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IN THE SIXTH JUDICIAL CIRCUIT COURT OF MARYLAND FOR MONTGOMERY COUNTY 50 MARYLAND AVE. ROCKVILLE.

MD 20850 SCOTT SHIRLEY, Plaintiff,
VS.

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MOTIONFOREMERGE}\iCY PRELIMINARY INJTINCTIVE RELIEF

ERICHECKMAN,RFL PRESIDENT, ROCr(VLLE FOOTBALLLEAGTJE BOARDOF DTRECTORS
Defendants

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MqTION,FOR,pMERGEIICY PRETJMTNARYTNJTJNCTTVE RSLTEF

Plaintiff ScottShirleyherebysubmits preliminaryinjunctiverelief motionfor emergency enjoining Defendants the from punitiveactions takenagainst Plaintiff asthe resultof false accusations against Plaintiff. Plaintiff furtherasserts Defendants not follow proper did coaches reviewprocedures outlinedin the RockvilleFootballLeague as (RFL) Rules.

1. Plaintiff would prevailin overtuming punitiveactions Defendants any giventhe by properopportunity present to multiplewitness testimony evidence behalfof and on Plaintiff. 2. Plaintiff wasnotifiedby e-mailat l0:2QPM on November18,2009that he was suspended from coaching dutiesof his 8-10yearold footballplayersdueto falseallegations beingverballyabusive, of usingfoul language acting and aggressively towardsanother volunteer adultduringa youth footballgame.

3. Allegations Defendant Defendants by or haveno merit andPlaintiff hasmultiple testimonies bystanders testifuthatno suchincidenteveroccurred. of to 4. Defendant's claim of league commissionsr's confirmation improperbehavior to by Plaintiff in the Defendant's suspension decision false. League is commissioner denies confirmingPlaintiff actedinappropriately supported writing by as in commissioner. 5. Plaintiff wasneverwamedby Defendants alleged of violationof behavior.A which is outlinedin the RFL ruleswhich werecreated Defendants Procedure bv and previousRFL Boardmembers beforethem. 6. Defendants specificallyaddressed allegations against Plaintiff at a RFL Board meetingon November18,2009withoutanynotificationto Plaintiff denyingPlaintiff
an opportunityto due process.

procedures the ooRFL 7. Defendant's violatedandignoredseveral of Coaches Review" procedures presented Plaintiffand all othervolunteer as to coaches the throughout RFL on the defendant's website. 8. Plaintiff s youth footballteamplaysin the MarylandStateChampionship Sunday, on December 13,2009andthe allegations the defendants by leadingto the suspension would greatlyimposea hardship uponthekids andtheir familiesby hinderingthe children'sperformance the gamewithouttheplaintiff who is their offensive in coordinator hascoached and themfor the pastten games.

9. Plaintiff hascoached the RFL sincethe year2000asan assistant headcoach. in and

preliminaryinjunctiverelief in THEREFORE, Plaintiff asksthe courtto grantemergency this matter,

Respectfully submitted,

r"L\\o\zc bq,
ScottAlan hirley
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