ELECTRONICALLY FILED

Washington County Circuit Court

Kyle Sylvester, Circuit Clerk
2018-Jul-24 14:34:21
72CV-18-1805
C04D01 : 2 Pages

IN THE CIRCUIT COURT OF WASHINGTON COUNTY, ARKANSAS

CIVIL DIVISION

JANE DOE PLAINTIFF

v. CASE NO.: 72CV-18-1805

FAYETTEVILLE PUBLIC SCHOOLS

a/k/a FAYETTEVILLE SCHOOL
DISTRICT DEFENDANT

MOTION TO SEAL RECORD

COMES NOW, Plaintiff JANE DOE, by and through her attorneys, Clark Law Firm,

PLLC, and for her Motion to Seal, states as follows:

1. Jane Doe has lodged her Complaint in this Circuit Court, praying for Declaratory

Judgment and Injunctive Relief.

2. In order for the Court to make a determination in this matter, the records at issue

must be provided, and the parties counsel must be permitted to discuss them openly with the Court.

3. Absent an order sealing the record, any records provided or arguments made to the

Court would be a matter of public record, which would effectively nullify any opportunity to

protect the privacy of Jane Doe and for the Court to provide the requested relief.

4. Plaintiff therefore respectfully requests that the Court permit her to provide the

records at issue in this cause to the Court under seal, and further to close any hearing on the matter,

so counsel may openly discuss the records with the Court.

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 WHEREFORE, Plaintiff, Jane Doe, prays this Court Grant her Motion to Seal Record, for

her costs and attorney’s fees, and for all other relief to which she may be entitled.

ATTORNEY FOR PLAINTIFF JANE DOE

By: ___/s/Suzanne G. Clark_________________

Suzanne G. Clark, ABA #2008126
CLARK LAW FIRM, PLLC
244 West Dickson Street, Suite 201
PO Box 4248
Fayetteville, Arkansas 72702-4248
Tel: 479-856-6380
Fax: 479-856-6381
Email: sclark@clark-firm.com

CERTIFICATE OF SERVICE

I, Suzanne G. Clark, certify that on this 24th day of July, 2018, that I electronically filed
the foregoing pleading with the Clerk of the Court using the Court’s eFlex system, which shall
provide notification of the filing to counsel of record below:

Missy McJunkins Duke

Cross. Gunter, Witherspoon & Galchus. P.C.
500 President Clinton Ave, Suite 200
Little Rock, AR 72201
Email: Mduke@cgwg.com

__/s/ Suzanne G. Clark__________

Suzanne G. Clark

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