Case: Cousins v. School Board of Orange County

COMPLAINT against All Defendants with Jury Demand (Filing fee $402 receipt number AFLMDC-19810558) filed by All Plaintiffs. (Attachments: # 1 Civil Cover Sheet, # 2 Proposed Summons, # 3 Proposed Summons, # 4 Proposed Summons, # 5 Proposed Summons)(Dandeneau, Debra) (Entered: 07/25/2022)

1 Civil Cover Sheet

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2 Proposed Summons

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3 Proposed Summons

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4 Proposed Summons

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5 Proposed Summons

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CORPORATE Disclosure Statement by CenterLink, Inc. identifying Corporate Parent CenterLink, Inc. for CenterLink, Inc. (Dandeneau, Debra) Modified on 7/26/2022 to edit docket text (KNC). (Entered: 07/25/2022)

CORPORATE Disclosure Statement by R.R.D. identifying Corporate Parent R.R.D. for R.R.D. (Dandeneau, Debra) Modified on 7/26/2022 to edit docket text (KNC). (Entered: 07/25/2022)

CORPORATE Disclosure Statement by K.R.D. identifying Corporate Parent K.R.D. for K.R.D. (Dandeneau, Debra) Modified on 7/26/2022 to edit docket text(KNC). (Entered: 07/25/2022)

CORPORATE Disclosure Statement by Jennifer Cousins identifying Corporate Parent Cousins, Jennifer for Jennifer Cousins. (Dandeneau, Debra) Modified on 7/26/2022 to edit docket text (KNC). (Entered: 07/25/2022)

CORPORATE Disclosure Statement by Vikranth Reddy Gongidi identifying Corporate Parent Gongidi, Vikranth for Vikranth Reddy Gongidi. (Dandeneau, Debra) Modified on 7/26/2022 to edit docket text (KNC). (Entered: 07/25/2022)

CORPORATE Disclosure Statement by Will Larkins. (Dandeneau, Debra) (Entered: 07/25/2022)

CORPORATE Disclosure Statement by David Dinan. (Dandeneau, Debra) (Entered: 07/25/2022)

CORPORATE Disclosure Statement by N.C. (Dandeneau, Debra) Modified on 7/26/2022 to edit docket text(KNC). (Entered: 07/25/2022)

CORPORATE Disclosure Statement by P.C. (Dandeneau, Debra) Modified on 7/26/2022 to edit docket text (KNC). (Entered: 07/25/2022)

CORPORATE Disclosure Statement by S.C. (Dandeneau, Debra) Modified on 7/26/2022 to edit docket text(KNC). (Entered: 07/25/2022)

CORPORATE Disclosure Statement by M.C. (Dandeneau, Debra) Modified on 7/26/2022 to edit docket text (KNC). (Entered: 07/25/2022)

CORPORATE Disclosure Statement by Matthew Cousins. (Dandeneau, Debra) (Entered: 07/25/2022)

NOTICE of a related action per Local Rule 1.07(c) by Jennifer Cousins. Related case(s): Yes (Dandeneau, Debra) (Entered: 07/25/2022)

NEW CASE ASSIGNED to Judge Wendy W. Berger and Magistrate Judge Daniel C. Irick. New case number: 6:22-cv-1312-WWB-DCI. (SJB) (Entered: 07/26/2022)

NOTICE to counsel Camilla B. Taylor, Kell L. Olson, Paul D. Castillo and Jennifer Vail: Local Rule 2.01(c), Special Admission of Non-Resident Lawyer - File a Motion to Appear Pro Hac Vice. Co-counsel with filing rights may electronically file the motion on behalf of the non-resident lawyer or the motion may be filed on paper; Pay the Special Admission Fee; Submit a Pro Hac Vice E-File Registration through PACER. Visit www.flmd.uscourts.gov/for-lawyers for details (Signed by Deputy Clerk). (KNC) (Entered: 07/26/2022)

SUMMONS issued as to All Defendants. (KNC) (Entered: 07/26/2022)

Case Assigned/Reassigned

Notice to Counsel of Local Rule

STANDING ORDER ON DISCOVERY MOTIONS. Signed by Magistrate Judge Daniel C. Irick on 2/1/2021. (RN) (Entered: 07/27/2022)

NOTICE TO COUNSEL AND PARTIES: The Middle District of Florida's revised Local Rules become effective February 1, 2021 and can be found on the Court's public website https://www.flmd.uscourts.gov/local-rules. For a just and efficient resolution of this case, the parties are DIRECTED to read and comply with the Middle District of Florida's Local Rules. See Local Rule 1.01(a). Failure to comply with ANY Local Rules or Court Orders may result in the imposition of sanctions including, but not limited to, the dismissal of this action or entry of default without further notice. Signed by Judge Wendy W. Berger on 7/28/2022. (RMF) (Entered: 07/28/2022)

NOTICE of Local Rule 3.02(a)(2), which requires the parties in every civil proceeding, except those described in subsection (d), to file a case management report (CMR) using the uniform form at www.flmd.uscourts.gov. The CMR must be filed (1) within forty days after any defendant appears in an action originating in this court, (2) within forty days after the docketing of an action removed or transferred to this court, or (3) within seventy days after service on the United States attorney in an action against the United States, its agencies or employees. Judges may have a special CMR form for certain types of cases. These forms can be found at www.flmd.uscourts.gov under the Forms tab for each judge. (Signed by Deputy Clerk). (RMF) (Entered: 07/28/2022)

*Order no pdf

Notice to Counsel of Local Rule

ORDER of recusal. The Clerk is directed to reassign this case to another United States Magistrate Judge. See Order. Signed by Magistrate Judge Daniel C. Irick on 8/1/2022. (RN) (Entered: 08/01/2022)

NOTICE of Appearance by Jon Robert Phillips on behalf of The School Board of Duval County, Florida (Phillips, Jon) (Entered: 08/01/2022)

NEW CASE ASSIGNED to Magistrate Judge Leslie Hoffman Price. New case number: 6:22-cv-1312-WWB-LHP. Magistrate Judge Daniel C. Irick no longer assigned to the case. (SJB) (Entered: 08/01/2022)

Case Assigned/Reassigned

NOTICE of Appearance by Laura J. Boeckman on behalf of The School Board of Duval County, Florida (Boeckman, Laura) (Entered: 08/02/2022)

NOTICE of Appearance by Howard S. Marks on behalf of The School Board of Orange County, Florida (Marks, Howard) (Entered: 08/03/2022)

NOTICE of Appearance by Sheena A. Thakrar on behalf of The School Board of Orange County, Florida (Thakrar, Sheena) (Entered: 08/03/2022)

NOTICE of Appearance by Matthew Joseph Carson on behalf of The School Board of Indian River County, Florida (Carson, Matthew) (Entered: 08/04/2022)

NOTICE of Appearance by Jeffrey Slanker on behalf of The School Board of Indian River County, Florida (Slanker, Jeffrey) (Entered: 08/04/2022)

NOTICE of Appearance by Robert Jacob Sniffen on behalf of The School Board of Indian River County, Florida (Sniffen, Robert) (Entered: 08/04/2022)

NOTICE of Appearance by Terry Joseph Harmon on behalf of The School Board of Indian River County, Florida (Harmon, Terry) (Entered: 08/04/2022)

Unopposed MOTION for Extension of Time to File Answer re 1 Complaint, by All Plaintiffs. (Dandeneau, Debra) Motions referred to Magistrate Judge Leslie Hoffman Price. (Entered: 08/09/2022)

MOTION for Jennifer Vail to appear pro hac vice, Special Admission fee paid, Receipt No. AFLMDC-19866843 for $150 by All Plaintiffs. (Dandeneau, Debra) Motions referred to Magistrate Judge Leslie Hoffman Price. (Entered: 08/10/2022)

ORDER granting 31 Unopposed Motion for Extension of Time to Respond to Plaintiffs' Complaint. The deadline for Defendants to respond to the Complaint is extended up to and including September 30, 2022. Signed by Magistrate Judge Leslie Hoffman Price on 8/10/2022. (ECJ) (Entered: 08/10/2022)

ORDER denying without prejudice 32 Motion to Appear Pro Hac Vice. Signed by Magistrate Judge Leslie Hoffman Price on 8/10/2022. (ECJ) (Entered: 08/10/2022)

MOTION for Jennifer Vail to appear pro hac vice by All Plaintiffs. (Dandeneau, Debra) Motions referred to Magistrate Judge Leslie Hoffman Price. (Entered: 08/11/2022)

Unopposed MOTION for Paul D. Castillo to appear pro hac vice by All Plaintiffs. (Castillo, Paul) Motions referred to Magistrate Judge Leslie Hoffman Price. (Entered: 08/16/2022)

. Special Admission for Non-Resident Attorney Paul D. Castillo. (Castillo, Paul)

CERTIFICATE of interested persons and corporate disclosure statement by The School Board of Indian River County, Florida. (Carson, Matthew) (Entered: 08/18/2022)

CERTIFICATE of interested persons and corporate disclosure statement by The School Board of Orange County, Florida. (Thakrar, Sheena) (Entered: 08/18/2022)

NOTICE of Appearance by Sean Fahey on behalf of The School Board of Palm Beach County, Florida (Fahey, Sean) (Entered: 08/22/2022)

PRO HAC VICE FEES paid by attorney PAUL D. CASTILLO, appearing on behalf of (Filing fee $150 receipt number ORL104893.) Related document: 36 Unopposed MOTION for Paul D. Castillo to appear pro hac vice . (SRD)

CORPORATE Disclosure Statement by The School Board of Duval County, Florida. (Boeckman, Laura) (Entered: 08/23/2022)

Unopposed MOTION for Camilla B. Taylor to appear pro hac vice, Special Admission fee paid, Receipt No. AFLMDC-19916216 for $150 by All Plaintiffs. (Dandeneau, Debra) Motions referred to Magistrate Judge Leslie Hoffman Price. (Entered: 08/23/2022)

Unopposed MOTION for Kell L. Olson to appear pro hac vice, Special Admission fee paid, Receipt No. AFLMDC-19916319 for $150 by All Plaintiffs. (Dandeneau, Debra) Motions referred to Magistrate Judge Leslie Hoffman Price. (Entered: 08/23/2022)

REFUND for duplicate payment. Receipt number AFLMDC-19866761 refunded in the amount of $ $150.00 paid to Debra Dandeneau. (NLC) Modified on 8/23/2022 to edit docket text (KNC).

ORDER granting 36 Unopposed Motion to Appear Pro Hac Vice; granting 41 Unopposed Motion to Appear Pro Hac Vice; granting 42 Unopposed Motion to Appear Pro Hac Vice. Paul D. Castillo, Esq., Camilla B. Taylor, Esq., and Kell L. Olson, Esq. may specially appear in this case as counsel for Plaintiffs. The Clerk of Court is directed to mail a copy of this Order to Attorneys Castillo, Taylor, and Olson. Signed by Magistrate Judge Leslie Hoffman Price on 8/24/2022. (ECJ) (Entered: 08/24/2022)

ORDER granting 35 Motion to Appear Pro Hac Vice. Jennifer Vail, Esq. may specially appear in this case as counsel for Plaintiffs. The Clerk of Court is directed to mail a copy of this Order to Attorney Vail. Signed by Magistrate Judge Leslie Hoffman Price on 8/26/2022. (ECJ) (Entered: 08/26/2022)

MOTION for Preliminary Injunction by All Plaintiffs. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Proposed Order)(Dandeneau, Debra) (Entered: 08/26/2022)

REQUEST for oral argument and evidentiary hearing. by CenterLink, Inc., Jennifer Cousins, Matthew Cousins, David Dinan, Vikranth Reddy Gongidi, K.R.D., Will Larkins, M.C., N.C., P.C. R.R.D., S.C. (Dandeneau, Debra) Modified on 8/29/2022 to edit docket text (KNC). (Entered: 08/26/2022)

ORDER: Defendants shall file their responses to the Motion for Preliminary Injunction on or before September 2, 2022. On or before September 6, 2022, the parties shall file a joint notice, not to exceed ten pages, informing this Court if an evidentiary hearing is necessary in this matter. If the Court determines, after review of the parties' submissions and joint notice, that an evidentiary hearing is necessary for the resolution of the Motion, a hearing will be set by the Court. Otherwise, the Court will issue a ruling based on the parties' written submissions. Signed by Judge Wendy W. Berger on 8/29/2022. (RMF) (Entered: 08/29/2022)

Set deadlines as to 45 MOTION for Preliminary Injunction . Responses due by 9/2/2022 (KNC)

Set Motion and R&R deadlines/hearings - PUBLIC

NOTICE of Appearance by Henry Charles Whitaker on behalf of Attorney General of Florida (Whitaker, Henry) (Entered: 09/02/2022)

RESPONSE to Motion re 45 MOTION for Preliminary Injunction filed by The School Board of Duval County, Florida. (Attachments: # 1 Exhibit Declaration of Heather Albritton)(Boeckman, Laura) (Entered: 09/02/2022)

RESPONSE in Opposition re 45 MOTION for Preliminary Injunction filed by The School Board of Indian River County, Florida. (Carson, Matthew) (Entered: 09/02/2022)

MOTION to Intervene by Attorney General of Florida. (Whitaker, Henry) Motions referred to Magistrate Judge Leslie Hoffman Price. (Entered: 09/02/2022)

RESPONSE in Opposition re 45 MOTION for Preliminary Injunction filed by Attorney General of Florida. (Whitaker, Henry) (Entered: 09/02/2022)

NOTICE of Appearance by Bilal Ahmed Faruqui on behalf of Attorney General of Florida (Faruqui, Bilal) (Entered: 09/02/2022)

RESPONSE to Motion re 45 MOTION for Preliminary Injunction filed by The School Board of Orange County, Florida. (Thakrar, Sheena) Modified on 9/6/2022 to edit docket text (KNC). (Entered: 09/02/2022)

RESPONSE in Opposition re 45 MOTION for Preliminary Injunction filed by The School Board of Palm Beach County, Florida. (Fahey, Sean) (Entered: 09/02/2022)

NOTICE of Appearance by Jon Erik Bell on behalf of The School Board of Palm Beach County, Florida (Bell, Jon) (Entered: 09/06/2022)

CERTIFICATE of interested persons and corporate disclosure statement by The School Board of Palm Beach County, Florida. (Fahey, Sean) (Entered: 09/06/2022)

NOTICE of Appearance by Anita J. Patel on behalf of Attorney General of Florida (Patel, Anita) (Entered: 09/06/2022)

Joint NOTICE Regarding Evidentiary Hearing on Plaintiffs' Motion for Preliminary Injunction by CenterLink, Inc., Jennifer Cousins, Matthew Cousins, David Dinan, Vikranth Reddy Gongidi, K.R.D., Will Larkins, M.C., N.C., P.C. R.R.D., S.C. (Dandeneau, Debra) Modified on 9/7/2022 to edit docket text (KNC). (Entered: 09/06/2022)

MOTION for Leave to File Other Document: Reply in Support of Plaintiffs' Motion to Preliminary Injunction. by All Plaintiffs. (Dandeneau, Debra) Motions referred to Magistrate Judge Leslie Hoffman Price. Modified on 9/8/2022 to edit docket text (KNC). (Entered: 09/08/2022)

ENDORSED ORDER granting 60 Plaintiffs' Motion for Leave to File Reply. Plaintiffs may file a single reply to Defendants' Responses to the Motion for Preliminary Injunction, not to exceed seven pages inclusive of all parts, on or before September 19, 2022. Signed by Judge Wendy W. Berger on 9/12/2022. (MDJ) (Entered: 09/12/2022)

ORDER granting 51 Attorney General Moody's Unopposed Motion to Intervene. Attorney General Moody shall file a response to the complaint (Doc. No. 1) on or before September 30, 2022. See PDF for additional details. Signed by Magistrate Judge Leslie Hoffman Price on 9/12/2022. (BAB) (Entered: 09/12/2022)

CASE MANAGEMENT REPORT. (Dandeneau, Debra) (Entered: 09/12/2022)

ORDER for Jennifer Vail to comply with the administrative procedures regarding electronic filing on or before 9/26/2022. Signed by Judge Wendy W. Berger on 9/12/2022. (RMF) (Entered: 09/12/2022)

Set deadlines as to 45 MOTION for Preliminary Injunction . Plaintiffs' Reply to Defendants' Responses due by 9/19/2022. (KNC)

Order on Motion for Leave to File Document

**Stricken pursuant to Order 66.** REPLY to Response to Motion re 45 MOTION for Preliminary Injunction filed by CenterLink, Inc., Jennifer Cousins, Matthew Cousins, David Dinan, Vikranth Reddy Gongidi, K.R.D., Will Larkins, M.C., N.C., P.C. R.R.D., S.C. (Dandeneau, Debra) Modified on 9/20/2022 to edit docket text (KNC). Modified on 9/21/2022, to add stricken language. (SPB) (Entered: 09/19/2022)

ENDORSED ORDER striking 65 Plaintiffs' Reply in Support of Motion for Preliminary Injunction. Pursuant to the 61 September 12, 2022 Order, Plaintiffs were permitted to file a reply "not to exceed seven pages inclusive of all parts." Nevertheless, Plaintiffs' Reply is eight pages in length, with the necessary signature and certificate of service contained on the final page. The 45 Motion for Preliminary Injunction similarly runs afoul of the page limitations for motions clearly set forth in the Local Rules of this Court. M.D. Fla. R. 3.01(a) (providing that a motion may be "no longer than twenty-five pages inclusive of all parts"). In the interests of an expedient resolution, the Court did not strike the Motion for Preliminary Injunction, but even after a clear directive on the record, Plaintiffs have been unable to comply with the requirements of this Court. Accordingly, the Reply is stricken. The Court will permit Plaintiffs one final opportunity to file a reply that complies with this Court's Order, but Plaintiffs are cautioned that future failures to comply with all applicable rules and orders of this Court may result in the striking or denial of filings without notice or leave to refile. Plaintiffs may file an amended reply, not to exceed seven pages in total, before 5:00 p.m. today. Signed by Judge Wendy W. Berger on 9/20/2022. (MDJ) (Entered: 09/20/2022)

REPLY to Response to Motion re 45 MOTION for Preliminary Injunction . filed by CenterLink, Inc., Jennifer Cousins, Matthew Cousins, David Dinan, Vikranth Reddy Gongidi, K.R.D., Will Larkins, M.C., N.C., P.C. R.R.D., S.C.. (Dandeneau, Debra) (Entered: 09/20/2022)

Order to strike

**STRICKEN PER 69 ORDER** First AMENDED COMPLAINT for Declaratory, Injunctive, and Other Relief against All Defendants with Jury Demand. filed by All Plaintiffs.(Dandeneau, Debra) Modified on 10/3/2022 to edit docket text (KNC). Modified on 10/4/2022 to edit docket text (KNC). (Entered: 09/30/2022)

ORDER: Plaintiffs' First Amended Complaint 68 is STRICKEN. On or before October 11, 2022, Plaintiffs shall file proofs of service in accordance with Local Rule 1.10(a). Failure to do so may result in the dismissal of this action without further notice. Signed by Judge Wendy W. Berger on 10/3/2022. (RMF) (Entered: 10/03/2022)

PROOF of service as to The School Board of Orange County by CenterLink, Inc., Jennifer Cousins, Matthew Cousins, David Dinan, Vikranth Reddy Gongidi, K.R.D., Will Larkins, M.C., N.C., P.C. R.R.D., S.C. (Attachments: # 1 Exhibit A)(Dandeneau, Debra) Modified on 10/4/2022 to edit docket text (KNC). (Entered: 10/03/2022)

PROOF of service as to The School Board of Indian River County by CenterLink, Inc., Jennifer Cousins, Matthew Cousins, David Dinan, Vikranth Reddy Gongidi, K.R.D., Will Larkins, M.C., N.C., P.C. R.R.D., S.C. (Attachments: # 1 Exhibit A)(Dandeneau, Debra) Modified on 10/4/2022 to edit docket text (KNC). (Entered: 10/03/2022)

PROOF of service as to The School Board of Palm Beach County by CenterLink, Inc., Jennifer Cousins, Matthew Cousins, David Dinan, Vikranth Reddy Gongidi, K.R.D., Will Larkins, M.C., N.C., P.C. R.R.D., S.C. (Attachments: # 1 Exhibit A)(Dandeneau, Debra) Modified on 10/4/2022 to edit docket text (KNC). (Entered: 10/03/2022)

PROOF of service as to The School Board of Duval County by CenterLink, Inc., Jennifer Cousins, Matthew Cousins, David Dinan, Vikranth Reddy Gongidi, K.R.D., Will Larkins, M.C., N.C., P.C. R.R.D., S.C. (Attachments: # 1 Exhibit A)(Dandeneau, Debra) Modified on 10/4/2022 to edit docket text (KNC). (Entered: 10/03/2022)

ENDORSED ORDER: the deadline for Defendants to respond to the 1 Complaint is extended through October 18, 2022. Signed by Judge Wendy W. Berger on 10/4/2022. (MDJ) (Entered: 10/04/2022)

Reset deadlines: for All Defendants. Response to the Complaint due 10/18/2022. (KNC)

*Order no pdf

CASE MANAGEMENT AND SCHEDULING ORDER: Amended Pleadings due by 10/19/2022 Joinder of Parties due by 10/19/2022 Discovery due by 4/5/2024 Dispositive motions due by 5/7/2024 Pretrial statement due by 9/9/2024 All other motions due by 8/7/2024 Plaintiff disclosure of expert report due by 2/6/2024 Defendant disclosure of expert report due by 3/7/2024 Trial Status Conference set for 9/10/2024 at 10:00 AM in Orlando Courtroom 3 B before Judge Wendy W. Berger Bench Trial set for the October 2024 trial term commencing on 10/7/2024 at 09:00 AM in Orlando Courtroom 3 B before Judge Wendy W. Berger. Conduct mediation hearing by 4/19/2024. Lead counsel to coordinate dates. Signed by Judge Wendy W. Berger on 10/6/2022. (RMF) (Entered: 10/06/2022)

ORDER: the parties are directed to confer, and then advise the Court, on the selection of a mediator, on or before October 21, 2022. Signed by Judge Wendy W. Berger on 10/6/2022. (RMF) (Entered: 10/06/2022)

STANDING ORDER on Discovery Motions. Signed by Magistrate Judge Leslie Hoffman Price on 2/7/2022.(BAB) (Entered: 10/07/2022)

Joint NOTICE of Filing Amended Complaint by CenterLink, Inc., Jennifer Cousins, Matthew Cousins, David Dinan, Vikranth Reddy Gongidi, K.R.D., Will Larkins, M.C., N.C., P.C. R.R.D., S.C. (Dandeneau, Debra) Modified on 10/17/2022 to edit docket text (KNC). (Entered: 10/14/2022)

First AMENDED COMPLAINT against All Defendants with Jury Demand. filed by All Plaintiffs.(Dandeneau, Debra) Modified on 10/17/2022 to edit docket text (KNC). (Entered: 10/14/2022)

NOTICE OF SELECTION of Thomas H. Bateman, III as mediator by Jennifer Cousins, Matthew Cousins, David Dinan, Vikranth Reddy Gongidi, K.R.D., Will Larkins, M.C., N.C., P.C. R.R.D., S.C. (Dandeneau, Debra) Modified on 10/20/2022 to edit docket text (KNC). (Entered: 10/19/2022)

ORDER: Plaintiffs' Motion for Preliminary Injunction 45 is DENIED. The First Amended Complaint 79 is DISMISSED without prejudice. On or before November 3, 2022, Plaintiffs may file an amended complaint in accordance with this Order. Failure to timely file an amended pleading that corrects the deficiencies noted herein may result in the dismissal of this action without further notice.Signed by Judge Wendy W. Berger on 10/20/2022. (RMF) (Entered: 10/20/2022)

Set deadlines: Amended Complaint due by 11/3/2022 (KNC)

Set/reset deadlines/hearings-PUBLIC

SECOND AMENDED COMPLAINT against Attorney General of Florida, The School Board of Duval County, Florida, The School Board of Indian River County, Florida, The School Board of Orange County, Florida, The School Board of Palm Beach County, Florida, State Board of Education with Jury Demand. filed by All Plaintiffs.(Dandeneau, Debra) Modified on 11/4/2022 to edit docket text (KNC). (Entered: 11/03/2022)

PROPOSED summons to be issued by CenterLink, Inc., Jennifer Cousins, Matthew Cousins, David Dinan, Vikranth Reddy Gongidi, K.R.D., Will Larkins, M.C., N.C., P.C. R.R.D., S.C.. (Dandeneau, Debra) (Entered: 11/03/2022)