IN THE UNITED STATES DISTRICT COURTFOR THE WESTERN DISTRICT OF PENNSYLVANIA
FREEDOM FROM RELIGIONFOUNDATION, INC., DOE 1, BY DOE 1’S NEXT OF FRIEND AND PARENT,MARIE SCHAUB, WHO ALSO SUES ONHER OWN BEHALF, DOE 2, BY DOE 2’S NEXT OF FRIEND AND PARENT DOE 3,WHO ALSO SUES ON DOE’S OWNBEHALF,Plaintiffs,vs. NEW KENSINGTON-ARNOLD SCHOOLDISTRICT,Defendant.::::::::::::::::C.A. No. 12-01319JURY TRIAL DEMANDED
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 1’snext friend and parent, Marie Schaub, who also sues on her own behalf, Doe 2, by Doe 2’s nextfriend and parent Doe 3, who also sues on Doe 3’s own behalf, have brought the underlying FirstAmendment lawsuit against the Defendant New Kensington-Arnold School District (“theDistrict”).2. While the District was amenable to the idea of the individually namedPlaintiffs proceeding with pseudonyms and the use of a protective order in general, the District isunable to agree with the unjustifiably restrictive language contained in the Plaintiff’s proposed protective order.
Case 2:12-cv-01319-TFM Document 22 Filed 03/22/13 Page 1 of 2