Heward et al v. Board of Education of Anne Arundel County et al
Mr. Mark Heward, Belinda Heward and Mark Heward |
Board of Education of Anne Arundel County, Patrick Bathras, Paige Chang, Janine Robinson and Board of Education of Anne Arundel County doing business as Anne Arundel County Public Schools |
1:2023cv00195 |
January 25, 2023 |
US District Court for the District of Maryland |
Ellen Lipton Hollander |
Civil Rights: Education |
28 U.S.C. § 1446 Notice of Removal |
Both |
Docket Report
This docket was last retrieved on September 29, 2023. A more recent docket listing may be available from PACER.
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Filing 30 ORDER granting School Board Defendants' #29 Motion for Extension of Time to File Reply to #21 Opposition to #15 Corrected MOTION to Dismiss or in the alternative for MOTION for Summary Judgment. Signed by District Judge Ellen Lipton Hollander on 3/13/2023. (dass, Deputy Clerk) |
Filing 29 MOTION for Extension of Time to File Reply as to #21 Response in Opposition to #15 Corrected MOTION to Dismiss or in the alternative for MOTION for Summary Judgment, by Patrick Bathras, Board of Education of Anne Arundel County, Paige Chang (Attachments: #1 Text of Proposed Order Proposed Order)(Banton, Tamal) |
Filing 28 ORDER granting #22 Motion to Seal. Signed by District Judge Ellen Lipton Hollander on 3/7/2023. (dass, Deputy Clerk) |
Filing 27 ORDER granting #20 Motion for Leave to File Excess Pages. Signed by District Judge Ellen Lipton Hollander on 3/7/2023. (dass, Deputy Clerk) |
Filing 26 -SEALED - NOTICE of Filing Under Seal Exhibit 4 to Response to Motion to Dismiss, or in the Alternative, Motion for Summary Judgment filed by Board Defendants by Belinda Heward, Mark Heward re #21 Response in Opposition to Motion, #22 MOTION to Seal (Ledyard, David) |
Filing 25 -SEALED - NOTICE of Filing Under Seal Exhibit 3 to Response to Motion to Dismiss, or in the Alternative, Motion for Summary Judgment filed by Board Defendants by Belinda Heward, Mark Heward re #21 Response in Opposition to Motion, #22 MOTION to Seal (Ledyard, David) |
Filing 24 -SEALED - NOTICE of Filing Under Seal Exhibit 2 to Response to Motion to Dismiss, or in the Alternative, Motion for Summary Judgment filed by Board Defendants by Belinda Heward, Mark Heward re #21 Response in Opposition to Motion, #22 MOTION to Seal (Ledyard, David) |
Filing 23 -SEALED - NOTICE of Filing Under Seal Exhibit 1 to Response to Motion to Dismiss, or in the Alternative, Motion for Summary Judgment filed by Board Defendants by Belinda Heward, Mark Heward re #21 Response in Opposition to Motion, #22 MOTION to Seal (Ledyard, David) |
Filing 22 -SEALED- MOTION to Seal by Belinda Heward, Mark Heward (Attachments: #1 Text of Proposed Order Proposed Order, #2 Exhibit Exhibit 1, #3 Exhibit Exhibit 2, #4 Exhibit Exhibit 3, #5 Exhibit Exhibit 4)(Ledyard, David) |
Filing 21 RESPONSE in Opposition re #15 Corrected MOTION to Dismiss Amended ComplaintCorrected MOTION to Dismiss for Failure to State a Claimas to Counts I through XCorrected MOTION for Summary Judgment as to Counts I through X filed by Belinda Heward, Mark Heward. (Attachments: #1 Text of Proposed Order Proposed Order, #2 Exhibit Exhibit 5, #3 Exhibit Exhibit 1, #4 Exhibit Exhibit 2, #5 Exhibit Exhibit 3, #6 Exhibit Exhibit)(Ledyard, David) |
Filing 20 MOTION for Leave to File Excess Pages by Belinda Heward, Mark Heward (Attachments: #1 Text of Proposed Order Proposed Order)(Ledyard, David) |
Filing 19 ORDER granting #18 Consent Motion for Extension of Time to File Response to #15 (Corrected) MOTION to Dismiss or in the alternative for Summary Judgment. Signed by District Judge Ellen Lipton Hollander on 2/8/2023. (dass, Deputy Clerk) |
Filing 18 MOTION for Extension of Time to File Response/Reply as to #15 Corrected MOTION to Dismiss Amended ComplaintCorrected MOTION to Dismiss for Failure to State a Claimas to Counts I through XCorrected MOTION for Summary Judgment as to Counts I through X by Belinda Heward, Mark Heward (Attachments: #1 Text of Proposed Order)(Ledyard, David) |
Filing 17 NOTICE by Patrick Bathras, Board of Education of Anne Arundel County, Paige Chang, Janine Robinson of Defendants' Local Rule 103.5a Certification (Attachments: #1 Exhibit Plaintiffs' Case Information Report, #2 Exhibit Plaintiffs' Complaint, #3 Exhibit Writ of Summons to BOE 10-18-22, #4 Exhibit Writ of Summons to Bahtras10-18-22, #5 Exhibit Writ of Summons to Chang 10-18-22, #6 Exhibit Writ of Summons to Robinson 10-18-22, #7 Exhibit Plaintiffs' Amended Complaint, #8 Exhibit Plaintiffs' Request for Reissuance of Summons, #9 Exhibit Writ of Summons to Bathras - 1-18-23, #10 Exhibit Writ of Summons to Robinson - 1-18-23, #11 Exhibit Writ of Summons to Chang - 1-18-23, #12 Exhibit Writ of Summons to BOE - 1-18-23, #13 Exhibit Defendants' Notice of Filing of Notice of Removal (with Notice of Removal))(Banton, Tamal) |
Filing 16 -SEALED - NOTICE of Filing Under Seal Exhibits 4, 10, 11, 12, 13, 14, 15, 16, 17, and 20 by Patrick Bathras, Board of Education of Anne Arundel County, Paige Chang, Janine Robinson re #15 Corrected MOTION to Dismiss Amended ComplaintCorrected MOTION to Dismiss for Failure to State a Claimas to Counts I through XCorrected MOTION for Summary Judgment as to Counts I through X (Banton, Tamal) |
Filing 15 Corrected MOTION to Dismiss Amended Complaint, Corrected MOTION to Dismiss for Failure to State a Claimas to Counts I through X, Corrected MOTION for Summary Judgment as to Counts I through X by Patrick Bathras, Board of Education of Anne Arundel County, Paige Chang, Janine Robinson (Attachments: #1 Memorandum in Support Memorandum in Support of Motion to Dismiss, or in the alternative, Motion for Summary Judgment, #2 Exhibit Exhibit 1 - Declaration of Principal Patrick Bathras, #3 Exhibit Exhibit 2 - Declaration of Assistant Principal Paige Chang, #4 Exhibit Exhibit 3 - Declaration of Regional Assistant Superintendent Janine Robinson, #5 Exhibit Exhibit 4 - SEAL NOTICE - SPHS Bullying Report - October 18, 2021, #6 Exhibit Exhibit 5A- ASU article: ASU Notice Against Blackface at Blackout games, #7 Exhibit Exhibit 5B- ASU article: Party likes its 1899 ASU Blackface, #8 Exhibit Exhibit 5C - ASU article : Racist or Insensitive ASU, #9 Exhibit Exhibit 5D - ASU article: ASU Blackface tradition for Blackout, #10 Exhibit Exhibit 6A - AACPS Policy JCCA, #11 Exhibit Exhibit 6B - AACPS Administrative Regulation JCCA-RA, #12 Exhibit Exhibit 7A - AACPS Policy JCCC, #13 Exhibit Exhibit 7B - AACPS Administrative Regulation JCCC-RA, #14 Exhibit Exhibit 8A - AACPS Policy JO, #15 Exhibit Exhibit 8B - AACPS Administrative Regulation - JO-RA, #16 Exhibit Exhibit 9 - AACPS SY21/22 Student Handbook (Code of Conduct), #17 Exhibit Exhibit 10 - SEAL NOTICE - Written Statement of K.H. - October 18, 2021, #18 Exhibit Exhibit 11 - SEAL NOTICE - K.H. Photo, October 16, 2021, #19 Exhibit Exhibit 11A - Redacted Version of K.H. Photo, October 16, 2021, #20 Exhibit Exhibit 12 - SEAL NOTICE - SPHS Student Statements October 18, 2021, #21 Exhibit Exhibit 13 - SEAL NOTICE - K.H. Suspension Letter October 18, 2021, #22 Exhibit Exhibit 14 - SEAL NOTICE - Appeal of Suspension Letter, #23 Exhibit Exhibit 15 - SEAL NOTICE - Principal Bathras Response to Appeal of Suspension, #24 Exhibit Exhibit 16 - SEAL NOTICE - Heward Appeal of Bathras Response, #25 Exhibit Exhibit 17 - SEAL NOTICE - Janine Robinson's Response to Appel, #26 Exhibit Exhibit 18 - MSDE Opinion 20-04, #27 Exhibit Exhibit 19A - Baltimore Sun Article, April 1, 2022, #28 Exhibit Exhibit 19B - Capital Gazette Article - April 1, 2022, #29 Exhibit Exhibit 20 - SEAL NOTICE - K.H. Photo, April 2022, #30 Text of Proposed Order Proposed Order)(Banton, Tamal) |
Filing 14 -SEALED- MOTION to Seal Exhibits 4, 10, 11, 12, 13, 14, 15, 16, 17, and 20 by Patrick Bathras, Board of Education of Anne Arundel County, Paige Chang, Janine Robinson (Attachments: #1 Exhibit Exhibit 4 - Severna Park High School Bullying Report, October 18, 2021, #2 Exhibit Exhibit 10 - Written Statement of K.H., October 18, 2021, #3 Exhibit Exhibit 11A - K.H. Photo, October 16, 2021, #4 Exhibit Exhibit 11B - K.H. Photo, October 16, 2021, #5 Exhibit Exhibit 12 - Severna Park High School Student Statements, October 18, 2021, #6 Exhibit Exhibit 13 - School Suspension of K.H. Letter, October 18, 2021, #7 Exhibit Exhibit 14A - Heward Appeal to Bathras, #8 Exhibit Exhibit 14B - Heward Appeal of School Suspension, #9 Exhibit Exhibit 15A - Principal Bathras Response to Heward, #10 Exhibit Exhibit 15B - Principal Bathras Response to Heward Appeal, #11 Exhibit Exhibit 16 - Heward Appeal of Bathras Responses, #12 Exhibit Exhibit 17 - Janine Robinson Response to Appeal of Principal's decision, #13 Exhibit Exhibit 20 - K.H. Photo, April 2022)(Banton, Tamal) |
Filing 13 -SEALED - NOTICE of Filing Under Seal Exhibits 4, 10, 11, 12, 13, 14, 15, 16, 17, and 20 by Patrick Bathras, Board of Education of Anne Arundel County, Paige Chang, Janine Robinson re 12 MOTION to Dismiss Amended Complaint MOTION to Dismiss for Failure to State a Claimas to Counts I through X MOTION for Summary Judgment as to Counts I through X (Attachments: #1 Exhibit Exhibit 4 - Severna Park High School Bullying Report, October 18, 2021, #2 Exhibit Exhibit 10 - Written Statement of K.H., October 18, 2021, #3 Exhibit Exhibit 11A - K.H. Photo, October 16, 2021, #4 Exhibit Exhibit 11B - K.H. Photo, October 16, 2021, #5 Exhibit Exhibit 12 - Severna Park High School Student Statements, October 18, 2021, #6 Exhibit Exhibit 13 - School Suspension of K.H. Letter, October 18, 2021, #7 Exhibit Exhibit 14A - Heward Appeal to Bathras, #8 Exhibit Exhibit 14B - Heward Appeal of School Suspension, #9 Exhibit Exhibit 15A - Principal Bathras Response to Heward, #10 Exhibit Exhibit 15B - Principal Bathras Response to Heward Appeal, #11 Exhibit Exhibit 16 - Heward Appeal of Bathras Responses, #12 Exhibit Exhibit 17 - Janine Robinson Response to Appeal of Principal's decision, #13 Exhibit Exhibit 20 - K.H. Photo, April 2022)(Banton, Tamal) |
Filing 11 ORDER granting #8 Correspondence re: School Board Defendants' Motion/Request to Exceed 35 Page Limitation (L.R. 105.3) on Memorandum in Support of Motion to Dismiss, or in the alternative, Motion for Summary Judgment. Signed by District Judge Ellen Lipton Hollander on 1/27/2023. (dass, Deputy Clerk) |
Filing 10 NOTICE by Patrick Bathras, Board of Education of Anne Arundel County, Paige Chang, Janine Robinson re #1 Notice of Removal,,, Notice of Filing Notice of Removal (Banton, Tamal) |
Filing 9 NOTICE by Patrick Bathras, Board of Education of Anne Arundel County, Paige Chang, Janine Robinson re #5 Notice of Standing Order 2021-13 Concerning Removal Actions Defendants' Joint Statement of Removal (Banton, Tamal) |
Filing 8 Correspondence re: School Board Defendants' Motion/Request to Exceed 35 Page Limitation (L.R. 105.3) on Memorandum in Support of Motion to Dismiss, or in the alternative, Motion for Summary Judgment (Attachments: #1 Text of Proposed Order Proposed Order)(Banton, Tamal) |
Filing 7 Local Rule 103.3 Disclosure Statement by Board of Education of Anne Arundel County identifying Corporate Parent Board of Education of Anne Arundel County for Board of Education of Anne Arundel County.(Banton, Tamal) |
Filing 6 NOTICE by Patrick Bathras, Board of Education of Anne Arundel County, Paige Chang, Janine Robinson re #1 Notice of Removal,,, (Culpepper, Philip) |
Filing 5 Clerk's Notice of Standing Order concerning removal actions filed in this Court, which can be downloaded #here. (dass, Deputy Clerk) |
Filing 4 QC NOTICE re: #1 Notice of Removal filed by Janine Robinson, Paige Chang, Patrick Bathras. **The following attachment is missing - U.S. District Court Civil Cover Sheet. Please file U.S. District Court Civil Cover Sheet using the event Notice (Other) and link it to the #1 Notice of Removal. Thank you. (dass, Deputy Clerk) |
Filing 3 Request to re-issue summons. (dass, Deputy Clerk) |
Filing 2 AMENDED COMPLAINT against Patrick Bathras, Board of Education of Anne Arundel County, Paige Chang, Janine Robinson, filed by Mark Heward, Belinda Heward.(dass, Deputy Clerk) |
THE ABOVE DOCUMENTS (2-3) ARE COPIES OF ORIGINAL PAPERS FILED IN THE CIRCUIT COURT FOR ANNE ARUNDEL COUNTY. (dass, Deputy Clerk) |
Filing 1 NOTICE OF REMOVAL from Circuit Court for Anne Arundel County, case number C-02-cv-22-001726. ( Filing fee $ 402 receipt number AMDDC-10392793), filed by Janine Robinson, Paige Chang, Patrick Bathras. (Attachments: #1 Exhibit Ex. 1A - Original Complaint in the Circuit Court for Anne Arundel County (10/17/2022), #2 Exhibit Ex. 1B - Civil Non Domestic Case Information Report - Circuit Court for Anne Arundel County (10/17/2022), #3 Exhibit Ex. 1C - Amended Complaint in the Circuit Court for Anne Arundel County (12/27/2022), #4 Exhibit Ex. 1D - Request to Reissue Summons (1/17/2023), #5 Exhibit Ex. 2 - AACo. Circuit Court Docket Sheet, #6 Exhibit Ex. 3 - Plaintiffs' email of Amended Complaint to Counsel, #7 Exhibit Ex. 4 - Notice of Filing of Notice of Removal)(Banton, Tamal) |
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