The Daniels' Family vs. Putnam City School District

J/
JS44 (Rev. 06/17) CIVIL COVER SHEET
The JS 44 civil cover sheet court. and the This information form, approved contained by the herein Judicial neither Conference replace nor of supplement the United States
the filing in September and service 1974, of pleadings is required or for other the papers use of as the required Clerk of by Court law, for except the as provided by local
rules of purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
1. (a) PLAINTIFFS DEFENDANTS
Adam Daniels and Kelsey Daniels, individually and next of friend of Putnam City Sch. Dist., Overholser Elem. Sch. and Putnam City Sch.
C.D.D., M.K.D. and A.A.D. Bd.
(b) County of Residence of First Listed Plaintiff Oklahoma County of Residence of First Listed Defendant Oklahoma
(IN U.s. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE
(EXCEPT IN U.s. PLAINTIFF CASES) TRACT OF LAND INVOLVED.
Attor
Jefshy and Telephone Ntunber) Laura L. Holmgren-Ganz, Ctr. for Educ. Law, P.C.
620 N. Robinson, ste. 201 ,0kla. City, 0K 73102 920 N. Broadway, Ste. 300, Okla. City, 0K 73102
(405) 606-8400 (405) 528-2800
11. BASIS OF (Place an one Bo.vonly) 111. CITIZENSHIP OF PRINCIPAL PARTIES (Place an in one
JURISDICTION Federal Question (For Diversity Cases Only) and One Bo.vJbr Defendant)
(U.S. Govermnent Not a Party) PTF DEF PTF DEF
U.S. Government Citizen of This state Incorporated or Principal Place of Business In This State
Plaintiff
Diversity Citizen of Another State Incorporated and Principal Place of Business In Another
(Indicate Citizenship ofParties in Item Ill) State
U.S. Government
Citizen or Subject of a n3 Foreign Nation
Foreign Count
IV. NATURE OF SUIT (Place an one Click here for: Nature of Suit Code Descriptions.
TORTS FORFEITURE/PENALTY BANKRUPTCY
CONTRACT OTHER STATUTES
PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure D 422 Appeal 28 USC 158 0 375 False Claims Aet
O 1 10 Insurance
310 Airplane 0 365 Personal Injury of Property 21 USC
O 423 Withdrawal 0 376 Qui Tam (31 USC
O 120 Marine 881
315 Airplane Product Product Liability 28 USC 157 3729(a)) D 400 State
D 130 Miller Act -7 69() Other Reapportionment
Liability 0 367 Health care/
O 140 Negotiable Instnlment 0 410 Antitrust
320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS
O 150 Recovery or Overpaytnent D 430 Banks and Banking
Slander Personal Injury a 330 Federal
& Enforcement of D 82() Copyrights
Employers' Product Liability 450 Commerce
Judgment n 830 Patent
Liability 0 368 Asbestos Personal
151 Medicare Act D 835 Patent - Abbreviated 0 460 Deportation
340 Marine Injury Product
New Drug Application 0 470 Racketeer Influenced and
O 152 Recovery of Defaulted -7 345 Marine Product Liability
Student Loans D 840 Trademark Corrupt Organizations
Liability PERSONAL PROPERTY
(Excludes Veterans) 350 Motor Vehicle 0 370 Other Fraud D 480 Consumer Credit
LABOR SOCIAL SECURITY
D 153 Recovery of Overpayment 355 Motor Vehicle 0 371 Truth in Lending Product D 490 Cable/Sat TV
710 Fair Labor Standards 0 861 HIA (1395fO
of Veteran's Benefits Liability 0 380 Other Personal O 850 Securities/Conunodities/
Act 0 862 Black Lung (923)
360 Other Personal Property Damage Exchangc
O 160 Stockholders' Suits 720 Labor/Management 0 863 DIWC/DIWW (405(g))
D 1 90 Other Contract Injury 0 385 Property Datnage Relations 0 864 SSID Title XVI D O 890 Other Statutory Actions
362 Personal Injury - Product Liability
D 1 95 Contract Product Liability 740 Railway Labor Act n 865 RSI (405(g)) D 891 Agricultural Acts
Medical Mal ractice 751 Family and Medical
D 196 Franchise Leave Act
893 Environmental Matters
790 Other Labor Litigation O 895 Freedom of Information

FEDERAL TAX Act
791 Employec Retirement
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS Income Security Act D 896 Arbitration
X 440 Other Civil Rights Habeas Corpus: 0 463 suns O 899 Administrative Procedure
D 210 Land Condemnation Alien Detainee n 510 D 870 Taxes (U.s. Plaintiff Act/Review or Appeal of
441 voting Motions to Vacate or Detzndant) n 871 IRS
O 220 Foreclosure Agency Decision
442 Employment Sentence Third Party
230 Rent Lease & Ejectment IMMIGRATION
443 Housing/ D 530 General 26 USC 7609 D 950 Constitutionality of
0 240 Torts to Land Accommodations State Statutes
D 245 Tort Product Liability D 535 Death Penalty
D 445 Amer. w/Disabilities 462 Naturalization Application
D 290 All Other Real Property Other: 465 Other Immigration
Employment 0 540 Mandamus & Other n Actions
446 Amer. w/Disabilities 550 Civil Rights
Other 0 555 Prison Condition
448 Education 0 560 Civil Detainee
Conditions of
Confinement
V. ORIGIN in one only)
DI
Original Remanded from D 4 Reinstated or Multidistrict D 8 Multidistrict
X 2 Removed from 0 5 Transferred from
Proceeding State Court Appellate Court Reopened Another District Litigation Litigation
(spec!f.r) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do nor citejurisdictional statutes unless diversity):
VI. CAUSE OF ACTION 42 U.S.C. 1983
Brief description of cause:
De rivation of religious freedom and unreasonable search
Vll. REQUESTED IN O CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. 300,000.00 JURY DEMAND:
Vlll. RELATED CASE(S)
IF ANY (See instructions): JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
09/11/2017 s/Laura L. Holmgren - Ganz
FOR OFFICE USE ONLY
RECEIPT AMOUNT APPLYING IFP JUDGE MAG. JUDGE
IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF OKLAHOMA
ADAM DANIELS and

KELSEY DANIELS, individually and as parents and
next friend of C.D.D., M.K.D., and
A. A. D., minor children ) State Case No. CJ-2017-
) 4751
Plaintiffs, -
vs-
INDEPENDENT SCHOOL DISTRICT, ) Case No. CIV-17-

NO. (0-001) OF OKLAHOMA COUNTY
OKLAHOMA, a political subdivision of
The State of Oklahoma, a/k/a
PUTNAM CITY SCHOOLS,
OVERHOLSER ELEMENTARY SCHOOL a/k/a
Independent School No. 126,
PUTNAM CITY SCHOOL BOARD
Defendants.
NOTICE OF REMOVAL
Defendants, Independent School District No. (0-001) ofOklahoma County,Oklahoma,
a/k/a Putnam City Schools ("District"), Overholser Elementary School a/k/a Independent
School No. 126 ("Overholser"), Putnam City School Board ("Board"), hereby give notice to
all parties that this action is removed from the District Court ofOklahoma County,
Oklahoma
of Removal.wpd
to the United States District Court for the Western District of Oklahoma, Pursuant to 28
U.S.C. S 1446(a) and (b), Federal Rules of Civil Procedure 81 (c), and Local Civil Rule
81.2.
In support of removal, Defendants submit the following:
1. On August 21, 2017, Plaintiffs filed suit against Defendants in the District
Court of Oklahoma County, Oklahoma, alleging defamation, negligence, and violation of
Plaintiffs' rights under 42 U.S.C. 51983 for deprivation of Plaintiffs' First and Fourth
19.
2. Defendants were served with a summons on August 21, 2017. Exhibit 2
Summons.
3. Pursuant to Local Rule 81.2, a copy of the state district court docket sheet is
attached. Exhibit 3 - District Court Docket Sheet.
4. There are no motions currently pending in the state court action. Exhibit 3.
5. Jurisdiction and venue are proper in this Court pursuant to 28 U.S.C. 133 1,
1367, 1391 (b) and 1446(b) since Plaintiffs' Petition concerns federal questions arising
under
42 U.S.C. 51983 and the site of the alleged incident and location of Defendants are within
7. The undersigned counsel of record affirmatively represents that a copy of this
Notice is contemporaneously served on the Court Clerk for the District of Oklahoma
County pursuant to 28 U.S.C.
of Removal.wpd
G
S/Laura L. Holmgren-Ganz
Laura L. Holmes, OBA #14748
Laura L. Holmgren-Ganz, OBA #12342
Attorney For Defendants
The Center For Education Law, P.C.
900 N. Broadway, Suite 300
Oklahoma City, OK 73102
Telephone: (405) 528-2800
Facsimile: (405) 528-5800
E-mail: Ll-lolmes@cfel.com
E-mail: LGanz@i)cfel.com
Certificate of Service
I hereby certify that on September I l , 2017 1 electronically transmitted the

attached document to the Clerk of the Court using the ECF system for filing and
transmittal of a Notice of Electronic filing to the following registrants: Jeramy W.
Jarman.
Laura L. Holmgren-Ganz
of Removal.wpd
m THE DISTRICT COURT OF OKLAHOMA c0U14TLYED IN CO(JRT
OKLAHOMA COUNTY
AUG
ADAM DANIELS and
KELSEY DANELS, individuallyRICK WARREN and as parents and next friend ofCOURT
CLERK
40
and minor
children
Plaintiff,
) - 47 51
NDEPENDENT SCHOOL DISTRICT.,
NO. (0-001) OF OKLAHOMA COUNTY ) OKLAHOMA,
a political subdivision of
The state of Oklahoma, a.k.a.
OVERHOLSER ELEVENTARY SCHOOL,)
a.k.a. Independent School No. 126,
PUTNANBI CITY SCHOOL BOARD
Defendant(s).
PETITION
coryms NOW the Plaintiff(s), ADAM DANELS and KELSEY DANIELS,
individually and as the parents and next friend of C.
D, and A , minor children, for their cause of against
Defendant(s) alleges and states as follows:
1. Plaintiffs are currently and were, at the time of the actions giving rise to this
litigation, residents of Oklahoma County, State of Oklahoma.
2. Defendant, Independent School Dis&ict No. (1-001) of Oklahoma County, Oklahoma,
Pumam City Schools, Overholser Elementary School a.k.a. Independent School

Exhibit No. I
Disfrict No. 126, and Putnam City School Board, (hereinafter referred to as the
"District"), is a political subdivision of the State of Oklahoma and operates
public schools in Oklahoma County, Oklahoma.
3. The Defendant, District, is a public school conducting business in Oklahoma County,
State of Oklahoma, and may be served with process upon its Board Clerk;
5401 Northwest 40th Street, Warr Acres, Oklahoma 73122-3302. Therefore,
venue is proper in Oklahoma County.
4. The Dist-ict employs administators, teachers, school nurses and other support staff and
is responsible for the acts and omissions of these employees acting within the scope of
their employment.
5. This Petition is brought pursuant to the Oklahoma Governmental Tort Claim Act, Title 51
Okla. 151 et seq (the Act). The notice required by the Act was served on Defendants,
Distict, on or about April 3, 2017, (copy of notice and certified mail green cards attached
as Exhibit "A"). Defendants failed to respond giving rise to this action.
STATENENT OF FACTS
Over a period of years the and their children above named have been subjected to repeated false
allegaons as well as treamlent that no child should be subjected to at the hand of the staff of Putman
City Schools, yet especially children with the limitations of the children involved herein. lhe Putnam City
School District, (The District) through its agents and various schools have systemacally subjected the
Defendants to undue allegations and scrutiny using the Department of Human Services, a state Agency
of this great state. Further, the District has taken an adversarial stance toward the Parents of these children
based largely on the fact that the Parents practice an alternative religion which is a violation ofthe Civil
Rights of the Plaintiffs.

During this same timeframe, the children above named were subjected to varied levels of abusive
and negligent acts of the Distict staff teachers and nurses to include the administrators and principles of
those schools. In fact, the Parent Plaintiffs were subjected to approximately forty (40) visits from DHS
Child Pmtecdve Services over a period of years, most of which were based on falsified allegations
purported by the District personnel. This, the Plaintiffs allege was retaliation for the complaints made
against the school at different times over the years. In addition, these DHS referrals were a result of flie
Plaintiffs pracdcing an alterave non-Christian based a fact the
Distict was well aware of. The Plaintiffs participate in and began the local charter of Dakhma Of
Anramainyu and Adam Daniels is the Dastur, which is the Lead Minister of this Religious Group. Facts
which the Disict became aware of in 2013 when this charter was created and recognized by the
Oklahoma and United States Government as a Church or Religion. More specifically the facts are:
6. On or about April of 2016 it was discovered that M who is profoundly autistic and mute had
been subjected to repeated stip searches at the hands of the school nurse from Western Oaks
Middle school and Lake Park Elementary. Such acts were discovered during an
Individualized Education Plan evaluaon conducted by the Nurse at Putnam City West High
School when M began attendance there. There had pzeviously been allegaons against the
District Nurse by Plainffs in the years prior. However, any wrongdoing was denied. Only
in April of 2017 was it discovered, through the acons of M , who is mute, that she had been
subjected to repeated stip searches at the hands of the nurse over a period of years. It is
believed by the Plaintiffs that these facts were never reported to DHS Child Protecfr.ze
Services by the nurse at Putnam City High School which is required by law.
7. On Or about April and May of 2017 it was discovered that C D had been
subjected to abusive and harassing acts at the hands of her teacher and students with the
acquiescence of the teacher. It was discovered that C , who is autistic, was subjected to video
and audio media by both the teacher and other students over a period of weeks which caused
C to react in outbursts of self-harm and physical aggression that the teacher knew should be
avoided. C was subjected to her own fears and would in turn tear her clothes off and/or striker
herself or objects repeatedly in several separate incidents. One in which she severely injured
her hand. Other injuries have also occurred and each me the reason for those injuries are
simply not lcnown by the teacher charged with supervising C . that were initiated by the
teacher and other students under supervision ofthe teacher.
8. Near the end of January 2017, DHS Child Protective Services were yet again contacted by
the District Defendant personnel in an effort to smear the reputation ofthe Plaintiffs and as
retaliation for the complaints of the Plaintiffs against the District. During that investigaon,
the Plainffs were visited for the what is estimated to be 40fr visit from DHS caused by
allegaons against them at the hands of the District. Also during that investigation it was
proffered by the DHS caseworker that it is possible that the District was using DHS simply
to retaliate against the Plainffs. However, DHS has never provided any documentation for
many ofthese investigaons. These visits were conducted over a period of years only to
crescendo in 2016 after the above referenced discovery of abuse against M D The choice of
religion is also frequently brought up during interviews and is information passed on to DHS
from the Disfrict.
9. On or about Janurary of 2015, M D received a fractured ankle which required medical care
and surgery. The cause of the injury was never clearly idenffed by the District.
Several accounts that vary from one another were provided at the frne by the District
personnel. However, the attending Physician specifically mendoned the location of the
fracture was the result of massive force not likely caused by a simple frip over an item as
was stated by the District To this day, Plaintiffs are sll not frilly aware of what caused such
a severe injury to their Daughter. Additionally, following the injury faculty and staff failed
to provide immediate and proper care for the injury sustained.

COUNT 1 DEFAMATION
10: The Disfrict has persecuted with impunity the Daniels family and directed undue scrutiny on
them as a result of an alternative religion shown above. The Dist-ict has systemically and through its
agents over a period of years made allegaffons against the Plaintiffs using the Departnent of Human
Services via their Child Protecff,re Services division as a weapon of convenience against them. DHS has
been contacted by the school and personnel have approached the Plaindffs home where they conducted
interviews and on more than 30 occasions since 2013. The most recent of which was just
in February of 2017 when yet another was initiated at the hands of Puma.m City Schools.
The District has operated in unison with its Adminisfration, Teachers, and Principals in several different
schools spanning a of several years to pervasively pursue false or misleading claims against the
Pefioners directly related to their choice of religious practice resulting in damage to the stance in the
community as well as their business which happens to be a Church called Dakhma of Angra Mainyu. Mr.
Daniels is a published Author and leader of the chuNh. The constant brage of complaints and
circulafing rumors perpefrated by the Dis&ict has affected the income and stance ofthe Plaintiffs
substantially.
COUNT 11 - 1983 VIOLATIONS
11. Plainff incorporates the facts and allegations above and further states that the Defendants
have violated the Civil Rights of both the children and parent Plaintiffs in confradiction of 42 U.S. Code
1983 et seq. M D is a student at Putnam City West High School. M has severe Autism and is mute. Mr.
and Mrs. Daniels, The Plaintiffs here, had suspicions of neglect and abuse to include stip searches at the
hands of the school nurse while the child attended Western Oaks Middle School. lhe Plainffs reported
said allegations to the YEP Insfructor as well as the Principle of that school only to be reported to DHS
as menfioned above themselves. On or about mid April 2016, Mr.

and Mrs. Daniels were advised that their daughter was exhibiting a suspect behavior during an EP
evaluation. During that evaluaon, conducted by the nurse of Putnam City West High School, M
undressed herself without prompdng, as she was "accustomed to doing," according to the nurse. Nurse
met with the and the nurse was informed that this behavior was out of character and was a result of the
repeated st-ip searches at the hands of the prior school nurse. The Nurse did not report the allegation to
the of Human Services Child Protecve Services as required by law. Additionally, the
Principal and Administration of Western Oaks also never reported the aberrant behavior. It should be
noted, M was subjected to such acts simply because of her state as disabled and lus no ability complain
to others. The Plaintiffs had been berated with complaints as retaliafion for any remark made to the
contary of the wishes of the Dist-ict agents who worked together to insulate each other from liability to
the detriment ofdlis child and the Plaintiffs.
12. The Parent Plainfffs were subjected to repeated of neglect and abuse at the hands
of the District personnel. As mentioned, over a period of years to include early 2017, the
Dist-ict leveled allegations against the Plainffs in part as a result of retaliation and in part as a result of
their choice of religion. The District made comments frequently conceming the alternative pracces of
the Plaintiffs and the District passed on informafion to DHS during their referrals regarding the Plaintiffs
choice of religion. Even going so far as to allege or inquire as to whether the parties maintain a "dungeon".
This retaliation and mistreatnent based solely on the choice of religious practices has resulted in losses
both financial and emotional to the parties involved. The acts of the Districts personnel are the proximate
cause of cause ofthe losses sustained and repeated home visits by DHS.
13. Defendants also violated the Plainfiffs rights under 42 U.S.C. 1983 by retaliating against the
Plainfiffs and failing to provide protection of the Children Plaindffs from bullying and mistreatment at
the hands of students and teachers as described above. Plaintiffs complained of the lack of supervision
and the overt acts of Dist-ict Personnel and yet the mistreatment connued even drawing retaliation from
the Distict against the Plaintiffs which established a custom of disregarding complaints made by the
Plainffs and discouraged futher complaints from the Plaintiffs.
14. The acts and omissions of the Defendants caused the proximate injuries to and misfreatment
of the children Plaintiffs and severe emotional harm and physical harm as well as financial to the Parent
Plainffffs herein to include medical expenses, permanent injuries, scaring and continuing emotional as
well as physical pain and suffering.
COUNT m NEGLIGENCE
15. Plaintiff incorporates the facts and allegadons above and further states that the Defendant was
negligent in providing a safe environment for the minor children and in protecting the children from
foreseeable harm after repeated complaints of such acts or omissions by its agents clearly placing the
District on noce of such negligent acts.
17. Defendants were negligent in providing and rendering appropriate care and treament to the
minor children either causing injuries to the children or after an injury occurred.
18. The Defendants were negligent in supervising and retaining teachers and staff capable of
fulfilling the schools duty of the students from harm. The Defendant District was also negligent in
performing a&ns necessary to enforce or carry out school policies or customs regarding protecting the
children from harassment, bullying, and harm to the children.
19. Due to the Negligence of the Administation, Faculty and Staff of several Pumam City
Schools and the Putnam City School District, the have suffered vast financial losses as well as physical
and emofional harm as mentioned above. The aforementioned Putnam City actors have demonstrated
complete disregard for the safety and welfare of M and C and have systematically persecuted the Plaindffs
based primarily on their beliefs.
WFEREFORE, Plaintiffs respectfully requests judgnent against the Defendant,
Disfrict, for an amount in excess of the amount required for diversity jurisdiction pursuant to
Section 1332 of Title 28 of the United States Code, but not less than $300,000.00 along with
costs, interest, attorney fees, and any other further relief to which they may be entitled.
Re ctfully submitted,
ARMAN
LAW OFFICES JERAMY JARMAN P.c.
620 N. Robinson Suite 201
Oklahoma City, Oklahoma 73102
Telephone: (405) 606-8400
Facsimile: (405) 601-0338
JeramyJarman@gmail.com
Attorneyfor Plaintiff
ATTORNEYLIEN CLAIID
IN THE DISTRICT COURT OF OKLAHOMA COUNTY
STATE OF OKLAHOMA
ADAM DANIELS and
KELSEY DANIELS, individually and as
Darents and next friend of
c I), D
M D and
minor children
Plaintiff,
INDEPENDENT SCHOOL DISTRICT., 2017- 4751

OKLAHOMA, a political subdivision of
The state of Oklahoma, a.k.a.
OVERHOLSER ELEMENTARY
SCHOOL,)
a.k.a. Independent School No. 126,
PUTNAMN CITY SCHOOL BOARD
Defendant(s).
SUMMONS
TO THE ABOVE NAMED DEFENDANT(S): INDEPENDENT SCHOOL
DISTRICT, NO. (0-001) OF OKLAHOMA COUNTY COUNTY,
OKLAHOMA, PUTNAM CITY SCHOOLS, OVERHOLDER ELEMENTARY
SCHOOL, a.k.a., Independent School No. 126, PUTNAMN CITY SCHOOL
BOARD.
You have been sued by the above named Plaintiff, and you are directed to file a written Response to
the attached Petition in the court at the above address within twenty (20) days after service of this
Summons upon you, exclusive of the day of service. Within the same time, a copy of your Response
must be delivered or mailed to the attorney for the Plaintiff.
Unless you respond to the Petition within the time stated, judgment will be rendered against
you for the relief demanded in the Motion, together with the costs of the action.
Issued on August Q, 2017.

[SEAL]
Jeramy Jarman OBA #20508
620 N. Robinson Ave., Ste. 201
Telephone (405) 601-7206
Fax (405) 601-0338
Exhibit No. 2
Attorney for Petitioner
YOU MAY SEEK THE ADVICE OF ANY ATTORNEY ON ANY MATTER CONNECTED WITH THIS
SUIT OR YOUR RESPONSE. SUCH ATTORNEY SHOULD BE CONSULTED IMMEDIATELY SO
THAT A RESPONSE MAY BE FILED WITHIN THE TIME LIMIT STATED IN THE SUMMONS.
This Summons and Notice was served on Signatufe of person serving summons this
Case 5:17-cv-00974-R Document 5 Filed 09/19/17 Page 15 of 76
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IN THE DISTRICT COURT IN AND FOR OKLAHOMA COUNTY, OKLAHOMA

dam Daniels and
Kelsey Daniels, Individually and
as Parents and next friend of
CDD, MKD, and AAD, minor children
Plaintiffs, No. CJ-2017-4751
(Civil relief more than $10,000:
OTHER <..DESCRIPTION OF ACTION..>)
Independent School District
No 0-001 Of Oklahoma County Filed: 08/21/2017
Oklahoma, a political subdivision of
The State of Oklahoma aka Putnam
Judge: Andrews, Don
City Schools, Overholser Elementary
School aka Independant School NO
126 Putnam City School Board
Defendants.
Parties
Daniels, Adam , Plaintiff

A A , Minor
D Minor
Daniels, Kasey , Plaintiff
Minor
Independent School District No 0-001 Of Oklahoma ,
Defendant Overholser Elementary School , Defendant
Attorneys
Attorney Represented Parties

Jarman, Jeramy(Bar # 20508) D.

620 N. ROBINSON AVE SUITE 201 c
OKC, OK 73102 M K
Daniels, Adam
Daniels, Kelsey
Events
Event Party Docket Reporter
Issues
For cases filed before 1/1/2000, ancillary issues may not appear except in the docket.
Exhibit No. 3
1/4
Issue # 1. Issue: OTHER <..DESCRIPTION OF ACTION..> (OTHER)
Filed by: Daniels, Adam
Filed Date: 08/21/2017
Party Name: Disposition Information:
Pending.
Docket
Date Code Count Party Serial # Entry Date

08-21-2017 TEXT 1 92374118 Aug 21 2017 $ 0.00 CIVIL RELIEF MORE
THAN $10,000 INITIAL FILING.
08-21-2017 OTHER 92374120 Aug 21 2017 Realized

$ 0.00
OTHER <..DESCRIPTION OF ACTION..>
08-21-2017 DMFE 92374121 Aug 21 2017 Realized

$ 7.00
DISPUTE MEDIATION FEE($ 7.00)
08-21-2017 PFEI 92374122 Aug 21 2017 Realized $

163.00
PETITION($ 163.00)
08-21-2017 PFE7 92374123 Aug 21 2017 Realized

$ 6.00
LAW LIBRARY FEE($ 6.00)
08-21-2017 OCISR 92374124 Aug 21 2017 Realized $

25.00
OKLAHOMA COURT INFORMATION SYSTEM REVOLVING FUND($ 25.00)
08-21-2017 OCJC 92374125 Aug 21 2017 Realized

$ 1 .55
OKLAHOMA COUNCIL ON JUDICIAL COMPLAINTS REVOLVING FUND($
1.55)
08-21-2017 OCASA 92374126 Aug 21 2017 f)07Arvl Realized

$ 5.00
OKLAHOMA COURT APPOINTED SPECIAL ADVOCATES($ 5.00)
08-21-2017 SSFCHSCPC 92374127 Aug 21 2017 Realized

$ 10.00
SHERIFF'S SERVICE FEE FOR COURTHOUSE SECURITY PER BOARD OF
COUNTY COMMISSIONER($ 10.00)
08-21-2017 CCADMINCSF 92374128 Aug 21 2017 Realized

$ 1 .00
COURT CLERK ADMINISTRATIVE FEE ON COURTHOUSE SECURITY PER
BOARD OF COUNTY COMMISSIONER($ 1.00)
08-21-2017 CCADMINOI 55 92374129 Aug 21 2017 Realized

$ 0.16
COURT CLERK ADMINISTRATIVE FEE ON $1.55 COLLECTION($ 0.16)

08-21-2017 SUFIS 92374130 Aug 21 2017 Realized
$ 0.45
STATE JUDICIAL REVOLVING FUND - INTERPRETER AND TRANSLATOR
SERVICES($
0.45)
08-21-2017 DCADMIN155 92374131 Aug 21 2017 Realized

$ 0.23
DISTRICT COURT ADMINISTRATIVE FEE ON $1.55 COLLECTIONS($ 0.23)
08-21-2017 DCADMlN05 92374132 Aug 21 2017 Realized

$ 0.75
DISTRICT COURT ADMINISTRATIVE FEE ON $5 COLLECTIONS($ 0.75)
08-21-2017 DCADMINCSF 92374133 Aug 21 2017

Realized $ 1 .50
DISTRICT COURT ADMINISTRATIVE FEE ON COURTHOUSE SECURITY
PER BOARD OF COUNTY COMMISSIONER($ 1.50)
08-21-2017 CCADMlN04 92374134 Aug 21 2017 Realized

$ 0.50
COURT CLERK ADMINISTRATIVE FEE ON COLLECTIONS($ 0.50)
08-21-2017 LTF 92374135 Aug 21 2017 Realized $

10.00
LENGTHY TRIAL FUND($ 10.00)
08-21-2017 SMF 92374136 Aug 21 2017 Realized

$ 20.00
SUMMONS FEE($ 20.00)
08-21-2017 P 92381506Aug 22 2017 $ 0.00 pETlTlON

Document Available (#1037495569)
08-21-2017 TEXT 92374119 Aug 21 2017 $ 0.00 OCIS HAS AUTOMATICALLY

ASSIGNED JUDGE ANDREWS, DON TO THIS CASE.
08-21-2017 ACCOUNT 92374148 Aug 21 2017 $ 0.00

RECEIPT # 2017-4191510 ON 08/21/2017.
PAYOR: JARMAN LAW FIRM TOTAL AMOUNT PAID: $ 252.14.
LINE ITEMS:
CJ-2017-4751: $183.00 ON ACOI CLERK FEES.
CJ-2017-4751: $6.00 ON AC23 LAW LIBRARY FEE CIVIL AND CRIMINAL.
CJ-2017-4751: $1.66 ON AC31 COURT CLERK REVOLVING FUND.
CJ-2017-4751: $5.00 ON AC58 OKLAHOMA COURT APPOINTED SPECIAL
ADVOCATES.
CJ-2017-4751 : $1.55 ON AC59 COUNCIL ON JUDICIAL COMPLAINTS
REVOLVING FUND.
CJ-2017-4751: $7.00 ON AC64 DISPUTE MEDIATION FEES CIVIL ONLY
CJ-2017-4751 : $0.45 ON AC65 STATE JUDICIAL REVOLVING FUND,
INTERPRETER SVCS.
CJ-2017-4751: $2.48 ON AC67 DISTRICT COURT REVOLVING FUND.
CJ-2017-4751. $25.00 ON AC79 oas REVOLVING FUND.
Cd-2017-4751: $10.00 ON AC81 LENGTHY TRIAL FUND.
CJ-2017-4751: $10.00 ON AC88 SHERIFF'S SERVICE FEE FOR COURT
HOUSE SECURITY.
3/4
06-23-2017 SMS 92415025 Aug 24 2017 $ 0.00
SUMMONS RETURNED, SERVED: INDEPENDENT SCHOOL DISTRICT

NO. (0-001), BY
SERVING FRED RHODES, ON 8-21-17
08-23-2017 SMS 92415038 Aug 24 2017 $ 0.00
SUMMONS RETURNED, SERVED: PUTNAM CITY SCHOOL BOARD,

BY SERVING FRED RHODES ON 8-21-17
08-23-2017 SMS 92415052 Aug 24 2017 $ 0.00
SUMMONS RETURNED, SERVED: OVERHOLSER ELEMENTARY

SCHOOL BY SERVING
MARJORIE IVEN, ON 8-21-17
Report Generated by The Oklahoma Court Information System at August 30, 2017 13:14 PM
End of Transmission.

ADAM DANIELS and )

KELSEY DANIELS, individually ) and as parents and next
friend of )
C.D.D., M.K.D. and )
A.A.D., minor children )
)
Plaintiffs, )
-vs- )
) Case No. CIV-17-00974-R

INDEPENDENT SCHOOL DISTRICT, )
OKLAHOMA, a political subdivision of )
)
The State of Oklahoma, a/k/a
)
OVERHOLSER ELEMENTARY SCHOOL ) a/k/a
Independent School No. 126, )
PUTNAM CITY SCHOOL BOARD )
)
Defendants. )
DEFENDANTS MOTION TO DISMISS AND BRIEF IN SUPPORT
Laura L. Holmes
Laura L. Holmgren-Ganz
The Center for Education Law, Inc.
(405) 528-2800
(405) 528-5800 (fax)
Lholmes@cfel.com
Lganz@cfel.com
TABLE OF CONTENTS
INTRODUCTION ............................................................................................................... 1
STANDARD OF REVIEW ................................................................................................. 2
ARGUMENT AND AUTHORITY .................................................................................... 3

Proposition I: Overholser Elementary School and Putnam City School Board
are not legal entities. ...................................................................................... 3
Proposition II: Minor Plaintiff A.A.D. fails to state a
claim against Defendants ............................................................................... 5
Proposition III: Reporting to DHS does not create a private cause of action. .......... 6
Proposition IV: Plaintiffs fail to state a claim for defamation. ................................. 9
Proposition V: Court lacks jurisdiction over any IDEA claims because Plaintiffs have failed to
exhaust their administrative remedies. .......................................... 12 Proposition VI: Plaintiffs
fail to allege a claim under Section 1983. ..................... 16
Proposition VII: Much of Plaintiffs action is time-barred, and this Court lacks jurisdiction over
the time-barred state claims made against Defendants. . 18
Proposition VIII: Count III of Plaintiffs Petition fails to state a claim because District is exempt
from liability for its discretionary actions. .................................. 20
A. Failure to provide a safe environment: ................................................ 20
B. Negligent supervision and retention of teachers ................................. 21
Proposition IX: Plaintiffs claim for negligence regarding appropriate care and treatment of a
minor fails to state a claim upon which relief may be granted.
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
CONCLUSION ................................................................................................................. 25
Certificate of Service ......................................................................................................... 26

i
TABLE OF AUTHORITIES
Cases
Ashcroft v. Iqbal,
556 U.S. 662, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009)................................................ 2 Allen v. Justice
Alma Wilson Seeworth Academy, Inc.,
2012 WL 1298588 22,23
Baker v. McCollan,
443 U.S. 137 (1979) ..................................................................................................... 16
Bell Atlantic Corp. v. Twombly,

550 U.S. 544, 127 S.Ct. 1955, 167 L.Ed.2d 929 (2007)........................................ 2, 3, 6
Benedix v. Ind. Sch. Dist. No. 7 of,

Okla. County, 2009 WL 975145 .................................................................................. 22
Burns v. Holcombe,
No. 90-CV-152-JHP, 2010 WL 2756954 (E.D. Okla. July 12, 2010) ........................ 23
Chambers v. City of Ada,

1995 OK 24, 894 P.2d 1068 ........................................................................................ 11
Collins v. City of Harker Heights,

503 U.S. 115, 112 S.Ct. 1061, 117 L.Ed.2d 261 (1992).............................................. 16
Cudjoe v. Ind. Sch. Dist. No. 12,

297 F.3d 1058 (10th Cir. 2002) ................................................................................... 14
Curtis v. Oklahoma City Public Schools,

147 F.3d 1200 (10th Cir. 1998) ................................................................................... 17
Curtis v. Board of Education, Sayre Public Schools,

1995 OK 119, 914 P.2d 656 ................................................................................... 18, 19
Frazier v. Fairhaven Sch. Comm.,

276 F.3d 52 (1st Cir. 2002) .......................................................................................... 13
Fry v. Napoleon Community Schools,

137 S.Ct. 743, 197 L.Ed.2d 46, 85 USLW 4053 (2017) ............................................. 15
Fuller v. Odom,
741 P.2d 449 (Okla. 1987) ........................................................................................... 19
Fumi v. Board of County Commrs of Rogers County,
No. 10-CV-769-TCK-PJC, 2011 WL 4608296 (N.D. Okla. Oct. 3, 2011) ................. 23
Garrison v. Louisiana,
379 U.S. 64, 85 S.Ct. 209, 13 L.Ed.2d 125 (1964) ...................................................... 10
Gertz v. Robert Welch, Inc.,

418 U.S. 323, 94 S.Ct. 2997, 41 L.Ed.2d 789 (1974).................................................. 10
Gilkey v. Counts, 15-CV-0711-CVE-PJC,
2016 WL 4148357 (N.D. Okla. Aug. 4, 2016) .............................................................. 4

ii
Hayes v. Unified Sch. Dist. No. 377,
877 F.2d 809 (10th Cir. 1989) ..................................................................................... 14
Hazlett v. Board of Commrs,
168 OK 290, 32 P.2d 940 ............................................................................................ 12
Higginbottom v. Mid-Del District, et al.,

2016 WL 968599 ......................................................................................................... 22
Holman By and Through Holman v. Wheeler,

1983 OK 72, 677 P.2d 645 .......................................................................................... 12
Houston v. Ind. Sch. Dist. No. 89 of Okla. County,

949 F. Supp. 2d 1104 (W.D. Okla.) ............................................................................. 22
Houston v. Reich,
932 F.2d 883 (10th Cir. 1991) ..................................................................................... 12
Ind. Sch. Dist. No. 8 of Seiling v. Swanson,

1976 OK 71, 553 P.2d 296 .................................................................................... 17, 21
Justice Alma Wilson Seeworth Academy, Inc.,

No. CIV-12-93-HE, 2012 WL 1298588 ...................................................................... 22
Kirschstein v. Haynes,
1990 OK 8, 788 P.2d 941 .............................................................................................. 9
M.D.F. v. Ind. Sch. Dist. No. 50 of Osage County,

2010 WL 2326260 (N.D. Okla. 6/3/2010, Judge Frizzell) .......................................... 14
McMullen v. City of Del City,

1996 OK CIV APP 46, , 920 P.2d 528 ........................................................................ 11
Monell v. New York City Dept. of Social Services,

436 U.S. 658, 98 S.Ct. 2018, 56 L.Ed.2d 611 (1978).................................................. 16
Murphy v. Spring, 13-CV-96-TCK-PJC,
2013 WL 5172951 (N.D. Okla. Sept. 12, 2013) ............................................................ 4
Murrell v. Sch. Dist. No.1,

186 F.3d 1238 (10th Cir.1999) .............................................................................. 16, 17
Myers v. Lashley,
2002 OK 14, 44 P.3d 553 .............................................................................................. 7
Najera v. Ind. Sch. Dist. of Stroud No. I-54 of Lincoln Cnty.,

60 F. Supp. 3d 1202 (W.D. Okla. 2014) ...................................................................... 22
Niece v. Sears, Roebuck and Company,

293 F.Supp. 792 (N.D. Okla. 1968) ............................................................................... 2
Padilla v. Sch. Dist. No. 1 in Denver, Colo.,

233 F.3d 1268 (10th Cir. 2000) ................................................................................... 14
Parker v. City of Midwest City,

1993 OK 29, , 850 P.2d 1065 ...................................................................................... 11
Paulson v. Sternlof,
2000 OK CIV APP 128, 15 P.3d 981 ............................................................................ 6
iii
Primeaux v. Ind. Sch. Dist. No. 5 of Tulsa County Okla.,
954 F. Supp.2d 1292 (N.D. Okla. 2012) ........................................................................ 4
Randell v. Tulsa Ind. Sch. Dist. No. 1,

1994 OK CIV APP 156, 889 P.2d 1264 ................................................................ 21, 24
Reyna v. Ind. Sch. Dist. No. 01 of Oklahoma County,

Case No. CIV-09-1223-D (W.D. Okla. May 21, 2010) 5
Robbins v. Oklahoma,
519 F.3d 1242 (10th Cir. 2008) ..................................................................................... 3
Robinson v. City of Bartlesville Board of Education,

1985 OK 39, 700 P.2d 1013 ........................................................................................ 20
Rost v. Steamboat Springs RE-2 School Dist.,

511 F.3d 1114 (10th Cir. 2008) ................................................................................... 18
Sauers v. Salt Lake County,

1 F.3d 1122 (10th Cir. 1993) ....................................................................................... 16
School Board Dist. No.18, Garvin County v. Thompson,

1909 OK 136 ................................................................................................................ 21
SCO Group, Inc., v. Novell, Inc.,

692 F.Supp. 1287 (D. Utah 2010)................................................................................ 10
Seals v. Jones,
No. 12 CV-569-JED-TLW, 2013 WL 5408004 (N.D. Okla. Sept. 25, 2013)............. 23
Shanbour v. Hollingsworth,
1996 OK 67, 918 P.2d 73 ............................................................................................ 19
Springer v. Richardson Law Firm 2010 OK CIV APP 72,

239 P.3d 473 9
State v. Dixon,
1996 OK 15, 912 P.2d 842 .......................................................................................... 19
Swanson v. Bixler,
750 F.2d 810 (10th Cir. 1984) ....................................................................................... 2
Team Systems International, LLC v. Haozous,

2015 WL 2131479 (W.D. Okla., May 7, 2015) ............................................................. 4
Trice v. Burress,
2006 OK CIV APP 79, 137 P.3d 1253 .......................................................................... 9
Truitt v. Diggs,
611 P.2d 633 ................................................................................................................ 21
Tuffys, Inc. v. City of Oklahoma City,
2009 OK 4,, 212 P.3d 1158 ......................................................................................... 11
Urban v. Jefferson County Sch. Dist. R-1,

89 F.3d 720 (10th Cir. 1996) ....................................................................................... 14
White v. City of Tulsa,

No. 13-CV- 128-TCK-PJC, 2013 WL 4784243 (N.D. Okla. Sept. 5, 2013) .............. 23
iv
Young v. Okla. City Public Schools, Ind. Sch. Dist. 89,
et al., 2013 WL 6567144 ............................................................................................. 22
Statutes
20 U.S.C. 1400 ............................................................................................................ 12
20 U.S.C. 1415(l) ......................................................................................................... 14
20 U.S.C. 1415(a).......................................................................................................... 13
42 U.S.C. 1983 ....................................................................................................... passim
10 O.S. 175.20 ................................................................................................................. 7

10 O.S. 402(3) . ..8
10A O.S. 1-1-102 8
10A O.S. 1-1-105.6,8
10A O.S. 1-2-101 ..7

10A O.S. 1-2-1046
51 O.S. 152 . 5,11

51 O.S. 152.1 20 51 O.S. 153 .
11
51 O.S. 155 .20, 22
51 O.S. 156 19 51 O.S. 163

.5 70 O.S. 5-105
.3
70 O.S. 5-106 .3
70 O.S. 5-117 .. 17, 20
Regulations
34 C.F.R. 300.507 ......................................................................................................... 14
OAC 340:75-3-130 9, 10
v
Defendants Independent School District No. 1 of Oklahoma County, Oklahoma, a/k/a Putnam
City Public Schools, (District), Overholser Elementary School a/k/a Independent School No. 126
(Overholser), and Putnam City School Board, hereby move for dismissal of Plaintiffs Petition for failure
to state a claim upon which relief can be granted pursuant to Fed. R. Civ. P. 12(b)(6).
INTRODUCTION
Adam Daniels and Kelsey Daniels are the parents and next friend of C.D.D. and M.K.D, and
A.A.D., minors, who bring this action against Defendants alleging defamation, negligence, and violations
of alleged federal rights brought pursuant to 42 U.S.C. 1983 (Section 1983). In Count I, Plaintiffs
allege that Defendants persecuted Plaintiffs over a period of years because of their religion by filing
allegations with Department of Human Services (DHS) that are false or misleading resulting in damage
to Plaintiffs stance in the community and loss of business income. Plaintiff Adam Daniels claims that he
is a published author and church leader. Petition at 10, Doc. No. 1-1.
In Count II, Plaintiffs alleges that they reported allegations of neglect and abuse, including a strip
search by Districts employee, at an Individual Education Program (IEP) meeting for M.K.D. which
Defendants never reported to DHS. Petition at 11, Doc. No. 1-1. Additionally in Count II, Plaintiffs claim
that Defendants retaliated against them because of their religion by making comments about their
religion and passing on information to DHS about Plaintiffs religion. Petition at 12, Doc. No. 1-1. In
Count II, Plaintiffs also claim that
1
Defendants failed to protect Plaintiffs children from bullying and mistreatment by students and
teachers. Petition at 13, Doc. No. 1-1. In Count III, Plaintiffs claim that Defendants were negligent in
providing a safe environment, treatment and care for Plaintiffs children, and negligent in supervising
G:\PC-L\Daniels\Pldgs\Def. MTD.wpd
and retaining teachers and staff capable of protecting students from harm. Petition at 15-18, Doc. No.
1-1.
STANDARD OF REVIEW
A motion pursuant to Rule 12(b)(6) assumes that the court is authorized to resolve the dispute
and tests whether there is a legal dispute to resolve. The function of a Rule 12(b)(6) motion is to test the
law of a claim, not the facts which support it. Niece v. Sears, Roebuck and Company, 293 F.Supp. 792,
794 (N.D. Okla. 1968).
In deciding a motion to dismiss for failure to state a claim, the allegations of the complaint must
be viewed in the light most favorable to the plaintiff. Swanson v. Bixler, 750 F.2d 810, 813 (10th Cir.
1984). Pleadings that are no more than legal conclusions are not entitled to the assumption of truth;
while legal conclusions can provide the framework of a complaint, they must be supported by factual
allegations. Ashcroft v. Iqbal, 556 U.S. 662, 679, 129 S.Ct. 1937, 1950, 173 L.Ed.2d 868 (2009). A
complaint need not contain detailed factual allegations; however, a plaintiffs obligation requires more
than labels and conclusions, and a mere recitation of the elements of a cause of action will not be
sufficient.
Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555, 127 S.Ct. 1955, 167 L.Ed.2d 929 (2007). A plaintiff must
allege sufficient facts to nudge [ ] their claims across the line from
2
conceivable to plausible. Id. at 570.
One of the purposes of the plausibility requirement is to weed out claims that do not (in the
absence of additional allegations) have a reasonable prospect of success and to inform the defendants
of the actual grounds of the claim against them. Robbins v. Oklahoma, 519 F.3d 1242, 1248 (10th Cir.
2008). The degree of specificity necessary to establish plausibility and fair notice, and therefore the
need to include sufficient factual allegations, depends on context which ultimately depends on the type
of case. Robbins, 519 F.3d at 1248.
ARGUMENT AND AUTHORITY
Proposition I: Overholser Elementary School and Putnam City School Board are not legal entities.
Plaintiffs have named Overholser Elementary School and Putnam City School Board in the style
of the case, and, in Paragraph 2 of the Petition allege that Overholser Elementary School and Putnam
City School Board are political subdivisions of the state of Oklahoma. Oklahoma law provides that a
school district is a corporate body possessing the powers of a corporation for public purposes. 70 O.S.
5105. The law further provides that a school district may sue and be sued by the name and style of
Independent School District Number
... The governing body of each school district is referred to as the board of education. 70 O.S. 5
106. A school board is not itself a separate body corporate, and has no legal existence independent of
the school district it governs. As such, there is no similar law or other authority which permits a board of
education of a public school district to sue or be
3
sued in its own name.
In Primeaux v. Ind. Sch. Dist. No. 5 of Tulsa County Okla., 954 F. Supp.2d 1292, 1295 (N.D. Okla.
2012), the United States District Court for the Northern District of Oklahoma held that a public school
board is not a separate suable entity under Oklahoma law. Id. at *2. Further, in ruling that the board
should be dismissed, the court found that where an Oklahoma school district is named as a defendant,
any claims against the school board are duplicative of claims against the school district. Id. See also
Team Systems International, LLC v. Haozous, 2015 WL 2131479, *2 (W.D. Okla., May 7, 2015) (stating in
dicta that a school board may not sue or be sued); Gilkey v. Counts, 15-CV-0711-CVE-PJC, 2016 WL
4148357, at *2 (N.D. Okla. Aug. 4, 2016) (dismissing a board of education as an improper party as it
lacked the capacity to be sued under Oklahoma law); Murphy v. Spring,
13-CV-96-TCK-PJC, 2013 WL 5172951, at *2 (N.D. Okla. Sept. 12, 2013)(holding,
Oklahoma school boards are not separate suable entities.)
Overholser Elementary School is a school site within Putnam City Schools and is not a separate
legal entity capable of being sued. The school board which governs a school district is not a legal entity
capable of being sued. Rather, by naming and serving Independent School District No. 1 of Oklahoma
County which is commonly known as Putnam City Schools, Plaintiffs have named and served the
appropriate legal entity. Plaintiffs claims against Overholser Elementary and Putnam City School Board
are duplicative of those claims against the District and should therefore be dismissed.
4
Additionally, Counts I and III of the Petition allege that Overholser Elementary
School and Putnam City School Board are liable in defamation and negligence. Petition at
10, 15-19, Doc. No.1-1. These claims of negligence are governed by the Governmental Tort Claims Act
(GTCA) which provides that [S]uits instituted pursuant to the provisions of this act shall name as
defendant the state or the political subdivision against which liability is sought to be established. 51
O.S. 163(C). The GTCA defines a political subdivision as: a municipality, a school district, a county, a
public trust . . . 51 O.S. 152(11) (emphasis added). Neither an elementary school or a school board fit
the definition of a political subdivision under the GTCA. This court has previously held that an
individual school site is an improper party and dismissed the plaintiffs claims against it. Reyna v. Ind.
Sch. Dist. No. 01 of Oklahoma County, Oklahoma, et al., Case No. CIV-09-1223-D *5 (W.D. Okla.
May 21, 2010). Attached as Exhibit 1. Like Reyna, Plaintiffs improperly named Overholser Elementary
School, an individual school site, as a defendant in this case. Thus, for these reasons, Overholser
Elementary School and Putnam City School Board should be dismissed from this action.
Proposition II: Minor Plaintiff A.A.D. fails to state a claim against Defendants.
Plaintiff A.A.D. fails to state a claim against Defendants. The Supreme Court has held that
plaintiffs obligation to provide the grounds of [her] entitlement to relief requires more than labels
and conclusions, and a formulaic recitation of the elements of a cause of action will not do. . . Factual
allegations must be enough to raise a right to relief above the
5
speculative level. Bell Atlantic Corp., 550 U.S. at 555. [T]he pleading must contain something more
than a statement of facts that merely creates a suspicion [of] a legally cognizable right of action. Id.
In this case, Plaintiffs Petition fails to allege specific facts regarding how Defendants injured
minor Plaintiff A.A.D. Unlike the other minor Plaintiffs M.K.D. and C.D.D., A.A.D. is never mentioned in
any Plaintiffs allegations except for in the style of the case. Plaintiffs Petition fails to meet the required
standard of pleading as to A.A.D.s claims against
Defendants. Thus, Plaintiff A.A.D.s claims against Defendants should be dismissed.
Proposition III: Reporting to DHS does not create a private cause of action.
Plaintiffs claim that Districts employees made false or misleading allegations to DHS about
Plaintiffs. Plaintiffs also claim that District failed to report alleged abuse to DHS after
Plaintiffs reported to one of Districts teachers and principal the alleged strip search of
M.K.D. by a school employee. Petition at 10-12, Doc. No. 1-1.
With respect to Plaintiffs claim regarding false or misleading allegations being made to DHS, the
child abuse reporting statutes do not create a private right of action. Paulson
v. Sternlof, 2000 OK CIV APP 128, 13, 15 P.3d 981, 984. Oklahomas child abuse reporting laws express
the States strong public interest in protecting children from abuse by requiring mandatory reporting of
actual and suspected child abuse or neglect to DHS. The statutory scheme imposes upon all persons an
obligation to report in good faith all suspected instances of child abuse to DHS. 10A O.S. 1-1-105. Any
one acting in good faith and
6
exercising due care in reporting child abuse shall have immunity from any liability, civil or criminal, that
might otherwise be incurred or imposed. ... the good faith of any person in making a report pursuant to
the provisions of Section 1-2-101 of this title shall be presumed. 10A O.S. 1-2-104. See also, Myers v.
Lashley, 2002 OK 14, 11, 44 P.3d 553, 55859.
In this case, Plaintiffs have not pled any facts that would overcome the presumption of good
faith associated with Districts reports of alleged abuse to DHS. Moreover, as the Paulson court noted,
there is no private right of action under the child abuse reporting statutes. Therefore, this claim should
be dismissed.
With respect to the allegation that District is somehow liable for failing to report the allegations
of a strip search to DHS, the law does not require reports to DHS of alleged actions of abuse by school
employees in their role as employees of a school district. According to the Oklahoma Childrens Code,
child abuse reporting requirements pertain only to abuse inflicted by the childs primary care givers, not
by teachers or any other school employee. Although 10A O.S. 1-2-101(B) discusses the duty of
individuals to report child abuse, the Oklahoma Childrens Code defines abuse as harm inflicted by a
person responsible for the childs health, safety, or welfare which is defined as:
a parent; a legal guardian; custodian; a foster parent; a person eighteen (18) years of
age or older with whom the childs parent cohabitates or any other adult residing in the
home of the child; an agent or employee of a public or private residential home,
institution, facility or day treatment program1 as
10 O.S. 175.20 identifies day care treatment programs as day programs where children
1
receive psychiatric or psychological treatment. It does not include public schools.
7
defined in Section 175.20 of Title 10 of the Oklahoma Statutes; or an owner, operator,
or an employee of a child care facility as defined by Section 402 of Title 10 of the
Oklahoma Statutes2.
10A O.S. 1-1-105(50) .
These definitions make clear that the purpose of the child abuse reporting provisions is to report
suspected abuse inflicted by a childs primary care givers, not by a teacher or other individual. This
legislative intent is made even more clear by the Acts express statement of legislative intent which
provides, [f]or the purposes of the Oklahoma Childrens Code, the Legislature recognizes that: . . .
[p]arents have a natural, legal, and moral right, as well as a duty, to care for and support their children.
10A O.S. 1-1- 102(A)(1) (emphasis added). A child has a right to be raised by the mother and father of
the child as well as a right to be raised free from physical and emotional abuse or neglect. Id. at 1-1-
102(A)(2) (emphasis added). Subsection B provides further that [i]t is the intent of the Legislature that
the Oklahoma Childrens Code provide the foundation and process for state intervention into the parent-
child relationship . . . Id. at 1-1-102(B) (emphasis added). Clearly, the Oklahoma Childrens Code was
written to address child abuse inflicted by parents and primary care givers, not teachers or other school
employees.
10 O.S. 402(3) defines child care facility as any public or private child care residential
2
facility, child-placing agency, foster familyhome, child care center, part-daychild care program, school-
age program, summer day camp, family child care home, or large family child care home providing either
full-time or part-time care for children away from their own homes. This definition also does not
include public schools.
8
Thus, to the extent that Plaintiffs claim District failed to report alleged child abuse by a school
employee, Oklahoma law does not require such a report. Plaintiffs claim should therefore be dismissed.
Proposition IV: Plaintiffs fail to state a claim for defamation.

In Count I of Plaintiffs Petition, Plaintiffs claim that Defendants reporting to DHS resulted in
damage to Plaintiffs stance in the community as well as their business which happen to be a [c]hurch
called Dakhma of Angra Mainyu. Petition 10, Doc. No. 1-1.
Plaintiffs appear to argue that Districts alleged reports to DHS defamed Plaintiffs.
Under Oklahoma law, the elements of a defamation claim are: (1) a false and defamatory
statement, (2) an unprivileged publication to a third party, (3) fault amounting at least to negligence on
the part of the publisher; and (4) either the actionability of the statement irrespective of special damage,
or the existence of special damage caused by the publication.
Trice v. Burress, 2006 OK CIV APP 79, 10, 137 P.3d 1253, 1257; Springer v. Richardson Law Firm, 2010
OK CIV APP 72, 239 P.3d 473, 475. DHS reports are confidential and subject to disclosure only in cases
where criminal charges are filed or when otherwise ordered to be disclosed by a court. OAC 340:75-3-
130. The Oklahoma Supreme Court has held that communications made within the context of judicial or
quasi-judicial proceedings the privilege extends to communications regardless of whether they are true
or false. Kirschstein
v. Haynes, 1990 OK 8, 788 P.2d 941, 950.
9
Plaintiffs never allege that any of the reports by Defendants to DHS were not a
privileged publishing to a third party. In fact, according to DHS rules, reporting of possible child abuse is
confidential. OAC 340:75-3-130. The only time it may be publicly published is when criminal charges are
filed by the State which is a judicial proceeding. Hence, Defendants statements are privileged because the
communication is made in a quasi-judicial proceeding. Thus, Plaintiffs claim for defamation must be
dismissed because Plaintiffs fail to state a claim against Defendants.
Plaintiff Adam Daniels claims that he is a published author and lead minister of the Dakhma of
Angra Mainyu. Petition at 5,10, Doc. No.1-1. The Supreme Court defines a public figure as:
Those who, by reason of the notoriety of their achievements or the vigor and success
with which they seek the public's attention, are properly classed as public figures and
those who hold governmental office.
Gertz v. Robert Welch, Inc., 418 U.S. 323, 342, 94 S.Ct. 2997, 41 L.Ed.2d 789 (1974). In
Gertz, a limited-purpose public figure is defined as one who voluntarily injects himself or is drawn into
a particular controversy and thereby becomes a public figure for a limited range of issues. Id. at 351;
SCO Group, Inc., v. Novell, Inc., 692 F.Supp. 1287, 1296 (D. Utah 2010). In a defamation claim, a public
figure must prove both that the publication was false and that defendant published it in knowing or
reckless disregard as to its falsity, that is, with a high degree of awareness of its probable falsity. Garrison
v. Louisiana,379 U.S. 64, 74, 85 S.Ct. 209, 215, 13 L.Ed.2d 125 (1964).
10
Underthe Oklahoma Governmental Tort Claims Act (GTCA), a political subdivision can only be
liable for the tortious action of an employee if the employee acts within the scope of his employment. 51
O.S. 153(B). Districts liability in tort pursuant to the GTCA shall be exclusive and in place of all other
liability . . . at common law or otherwise. 51 O.S. 153(B). Further, District shall not be liable under the
provisions of [the GTCA] for any act or omission of an employee acting outside the scope of his
employment. Id. The immunity granted by the GTCA is a jurisdictional question which must be
determined by the court sua sponte. Chambers v. City of Ada, 1995 OK 24, 21, 894 P.2d 1068, 1074.
Scope of employment for purposes of the GTCA means performance by an
employee acting in good faith within the duties of his office or employment. . . . 51 O.S. 152(9)
(emphasis added). See also Tuffys, Inc. v. City of Oklahoma City, 2009 OK 4, 14- 15, 212 P.3d
1158,1163. As the Oklahoma Supreme Court noted in Tuffys, Inc., an employee is acting within the scope
of employment if the employee is engaged in work assigned, or if doing that which is proper, necessary
and usual to accomplish the work assigned, or doing that which is customary within the particular trade
or business. Id. at 1163. A governmental entity subject to the protections of the GTCA, such as District,
cannot be held liable for any act of an employee unless the employee can be found to have acted in good
faith and within the scope of employment. McMullen v. City of Del City, 1996 OK CIV APP 46, 5-9, 920
P.2d 528, 530-31; Parker v. City of Midwest City, 1993 OK 29, 6-10, 850 P.2d 1065, 1066-67. However,
such protection does not render such employees immune from liability
11
for willful and wanton negligence or conduct which places the employees outside the scope of their
employment. Holman By and Through Holman v. Wheeler, 1983 OK 72, 677 P.2d 645, 647. In other
words, the GTCA may not be construed to mean that an employee may conduct himself in a willful and
wanton manner and retain the immunity from liability that the Tort Claims Act provides. Id.; see also
Hazlett v. Board of Commrs, 168 OK 290, 32 P.2d 940; Houston v. Reich, 932 F.2d 883 (10th Cir. 1991).
In this case, Plaintiff Adam Daniels claims that he is a public figure and [t]he District has operated
in unison with its Administration, Teacher, and Principals in several different schools spanning a time
frame of several years to pervasively pursue false and misleading claims against the Petitioners directly
related to their choice of religious practice resulting in damage. Petition at 10, Doc. No.1-1. Since
Plaintiff Adam Daniels claims to be a public figure and that Districts employees defamed him because of
his association with Dakhma of Angra Mainyu, Plaintiff must show that Districts employees acted with
reckless disregard for the truth or that they acted in bad faith as to the reports to DHS. According to the
GTCA, if Districts employees acted in reckless disregard for the truth, then those employees actions fall
outside the scope of their employment and District may not be held liable. Thus, the court should dismiss
Plaintiffs Count I defamation claim against District.
Proposition V: Court lacks jurisdiction over any IDEA claims

because Plaintiffs have failed to exhaust their administrative
remedies.
M.K.D. and C.D.D. are students with a disability as defined by the Individuals with
Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. Petition at 6-7, Doc. No. 1-1.
12
Throughout Plaintiffs Petition, Plaintiffs complain of the method of providing education. Plaintiffs claim
that they had suspicion of neglect and abuse to include strip searches at the hands of the school nurse
which Plaintiffs reported to the IEP instructor as well as the Principal of that school. . . [o]n or about mid
April 2016, Mr. and Mrs. Daniels were advised that their daughter was exhibiting a suspect behavior
during an IEP evaluation. Petition at 6 and 11, Doc. No. 1-1. These allegations relate to and concern
the education and related services which were provided to M.K.D. and A.A.D. as a result of their eligibility
for such services under the IDEA. In Count II of Plaintiffs Petition, they claim that M.K.D. was subjected to
strip searches, bullying and mistreatment at the hand of students and teachers which violated
Plaintiffs rights under 42 U.S.C. 1983. Petition at 11 and 13, Doc. No.1- 1.
IDEA is a comprehensive statutory scheme designed to provide students with disabilities a free
appropriate education which includes special education and related services. Frazier v. Fairhaven Sch.
Comm., 276 F.3d 52, 58 (1st Cir. 2002). In order to accomplish this goal, IDEA establishes certain
procedural safeguards. Id. Specifically, IDEA requires that state educational agencies such as the
Oklahoma State Department of Education (OSDE) or local education agencies such as Putnam City
Schools establish and maintain certain procedural safeguards with respect to the provision of a free
appropriate public education (FAPE) for students with disabilities. 20 U.S.C. 1415(a).
13
IDEA requires that parties exhaust the required administrative remedies prior to bringing a civil
action under IDEA, the Americans with Disabilities Act of 1990, Title V of the Rehabilitation Act of 1973, or
other Federal laws (such as Section 1983) protecting the rights of children with disabilities whenever the
relief sought in the civil action is also available under IDEA. 20 U.S.C. 1415(l); Cudjoe v. Ind. Sch. Dist.
No. 12, 297 F.3d 1058, 1064 (10th Cir. 2002); Padilla v. Sch. Dist. No. 1 in Denver, Colo., 233 F.3d 1268,
1270 (10th Cir. 2000); M.D.F. v. Ind. Sch. Dist. No. 50 of Osage County, 2010 WL 2326260 (N.D. Okla.
6/3/2010, Judge Frizzell). See also, Hayes v. Unified Sch. Dist. No. 377, 877 F.2d 809 (10th Cir. 1989) (in a
case challenging use of a time-out room, exhaustion of the Act's administrative remedies was necessary
before any action was brought in federal court, even if the Act is not the exclusive remedy available). The
purpose of requiring exhaustion of administrative remedies is "to permit agencies to exercise discretion
and apply their expertise, to allow the complete development of the record before judicial review, to
prevent parties from circumventing the procedures established by Congress, and to avoid
unnecessaryjudicial decisions by giving the agency an opportunity to correct errors." Urban v. Jefferson
County Sch. Dist. R-1, 89 F.3d 720, 724 (10th Cir. 1996). The regulations implementing IDEA provide that
a due process hearing is to be held whenever a parent has a concern relating to the educational
placement or the provision of a free appropriate public education ("FAPE") to a student with a disability.
34 C.F.R. 300.507.
14
The Supreme Court has held that [i]n determining whether a plaintiff seeks relief for the denial
of a FAPE, what matters is the gravamen of the plaintiffs complaint, setting aside any attempts at artful
pleading. Fry v. Napoleon Community Schools,137 S.Ct. 743,747, 197 L.Ed.2d 46, 85 USLW 4053 (2017).
One clue to the gravamen of a complaint can come from asking a pair of hypothetical questions. First,
could the plaintiff have brought essentially the same claim if the alleged conduct had occurred at a public
facility that was not a school? Second, could an adult at the school have pressed essentially the same
grievance? . . . [W]hen the answer is no, then the complaint probably does concern FAPE. Id.
In this case, the factual basis of Plaintiffs Count II claim arise out of the educational services
provided to minor Plaintiffs who are disabled. Plaintiffs claim that during an IEP meeting they expressed
concerns of a strip search by a school employee which was not reported to DHS. As a result of Plaintiffs
complaint, Defendants allegedly retaliated against Plaintiffs by reporting them to DHS and failing to
protect Plaintiffs children. Petition at 11- 13, Doc. No. 1-1. Plaintiffs cannot meet the Fry test because
such a claim cannot arise outside of a school setting nor could an adult file the same grievance.
Additionally, Plaintiffs never allege that they exhausted their administrative remedies in their Petition.
Thus, Plaintiffs Count II should be dismissed regarding any claims about educational services.
15
Proposition VI: Plaintiffs fail to allege a claim under Section
1983.
In Count II of the Petition, Plaintiffs claim that Defendants violated various constitutional rights of
both the children and the parents in violation of Section 1983. Petition at 11, Doc. No. 1-1.
Section 1983 provides that any person who, under color of state law, causes a deprivation of
rights shall be liable to the party injured by such deprivation. 42 U.S.C. 1983. Section 1983, however, is
not a source of substantive rights but merely provides a method for vindicating other federal rights
conferred by the United States Constitution and federal statutes. Baker v. McCollan, 443 U.S. 137, 144
n.3 (1979). The purpose of Section 1983 is to deter state actors from using their authority to deprive
individuals of federally guaranteed rights. Id. Local governmental entities such as District are persons
who may be sued under Section 1983. Sauers v. Salt Lake County, 1 F.3d 1122 (10th Cir. 1993) relying on
Monell v. New York City Dept. of Social Services, 436 U.S. 658, 98 S.Ct. 2018, 56 L.Ed.2d 611 (1978) and
Collins v. City of Harker Heights, 503 U.S. 115, 112 S.Ct. 1061, 117 L.Ed.2d 261 (1992). However,
respondeat superior liability is not a valid theory for imposing Section 1983 liability on a governmental
entity. Sauers at 1129.
A school district may be liable for violations of federal rights under Section 1983 utilizing the
municipal liability framework established bythe courts. This framework requires a plaintiff to establish
that the school districts actions are either representative of an official policy or custom or taken by an
official with final policy-making authority. Murrell v. Sch.
16
Dist. No.1, 186 F.3d 1238, 1249 (10 Cir.1999); see also, Rost v. Steamboat Springs RE-2 School Dist., 511
th
F.3d 1114, 1124 (10th Cir. 2008). With respect to an official policy, in order to subject a school district to
liability, the policy must be officially promulgated and adopted by the appropriate officers. Murrell at
1249. In order to demonstrate that an official policy exists, the plaintiff must show that there is a policy
statement, ordinance, regulation, or decision officially promulgated and adopted by the governmental
entity. Absent an official policy, the governmental entity may be held liable only if the discriminatory
practice is so well settled as to constitute a custom and practice. Murrell at 1249.
In Oklahoma, the board of education of a school district is the final policy making authority for a
public school district. 70 O.S. 5-117. Neither a superintendent, a high school principal, or teacher has
final policy making authority for a school district. Rather, under Oklahoma law, only a board of education
is empowered to adopt rules or policies regarding the learning environment and student safety. Ind. Sch.
Dist. No. 8 of Seiling v. Swanson, 1976 OK 71, 553 P.2d 296. Under Oklahoma law, the duly-elected board
of education is the final policy-making authority. Curtis v. Oklahoma City Public Schools, 147 F.3d 1200
(10th Cir. 1998).
Plaintiffs Petition does not specify which constitutional rights have allegedly been violated by
Defendants and have thus failed to plead an appropriate Section 1983 claim since Section 1983 is not the
source of substantive rights. Plaintiffs also have not alleged that there are any policy statements,
ordinances, regulations, or official decisions adopted by Districts
17
Board of Education which caused any violation of their alleged constitutional rights. Moreover, Plaintiffs
have not alleged any facts which would demonstrate a custom or practice or that any actions which
resulted in a denial of their rights were taken by a person with final policy making authority for District.
Accordingly, Plaintiffs Section 1983 claims asserted in Count II against the Defendant must be dismissed
for failure to state a claim.
Proposition VII: Much of Plaintiffs action is time-barred, and

this Court lacks jurisdiction over the time-barred state claims
made against Defendants.
Plaintiffs claim in Count I of their Petition that they were subject to DHS interview and
investigation on more than 30 occasions since 2013 as a result of Defendants reporting false and
misleading claims. Petition at 10, Doc. No. 1-1. Plaintiffs also filed negligence claims in Count III of their
Petition that Defendants were negligent in providing a safe environment for the minor children,
negligent in providing and rendering appropriate care and treatment to minor children, and negligent
in supervising and retaining teachers and staff capable of fulfilling the school duty of protecting the
students from harm. Moreover, on or about January of 2015, M.[K.]D. received a fractured ankle which
faculty and staff failed to provide immediate and proper care for the injury sustained. Petition at 9,
15,17- 18, Doc. No. 1-1. Plaintiffs claim that they filed a notice of tort claim with Defendants on or about
April 3, 2017. Petition at 5, Doc. No. 1-1.
The GTCA is the exclusive remedy against a governmental entity in this State; the only recovery
available in tort against a political subdivision must be found within the boundaries defined by the
[GTCA]. Curtis v. Board of Education, Sayre Public Schools,
18
1995 OK 119, 914 P.2d 656, 658, citing Fuller v. Odom, 741 P.2d 449, 452 (Okla. 1987).
Compliance with the written notice of claim and denial of claim provisions of the GTCA are prerequisites
to the State's consent to be sued in tort and to the exercise of judicial power to remedyalleged tortious
wrongs bygovernment entities. Shanbour v. Hollingsworth, 1996 OK 67, 918 P.2d 73. A plaintiff suing a
governmental entity may not invoke the court's power to adjudicate a claim against a political subdivision
without complying with the statutory requirements relating to presuit notice of such claims. State v.
Dixon, 1996 OK 15, 912 P.2d 842. The GTCA requires as a prerequisite to the filing of suit against a
political subdivision such as District that a putative plaintiff present a claim to the District within one year
of the date the loss occurs. 51 O.S. 156.
A review of Plaintiffs Petition clearly reveals that they are attempting to lodge tort claims under
Oklahoma law for events that occurred well before April 3, 2016, i.e. not within one year of filing their
tort claim with District. Specifically, Plaintiffs claim that Defendants defamed them since 2013 and were
negligent in their care of M.K.D.s broken ankle in January 2015. Petition at 9 and 10, Doc. No. 1-1. As
such, Plaintiffs defamation and negligence claims asserted against Defendants which occurred prior to
April 3, 2016, are time barred and must be dismissed because this Court lacks jurisdiction over such
claims.
19
Proposition VIII: Count III of Plaintiffs Petition fails to state a claim because District is exempt
from liability for its discretionary actions.
A. Failure to provide a safe environment:
Count III of Plaintiffs Petition alleges that Defendants [were] negligent in providing a safe
environment for minor children and in protecting the children from foreseeable harm. Petition at 15,
Doc. No. 1-1. However, District is immune from such liability under the GTCA.
The immunity of a political subdivision is waived only to the extent and in the manner provided
by the GTCA. 51 O.S. 152.1. The GTCA sets forth certain exemptions from liability including the
following:
The state or a political subdivision shall not be liable if a loss or claim results from:
. . . (5) Performance of or the failure to exercise or perform any act or service

which is in the discretion of the state or political subdivision or its employees;
51 O.S. 155(5). An action of a political subdivision is discretionary when it is the result of judgment.
Robinson v. City of Bartlesville Board of Education, 1985 OK 39, 700 P.2d 1013,1017.
A board of education has the power to make rules governing the board and the school district
and the power to maintain and operate a complete public school system of such character as the board of
education shall deem best suited to fit the needs of the school district. 70 O.S. 5-117. These powers give
discretion to the boards of education to determine curriculum, attendance, grading policies, discipline of
students and securitymeasures, among
20
other powers that are reasonably related to the education function of school districts. See, Ind. Sch. Dist.
No. 8 of Seiling v. Swanson, 1976 OK 71, 553 P.2d 496; School Board Dist. No.18,
Garvin County v. Thompson, 1909 OK 136, 103 P.578; Randell v. Tulsa Ind. Sch. Dist. No. 1, 1994 OK CIV
APP 156, 889 P.2d 1264.
As to Plaintiffs claim alleging District negligently failed to provide a safe environment, District is
immune from liability for such claim under the discretionary function exemption of the GTCA. The
Oklahoma Supreme Court recognizes that a great deal of discretion is involved in determining what
security measures might be needed for a school. Truitt v. Diggs, 611 P.2d 633, 635. In other words, such
a decision by District is a legitimate judgment call.
Since Districts decisions regarding a safe school environment are discretionary decisions, such
decisions and actions are exempt and immune from liability under Section 155(5) of the GTCA. Thus,
Plaintiffs claim that District failed to provide a safe environment should be dismissed.
B. Negligent supervision and retention of teachers:
Count III of Plaintiffs Petition also alleges that Defendants were negligent in supervising and
retaining teachers and staff capable of fulfilling the schools duty of protecting the students from harm.
Petition at 18, Doc. No.1-1. As previously stated, the GTCA is the exclusive remedy for a tort claim
against a school district. As to Plaintiffs claim alleging negligent supervision and retention of teachers,
District is immune from liability for
21
such claims under the discretionary function exemption of the GTCA. 51 O.S. 155(5). A school district's
decisions regarding the hiring, retention, training, and supervision of its employees are generally the kind
of decisions that implicate policy concerns related to its educational mission.
Employment decisions are protected under the discretionary function exemption in Section
155(5) of the GTCA. This Court and other Oklahoma federal trial courts have consistently recognized that
personnel decisions such as hiring, supervision, and retention of employees involve policy making and
planning concerns, and thus, warrant protection as discretionarydecisions exempt from tort litigation
challenging such decisions. A claim against a school district for negligence in its hiring, supervision, and
retention of teachers and/or staff is barred by the discretionary function exemption of the GTCA.
Higginbottom v. Mid-Del District, et al., 2016 WL 968599, Case No. CIV-15-1091-D (W.D. Okla. Mar. 9,
2016); see also, Najera v. Ind. Sch. Dist. of Stroud No. I-54 of Lincoln Cnty., 60 F. Supp. 3d 1202, 1206
(W.D. Okla. 2014);Young v. Okla. City Public Schools, Ind. Sch. Dist. 89, et al., 2013 WL 6567144, CIV-13-
633-M (W.D. Okla. July 24, 2013)(the school districts decision regarding hiring, retention, and
supervision of its employees is deemed to be a discretionary act and, thus, falls under the GTCAs
discretionary exemption.); Houston v. Ind. Sch. Dist. No. 89 of Okla. County, 949 F. Supp. 2d 1104 (W.D.
Okla.); Benedix v. Ind. Sch. Dist. No. 7 of Okla.
County, 2009 WL 975145, Case No. CIV-08-1060-D (W.D. Okla. Apr. 9, 2009); Allen v.
Justice Alma Wilson Seeworth Academy, Inc., No. CIV-12-93-HE, 2012 WL 1298588 at *2
22
(W.D. Okla. Apr. 16, 2012) (school boards training, supervision, and retention of its employees was
discretionary under GTCA and citing cases in support); Seals v. Jones, No. 12 CV-569-JED-TLW, 2013 WL
5408004, at *4 (N.D. Okla. Sept. 25, 2013) (negligent hiring and retention of employees falls within the
discretionary functions provision of the GTCA, for which county is immune from suit as a matter of law);
White v. City of Tulsa, No. 13-CV- 128-TCK-PJC, 2013 WL 4784243, at *5 (N.D. Okla. Sept. 5, 2013) (city
was immune for officers alleged negligent training and supervision because such acts were
discretionary); Fumi v. Board of County Commrs of Rogers County, No. 10-CV-769-TCK-PJC, 2011 WL
4608296, at **6-7 (N.D. Okla. Oct. 3, 2011) (agreeing that entity was immune from officers alleged
negligent hiring, training, supervision and retention under Section 155(5)); Burns v. Holcombe, No. 90-CV-
152-JHP, 2010 WL 2756954, at *15 (E.D. Okla. July 12, 2010) (a political subdivision is not subject to suit
for discretionary acts such as hiring, supervising, and training employees).
Therefore, based on the GTCAs exemption from liability for discretionary acts, District is entitled
to have Plaintiffs Count III claim for negligently failing to provide a safe environment and negligent
supervision and retention of teachers dismissed as these are the sorts of discretionary functions for which
District is exempt.
23
Proposition IX: Plaintiffs claim for negligence regarding
appropriate care and
treatment of a minor fails to state a claim upon which relief may be
granted.
In Count III, Plaintiffs allege that Defendants were negligent in providing and rendering
appropriate care and treatment of a minor children either causing injuries to the children or after an
injury occurred. Petition at 17, Doc. No.1-1. Plaintiffs Petition fails to state any facts to support this
claim as to what District did or did not do in the way of care or treatment after the alleged incidents
(2015 M.K.D.s broken ankle which is time barred and April/May 2017 C.D.D.s hand injury). As stated
earlier in this brief, conclusions and speculations will not meet the standard of review under Rule 12(b)(6)
Fed. R. Civ. P. Plaintiff provides zero factual basis for their claim that District negligently rendered care for
or treated M.K.D. or C.D.D. after the incidents. The fact that minor children were physically injured after
the incident in no way implies that they were negligently disregarded or improperly treated at school
after the incident. See Randell v. Tulsa Ind. Sch. Dist. No. 1,1994 OK CIV APP 156, 889 P.2d 1264.
Since Plaintiffs Petition failed to provide any factual basis for their claim that Defendants were
negligent in rendering appropriate care and treatment of minors after the incidents, it is unsupported and
fails to meet the standard of review under Rule 12(b)(6) Fed.
R. Civ. P. Thus, Plaintiffs Count III claim for negligent care and treatment must be dismissed.
24
Case 5:17-cv-00974-R Document 5 Filed 09/19/17 Page LI of 76
CONCLUSION
Defendants Overholser Elementary School and Putnam City School Board are not legal entities
capable of being sued. Plaintiffs cannot maintain any federal causes of action under IDEA because they
have failed to exhaust their administrative remedies. Plaintiffs claims under Section 1983 do not state
a claim against these Defendants because Plaintiffs have not alleged any particular constitutional rights
violated and have not alleged any District custom or policy resulting in loss or damage to them.
With respect to the state law claims, this Court does not have jurisdiction over the claims that
occurred prior to April 3, 2016. There is no private right of action for alleged violation of the Child
Abuse Reporting statute. Also, Plaintiffs fail to state a defamation claim against Defendants because
reporting to DHS is a confidential and privileged communication. Further, the Defendants are immune
from liability of the remainder of the claims pursuant to several exemptions in the GTCA.
Thus, Defendants respectfully request that this Court dismiss all of Plaintiffs claims and find in
favor of Defendants.
Laura L. Holmes, OBA #14748
Laura L. Holmgren-Ganz, OBA #12342
Attorneys For Defendants
The Center For Education Law, P.C.
Telephone: (405) 528-2800
Facsimile: (405) 528-5800
E-mail: Lholmes@cfel.com
E-mail: LGanz@cfel.com
LI
Case 5:17-cv-00974-R Document 5 Filed 09/19/17 Page LII of 76
G:\PC-L\Daniels\Pldgs\Def. MTD.wpd 25
Certificate of Service
I hereby certify that on September 19, 2017 I electronically transmitted the attached document
to the Clerk of the Court using the ECF system for filing and transmittal of a Notice of Electronic filing to
the following registrants: Jeramy W. Jarman.
LII
Case 5:17-cv-00974-R Document 5 Filed 09/19/17 Page LIII of 76

ADAM DANIELS and )

KELSEY DANIELS, individually )
and as the parents and next of friend of )

C.D.D., M.K.D., and )
Plaintiffs, )
)
v. )
)
NO. (0-001) OF OKLAHOMA COUNTY )
OKLAHOMA, a political subdivision of ) The
State of Oklahoma, a/k/a )
OVERHOLSER ELEMENTARY )
SCHOOL, a/k/a Independent School )
No. 126, PUTNAM CITY )
PUTNMAN CITY SCHOOL BOARD )
Defendants. )
LIII
Case 5:17-cv-00974-R Document 5 Filed 09/19/17 Page LIV of 76
ORDER GRANTING PLAINTIFFS EXTENSION OF TIME

TO REPLY TO DEFENDANTS MOTION TO DISMISS
NOW on this 10th day of October, 2017, this matter comes on for hearing on the
Plaintiffs Unopposed Application To Enlarge Response Time to respond to Defendants
Motion to Dismiss, Document (5).
IT IS THEREFORE ORDERED, ADJUDGED AND DECREED that

the
Plaintiffs have until ten (10) days from October 9th, 2017 or until October 19th, 2017 to file
a response to the Defendants Motion to Dismiss.
IT IS SO ORDERED THIS 10th day of October, 2017.
LIV
Case 5:17-cv-00974-R Document 5 Filed 09/19/17 Page LV of 76

)
)
ADAM DANIELS and )
KELSEY DANIELS, individually )
and as the parents and next of friend of )
C.D.D., M.K.D., and )
Plaintiffs, )
)
vs. )
)
LV
Case 5:17-cv-00974-R Document 5 Filed 09/19/17 Page LVI of 76

NO. (0-001) OF OKLAHOMA COUNTY )
OKLAHOMA, a political subdivision of ) The
State of Oklahoma, a/k/a )
OVERHOLSER ELEMENTARY )
SCHOOL, a/k/a Independent School )
No. 126, PUTNAM CITY )
PUTNMAN CITY SCHOOL BOARD )
PLAINTIFFS RESPONSE TO DEFENDANTS MOTION TO DISMISS

AND BRIEF IN SUPPORT
Jeramy W. Jarman
Jarman Law Offices Jeramy

Jarman P.C.
620 N. Robinson Ave Suite 201
(405) 606-8400
(405) 601-0338(fax)
TABLE OF CONTENTS
INTRODUCTION .................................................................................................................61
STANDARD OF REVIEW ...................................................................................................61
ARGUMENT AND AUTHORITY ......................................................................................63
Response to Proposition I....................................................................................................63
Response to Proposition II ..................................................................................................63

LVI
Case 5:17-cv-00974-R Document 5 Filed 09/19/17 Page LVII of 76
Response to Proposition III.................................................................................................64
Response to Proposition IV .................................................................................................66
Response to Proposition V ..................................................................................................68
Response to Proposition VII ...............................................................................................68
Response to Proposition VIII..............................................................................................73
Response to Proposition IX .................................................................................................74
CONCLUSION ......................................................................................................................75
Certificate of Service..21
TABLE OF AUTHORITIES
Cases:
Swanson v. Bixler,
750 F.2d 810, 813 (10th Cir 1984)2
Ashcroft v. Iqbal,
556 U.S. 662, 678, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009)2
Tuffy's, Inc. v. City of Oklahoma City,
212 P.3d 1158, 2009 OK (Okla., 2009).2
Khalik v. United Air Lines,
671 F.3d 1188, 1192 (10th Cir.2012)..3 Hall v. Bellmon,
935 F.2d 1106, 1109 (10th Cir.1991)..3
Robbins v. Oklahoma,
519 F.3d 1242 (10th Cir. 2008)3
Bell Atlantic Corp. v. Twombly,

550 U.S. 544 (2007).3
Swanson v. Bixler,
750 F.2d 810, 813 (10th Cir 1984)4
Paulson v. Sternlof,
LVII
Case 5:17-cv-00974-R Document 5 Filed 09/19/17 Page LVIII of 76
2000 OK CIV APP 128 (2000)....5

Myers v. Lashley,
202 OK 14 (2002)...5, 6, 7
Kremeier v. Transitions Inc
345 P. 3d 1128 (2015).7
Kirschstein v. Haynes,
1990 OK 8 (1990)...8, 9
Garrison v. Louisiana
379 U.S. 64 (1964)...9
Baker v. McCollan,
443 U.S. 137 (1997)....11
Sauers v. Salt Lake County,
1 F.3d 1122 (C.A.10 (Utah), 1993)..11
Murell v. Ind Dist No. 1,
186 F.3d 1238 (10th Cir 1999)..12
Baker v. McCollan,
443 U.S. 137 (1979)....12
Paul v. Davis,
424 U.S. 693, 701, (1976).12
Escue v. N. Okla. College,
450 F.3d 1146, 1152 (10th Cir. 2006)....12
Gebser v. Lago Vista Indep. Sch. Dist.,
524 U.S. 274, (19980).12
Jackson v. Birmingham Bd. of Educ.,
544 U.S. 167, 173 (2005)12
Davis v Monroe Cty. Bd. Education,
526 U.S. 629 (1999).13
Greenberg v. Wolfberg,
890 P.2d 895, 1994 OK 147 (Okla., 1994)..13
LVIII
Case 5:17-cv-00974-R Document 5 Filed 09/19/17 Page LIX of 76
Uhlrig v. Harder,
64 F.3d 567 (C.A.10 (Kan.), 1995)13, 14
Medina v. City and County of Denver,
960 F.2d 1493, 1495-99 (10th Cir.1992).13, 18
Vernonia School District 47J v. Acton,
515 U.S. 646 at 652 - 653, 115 S.Ct. 2386 at 2390, 132 L.Ed.2d 564 (1995)..15
National Treasury Employees Union v. Von Raab,
489 U.S. 656, 665 - 668, 109 S.Ct. 1384, 103 L.Ed.2d 685 (1989).....15
Hoyt v. Paul R. Miller, M.D., Inc.,
1996 OK 80...16
Nunley v. Pioneer Pleasant Vale School Dist. #56,
190 F.Supp.2d 1263 (W.D. Okla., 2002)...17
Uhlrig v. Harder,
64 F.3d 567 (C.A.10 (Kan.), 1995).18
Hazlett v. Board of County Commissioners of Muskogee County,
168 Okl. 290, 32 P.2d 940 (1934)...18
Randell v. Tulsa Ind. Sch. Dist. No. 1.,
1994 OK CIV APP 156 (1994)....19 STATUTES:
Federal Rule of Civil Procedure 12(b)(6)1 10A O.S. 1-2-

102..5
10A O.S. 1-2-104..5
10A O.S. 1-1-102(A)....6
10A O.S. 1-1-105..6 10A O.S. 1-2-

101...6,8 10A O.S. 1-2-101
(B)(1)...6
20 U.S.C. 1400....10
42 U.S.C. 1983..11, 12 20 U.S.C. 1681

1688...12
Civil Rights Restoration Act of 1987.....12
42 U.S.C. 2000CC-1..15,16
LIX
Case 5:17-cv-00974-R Document 5 Filed 09/19/17 Page LX of 76
51 O.S.2001 251.15
51 O.S. 156.17
51 O.S. 157.17
Regulations:
Title 10 of the Oklahoma Administrative Code 210:35-3-1888
34 C.F.R. 300.50711
LX
PLAINTIFFS RESPONSE TO MOTION TO DISMISS
AND BRIEF IN SUPPORT
COMES NOW, the Plaintiffs, Adam Daniels and Kelsey Daniels, on behalf of the minor children, C.D.D., M.K.D., and A.A.D.,
by and through their counsel Jeramy W. Jarman, of the
Law Offices of Jeramy Jarman, P.C., submit the following Response and Brief in Opposition to Defendants, Motion to Dismiss
the Complaint. For the reasons set forth below, Plaintiffs request that this Court deny the Motion to Dismiss in its entirety and
award Attorney fees for the preparation of this Response to Plaintiffs.
INTRODUCTION
The Complaint contains page after page of detailed allegations. Under any reading of the applicable standard
requiring particularity, Adam Daniels and Kelsey Daniels, on behalf of the minor children, C.D.D., M.K.D., and A.A.D., Plaintiffs
meet and exceeds their pleading obligations. Nevertheless, Defendants, have moved to dismiss the Complaint, claiming that
the Plaintiffs, have not provided enough information. Implicitly recognizing Defendants motion is doomed under the actual
9(b) standard, Defendants instead create their own much higher evidentiary pleading standard as well as a far overly narrow
reading of much of the case law included in their Brief. Even under this standard, Plaintiffs Complaint must survive and the
Defendants motion should be denied.
STANDARD OF REVIEW
A motion under Rule 12(b)(6) merely tests the legal sufficiency of a complaint, requiring a court to construe the
complaint liberally, assume all facts as true, and draw all reasonable inferences in favor of the plaintiff. In deciding a motion
to dismiss the allegations of the complaint must be viewed in a light most favorable to the plaintiff. Swanson v. Bixler, 750
F.2d 810, 813 (10th Cir 1984).
Regarding the standard for determining whether to dismiss a claim pursuant to Federal Rule of Civil Procedure
12(b)(6), the United States Supreme Court has held: To survive a motion to dismiss, a complaint must contain sufficient
factual matter, accepted as true, to state a claim to relief that is plausible on its face. A claim has facial plausibility when the
plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the
misconduct alleged. The plausibility standard is not akin to a probability requirement, but it asks for more than a sheer
http://www.oscn.net]applications/oscn/GetCaselnformation.asp?number=CJ-2017-4751 &db=Oklahoma&submitted=true
possibility that a defendant has acted unlawfully. Where a complaint pleads facts that are merely consistent with a
defendant's liability, it stops short of the line between possibility and plausibility of entitlement to relief. Ashcroft v. Iqbal,
556 U.S. 662, 678, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009) (internal quotations and citations omitted).
Additionally, looking to Tuffy's, Inc. v. City of Oklahoma City, 212 P.3d 1158, 2009 OK (Okla., 2009) An order
dismissing a case for failure to state a claim upon which relief can be granted is subject to de novo review. When reviewing a
motion to dismiss, the Court must take as true all of the challenged pleading's allegations together with all reasonable
inferences which may be drawn from them. The purpose of a motion to dismiss is to test the law that governs the claim in
litigation, not the underlying facts. A pleading must not be dismissed for failure to state a legally cognizable claim unless the
allegations indicate beyond any doubt that the litigant can prove no set of facts which would entitle the plaintiff to relief.
Tuffy's, Inc. v. City of Oklahoma City, 212 P.3d 1158 at 1163. The burden to show the legal insufficiency of the petition is on
the party moving for dismissal. Motions to dismiss are usually viewed with disfavor under this standard, and the burden of
demonstrating a petition's insufficiency is not a light one.
Further, where the well-pleaded facts do not permit the court to infer more than the mere possibility of misconduct,
the complaint has allegedbut it has not shownthat the pleader is entitled to relief. Id. at 679, 129 S.Ct. 1937 (internal
quotations and citations omitted). Additionally, [a] pleading that offers labels and conclusions or a formulaic recitation of
the elements of a cause of action will not do. Nor does a complaint suffice if it tenders naked assertion[s] devoid of further
factual enhancement. Id. at 678, 129 S.Ct. 1937 (internal quotations and citations omitted). While the 12(b)(6) standard
does not require that Plaintiff establish a prima facie case in her complaint, the elements of each alleged cause of action help
to determine whether Plaintiff has set forth a plausible claim. Khalik v. United Air Lines, 671 F.3d 1188, 1192 (10th
Cir.2012). Finally, [a] court reviewing the sufficiency of a complaint presumes all of plaintiff's factual allegations are true and
construes them in the light most favorable to the plaintiff. Hall v. Bellmon, 935 F.2d 1106, 1109 (10th Cir.1991).
When shining a light on plausibility as referenced by the Defendants, this case is one of a unique and varied series of
facts. In compliance with Robbins v. Oklahoma, 519 F.3d 1242 (10th Cir. 2008), the claim must be one that has a reasonable
prospect of success. Additionally, the claim should include sufficient factual allegations and those depend on context
Which is dependent on the type of case. Robbins v. Oklahoma, 519 F.3d 1242 at 1248. Further, under Bell Atlantic Corp. v.
Twombly, 550 U.S. 544, a Plaintiff must allege sufficient facts to nudge their claims across the line from conceivable to
plausible. Id. At 570.
ARGUMENT AND AUTHORITY

RESPONSE TO PROPOSITION I
Denied in part and admitted in part, reference is made to Response below to Proposition IV wherein the Defendants
here attempt to stand behind the fact that the District did not incorporate any official policy that violates the 1983 rights of
the Plaintiffs. However, in the event a particular school, namely Overholser Elementary were to incorporate their own policy
which is in depth enough to be considered a policy of that school and also a custom. Then that school should most certainly
be an entity in and of themselves. Plaintiffs herein, while wronged and in a position of anguish at the hands of the
Defendants, Plaintiffs agree to a dismissal of the parties hereto aside from Putnam City Schools, Independent School District
No (0-001).
However, Plaintiffs respectively request dependent on the outcome of the Motion filed by Defendants to seek Leave of Court
to Amend the named parties in the Complaint at a time certain thereafter.
RESPONSE TO PROPOSITION II
In the light most favorable to the Plaintiff as supported by case law and referenced by the Defendants own motion,
Plaintiff A.A.D. has been subjected to repeated interrogations at the hands of DHS Child Protective Services that were
initiated by Defendants on more than forty (40) occasions. See Swanson v. Bixler, 750 F.2d 810, 813 (10th Cir 1984) In addition
to interrogations at the hands of Police and scrutiny by the very same teachers, and administrators her siblings were affected
by. The claim of A.A.D. lies parallel to the majority of those claims related to retaliation by the Defendant as well as Civil
Rights violation related to her choice of
Religion. Additionally, A.A.D. was subjected to the emotional distress caused directly by actions of the Defendants as those
actions caused a caustic and adversarial body to encroach on her person, home, and peace on more occasions than any
reasonable human would deem proper.
Furthermore, the case at bar requires a thorough evaluation of records regularly kept in the course of business by
that very weapon of convenience that Defendants used so often against these Plaintiffs. DHS maintains contact information
for countless encounters with all Plaintiffs, including A.A.D., her teachers, her principle, and even her fellow members of their
spiritual group. To deny that those things have in turn, affected A.A.D would be unjust and lack the requisite insight into the
facts and circumstances as presented in the complaint and herein.
RESPONSE TO PROPOSITION III

Defendants, in their Motion, claim that a reporting of child abuse or neglect does not create a private cause of action.
Paulson v. Sternlof, 2000 OK CIV APP 128 However, to approach this issue in such a myopic fashion would fall short of the
true meaning and language of the child abuse reporting laws of this state as well as case law related thereto. 10A O.S. 1-
2102 clearly requires the reporting to the Department of Human Services allegations of abuse or neglect. That requirement
extends to all individuals and includes a criminal penalty for the failure to report. That reporting duty though must be in good
faith and with due care as admitted by the Defendants own Motion as well as 10A O.S. 1-2-104. Further, case law on the
topic has dealt with the application of the good faith requirement on more than one occasion. In the Myers
v. Lashley, 202 OK 14 case as cited by Defendants the Oklahoma Supreme Court has relied on this portion of the statute
during their analysis. Thus, due care and good faith are requisite in order to garner protection under the immunity provided
by the same section at 10A O.S. 1-2104.
In the case at bar, the Plaintiffs allege and evidence suggests the reporting was not in good faith and was not with
due care. The Plaintiffs were subjected to over forty referrals initiated by the hand of District personnel. Such a vast number
of referrals with not one finding of any abuse or neglect on its face calls in to question the motivations and good faith nature
of the referrals themselves. The quantity of referrals in conjunction with the timing of those referrals which were made
regularly after complaints by the Plaintiffs to District personnel after the interactions with District personnel were of a
questionable nature at the very least call for a further look into the facts surrounding those referrals. DHS referrals, being of a
confidential and protected nature will need to be sought in order to provide insight into the specific persons and acts alleged.
Such records cannot be obtained absent Court Order. To dispose of the instant case before a test of good faith has been
applied to the reporting would be unjust.
In reference to the District being liable for failing to report suspected abuse by its own agent, another nurse. The
statute referenced, 10A O.S. 1-1-102(A) and 1-1-105 wherein the definitions of those who are required to report uses a
veiled look with rose colored glasses to skirt responsibility. Those definitions are not designed to remove specific groups from
responsibility to report abuse of children. Quite the opposite, the statutory scheme of the Oklahoma Childrens Code and
Child Abuse Reporting statutes are to encourage every person to report abuse. 10A O.S. 1-2-101 (B)(1) Furthermore, the
Courts of this great state have provided further information as they pertain to teachers. In Myers v. Lashley, 202 OK 14, at
558 cited by the Defendant, the Oklahoma Supreme Court laid out clear language by saying: Oklahoma's child abuse
reporting laws express the State's strong public interest in protecting children from abuse by the policy of mandatory
reporting of actual and suspected child abuse or neglect to appropriate authorities and agencies. The statutory scheme
imposes upon all health care professionals (teachers as well as all other persons) an obligation to report in good faith all
suspected instances of child abuse to the Department of Human Services. Myers v. Lashley, 202 OK 14, at 558 Emphasis
added. Teachers are not outside the penumbra of the Statutes pertinent in this case.
A teachers duty to report remains in tact. The stance taken by the Defendant here with such a narrow inference of
Statutory language would be a slippery slope toward a chilling effect on reporting of child abuse in more ways than one. This
is something the Court in Kremeier v. Transitions Inc 345 P. 3d 1128, was clear to lay out in paragraph 17: we reject
Kremeiers strict interpretation of the statute. Such an interpretation would have a chilling effect on the reporting of child
abuse, and would be clearly inconsistent with the strong public intertest, articulated by the Myers Court and by the
Legislature in protecting children from abuse. Such an interpretation would constitute an absurd reading of the statute meant
to protect children. While in the Kremeir case the Court was referencing the duty of reporting to have good faith, it is clear
that the Court has provided strong language regarding the purpose and intent of these laws.
Herein, the Defendant would have this Court operate in contradiction to the intent of the
Legislature, and public interest by limiting the duty to report and excluding teachers.
Additionally, and possibly more importantly the Defendants motion fails to recognize the Plaintiffs Petition lays out
the fact that a nurse is the individual who was alleged to have failed to report abuse. This person, in addition to the Principle,
and other staff who remain to date silent about suspected abuse are together operating as a group in a concerted effort to
both retaliate against the Plaintiffs using these DHS referrals as well as persecute the Plaintiffs based on their Religious
preferences. The nurse, teachers, and principle who all participated in the meeting had with the Plaintiffs work closely with
one another and have a vested interest to protect one
another to the detriment of the children and Plaintiffs. 10A O.S. 1-2-101 applies to each and every one of those individuals.
Even more on point may be the fact that Title 210 of the Oklahoma Administrative code for the State Department of
Education has promulgated the following found at 210:35-3-188:
210:35-3-188. Child Abuse and Neglect Hotline signs in schools
(a) Requirement to post a visible sign. Each public school in Oklahoma shall post a sign or signs, in English and Spanish,
showing the toll-free telephone number of the Child Abuse and Neglect Hotline operated by the Department of Human
Services (DHS). Sample signs in English and Spanish are available on the State Department of Education website.
Even the school Board notes a vested interest in reporting of abuse in a timely fashion. The irony in the instant case is
that this is the same duty that the District staff has stood by more than 40 times when making false allegations against the
Plaintiffs and now attempting to slide by that same duty when the table turns.
The acts of abuse were not simply those of one rogue individual in the school. In fact, the acts were perverse and
RESPONSE TO PROPROSITION IV
In some ways, yes the allegation is that District participated in Defamation against the Plaintiffs hereto through a
repeated systemic reporting of allegations to DHS in order to smear the reputation and credibility of the Plaintiffs. However,
the Motion filed by the Defendant oversimplifies the analyses and application of case law. For example, in the Kirschstein v.
Haynes, 1990 OK 8 case the Defendants rely on the principle that a privilege extends to communications related to a quasi
judicial proceeding regardless of whether they are true or false. Yet, the Defendants here fail to apprise the Court of the
necessity that the statements need to be in good faith and contemplated under serious consideration. Kirschstein v.
Haynes, 1990 OK 8 at 952. The repeated defamatory statements hereto were both retaliatory and detrimental to the
performance of the father, Adam Daniels role as leader of his religion in this State. This should be construed in the same vein
as an Arch Diocese being subjected to the exact defamatory
acts.
The elements of defamation have been met when the facts of the allegation are construed in a light most favorable
to the Plaintiff. The allegations were false, they were not privileged under the applicable case law, they were negligent and
those statements or reports caused damage to the Plaintiffs herein on multiple levels. Furthermore, the statements or
reports were in reckless disregard as to the veracity of the statements as considered in Garrison v. Louisiana 379 U.S. 64 as
also quoted by the Defendants. Most certainly a high degree of probable falsity exists when reports are made and unfounded
on near forty occasions against one family.
Regarding the scope of employment issues at hand. The case presented today is distinguished from those highlighted
by the Defendants by the tacit and broad-based actions of the School, and District. This was not the act of a rogue teacher, or
principal, or school nurse. These were acts perpetrated by countless staff members including teachers, nurses, principals,
administrators and even a confrontation with one of the schools custodians. Such a widespread series of actions removes
this from an analysis of the good or bad faith of the actors as individuals and through such pervasive and broad patterned
events highlights the liability of the District itself. The ratification of such acts by so many individuals here should not go
unrecognized and should be classified as a consortium of malicious acts against the Plaintiffs.
In the case law provided by the Defendants the Courts analysis of acting in the scope of employment to include
actions that were in good faith and within the duties of the employment.
When looking to provide clarity of those duties we look to the policies and practices of the
District Defendant itself. Such practices and policies need not be official and printed in a book. Yet, acceptance of practices
can be so pervasive as to create an environment of support of those very acts. Such is the case at bar, where countless actors
have repeatedly violated the rights of the Defendants through retaliation, as well as persecution simply based on their
religious practices. Sadly again, the children in the case have suffered the most acute and ubiquitous injuries of all named
Plaintiffs while in the care of those entrusted to protect and educate them.
Through their actions and ratifications of actions, the District knew such acts and reports were being committed and
it was foreseeable that the actions and reports would continue in to the future and result in further deprivation of Plaintiffs
good name and Constitutionally protected rights. The District should be held responsible for the cohort of actors that it
perfused.
RESPONSE TO PROPOSITION V
The Defendants have provided substantial case law to provide guidance regarding the applicability of the Individuals
with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The body of laws that make up IDEA and supporting case law
related to the exhaustion of administrative remedies as referenced by the Defendants motion are simply inapplicable. The
Plaintiffs here complained, complained again, complained again and yet again. Each complaint was met with DHS visiting
their home and Police knocking on their door demanding entry and demanding to rifle through their dwelling as well as
interrogate the entire family on countless occasions. These Plaintiffs have met their burden of exhaustion of administrative
remedies a few times over even as plead. Plaintiffs sought out assistance from teachers, then the nurse, the principle,
administrators and at each level of their request for assistance the result was the same. Perverse abuse of their homestead
by the very system quoted by the Defendants in their IDEA guise, sending the ever valiant DHS operatives to investigate yet
another false or misleading claim against the parents who are Plaintiffs here. This has lead to a litany of Civil Rights Violations
under 1983 and other areas of law. Had there been a Due Process Hearing or an adequate handling of the complaints by
these Plaintiffs, quite possibly the instant action could have been avoided. 34 C.F.R. 300.507
Furthermore, any view of the allegations of the complaint also should consider that the Plaintiffs herein complied
with the Notice Requirements of the GTCA. More than ninety (90) days prior to the filing of the action in State District Court
notice of the claims laid out in the petition were provided via certified mail to the Defendants. No response was seen from
the Defendants. Despite yet another complaint where the Defendants could have made some sort of response. Other than
sending another state agency as a bully to pressure the plaintiffs further that
is.
RESPONSE TO PROPOSITION VI
A claim under 42 U.S.C. 1983 is as mentioned, is in essence the enforcement of vindication of federal rights
conferred by the United States Constitution and federal statutes. Baker v. McCollan, 443 U.S. 137. (1979) The case law
history and statutory language interpretation is immense and historic. However, the cases relied upon and authority relied
upon by the Defendant each show that the Motion filed here is premature. Those cases, by vast majority are after fact
finding, discovery and many even a trial on the merits have been conducted. See as provided by Defendants Baker v.
McCollan, 443 U.S. 137. (1979), Sauers v.
Salt Lake County, 1 F.3d 1122 (C.A.10 (Utah), 1993), et al. Cases such as this as well as the case here are fact intensive and any
analysis of the proper classification of the actions of the Defendants and whether or not those acts were officially promulgated
rules or a well settled custom or practice of the District. It is not feasible to determine the existence of custom or practice
when looking to the actions of these Defendants absent Discovery and a thorough evaluation of the evidence obtained. Murell
v. Ind Dist No. 1, 186 F.3d 1238 (10th Cir 1999)
Further, the Due Process Clause should be interpreted to impose federal duties that are analogous to those
traditionally imposed by state tort law, see, e.g., id., at 332-333, 106 S.Ct., at
665-666; Baker v. McCollan, 443 U.S. 137, 146, 99 S.Ct. 2689 2695, 61 L.Ed.2d 433 (1979);
Paul v. Davis, 424 U.S. 693, 701, 96 S.Ct. 1155 1160, 47 L.Ed.2d 405 (1976).
Sexual Discrimination and Retaliation

Those Constitutional and federal rights are expansive, for example Sexual Discrimination under 20 U.S.C. 1681
1688, Plaintiff's claims under 42 U.S.C. 1983 and Title IX of the
Educational Amendments of 1972, as amended by the Civil Rights Restoration Act of 1987, 20 U.S.C. 1681 et seq, is a
specific body of law that provides a claim to damages and compensation for actions of school districts. "Sexual harassment is
a form of discrimination on the basis of sex and is actionable under Title IX." Escue v. N. Okla. College, 450 F.3d 1146, 1152
(10th Cir. 2006). A private cause of action for monetary damages may be awarded for the deliberate indifference to a
teacher's sexual harassment of a student against a school district that receives federal funds. Gebser v. Lago Vista Indep. Sch.
Dist., 524 U.S. 274, 290-91 (1998); see also Jackson v. Birmingham Bd. of Educ., 544 U.S. 167, 173 (2005).
Analogous, in the case at hand we have a perverse and lengthy perpetration of students and all the while the District
has used DHS as a shielded to insulate its own liability and conceal the actions of its own personnel.
Additionally the scope of the protections afforded the student are important here. See
Davis v Monroe Cty. Bd. Education, 526 U.S. 629, 119 S.Ct. 1661 involving a violation of the Equal Protection Clause of the
Fourteenth Amendment by the School Districts failing to protect the student. Therein, the District, principal and teachers
violated the Due Process Clause of the Fourteenth Amendment by failing to protect the plaintiff from the perpetrator.
Similarly, here as above we have a case involving a failure to protect under a related doctrine.
Abuse Of Process
Less direct, yet should be considered, Abuse of process claims under 1983 are another angle of liability as
applicable here. Those cases again are vast and the legal interpretations lengthy. See Greenberg v. Wolfberg, 890 P.2d 895,
1994 OK 147 (Okla., 1994). The Oklahoma Supreme Court has set out the elements which must be established to state a claim
for abuse of process. These elements are: "(1) the improper use of the court process (2) primarily for an ulterior improper
purpose (3) with resulting damage to the plaintiff asserting the misuse." Greenberg v. Wolfberg, 1994 OK 147, 22, 890 P.2d
895, 905 (footnotes omitted). The Defendants herein have made more than forty attempts to push the Plaintiffs into a
litigious situation using the DHS complaint and Deprived Docket of the District Court. This is the essence of the claim of DHS
being used as a weapon of convenience against the complaining Plaintiffs.
Creation of Danger Doctrine and Retaliation

The facts also as alleged provide protection under the penumbra of having created a danger where the Plaintiffs were
exposed to. Under, Uhlrig v. Harder, 64 F.3d 567 (C.A.10 (Kan.), 1995) A state also may be liable for an individual's safety under
a "danger creation" theory if it created the danger that harmed that individual--that is, provided that the other elements of a
Sec. 1983 claim have been satisfied. See Medina v. City and County of Denver, 960 F.2d 1493, 1495-99 (10th Cir.1992)
(explaining that police officers who engaged in a high speed car chase could be liable for creating a special danger faced by a
bicyclist, but were protected in that case by their shield of qualified immunity). The classic case of state actors creating a
danger so as to give rise to Sec. 1983 liability is Wood v. Ostrander, where police officers placed plaintiff in danger by
impounding her car and abandoning her in a high crime area at 2:30 a.m., thereby "distinguish[ing] Wood from the general
public and trigger[ing] a duty of the police to afford her some measure of peace and safety." 879 F.2d 583, 589-90 (9th Cir.1989),
cert. denied, 498 U.S. 938, 111 S.Ct. 341, 112 L.Ed.2d 305 (1990).
Further on that topic, Uhlrig v. Harder, 64 F.3d 567 (C.A.10 (Kan.), 1995) However, many state activities have the
potential for creating some danger--as is true of most human endeavors--but not all such activities constitute a "special" danger
giving rise to Sec. 1983 liability. For the state to be liable under Sec. 1983 for creating a special danger (i.e. where a third party
other than a state actor causes the complained of injury), a plaintiff must allege a constitutionally cognizable danger. That is,
the danger creation theory must ultimately rest on the specifics of a substantive due process claim--i.e. a claim predicated on
reckless or intentionally injury-causing state action which "shocks the conscience." As explained by the Fifth Circuit in Leffall v.
Dallas Indep. Sch. Dist., "it is not enough to show that the state increased the danger of harm from third persons; the [Sec.]
1983 plaintiff must also show that the state acted with the requisite degree of culpability in failing to protect the plaintiff." 28
F.3d 521, 531 (5th Cir.1994). In that case, an additional examination of the facts required a degree of conscience shocking"
behavior or acts. Similarly, in the instant case before this Court, the allegations and facts alleged are shocking to rise to the
level requisite therein. Repeated strip searches and, an intentional cover up of the abusive acts of teachers using another state
agency as a weapon against the complaining party is shocking on many levels. That fact combined with the actions of other
students, from which teachers did not protect the Plaintiffs from and even participated in calls for this case to move forward
into the fact finding portion of the claim, surviving this portion of the Motion to Dismiss.
Fourth Amendment
Yet another view of the facts as presented here call to question whether the Fourth Amendment of the United States
Constitution has been violated. In the event the M.K.D. was strip searched by school officials in an effort to improperly and
without probable cause search for anything of use to them, these acts should be considered a violation of her Fourth
Amendment Rights against unreasonable search and seizure. Given, if the facts are construed in the light most favorable to the
Plaintiffs, those actions were both a search and a seizure under the massive body of law that supports such claims. A "search"
is governed by Fourth Amendment principles of reasonableness. Vernonia School District 47J v. Acton, 515 U.S. 646 at 652 -
653, 115 S.Ct. 2386 at 2390, 132 L.Ed.2d 564 (1995). As applied here, any search and seizure of the body of M.K.D or, C.D.D is
not supported by a warrant, probable cause, or individualized suspicion. As the Supreme Court has held, however, neither
a warrant, nor probable cause, nor any measure of individualized suspicion is an indispensable component of reasonableness
in every circumstance. Vernonia, supra; National Treasury Employees Union v. Von Raab, 489 U.S. 656, 665 - 668, 109 S.Ct.
1384, 103 L.Ed.2d 685 (1989).
First Amendment and Religious Discrimination to include Retaliation

Lastly, the broadly construed First Amendment of the United States Constitution brings to bear on the instance case a claim of
Discrimination based on the Plaintiffs religious practices. Under 42 U.S.C. 2000CC-1, et seq, and the Oklahoma Religious
Freedom Act (ORFA), 51
O.S.2001 251, et seq the Plaintiffs are to be afforded free reign to practice what religion they so choose. Hoyt v. Paul R.
Miller, M.D., Inc., 1996 OK 80, 921 P.2d 350, 351-52. That Courts review of the statutory language is included herein: Title
42 U.S.C. 2000cc-1 states in relevant part:
(A) General rule
No government shall impose a substantial burden on the religious exercise of a person residing in or confined
to an institution... even if the burden results from a rule of general applicability, unless the government
demonstrates that imposition of the burden on that person
(1) is in furtherance of a compelling governmental interest; and
(2) is the least restrictive means of furthering that compelling governmental
interest.
(B) Title 51 O.S.2001 253 provides:
A. Except as provided in subsection B of this section, no governmental entity shall substantially burden
a person's free exercise of religion even if the burden results from a rule of general applicability.
B. No governmental entity shall substantially burden a person's free exercise of religion unless it
demonstrates that application of the burden to the person is:
1. Essential to further a compelling governmental interest; and
2. The least restrictive means of furthering that compelling governmental interest. As applied
to the facts presented herein, the Districts actions in making use of DHS as an investigative and harassing weapon
against the Plaintiffs was deep seated in the disdain for the Plaintiffs public participation in an alternative Religion.
The Petition alleges and facts presented supports countless statements by school personnel as well as DHS personnel
and Law Enforcement during their visits and interrogations with the Plaintiffs that relate to their practice of religion.
This right was infringed upon by the teachers, nurse, principal and administrators in an egregious fashion. However,
further information is necessary in regards to this claim as well.
RESPONSE TO PROPOSITION VII
In response to the claim that this action is time barred we encourage the Court to look to the Statute of Limitations
on those actions see: Nunley v. Pioneer Pleasant Vale School Dist. #56, 190 F.Supp.2d 1263 (W.D. Okla., 2002). Wherein, the
statute of limitations is tolled until the removal of a Disability. Two of the plaintiff children two of which are permanently
disabled. The duty was owed to those Plaintiffs and the Disability remains intact. Furthermore, the acts of the District in this
case, having occurred over a period of years, were not discovered until more recently that these were the actions of the
District against their interests and rights they pursue to enforce with this action. Any review of the Statute provided by the
Defendant here at 51 O.S. 156 should also include a glance at 51 O.S. 157 where the GTCA for Oklahoma clearly provides
that a lack of response within ninety (90) is a denial of claim and affords the Plaintiff the right to file suit as is the situation
here.
In the event that the Court should apply a time line bar to events prior to a certain date, the actions post that date
should still be considered supported by the Petition and survive the Motion to Dismiss. However, that date is one that
remains as of yet uncertain based on the tolled state of at least two of the Plaintiffs as well as what actions may remain
colorable by the
Plaintiffs.
RESPONSE TO PROPOSITION VIII

Reference is made above to the response to Proposition VI wherein several bodies of law are labeled and levelled as
claims supported by the Petition in this case. In order to peer into the allegations of a safe environment we need first to assess
the evidence to be provided. That aside, the case at hand involves more than Discretion from the District. Truitt v. Diggs, 611
P.2d 633, 635. A narrow view of those cases regarding discretion lacks a grasp of the facts as presented in this case. In fact,
from above, the facts also as alleged provide protection under the penumbra of having created a danger where the Plaintiffs
were exposed to. Under, Uhlrig v. Harder, 64 F.3d 567 (C.A.10 (Kan.), 1995) A state also may be liable for an individual's safety
under a "danger creation" theory if it created the danger that harmed that individual--that is, provided that the other elements
of a Sec. 1983 claim have been satisfied. See Medina v. City and County of Denver, 960 F.2d 1493, 1495-99 (10th Cir.1992)
(explaining that police officers who engaged in a high speed car chase could be liable for creating a special danger faced by a
bicyclist, but were protected in that case by their shield of qualified immunity). 6 The classic case of state actors creating a
danger so as to give rise to Sec. 1983 liability is Wood v. Ostrander, where police officers placed plaintiff in danger by
impounding her car and abandoning her in a high crime area at 2:30 a.m., thereby "distinguish[ing] Wood from the general
public and trigger[ing] a duty of the police to afford her some measure of peace and safety." 879 F.2d 583, 589-90 (9th Cir.1989),
cert. denied, 498 U.S. 938, 111 S.Ct. 341, 112 L.Ed.2d 305 (1990).
The next portion of the Defendants motion addresses Negligent Supervision and retention of teachers. The case law
presented fails to recognize that the claim here is that the District knowingly employed, trained, and supervised personnel
who were sublimely negligent in the dealing with and treatment of the Plaintiff children. Such as in Hazlett v. Board of
County Commissioners of Muskogee County, 168 Okl. 290, 32 P.2d 940 (1934).
In Hazlett, the Supreme Court of Oklahoma upheld the furtherance of that action for want of good faith on the part of
the defendant. The facts as alleged show sufficiently that bad faith was a factor in many of the claims above. Hence,
removing the discretion approach preferred under the GTCA by the Defendants in their brief.
Even so, the participation of the teacher in abuse of a child in the classroom by subjecting that child to stimulus that
amounts to terror and having that teacher support other students in their performing the same terrorizing acts should not be
veiled and is a clear indication of lack of supervision along with a lack of a safe environment.
RESPONSE TO PROPOSITION IX
Count III of the Petition does claim negligence in providing and rendering appropriate care and treatment of a minor
child either causing injuries to the children or after an injury occurred. The allegation is two fold, first that an injury was
sustained and treatment and care was not provided on more than one occasion. The factual basis for that claim is what was
seen by the parents to these children. On several occasions injuries were present on a child and when questioned about the
cause of those injuries there is no explanation. As provided in the Petition those injuries were as severe as broken bones and
the list of injuries is long as the timeline is long. There was further no treatment provided when those injuries occur despite
multiple and frequent interactions with the school nurse as plead. The injuries were disregarded and in compliance with
Randell v. Tulsa Ind. Sch. Dist. No. 1, 1994 OK CIV APP 156, the District should be liable for such actions.
Additionally, the frequent strip searches at the hands of the nurse and as supported by the principle, teachers and
administrators who participated in the IEP meetings is clearly negligent care and treatment of the child Plaintiff. Although it
should be noted that the Petition also details the mistreatment of both Autistic children referenced. Not simply by
malfeasantly not providing treatment, but through the abusive application of tactics in the classroom that were ratified and
supported by the principal and other members of the IEP team as previously plead.
CONCLUSION
The case at bar is a David vs. Goliath scenario. The Defendants have pursued very early on this Motion to Dismiss. However,
the facts as known by the Plaintiffs are limited, yet compelling nonetheless, and only a small portion of what should be available
to them. It would be a travesty of justice to dismiss the instant action prematurely prior to the proverbial Pandoras Box being
opened. It just so happens that the District and DHS maintain dominion of the key to that box and it is only with the aid of the
Court in such a proceeding as this that David may find his stone and the Plaintiff may gain access to that within the box.
WHEREFORE, PREMISES CONSIDERD, Plaintiffs above named, having fully answered and refuted the Motion to Dismiss filed
by the Defendants, do hereby request the Court to deny the Motion To Dismiss and award costs of the response to this Motion
to Plaintiffs.
By: /s/ Jeramy W. Jarman

Jeramy W. Jarman OBA #20508
Of the Firm:
THE LAW OFFICES OF

JERAMY JARMAN PC.
620 N. Robinson Avenue, Suite 201
Phone: 405-606-8400
Fax: 405-601-0338
Attorney for Plaintiffs
CERTIFCATE OF SERVICE
I hereby certify that on the 19th day of October, 2017, I electronically transmitted the above document to the Clerk of
Court using the ECF System for filing. Based on the records currently on file, the Clerk will transmit a Notice of Electronic Filing
to the following ECF registrants:
Laura L. Holmes
Laura L. Holgren-Ganz
The Center for Education Law, Inc.
Telephone (405) 528-2800
Fax line (405) 528-5800
E mail- Lhomes@cfel.com
Lganz@cfel.com
/s/ Jeramy W. Jarman

Jeramy W. Jarman OBA #20508

The Daniels&#39; Family vs. Putnam City School District

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The Daniels&#39; Family vs. Putnam City School District

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J/

JS44 (Rev. 06/17) CIVIL COVER SHEET

790 Other Labor Litigation O 895 Freedom of Information

DATE SIGNATURE OF ATTORNEY OF RECORD

09/11/2017 s/Laura L. Holmgren - Ganz

FOR OFFICE USE ONLY

RECEIPT AMOUNT APPLYING IFP JUDGE MAG. JUDGE

IN THE UNITED STATES DISTRICT COURT

ADAM DANIELS and

INDEPENDENT SCHOOL DISTRICT, ) Case No. CIV-17-

Defendants, Independent School District No. (0-001) ofOklahoma County,Oklahoma,

In support of removal, Defendants submit the following:

Court of Oklahoma County, Oklahoma, alleging defamation, negligence, and violation of

2. Defendants were served with a summons on August 21, 2017. Exhibit 2

attached. Exhibit 3 - District Court Docket Sheet.

7. The undersigned counsel of record affirmatively represents that a copy of this

County pursuant to 28 U.S.C.

I hereby certify that on September I l , 2017 1 electronically transmitted the

coryms NOW the Plaintiff(s), ADAM DANELS and KELSEY DANIELS,

individually and as the parents and next friend of C.

D, and A , minor children, for their cause of against

Defendant(s) alleges and states as follows:

litigation, residents of Oklahoma County, State of Oklahoma.

2. Defendant, Independent School Dis&ict No. (1-001) of Oklahoma County, Oklahoma,

Pumam City Schools, Overholser Elementary School a.k.a. Independent School

"District"), is a political subdivision of the State of Oklahoma and operates

public schools in Oklahoma County, Oklahoma.

3. The Defendant, District, is a public school conducting business in Oklahoma County,

5401 Northwest 40th Street, Warr Acres, Oklahoma 73122-3302. Therefore,

venue is proper in Oklahoma County.

as Exhibit "A"). Defendants failed to respond giving rise to this action.

Rights of the Plaintiffs.

Plaintiffs pracdcing an alterave non-Christian based a fact the

teacher and other students under supervision ofthe teacher.

from the Disfrict.

to provide immediate and proper care for the injury sustained.

COUNT 11 - 1983 VIOLATIONS

as menfioned above themselves. On or about mid April 2016, Mr.

the detriment ofdlis child and the Plaintiffs.

Plainffs and discouraged futher complaints from the Plaintiffs.

well as physical pain and suffering.

District on noce of such negligent acts.

children from harassment, bullying, and harm to the children.

based primarily on their beliefs.

WFEREFORE, Plaintiffs respectfully requests judgnent against the Defendant,

INDEPENDENT SCHOOL DISTRICT., 2017- 4751

Issued on August Q, 2017.

IN THE DISTRICT COURT IN AND FOR OKLAHOMA COUNTY, OKLAHOMA

Daniels, Adam , Plaintiff

Attorney Represented Parties

Jarman, Jeramy(Bar # 20508) D.

Event Party Docket Reporter

Date Code Count Party Serial # Entry Date

08-21-2017 OTHER 92374120 Aug 21 2017 Realized

08-21-2017 DMFE 92374121 Aug 21 2017 Realized

08-21-2017 PFEI 92374122 Aug 21 2017 Realized $

08-21-2017 PFE7 92374123 Aug 21 2017 Realized

08-21-2017 OCISR 92374124 Aug 21 2017 Realized $

08-21-2017 OCJC 92374125 Aug 21 2017 Realized

08-21-2017 OCASA 92374126 Aug 21 2017 f)07Arvl Realized

08-21-2017 SSFCHSCPC 92374127 Aug 21 2017 Realized

08-21-2017 CCADMINCSF 92374128 Aug 21 2017 Realized

08-21-2017 CCADMINOI 55 92374129 Aug 21 2017 Realized

Date Code Count Party Serial # Entry Date

08-21-2017 DCADMIN155 92374131 Aug 21 2017 Realized

08-21-2017 DCADMlN05 92374132 Aug 21 2017 Realized

08-21-2017 DCADMINCSF 92374133 Aug 21 2017

The Daniels' Family vs. Putnam City School District

The Daniels' Family vs. Putnam City School District