COMPLAINT FOR DECLARATORY, AND INJUNCTIVE RELIEF, AND FOR COMPENSATORY AND PUNITIVE DAMAGES

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "COMPLAINT FOR DECLARATORY, AND INJUNCTIVE RELIEF, AND FOR COMPENSATORY AND PUNITIVE DAMAGES"

Transcription

1 MARTHA MATTHEWS, SBN 0 ACLU FOUNDATION OF SOUTHERN CALIFORNIA Beverly Boulevard Los Angeles, CA 00 Telephone: (1) -00 x Facsimile: (1) 0-0 COURTNEY JOSLIN, SBN 0 NATIONAL CENTER FOR LESBIAN RIGHTS 0 Market Street, Suite 0 San Francisco, California Telephone: (1) - Facsimile: (1) - Attorneys for Plaintiff ASHLY MASSEY UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA ASHLY MASSEY, by and through her next friend AMELIA MASSEY vs. Plaintiff, BANNING UNIFIED SCHOOL DISTRICT, DR. KATHLEEN McNAMARA, MANUEL PEREDIA, KIRBY DABNEY, and KAREN GILL, Defendants. Case No.: FOR DECLARATORY, AND INJUNCTIVE RELIEF, AND FOR COMPENSATORY AND PUNITIVE DAMAGES JURY TRIAL DEMAND 0 1 Introduction 1. This is a civil rights action demanding declaratory and injunctive relief and monetary damages from the Banning Unified School District (BUSD) and four individual public school officials for depriving the plaintiff, Ashly Massey, of the benefits and programs based on her sexual orientation. Plaintiff seeks to compel BUSD officials to respond appropriately to complaints of discrimination based on real or perceived sexual orientation. Plaintiff also seeks monetary damages for the discrimination she suffered.

2 Parties. At all relevant times, Ashly Massey was an eighth grade student at Coombs Middle School in the Banning Unified School District. Plaintiff Ashly Massey appears in this action by and through her next friend, her mother, Amelia Massey.. Defendant Banning Unified School District (BUSD) is a public school district organized and operating under the laws of the State of California. BUSD controls and operates the Coombs Middle School and other public schools in the Banning area. A portion of the funding for each of these schools comes from the state and federal governments.. Defendant Kathleen McNamara is the superintendent of BUSD; Defendants Manuel Peredia and Kirby Dabney are the Principal and Vice Principal, respectively, of Coombs Middle School. Defendant Karen Gill is a physical education teacher at Coombs Middle School. All of these defendants were, at all relevant times, acting within the scope of their employment by the BUSD as administrators or teachers.. The BUSD, by and through the Defendants sued individually in this lawsuit, is responsible for creating and maintaining an educational environment that is free from discrimination. The BUSD and individual defendants McNamara, Peredia, and Dabney are responsible for making policy and/or for implementing disciplinary and anti-discrimination policies for the BUSD as a whole and for Coombs Middle School. Further, these Defendants are responsible for enforcing and ensuring that their subordinates, agents, and employees implement and comply with such laws and policies by taking prompt action in response to incidents of inappropriate behavior, harassment, and/or discrimination against students.. Upon information and belief, each of the Defendants performed, participated in, aided and/or abetted, or were deliberately indifferent to the acts averred herein, proximately caused

3 the damages averred below, and are liable for Plaintiff for the damages and other relief sought herein.. Upon information and belief, at all relevant times, each and every Defendant was acting within the scope of his or her authority as a public school administrator or teacher, and was acting with the consent, permission and authorization of the remaining Defendants. All actions of each Defendant was ratified and approved by every other Defendant.. Upon information and belief, all of the actions alleged in this Complaint were taken pursuant to customs, policies, and practices of the BUSD and Defendants have been, are presently, and will be acting under the color and authority of the laws of the United States and the state of California. Jurisdiction and Venue. This Court has jurisdiction over plaintiff s federal civil rights claims, under U.S.C. 1. This Court has supplemental jurisdiction over plaintiffs state-law claims arising from the same factual circumstances, events and transactions, under U.S.C. 1(a).. Venue is proper in this Court under U.S.C. 1(b) because the plaintiff resides in, and all incidents, events, and occurrences giving rise to this action occurred in, the County of Riverside, California. Facts Common to All Claims. In late March 00, while in the locker room after Physical Education class at Coombs Middle School, one of Ashly s friends asked Ashly if Ashly is a lesbian. Ashly responded affirmatively. 1. That evening, Ashly s mother, Amelia Massey, received a telephone call from Ms. Karen Gill (Gill), Ashly s Physical Education teacher, informing Ms. Massey that she had a problem with Ashly being in the girls locker room. Gill said that Ashly told the other girls that she

4 is a lesbian and that the girls feel uncomfortable being around Ashly in the locker room because of Ashly s sexual orientation. 1. Ms. Massey asked if Ashly had behaved improperly in the locker room. Gill responded that Ashly had not acted inappropriately; that Ashly had not made any inappropriate sexual comments or engaged in any inappropriate sexual conduct. 1. Ms. Massey asked Gill if Ashly was meeting the requirements of Physical Education class, to which Gill responded affirmatively. 1. Gill told Ms. Massey that she would call her again if there were any future problems. 1. Ms. Massey never received another phone call from Gill. 1. When Ashly went to P.E. class the next day, Gill told Ashly to go to the principal s office and that she was no longer allowed to go to P.E. class. 1. For the next week and one-half, Ashly sat in the principal s office every day during the time she was supposed to be at Physical Education class. No one explained why she was to sit and wait in the principal s office. And during this week and one-half, no school official ever met with Ashly to discuss the situation.. Every day that Ashly sat in the office, other students would see her there and ask her why she was there. The other students assumed she had done something wrong and was in the principal s office to be disciplined. 0. No school official ever called Ashly s mother, Amelia Massey, to inform her that her daughter was being prohibited from going to Physical Education class. 1. About a week and a half after Ashly was first told by Gill that she could no longer attend Physical Education class, Ms. Massey coincidentally arranged a meeting with Vice Principal Dabney to discuss an unrelated need to arrange Ashly s schedule to accommodate a medical research program Ashly had begun. During this meeting, Ms. Massey asked why Ashly had been

5 removed from Physical Education class. Mr. Dabney said that Principal Peredia had made the decision that Ashly should be precluded from attending Physical Education class.. During this meeting, it was decided that Ashly would leave school early to attend the research program. Physical Education was one of the classes that was eliminated from Ashly s schedule as a result of this decision.. This decision about rearranging Ashly s schedule was independent of and had no relation to Mr. Peredia s decision to forbid Ashly from attending Physical Education class. Had there not been a need to change Ashly s schedule for another reason, the school would have continued to prohibit Ashly from attending Physical Education class.. As a result of Defendants conduct, Ashly was prevented from attending Physical Education class for a period of a week and one-half.. Defendants conduct was emotionally damaging to Ashly. Having to sit in the principal s office every day during Physical Education class was humiliating and denigrating, and made Ashly feel that she was being punished because of her sexual orientation.. At all relevant times, BUSD s written nondiscrimination policy failed to protect students from discrimination on the basis of sexual orientation.. Although Ashly no longer attends school in the Banning Unified School District, she still lives within miles of the district and her grandmother continues to reside within the Banning Unified School District. There is a significant likelihood that she will return to the BUSD some time before she graduates from high school and she is afraid that, if she does return, she will be subjected again to discrimination on the basis of her sexual orientation. Claims for Relief First Claim for Relief (Equal Protection -- U.S.C. )

6 Plaintiff realleges and repleads all of the allegations in paragraphs 1 - of this Complaint and incorporates them by reference.. Defendants denied Plaintiff an equal opportunity to participate in physical education classes at a public school, solely on the basis of Plaintiff s real or perceived sexual orientation. 0. Plaintiff s right to equal protection of the laws under the Fourteenth Amendment to the United States Constitution was violated by this denial of equal access to public school classes. 1. Plaintiff has a cause of action for violation of her constitutional right to equal protection, under the Civil Rights Act, U.S.C.. Second Claim for Relief (Cal. Educ. Code 00 et seq.). Plaintiff realleges and repleads all of the allegations in paragraphs 1 of this Complaint and incorporates them by reference.. Defendants prevented Plaintiff from participating in Physical Education class, a program or activity of the school, on the basis of Plaintiff s real or perceived sexual orientation.. Defendants conduct constituted discrimination on the basis of sexual orientation in violation of California Education Code 00 et seq. Third Claim for Relief California Civil Code Sections 1 and (a), Unruh Civil Rights Act. Plaintiff realleges and repleads all of the allegations in paragraphs 1 - of this Complaint and incorporates them by reference. 1.. Defendants are a business establishment within the meaning of Civil Code Section. At all relevant times, Plaintiff was a student at Coombs Middle School in the Banning Unified School District.

7 Starting in March 00, Plaintiff was prevented from attending P.E. class because of her real or perceived sexual orientation. This decision to preclude Ashly from attending P.E. class was made by Principal Peredia and was ratified by Vice Principal Dabney. Prayer for Relief WHEREFORE, Plaintiff prays for a judgment in her favor as follows: 1. Issue a judgment declaring that the acts of the Defendants described herein violate the Fourteenth Amendment to the United States Constitution, California Education Code Section 00 et seq., and the California Civil Code Section 1 et seq.. Issue an injunction ordering Defendants to stop engaging in such unconstitutional and unlawful acts, and to develop policies and procedures for preventing the recurrence of any such unconstitutional and unlawful acts, including but not limited to the following: a. Require Defendants to adopt policies with specific guidelines for instructing teachers and administrators about how to address complaints by students who have been taunted, harassed, or discriminated against because of their actual or perceived sexual orientation or gender; b. Require Defendants to provide annual trainings for BUSD teachers, staff, and administrators on their legal obligation to treat all students equally, regardless of real or perceived sexual orientation and gender, and to respond to and take steps to prevent harassment and discrimination on the basis of actual or perceived sexual orientation or gender; c. Require teachers and administrators in BUSD schools to conduct age-appropriate anti-bias education programs for all students addressing issues of diversity, homophobia, and tolerance, wherein students are instructed about laws prohibiting

8 harassment and discrimination based on actual or perceived sexual orientation or gender; d. Require Defendants to maintain complete and accurate written records concerning each complaint of harassment or discrimination on the basis of real or perceived sexual orientation or gender as well as the specific action BUSD teachers and administrators took to resolve the complaint;. For compensatory damages and consequential damages to be awarded to Ashly Massey according to proof at trial;. For exemplary and punitive damages to be awarded to Ashly Massey according to proof at trial;. For interest;. For costs of suit and attorneys fees; and. For such other and further relief as the Court may deem just, proper, and appropriate. Demand for Jury Pursuant to Rule (b) of the Federal Rules of Civil Procedure and Rule -1 of the Local Rules, Plaintiff demands trial by jury for all the issues pleaded herein so triable. Dated: December 1, 00 1 By MARTHA MATTHEWS ACLU OF SOUTHERN CALIFORNIA COURTNEY JOSLIN NATIONAL CENTER FOR LESBIAN RIGHTS Attorneys for Plaintiff ASHLY MASSEY

9

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN FRANCISCO UNLIMITED CIVIL CASE

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN FRANCISCO UNLIMITED CIVIL CASE Christopher B. Dolan (SBN ) Shawn R. Miller (SBN ) Market Street San Francisco, CA Tel: () -00 Fax: () -0 Attorneys for Plaintiff CHARLENE HASTINGS IN SUPERIOR COURT OF STATE OF CALIFORNIA IN AND FOR COUNTY

More information

) ) ) ) ) ) ) ) ) ) ) ) ) ) SHANNON ROSE and JANE BROOKS, Case No.: Plaintiffs, COMPLAINT

) ) ) ) ) ) ) ) ) ) ) ) ) ) SHANNON ROSE and JANE BROOKS, Case No.: Plaintiffs, COMPLAINT MARTHA A. MATTHEWS (Bar No. 00 AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF SOUTHERN CALIFORNIA Beverly Boulevard Los Angeles, CA 00- Telephone: ( -00 Facsimile: ( 0-0 JORDAN C. BUDD (Bar No. AMERICAN

More information

CASE 0:12-cv-02811-RHK-SER Document 1 Filed 11/02/12 Page 1 of 8 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA ) ) ) ) ) ) ) ) ) ) ) ) )

CASE 0:12-cv-02811-RHK-SER Document 1 Filed 11/02/12 Page 1 of 8 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA ) ) ) ) ) ) ) ) ) ) ) ) ) CASE 0:12-cv-02811-RHK-SER Document 1 Filed 11/02/12 Page 1 of 8 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA File No. Julius Chad Zimmerman, Plaintiff, v. Dave Bellows, in his individual and official

More information

Case4:13-cv-05715-DMR Document1 Filed12/11/13 Page1 of 5

Case4:13-cv-05715-DMR Document1 Filed12/11/13 Page1 of 5 Case:-cv-0-DMR Document Filed// Page of WILLIAM R. TAMAYO, SBN 0 (CA) MARCIA L. MITCHELL, SBN (WA) DERA A. SMITH, SBN (CA) U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Phillip Burton Federal Building 0

More information

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO, WEST DISTRICT 9 10 11 12 13 14 15 16 17 18

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO, WEST DISTRICT 9 10 11 12 13 14 15 16 17 18 JAMES W. JOHNSTON ATTORNEY AT LAW 00 S. Flower Street, Suite 10 Los Angeles, California 001 State Bar No. (1) 1- Attorney for Plaintiff IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO,

More information

Case 5:14-cv-00631 Document 1 Filed 07/11/14 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

Case 5:14-cv-00631 Document 1 Filed 07/11/14 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION Case 5:14-cv-00631 Document 1 Filed 07/11/14 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION CAROLE RIELEY Plaintiff, CIVIL ACTION NO. 5:14 cv 00631

More information

Case 3:14-cv-00671-HU Document 1 Filed 04/23/14 Page 1 of 12 Page ID#: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON

Case 3:14-cv-00671-HU Document 1 Filed 04/23/14 Page 1 of 12 Page ID#: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON Case 3:14-cv-00671-HU Document 1 Filed 04/23/14 Page 1 of 12 Page ID#: 1 OSB#013943 sean.riddell@live.com Attorney At Law 4411 NE Tillamook St Portland, OR 97140 971-219-8453 Attorney for Plaintiff IN

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY DEFENDANT S ANSWER

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY DEFENDANT S ANSWER Case 1:14-cv-05919-JEI-KMW Document 19 Filed 02/13/15 Page 1 of 11 PageID: 84 Frank L. Corrado, Esquire Attorney ID No. 022221983 BARRY, CORRADO & GRASSI, PC 2700 Pacific Avenue Wildwood, NJ 08260 (609)

More information

How to Write a Complaint

How to Write a Complaint Federal Pro Se Clinic CENTRAL DISTRICT OF CALIFORNIA How to Write a Complaint Step : Pleading Paper Complaints must be written on pleading paper. Pleading paper is letter-sized (8. x paper that has the

More information

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff, BLUE MAX TRUCKING, INC., Defendant. CIVIL ACTION NO. 3:02CV COMPLAINT

More information

UNITED STATES DISTRICT COURT DISTRICT OF HAWAII. Case No.: CV-06-00~CK-LEK

UNITED STATES DISTRICT COURT DISTRICT OF HAWAII. Case No.: CV-06-00~CK-LEK MARY A. WILKOWSKI 4622 304C Iolani Avenue Honolulu, Hawai 96813 Telephone: (808) 536-5444 FacsImile: (808) 591-2990 E-Mail: maw808@aol.com Attorney for Plaintiff-Intervenor DORIS F ALETOI UNITED STATES

More information

IN THE CIRCUIT COURT OF THE 9 th JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA

IN THE CIRCUIT COURT OF THE 9 th JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA IN THE CIRCUIT COURT OF THE 9 th JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA DEAN KUMANCHIK, vs. Plaintiff, Case No.: UNIVERSAL CITY DEVELOPMENT PARTNERS, LTD d/b/a UNIVERSAL STUDIOS, a Florida

More information

FIRST AMENDED CLASS ACTION AND COLLECTIVE COMPLAINT AND JURY DEMAND

FIRST AMENDED CLASS ACTION AND COLLECTIVE COMPLAINT AND JURY DEMAND District Court, Denver County, Colorado 1437 Bannock Street Denver, Colorado 80202 GUILLERMO ARTEAGA-GOMEZ, Individually and on behalf of all others similarly situated, DATE FILED: January 22, 2015 6:02

More information

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 1 1 1 1 1 0 1 Luke L. Dauchot (SBN Nimalka R. Wickramasekera (SBN Benjamin A. Herbert (SBN South Hope Street Los Angeles, California 001 Telephone: (1 0-00 Facsimile: (1 0-00 Attorneys for Plaintiff, v.

More information

Case 5:11-cv-00186-SWW Document 4 Filed 08/18/11 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS PINE BLUFF DIVISION

Case 5:11-cv-00186-SWW Document 4 Filed 08/18/11 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS PINE BLUFF DIVISION Case 5:11-cv-00186-SWW Document 4 Filed 08/18/11 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS PINE BLUFF DIVISION KYMBERLY L. WIMBERLY PLAINTIFF v. CASE NO. 5:11 CV 0186

More information

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DAMAGES

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DAMAGES IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION WAYNE WILLIAMS, on behalf of himself and all others similarly situated, v. Plaintiff, PROTECT SECURITY, LLC. Defendant.

More information

Case 5:14-cv-00590-OLG Document 9 Filed 07/31/14 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

Case 5:14-cv-00590-OLG Document 9 Filed 07/31/14 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION Case 5:14-cv-00590-OLG Document 9 Filed 07/31/14 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION DESTINY ANNMARIE RIOS Plaintiff VS. CIVIL ACTION NO. 5:14-cv-00590

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA Case :-cv-000-jah -CAB Document Filed 0// Page of 0 Joshua B. Swigart, Esq. (SBN: ) josh@westcoastlitigation.com Robert L. Hyde, Esq. (SBN: ) bob@westcoastlitigation.com Hyde & Swigart Camino Del Rio South,

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND (Southern Division) v. * Civil Action No.: * * * * ooo0ooo * * * * COMPLAINT

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND (Southern Division) v. * Civil Action No.: * * * * ooo0ooo * * * * COMPLAINT Case 8:11-cv-00951-DKC Document 1 Filed 04/12/11 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND (Southern Division) YASMIN REYAZUDDIN, * 12903 Margot Drive Rockville, Maryland

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF MONTEREY. No.

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF MONTEREY. No. TREVOR A. GRIMM, State Bar No. JONATHAN M. COUPAL, State Bar No. 1 TIMOTHY A. BITTLE, State Bar No. 00 Howard Jarvis Taxpayers Foundation 1 Eleventh Street, Suite 1 Sacramento, CA 1 (1-0 Attorneys for

More information

Case3:15-cv-01367 Document1 Filed03/24/15 Page1 of 9

Case3:15-cv-01367 Document1 Filed03/24/15 Page1 of 9 Case:-cv-0 Document Filed0// Page of 0 David M. Poore, SBN Scott A. Brown, SBN 0 BROWN POORE LLP 0 Treat Blvd., Suite Walnut Creek, California Telephone: () - dpoore@bplegalgroup.com James Mills, SBN LAW

More information

1. What acts and behavior constitute sexual harassment, including the fact that sexual harassment could occur between people of the same gender.

1. What acts and behavior constitute sexual harassment, including the fact that sexual harassment could occur between people of the same gender. STUDENTS CORONA-NORCO UNIFIED SCHOOL DISTRICT 5475 STUDENT RECORDS/RIGHTS RESOLUTION OF STUDENT GRIEVANCES PROHIBITION OF SEXUAL HARASSMENT The Governing Board is committed to maintaining an educational

More information

Case3:15-cv-03986-JCS Document1 Filed09/01/15 Page1 of 11 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

Case3:15-cv-03986-JCS Document1 Filed09/01/15 Page1 of 11 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA Case:-cv-0-JCS Document Filed0/0/ Page of KRONENBERGER ROSENFELD, LLP Karl S. Kronenberger (Bar No. ) Jeffrey M. Rosenfeld (Bar No. ) Ansel J. Halliburton (Bar No. 0) 0 Post Street, Suite 0 San Francisco,

More information

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES 9 10 11 12 13 14 15 16 17 18

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES 9 10 11 12 13 14 15 16 17 18 JAMES W. JOHNSTON ATTORNEY AT LAW 00 S. Flower Street, Suite 00 Los Angeles, California 001 State Bar No. (1) 1- Attorney for Plaintiff IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA Case:-cv-0 Document Filed0// Page of Michael Millen Attorney at Law (#) Calle Marguerita Ste. 0 Telephone: Fax: (0) -0 mikemillen@aol.com Attorney for Plaintiff UNITED STATES DISTRICT COURT NORTHERN DISTRICT

More information

Case 3:15-cv-00592-LAB-BLM Document 1 Filed 03/16/15 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA

Case 3:15-cv-00592-LAB-BLM Document 1 Filed 03/16/15 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA Case :-cv-00-lab-blm Document Filed 0// Page of 0 ERIC H. HOLDER, JR. Attorney General VANITA GUPTA Acting Assistant Attorney General STEVEN H. ROSENBAUM Chief, Housing and Civil Enforcement Section ELIZABETH

More information

Plaintiff, : X. Nature of the Action. 1. This is an action for breach of a settlement agreement, retaliation

Plaintiff, : X. Nature of the Action. 1. This is an action for breach of a settlement agreement, retaliation Case 1:06-cv-03834-JGK-THK Document 17 Filed 12/20/2006 Page 1 of 16 Thomas J. Luz (TL-4665) PEARCE & LUZ LLP Attorneys for Plaintiff Peter Lindner 1500 Broadway, 21 st Floor New York, New York 10036 (212)

More information

Case 3:14-cv-00137-AC Document 10 Filed 03/26/14 Page 1 of 14 Page ID#: 43

Case 3:14-cv-00137-AC Document 10 Filed 03/26/14 Page 1 of 14 Page ID#: 43 Case 3:14-cv-00137-AC Document 10 Filed 03/26/14 Page 1 of 14 Page ID#: 43 Calvin L. Keith, OSB No. 814368 CKeith@perkinscoie.com Sarah J. Crooks, OSB No. 971512 SCrooks@perkinscoie.com PERKINS COIE LLP

More information

SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES

SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES (SPACE BELOW FOR FILING STAMP ONLY) LAW FIRM OF KAISER, DEBIASO. ANDREW AND SWINDELLS SUMfTOMO TOWER NINTH FLOOR 444 WEST OCEAN BOULEVARD LONG BEACH, CALIFORNIA 90802-4516 (310) 590-8471 ERIC C. DEMLER

More information

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOLANO. Defendants. ) THE PARTIES

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOLANO. Defendants. ) THE PARTIES '. 1 6 MILLSTONE PETERSON & WATTS, LLP Attorneys at Law GLENN W. PETERSON, ESQ (SBN 6 Lava Ridge Court, Suite Roseville, CA 661 Phone: -80-8 Fax: -80-8 Attorneys for Plaintiff Otto W. Giuliani ENDORSED

More information

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA Case 2:11-cv-00225-KDE-SS Document 1 Filed 02/02/11 Page 1 of 15 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA ) MARIO CACHO and ANTONIO OCAMPO, ) ) Plaintiffs, ) No. v. ) ) SHERIFF

More information

IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION : : : : : : : : : : : : : : : : : :

IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION : : : : : : : : : : : : : : : : : : IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION JOAN FREDERICKS c/o Alphonse A. Gerhardstein 617 Vine Street #14009 Cincinnati, OH 45251, vs. Plaintiff, JOHN E. POTTER, et.

More information

USDC IN/ND case 1:15-cv-00157-JD-SLC document 1 filed 06/19/15 page 1 of 5

USDC IN/ND case 1:15-cv-00157-JD-SLC document 1 filed 06/19/15 page 1 of 5 USDC IN/ND case 1:15-cv-00157-JD-SLC document 1 filed 06/19/15 page 1 of 5 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA FORT WAYNE DIVISION A.B., a minor child, by his mother and next friend,

More information

Case 2:14-cv-00644-DB Document 2 Filed 09/03/14 Page 1 of 10

Case 2:14-cv-00644-DB Document 2 Filed 09/03/14 Page 1 of 10 Case 2:14-cv-00644-DB Document 2 Filed 09/03/14 Page 1 of 10 STEWART GOLLAN USB # 12524 UTAH LEGAL CLINIC Cooperating Attorneys for UTAH CIVIL RIGHTS & LIBERTIES FOUNDATION, INC. 214 East Fifth South Street

More information

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA HARRISONBURG DIVISION EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, ) ) )

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA HARRISONBURG DIVISION EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, ) ) ) Case 5:10-at-99999 5:10-cv-00097-sgw Document -jgw 54 Document (Court only 1 Filed 09/21/10 Page 1 1 of of 6 6 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA HARRISONBURG DIVISION

More information

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION Case 3:10-cv-01903-K Document 1 Filed 09/22/10 Page 1 of 6 PageID 1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, CIVIL

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA EASTERN DIVISION ) ) ) ) ) ) ) ) ) ) ) NATURE OF THE ACTION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA EASTERN DIVISION ) ) ) ) ) ) ) ) ) ) ) NATURE OF THE ACTION IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA EASTERN DIVISION EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff, v. SAFELITE GLASS CORP. Defendant. CIVIL ACTION NO. COMPLAINT

More information

Case 14-90056-LT Filed 05/14/14 Entered 05/14/14 14:14:36 Doc 6 Pg. 1 of 13

Case 14-90056-LT Filed 05/14/14 Entered 05/14/14 14:14:36 Doc 6 Pg. 1 of 13 Case -00-LT Filed 0// Entered 0// :: Doc Pg. of NANCY L. STAGG, CA Bar No. 0 nstagg@foley.com MATTHEW J. RIOPELLE, CA Bar No. 0 mriopelle@foley.com FOLEY & LARDNER LLP VALLEY CENTRE DRIVE, SUITE 00 SAN

More information

Case 3:10-cv-04126-JAP -DEA Document 1 Filed 08/11/10 Page 1 of 6 PageID: 1

Case 3:10-cv-04126-JAP -DEA Document 1 Filed 08/11/10 Page 1 of 6 PageID: 1 Case 310-cv-04126-JAP -DEA Document 1 Filed 08/11/10 Page 1 of 6 PageID 1 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Newark Area Office One Newark Center, 21st Floor Newark, N.J. 07102 Rosemary DiSavino,

More information

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE ) ) ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE ) ) ) ) ) ) ) ) ) ) ) ) ) ) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MICROSOFT CORPORATION, a Washington Corporation v. Plaintiff, SALESFORCE.COM, INC., a Delaware Corporation Defendants. UNITED STATES DISTRICT

More information

Case 1:15-cv-23825-KMW Document 11 Entered on FLSD Docket 01/28/2016 Page 1 of 8 UNTIED STATE DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Case 1:15-cv-23825-KMW Document 11 Entered on FLSD Docket 01/28/2016 Page 1 of 8 UNTIED STATE DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case 1:15-cv-23825-KMW Document 11 Entered on FLSD Docket 01/28/2016 Page 1 of 8 DAVID BALDWIN, v. Plaintiff, ANTHONY FOXX, in his official capacity as Secretary of The United States Department of Transportation,

More information

Case4:15-cv-04219-DMR Document1 Filed09/16/15 Page1 of 11

Case4:15-cv-04219-DMR Document1 Filed09/16/15 Page1 of 11 Case:-cv-0-DMR Document Filed0// Page of MICHAEL G. RHODES () (rhodesmg@cooley.com) California Street, th Floor San Francisco, CA Telephone: Facsimile: BRENDAN J. HUGHES (pro hac vice to be filed) (bhughes@cooley.com)

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION RPOST HOLDINGS, INC., RPOST COMMUNICATIONS LIMITED, and RMAIL LIMITED, CIVIL ACTION NO. Plaintiffs, v. ADOBE SYSTEMS

More information

&lagistiiale JUDGE ROSEMONO

&lagistiiale JUDGE ROSEMONO IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION H. STUiiiiT CGNNINGHAM UmEQ SIXm DISTRICT COW JULIE A. TEURBER, Plaintiff,' t ) CIVIL ACTION NO. V. CAROL M. BROWNER,

More information

Case 1:09-cv-07693 Document 1 Filed 12/10/09 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

Case 1:09-cv-07693 Document 1 Filed 12/10/09 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION Case 1:09-cv-07693 Document 1 Filed 12/10/09 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff, v.

More information

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO, WESTERN DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO, WESTERN DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO, WESTERN DIVISION MAVERICK COUCH, a minor, by and through his Mother and Next Friend, TONYA COUCH, v. Plaintiff, WAYNE LOCAL SCHOOL

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA 1 1 1 1 1 1 1 1 0 1 LAW OFFICES OF RONALD A. MARRON RONALD A. MARRON (SBN 10) ron@consumersadvocates.com ALEXIS WOOD (SBN 000) alexis@consumersadvocates.com KAS GALLUCCI (SBN 0) kas@consumersadvocates.com

More information

Case 1:15-cv-00877-GLS-TWD Document 1 Filed 07/21/15 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF NEW YORK

Case 1:15-cv-00877-GLS-TWD Document 1 Filed 07/21/15 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF NEW YORK Case 1:15-cv-00877-GLS-TWD Document 1 Filed 07/21/15 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF NEW YORK EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff, CIVIL ACTION

More information

COMPLAINT WITH JURY DEMAND. of police reports in bad faith. Plaintiff claims that Defendants acted willfully, wantonly and in

COMPLAINT WITH JURY DEMAND. of police reports in bad faith. Plaintiff claims that Defendants acted willfully, wantonly and in Weld County, Colorado, District Court, 901 9 th Avenue Greeley, CO 80631 970.351.7300 Plaintiff: vs. Defendants: JENNIFER BELL, individually and on behalf of all others similarly situated, BRADLEY PETROLEUM,

More information

Case5:15-cv-03698-HRL Document1 Filed08/12/15 Page1 of 10

Case5:15-cv-03698-HRL Document1 Filed08/12/15 Page1 of 10 Case:-cv-0-HRL Document Filed0// Page of 0 Donald E. J. Kilmer, Jr. [SBN: ] LAW OFFICES OF DONALD KILMER Willow Street, Suite 0 San Jose, California Voice: (0) - Fax: (0) - E-Mail: Don@DKLawOffice.com

More information

Case 8:14-cv-01576-VMC-AEP Document 1 Filed 06/27/14 Page 1 of 13 PageID 1

Case 8:14-cv-01576-VMC-AEP Document 1 Filed 06/27/14 Page 1 of 13 PageID 1 Case 8:14-cv-01576-VMC-AEP Document 1 Filed 06/27/14 Page 1 of 13 PageID 1 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION SARA HELLWEGE, v. Plaintiff, TAMPA FAMILY

More information

Case 1:12-cv-01676-RLV-AJB Document 1 Filed 05/14/12 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

Case 1:12-cv-01676-RLV-AJB Document 1 Filed 05/14/12 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION Case 1:12-cv-01676-RLV-AJB Document 1 Filed 05/14/12 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION BRENDA L. HONEYCUTT, * * Plaintiff, * * v. * CIVIL ACTION

More information

Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA SAN BERNARDINO COUNTY CIVIL DIVISION. MARIA GODINEZ, an individual,

Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA SAN BERNARDINO COUNTY CIVIL DIVISION. MARIA GODINEZ, an individual, VACHON LAW FIRM Michael R. Vachon, Esq. (SBN ) 0 Via Del Campo, Suite San Diego, California Tel.: () -0 Fax: () - Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA SAN BERNARDINO COUNTY

More information

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION INTRODUCTION

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION INTRODUCTION IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, v. Plaintiff; OVERNITE TRANSPORTATION COMPANY, Defendant. Case No. 2:02-cv-591

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) )

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) ) Case :-cv-0-srb Document Filed 0// Page of 0 LAWRENCE BREWSTER Regional Solicitor DAVID KAHN Counsel for Employment Standards KATHERINE KASAMEYER Trial Attorney Email: Kasameyer.katherine@dol.gov CA State

More information

Case3:13-cv-02858-JST Document27 Filed11/27/13 Page1 of 14

Case3:13-cv-02858-JST Document27 Filed11/27/13 Page1 of 14 Case:-cv-0-JST Document Filed// Page of 0 Clayeo C. Arnold, California SBN 00 carnold@justiceyou.com Christine M. Doyle, California SBN 0 cdoyle@justiceyou.com CLAYEO C. ARNOLD, A PROFESSIONAL LAW CORPORATION

More information

Case 1:14-cv-12193-WGY Document 1 Filed 05/16/14 Page 1 of 9 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS COMPLAINT AND JURY DEMAND

Case 1:14-cv-12193-WGY Document 1 Filed 05/16/14 Page 1 of 9 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS COMPLAINT AND JURY DEMAND Case 1:14-cv-12193-WGY Document 1 Filed 05/16/14 Page 1 of 9 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS PRIVATE BUSINESS JETS, L.L.C. Plaintiff, v. Civil Action No. PRVT, Inc. Defendant. COMPLAINT

More information

1 2 3 4 5 [ATTORNEY NAME] (ATTORNEY STATE BAR NUMBER) [ATTORNEY EMAIL ADDRESS] [LAW FIRM NAME] [LAW FIRM STREET ADDRESS] [LAW FIRM CITY/STATE/ZIP CODE] [LAW FIRM TELEPHONE NUMBER] [LAW FIRM FAX NUMBER]

More information

IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA

IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA H.L. WATKINS AND COMPANY, INC., ) ) PLAINTIFF, ) ) CIVIL ACTION FILE NO. v. ) ) 06-CV8980-3 THE HOT LEAD COMPANY, LLC, ) ROBERT MICHAEL HORNE, )

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA Jack Anderson, Esq. SBN 0 JACK ANDERSON, ESQ., APLC Balboa Avenue, Suite E San Diego, California Tel.: ( - Fax: ( 0- jackandersonaplc@yahoo.com Attorney for Defendant and Cross-Complainant Starline Windows,

More information

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA 1 TERRY GODDARD The Attorney General Firm No. 00 Sandra R. Kane, No. 00 Assistant Attorney General Civil Rights Division 1 West Washington Street Phoenix, AZ 00 Telephone: (0) - CivilRights@azag.gov Attorneys

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA NATURE OF THE ACTION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA NATURE OF THE ACTION IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, DEC 28 Pi i 3", 15 OA~LOREITA G. WtlYTE CLERK Vo Plaintiff, PARAGON SYSTEMS, INC. CWIL

More information

Case 4:08-cv-01366 Document 18 Filed in TXSD on 05/28/08 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

Case 4:08-cv-01366 Document 18 Filed in TXSD on 05/28/08 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION Case 4:08-cv-01366 Document 18 Filed in TXSD on 05/28/08 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION SUSAN CARNABY V. C IVIL ACTION NUMBER H-08-1366 C ITY

More information

UNITED STATES DISTRICT COURT DISTRICT OF OREGON

UNITED STATES DISTRICT COURT DISTRICT OF OREGON WILLIAM R. GOOODE Attorney at Law 4224 Southwest Melville Avenue Portland, OR 97201-1357 Telephone: (503) 244-9101 Fax: (503) 244-0019 e-mail: goodewilliam@hotmail.com Oregon State Bar ID No. 84049 Attorney

More information

Case 3:10-cv-02236-DRD Document 31 Filed 05/05/11 Page 1 of 9

Case 3:10-cv-02236-DRD Document 31 Filed 05/05/11 Page 1 of 9 Case 3:10-cv-02236-DRD Document 31 Filed 05/05/11 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO DAVID ASHE Plaintiff, CIVIL NO. 10-2236 ( DRD ) vs. DISTRIBUIDORA NORMA,

More information

S tj M M ONS UNION LEAGUE CLUB, PI ai nti ff Demands a Trial by Jury. Index No. Plaintiff, TO THE ABOVE NAMED DEFENDANT:

S tj M M ONS UNION LEAGUE CLUB, PI ai nti ff Demands a Trial by Jury. Index No. Plaintiff, TO THE ABOVE NAMED DEFENDANT: SCANNED ON 311912012 f' r V. UNION LEAGUE CLUB, Plaintiff, Index No. S tj M M ONS PI ai nti ff Demands a Trial by Jury TO THE ABOVE NAMED DEFENDANT: YOU ARE HEKF,HY SUMMONED to answer the complaint in

More information

Courthouse News Service

Courthouse News Service Case 3:15-cv-00168-HZ Document 1 Filed 01/30/15 Page 1 of 6 Samuel T. Stanke OSB No. 034631 E-mail: sam@stankelaw.com, LLC 1400 SW Montgomery Street Portland, OR 97201 Telephone: 503-224-1127 Facsimile:

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA BROWARD DIVISION. Plaintiff, Case No.: COMPLAINT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA BROWARD DIVISION. Plaintiff, Case No.: COMPLAINT UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA BROWARD DIVISION NANCY PRITCHARD, v. Plaintiff, Case No.: KAPLAN HIGHER EDUCATION CORPORATION; KAPLAN HIGHER EDUCATION CORPORATION, as PLAN ADMINISTRATOR;

More information

Case 2:02-cv-01069-WHA-SRW Document 1 Filed 09/17/2002 Page 1 of 5 , '\ IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA

Case 2:02-cv-01069-WHA-SRW Document 1 Filed 09/17/2002 Page 1 of 5 , '\ IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA Case 2:02-cv-01069-WHA-SRW Document 1 Filed 09/17/2002 Page 1 of 5, '\ IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA D \ \..': t', I ' NORTHERN DIVISION " \ NASH J. COOLEY ) FILED

More information

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. Case No: Defendants, Steven Lecy and the City of Minneapolis, through their

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. Case No: Defendants, Steven Lecy and the City of Minneapolis, through their CASE 0:13-cv-00873-RHK-TNL Document 1 Filed 04/15/13 Page 1 of 4 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA Michael A. Ofor, Case No: Plaintiff, v. Steven Lecy, and City of Minneapolis, NOTICE

More information

Case 2:11-cv-02535-GMS Document 1 Filed 12/21/11 Page 1 of 11

Case 2:11-cv-02535-GMS Document 1 Filed 12/21/11 Page 1 of 11 Case :-cv-0-gms Document Filed // Page of 0 LAWRENCE BREWSTER Regional Solicitor DANIELLE L. JABERG Counsel for ERISA CA State Bar No. KATHERINE M. KASAMEYER Trial Attorney CA State Bar No. Office of the

More information

AMENDED CLASS ACTION COMPLAINT

AMENDED CLASS ACTION COMPLAINT IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. KIM WALLANT and LOUIS BOREK, on behalf of themselves and all others similarly situated, vs. Plaintiffs, FREEDOM

More information

SCHOOL SAFETY & VIOLENCE PREVENTION FOR LESBIAN, GAY, BISEXUAL & TRANSGENDER STUDENTS:

SCHOOL SAFETY & VIOLENCE PREVENTION FOR LESBIAN, GAY, BISEXUAL & TRANSGENDER STUDENTS: SCHOOL SAFETY & VIOLENCE PREVENTION FOR LESBIAN, GAY, BISEXUAL & TRANSGENDER STUDENTS: A Question & Answer Guide for California School Officials & Administrators A publication of the California Safe Schools

More information

Case 1:10-cv-03183 Document 1 Filed 05/24/10 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

Case 1:10-cv-03183 Document 1 Filed 05/24/10 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION Case 1:10-cv-03183 Document 1 Filed 05/24/10 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION JEFFREY ALLEN, Individually and ) on behalf of other

More information

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORIGIA-~~T ~:J,-~T,>cURT SAVANNAH DIVISION j Ga. NATURE OF THE ACTION

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORIGIA-~~T ~:J,-~T,>cURT SAVANNAH DIVISION j Ga. NATURE OF THE ACTION i.., B ORIGINAL IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORIGIA-~~T ~:J,-~T,>cURT SAVANNAH DIVISION j Ga. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff, ) CIVIL_~TION NO.

More information

Case 1:13-cv-01069 Doc #1 Filed 09/30/13 Page 1 of 8 Page ID#1 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MICHIGAN

Case 1:13-cv-01069 Doc #1 Filed 09/30/13 Page 1 of 8 Page ID#1 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MICHIGAN Case 1:13-cv-01069 Doc #1 Filed 09/30/13 Page 1 of 8 Page ID#1 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MICHIGAN UNITED STATES OF AMERICA, v. Plaintiff, CIVIL ACTION NO. DALE VANDERVENNEN

More information

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS CAROL LANNAN and ANN WINN, on behalf of themselves and others similarly situated, Plaintiffs, v. LEVY & WHITE and ROBERT R. WHITE, ESQ., Case No.

More information

Plaintiffs, Defendants. PLEASE TAKE NOTICE that Plaintiff, Rebecca Weston, hereby accepts the Offer of

Plaintiffs, Defendants. PLEASE TAKE NOTICE that Plaintiff, Rebecca Weston, hereby accepts the Offer of 07/15/2034 12:01 973-539-3130 Prom: D Bayle Loflls 201-488-7D29 To: Kalhryn Haffleld SCHENCK PRICE SMITH Date: 7/14/2004 Time: 12:45:04 PM PAGE 04/11 Page 3 of 5 LAW OFFICE D. GAYLELOFTIS 210 RI\/ER STREET

More information

THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) )

THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) ) Case :-cv-00-loa Document Filed 0// Page of 0 Bradley Jardis, vs. Keith M. Knowlton, L.L.C. SBN 0 S. Rural Road, Suite 0, PMB# Tempe, Arizona -00 (0 -; FAX (0 - Keith M. Knowlton - SBN 0 Attorney for Plaintiff

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION SMILEBOND SYSTEMS LLC, a Michigan Limited Liability Company, v. Plaintiff, GC AMERICA INC. an Illinois Corporation,

More information

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA. Complaint. Credit Extension Uniformity Act 73 P.S. 2270, et seq.

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA. Complaint. Credit Extension Uniformity Act 73 P.S. 2270, et seq. UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA Michael XXXX : Civil Action v. : Enhanced Recovery Corp. : Complaint Jurisdiction & Venue 1. This is an action under the Fair Debt

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ) ) ) ) ) ) ) ) ) ) COMPLAINT THE PARTIES

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ) ) ) ) ) ) ) ) ) ) COMPLAINT THE PARTIES IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE AEROSCOUT, LTD. and AEROSCOUT, INC., v. CENTRAK INC., Plaintiffs, Defendant. C.A. No. JURY TRIAL DEMANDED COMPLAINT Plaintiffs AeroScout,

More information

-1- SECOND AMENDED COMPLAINT

-1- SECOND AMENDED COMPLAINT VACHON LAW FIRM Michael R. Vachon, Esq. (SBN ) 0 Via Del Campo, Suite San Diego, California Tel.: () -0 Fax: () - Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES

More information

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION JAMES C. STURDEVANT (SBN 94551 JESPER I. RASMUSSEN (SBN 121001 THE STURDEVANT LAW FIRM A Professional Corporation 475 Sansome Street, Suite 1750 San Francisco, California 94111 Telephone: (415 477-2410

More information

No. Plaintiff Kelvin Bledsoe ( Plaintiff ), by his undersigned counsel, brings claims

No. Plaintiff Kelvin Bledsoe ( Plaintiff ), by his undersigned counsel, brings claims UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK KELVIN BLEDSOE, Plaintiff, v. SAAQIN, INC., No. COMPLAINT FOR VIOLATION OF FAIR LABOR STANDARDS ACT JURY TRIAL DEMANDED Defendant. Plaintiff Kelvin

More information

Case: 1:11-cv-00803-HJW Doc #: 3 Filed: 12/08/11 Page: 1 of 17 PAGEID #: 46 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

Case: 1:11-cv-00803-HJW Doc #: 3 Filed: 12/08/11 Page: 1 of 17 PAGEID #: 46 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION Case: 1:11-cv-00803-HJW Doc #: 3 Filed: 12/08/11 Page: 1 of 17 PAGEID #: 46 LEAH MARZOUGUI, : UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION Plaintiff, : Case No: 1:11-cv-803 -vs-

More information

INTRODUCTION. States Constitution and 42 U.S.C. 1983 against the State of New Jersey, New Jersey s

INTRODUCTION. States Constitution and 42 U.S.C. 1983 against the State of New Jersey, New Jersey s LAW OFFICES OF WALTER M. LUERS, LLC Suite C203 23 West Main Street Clinton, New Jersey 08809 Telephone: 908.894.5656 Facsimile: 908.894.5729 wluers@luerslaw.com MARK R. BROWN, ESQ. 303 E. Broad Street

More information

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION GEORGIACARRY.ORG, INC. and ) REBECCA BREED, ) ) Plaintiffs, ) CIVIL ACTION FILE NO. ) v. ) ) KIPLING L. MCVAY in

More information

Case 2:15-cv-03432-DDP-AGR Document 1 Filed 05/07/15 Page 1 of 15 Page ID #:1 UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA

Case 2:15-cv-03432-DDP-AGR Document 1 Filed 05/07/15 Page 1 of 15 Page ID #:1 UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA Case :-cv-0-ddp-agr Document Filed 0/0/ Page of Page ID #: 0 Matthew T. Walsh, Esq. (Bar No. ) CARROLL, McNULTY & KULL LLC 00 North Riverside Plaza, Suite 00 Chicago, Illinois 00 Telephone: () 00-000 Facsimile:

More information

Case 3:08-cv-01406-JM-CAB Document 9 Filed 08/25/2008 Page 1 of 7

Case 3:08-cv-01406-JM-CAB Document 9 Filed 08/25/2008 Page 1 of 7 Case :0-cv-00-JM-CAB Document Filed 0//0 Page of 0 JOHN J. SANSONE, County Counsel County of San Diego By THOMAS D. BUNTON, Senior Deputy (State Bar No. 0 00 Pacific Highway, Room San Diego, California

More information

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA LYNCHBURG (CHARLOTTESVILLE) DIVISION. Plaintiff, Case No. v.

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA LYNCHBURG (CHARLOTTESVILLE) DIVISION. Plaintiff, Case No. v. IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA LYNCHBURG (CHARLOTTESVILLE) DIVISION UNIVERSITY OF VIRGINIA PATENT FOUNDATION Plaintiff, Case No. v. HAMILTON COMPANY AND HAMILTON

More information

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION INSTITUTE FOR CREATION RESEARCH GRADUATE SCHOOL, Plaintiff, v. CAUSE NO. A:09 CA 382 TEXAS HIGHER EDUCATION COODINATING

More information

) Verified c-o-m-p-la-in-t- --;o~~&"-a~a~e~a6d4 0. Plaintiff, ) Demand for Jury Trial. Defendants. ) Over $25,000.00 ----------------------------~)

) Verified c-o-m-p-la-in-t- --;o~~&-a~a~e~a6d4 0. Plaintiff, ) Demand for Jury Trial. Defendants. ) Over $25,000.00 ----------------------------~) \\.. I' 1 1 1 1 ORIAEDCOPY ~~G'NAL F'L~~rt LeOS Angeles Superior Michael B. Eisenberg, Esq. #0 EISENBERG & ASSOCIATES 0 Wilshire Blvd, Suite OC1 1 Los Angeles, California 00 =... Telephone: () 1-1 John

More information

UNITED STATES DISTRICT COURT DISTRICT OF OREGON EUGENE DIVISION

UNITED STATES DISTRICT COURT DISTRICT OF OREGON EUGENE DIVISION Lake James H. Perriguey, OSB No. 983213 lake@law-works.com LAW WORKS LLC 1906 SW Madison Street Portland, OR 97205-1718 Telephone: (503) 227-1928 Facsimile: (503) 334-2340 Lea Ann Easton, OSB No. 881413

More information

Case 3:15-cv-04959 Document 1 Filed 10/28/15 Page 1 of 13

Case 3:15-cv-04959 Document 1 Filed 10/28/15 Page 1 of 13 Case 3:15-cv-04959 Document 1 Filed 10/28/15 Page 1 of 13 Phil Telfeyan California Bar No. 258270 Attorney, Equal Justice Under Law 601 Pennsylvania Avenue NW South Building Suite 900 Washington, D.C.

More information

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA DEBRA WONG YANG United States Attorney GARY PLESSMAN Assistant United States Attorney Chief, Civil Fraud Section California State Bar No. 1 Room 1, Federal Building 00 North Los Angeles Street Los Angeles,

More information

IN THE UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA GREENVILLE DIVISION

IN THE UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA GREENVILLE DIVISION IN THE UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA GREENVILLE DIVISION ZIPIT WIRELESS INC., Plaintiff, v. BLACKBERRY LIMITED F/K/A RESEARCH IN MOTION LIMITED and BLACKBERRY CORPORATION f/k/a

More information

Case: 1:16-cv-00951 Document #: 1 Filed: 01/22/16 Page 1 of 18 PageID #:1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

Case: 1:16-cv-00951 Document #: 1 Filed: 01/22/16 Page 1 of 18 PageID #:1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION Case: 1:16-cv-00951 Document #: 1 Filed: 01/22/16 Page 1 of 18 PageID #:1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION PAMELA ANDERSON, Individually and ) as Independent

More information

JEFFERSON CIRCUIT COURT JUDGE DIVISION. MELISSA ROWE, Individually and as Mother and Next Friend of E.R

JEFFERSON CIRCUIT COURT JUDGE DIVISION. MELISSA ROWE, Individually and as Mother and Next Friend of E.R NO. MELISSA ROWE, Individually and as Mother and Next Friend of E.R VS. COMPLAINT JEFFERSON CIRCUIT COURT JUDGE DIVISION PLAINTIFF LANA KAELIN c/o Eastern High School 12400 Old Shelbyville Road Louisville,

More information

IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA

IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA 1 of 5 7/6/2007 11:19 AM IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. LONG BEACH MORTGAGE COMPANY, Defendant. COMPLAINT FOR COMPENSATORY

More information