amended federal lawsuit brought by jesse rawls sr. and mark sussman

8/13/2019 Amended Federal Lawsuit Brought by Jesse Rawls Sr. and Mark Sussman

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UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF PENNSYLVANIA

JESSE RAWLS, SR. and : 1:13-CV-02867-JEJ

MARK Y. SUSSMAN :

Plaintiffs, :: (Judge John E. Jones, II

v. :

:

DR. SUSAN KEGERISE, :

Defendant :

AMENDED COMPLAINT

Plaintiffs JESSE RAWLS, SR. and MARK Y. SUSSMAN

(collectively Plaintiffs) hereby bring the following action against DR.

KEGERISE, its superintendent (collectively Defendants) to enjoin De

from violating Plaintiffs rights under the First Amendment to the Unite

Constitutional rights, and in support thereof, aver the following:

INTRODUCTION

1. Plaintiffs file this action because Defendant has systeviolated their rights under the Constitutions of the United States and the

Commonwealth of Pennsylvania.

2. Defendant has violated Plaintiffs rights to free speec

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3. Defendant has violated Plaintiffs rights to perform tconstitutional and statutory duties as elected officials under the Constitu

laws of the United States and Pennsylvania.

4. Plaintiffs ask this Court to uphold Plaintiffs rights uUnited States Constitution and enjoin Defendant from committing acts o

omissions that violate Plaintiffs constitutional or statutory rights.

THE PARTIES

5. Plaintiff Jesse Rawls, Sr. is an elected member of theSusquehanna Township School Board of Directors (Board), resides in

registered to vote in Susquehanna Township, and pays taxes to the Susq

Township School District (STSD).

6. Plaintiff Mark Y. Sussman is an elected member of tresides in and is registered to vote in Susquehanna Township, pays taxe

and is the parent of a student enrolled in STSD.

7. Defendant Dr. Susan Kegerise is employed by the Bsuperintendent of STSD.

JURISDICTION AND VENUE



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9. Additionally, this Court has subject matter jurisdictioto 28 U.S.C. 1343 (a).

10. Venue is proper in this District pursuant to 28 U.S.Cbecause all parties are residents within the Commonwealth of Pennsylva

events giving rise to the claims occurred in this District.

THE FACTS

11. The Board has employed Dr. Kegerise since 2005 assuperintendent and since 2009 as Superintendent of STSD. The Board is

empowered to employ Dr. Kegerise by Sections 508, 1071, and 1073 of

12. On or about May 7, 2013, the Board entered into a nContract with Dr. Kegerise to extend her term as Superintendent four an

years, through June 30, 2017 (Contract). A true and correct copy of th

is appended hereto and incorporated herein as Exhibit A.

13. Article VI of the Contract states that the board retainpower, rights, authority, duties and responsibilities conferred upon a

in each respective partyby the laws and the Constitution of the Com

of Pennsylvania save for any power or rights limited by the expres



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District Superintendent for study, disposition, or recommendation to the

School Directors as appropriate.

15. It is believed and therefore averred that the plain lanSection 4.02 has been interpreted and enforced to prevent and interfere w

direct communication between elected Directors and parents, students, t

residents, and taxpayers.

16. At all times relevant hereto, Jason Kutulakis, Esquireemployed by Dr. Kegerise as her personal attorney, and has acted on he

and with her knowledge and approval.

17. It is believed and therefore averred that between Feband September 2013, Kutulakis attended most, if not all, of the regularly

monthly meetings of the Board. Discovery will show the exact number

Kutulakis attended on Kegerises behalf.

18. At each of the meetings Kutulakis attended, he woulfront row, usually directly across from Plaintiff and Board member Raw

always in direct view of both Plaintiffs.

19. Although public meetings of the School Board are no



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School auditorium due to public interest in a number of issues, includin

related to this litigation.

20. The meeting was attended by a standing-room-only cSTSD stakeholders and other interested people. Nonetheless, Kutulakis

front row directly across from Rawls, Sr. in an apparent attempt to singl

for intimidation.

21. It is believed and therefore averred that Kutulakis attboard meetings in order to intimidate and/or attempt to intimidate Plaint

other Board members from performing their lawful duties as elected off

did so on Dr. Kegerises behalf and with her knowledge and approval.

22. Following certain Board meetings, Kutulakis sentcorrespondence to Plaintiffs Rawls, Sr. and Sussman, and/or Board Pres

Michael Ferguson, in which Kutulakis attempted to interfere with and/o

the lawful duties of the elected Board members including Plaintiffs.

23.

At a public meeting of the Board on January 28, 201

Rawls, Sr. questioned the circumstances related to the hiring of a relativ

Kegerise by STSD.



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25. In correspondence dated February 22, 2013, Kutulakon behalf of and with the knowledge of Dr. Kegerise in his role of perso

attorney, insisted of the Board President that you retract your appointm

special counsel, make a determination that this investigation is fruitless

demand a public apology from Jesse Rawls at the next School Board me

true and correct copy of the Kutulakis correspondence to Ferguson date

22, 2013 is appended hereto and incorporated herein as Exhibit B.

26. Further, Kutulakis stated [p]lease accept this corresas a formal demand to take all actions necessary to support Dr. Kegerise

privately and publicly against the relentless attacks and accusations mad

Rawls.

27. Board President Ferguson emailed Board members, Kegerise, and Blunt, and informed them that in response to an inquiry fr

reporter for the Harrisburg Patriot-Newsreporter about whether the boa

taking any action regarding Dr. Kegerise and Mr. Rawls' allegations, Fe

stated that it would inappropriate for me to say anything. I would impl

do the same. Paul-[Blunt,] please confirm my assessment.



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29. On February 27, 2013, Plaintiff Sussman sent an emKegerise stating I heard that cheerleaders were not at the basketball ga

correct?

30. Several additional emails followed, including one whSussman offered to correspond with Michael Knill, the Susquehanna To

High School athletic director.

31. In correspondence dated March 4, 2013, and directedschool board president, Kutulakis wrote complaining that the Sussman e

violated Dr. Kegerises contract and that Mr. Sussman and Mr. Rawls

interfere with the contractual obligations between the School District an

Kegerise and this must cease immediately. A true and correct copy of t

Kutulakis correspondence to Sussman dated March 4, 2013 is appended

incorporated herein as Exhibit C.

32. In every instance where Kutulakis attempted to interand/or influence Board members or matters, he acted on behalf of Dr. K

with her knowledge and approval.

33. Discovery will show whether other Board members



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34. In an email dated May 18, 2013, Kutulakis wrote Suclaimed that Sussman violated the Contract in part because Sussman sta

private conversations that teachers are afraid and students are out of co

true and correct copy of the Kutulakis email to Sussman dated May 18,

appended hereto and incorporated herein as Exhibit D.

35. Kutulakis further demanded that Sussman immediatethe names of every teacher with whom Sussman spoke.

36. Kutulakis further stated that if Sussman failed to commidnight on Saturday, May 19, 2013

1, litigation would be initiated the f

Monday due to Kutulakis view that Sussman was tortiously interferin

Kegerises Contract.

37. In written correspondence dated May 17, 2013, Kuturepeated the demands and threats made in the email dated May 18, 2013

and correct copy of the Kutulakis correspondence to Sussman dated Ma

is appended hereto and incorporated herein as Exhibit E.2

1May 19, 2013 fell on a Sunday, not a Saturday as stated in the corresp



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38. In both the email dated May 18, 2013, and the writtecorrespondence dated May 17, 2013, Kutulakis insisted that Sussman im

retract in writing the comments made by Sussman and that Kutulakis be

the written correspondence.

39. Kutulakis also demanded that Sussman provide Dr.with a formal written acknowledgment of the very positive role she has

the Districts Superintendent must also occur. Your retraction must occ

midnight, Saturday, May 19, 2013.

40. In correspondence dated March 1, 2013, Kutulakis wRawls, Sr. and complained that Rawls, Sr. indicated he desired to have

personal email made public so residents of the district may communicat

with him about their concerns. All complaints or concerns are required t

provided to the administration, specifically Dr. Kegerise. Again, this is

breach of her contract and must cease immediately. A true and correct

Kutulakis correspondence to Rawls, Sr. dated March 4, 2013 is appende

and incorporated herein as Exhibit F.

41. On March 1, 2013, Kutulakis wrote Sussman essenti



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specifically Dr. Kegerise. Again, this is a material breach of her contrac

cease immediately. A true and correct copy of the Kutulakis correspon

Sussman dated March 1, 2013 is appended hereto and incorporated here

Exhibit G.

42. Rawls, Sr. understood the correspondence of March threaten legal action if he continued to attempt to correspond with STSD

students, teachers, taxpayers, and residents, notwithstanding the fact tha

Sr. wanted to communicate with them and they wanted to communicate

43. Sussman did not know why Kutulakis was writing hiRawls conduct, but he believed that Kutulakis was warning him that he

use his personal email address for communicating with STSD parents, s

teachers, taxpayers, and residents.

44. As personal attorney for Dr. Kegerise, Kutulakis wrorelevant correspondence on her behalf and with her knowledge and appr

45. In late 2012 and early 2013, the Board considered tacommunity survey of STSD stakeholders to assess views on issues relat

STSD.

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instance . . . while a survey permitting input from resmake sense to allow community outreach, it may not

to obtain anonymous allegations into the administratIt may not become an additional tool to conduct a wi

See Exhibits E and F appended hereto.

47. The community survey was never undertaken.48.

It is believed and therefore averred that Discovery w

additional correspondence written by Kutulakis on behalf of and with th

knowledge and approval of Kegerise that serve to violate or attempt to v

recipients constitutional and statutory rights.

49. Plaintiffs do not believe Discovery will show any inswhere STSD Solicitor Blunt responded to Kutulakis in any way about

inappropriate threats of litigation or Kutulakis attempts to interfere with

business or Board members activities on behalf of Dr. Kegerise, an em

the Board.

50. At no time during his representation of STSD has Mexplained to Plaintiffs what activities Board members could engage in th

be constitutionally protected or otherwise protected under the immunity

elected positions.



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52. In email correspondence dated March 20, 2013, and Board members and Dr. Kegerise, Blunt wrote:

I realize that Board members have concerns over theSues attorney has sent them letters. Those concerns

founded. Board members only enjoy the extensive imliability the law provides when they are acting within

as Board members. When they are acting as individunot as members of the Board, they are subject to the

of liability as anyone else. One of the critical issues determining whether a Board member is acting as a B

member is whether their actions are in accordance wadvice of the Solicitor. . . . To put the matter plainly,

protect individual Board members if and when their

authorized by the Board as a whole and if they are wdisavow the unauthorized actions of other Board me

Worse still, I cannot protect innocent Board memberDistrict unless I am allowed to disavow those action

board members] on behalf of the District and Board.

53. In email correspondence dated July 31, 2013, and adBoard members and Dr. Kegerise, Paul Blunt wrote:

It has come to my attention that some of you attendecommunity meeting sponsored and organized by P

Speaks in which the chief topic of discussion was the

effort . . . . While all of you, obviously, have the righ

any meeting you choose, I must again advise that it iadvised to attend such meetings precisely because it the appearance and invites the assumption that you a

representing the Board and District.

54 If t t d t t h id t l t t


C 1 13 02867 JEJ D 10 Fil d 01/21/14 P 13


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55. The official STSD website explains that [w]hen usiemail address, mail is sent to the District's Superintendent, who then for

message to all members of the school board. A member of District Adm

may reply to the sender for additional information or feedback prior to f

to the School Board.

56. Under the single email address scheme, the superintethe absolute discretion to determine when an email will be distributed to

or even ifan email will be disseminated.

57. Plaintiffs have never been shown how to directly accsent to the official school board email address, nor have they been show

send emails from the official address. Plaintiffs are not privy to the acco

information or passwords necessary to access the official account.

58. Plaintiffs are without knowledge as to whether or noBoard members have been shown how to directly access this account or

emails from it.

59. On or about October 1, 2013, Susquehanna TownshiAdam Wiener, an elector, taxpayer, and parent of two children enrolled


C 1 13 02867 JEJ D t 10 Fil d 01/21/14 P 14


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principal at Susquehanna Township High School and an enrolled studen

Sharkey Matter). A true and correct transcription of the Wiener email

referenced here and in the following Paragraphs is appended hereto and

incorporated herein as Exhibit H.

60. The email was addressed to Dr. Kegerise and Schoomembers.

61. On or about October 5, 2013, having received no reseven an acknowledgement of his email dated October 1, 2013, Wiener c

Board members whom he knew personally, Kathy DelGrande and Plain

Sussman.

62. Both Board members told Wiener that the email he sweek prior had not been disseminated to the Board.

63. At no time subsequent to the October 1, 2013, emailmember of the District administration contact Wiener for additional info

feedback prior to sending the email to the Board.

64. Sussman told Wiener several times that Sussman waallowed to discuss the substance of the email.


Case 1:13 cv 02867 JEJ Document 10 Filed 01/21/14 Page 15


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66. Notably, although Mrs. DelGrande said that she couldiscuss confidential information, she was able to discuss generally Wien

concerns and she did not appear to be under the same threat of personal

as Sussman, even though she and Sussman are both elected Board direc

67. Sussman did promise Wiener that he would attempt Wieners email disseminated to the Board.

68. Sussman emailed Dr. Kegerise requesting that Wienwhich was directed to and intended for the Board, be distributed to the B

69. Sussman also verbally requested that Dr. Kegerise dWieners email to the Board.

70. On October 8, 2013, Wiener again sent an email to [email protected],stating in part I was informed that the e

not been sent to the [members] of the board, and I am still unsure if [it]

of today. I have the right to have my question answered. See Exhibit H

hereto.

71. Despite Sussmans email and verbal request to Dr. Kthat she distribute Wieners October 1, 2013, email correspondence to B


mailto:[email protected]:[email protected]:[email protected]


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72. On October 21, 2013, having not received any reply acknowledgement to his two previous emails, Wiener again emailed Dr

and School Board Members, stating: I still have not received a reply fr

any other school board member to my email that was sent on October 1

believe that it is very unprofessional to not even dignify my question wi

response. Is there another avenue I should explore to get a reply[?]

(Emphasis added.)See Exhibit H appended hereto.

73. Finally, on October 25, 2013, STSD Solicitor Blunt rWiener by email, referring to Wieners repeated missives demanding

information.

74. In his reply email, Blunt stated in part: Contrary to the newspaper, the District handled the Sharkey matter exactly as the law

and there were no reports or allegations by anyone to District emplo

any inappropriate relationship between Mr. Sharkey and the allege

(Emphasis added.) See Exhibit H appended hereto.

75. Blunt made this false assertion despite the fact that hpreviously acknowledged in the media that four teachers had reported th



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82. Oddly, the December 17, 2013 asserted without citatsupporting authority that the contents of the letter may not be used in li

except to enforce the directive contained herein. See Exhibit I.

83. On January 10, 2014, Kegerise filed a lawsuit in the Common Pleas for Dauphin County against Plaintiffs Rawls and Sussm

requesting emergency injunctive relief.

84. On January 15, 2014, Plaintiffs removed that lawsuitcourt (docketed in this Honorable Court at 1:14-CV-00067-JEJ).

85. In the state court complaint, Kegerise alleged:Sussman attempted to make service of the Complainthe instant matter] on an assistant district solicitor du

recess of the December 17, 2013 meeting of the SchoSussman dropped the papers on the floor of the men'

while the assistant solicitor was making use of the farequested the papers be picked up.

A true and correct copy of the Complaint seeking injunctive relief is inc

herein and appended hereto as Exhibit J.

86. On January 16, 2014, undersigned counsel spoke in pBrian Taylor, Esq., the assistant district solicitor referenced above.

87 Wh k d b t th t th t S d

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88. It is believed and therefore averred that Kutulakis knincluded false information in that complaint in dereliction of his profess

responsibilities and rules of court.

89. Kegerise signed a verification of the state court compverifying that the statements contained therein were true and correct sub

penalties for unsworn falsification.

90. It is believed and therefore averred that Discovery wnumerous emails written by parents, students, teachers, taxpayers, and r

that were directed to Board members but never forwarded to them by D

COUNT I

Violation of Rights to Free Speech 42 U.S.C. 1983;First Amendment to the United States Constitution

91. The previous paragraphs of the Complaint are incorpreference as if fully set forth herein.

92. Plaintiffs are guaranteed the right to free speech by tAmendment to the United States Constitution.

93. At all times relevant hereto, Plaintiffs have served asmembers of the Susquehanna Township School Board of Directors

g



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95. At all times relevant hereto, Plaintiffs have desired totheir First Amendment rights of free speech in order to communicate wi

parents, students, teachers, taxpayers and residents.

96. At all times relevant hereto, assorted STSD parents, teachers, taxpayers, and residents have desired to communicate with the

School Board members, including Plaintiffs.

97. In addition to examples provided above, discovery wnumerous instances where constitutionally protected free speech has bee

interfered with by Dr. Kegerise directly, on her behalf and/or with her a

98. Under authority invested in Dr. Kegerise by state lawcontract, she had the ability at all times relevant hereto to order constitu

violations be stopped.

99. Instead, Dr. Kegerise allowed or directed that constiviolations continue.

100. Dr. Kegerise is liable for her actions and omissions aactions and omissions of those acting on her behalf, both in her individu

official capacities.



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102. As direct and proximate result of Dr. Kegerises actiinactions, Plaintiffs have incurred attorneys fees and other costs.

COUNT II

Punitive Damages

Plaintiffs v. Dr. Susan Kegerise, in her individual capacit

103. The previous paragraphs of the Complaint are incorpreference as if fully set forth herein.

104. At all times material hereto, Kegerise knew or shoulknown that her conduct, as stated above and as will be further shown in

constituted a violation of Plaintiffs First Amendment rights.

105. Despite this, Kegerise acted willfully, recklessly, andwantonly, either herself or through Kutulakis and others, to deprive the

large and Plaintiffs in particular of their First Amendment rights genera

more specifically as follows:

a. By monitoring correspondence sent to athe Board;



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d. By repeatedly threatening legal action aseveral individuals, including but not limited to Plaintiffs, f

exercising their First Amendment rights;

e. By acting to intimidate individuals, inclnot limited to Plaintiffs, in an attempt to prevent them from

their First Amendment rights; and

f. By punishing or threatening to punish Bmembers including but not limited to Plaintiffs, and other S

stakeholders, for exercising their First Amendment rights.

106. Kegerises continued and persistent violations of PlaFirst Amendment rights constitute reckless, wanton, intentional, and/or

actions.

107. Plaintiffs therefore demand punitive be awarded agaKegerise, in her individual capacity.

PRAYER FOR RELIEF

WHEREFORE the Plaintiffs, Jesse Rawls, Sr. and Mark Y

Sussman demand judgment be entered in their favor against Defendant



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C. Compensatory Relief against the Defendant;D. Punitive damages against the Defendant;E. Attorney fees and costs as authorized by law; and,F. Such other relief as the Court deems necessary and a

The Keisling Law Offices, P.C.

/s/ Bret KeislingBret Keisling, Esquire

Attorney ID #20135217 S. Second Street, Suite 301

Harrisburg, PA 17101(717) 303-3446 (Phone)

(717) 801-1786 (fax)Email:[email protected]

Date: January 21, 2014

mailto:[email protected]:[email protected]:[email protected]:[email protected]


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Certificate of Service

I, Bret Keisling, Esq. certify that on January 21, 2014, the foregoi

Amended Complaint was served on the following parties by electronic m

the addresses listed below:

[email protected]

[email protected]

[email protected]

_______________/s/_______________

Bret Keisling, Esq.

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From: "J kutulakis"

Date: May 18, 2013 7:50 AM

Subject: CommentsTo: "[email protected]"

Cc: "[email protected]"

Mr. Sussman:

I hope that this email finds you well. I am out of town and am unable to develop a fhowever one will follow.

It has been brought to my attention that you have been making comments about the Susquehanna Township School District including but not limited to statements that

are afraid and the students are out of control. I am informed that you specifically in

the administration must go as a result.

I write to formally ask that you immediately provide me the names of the teaches w

you have specifically discussed this matter.

I also write to inform you that I believe you are tortiously interfering with Dr. Kege

with the District. I ask that you immediately retract these statements with whomeve

them and do so in writing, also copying me. I believe an apology to Dr. Kegerise wwritten acknowledgment of the very positive role she has played as the District's Su

must also occur. Your retraction must occur by midnight, Saturday, May 19th.

If you are unable and unwilling to follow these requests, I will be taking swift legal

Monday. If you have retained independent legal counsel, please forward this imme

attorney and provide me his/her contact information. I am copying Solicitor Blunt oprofessional courtesy, but do not believe his capacity as the Solicitor covers your co

appears you are acting independent of the Board on this matter. I will defer to him

capacity of his representation of you.

I want to be crystal clear. I have individuals who have provided very specific inform

what you have said to them. It is unconscionable to knowingly make such blatantlystatements about the Districts outstanding administration. Your failure to correct thby day's end will undoubtedly result a a legal battle.

Thank you in anticipation of you prompt attention to this matter.

mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]


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From:Adam [email protected]

To: "[email protected]"



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@ g @ gSent:Tuesday, October 1, 2013 8:20 AMSubject:student safety

Dr . Keger i se and School Boar d Member s:

My name i s Adam Wi ener . I am t he parent of t wo st udent s di st r i ct . My son i s i n 5t h gr ade and my daught er i s on 2wr i t i ng t o you out of gr ave concer n not onl y f or my chi lbut al l of t he chi l dr en i n our school s. My concer n i s r et he r ecent char ges f i l ed agai nst Mr . Shar key, speci f i cal

handl i ng of t he i ssue by t he admi ni st r at i on. Ar e t her e pput t he admi ni st r at or s who ar e cur r ent l y the subj ect of i nvest i gat i on on l eave pendi ng t he out come of t he i nvestI f not , pl ease expl ai n why.

Thank you,

Adam Wiener

On Tuesday, October 8, 2013 11:04 AM, Adam < [email protected]> wrote:Dr . Keger i se and School Boar d Member s:Pl ease see my emai l bel ow t hat was sent on Oct ober 1st . t ol d by Dr . Keger i se t hat eveni ng t hat my emai l woul d bet he school boar d. I was i nf ormed t hat t he e- mai l had nobeen sent t o t he memeber s of t he boar d, and I am st i l l ui f i s has been as of t oday. I have t he r i ght t o have myquest i on answer ed. These t ypes of act i ons ar e what per pet he bel i ef t hat t he admi ni st r at i on wi l l not answer questor even respond to ver y i mpor t ant i ssues.

Thank YouAdam Wi ener

From:Adam


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p g p yThank you,

Adam Wi ener

On Oct 25, 2013, at 7:45 AM, Paul Blunt wrote:

Mr . Wi ener :

I am t he sol i ci t or f or t he Susquehanna Townshi p SchoolDi st r i ct . I n r esponse t o your r epeat ed mi ssi ves demandii nf or mat i on r egar di ng t he Di st r i ct admi ni st r at or s, pl easadvi sed of t he f ol l owi ng:

1. Per sonnel mat t er s ar e not publ i c i nf or mat i on and so ni nf or mat i on wi l l be pr ovi ded r egar di ng any Di st r i ct empl

2. Your demand appear s t o be based on some i naccur at e f a

and l egal assumpt i ons. Cont r ary to r eport s by t he newspaDi st r i ct handl ed t he Shar key mat t er exact l y as t he l aw rand t her e wer e no r epor t s or al l egat i ons by anyone t o Diempl oyees of any i nappr opr i at e r el at i onshi p bet ween Mr . and t he al l eged vi ct i m.

3. Per a request by t he DA, we can gi ve you no f ur t heri nf or mat i on regar di ng the mat t er .

Paul K. Bl unt , Esq.

From:[email protected]

Date:October 25, 2013 at 11:54:09 AM EDT

To:Paul Blunt

Cc:Michael Ferguson , "[email protected]"

Subject:Re:

Mr . Bl unt :Thank you f or r espondi ng t o my emai l . I woul d l i ke t o cf ew t hi ngs based on your r esponse. I n addi t i on your r es

I don' t bel i eve t hat t he saf et y of our chi l dr en i s a peri ssue. We may have t o di sagr ee on t hi s mat t er , but my t



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ar e that i f someone i s bei ng i nvest i gat ed on how a si t ua

handl ed ( agai n- not sayi ng t hey ar e gui l t y of any wr ongdI t woul d make sense, t o me, t hat person shoul d not be puposi t i on t o st i l l be r esponsi bl e f or t he same dut y t hat i nvest i gat ed.Gi ven t he f act s t hat your t hi r d bul l et poi nt may, i n youopi ni on, pr ecl ude you f r om r espondi ng t o me, and t he f aci t t ook t hr ee weeks and t hr ee emai l s f or an i ni t i al r espexpect at i ons f or a r epl y ar e l ow. However , I do appr eci

f act t hat my concer n was at l east gi ven t he r equi r edat t ent i on.

Thank youAdam Wi ener



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amended federal lawsuit brought by jesse rawls sr. and mark sussman

Documents