Case: Virginia State Conference NAACP v. County School Board of Shenandoah County

Legal Defense Fund

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF against County School Board of Shenandoah County (Filing & Administrative fee $ 405 receipt number AVAWDC-4445518.), filed by Mary Johnson, Virginia State Conference NAACP, Kay Doe, Kim Wallace Carter, Heather Brown, Edward Doe. (Attachments: # 1 Civil Cover Sheet)(jv)

MOTION to File Pseudonymously by Edward Doe, Kay Doe, Mary Johnson. (Attachments: # 1 Text of Proposed Order)(jv)

Brief / Memorandum in Support re 2 MOTION to File Pseudonymously filed by Edward Doe, Kay Doe, Mary Johnson. (jv)

Electronic Summons Issued as to County School Board of Shenandoah County NOTICE TO COUNSEL: Please print copies of the electronically issued summons for each defendant as necessary to effectuate service under Fed. R. Civ. P. 4.(jv)

SUMMONS Returned Executed by Mary Johnson, Virginia State Conference NAACP, Kay Doe, Kim Wallace Carter, Heather Brown, Edward Doe. County School Board of Shenandoah County served on 6/12/2024, answer due 7/3/2024.(Burchard, Kendall)

MOTION for Cara E. Souto to Appear Pro Hac Vice. Filing fee $ 100, receipt number AVAWDC-4452460. by Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP. (Burchard, Kendall)

MOTION for Stephanie Nnadi to Appear Pro Hac Vice. Filing fee $ 100, receipt number AVAWDC-4452480. by Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP. (Burchard, Kendall)

MOTION for Jason C. Raofield to Appear Pro Hac Vice. Filing fee $ 100, receipt number AVAWDC-4452482. by Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP. (Burchard, Kendall)

MOTION for Li Reed to Appear Pro Hac Vice. Filing fee $ 100, receipt number AVAWDC-4452486. by Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP. (Burchard, Kendall)

MOTION for Elizabeth Upton to Appear Pro Hac Vice. Filing fee $ 100, receipt number AVAWDC-4452490. by Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP. (Burchard, Kendall)

ORAL ORDER granting 6 MOTION for Cara E. Souto to Appear Pro Hac Vice; granting 7 MOTION for Stephanie Nnadito Appear Pro Hac Vice; granting 8 MOTION for Jason C. Raofield to Appear Pro Hac Vice; granting 9 MOTION for Li Reed to Appear Pro Hac Vice; granting 10 MOTION for Elizabeth Upton to Appear Pro Hac Vice. Entered by Judge Elizabeth K. Dillon on 6/25/2024. This Notice of Electronic Filing is the Official ORDER for this entry. No document is attached.(jv)

Attorney - Updating Contact Information

Order on Motion to Appear Pro Hac Vice AND Order on Motion to Appear Pro Hac Vice AND Order on Motion to Appear Pro Hac Vice AND Order on Motion to Appear Pro Hac Vice AND Order on Motion to Appear Pro Hac Vice

Jason C. Raofield, Esq., in accordance with Section C.9. of the Administrative Procedures for Filing, Signing and Verifying Pleadings and Papers by Electronic Means, a registered user is responsible for ensuring their mailing address, primary email address, and telephone number are kept up-to-date with this court by updating the information in their PACER account and submitting to this court. Click here for PACER aid to updating your personal information, address information or email noticing. (jv)

NOTICE of Appearance by Christopher Stanislaw Dadak on behalf of County School Board of Shenandoah County (Dadak, Christopher)

Notice of Requirement - Corporate Disclosure Statement

E-Magistrate Consent Notice to Parties

Order Referring Motion

NOTICE of Appearance by Jim H. Guynn, Jr on behalf of County School Board of Shenandoah County (Guynn, Jim)

NOTICE of Appearance by John Richard Fitzgerald on behalf of County School Board of Shenandoah County (Fitzgerald, John)

MOTION for Extension of Time to File Response/Reply by County School Board of Shenandoah County. (Attachments: # 1 Text of Proposed Order)(Guynn, Jim)

Magistrate Consent Notice to Parties. Click here to access the Consent Form (sln)

Notice of Filing Requirement - Pursuant to Standing Order dated May 15, 2000, and the adoption of Rule 7.1 of the Federal Rules of Civil Procedures, effective December 1, 2002, nongovernmental corporate parties are directed to file a Corporate Disclosure Statement with their first appearance, pleading, motion or response. Click here to access the Corporate Disclosure Statement Form. This form should be electronically filed in this matter as ordered. (sln)

Negative Corporate Disclosure Statement by County School Board of Shenandoah County (Guynn, Jim)

ORAL ORDER REFERRING MOTION: 15 MOTION for Extension of Time to File Response/Reply filed by County School Board of Shenandoah County Motions referred to Joel C. Hoppe.. Entered by Judge Elizabeth K. Dillon on 7/2/24. This Notice of Electronic Filing is the Official ORDER for this entry. No document is attached.(kld)

Negative Corporate Disclosure Statement by Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP (Burchard, Kendall) (Main Document 20 replaced on 7/3/2024) (kab). Modified on 7/3/2024 Replaced deficient pdf document with flattened pdf document(kab).

ORDER granting 15 Motion for Extension of Time to File Response/Reply. The Defendant shall file its responsive pleading on or before July 17, 2024. The Plaintiffs are to file any response in opposition to the responsive pleading by August 16, 2024. The Defendant is to file any reply memorandum in support of it responsive pleading by August 28, 2024. Signed by Magistrate Judge Joel C. Hoppe on 7/3/2024. (dsa)

ORDER TRANSFERRING CASE: Case transferred to District Judge Michael F. Urbanski for all further proceedings. Chief Judge Elizabeth K. Dillon no longer assigned to case. Signed by Chief Judge Elizabeth K. Dillon on 7/3/2024. (skm)

Scheduling Letter (mka)

MOTION for Kaitlin Banner to Appear Pro Hac Vice. Filing fee $ 100, receipt number AVAWDC-4466751. by Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP. (Burchard, Kendall)

MOTION for Marja Plater to Appear Pro Hac Vice. Filing fee $ 100, receipt number AVAWDC-4466755. by Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP. (Burchard, Kendall)

ORDER granting 24 MOTION to Appear Pro Hac Vice. Attorney Kaitlin Banner for Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP added. Signed by Senior Judge Michael F. Urbanski on 7/12/2024. (al) (Main Document 26 replaced on 7/12/2024) (al). Modified on 7/12/2024 Document replaced with file stamped copy (al).

ORDER granting 25 MOTION to Appear Pro Hac Vice. Attorney Marja Plater for Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP added. Signed by Senior Judge Michael F. Urbanski on 7/12/2024. (al)

NOTICE of Hearing: (N) (No Interpreter requested) (Click on this link for guidance for participation via Zoom and Click on this link for instructions on how to listen to public hearings) Scheduling Conference set for 9/4/2024 10:00 AM in via Zoom before Senior District Judge Michael F Urbanski. (mka)

Notice of Hearing

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by County School Board of Shenandoah County. (Fitzgerald, John)

Brief / Memorandum in Support re 29 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM . filed by County School Board of Shenandoah County. (Fitzgerald, John)

NOTICE of Appearance by Cara Elizabeth Souto on behalf of Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP (Souto, Cara)

NOTICE of Appearance by Jason C. Raofield on behalf of Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP (Raofield, Jason)

NOTICE of Appearance by Stephanie Uchechi Nnadi on behalf of Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP (Nnadi, Stephanie)

NOTICE of Appearance by Elizabeth Upton on behalf of Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP (Upton, Elizabeth)

NOTICE of Appearance by Li Reed on behalf of All Plaintiffs (Reed, Li)

RESPONSE in Opposition re 2 MOTION to File Pseudonymously . filed by County School Board of Shenandoah County. (Fitzgerald, John)

RESPONSE in Support re 2 MOTION to File Pseudonymously, RESPONSE in Opposition . filed by Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP. (Burchard, Kendall)

NOTICE of Hearing on Motion 29 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM : (CR) (No Interpreter requested) NOTICE TO COUNSEL This hearing has been set for one hour. If you think the hearing will take longer than one hour please contact the Courtroom Deputy as soon as possible. Motion Hearing set for 10/1/2024 11:00 AM in Harrisonburg before Senior Judge Michael F. Urbanski. (mka)

Notice of Hearing on Motion

RESPONSE in Opposition re 29 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM . filed by Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP. (Burchard, Kendall)

MOTION for Ryan Downer to Appear Pro Hac Vice. Filing fee $ 100, receipt number AVAWDC-4490110. by Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP. Motions referred to Judge Joel C. Hoppe. (Burchard, Kendall)

ORAL ORDER granting 40 MOTION for Ryan Downer to Appear Pro Hac Vice in this case. Entered by Magistrate Judge Joel C. Hoppe on 8/19/24. This Notice of Electronic Filing is the Official ORDER for this entry. No document is attached. (The Clerk is directed to mail a copy of this Order to any applicable pro se party/parties via US Mail)(JCH)

Order on Motion to Appear Pro Hac Vice

Rule 26(f) Agreed Written Plan by Plaintiffs Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP (Burchard, Kendall)

REPLY to Response to Motion re 29 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM . filed by County School Board of Shenandoah County. (Fitzgerald, John)

NOTICE of Appearance by Ashley Joyner Chavous on behalf of All Plaintiffs (Chavous, Ashley)

Notice of Appearance

Minute Entry for proceedings held before Senior Judge Michael F. Urbanski: Scheduling Conference held on 9/4/2024. (kab)

Notice Rescheduling Hearing on Motion AND Notice of Hearing on Motion

Order

Notice of Hearing

ORAL ORDER unreferring 2 MOTION to File Pseudonymously filed by Edward Doe, Mary Johnson, Kay Doe. Entered by Senior Judge Michael F. Urbanski on 9/4/2024. This Notice of Electronic Filing is the Official ORDER for this entry. No document is attached.(mka)

NOTICE Rescheduling Hearing on Motion 29 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM, (CR) (No Interpreter requested) previously set for 10/1/2024 at 11:00am before Judge Urbanski in Harrisonburg: NOTICE of Hearing on Motion re 2 MOTION to File Pseudonymously by Edward Doe, Kay Doe, Mary Johnson, and 29 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM - Motion Hearing set for 9/27/2024 11:00 AM in Harrisonburg before Senior Judge Michael F. Urbanski. NOTICE TO COUNSEL This hearing has been set for three (3) hours. (mka)

NOTICE of Hearing: (CR) (No Interpreter requested) Bench Trial set for 7/14-18/2025 09:30 AM in Harrisonburg before Senior Judge Michael F. Urbanski. Counsel must contact the Clerk's Office no later than five (5) business days before the scheduled trial date for your technology needs. (mka)

NOTICE of Appearance by Ryan C. Downer on behalf of All Plaintiffs (Downer, Ryan)

Notice of Appearance

Minute Entry for proceedings held before Senior Judge Michael F. Urbanski: Motion Hearing held on 9/27/2024 re 2 MOTION to File Pseudonymously filed by Edward Doe, Mary Johnson, Kay Doe, 29 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by County School Board of Shenandoah County. Opinion and order forthcoming. (Court Reporter: Whitney Stier) (mka)

TRANSCRIPT REQUEST (Ordinary-30 calendar days Service) by County School Board of Shenandoah County for Motion Hearing held on 9/27/2024 reported by Court Reporter Whitney Stier before Judge Michael F. Urbanski. Transcript Due Deadline will be set when Financial Arrangements are made. (Guynn, Jim)

TRANSCRIPT REQUEST (Ordinary-30 calendar days Service) by Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP for Motion Hearing held on 9/27/2024 reported by Court Reporter Whitney Stier before Judge Judge Michael F. Urbanski. Transcript Due Deadline will be set when Financial Arrangements are made. (Souto, Cara)

Financial arrangements made (Original) (Ordinary-30 calendar days Service) re 51 Transcript Request, Transcript due by 11/12/2024. (ws)

Financial Arrangements Made

Financial arrangements made (Copy) (Ordinary-30 calendar days Service) re 52 Transcript Request, Transcript due by 11/12/2024. (ws)

Rule 26(f) Agreed Written Plan by Plaintiffs Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP (Burchard, Kendall)

Notice Rescheduling Hearing (CR) (No Interpreter requested) previously set for 7/14-18/2025 at 9:30am before Judge Urbanski in Harrisonburg Bench Trial reset for 6/30/2025 to 7/3/2025 at 09:30 AM in Harrisonburg before Senior Judge Michael F. Urbanski. Counsel must contact the Clerk's Office no later than five (5) business days before the scheduled trial date for your technology needs. (mka)

Notice Rescheduling Hearing

MOTION to Withdraw as Attorney on behalf of Stephanie Nnadi by Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP. Motions referred to Judge Joel C. Hoppe. (Attachments: # 1 Proposed Order)(Burchard, Kendall)

Order on Motion to Withdraw as Attorney

ORAL ORDER granting 57 Motion to Withdraw as Attorney. Attorney Stephanie Uchechi Nnadi terminated. Entered by Magistrate Judge Joel C. Hoppe on 10/25/24. This Notice of Electronic Filing is the Official ORDER for this entry. No document is attached. (The Clerk is directed to mail a copy of this Order to any applicable pro se party/parties via US Mail)(JCH)

TRANSCRIPT of Proceedings: Pretrial Motions held on 9-27-2024 before Judge Urbanski. Court Reporter/Transcriber Whitney Stier. NOTICE RE REDACTION OF TRANSCRIPTS: The parties have seven (7) calendar days to file with the Court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript will be made remotely electronically available to the public without redaction after 90 calendar days. The policy is located on our website at www.vawd.uscourts.gov. Transcript may be viewed at the court public terminal or purchased through Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER unless a Redacted Transcript has been filed. Redaction Request due 11/20/2024. Redacted Transcript Deadline set for 12/2/2024. Release of Transcript Restriction set for 1/28/2025. (ws)

Transcript Copy Delivered

Transcript Copy Delivered re 52 Transcript Request, (ws)

MEMORANDUM OPINION. Signed by Senior Judge Michael F. Urbanski on 1/22/2025. (sln)

ORDER denying 29 Motion to Dismiss for Failure to State a Claim. Signed by Senior Judge Michael F. Urbanski on 1/22/2025. (sln)

MEMORANDUM OPINION. Signed by Senior Judge Michael F. Urbanski on 1/22/2025. (sln)

ORDER granting 2 Motion File Pseudonymously. Signed by Senior Judge Michael F. Urbanski on 1/22/2025. (sln)

Order Referring Case for Mediation. Signed by Senior Judge Michael F. Urbanski on 01/22/2025. (sln)

MOTION for Lauren Smith to Appear Pro Hac Vice. Filing fee $ 100, receipt number AVAWDC-4596257. by Virginia State Conference NAACP, Heather Brown, Kim Wallace Carter, Kay Doe, Edward Doe, Mary Johnson. (Attachments: # 1 Text of Proposed Order)(Chavous, Ashley) Modified on 1/24/2025 to remove referral text from docket entry (rb).

MOTION for Stephanie Nnadi to Appear Pro Hac Vice. Filing fee $ 100, receipt number AVAWDC-4596260. by Virginia State Conference NAACP, Heather Brown, Kim Wallace Carter, Kay Doe, Edward Doe, Mary Johnson. (Attachments: # 1 Text of Proposed Order)(Chavous, Ashley) Modified on 1/24/2025 to remove referral text from docket entry (rb).

ORDER granting 66 MOTION to Appear Pro Hac Vice as to Lauren Smith. Signed by Senior Judge Michael F. Urbanski on 01/24/2025. (rb)

ORDER granting 67 MOTION to Appear Pro Hac Vice. Attorney Stephanie Uchechi Nnadi for Heather Brown, Kim Wallace Carter, Edward Doe, Kay Doe, Mary Johnson, Virginia State Conference NAACP added. Signed by Senior Judge Michael F. Urbanski on 01/24/2025. (rb)

NOTICE of Appearance by Lauren Taylor Smith on behalf of All Plaintiffs (Smith, Lauren)

Notice of Appearance

E-Magistrate Consent Notice to Parties

NOTICE of Appearance by Stephanie Uchechi Nnadi on behalf of All Plaintiffs (Nnadi, Stephanie)

Magistrate Consent Notice to Parties. Click here to access the Consent Form (rb)

ANSWER to Complaint 1 Complaint, by County School Board of Shenandoah County.(Fitzgerald, John)

DEMAND for Trial by Jury by County School Board of Shenandoah County (Fitzgerald, John)

Order Setting Settlement Conference. Settlement Conference set for 4/21/2025 10:00 AM in Charlottesville before Magistrate Judge Joel C. Hoppe. Signed by Magistrate Judge Joel C. Hoppe on 3/7/2025. (Attachments: # 1 Exhibit A)(ck) Main Document 75 replaced on 3/7/2025 to add file stamp) (ck).

Notice of Hearing

NOTICE of Hearing: (N) (No Interpreter requested) In Chambers Conference re: mediation set for 4/7/2025 09:00 AM by telephone conference before Magistrate Judge Joel C. Hoppe. Dial in instructions emailed to counsel.(ck)

NOTICE of Hearing: (N) (No Interpreter requested) Settlement Conference set for 4/21/2025 10:00 AM in Charlottesville before Magistrate Judge Joel C. Hoppe. (ck)

NOTICE of Hearing: (CR) (No Interpreter requested) NOTICE TO COUNSEL This hearing has been set for one hour. If you think the hearing will take longer than one hour please contact the Courtroom Deputy as soon as possible. (Click on this link for guidance for participation via Zoom and Click on this link for instructions on how to listen to public hearings) Status Conference set for 3/12/2025 02:00 PM in via Zoom before Senior Judge Michael F. Urbanski. (mka)

Notice of Hearing