FW: Stern - Response to 12/9/15 Public Records Request

Frank Upchurch <fdupchurch@ubulaw.com>

To: "grantstern@gmail.com" <grantstern@gmail.com>
Cc: "Christina H. Langston" <Christina.Langston@stjohns.k12.fl.us>

Fri, Dec 11, 2015 at 10:45 AM

From: Cindy Strickland

Sent: Friday, December 11, 2015 10:43 AM
To: Frank Upchurch <fdupchurch@ubulaw.com>
Subject: Stern - Response to 12/9/15 Public Records Request

Dear Mr. Stern:

The Community Relations Department asked me to assist in responding to your public records request dated
December 9, 2015.
1.
I am advised that outside counsel incurred 6.9 hours in regard to the preparation and filing
of the complaint. This time has not yet been billed to the District and the District does not have any
responsive documents.

2.
Outside counsels engagement letter is enclosed. Outside counsel was initially engaged to
defend the public records lawsuit that Mr. Gray brought against the District. Mr. Gray dismissed that
lawsuit with prejudice on December 4, after being served with a Florida Statute 57.105 frivolous claim
notice. Although not requested, pleadings in that initial lawsuit are enclosed.

3.
I have incurred 9.7 hours through December 9 in connection with the preparation and filing
of the December lawsuit. My firm advanced $453.00 for filing and service fees. Such time and costs
have not been billed and there are no responsive documents.

4.
On December 4, the Superintendent made the decision to file suit against Mr. Gray.
Unfortunately, Mr. Grays dismissal of his lawsuit earlier that day did not mark the end of his
provocative and disruptive actions toward the District. On December 3, the day after the San
Bernandino shootings, Mr. Gray was seen by school officials acting in a suspicious and provocative
manner, cruising in his van slowly back and forth past two schools. On December 4, Mr. Gray
harassed bus drivers for records at a school, just as he had done at the Maintenance Department in
the case he filed and lost. The Superintendent authorized counsel to file suit against Mr. Gray to
enjoin him from continuing to disregard District public records procedures and from continuing to
harass the District and its employees, thereby interfering with employees doing their assigned jobs
and disrupting District operations. The School Board members were individually advised of that
decision before suit was filed on Monday, December 7. There are no responsive documents.

Please feel free to contact me if you have any questions.

Frank D. Upchurch III
Upchurch, Bailey & Upchurch, PA

Post Office Drawer 3007

St. Augustine, Florida 32085-3007
Telephone # (904) 829-9066
Fax # (904) 825-4862
Email: fdupchurch@ubulaw.com
Website: www.ubulaw.com

Documents in response to PRR.pdf

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