Case 2:12-cv-01319-TFM Document 22 Filed 03/22/13 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA FREEDOM FROM RELIGION FOUNDATION, INC., DOE 1, BY DOE 1S NEXT OF FRIEND AND PARENT, MARIE SCHAUB, WHO ALSO SUES ON HER OWN BEHALF, DOE 2, BY DOE 2S NEXT OF FRIEND AND PARENT DOE 3, WHO ALSO SUES ON DOES OWN BEHALF, vs. Plaintiffs, : : : : : : : : : : : : : : : :

C.A. No. 12-01319

JURY TRIAL DEMANDED

NEW KENSINGTON-ARNOLD SCHOOL DISTRICT, Defendant.

MOTION FOR PROTECTIVE ORDER Defendant, the New Kensington-Arnold School District, by and through its attorneys, Anthony G. Sanchez, Esquire, Amie A. Thompson, Esquire and the law firm of Andrews & Price, file the following Brief in Support of Motion for Protective Order. 1. Plaintiffs Freedom from Religion Foundation, Inc. (FFR), Doe 1, by Doe 1s

next friend and parent, Marie Schaub, who also sues on her own behalf, Doe 2, by Doe 2s next friend and parent Doe 3, who also sues on Doe 3s own behalf, have brought the underlying First Amendment lawsuit against the Defendant New Kensington-Arnold School District (the District). 2. While the District was amenable to the idea of the individually named

Plaintiffs proceeding with pseudonyms and the use of a protective order in general, the District is unable to agree with the unjustifiably restrictive language contained in the Plaintiffs proposed protective order.

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3.

By way of their motion, Plaintiffs seek to limit the Districts ability to gather

information before discovery even ensues. 4. For reasons outlined more fully in Defendant's Brief in Support of Motion for

Protective Order, the District maintains that the Plaintiffs cannot demonstrate good cause for the imposition of their overly broad and unduly harsh proposed protective order. 5. For reasons outlined more fully in the Defendant's Brief in Support of Motion for

Protective Order, the District believes that the individually-named Plaintiffs are adequately protected by the combination of this Court's order permitting the individually-named Plaintiffs to proceed under pseudonyms and the District's proposed protective order. WHEREFORE, for the reasons outlined more fully in Defendant's Brief in Support of Motion for Protective Order, the New Kensington Arnold School District respectfully asks this Court to adopt the Districts proposed protective order. Respectfully submitted, ANDREWS & PRICE By: /s/ Anthony G. Sanchez Anthony G. Sanchez, Esquire PA I.D. #55945 /s/ Amie A. Thompson Amie A. Thompson, Esquire P.A. I.D. #309345 Firm #549 1500 Ardmore Boulevard Suite 506 Pittsburgh, PA 15221 (412) 243-9700 Attorneys for the Defendant