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Reply Brief 98%

LINDE4AAN CLERK OF SUPREME COURT DEPUTY CLERK/ • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TABLE OF CONTENTS COVER ii TABLE OF CONTENTS TABLE OF AUTHORITIES REPLY 1 Bar Counsel misleads this Honorable Court regarding Kossack's alleged plea 1 The direction of the fact finding hearing changed 1 Kossack never benefitted, knew of, or encouraged any of Michelle's actions which caused one client a $4,000.00 3 Bar Counsel's cited cases are not on point but do suggest Kossack's sanction be less than a suspension 10 No suspension may be imposed absent proof of the concurrence of four Panel members 13 Kossack committed no wrong entrusting Sharon with Michelle's keys 14 The public will not be "protected"


Panama 210 Plaintiff's Response to Defendants' Motion for Attorney Fees re motion to compel sanctions of $2,026.50. 98%

5:11-cv-00032-RS/CJK PLAINTIFF’S RESPONSE TO DEFENDANTS’ MOTION FOR ATTORNEY FES The Plaintiff, Slep-Tone Entertainment Corporation, by its counsel, hereby responds in opposition to the motion (Doc.


Week 2 98%

REPORT #2009-29 THE WHITE HOUSE COUNSEL’S OFFICE MaryAnne Borrelli, Connecticut College Karen Hult, Virginia Polytechnic Institute Nancy Kassop, State University of New York – New Paltz EXECUTIVE SUMMARY Given that the United States of America is governed under the rule of law, and that the President is its elected Chief Magistrate, the role of the White House Counsel’s Office is to maintain the presidency in lawful tension with all other elements, in and out of government.


Manafort Motion to Dismiss 96%

Manafort, Jr., by and through counsel, hereby moves to dismiss the superseding indictment pursuant to Federal Rules of Criminal Procedure 12(b)(2) and 12(b)(3).


w E 18980000 96%



20160706 NOTICE OF HEARING FLD 065180061-1 95%

NOV AR (P66273) Co-Counsel for Plaintiff 117 N.


DHC - 17.05.2016 95%

Mr.Sudhir Nandrajog, Sr.Advocate, with Mr.Rahul Mehra, Standing Counsel.


Panama 181 Order issuing sanctions chiding Harrington 95%

I have previously entered an order requiring payment by plaintiff to Donovan’s Reef, and its attorney, a fee in the amount of $2,026.50 as a sanction for plaintiff’s representative’s failure to provide deposition answers at the express direction of plaintiff’s counsel.


108 - Motion for Sanctions 94%

on Monday, March 26 25th, 2013, or as soon thereafter as counsel may be heard in the above entitled 27 Court, pursuant to 18 U.S.C.


83 - Motion to Enlarge Time 94%

19 20 21 The Plaintiff, Slep-Tone Entertainment Corporation, by its undersigned 22 counsel, hereby moves the Court pursuant to Local Rule 6-1 for an extension of 23 time for the parties to file their proposed discovery plan and scheduling order.


hearing committee-HCJamesQButler31107etal (2) 94%

The Office of Bar Counsel was represented by Deputy Bar Counsel Elizabeth A Herman, Esq.


Agung 1 Asep Rohiman Lesmana 93%

PSIKOPEDAGOGIA ©2015 Universitas Ahmad Dahlan ISSN:


jagex-impsoft 93%

76] of October 14, 2011 since not only were Defendants unaware of the actions taken by Plaintiffs until October 25, 2011 (even though Plaintiffs’ counsel had a duty to inform Defendants’ counsel months earlier), but this is not a discovery dispute, but rather a request for sanctions for violating this Court’s Protective Order and to right the ongoing wrong improperly inflicted upon Defendants.


6acc30b 93%

JSELLECK Communicate(Other Outside Counsel) Billable Converted:


20190903093035.PDF 92%

Crisis Intervention Network: Craig M.


Record Of Proceedings SUPREME COURT 91%

UPON hearing the counsel the Court made the following O R D E R On the last occasion, the Court had noted 7 (seven) conditions which had been taken exception to by Mr.


107 Response to Motion to Reconsider 90%

22 Remarkably, Slep-tone and its Los Angeles-based counsel cannot be 23 24 Slep-Tone and Its Counsels Continue to Flout Local Rules burdened to follow the Local Rules.


GBU Mountain News LV - April 17, 2014 90%

On Tuesday, April 15, 2014, Deputy Counsel Gurujodha S.



STATE OF LOUISIANA COURT OF APPEAL THIRD CIRCUIT P O Box 16577 Lake Charles LA 70616 337 433 9403 Hon Patrick Louis Michot Larry Lane Roy Judge 15th JDC Brown Sims P O Box 3075 600 Jefferson St Lafayette LA 70502 3075 Lafayette LA 70501 Suite 800 Shelton Dennis Blunt Phelps Dunbar P O Box 4412 Baton Rouge LA 70821 4412 NOTICE OF JUDGMENT AND CERTIFICATE OF MAILING May 10 2017 Docket Number CA 16 169 PAT COOPER VERSUS LAFAYETTE PARISH SCHOOL BOARD NOTICE IS HEREBY GIVEN that the attached judgment and written opinion was rendered this date and a copy was mailed to the trial judge all counsel of record and all parties not represented by counsel as listed above FOR THE COURT 1 4AA oft 4 Charles K McNeely Clerk of Court STATE OF LOUISIANA COURT OF APPEAL THIRD CIRCUIT 16 169 Judgment rendered and mailed to all PAT COOPER parties or counsel on May 10 2017 VERSUS Applications for rehearing may be filed within the delays allowed by La Code Civ P art 2166 or La Code Crim P art 922 LAFAYETTE PARISH SCHOOL BOARD APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF LAFAYETTE NO C 20145941 HONORABLE PATRICK L MICHOT DISTRICT JUDGE ON REHEARING VAN H KYZAR JUDGE Court composed of Ulysses Gene Thibodeaux Chief Judge John E Conry and Gl Van H Kyzar Judges J AFFIRMED IN PART REVERSED IN PART RENDERED AND REMANDED L Lane Roy Brown Sims P C 600 Jefferson Street Suite 800 Lafayette LA 70501 337 484 1240 COUNSEL FOR PLAINTIFF APPELLANT Dr Pat Cooper Shelton Dennis Blunt Paul LeBlanc Jack B Stanley Phelps Dunbar LLP P O Box 4412 Baton Rouge LA 70821 4412 225 346 0285 COUNSEL FOR DEFENDANT APPELLEE Lafayette Parish School Board KYZAR Judge This matter is before us on rehearing from our previous decision Lafayette Parish School Board 16 169 La App 3 Cir 11 23 16 Cooper v 207 So 3d 1158 We now affirm the judgment of the lower court in part reverse in part render and remand the matter for proceedings consistent herewith DISCUSSION OF THE RECORD Dr Pat Cooper was hired by the Lafayette Parish School Board Board to a three year System term as superintendent of pursuant to a January 1 the Lafayette Parish School System 2012 written contract School Dr Cooper who has a Ph D in Education and previous experience as a superintendent in both Louisiana and Mississippi experienced was hired based on a five to four vote of the Board and difficulties with the Board from the outset In addition to the already strained relations between them the Louisiana Legislature passed 2012 La Acts I No 1 hereinafter Act 1 boards which totally changed the relationship between school and superintendents of schools in the By the middle of 2014 the state Board who had engaged outside counsel authorized an investigation into actions taken by Dr Cooper which resulted in formal disciplinary charges being levied against him The charges were as follows Charge No 1 Unworthiness Inefficiency Breach of Contract Failure to Comply with Board Policy and State Law relative to Cooper s refusal to comply with or enforce the Board s directive to terminate the of employment Special Assistant to the Superintendent Thad Welch Charge No 2 Unworthiness Inefficiency Breach of Contract Failure to Comply with Board Policy and State Law relative to Cooper s failure to abide by and enforce the Board s amendment of the approved budget to remove the line item authorizing the 2012 La Acts No 1 became effective on July 1 2012 payment of a salary for the special assistant to the superintendent Charge No 3 Inefficiency Breach of Contract Failure to Comply with Board Policy and State Law relative to Cooper directing that public School Board funds be used to pay an attorney Unworthiness that he hired the where purpose of such representation was to advise Dr Cooper regarding a dispute with and a possible action against the School Board Charge No 4 Unworthiness Inefficiency Breach of Contract Failure to Comply with Board Policy and State Law relative to Cooper s action in connection with the payment of select principals in an amount in excess of the Salary Schedule established by the School Board Charge No 5 Unworthiness relative to Cooper receiving a negative evaluation for his job performance for the 2013 2014 school year by a majority vote of the Board Following hearings on November 5 and 6 2014 the Board held that its counsel had proven by a preponderance of the evidence that Dr Cooper was guilty of the facts Proven alleged charge in the first four constituted failure to comply with unworthiness Board policy It further held that the facts of each charges inefficiency and state law by breach Dr Cooper of contract and Thus the Board voted seven to two to terminate Dr Cooper s employment effective immediately on November 6 2014 Dr Cooper immediately sought review of the Board s decision from the Fifteenth Judicial District Court in Lafayette Parish at the conclusion of which the district court rejected three of the four charges relied upon by the Board to terminate Dr Cooper s employment but upheld the Board s decision as to Charge Number Four Following the denial of motions for new trial Dr Cooper appealed 2 Charge Number Five relative to Cooper receiving a negative evaluation failed to receive a two thirds majority of the vote as required by Section 15 D of Cooper s employment contract thus it was not an issue before either the district court or this court 2