Complaints, Pleadings & Motions

Brief on Motion to Proceed using Pseudonym – Child Pornography

• Minnesota

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Brief in Opposition of Summary Judgment – Student on Student – Actual Knowledge of Harassment

• Ohio

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Amended Complaint against School District & Student Perpetrators/Parents

• Massachusetts

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2019- CSA – Closing Argument

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2016 IL App Opinion (Carlson v. Jerousek) – reversing grant of broad discovery; privacy PC data; Issue – circumstances under which a party to a civil suit may inspect the contents of another person’s computer through forensic imaging, seeking metadata and other information; holding: request was contrary to discovery protocol, information sough was not clearly specified and the probative value of that information was questionable while the burden to plaintiff’s privacy interest was significant, and there were ample avenues open to defendants to discovery the info they sought without granting them broad access to plaintiff’s computers

• Illinois

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