Shellonnee Chinn vs The Elmwood Franklin School

Page 1

Case: 1:15-cv-00938-FPG As of: 10/12/2017 11:39 AM EDT 1 of 8 LEAD,MEDIATION,ProSe

U.S. DISTRICT COURT U.S. District Court, Western District of New York (Buffalo) CIVIL DOCKET FOR CASE #: 1:15−cv−00938−FPG Chinn v. The Elmwood Franklin School et al Assigned to: Hon. Frank P. Geraci, Jr. Demand: $9,000,000 Cause: 42:1983 Civil Rights (Employment Discrimination) Plaintiff Shellonnee B. Chinn

Date Filed: 10/29/2015 Jury Demand: Plaintiff Nature of Suit: 442 Civil Rights: Jobs Jurisdiction: Federal Question

represented by Shellonnee B. Chinn 55 Janet Street Buffalo, NY 14215 716−316−9312 PRO SE

V. Defendant The Elmwood Franklin School

represented by Brendan Patrick Kelleher Harris Beach LLP Larkin at Exchange 726 Exchange Street Suite 1000 Buffalo, NY 14210 716−200−5050 Fax: 716−200−5201 Email: bkelleher@harrisbeach.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant The Buffalo Public Schools District

represented by Joel Clarence Moore City of Buffalo Corporation Counsel's Office 1100 City Hall 65 Nigara Square Buffalo, NY 14202−3331 716−851−4313 Fax: 716−551−5563 Email: jcmoore@buffaloschools.org LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant Sarah Duddy individually and as The Elmwood Franklin, Lower School Head of School, and Defacto Head of School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant Andrew Deyell individually and as The Elmwood Franklin School, Head of School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant Fred Acquavita individually, and as The Elmwood

represented by Brendan Patrick Kelleher (See above for address)


Case: 1:15-cv-00938-FPG As of: 10/12/2017 11:39 AM EDT 2 of 8 Franklin, Interim Head of School, Acting Lower School Head of School, and Defacto Head of School

LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant Alyssa Schwabe individually, and as The Elmwood Franklin School, Defacto Head of School, and Lower School Teacher

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant Patti Scaffidi individually, and as The Elmwood Franklin School, Defacto head of School, and Lower School Teacher

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant Molly Clauss individually, and as The Elmwood Franklin School, Defacto Head of School, and Lower School Teacher

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant Jenna Evaldi individually, and as The Elmwood Franklin School, Defacto ehad of School, and Lower School Teacher

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant Michele Kulpit individually, and as The Elmwood Franklin School, Defacto Head of School, and Lower School Teacher

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant The Elmwood Franklin School Board of Trustees each in their official and individual capacties: Michael Joseph, Alice Jacobs, Barry Heneghan, Catherine Beltz−Foley, Cyndi Burnett, Christopher Koch, Omar Kahn, Brian J. Lipke, Alon Kupferman, Kimisha Brown Houston, Cutler Greene, Arthur Glick, etc.

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

V. Consol Defendant Michael Joseph individually and as Trustee of The Elmwood Franklin School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant Alice Jacobs individually and as Trustee of The Elmwood Franklin School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED


Case: 1:15-cv-00938-FPG As of: 10/12/2017 11:39 AM EDT 3 of 8 Consol Defendant Barry Heneghan individually and as Trustee of The Elmwood Franklin School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant Catherine Beltz−Foley individually and as Trustee of The Elmwood Franklin School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant Cyndi Burnett individually and as Trustee of The Elmwood Franklin School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant Christopher Koch individually and as Trustee of The Elmwood Franklin School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant Omar Khan individually and as Trustee of The Elmwood Franklin School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant Brian J. Lipke individually and as Trustee of The Elmwood Franklin School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant Alon Kupferman individually and as Trustee of The Elmwood Franklin School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant Kimisha Brown Houston individually and as Trustee of The Elmwood Franklin School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant Cutler Greene individually and as Trustee of The Elmwood Franklin School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant Arthur Glick individually and as Trustee of The Elmwood Franklin School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED


Case: 1:15-cv-00938-FPG As of: 10/12/2017 11:39 AM EDT 4 of 8 Consol Defendant Keith Frome individually and as Trustee of The Elmwood Franklin School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant Scott Friedman individually and as Trustee of The Elmwood Franklin School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant Terri Rich individually and as Trustee of The Elmwood Franklin School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant Peter Allen Weinmann

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant Nicholas B. Tzetzo individually and as Trustee of The Elmwood Franklin School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant Sonja Siren individually and as Trustee of The Elmwood Franklin School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant . Robert Scott individually and as Trustee of The Elmwood Franklin School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant Anthony Johnson individually and as Trustee of The Elmwood Franklin School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant Michele Lee individually and as Trustee of The Elmwood Franklin School

represented by Brendan Patrick Kelleher (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed

#

Docket Text

09/28/2017

69 DECISION AND ORDER: The Court Orders as follows:


Case: 1:15-cv-00938-FPG As of: 10/12/2017 11:39 AM EDT 5 of 8 1) Plaintiff's Motions for an extension of time to complete service on Defendants is GRANTED, and she shall have until October 31, 2017 to serve all Defendants; 2) Defendant Deyell's Motion to Vacate the Clerk's Entry of Default in Case No. 15−CV−1050 is GRANTED, and Plaintiff's Motion for Default Judgment against Deyell is DENIED; 3) Plaintiff's applications for costs regarding service are DENIED WIHTOUT PREJUDICE, and the parties are strongly encouraged to discuss and resolve the issue of reasonable service costs against Defendants amongst themselves; and 4) the cases of (1) Chinn v. Elmwood Franklin, 15−CV−938−FPG; (2) Chinn v. Elmwood Franklin, 15−CV−964−FPG; (3) Chinn v. Deyell, 15−CV−1050−FPG; and (4) Chinn v. Duddy, 16−CV−61−FPG are hereby CONSOLIDATED, and all future filings shall occur under the lead docket of 15−CV−938−FPG. 5) After consolidating the cases, the Clerk of Court shall close case numbers 15−CV−964−FPG, 15−CV−1050−FPG, and 16−CV−61−FPG. SO ORDERED. Signed by Hon. Frank P. Geraci, Jr. on 9/28/17.A copy of the NEF from each of the 4 cases, and a single copy of the Decision and Order entered in each case has been mailed to the pro se Plaintiff. (SCE) −CLERK TO FOLLOW UP− (Entered: 09/28/2017) 03/21/2017

68 AFFIRMATION filed by The Elmwood Franklin School , et al.. (Attachments: # 1 Civil Cover Sheet Defendant's Cover Letter to Judge Geraci, # 2 Exhibit Complaint, # 3 Exhibit Motion for Enlargement of Time, # 4 Exhibit Plaintiff's Motion for Service Fees)(Kelleher, Brendan) (Entered: 03/21/2017)

03/21/2017

67 AFFIRMATION filed by The Elmwood Franklin School , et al.. (Attachments: # 1 Exhibit Complaint, # 2 Exhibit Motion for Enlargement of Time, # 3 Exhibit Plaintiff's Motion for Service Fees, # 4 Civil Cover Sheet Defendant's Cover Letter to Judge)(Kelleher, Brendan) (Entered: 03/21/2017)

03/01/2017

66 MOTION for Payment of Service Costs as to Alice Jacobs by Shellonnee B. Chinn.(NRE) (Entered: 03/03/2017)

03/01/2017

65 MOTION for Payment of Service Costs as to Alan Kupferman by Shellonnee B. Chinn.(NRE) (Entered: 03/03/2017)

03/01/2017

64 MOTION for Payment of Service Costs as to Alyssa Schwabe by Shellonnee B. Chinn.(NRE) (Entered: 03/03/2017)

03/01/2017

63 MOTION for Payment of Service Costs as to Andrew Deyell by Shellonnee B. Chinn.(NRE) (Entered: 03/03/2017)

03/01/2017

62 MOTION for Payment of Service Costs as to Anthony Johnson by Shellonnee B. Chinn.(NRE) (Entered: 03/03/2017)

03/01/2017

61 MOTION for Payment of Service Costs as to Arthur Glick by Shellonnee B. Chinn.(NRE) (Entered: 03/03/2017)

03/01/2017

60 MOTION for Payment of Service Costs as to Barry Heneghan by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

59 MOTION for Payment of Service Costs as to Brian J. Lipke by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

58 MOTION for Payment of Service Costs as to Catherine Beltz−Foley by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

57 MOTION for Payment of Service Costs as to Christopher Koch by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)


Case: 1:15-cv-00938-FPG As of: 10/12/2017 11:39 AM EDT 6 of 8 03/01/2017

56 MOTION for Payment of Service Costs as to Cutler Greene by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

55 MOTION for Payment of Service Costs as to Cyndi Burnett by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

54 MOTION for Payment of Service Costs as to Fred Acquavita by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

53 MOTION for Payment of Service Costs as to Jenna Evaldi by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

52 MOTION for Payment of Service Costs as to Keith Frome by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

51 MOTION for Payment of Service Costs as to Kimisha Brown Houston by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

50 MOTION for Payment of Service Costs as to Michael Joseph by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

49 MOTION for Payment of Service Costs as to Michele Kulpit by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

48 MOTION for Payment of Service Costs as to Michele Lee by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

47 MOTION for Payment of Service Costs as to Molly Clauss by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

46 MOTION for Payment of Service Costs as to Nicholas B. Tzeto by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

45 MOTION for Payment of Service Costs as to Omar Kahn by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

44 MOTION for Payment of Service Costs as to Patti Scaffidi by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

43 MOTION for Payment of Service Costs as to Peter Allen Weinmann by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

42 MOTION for Payment of Service Costs as to Robert Scott by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

41 MOTION for Payment of Service Costs as to Sarah Duddy by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

40 MOTION for Payment of Service Costs as to Scott Friedman by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

39 MOTION for Payment of Service Costs as to Sonja Siren by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

38 MOTION for Payment of Service Costs as to Terri Rich by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

03/01/2017

37 MOTION for Payment of Service Costs as to The Elmwood Franklin School by Shellonnee B. Chinn.(NRE) (Entered: 03/02/2017)

01/30/2017

36 SUMMONS Returned Executed by Shellonnee B. Chinn. Fred Acquavita served on 1/27/2017, answer due 2/17/2017. (SG) (Entered: 01/31/2017)

01/24/2017

35 ANSWER to 1 Complaint, by The Buffalo Public Schools District.(Moore, Joel) (Entered: 01/24/2017)

01/24/2017

34 NOTICE of Appearance by Joel Clarence Moore on behalf of The Buffalo Public Schools District (Moore, Joel) (Entered: 01/24/2017)

01/09/2017

33 SUMMONSES returned executed as to Trustees (SG) (Entered: 01/11/2017)


Case: 1:15-cv-00938-FPG As of: 10/12/2017 11:39 AM EDT 7 of 8 01/05/2017

32 SUMMONS RETURNED Executed by Plaintiff as to Catherine Beltz−Foley. (SG) (Entered: 01/09/2017)

01/05/2017

31 SUMMONS Returned Executed by Shellonnee B. Chinnas to The Elmwood Franklin School (SG) (Entered: 01/09/2017)

01/05/2017

30 SUMMONS Returned Executed by Shellonnee B. Chinn. The Buffalo Public Schools District served on 1/5/2017, answer due 1/26/2017. (SG) (Entered: 01/09/2017)

01/03/2017

29 MOTION for extension of time to serve by Shellonnee B. Chinn. (Attachments: # 1 Proposed Order)(SG) (Entered: 01/04/2017)

12/22/2016

28 NOTICE of Defendant's Failure to Comply with Electronic Filing and Service of Documents by Shellonnee B. Chinn (SG) (Entered: 12/22/2016)

12/08/2016

27 NOTICE of Defendant's Failure to Comply with FRCP 7.1 by Shellonnee B. Chinn (SG) (Entered: 12/12/2016)

12/06/2016

26 NOTICE of Defendant's Failure to Comply with FRCP 5(a) by Shellonnee B. Chinn (SG) (Entered: 12/07/2016)

11/10/2016

25 SUMMONS Returned Executed by Shellonnee B. Chinn. Michele Kulpit served on 11/10/2016, answer due 12/1/2016. (SG) (Entered: 11/15/2016)

11/10/2016

24 SUMMONS Returned Executed by Shellonnee B. Chinn. The Elmwood Franklin School served on 11/10/2016, answer due 12/1/2016. (SG) (Entered: 11/15/2016)

11/01/2016

23 SUMMONS Returned Executed by Shellonnee B. Chinn. Patti Scaffidi served on 10/31/2016, answer due 11/21/2016. (SG) (Entered: 11/02/2016)

11/01/2016

22 Letter from Plaintiff, dated 11/1/16, to Brendan P. Kelleher, Esq. (SG) (Entered: 11/01/2016)

10/24/2016

21 AFFIDAVIT of Service for Summons and Complaint served on Andrew Deyell on 10/24/2016, filed by Shellonnee B. Chinn. (KLH) (Entered: 10/25/2016)

10/24/2016

Clerk's Default Not Entered. Plaintiff notified. Reason: Answer timely filed. (KLH) (Entered: 10/24/2016)

10/24/2016

20 REQUEST for Clerk's Entry of Default by Shellonnee B. Chinn against The Elmwood Franklin School Board of Trustees. (KLH) (Entered: 10/24/2016)

10/24/2016

19 REQUEST for Clerk's Entry of Default by Shellonnee B. Chinn against Alyssa Schwabe. (KLH) (Entered: 10/24/2016)

10/24/2016

18 REQUEST for Clerk's Entry of Default by Shellonnee B. Chinn against The Elmwood Franklin School Board of Trustees − Arthur Glick. (KLH) Modified on 10/24/2016 to correct file date (KLH). (Entered: 10/24/2016)

10/24/2016

17 REQUEST for Clerk's Entry of Default by Shellonnee B. Chinn against The Elmwood Franklin School Board of Trustees − Christopher Koch. (KLH) Modified on 10/24/2016 to identify individual deft and correct file date (KLH). (Entered: 10/24/2016)

10/20/2016

16 REQUEST for Clerk's Entry of Default by Shellonnee B. Chinn against Molly Clauss. (KLH) (Entered: 10/24/2016)

10/20/2016

15 REQUEST for Clerk's Entry of Default by Shellonnee B. Chinn against Sarah Duddy. (KLH) (Entered: 10/24/2016)

10/20/2016

14 REQUEST for Clerk's Entry of Default by Shellonnee B. Chinn against Jenna Evaldi. (KLH) (Entered: 10/24/2016)

10/17/2016

ADR Plan electronically forwarded to attorneys. The ADR Plan is available for download at http://www.nywd.uscourts.gov/alternative−dispute−resolution(SG) (Entered: 10/17/2016)

10/14/2016

13 ANSWER to 1 Complaint, by Fred Acquavita, Molly Clauss, Andrew Deyell, Sarah Duddy, Jenna Evaldi, Michele Kulpit, Patti Scaffidi, Alyssa Schwabe, The Buffalo Public Schools District, The Elmwood Franklin School, The Elmwood Franklin School Board of Trustees.(Kelleher, Brendan) (Entered: 10/14/2016)


Case: 1:15-cv-00938-FPG As of: 10/12/2017 11:39 AM EDT 8 of 8 09/27/2016

12 AFFIRMATION/CERTIFICATE OF SERVICE by Shellonnee B. Chinn (SG) (Entered: 09/29/2016)

09/27/2016

11 AFFIRMATION/CERTIFICATE OF SERVICE by Shellonnee B. Chinn (SG) (Entered: 09/29/2016)

09/27/2016

10 AFFIRMATION/CERTIFICATE OF SERVICE by Shellonnee B. Chinn re 1 Complaint, (SG) (Entered: 09/29/2016)

09/27/2016

9 SUMMONS Returned Executed by Shellonnee B. Chinn. Alyssa Schwabe served on 9/27/2016, answer due 10/18/2016. (SG) (Entered: 09/29/2016)

09/27/2016

8 AMENDED SUMMONS Returned Executed by Shellonnee B. Chinn. Molly Clauss served on 9/23/2016, answer due 10/14/2016. (SG) (Entered: 09/29/2016)

09/27/2016

7 AMENDED SUMMONS Returned Executed by Shellonnee B. Chinn. Jenna Evaldi served on 9/23/2016, answer due 10/14/2016. (SG) (Entered: 09/29/2016)

09/27/2016

6 AMENDED SUMMONS Returned Executed by Shellonnee B. Chinn. Sarah Duddy served on 9/23/2016, answer due 10/14/2016. (SG) (Entered: 09/29/2016)

09/23/2016

5 CERTIFICATE OF SERVICE by Shellonnee B. Chinn re 1 Complaint, (SG) (Entered: 09/26/2016)

09/23/2016

4 CERTIFICATE OF SERVICE by Shellonnee B. Chinn re 1 Complaint, (SG) (Entered: 09/26/2016)

09/23/2016

3 CERTIFICATE OF SERVICE by Shellonnee B. Chinn re 1 Complaint, (SG) (Entered: 09/26/2016)

09/06/2016

Summons Issued as to Fred Acquavita, Molly Clauss, Andrew Deyell, Sarah Duddy, Jenna Evaldi, Michele Kulpit, Patti Scaffidi, Alyssa Schwabe, The Buffalo Public Schools District, The Elmwood Franklin School, The Elmwood Franklin School Board of Trustees. (SG) (Entered: 09/06/2016)

09/06/2016

Filing fee: $ 400.00, receipt number 52025 (SG) (Entered: 09/06/2016)

11/02/2015

Consent to Proceed Before a Magistrate Judge mailed to plaintiff. (SG) (Entered: 11/02/2015)

10/29/2015

AUTOMATIC REFERRAL to Mediation The ADR Plan was handed to plaintiff at Intake along with List of Mediators and Privacy Notice.(SG) (Entered: 11/02/2015)

10/29/2015

2 MOTION for Leave to Proceed in forma pauperis by Shellonnee B. Chinn.(SG) (Entered: 11/02/2015)

10/29/2015

1 COMPLAINT against Fred Acquavita, Molly Clauss, Andrew Deyell, Sarah Duddy, Jenna Evaldi, Michele Kulpit, Patti Scaffidi, Alyssa Schwabe, The Buffalo Public Schools District, The Elmwood Franklin School, The Elmwood Franklin School Board of Trustees, filed by Shellonnee B. Chinn.(SG) (Entered: 11/02/2015)


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