Thompson v. Mukilteo School District No 6
| Rosa Maria Cabrera Thompson |
| Mukilteo School District No 6 |
| 2:2025cv00529 |
| March 25, 2025 |
| U.S. District Court for the Western District of Washington |
| Jamal N Whitehead |
| Civil Rights: Jobs |
| 28 U.S.C. § 1331 Fed. Question: Employment Discrimination |
| Plaintiff |
Docket Report
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This docket was last retrieved on July 22, 2026. A more recent docket listing may be available from PACER.
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Filing 159
DECLARATION of ROSA MARIA CABRERA THOMPSON by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 158
ORDER. The Court held a hearing on several pending motions on Friday, September 12, 2025. This written order confirms and supersedes the Court's oral rulings and controls in the event of any inconsistency with statements made during the hearing. Mukilteo School District No. 6's ("District") Motion to Adopt a Modified Model Court Electronically Stored Information (ESI) Agreement is GRANTED. Dkt. No. #115 . Plaintiff Rosa Maria Cabrera Thompson's competing Motion for Discovery for Entry of ESI Protocol is DENIED. Dkt. No. #117 . The District's Motion to Compel Plaintiff to Delete, Destroy, and Disregard Inadvertently Disclosed Documents is GRANTED. Dkt. No. #126 . Thompson's Motion for In Camera Review and Applying the Crime-Fraud Exception is DENIED. Dkt. No. #131 . The Court STRIKES the sealed document indexes and documents submitted by Thompson. Dkt. Nos. #146 , #155 . Thompson's Motion for Partial Summary Judgment is STRICKEN with leave to refile. Dkt. No. #122 . The District's Motion for an Extension to respond to Thompsons Motion for Summary Judgment is DENIED AS MOOT. Dkt. No. #151 . Signed by Judge Jamal N Whitehead. (KRA)
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Filing 157
MINUTE ENTRY for proceedings held before Judge Jamal N Whitehead- Dep Clerk: Grant Cogswell; Pla Counsel: Dr. Rosa Maria Cabrera Thompson; Def Counsel: Megan Starks; CR: Nancy Bauer; Time of Hearing: 9:00AM; Courtroom: Zoom;Motion Hearing held on 9/12/2025. The Court hears oral arguments on the pending motions in this matter. After hearing argument, the Court takes this matter under advisement and will issue a written order with the Court's rulings. (GC)
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Filing 156
MINUTE ORDER (text-only) made at the direction of the Honorable Jamal N. Whitehead: This Court admonished Plaintiff Thompson's serial filings regarding inadvertently disclosed documentsthe subject of two existing motions pending before this Court. Dkt. No. #145 ; see Dkt. Nos. #126 , #131 . Despite this Court's express warning that "continued serial filings may result in sanctions, including filing restrictions," Thompson has disregarded the Court's directive and filed yet another motion on the same subject matter. The Motion for Preliminary Injunction is STRICKEN. Dkt. No. #148 . Thompson's persistent refiling of substantially similar motions wastes judicial resources and violates this Court's prior order. The matters at issue remain scheduled for hearing on Friday, September 12, 2025. Authorized by Judge Jamal N Whitehead. (KRA)
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Filing 155
STRICKEN per Order at Dkt. #158 SEALED DOCUMENT Supplemental Index of Documents for In Camera Review by Plaintiff Rosa Maria Cabrera Thompson re #131 MOTION IN CAMERA REVIEW AND APPLYING THE CRIMEFRAUD EXCEPTION and #138 Emergency MOTION for Temporary Restraining Order , PROTECTIVE ORDER, AND IN CAMERA REVIEW TO ADDRESS FRAUD ON THE COURT AND BREACH OF SETTLEMENT AGREEMENT. (Attachments: #1 Documents) (KRA) Modified to strike on 9/12/2025 (KRA).
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Filing 154
DECLARATION of ROSA MARIA CABRERA THOMPSON filed by Plaintiff Rosa Maria Cabrera Thompson re #151 MOTION for Extension of Time re #122 MOTION for Partial Summary Judgment on Count I Breach of Contract, #126 Emergency MOTION Compel to Destroy (Attachments: #1 Exhibit Exhibit F-RFP #4, #2 Exhibit Exhibit-B-Interrogatory Set #1, #3 Exhibit Exhibit C-RFP #1, #4 Exhibit Exhibit D-RFP #2, #5 Exhibit Exhibit G-RFP #6, #6 Exhibit Exhibit E-RFP #3, #7 Exhibit Exhibit A-Discovery Requests Emails July 1-July 13, 2025)(Thompson, Rosa)
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Filing 153
PROPOSED ORDER (Unsigned) re #152 Response to Motion, PLAINTIFFS OPPOSITION TO DEFENDANTS MOTION FOR EXTENSION OF TIME AND TO STRIKE/SEAL EXHIBITS (Thompson, Rosa)
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Filing 152
RESPONSE, by Plaintiff Rosa Maria Cabrera Thompson, to #151 MOTION for Extension of Time re #122 MOTION for Partial Summary Judgment on Count I Breach of Contract, #126 Emergency MOTION Compel to Destroy . (Thompson, Rosa)
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Set/Reset Hearings: Motion Hearing set for 9/12/2025 at 09:00 AM before Judge Jamal N Whitehead. This hearing will be held remotely using ZoomGov. (GC)
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Filing 151
MOTION for Extension of Time re #122 MOTION for Partial Summary Judgment on Count I Breach of Contract, #126 Emergency MOTION Compel to Destroy , filed by Defendant Mukilteo School District No 6. (Attachments: #1 Proposed Order Proposed Order Granting Defendants Motion for Extension of Deadline to File Responsive Briefing to Plaintiffs Motion for Partial Summary Judgment and Motion to Strike and Seal Inadvertently Disclosed Privileged Documents from the Docket) Noting Date 9/17/2025, (Molina, Zana)
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Filing 150
NOTICE of Unavailability of counsel Zana T Molina for Defendant Mukilteo School District No 6 from September 12, 2025 to September 22, 2025. (Molina, Zana)
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Filing 149
PROPOSED ORDER (Unsigned) re #131 MOTION IN CAMERA REVIEW AND APPLYING THE CRIMEFRAUD EXCEPTION re #124 Response to Motion, #122 MOTION for Partial Summary Judgment on Count I Breach of Contract, #123 Declaration,,,,,,,,, #126 Emergency MOTION Compel to Destroy, #122 MOTION for Partial Summary Judgment on Count I Breach of Contract, #146 Sealed Document, #126 Emergency MOTION Compel to Destroy , #123 Declaration,,,,,,,,, #148 MOTION for Preliminary Injunction (On Notice) (Thompson, Rosa)
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Filing 148
MOTION for Preliminary Injunction (On Notice), filed by Plaintiff Rosa Maria Cabrera Thompson. Noting Date 9/26/2025, (Thompson, Rosa)
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Filing 147
NOTICE to Withdraw Pending Motion re #118 MOTION for Sanctions ; by Plaintiff Rosa Maria Cabrera Thompson. (Thompson, Rosa)
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Filing 146
STRICKEN per Order at Dkt. #158 SEALED DOCUMENT INDEX OF DOCUMENTS FOR IN CAMERA REVIEW by Plaintiff Rosa Maria Cabrera Thompson re #131 MOTION IN CAMERA REVIEW AND APPLYING THE CRIMEFRAUD EXCEPTION and #138 Emergency MOTION for Temporary Restraining Order , PROTECTIVE ORDER, AND IN CAMERA REVIEW TO ADDRESS FRAUD ON THE COURT AND BREACH OF SETTLEMENT AGREEMENT. (KRA) Modified to strike on 9/12/2025 (KRA).
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Filing 145
ORDER denying Plaintiff's #143 Motion. The Federal Civil Rules and Local Civil Rules already provide the procedural framework for resolving discovery disputes between the parties. Thompson's motion at Dkt. No. #143 is therefore DENIED. The Court warns Thompson that continued serial filings may result in sanctions, including filing restrictions. Signed by Judge Jamal N Whitehead. (KRA)
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Filing 144
ORDER denying Thompson's #138 Motion for Temporary Restraining Order; denying as moot the District's #140 Motion Additional Time. Signed by Judge Jamal N Whitehead.(CJS)
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Filing 143
MOTION PLAINTIFFS MOTION TO SET SEQUENCING AND TO PRESERVE MATERIALS PENDING RULING ON DKTS. 126, 131 & 138 re #138 Emergency MOTION for Temporary Restraining Order , PROTECTIVE ORDER, AND IN CAMERA REVIEW TO ADDRESS FRAUD ON THE COURT AND BREACH OF SETTLEMENT AGREEMENT, #142 Notice-Other,,, #131 MOTION IN CAMERA REVIEW AND APPLYING THE CRIMEFRAUD EXCEPTION re #124 Response to Motion, #122 MOTION for Partial Summary Judgment on Count I Breach of Contract, #123 Declaration,,,,,,,,, #126 Emergency MOTION Compel to Destroy, #126 Emergency MOTION Compel to Destroy , filed by Plaintiff Rosa Maria Cabrera Thompson. (Attachments: #1 Proposed Order) Noting Date 8/27/2025, (Thompson, Rosa)
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Filing 142
NOTICE PLAINTIFFS NOTICE OF LODGING UNDER SEAL PURSUANT TO FRCP 26(b)(5)(B) AND LCR 5(g) re #131 MOTION IN CAMERA REVIEW AND APPLYING THE CRIMEFRAUD EXCEPTION re #124 Response to Motion, #122 MOTION for Partial Summary Judgment on Count I Breach of Contract, #123 Declaration,,,,,,,,, #126 Emergency MOTION Compel to Destroy, #122 MOTION for Partial Summary Judgment on Count I Breach of Contract, #126 Emergency MOTION Compel to Destroy , #138 Emergency MOTION for Temporary Restraining Order , PROTECTIVE ORDER, AND IN CAMERA REVIEW TO ADDRESS FRAUD ON THE COURT AND BREACH OF SETTLEMENT AGREEMENT, #123 Declaration,,,,,,,,, ; filed by Plaintiff Rosa Maria Cabrera Thompson. (Thompson, Rosa)
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Filing 141
PROPOSED ORDER (Unsigned) Additional Time (Molina, Zana)
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Filing 140
MOTION Additional Time , filed by Defendant Mukilteo School District No 6. Noting Date 8/25/2025, (Molina, Zana)
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Filing 139
PROPOSED ORDER (Unsigned) re #138 Emergency MOTION for Temporary Restraining Order , PROTECTIVE ORDER, AND IN CAMERA REVIEW TO ADDRESS FRAUD ON THE COURT AND BREACH OF SETTLEMENT AGREEMENT (Thompson, Rosa)
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Filing 138
Emergency MOTION for Temporary Restraining Order , PROTECTIVE ORDER, AND IN CAMERA REVIEW TO ADDRESS FRAUD ON THE COURT AND BREACH OF SETTLEMENT AGREEMENT, filed by Plaintiff Rosa Maria Cabrera Thompson. Noting Date 8/25/2025, (Thompson, Rosa)
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Filing 137
SURREPLY filed by Plaintiff Rosa Maria Cabrera Thompson re #126 Emergency MOTION Compel to Destroy (Thompson, Rosa)
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Filing 136
NOTICE PLAINTIFFS NOTICE OF INTENT TO FILE SURREPLY UNDER LCR 7(g) (REQUEST TO STRIKE NEW MATERIAL IN DEFENDANTS REPLY) re #126 Emergency MOTION Compel to Destroy , #133 Reply to Response to Motion ; filed by Plaintiff Rosa Maria Cabrera Thompson. (Thompson, Rosa)
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Filing 135
DECLARATION Updated of Zana Molina re #127 Declaration by Defendant Mukilteo School District No 6 (Molina, Zana) Modified linkage on 8/25/2025 (KRA).
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Filing 134
ERRATA re #127 Declaration by Defendant Mukilteo School District No 6 (Molina, Zana)
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Filing 133
REPLY, filed by Defendant Mukilteo School District No 6, TO RESPONSE to #126 Emergency MOTION Compel to Destroy (Attachments: #1 Exhibit)(Molina, Zana)
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Filing 132
PRAECIPE re #128 Response to Motion by Plaintiff Rosa Maria Cabrera Thompson (Attachments: #1 Exhibit Exhibit 1-Corrected Opposition and Cross Motion)(Thompson, Rosa)
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Filing 131
MOTION IN CAMERA REVIEW AND APPLYING THE CRIMEFRAUD EXCEPTION re #124 Response to Motion, #122 MOTION for Partial Summary Judgment on Count I Breach of Contract, #123 Declaration,,,,,,,,, #126 Emergency MOTION Compel to Destroy , #128 Response to Motion , filed by Plaintiff Rosa Maria Cabrera Thompson. (Attachments: #1 Proposed Order) Noting Date 9/5/2025, (Thompson, Rosa)
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Filing 130
REPLY, filed by Plaintiff Rosa Maria Cabrera Thompson, TO RESPONSE to #118 MOTION for Sanctions (Thompson, Rosa)
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Filing 129
DECLARATION of ROSA MARIA CABRERA THOMPSON filed by Plaintiff Rosa Maria Cabrera Thompson re #126 Emergency MOTION Compel to Destroy (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit, #4 Exhibit)(Thompson, Rosa)
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Filing 128
RESPONSE, by Plaintiff Rosa Maria Cabrera Thompson, to #126 Emergency MOTION Compel to Destroy . (Attachments: #1 Proposed Order)(Thompson, Rosa)
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Filing 127
DECLARATION of Zana Molina filed by Defendant Mukilteo School District No 6 re #126 Emergency MOTION Compel to Destroy (Molina, Zana)
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Filing 126
Emergency MOTION Compel to Destroy , filed by Defendant Mukilteo School District No 6. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F) Noting Date 9/19/2025, (Starks, Megan)
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Filing 125
DECLARATION of ZANA T. MOLINA IN SUPPORT OF DEFENDANTS RESPONSE TO PLAINTIFFS MOTION FOR SANCTIONS [DKT. 118] AND DEFENDANTS MOTION TO STRIKE SECTIONS OF PLAINTIFFS MOTION FOR SANCTIONS re #124 Response to Motion, by Defendant Mukilteo School District No 6 (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K)(Molina, Zana)
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Filing 124
RESPONSE, by Defendant Mukilteo School District No 6, to #118 MOTION for Sanctions . (Attachments: #1 Proposed Order [PROPOSED] ORDER DENYING PLAINTIFFS MOTION FOR SANCTIONS AND STRIKING IN PART PLAINTIFFS MOTION FOR SANCTIONS)(Molina, Zana)
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Filing 123
DECLARATION of ROSA MARIA CABRERA THOMPSON filed by Plaintiff Rosa Maria Cabrera Thompson re #122 MOTION for Partial Summary Judgment on Count I Breach of Contract (Attachments: #1 Supplement, #2 Exhibit Ragonesi-Neal EEOC Notice Email Exchange 1, #3 Exhibit Ragonesi-Neal EEOC Notice Email Exchange 2, #4 Exhibit WSRMP-MSD-KBM Lawyers collusion, #5 Exhibit MSD-Cabrera Seperation Agreement, #6 Exhibit WSRMP advising Ragonesi of RCT resolved (resignation) notice 11-3-2023, #7 Exhibit 11-15-23 Neal -Ragonesi illegal email exchanges under guise of Stokes Lawrence Invoice--See Ex. D & E-part 1, #8 Exhibit 11-15-23 Neal -Ragonesi illegal email exchanges under guise of Stokes Lawrence Invoice--See Ex. D & E-part 2, #9 Exhibit 11-29-23 Neal-Ragonesi illegal email and call exchange and call log with VM--See exhibit D & E, #10 Exhibit Neal-Shurtleff email exchange in re: plaintiff's reference checks, #11 Exhibit Ragonesi's uncivil and illegal retaliation email weaponizing illegal and fraudulent investigation report for RCT--see Exhibit D, E, and W, #12 Exhibit Ragonesi legal asst. circulates final investigation report R. Cabrera, #13 Exhibit Ragonesi closing report in re matters Cabrera Thompson, #14 Exhibit Ragonesi-WSRMP final invoice email in re: Rosa Cabrera Thompson (RCT), #15 Exhibit SPS EEOC Charge of Discrimination Notice, #16 Exhibit SPS Tort Claim email, #17 Exhibit WSRMP, KBM attorneys (Ragonesi's firm), and PattersonBuchannan attorneys (MSD Counsel) billing invoice that proves ongoing inter-district collusion and RICO activity, #18 Exhibit Ragonesi's legal asst. illegally shares plaintiff's discovery docs w/o plaintiff consent, #19 Exhibit KBM invoice charging for illegal and fraudulent services (Ragonesi-Neal exchange) see exhibits D, E, W, #20 Exhibit PRR Privilege log-11-29-2023 email-call-VM excluded, #21 Exhibit WSRMP-Morgenthaler communication with Ragonesi in re: new EEOC activity for plaintiff, #22 Exhibit US DOE OCR letter to MSD OCR Ref. no 10241148--prior to Ragonesi closing file, #23 Exhibit EEOC notice of fully executed settlement and Neal's notice to Brynelson (MSD Supt) and Dowd (MSD Asst. Supt) all were aware of fully executed EEOC settlement NLT 10/30/23)(Thompson, Rosa)
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Filing 122
MOTION for Partial Summary Judgment on Count I Breach of Contract, filed by Plaintiff Rosa Maria Cabrera Thompson. (Attachments: #1 Proposed Order) Noting Date 9/16/2025, (Thompson, Rosa)
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Filing 121
DECLARATION of ROSA MARIA CABRERA THOMPSON re #120 Notice-Other,, #111 Amended Complaint by Plaintiff Rosa Maria Cabrera Thompson (Attachments: #1 Exhibit Motion to Disqualify Conflicted Attorney Shannon Ragonesi Seattle Public Schools (SPS), #2 Exhibit Plaintiff's Reply in Support of Motion to Disqualify Conflicted Attorney Shannon Ragonesi Seattle Public Schools (SPS), #3 Exhibit Conflicted Attorney Shannon Ragonesi Seattle Public Schools (SPS) Contract while also Simultaneously under Contract/Retainer with Mukilteo School District (MSD))(Thompson, Rosa)
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Filing 120
NOTICE NOTICE of Filing Corrected Second Amended Complaint re [Dkt. #111] by Plaintiff Rosa Maria Cabrera Thompson re #112 Notice-Other, #110 Order on Motion to Amend, #111 Amended Complaint ; filed by Plaintiff Rosa Maria Cabrera Thompson. (Attachments: #1 Exhibit EXHIBIT A-Corrected Second Amended Complaint (numbered paragraphs + incorporation statements), #2 Exhibit EXHIBIT B-Original Complaint (Dkt. #1), #3 Exhibit EXHIBIT C-First Amended Complaint (Dkt. #46))(Thompson, Rosa)
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Filing 119
DECLARATION of ROSA MARIA CABRERA THOMPSON filed by Plaintiff Rosa Maria Cabrera Thompson re #90 Notice of Intent to Seek Sanctions Under FRCP 37(b)(2)(A) re #79 Emergency MOTION for Protective Order Renewed Protective Order, #86 Proposed Order (Unsigned), Set/Reset Hearings, #89 Brief,,,, #80 Emergency MOTION for Prote, #118 MOTION for Sanctions (Attachments: #1 Supplement, #2 Exhibit, #3 Exhibit)(Thompson, Rosa)
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Filing 118
MOTION for Sanctions , filed by Plaintiff Rosa Maria Cabrera Thompson. (Attachments: #1 Proposed Order) Noting Date 8/22/2025, (Thompson, Rosa)
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Filing 117
MOTION for Discovery Plaintiffs Motion for Entry of ESI Protocol [Proposed ESI Order Attached], filed by Plaintiff Rosa Maria Cabrera Thompson. (Attachments: #1 Exhibit Exhibit A-Plaintiff's Proposed ESI Order) Noting Date 8/22/2025, (Thompson, Rosa)
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Filing 116
DECLARATION of ATTORNEY ZANA T. MOLINA IN SUPPORT OF DEFENDANTS MOTION TO ADOPT A MODIFIED MODEL COURT ELECTRONICALLY STORED INFORMATION (ESI) AGREEMENT filed by Defendant Mukilteo School District No 6 re #115 MOTION TO ADOPT A MODIFIED MODEL COURT ELECTRONICALLY STORED INFORMATION (ESI) AGREEMENT (Molina, Zana)
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Filing 115
MOTION TO ADOPT A MODIFIED MODEL COURT ELECTRONICALLY STORED INFORMATION (ESI) AGREEMENT, filed by Defendant Mukilteo School District No 6. (Attachments: #1 Proposed Order Defendants Proposed Modified ESI Agreement and Order Granting Defendants Proposed Modified ESI Agreement) Noting Date 8/22/2025, (Molina, Zana)
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Filing 114
CERTIFICATE OF SERVICE by Plaintiff Rosa Maria Cabrera Thompson re #96 Praecipe-Other Fully Executed Certificate of Service (Thompson, Rosa)
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Filing 113
CERTIFICATE OF SERVICE by Plaintiff Rosa Maria Cabrera Thompson re #95 Praecipe-Other Fully Executed Certificate of Service (Thompson, Rosa)
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Filing 112
NOTICE OF FILING OF AMENDED COMPLAINT PURSUANT TO COURT ORDER re #111 Amended Complaint ; filed by Plaintiff Rosa Maria Cabrera Thompson. (Thompson, Rosa)
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Filing 111
Second AMENDED COMPLAINT against defendant(s) Mukilteo School District No 6 with JURY DEMAND filed by Rosa Maria Cabrera Thompson. (Attachments: #1 Proposed Order)(Thompson, Rosa)
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Filing 110
ORDER granting in part and denying in part Plaintiff's #97 Motion to Amend. The Court DIRECTS Thompson to "file and serve the amended pleading on all parties within fourteen (14) days of the filing of [this] order." Once Thompson has filed and served her amended pleading, the Court DIRECTS the District to file a responsive pleading within SIXTY (60) days. Signed by Judge Jamal N Whitehead. (LH)
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Filing 109
ORDER SETTING TRIAL DATE AND RELATED DATES by Judge Jamal N Whitehead. Length of Trial: 6-12 days. Jury Trial is set for 12/7/2026 at 09:00 AM in Courtroom 16106 before Judge Jamal N Whitehead. Joinder of Parties due by 9/19/2025, Amended Pleadings due by 5/11/2026, Expert Witness Disclosure/Reports under FRCP 26(a)(2) due by 5/11/2026, Discovery Motions due by 6/10/2026, Discovery completed by 7/10/2026, Dispositive motions due by 8/10/2026, Attorney settlement conference to be held by 10/8/2026, Motions in Limine due by 10/28/2026, Deposition Designations due by 11/16/2026, Pretrial Order due by 11/16/2026, Trial briefs to be submitted by 11/23/2026, Proposed voir dire questions due by 11/23/2026, Proposed jury instructions due by 11/23/2026, Pretrial Conference set for 11/30/2026 at 09:00 AM in Courtroom 16106 before Judge Jamal N Whitehead. Signed by Judge Jamal N Whitehead. (GC)
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Filing 108
JOINT STATUS REPORT signed by all parties. Estimated Trial Days: 6-12. Filed by Plaintiff Rosa Maria Cabrera Thompson.(Thompson, Rosa)
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Filing 107
ERRATA re #105 Status Report, #106 Errata Corrected Formatting Issues by Plaintiff Rosa Maria Cabrera Thompson (Attachments: #1 Exhibit Exhibit A-Corrected Formatting Issues and Signature)(Thompson, Rosa)
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Filing 106
ERRATA re #105 Status Report Plaintiff's Signature added to JSR by Plaintiff Rosa Maria Cabrera Thompson (Attachments: #1 Exhibit Exhibit A-JSR with Plaintiff's Signature)(Thompson, Rosa)
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Filing 105
STATUS REPORT by Defendant Mukilteo School District No 6 (Molina, Zana)
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Filing 104
REPLY, filed by Plaintiff Rosa Maria Cabrera Thompson, TO RESPONSE to #97 MOTION to Amend #46 Amended Complaint,,,,,SECOND AMENDED CIVIL RIGHTS COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF (Attachments: #1 Proposed Order)(Thompson, Rosa)
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Filing 103
DECLARATION of ZANA T. MOLINA IN SUPPORT OF DEFENDANT MUKILTEO SCHOOL DISTRICTS OPPOSITION TO PLAINTIFFS MOTION FOR LEAVE TO FILE SECOND AMENDED COMPLAINT re #102 Response to Motion by Defendant Mukilteo School District No 6 (Molina, Zana)
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Filing 102
RESPONSE, by Defendant Mukilteo School District No 6, to #97 MOTION to Amend #46 Amended Complaint,,,,,SECOND AMENDED CIVIL RIGHTS COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF. (Attachments: #1 Proposed Order)(Molina, Zana)
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Filing 101
CERTIFICATE OF SERVICE by Plaintiff Rosa Maria Cabrera Thompson re #99 Certificate of Service Corrected Version-Fully Executed (Thompson, Rosa)
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Filing 100
CERTIFICATE OF SERVICE by Plaintiff Rosa Maria Cabrera Thompson Fully Executed Certificate of Service (Thompson, Rosa)
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Filing 99
CERTIFICATE OF SERVICE by Plaintiff Rosa Maria Cabrera Thompson Fully Executed Certificate of Service (Thompson, Rosa)
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Filing 98
PRAECIPE Clerks Signature Needed by Plaintiff Rosa Maria Cabrera Thompson (Attachments: #1 Supplement)(Thompson, Rosa)
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Noting Date Reset re #97 MOTION to Amend #46 Amended Complaint SECOND AMENDED CIVIL RIGHTS COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF: Noting Date 7/22/2025. Reset per LCR 7(d)(3). (CJS)
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Filing 97
MOTION to Amend #46 Amended Complaint,,,,,SECOND AMENDED CIVIL RIGHTS COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF, filed by Plaintiff Rosa Maria Cabrera Thompson. (Attachments: #1 Exhibit Clean Version, #2 Exhibit Redlined Version, #3 Proposed Order) Noting Date 7/22/2025 7/18/2025, (Thompson, Rosa) Modified noting date on 7/2/2025 (CJS).
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Filing 96
PRAECIPE Clerks Signature Needed by Plaintiff Rosa Maria Cabrera Thompson (Attachments: #1 Supplement)(Thompson, Rosa)
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Filing 95
PRAECIPE Clerks Signature Needed by Plaintiff Rosa Maria Cabrera Thompson (Attachments: #1 Supplement)(Thompson, Rosa)
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Filing 94
MINUTE ENTRY for proceedings held before Judge Jamal N Whitehead - Dep Clerk: D. Staples; Pla Counsel: Rosa Thompson (Pro Se); Def Counsel: Megan Starks, Zana Molina; CR: Marci Chatelain; Time of Hearing: 1:00 PM; Courtroom: held via Zoom;Status Conference held on 6/24/2025. The Court holds a hearing to discuss the status and progress of this case. After hearing argument from the parties, the Court, for the reasons stated on the record, ORDERS as follows: The Court STRIKES the Motion to Amend, Dkt. No. #88 , and DIRECTS Thompson to submit an amended motion to amend within SEVEN (7) days of this Order. The Court DIRECTS Thompson to file her motion to amend in compliance with Local Civil Rule 15, which requires; among other things, that "[a] party who moves for leave to amend a pleading must attach a copy of the proposed amended pleading as an exhibit to the motion" and "must indicate on the proposed amended pleading how it differs from the pleading that it amends by bracketing or striking through the text to be deleted and underlining or highlighting the text to be added." See LCR 15(a). Defendant's opposition to Thompson's motion to amend, if any, is due TEN (10) days from the date of this Order, and Plaintiff's reply in support of the motion, if any, is due FOURTEEN (14) days from the date of this Order. Because Thompson indicates an intent to amend her complaint, the deadline for Defendant to file a responsive pleading under Fed. R. Civ. P.12 is STAYED pending resolution of any forthcoming motion to amend. (DS)
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Filing 93
ORDER. This Omnibus Order resolves all but one pending motion (Dkt. #88 ). The Court ORDERS as follows: The Court DENIES all pending requests for judicial notice and in camera review of evidence. The Court DENIES the request to coordinate this action with Thompsons other pending litigation in federal court. The Court DENIES all pending discovery motions, including Thompson's numerous motions for emergency protective orders. The Court DENIES Thompson's motion for entry of default. The Court DENIES all pending motions to strike. The Court DENIES all pending requests for sanctions, attorneys' fees, and costs. However, the Court warns Thompson that if she continues to seek discovery-related orders without following procedural rules, the Court may impose pre-filing restrictions or other sanctions. The District's motion to dismiss is GRANTED IN PART. Thompson's defamation claim (Count Five) and outrage claim (Count Seven) are DISMISSED WITHOUT PREJUDICE. The motion to dismiss is DENIED in all other respects. The scheduling order at Dkt. No. #77 remains in effect. The parties will have a chance to raise any questions or issues with the Court at a status conference that has been scheduled for Tuesday, 6/24/2025, at 1:00 PM (PST). Signed by Judge Jamal N Whitehead. (APH)
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Filing 92
NOTICE of Related Case(s) 2:25-cv-00468-TL, by Plaintiff Rosa Maria Cabrera Thompson. (Thompson, Rosa)
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Filing 91
STRICKEN NOTICE of Related Case(s) 2:25-cv-00468-TL, by Plaintiff Rosa Maria Cabrera Thompson. (Thompson, Rosa) Modified to strike per filer's request on 6/23/2025 (APH).
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Filing 90
MOTION Notice of Intent to Seek Sanctions Under FRCP 37(b)(2)(A) re #79 Emergency MOTION for Protective Order Renewed Protective Order, #86 Proposed Order (Unsigned), Set/Reset Hearings, #89 Brief,,,, #80 Emergency MOTION for Protective Order PLAINTIFFS EMERGENCY MOTION FOR EVIDENCE PRESERVATION ORDER Plaintiff moves this Court to issue an emergency evidence preservation order. Noting Date: 6/16/2025 no later than 6/23/2025. , filed by Plaintiff Rosa Maria Cabrera Thompson. Noting Date 7/2/2025, (Thompson, Rosa) Modified to strike "Motion" to reflect document case caption on 6/23/2025 (APH).
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Filing 89
Supplemental BRIEF re #58 MOTION for Default against Mukilteo School District,, #74 Emergency MOTION for Protective Order Plaintiff submits the attached Motion for Emergency Protective Order, Sanctions for Spoliation, and to Stay Joint Discovery Coordination, along with a [Proposed] Order., #69 MOTION MOTION FOR JUDICIAL NOTICE OF RELATED CASE AND LIMITED COORDINATION , #88 MOTION to Amend #46 Amended Complaint,,,, #1 Complaint, #65 MOTION to Dismiss Partially,, #49 MOTION for Judgment on the Pleadings , #80 Emergency MOTION for Protective Order PLAINTIFFS EMERGENCY MOTION FOR EVIDENCE PRESERVATION ORDER Plaintiff moves this Court to issue an emergency evidence preservation order. Noting Date: 6/16/2025 no later than 6/23/2025., #70 MOTION MOTION for Miscellaneous Relief: Motion to Strike Defendants Partial Motion to Dismiss (Dkt. 65) filed by Rosa Maria Cabrera Thompson. re #65 MOTION to Dismiss Partially, #69 MOTION MOTION FOR JUDICIAL NOTICE OF RELATED CASE AN, #79 Emergency MOTION for Protective Order Renewed Protective Order by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 88
MOTION to Amend #46 Amended Complaint,,,, #1 Complaint, #65 MOTION to Dismiss Partially,, filed by Plaintiff Rosa Maria Cabrera Thompson. (Attachments: #1 Proposed Order) Noting Date 7/7/2025, (Thompson, Rosa)
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Filing 87
ERRATA re #82 Response to Motion,, #72 Response to Motion, #60 Response to Motion, #78 Response to Motion,, #65 MOTION to Dismiss Partially, #76 Surreply by Defendant Mukilteo School District No 6 (Attachments: #1 Supplement Amended Dkt. 60, #2 Supplement Amended Dkt. 65, #3 Supplement Amended Dkt. 72, #4 Supplement Amended Dkt. 76, #5 Supplement Amended Dkt. 78, #6 Supplement Amended Dkt. 82)(Molina, Zana)
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Set/Reset Hearings: Status Conference set for 6/24/2025 at 01:00 PM before Judge Jamal N Whitehead. This hearing will be held remotely using Zoom. (GC)
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Filing 86
PROPOSED ORDER (Unsigned) re #81 Declaration, #80 Emergency MOTION for Protective Order PLAINTIFFS EMERGENCY MOTION FOR EVIDENCE PRESERVATION ORDER Plaintiff moves this Court to issue an emergency evidence preservation order. Noting Date: 6/16/2025 no later than 6/23/2025., #79 Emergency MOTION for Protective Order Renewed Protective Order (Thompson, Rosa)
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Filing 85
Second DECLARATION of ROSA MARIA CABRERA THOMPSON filed by Plaintiff Rosa Maria Cabrera Thompson re #80 Emergency MOTION for Protective Order PLAINTIFFS EMERGENCY MOTION FOR EVIDENCE PRESERVATION ORDER Plaintiff moves this Court to issue an emergency evidence preservation order. Noting Date: 6/16/2025 no later than 6/23/2025. (Attachments: #1 Exhibit Exhibit A-Email to Shannon Ragonesi re: Meet and Confer on Disqualification (June 1, 2025) and renewed attempt to Meet & Confer (June 17, 2025), #2 Exhibit Exhibit B-Email to MSD Counsel Re: Request for Documents Under FRCP 26 / LCR 37 (June 17, 2025), #3 Exhibit Exhibit C-MSDs Refusal to Meet and Confer and Produce Public Records (June 17, 2025))(Thompson, Rosa)
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Filing 84
REPLY, filed by Plaintiff Rosa Maria Cabrera Thompson, TO RESPONSE to #80 Emergency MOTION for Protective Order PLAINTIFFS EMERGENCY MOTION FOR EVIDENCE PRESERVATION ORDER Plaintiff moves this Court to issue an emergency evidence preservation order. Noting Date: 6/16/2025 no later than 6/23/2025. (Thompson, Rosa)
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Filing 83
DECLARATION of ATTORNEY ZANA T. MOLINAS DECLARATION IN SUPPORT OF DEFENDANTS RESPONSE TO PLAINTIFFS EMERGENCY MOTION FOR EVIDENCE PRESERVATION ORDER [DKT. 80] AND PLAINTIFFS RENEWED MOTION FOR PROTECTIVE ORDER, SANCTIONS, IN CAMERA REVIEW, AND COMPELLED RELEASE OF WRONGFULLY WITHHELD VOICEMAILS [DKT. 79] re #82 Response to Motion,, by Defendant Mukilteo School District No 6 (Attachments: #1 Exhibit F)(Molina, Zana)
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Filing 82
RESPONSE, by Defendant Mukilteo School District No 6, to #80 Emergency MOTION for Protective Order PLAINTIFFS EMERGENCY MOTION FOR EVIDENCE PRESERVATION ORDER Plaintiff moves this Court to issue an emergency evidence preservation order. Noting Date: 6/16/2025 no later than 6/23/2025., #79 Emergency MOTION for Protective Order Renewed Protective Order. (Attachments: #1 Proposed Order ORDER DENYING PLAINTIFFS EMERGENCY MOTION FOR EVIDENCE PRESERVATION ORDER [DKT. 80] AND PLAINTIFFS RENEWED MOTION FOR PROTECTIVE ORDER, SANCTIONS, IN CAMERA REVIEW, AND COMPELLED RELEASE OF WRONGFULLY WITHHELD VOICEMAILS [DKT. 79])(Molina, Zana)
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Filing 81
Emergency DECLARATION of ROSA MARIA CABRERA THOMPSON filed by Plaintiff Rosa Maria Cabrera Thompson re #80 Emergency MOTION for Protective Order PLAINTIFFS EMERGENCY MOTION FOR EVIDENCE PRESERVATION ORDER Plaintiff moves this Court to issue an emergency evidence preservation order. Noting Date: 6/16/2025 no later than 6/23/2025. (Thompson, Rosa)
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Filing 80
Emergency MOTION for Protective Order PLAINTIFFS EMERGENCY MOTION FOR EVIDENCE PRESERVATION ORDER Plaintiff moves this Court to issue an emergency evidence preservation order. Noting Date: 6/16/2025 no later than 6/23/2025., filed by Plaintiff Rosa Maria Cabrera Thompson. (Attachments: #1 Proposed Order, #2 Exhibit Exhibit D_Shurtleff Call Logs (pages 3-4), #3 Exhibit Exhibit D_Neal Call Logs, #4 Exhibit Exhibit H_Subpoena, #5 Exhibit Exhibit H_Schedule A, #6 Exhibit Exhibit J-MSD Objections, #7 Exhibit Exhibit A-EEOC Agreement, #8 Exhibit Exhibit B-Job revocation from Dr. Hart, #9 Exhibit Exhibit C-Ragonesi Voicemail & Call to Neal, #10 Exhibit Exhibit E-Neal Correspondence Email with Hart, #11 Exhibit Exhibit F: PRA Request 1-5-2024, #12 Exhibit Exhibit G: PRA Appeal 3-15-2025, #13 Exhibit Exhibit I: Waiver of Service for Subpoena, #14 Exhibit Exhibit K: Voicemail Transcript Goodpastor to Stevens (MSD Asst. Superintendent) references Miner (ESD Superintendent), #15 Exhibit Exhibit N: Zhu Case Excerpt, #16 Exhibit Exhibit L: Voicemail Request History Chart (January 5, 2024 June 13, 2025), #17 Exhibit Exhibit M: Summary of Post Job Denials) Noting Date 6/16/2025, (Thompson, Rosa)
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Filing 79
Emergency MOTION for Protective Order Renewed Protective Order, filed by Plaintiff Rosa Maria Cabrera Thompson. (Attachments: #1 Proposed Order, #2 Exhibit Subpoena for Tammy Bengen (MSD)) Noting Date 6/16/2025, (Thompson, Rosa)
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Filing 78
RESPONSE, by Defendant Mukilteo School District No 6, to #74 Emergency MOTION for Protective Order Plaintiff submits the attached Motion for Emergency Protective Order, Sanctions for Spoliation, and to Stay Joint Discovery Coordination, along with a [Proposed] Order.. (Attachments: #1 Proposed Order ORDER GRANTING DEFENDANTS MOTION TO STRIKE AND DENYING PLAINTIFFS MOTION FOR EMERGENCY PROTECTIVE ORDER, SANCTIONS FOR SPOILATION, AND TO STAY JOINT DISCOVERY COORDINATION WITH PREJUDICE)(Starks, Megan Molina, Zana) Modified to reflect correct filing attorney on 6/12/2025 (CJS).
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Filing 77
ORDER REGARDING INITIAL DISCLOSURES AND JOINT STATUS REPORT FRCP 26(f) Conference Deadline is 6/27/2025, Initial Disclosure Deadline is 7/11/2025, Joint Status Report due by 7/18/2025. Signed by Judge Jamal N Whitehead. (GC)
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Filing 76
SURREPLY filed by Defendant Mukilteo School District No 6 re #69 MOTION MOTION FOR JUDICIAL NOTICE OF RELATED CASE AND LIMITED COORDINATION Surreply re #73 (Molina, Zana)
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Filing 75
NOTICE Of Intent to File a Surreply re #73 Reply to Response to Motion,, ; filed by Defendant Mukilteo School District No 6. (Molina, Zana)
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Noting Date Reset re #74 Emergency MOTION for Protective Order Plaintiff submits the attached Motion for Emergency Protective Order, Sanctions for Spoliation, and to Stay Joint Discovery Coordination, along with a [Proposed] Order.: Noting Date 6/16/2025. Reset per LCR 7(d)(2) and direction of chambers.(CJS)
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Filing 74
Emergency MOTION for Protective Order Plaintiff submits the attached Motion for Emergency Protective Order, Sanctions for Spoliation, and to Stay Joint Discovery Coordination, along with a [Proposed] Order., filed by Plaintiff Rosa Maria Cabrera Thompson. (Attachments: #1 Proposed Order) Noting Date 6/16/2025 6/5/2025, (Thompson, Rosa) Modified noting date per LCR 7(d)(2) on 6/3/2025 (CJS).
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Filing 73
REPLY, filed by Plaintiff Rosa Maria Cabrera Thompson, TO RESPONSE to #70 MOTION MOTION for Miscellaneous Relief: Motion to Strike Defendants Partial Motion to Dismiss (Dkt. 65) filed by Rosa Maria Cabrera Thompson. re #65 MOTION to Dismiss Partially, #69 MOTION MOTION FOR JUDICIAL NOTICE OF RELATED CASE AN, #65 MOTION to Dismiss Partially, #69 MOTION MOTION FOR JUDICIAL NOTICE OF RELATED CASE AND LIMITED COORDINATION (Attachments: #1 Proposed Order, #2 Supplement Declaration, #3 Exhibit Exhibit 43, #4 Exhibit Exhibit 3)(Thompson, Rosa)
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Filing 72
RESPONSE, by Defendant Mukilteo School District No 6, to #69 MOTION MOTION FOR JUDICIAL NOTICE OF RELATED CASE AND LIMITED COORDINATION . (Attachments: #1 Proposed Order ORDER PARTIALLY DENYING PLAINTIFFS MOTION FOR JUDICIAL NOTICE OF RELATED CASES AND LIMITED COORDINATION)(Molina, Zana)
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Filing 71
NOTICE of Unavailability of counsel Megan F Starks for All Defendants from 5/21/2025-5/31/2025. (Starks, Megan)
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Filing 70
MOTION MOTION for Miscellaneous Relief: Motion to Strike Defendants Partial Motion to Dismiss (Dkt. 65) filed by Rosa Maria Cabrera Thompson. re #65 MOTION to Dismiss Partially, #69 MOTION MOTION FOR JUDICIAL NOTICE OF RELATED CASE AND LIMITED COORDINATION , filed by Plaintiff Rosa Maria Cabrera Thompson. (Attachments: #1 Proposed Order, #2 Exhibit Exhibit 42) Noting Date 6/6/2025, (Thompson, Rosa)
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Filing 69
MOTION MOTION FOR JUDICIAL NOTICE OF RELATED CASE AND LIMITED COORDINATION , filed by Plaintiff Rosa Maria Cabrera Thompson. (Attachments: #1 Proposed Order, #2 Supplement, #3 NOTICE OF MOTION AND MOTION FOR JUDICIAL NOTICE OF RELATED CASE AND LIMITED COORDINATION) Noting Date 6/6/2025, (Thompson, Rosa)
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Filing 68
NOTICE that the following is RE-NOTED: #58 MOTION for Default against Mukilteo School District,. Filed by Plaintiff Rosa Maria Cabrera Thompson. Noting Date 6/6/2025, (Thompson, Rosa)
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Filing 67
RESPONSIVE BRIEF re #61 Reply to Response to Motion, #64 Declaration (non motion), #66 Errata,, #60 Response to Motion, #63 Surreply, #65 MOTION to Dismiss Partially, #62 Notice-Other by Plaintiff Rosa Maria Cabrera Thompson. (Attachments: #1 Proposed Order, #2 Supplement)(Thompson, Rosa)
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Filing 66
ERRATA re #64 Declaration (non motion), #63 Surreply [63-1] Proposed Order by Defendant Mukilteo School District No 6 (Attachments: #1 Exhibit Amended Declaration of Attorney Zana T. Molina in Support of Defendants Surreply and Motion to Strike Plaintiffs Reply in Support of Motion for Clerks Entry of Default, #2 Exhibit Amended Defendant's Proposed Order Granting Defendants Motion to Strike Plaintiffs Reply in Support of Motion for Clerks Entry of Default and Denying Plaintiffs Motion for Default)(Molina, Zana)
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Filing 65
MOTION to Dismiss Partially, filed by All Defendants. (Attachments: #1 Proposed Order) Noting Date 6/6/2025, (Starks, Megan)
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Filing 64
DECLARATION of ZANA T. MOLINA IN SUPPORT OF DEFENDANTS SURREPLY AND MOTION TO STRIKE PLAINTIFFS REPLY IN SUPPORT OF MOTION FOR CLERKS ENTRY OF DEFAULT re #63 Surreply by Defendant Mukilteo School District No 6 (Attachments: #1 Exhibit D, #2 Exhibit E)(Molina, Zana)
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Filing 63
SURREPLY filed by Defendant Mukilteo School District No 6 re #58 MOTION for Default against Mukilteo School District, Surreply re #61 (Attachments: #1 Proposed Order)(Molina, Zana)
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Filing 62
NOTICE Of Intent to File a Surreply re #61 Reply to Response to Motion ; filed by Defendant Mukilteo School District No 6. (Molina, Zana)
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Filing 61
REPLY, filed by Plaintiff Rosa Maria Cabrera Thompson, TO RESPONSE to #58 MOTION for Default against Mukilteo School District, (Attachments: #1 Exhibit)(Thompson, Rosa)
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Filing 60
RESPONSE, by All Defendants, to #58 MOTION for Default against Mukilteo School District,. (Attachments: #1 Proposed Order)(Starks, Megan)
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Filing 59
REPLY, filed by Plaintiff Rosa Maria Cabrera Thompson, TO RESPONSE to #49 MOTION for Judgment on the Pleadings (Attachments: #1 Supplement Declaration, #2 Proposed Order)(Thompson, Rosa)
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Filing 58
MOTION for Default against Mukilteo School District,, filed by Plaintiff Rosa Maria Cabrera Thompson. (Attachments: #1 Proposed Order, #2 Supplement Declaration of Plaintiff)(Thompson, Rosa)
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Filing 57
RESPONSE, by Defendant Mukilteo School District No 6, to #49 MOTION for Judgment on the Pleadings . (Attachments: #1 Proposed Order ORDER DENYING PLAINTIFFS MOTION)(Molina, Zana)
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Filing 56
ORDER denying Plaintiff's #33 Motion for Protective Order and Plaintiff's #35 Motion for Sanctions. The Court declines to impose an award of attorney's fees and costs in the District's favor. Signed by Judge Jamal N Whitehead. (KRA)
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Filing 55
ERRATA re #40 Response to Motion by Defendant Mukilteo School District No 6 (Molina, Zana)
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Filing 54
DECLARATION of Megan F. Starks filed by Defendant Mukilteo School District No 6 re #51 Emergency MOTION for Protective Order (Attachments: #1 Exhibit Exhibit B, #2 Exhibit Exhibit C)(Molina, Zana)
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Filing 53
RESPONSE, by Defendant Mukilteo School District No 6, to #51 Emergency MOTION for Protective Order . (Attachments: #1 Proposed Order ORDER DENYING PLAINTIFFS MOTION)(Molina, Zana)
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Filing 52
MINUTE ORDER (text-only) made at the direction of the Honorable Jamal N. Whitehead: The Court issues this Minute Order to clarify apparent confusion among the Parties regarding noting dates, which in this District are governed by Local Civil Rule 7(d). On April 21, pro se Plaintiff Rosa Maria Cabrera Thompson filed a Motion for Judicial Notice, which she noted for consideration on April 25. Dkt. No. #49 . On April 22, in accordance with LCR 7(d)(3), the Court re-noted the Motion for Judicial Notice as a 21-day motion. See id. Two days later, on April 24, Thompson filed an Emergency Motion for Protective Order, which she noted for consideration on April 28. Dkt. No. #51 . Thompson argues the motion should be treated "emergently under FRCP 26(c), 11, 26(g), and 37." Id. at 2. But none of these authorities cited displace the rules set forth in LCR 7(d). As such, the Court DIRECTS the Clerk of Court to re-note Thompson's motion at Dkt. No. #51 as a 14-day motion under LCR 7(d)(2). Authorized by Judge Jamal N Whitehead. (KRA)
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Filing 51
Emergency MOTION for Protective Order , filed by Plaintiff Rosa Maria Cabrera Thompson. (Attachments: #1 Proposed Order, #2 Supplement Declaration, #3 Exhibit PRA request to Kennewick SD from MSD, #4 Exhibit Screenshot of PRA Request to KSD, #5 Exhibit Defendant Counsel Response to Demand From Plaintiff to cease improper discovery, #6 Exhibit EEOC Charge No: 551-2023-03533 Agreement, #7 Exhibit New EEOC Charge-OCR letter to Superintendent) Noting Date 05/08/2025 4/28/2025, (Thompson, Rosa) Modified noting date per Dkt. 52 Mintue Order on 4/25/2025 (KRA).
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NOTICE of Docket Text Modification re #49 MOTION for Judicial Notice of Administrative Law Judge Ruling, and Docket Note entered on 4/22/2025 regarding update to noting date for Dkt. #49 Motion: title of motion modified from Motion for Judgment on the Pleadings to Motion for Judicial Notice of Administrative Law Judge Ruling to reflect the title on the PDF document at Dkt. #49 . (KRA)
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Filing 50
REPLY, filed by Plaintiff Rosa Maria Cabrera Thompson, TO RESPONSE to #35 MOTION for Sanctions (Attachments: #1 Proposed Order, #2 Exhibit 33, #3 Exhibit 15, #4 Exhibit 16, #5 Exhibit 37, #6 Exhibit 22, #7 Exhibit 38, #8 Exhibit 10)(Thompson, Rosa)
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Noting Date Set/Reset per chambers direction re Plaintiff's #49 MOTION for Judicial Notice of Administrative Law Judge Ruling for Judgment on the Pleadings, pursuant to LCR 7(d)(3). Noting Date 5/12/2025. (KRA) Modified title to reflect title on PDF document at Dkt. #49 on 4/23/2025 (KRA).
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Filing 49
MOTION for Judicial Notice of Administrative Law Judge Ruling for Judgment on the Pleadings , filed by Plaintiff Rosa Maria Cabrera Thompson. (Attachments: #1 Exhibit ALJ Findings & Ruling, #2 Proposed Order) Noting Date 5/12/2025 4/25/2025, (Thompson, Rosa) Modified noting date on 4/22/2025 (KRA). Modified title to reflect title on PDF document on 4/23/2025 (KRA).
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Filing 48
RESPONSE, by Defendant Mukilteo School District No 6, to #35 MOTION for Sanctions . (Attachments: #1 Proposed Order ORDER DENYING PLAINTIFFS MOTION FOR SANCTIONS)(Molina, Zana)
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Filing 47
ERRATA re #40 Response to Motion by Defendant Mukilteo School District No 6 (Molina, Zana)
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Filing 46
Amended AMENDED COMPLAINT against defendant(s) Mukilteo School District No 6 with JURY DEMAND filed by Rosa Maria Cabrera Thompson. (Attachments: #1 Exhibit ALJ Decision, #2 Exhibit MSD Tort Claim Form & MSD Response, #3 Exhibit Evaluations (MSD & Shoreline), #4 Exhibit EEOC Charge No: 551-2023-03533 Agreement, #5 Exhibit Signed Seperation Agreement, #6 Exhibit Simone Neal Call Logs 11/29/23-12/7/2023, #7 Exhibit FPSD screening rubric and internal email confirming Plaintiff for interview, #8 Exhibit Stephen Shurtleff Call Logs 11/29/23-12/7/23, #9 Exhibit Email from Neal to Hart 12-1-2023, #10 Exhibit Completed Electronic References, #11 Exhibit Samuel Yuhan Call Log 12-12-23 thru 6-20-2024, #12 Exhibit Maria Stevens Call Logs 2-27-24 thru 11-14-24, #13 Exhibit Stephen Shurtleff Call Logs 1-30-24 thru 5-30-24, #14 Exhibit Simone Neal Call Logs 3-5-24 thru 6-6-24, #15 Exhibit Dr. Hart Email Correspondence (offer/revocation/reference check), #16 Exhibit Shurtleff: To Do December 1, 2023, #17 Exhibit Transcribed Voicemail, #18 Exhibit OCR Referral to EEOC and new EEOC Charge File)(Thompson, Rosa)
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Filing 45
RESPONSE, by Plaintiff Rosa Maria Cabrera Thompson, to #33 MOTION for Protective Order . (Attachments: #1 Exhibit Plaintiff Requests for Transcribed VM & VM, #2 Exhibit Transcribed VM from FPSD to MSD (defendant), #3 Exhibit Defendant originally denied Transcribed VM existed)(Thompson, Rosa)
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Filing 44
PROPOSED ORDER (Unsigned) re #33 MOTION for Protective Order , #42 Reply to Response to Motion, (Thompson, Rosa)
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Filing 43
DECLARATION of Rosa Maria Cabrera Thompson filed by Plaintiff Rosa Maria Cabrera Thompson re #33 MOTION for Protective Order (Attachments: #1 Exhibit 30-Defendant EEOC Position Statement (Reference to Investigation Report))(Thompson, Rosa)
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Filing 42
REPLY, filed by Plaintiff Rosa Maria Cabrera Thompson, TO RESPONSE to #33 MOTION for Protective Order , #35 MOTION for Sanctions (Attachments: #1 Exhibit 33-Email from Patty Dowd to Staff 4/3/2025, #2 Exhibit 2-EEOC Seperation Agreement, #3 Exhibit 3-Seperation Agreement, #4 Exhibit 30-reference to investigation report, #5 Exhibit 5-Plaintiff request for investigation report)(Thompson, Rosa)
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Filing 41
DECLARATION of Megan F. Starks In Support Of Defendants Response To Plaintiffs Motion For Protective Order filed by Defendant Mukilteo School District No 6 re #33 MOTION for Protective Order (Attachments: #1 Exhibit Exhibit A)(Molina, Zana)
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Filing 40
RESPONSE, by Defendant Mukilteo School District No 6, to #33 MOTION for Protective Order . (Attachments: #1 Proposed Order)(Molina, Zana)
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Filing 39
NOTICE of Appearance by attorney Zana T Molina on behalf of Defendant Mukilteo School District No 6. (Molina, Zana)
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Filing 38
SERVICE OF SUMMONS and Complaint returned executed upon defendant Mukilteo School District No 6 on 4/15/2025 (Thompson, Rosa)
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Filing 37
Summons(es) Electronically Issued as to defendant(s) Mukilteo School District No 6. (KRA)
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Filing 36
NOTICE of Appearance by attorney Megan F Starks on behalf of Defendant Mukilteo School District No 6. (Starks, Megan)
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Noting Dates Set/Reset, per chambers direction: #33 MOTION for Protective Order re-noted for 4/18/2025, per LCR 7(d)(2). #35 MOTION for Sanctions re-noted for 4/28/2025, per LCR 7(d)(3). (KRA)
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Filing 35
MOTION for Sanctions , filed by Plaintiff Rosa Maria Cabrera Thompson. (Attachments: #1 Exhibit 33-Email from Patty Dowd to Staff 4/3/2025, #2 Exhibit 32-Judge's Discovery Order) Noting Date 4/28/2025 4/11/2025, (Thompson, Rosa) Modified noting date on 4/7/2025 (KRA).
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Filing 34
EXHIBIT 34-USPS Certificated Mail Receipt-Motion for P.O. re #33 MOTION for Protective Order by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 33
MOTION for Protective Order , filed by Plaintiff Rosa Maria Cabrera Thompson. (Attachments: #1 Exhibit Seperation Agreement, #2 Exhibit EEOC Agreement 10/26/2026, #3 Exhibit Mukilteo School District Email to All Staff, #4 Exhibit Discovery Order 3/27/2025) Noting Date 4/18/2025 4/11/2025, (Thompson, Rosa) Modified noting date on 4/7/2025 (KRA).
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Filing 32
PRAECIPE TO ISSUE SUMMONS re #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 31
EXHIBIT 25 re #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 30
EXHIBIT 29 re #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 29
EXHIBIT 18 re #28 Exhibit, Notice to Filer, #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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NOTICE TO FILER: re #28 Exhibit. Document(s) contain personal identifiers that must be redacted per Federal Rule of Civil Procedure 5.2(a) and Local Rule of Civil Procedure 5.2 and have been sealed. You must refile a redacted version of the document. This will not affect your original filing date. (KRA)
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Filing 28
SEALED EXHIBIT 18 re #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa) Modified to administratively seal re DOB information on 4/4/2025 (KRA).
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Filing 27
EXHIBIT 4 re #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 26
EXHIBIT 19 re #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 25
EXHIBIT 7 re #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 24
EXHIBIT 3 re #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 23
EXHIBIT 2 re #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 22
EXHIBIT 20 re #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 21
EXHIBIT 1 re #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 20
EXHIBIT 21 re #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 19
EXHIBIT 24 re #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 18
EXHIBIT 22 re #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 17
EXHIBIT 23 re #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 16
EXHIBIT 28 re #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 15
EXHIBIT 27 re #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 14
EXHIBIT 26 re #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 13
EXHIBIT 9 re #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 11
SERVICE OF SUMMONS and Complaint returned executed upon defendant Mukilteo School District No 6 on 4/2/2025 (Thompson, Rosa)
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Filing 10
ORDER denying Plaintiff's #6 Motion for Temporary Restraining Order. Thompson's motion is DENIED in its entirety. Dkt. No. #6 . Signed by Judge Jamal N Whitehead. (KRA)
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Filing 12
NOTICE; filed by Plaintiff Rosa Maria Cabrera Thompson. (KRA)
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Filing 9
MINUTE ORDER REASSIGNING CASE by Judge Theresa L Fricke. Case reassigned to Judge Jamal N Whitehead for all further proceedings. Judge Theresa L Fricke no longer assigned to case. (GMR)
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Filing 8
Summons(es) Electronically Issued as to defendant(s) Rosa Maria Cabrera Thompson (GMR)
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Filing 7
PRAECIPE TO ISSUE SUMMONS re #6 MOTION for Temporary Restraining Order 2:25-cv-00529-TLF, #1 Complaint, by Plaintiff Rosa Maria Cabrera Thompson (Thompson, Rosa)
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Filing 6
MOTION for Temporary Restraining Order 2:25-cv-00529-TLF, filed by Plaintiff Rosa Maria Cabrera Thompson. Noting Date 3/31/2025, (Thompson, Rosa)
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Filing 5
NOTICE: Plaintiff Rosa Maria Cabrera Thompson has registered to electronically file and receive electronic service in this case. (KB)
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Filing 4
ORDER REGARDING DISCOVERY AND DEPOSITIONS by Judge Theresa L Fricke. (GMR- cc: ptlf via USPS)
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Filing 3
LETTER to Filer re case number and Judge assignment. cc Plaintiff via email and USPS. (HH)
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Filing 1
COMPLAINT against defendant(s) Mukilteo School District No 6 with JURY DEMAND (Summons(es) not received to issue) (Receipt # 200007177) filed by Rosa Maria Cabrera Thompson. (Attachments: #1 Civil Cover Sheet #2 Email Transmittal) (HH)
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| Plaintiff: Rosa Maria Cabrera Thompson | |
| Represented By: | Rosa Maria Cabrera Thompson |
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| Defendant: Mukilteo School District No 6 | |
| Represented By: | Zana T Molina |
| Represented By: | Megan F Starks |
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