Professional Documents
Culture Documents
2.
Outside counsels engagement letter is enclosed. Outside counsel was initially engaged to
defend the public records lawsuit that Mr. Gray brought against the District. Mr. Gray dismissed that
lawsuit with prejudice on December 4, after being served with a Florida Statute 57.105 frivolous claim
notice. Although not requested, pleadings in that initial lawsuit are enclosed.
3.
I have incurred 9.7 hours through December 9 in connection with the preparation and filing
of the December lawsuit. My firm advanced $453.00 for filing and service fees. Such time and costs
have not been billed and there are no responsive documents.
4.
On December 4, the Superintendent made the decision to file suit against Mr. Gray.
Unfortunately, Mr. Grays dismissal of his lawsuit earlier that day did not mark the end of his
provocative and disruptive actions toward the District. On December 3, the day after the San
Bernandino shootings, Mr. Gray was seen by school officials acting in a suspicious and provocative
manner, cruising in his van slowly back and forth past two schools. On December 4, Mr. Gray
harassed bus drivers for records at a school, just as he had done at the Maintenance Department in
the case he filed and lost. The Superintendent authorized counsel to file suit against Mr. Gray to
enjoin him from continuing to disregard District public records procedures and from continuing to
harass the District and its employees, thereby interfering with employees doing their assigned jobs
and disrupting District operations. The School Board members were individually advised of that
decision before suit was filed on Monday, December 7. There are no responsive documents.