I'll be updating the Peggy Petrilli Chronology over the next week or so.
Here are some of the new items:
Aug 22, 2007 – Superintendent Stu Silberman meets BTWA parents
Aug 27, 2007 – Petrilli’s resignation letter states, in its entirety, “I hereby resign my position in the Fayette County Schools.” with no effective date.
Handwritten, with Walther and Allen’s initials – “(3) Ms Petrilli will not apply or employment with Fayette County Schools at any time in the future.”
Aug 28, 2007 Email from Petrilli’s original attorney Jeff Walther to Brenda Allen contains Petrilli’s public statement and this:
“Given that Peggy is still an employee, consider whether the statement ought to be released by the district.”
Dec 19 – Petrilli and attorney Jeff Walther meet with Silberman
Feb 8- Verified Complaint filed
Feb 8 – Judge James D Ishmael randomly assigned to the case
Mar 3 – Answer to Plaintiff’s Complaint
“…Plaintiff was never discharged, or threatened with disciplinary actions, nor forced to resign…”
“Plaintiff made admissions of fact contrary to the legal position she has taken in this litigation on the issue of race discrimination, constructive discharge and/or retaliation…”
Mar 7 – Plaintiff requests production of documents
Mar 21 – Plaintiff served Responses to Requests for admissions
Mar 26 – Letter from McNeill to Golden
Apr 1 – Letter from Thompson to McNeill
Apr 2 – Letter from McNeill to attorney Melissa Thompson (of Golden & Walters)
Apr 22 – Plaintiff Peggy Petrilli’s Answers to Interrogatories and Responses to Requests for Production of Documents
Apr 29 – Plaintiff served Answers to Interrogatories and Requests for Production of documents
Apr 29 – Plaintiff served Supplemental Request for Documents
Apr 30 – Plaintiff asks Defense for Response to Interrogatories…Documents
May 12 – Plaintiff files Motion to Compel
May 12 – Plaintiff asks Leave to File Amended Complaint and “permissive joinder” of Brenda Allen (allege civil conspiracy)
May 14 – Defendants Oppose Motion to Amend
“The plaintiff is attempting to gerrymand history by connecting activities concluding after her resignation from her post in August 2007 as a causal basis for her suit filed in February.”
May 14 – Defendants Reply to Motion to Compel – given volume of requests, requests 30 days after May 16th hearing to comply.
May 15 – Defendants Response in Opposition to Motion to Amend Complaint
May 16- Hearing on Motions
May 19 – Orders issued on Court hearing
Plaintiff’s Motion to Compel SUSTAINED – 30 days after May 16th
Plaintiff’s Motion for Leave to File Amended Complaint SUSTAINED over objection
May 19 - Plaintiff’s First Amended Complaint Filed
“The Defendant [Brenda Allen]’s investigative report, dated April 23, 2008, is evidence of practice, custom and habit of the Fayette County Board of Education.”
“The investigative report…was an attempt by the defendants to manufacture evidence…”
May 20 - Plaintiff served First set of Interrogatories and Requests for Production of Documents on Brenda Allen
May 30 Letter from Thompson to McNeill – Plaintiff’s plan to depose: Stu Silberman, Carmen Coleman, Brenda Allen, Jock Gum, Jessica Berry, Alva Clark, Bob McLaughlin and Alice Weinberg.
June 2 – Defendant’s Motion to Dismiss Claims Raised in Amended Complaint and to Dismiss Brenda Allen as a Defendant
June 2 – Defendant’s Memorandum in Support of Motion to Dismiss Claims Raised in Amended Complaint and to Dismiss Brenda Allen as a Defendant.
“…Brenda Allen…is entitled to immunity in both her official and individual capacities…”
June 5 – Plaintiff’s Response to Defendant’s Motion to Dismiss Claims Raised in Amended Complaint and to Dismiss Brenda Allen as a Defendant
June 6 Hearing
June 9 - Defendant’s Answer to First Amended Complaint
June 9 – Defendant’s Motion to Compel Complete Responses to Requests for Admissions
June 9 – Defendant’s Motion to Compel Full answers to Interrogatories and Request for Production of Documents
June 12 – Plaintiff’s Response to Defendant’s Motion to Compel Full answers to Interrogatories and Request for Production of Documents and Defendant’s Motion to Compel Complete Responses to Requests for Admissions
June 12 - Reply to Plaintiff’s Response to Motion to Compel Full answers to Interrogatories and Request for Production of Documents and Production of Documents and Requests for Admissions
June 13 – Hearing
June 16 – Plaintiff served Supplemental Response to Interrogatory
June 17 – Hearing
June 20 – Letter from Thompson to McNeill
June 26 – Plaintiff’s Second Motion to Compel
July 1 – Defendant, Stu Silberman’s Answers and Responses to Plaintiff’s First Set of Interrogatories and Request for Production of Documents. Responds to discovery
July 3 – Defendant, Carmen Coleman’s Answers and Responses to Plaintiff’s First Set of Interrogatories and Request for Production of Documents.
July 3 - Defendant, Board of Education, Answers and Responses to Plaintiff’s First Set of Interrogatories and Request for Production of Documents. Responds to discovery
July 7 – Motion to Limit Duration of the Plaintiff’s deposition Defendants proposed “an extremely long day.”
Plaintiff’s asked for limitations of “one day of seven hours.”
July 7 – Supplement to Plaintiff’s Second Motion to compel
“Defendant’s answers to this discovery provided the Plaintiff with little to no information about the key events.”
“Defendants have stated that there were threats to picket the school, call the media and report matters to the Kentucky Department of Education.”
July 9 – Defendant’s Response to Plaintiff’s Second Motion to compel
July 9 - Defendant’s Response to Plaintiff’s Motion to Limit Duration of her Discovery Deposition.
July 10 – Defendant’s Response to Plaintiff’s Supplemental Motion to Compel
July 10 - Plaintiff’s Reply to Defendant’s Response to Plaintiff’s Second Motion to Compel
Defense made “no serious attempt to respond…”
July 18 – Plaintiff’s Notice of Cancellation of Videotape Depositions
July 21 – Defendant’s Clarification of Notice of Cancellation
July 23 – Defendant’s Reply and Objection to Plaintiff’s Second Motion and Supplemental to Second Motion and Supplemental to Second Motion to Compel Answers and Interrogatories and Request for Production of Documents.
July 23 – Plaintiff, Peggy Petrilli’s Supplemental Answers to Interrogatories and Responses to Requests for Production of Documents
July 24 – Hearing
July 25 – Notice of Statements Filed Under Seal for In Camera Review
July 30 – Defendant’s Notice of Videotape Deposition and Subpoena Duces Tecum
Petrilli Deposition set for Aug 18, 9 am at Golden’s office
Aug 1 – Notice of videotape Deposition for Stu Silberman with Request for Production of Documents
Silberman deposition set for Aug 28, 9 am, at Golden’s office
Aug 1 - Notice of videotape Deposition for Carmen Coleman with Request for Production of Documents
Coleman deposition set for Aug 27, 9 am, at Golden’s office
Aug 1 - Notice of videotape Deposition for Bob McLaughiln with Request for Production of Documents
Mclaughlin deposition set for Aug 27, 9 am, at Golden’s office
Aug 1 – Notice of videotape Deposition for Jock Gum with Request for Production of Documents
Gum deposition set for Aug 26, 9 am, at Golden’s office
Aug 4 – Plaintiff’s Motion for Reconsideration or, in the Alternative, Motion for Clarification
Aug 5 – Production of Documents Pursuant to Court’s Order
Aug 14 – Defendant’s Response to Plaintiff’s Motion for Reconsideration or, in the Alternative, Motion for Clarification
Aug 14 – Defendant’s Response to Plaintiff’s Production of Documents Pursuant to Court Order Regarding Brenda Allen in her Individual Capacity to dismiss Allen as a Defendant
Aug 15 Hearing
Aug 20 – Defendant’s Notice of completion of Videotape Deposition, Plaintiff, Peggy Petrilli
Aug 21 – Notices of Deposition for Jessica Berry, Alva Clark, Buddy Clark
Aug 22 – Amended Notices of Videotape Deposition and Subpoena Duces Tecum
Alva Clark, Sep 10, 9 am, at Golden’s office
Buddy Clark, Sep 9, 9 am, at Golden’s office
Jessica Berry, Sep 9, 9 am, at Golden’s office
Aug 29 – Defendant’s Notice of Completion of Videotape Deposition of Plaintiff, Peggy Petrilli
Began Aug 18; Continued Aug 26, scheduled to resume Sep 10
Sep 2 – Plaintiff’s Motion for Order, Pursuant to CR 30.04 and CR 37.01 (d), Stopping Any further harassment During Depositions and Motion for Costs.
Sep 2 - Defendant’s Renewed Motion for Summary Judgment on Defamation Claims Against All Defendants
“Petrilli herself also requested the investigation”
Sep 2 – Motion for Summary Judgment on Behalf of Defendant Carmen Coleman in Her Official and Individual CapacitiesSep 4 – Defendant’s Response to Plaintiff’s Motion for Order, Pursuant to CR 30.04 and CR 37.
Sep 5 - Hearing
Judge tells attorneys to behave - gives them five bucks and sends them to get a milk shake.
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