliminary Injunction #18 and the instant Motion for Leave to file Excess Pages #17 . In the instant Motion #17 , Defendants explain that they have made every attempt to condense their response and that it has exceeded the twenty (20) page limit under 7.01(c)(2) because (1) the Amended Complaint is 86 pages long, and (2) it was necessary to include factual background information. #17 at 1-2. The Court has reviewed Plaintiffs' Response #18 and finds the excess pages are warranted given the extensive factual background. Accordingly, UPON CONSIDERATION of the Motion, the pertinent portions of the record, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED that the Motion #17 is GRANTED. Defendants are hereby granted leave to file a response in excess of the 20-page limit, as to their Response #18 . Additionally, Plaintiffs' are hereby granted leave to re-file a reply up to fifteen (15) pages, if necessary. However, if Plaintiffs choose not to file an updated reply, they shall inform the Court on or before October 6, 2021. Signed by Judge K. Michael Moore on 10/4/2021. (thn)
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| Filing 19 Plaintiff's REPLY to Response to Motion re #13 Plaintiff's EXPEDITED MOTION Preliminary Injunction filed by K. B., Shana Borowski, E. C., J. C., P. C., Rebecca Disney, E. L., G. L., P. L., Dustin Lloyd, S. M., Emily Matchica, J. N., Victor Nin, William O'Connor Jr., T. O., Lindsay Pasquale, B. S., C. S., L. S., W. S., W. S.(2), Amber Santamarina, Landon Swan, Joyce Van Etten. (Leo, Louis) |
| Filing 18 RESPONSE in Opposition re #13 Plaintiff's EXPEDITED MOTION Preliminary Injunction filed by Frank Barbieri, Jr., Michael Burke, School Board of Palm Beach County. Replies due by 10/8/2021. (Attachments: #1 Exhibit A, #2 Exhibit B)(Fahey, Sean) |
| Filing 17 MOTION for Leave to File Excess Pages for Opposing Memorandum of Law to Plaintiffs' Expedited Motion for Preliminary Injunction by Frank Barbieri, Jr., Michael Burke, School Board of Palm Beach County. (Fahey, Sean) |
| Filing 16 Plaintiff's AMENDED COMPLAINT against All Defendants, filed by E. L., Lindsay Pasquale, William O'Connor Jr., E. C., Dustin Lloyd, J. C., C. S., B. S., Joyce Van Etten, Amber Santamarina, P. L., T. O., K. B., S. M., Victor Nin, Shana Borowski, G. L., J. N., Emily Matchica, P. C., L. S., W. S., Landon Swan, Rebecca Disney, W. S.(2). (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E)(Leo, Louis) |
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Filing 15
PAPERLESS ORDER SETTING BREIFING SCHEDULE ON MOTION FOR PRELIMINARY INJUNCTION #13 . THIS CAUSE came before the Court upon Plaintiffs' Motion for Preliminary Injunction. #13 . Plaintiffs have marked their Motion #13 as an "expedited motion" pursuant to Local Rule 7.1(d)(2). #17 at 1. Under the Local Rules, an expedited motion must set forth in detail the date by which an expedited ruling is needed and the reason the ruling is needed by the stated date. S.D. Fla. L.R. 7.1(d)(2). In Plaintiff's Motion, they inform the Court that school is resuming on September 20, 2021which is the next business day after Plaintiffs' Motion #13 was filed. However, a preliminary injunction is a "extraordinary and drastic remedy and the Court cannot rule on Plaintiffs' Motion on an expedited basis, by September 20, 2021, because that would foreclose Defendants the opportunity to respond, thereby undermining the purposes of affording a Defendant notice pursuant to Rule 65(a)(1). Autonation, Inc. v. Wilson, No. 16-62048-CIV, 2016 WL 8677193, at *2 (S.D. Fla. Dec. 30, 2016) (quoting Granny Goose Foods, Inc. v. Teamsters, 415 U.S. 423, 434 n.7 (1974) (The notice required by Rule 65(a) before a preliminary injunction can issue implies a hearing in which the defendant is given a fair opportunity to oppose the application and to prepare for such opposition.)). Therefore, the Court will consider Plaintiffs' Motion in accordance with the briefing schedule set forth below. Defendants are hereby ORDERED to respond to Plaintiffs' Motion for Preliminary Injunction #13 on or before October 1, 2021. Plaintiffs shall have up to seven (7) days to file a reply. If Plaintiffs opt not to file a reply, they shall inform the Court at their earliest convenience. If necessary, a hearing in this matter will be set by separate order after briefing on Plaintiffs' Motion for Preliminary Injunction #13 has been completed. Signed by Judge K. Michael Moore on 9/20/2021. (thn)
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Filing 14
ORDER SETTING DISCOVERY PROCEDURE. Signed by Magistrate Judge William Matthewman on 9/17/2021. See attached document for full details. (jas)
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| Filing 13 Plaintiff's EXPEDITED MOTION Preliminary Injunction by K. B., Shana Borowski, E. C., J. C., E. L., G. L., P. L., Dustin Lloyd, S. M., Emily Matchica, J. N., Victor Nin, William O'Connor Jr., T. O., Lindsay Pasquale, B. S., C. S., Amber Santamarina, Joyce Van Etten. (Attachments: #1 Text of Proposed Order Proposed Order Granting Expedited Motion for Preliminary Injunction)(Leo, Louis) |
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Filing 12
PAPERLESS ORDER REFERRING PRETRIAL DISCOVERY MATTERS TO MAGISTRATE JUDGE WILLIAM MATTHEWMAN. PURSUANT to 28 U.S.C. 636 and the Magistrate Rules of the Local Rules of the Southern District of Florida, the above-captioned Cause is referred to United States Magistrate Judge William Matthewman to take all necessary and proper action as required by law with respect to any and all pretrial discovery matters. Any motion affecting deadlines set by the Court's Scheduling Order is excluded from this referral, unless specifically referred by separate Order. It is FURTHER ORDERED that the parties shall comply with Magistrate Judge Matthewman's discovery procedures. Signed by Judge K. Michael Moore on 9/17/2021. (thn)
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Filing 11
PAPERLESS PRETRIAL ORDER. This order is entered upon a sua sponte review of the record. It is hereby ORDERED that S.D. Fla. L.R. 16.1 shall apply to this case and the parties shall hold a scheduling conference within thirty-five (35) days of the date of this Order. Within ten (10) days of the scheduling conference, counsel shall file a joint scheduling report. Failure of counsel to file a joint scheduling report within the deadlines set forth above may result in dismissal, default, and the imposition of other sanctions including attorney's fees and costs. The parties should note that the time period for filing a joint scheduling report is not tolled by the filing of any other pleading, such as an amended complaint or Rule 12 motion. The scheduling conference may be held via telephone. At the conference, the parties shall comply with the following agenda that the Court adopts from S.D. Fla. L.R. 16.1: (1) Documents (S.D. Fla. L.R. 16.1.B.1 and 2) - The parties shall determine the procedure for exchanging a copy of, or a description by category and location of, all documents and other evidence that is reasonably available and that a party expects to offer or may offer if the need arises. Fed. R. Civ. P. 26(a)(1)(B). (a) Documents include computations of the nature and extent of any category of damages claimed by the disclosing party unless the computations are privileged or otherwise protected from disclosure. Fed. R. Civ. P. 26(a)(1)(C). (b) Documents include insurance agreements which may be at issue with the satisfaction of the judgment. Fed. R. Civ. P. 26(a)(1)(D). (2) List of Witnesses - The parties shall exchange the name, address and telephone number of each individual known to have knowledge of the facts supporting the material allegations of the pleading filed by the party. Fed. R. Civ. P. 26(a)(1)(A). The parties have a continuing obligation to disclose this information. (3) Discussions and Deadlines (S.D. Fla. L.R. 16.1.B.2) - The parties shall discuss the nature and basis of their claims and defenses and the possibilities for a prompt settlement or resolution of the case. Failure to comply with this Order or to exchange the information listed above may result in sanctions and/or the exclusion of documents or witnesses at the time of trial. S.D. Fla. L.R. 16.1.I. Pursuant to Administrative Order 2016-70 of the Southern District of Florida and consistent with the Court of Appeals for the Eleventh Circuit's Local Rules and Internal Operating Procedures, within three days of the conclusion of a trial or other proceeding, parties must file via CM/ECF electronic versions of documentary exhibits admitted into evidence, including photographs of non-documentary physical exhibits. The Parties are directed to comply with each of the requirements set forth in Administrative Order 2016-70 unless directed otherwise by the Court. Telephonic appearances are not permitted for any purpose. Upon reaching a settlement in this matter the parties are instructed to notify the Court by telephone and to file a Notice of Settlement within twenty-four (24) hours. Signed by Judge K. Michael Moore on 9/17/2021. (thn)
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Filing 10
ORDER TRANSFERRING CASE to Judge K. Michael Moore for all further proceedings, accepted and signed on September 16, 2021. Judge William P. Dimitrouleas no longer assigned to case. Signed by Judge William P. Dimitrouleas and Judge K. Michael Moore on 9/16/2021. See attached document for full details. (thn)
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| Filing 8 NOTICE of Attorney Appearance by Sean Christian Fahey on behalf of Frank Barbieri, Jr., Michael Burke, School Board of Palm Beach County. Attorney Sean Christian Fahey added to party Frank Barbieri, Jr.(pty:dft), Attorney Sean Christian Fahey added to party Michael Burke(pty:dft), Attorney Sean Christian Fahey added to party School Board of Palm Beach County(pty:dft). (Fahey, Sean) |
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Filing 9
ORDER denying #6 Motion to Change Venue. Signed by Judge William P. Dimitrouleas on 9/16/2021. See attached document for full details. (drz)
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Filing 7
ORDER REQUIRING COUNSEL TO MEET, FILE JOINT SCHEDULING REPORT AND JOINT DISCOVERY REPORT. Signed by Judge William P. Dimitrouleas on 9/15/2021. See attached document for full details. (drz)
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| Filing 6 Plaintiff's MOTION to Change Venue to West Palm Beach Division by K. B., Shana Borowski, E. C., J. C., E. L., G. L., P. L., Dustin Lloyd, S. M., Emily Matchica, J. N., Victor Nin, William O'Connor Jr., T. O., Lindsay Pasquale, B. S., C. S., Amber Santamarina, Joyce Van Etten. Responses due by 9/29/2021 (Attachments: #1 Exhibit Emails From Defendants' Counsel)(Leo, Louis) |
| Filing 5 SUMMONS (Affidavit) Returned Executed on #1 Complaint,,, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by E. L., Lindsay Pasquale, William O'Connor Jr., E. C., Dustin Lloyd, J. C., C. S., B. S., Joyce Van Etten, Amber Santamarina, P. L., T. O., K. B., S. M., Victor Nin, Shana Borowski, G. L., J. N., Emily Matchica. Frank Barbieri, Jr. served on 9/14/2021, answer due 10/5/2021; Michael Burke served on 9/14/2021, answer due 10/5/2021; School Board of Palm Beach County served on 9/14/2021, answer due 10/5/2021. (Medgebow, Joel) |
| Filing 4 NOTICE of Attorney Appearance by Joel D Medgebow on behalf of K. B., Shana Borowski, E. C., J. C., E. L., G. L., P. L., Dustin Lloyd, S. M., Emily Matchica, J. N., Victor Nin, William O'Connor Jr., T. O., Lindsay Pasquale, B. S., C. S., Amber Santamarina, Joyce Van Etten (Medgebow, Joel) |
| Filing 3 Summons Issued as to Frank Barbieri, Jr., Michael Burke, School Board of Palm Beach County. (drz) |
| Filing 2 Clerks Notice of Judge Assignment to Judge William P. Dimitrouleas. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge William Matthewman is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent. (drz) |
| Filing 1 COMPLAINT (VERIFIED) against Frank Barbieri, Jr., Michael Burke, School Board of Palm Beach County. Filing fees $ 402.00 receipt number AFLSDC-15002927, filed by E. L., Lindsay Pasquale, William O'Connor Jr., E. C., Dustin Lloyd, J. C., C. S., B. S., Joyce Van Etten, Amber Santamarina, P. L., T. O., K. B., S. M., Victor Nin, Shana Borowski, G. L., J. N., Emily Matchica. (Attachments: #1 Civil Cover Sheet, #2 Summon(s) Defendant Frank Barbieri, Jr., #3 Summon(s) Defendant School Board of Palm Beach County, #4 Summon(s) Defendant Michael Burke, #5 Exhibit "A" (Declaration of Expert Stephen Petty), #6 Exhibit "B" (August 24, 2021 Letter from Palm Beach County School District))(Leo, Louis) |
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