Matthew DeCossas Suit

7/26/2019 Matthew DeCossas Suit

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UNITED STATES DISTRICT COURTEASTERN DISTRICT OF LOUISIANA

Elizabeth Z. DeCossas, Individually) CIVIL ACTION

& as Tutrix for Matthew DeCossas, )And Ronald DeCossas ) NO. 2:16-cv-03786)

versus ) Section (G)(5))

St. Tammany Parish School Board; )Bryon Gerchow; Kevin R Darouse; W. )L.Trey Folse III; Leonard Tridico) Judge N. BrownNeal M. Hennegan; Peter J. Jabbia; )Michael Astague )___________________________________) Mag. M. North

PETITION FOR MULTIPLE VIOLATIONS OF CIVIL RIGHTS

NOW INTO COURT, through undersigned counsel, come

Elizabeth DeCossas , Mother of, and Tutrix of the minor

child, Matthew DeCossas; and Ronald DeCossas, Father of

Matthew DeCossas and hereinafter state their claims against

Defendants for violations of their respective civil rights

and violations of 42 U.S.C. 1983 as follows:

Elizabeth DeCossas, a person of the full age of

majority and a resident citizen of St. Tammany Parish

Louisiana was at all times the Natural Mother and tutrix of

minor, Matthew DeCossas, who at all times relevant to these

proceedings, was sixteen years of age and attended,

pursuant to Louisianas mandatory attendance law,

Case 2:16-cv-03786-NJB-MBN Document 1 Filed 04/29/16 Page 1 of 19


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Fontainebleau High School, a public high school operated by

employees, staff, and management employed by and under the

control of the St. Tammany Parish School Board, a semi-

autonomous governmental body operating under the auspices

and regulations of St. Tammany Parish, the Louisiana

Legislature, the Louisiana State School Board authority and

the Board of Elementary and Secondary Education.

Ronald DeCossas at all times relevant to this cause,

was a person of the full age of majority and a resident

citizen of St. Tammany Parish Louisiana and was the natural

father of Matthew DeCossas, to whom he had loaned his own

personal cell phone which he had locked, pass-coded, and

encrypted for security and privacy protection secured

herein by the First Fourth, and Fifth Amendments of the

United States Constitution made applicable to the states by

the Fourteenth Amendment.

Additional Defendants to the Civil Rights violation

alleged infra. are:

a) Deputy Bryan Gerchow, a citizen of St. Tammany

Parish, employee of the St. Tammany Parish Sheriffs

Department commissioned a deputy thereof, and on loan

to and under the immediate supervision and control of

the defendant, the St. Tammany Parish School Board at

Fountainebleau High School;



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b) Kevin R. Darouse, citizen of St. Tammmany, and

Supervisor of Administration for St. Tammany School

Board, charged, as in this case, with providing

initial unbiased due process hearings on disciplinary

charges;

c) W.L. Trey Folse, III, citizen of St. Tammany

Parish and currently supervisor of St. Tammany Parish

Scool Board;

d) Leonard Tridico, citizen of St. Tammany Parish

and employee of the St. Tammny School Board as alleged

chief disciplinarian and investigator at

Fountainebleau High Scool;

e) Neal M. Hennegan, citizen of St. Tammany Parish

and elected member of St. Tammany School Board;

f)

Peter J. Jabbia, citizen of St. Tammany, employed

as assistant school supervisor in supervisor in charge

of civil rights;

g) Michael Astague, citizen of St. Tammany, employee

of St. Tammany School Board as Assistant Principal at

Fountainebleau, and charged with liaison with

disciplinary investigation and processing and other

employees charged with investigations or charges;

Plaintiffs have exhausted their administrative

remedies, such as they were, and in fact Plaintiffs were



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never accorded with any real rights; or with any real due

process procedures or hearings conforming to that

procedural and substantive due process guaranteed under the

U.S. Constitution and Bill of Rights, and made applicable

to states and their subdivisions under the Fourteenth

Amendment. Although Louisianas legislature had made a

feeble attempt to comply with their constitutional

obligations in passing LSA R.S. 17:416, that statute is

weak, ambiguous and contains no objective standards for

implementation, so St. Tammany School Board intentionally

perverted the legislative intent to implement its own

policy which is guaranteed to block compliance with

Constitutional due process in any form preventing citizens

from having any contradictory hearings; having assistance

of counsel; having any venue for making objections to basic

violations of a citizens inherent legal rights; and is

carefully conducted by Defendant school board and its

employees to support only the School Boards position with

hearings closed to participation except for school board

officials, and does not permit the citizens such as

plaintiffs here, to speak, to object, have counsel

participate, raise constitutional violations or offer

evidence on their behalf. All hearings are a sham; so

called appeals are an opportunity for the school board to



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further, honestly or dishonestly, perpetuate its own

position meaning that School Board affairs are conducted in

a one sided star chamber closed meeting, and all those

made defendants herein know and fully well know that their

conduct of disciplinary matters do not comply with basic

rights, constitutional or legal requirements, and are

perpetrations of extreme illegalities by those serving as

public servants.

I.

First Cause of Action

I.

Plaintiffs contend that on 8th January 2016 that 16

year old U, S, Citizen, Matthew DeCossas, for whom

Elizabeth DeCossas was legal tutrix, arrived on campus of

Fouintainebleau High School and was immediately ordered to

the office of defendant Leonard Tridico, and although

Matthew DeCossas was a good student with no prior

disciplinary problems, Tridico, in the presence of Bryan

Gerchow, the Defendant Deputy Sheriff, without either

notifying the minors legal guardian or reading him his

Miranda warning proceeded to forcibly and threateningly

interrogate him and search Matthew DeCossas and all his

personal, private, constitutionally protected effects



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without any credible evidence to support such invasive and

illegal search and interrogation.

II.

Notwithstanding that the initial illegal detainment

and forcible search of the minor on 8thJanuary 2016 by the

defendant sheriffs deputy, Gerchow, and defendants Tridico

and Astague found absolutely nothing. These defendants

continued to illegally hold DeCossas, and seized his

fathers, Ronald DeCossas cell phone which contained

constitutionally protected data and information and it was

not until these defendants threatened and illeglly forced

Matthew to unlock his fathers cell phone was Matthew

DeCossas permitted to return to his next class, having been

improperly and illegally detained and falsely imprisoned by

the School Boards representatives.

Tridico and Astague illegally seized the cell phone

belonging to Matthews father, Ronald DeCossas, doing so

without notifying the owner of the cell phone or notifying

the minors legal guardian, or obtaining a court order all

in violation of the U. S. Constitution, the First and Fifth

Amendments; and the States laws and constitution. Tridico

and Astague also improperly and illegally detained Matthew

in their offices after the clean search of all of Matthews



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effects for further unlawful detention and there

threatened, extorted, and forced Matthew DeCossas without

legal authority or cause into unlocking his fathers cell

phone which his father had instructed him never to do,

thereby violating his fathers and Matthews right to their

personal privacy and due process in violation of their

clear rights under the First, Fourth and Fifth Amendments,

made applicable to states and their subdivisions under the

Fourteenth Amendment. Defendants usurped all proper

authority under color of law, and illegally made no effort

to notify Matthews legal tutrix, or the actual owner of

the phone, Ronald DeCossas, and did not seek a court order

based on reasonable cause, although that would have been

the legal, prudent and responsible course of action by non-

judicial governmental representatives rather than resorting

to threats, torture, force, illegal extended detention, and

extortionate threats of a minor child, by persons such as

these defendants who clearly have no such legal authority

over any citizen of the United States.

III.

After having threatened immediate force and summary

punishment against Matthew DeCossas, illegally and

unconstitutionally scaring him into unlocking Ronald

DeCossas cell phone thereby violating their First and



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Fifth Amendment rights to privacy and their rights to

procedural and substantive due process, Defendants Tridico

and Astague had access to and illegally perused the

entirety of the owners confidential data privately held on

the phone, leading Defendants Tridico, Astague, and Gerchow

to allege there witnesses who were also threatened by

Tridico, Astague, and Gerchow also threatened by force and

extortion into agreeing to make irrelevant, fabricated, and

untimely allegations against Matthew DeCossas; and although

the initial invasion of the data on the cell phone was

illegal, they commenced further improper, forced

interrogations of Matthew DeCossas pursuing the fruit of

the forbidden tree, being that data from the illegally,

unconstitutionally, breached data from Plaintiffs private,

confidential, constitutionally protected information

contained on the cell phone; and without use of which the

Defendants would have had no evidence of any kind or any

support for disciplinary claims to mount against Matthew

DeCossas, since the initial interrogation and search that

same day was entirely negative for actionable evidence.

IV.

Defendants Tridico, Astague, and Gerchow called

DeCossas back and willfully and in maximum bad faith,

conducted another unauthorized, illegal, forced detention



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and forced interrogations without the minor child, Matthew

DeCossas having been advised about any of his legal rights

or provided any opportunity for even a phone call; read his

Miranda warnings required due to the potential charges of

drug use/possession; and again his tutrix, Elizabeth

DeCossas was not advised of the Defendants illegal

activities and interrogations.

Tridico, Astague, and Gerchow dictated at least three

different statements that they then forced the

unprotected and unrepresented minor to unwillingly write in

his own hand and then threatened and forced him to sign,

even though they were inherently contradictory and did not

match any true facts or evidence beyond some contrived

scenarios from fruit of the forbidden tree using names

and other data discovered only upon the rifled cell phone

as an alleged theoretical basis of facts from which they

fabricated their accusations.

Elizabeth DeCossas was not advised of any of the

illegal activities conducted by and on behalf of the St.

Tammany School Board by the other Defendants until after

the multiple, illegal interrogations, searches, invasion of

Ronald DeCossas protected cell phone data, the forced

statements until late in the afternoon when the School

Board and its employees believed that they had locked in



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their version, advised the tutrix of Matthew DeCossas

that he had been recommended for expulsion on disciplinary

and drug allegations and alleged possession, neither of

which was supported except by concocted, contrived, or

illegally obtained evidence. Plaintiffs will show that

the Defendants have a long history of abusive behavior,

threats, intimidations, extortions, falsification of facts

and statements, persecutions and violations of minor

students civil rights; and their parents civil rights all

of which is known, condoned, encouraged, and hidden by the

defendants and the St. Tammany Parish School Board despite

complaints directed to them.

V.

On 14th January 2016 the St. Tammany Parish School

Board, and the other Defendants herein, including

particularly Leonard Tridico, Michael Astugue, Kevin

Darouse, et. al. held a hearing, supposedly pursuant to LSA

R.R. 17:416 but the hearing was a poor imitation of the

requirements of the Louisiana statute in that the

Plaintiffs herein were denied any opportunity to have

counsel, present evidence, call or examine witnesses, make

objections based on constitutional violations, or object to

the gross one-sided nature in which only the Defendant

School Board employees stated unfounded opinions and



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illegal evidence based on illegally obtained and

constitutionally protected information allegedly linked to

Ronald DeCossas locked cell phone which had been forced

open thru threats and intimidation through repeated long

term detention of a minor by Defendant Tridico and

Defendant Sheriffs Deputy Gerchow against an undefended

and unrepresented child. The hearing was a sham even under

the Louisiana law and did not even attempt to provide

procedural and substantive due process and at its

conclusion, the hearing officer, Defendant Kevin R. Derouse

was observed by attendees to pull his previously prepared

and signed decision in favor of the School Board and the

ordered expulsion for four semesters, from the bottom of

his papers to present as his decision based on the

evidence he had heard during the hearing.

VI.

Plaintiff, Elizabeth DeCossas determined that an

appeal could be taken to the School Board and noticed an

appeal to the Defendant School Board in a timely fashion,

although employees of Defendant School Board advised her

that the notice date was much later and if filed at that

time, an appeal on this matter would have been untimely and

dismissed.



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Defendant School Board scheduled an appeal for

Plaintiffs which was conducted by St, Tammany Parish School

Board on 18th February 2016, and again contrary to the

Louisiana Statute demanding fair and just contradictory

hearings providing procedural and substantive due process,

Defendant, Peter Jabbia, ran the supposed fair appeal to

exclude any objections to procedure or validity of any

evidence, refused to permit Counsel to participate, heard

only a recitation of already discreditedand recanted,

unconstitutionally obtained illegal evidence, refused to

permit Plaintiffs to participate in any fashion, and it was

the intention of the School Board and Peter Jabbia to

permit School Board and its members to repeatedly

interrogate the minor, Matthew DeCossas, procedurally

unprotected, simply for the purpose of corroborating the

School Boards and the other Defendants previous illegal

and unconstitutional actions in clear violation of

Plaintiffs legal rights and constitutional protections as

guaranteed by law to persons and protected under 42 U.S.C.

Section 1983. School Board and other Defendants were

guilty of clear, overt, willful and bad faith violations of

Plaintiffs rights. In addition, Defendant School Member,

Neal M. Hennegan, a non-lawyer blatantly and willfully

threatened, harassed, and intimidated Plaintiffs, and



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their attorney, in telling them from the dais during

session at the appeal hearing that the School Board had

never lost a case in court, and that Plaintiffs were

getting bad legal advice if they were counseled to file

suit in court.

VII.

Petitioners are entitled to, and seek redress under

Section 1983, and request appropriate orders of this Court,

enjoining the St. Tammany Parish School Board and its

employees, school officials gone lawless, rogue and wild

acting under color of law, including the individual

Defendants named herein as specific actors in the detailed

account of violations; from further prejudicial or other

unconstitutional disciplinary action against Matthew

DeCossas based upon the alleged events leading to his

expulsion from school; an order that all records or

references to Matthew DeCossas or any reports or

disciplinary action concerning same be expunged from all

records, and especially his school records and driver

training records; that the expulsion be reversed and he be

returned to where he should have been before lawlessness,

thuggery, and overzealousness on the part of Defendants

intervened to damage and forever destroy his reputation and



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that of his parents; an admonition to Defendants that such

gross violations of a citizens constitutional rights will

not be tolerated; and a Judgment of this Court under

Section 1983 awarding substantial monetary damages to

Plaintiffs for the willful and abusive violations of rights

and civil rights guaranteed to citizens including

Plaintiffs by the U.S. Constitution and made applicable to

these Defendants by the Fourteenth Amendment including, but

not limited to, extreme emotional distress, subjection to

public embarrassment and humiliation, disruption of

Plaintiffs lives, punitive damages and attorney fees

needlessly incurred by Plaintiffs in defending against

willful bad faith disciplinary actions under color of law,

unconstitutional policy and procedures intentionally and

willfully violative not only of the U.S. constitution, and

Section 1983, but of Louisianas own constitution and

statute LSA R.S. 17:416 which Defendants willfully and

intentionally ignored, implementing instead a contrary

procedure which Defendants completely controlled like a

Star Chamber procedure designed to provide no required

notice, procedural or substantive due process for citizens

and Plaintiffs, and likewise intentionally and willfully in

bad faith blocking Plaintiffs access to and guaranteed

right to assistance of counsel at all stages of the



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disciplinary process. Plaintiffs also seek in judgment any

and all further equitable or legal relief implicit in or

appropriate from the facts or existing law.

VII.

The expulsion of Matthew DeCossas for four semesters

was irrational, personally subjective, excessive, and

unequal to other action taken by the same persons in

similar situations including the alleged co-perpetrator of

the alleged triggering event, who has now recanted and

admits that Astague, Tridico, and Gerchow threatened and

eventually forced him thru unlawful detentions, threats,

and verbal assaults, into capitulating to Defendants

accusations that were wholesale fabrications by Defendants

and comprised clear violations of his fundamental civil

rights through unequal protection of the law and subjective

punishment.

II.

SECOND CAUSE OF ACTION

I.

As an alternative cause of action against the

individual and collective Defendants enumerated herein,

separate and apart from their allegations and demands for

relief under the Civil Rights Act,42 U.S.C. Section 1983,

Plaintiffs are entitled to recover against them for their



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repetitive, willful, and intentional violations of

Plaintiffs civil rights as specified in the above and

foregoing allegations, which are incorporated herein by

reference thereto as if copied verbatim and en extenso.

Plaintiffs demand relief and a judgment against the St.

Tammany School Board and the named Defendants to the same

extent as prayed for within the First Cause of Action.

II.

Plaintiffs reiterate their individual and collective

demands for the various judgments, civil and equitable

relief, and damages as prayed for in the First Cause above.

III.

Plaintiffs request trial by jury on all issues in both

the first and second causes of action.

Respectfully submitted,

/s/ Fred E. Salley_____________________________FRED E. SALLEY, T.A. (11665)SALLEY & ASSOCIATESP.O. Box 354977378 Hwy 1081 Cretien AnnexCovington, Louisiana 70434

Telephone: (985) 867-8830Facsimile (985) 867-8927

Counsel for all Plaintiffs,Elizabeth DeCossas, et. al.



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SERVICES

Services by Certified Mail:

St. Tammany Parish School Board

321 Theard Str.Covington, La. 70434

Deputy Bryan GerchowFountainebleau High School100 Bulldog DriveMandeville, LA. 70471

Kevin R. DarouseSt. Tammany Parish School Board321 Theard Str.Covington, La. 70434

W.L. Trey FolseSt. Tammany Parish School Board321 Theard Str.Covington, La. 70434

Leonard TridicoFountainebleau High School100 Bulldog DriveMandeville, LA. 70471

Neal M. Henegan410 Magnolia LaneMandeville, LA. 70471

Peter J. JabbiaSt. Tammany Parish School Board321 Theard Str.Covington, La. 70434

Michael AstagueFountainebleau High School

100 Bulldog DriveMandeville, LA. 70471



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VERIFICATION

STATE OF LOUISIANA

PARISH OF ST. TAMMANY

Before me, the undersigned authority and notary public

for the Parish and State aforesaid, personally came and

appeared before me:

Elizabeth Zalot DeCossas

Who upon being placed under oath verified that she is a

citizen and major person residing in St. Tammany Parish and

the mother and Tutrix of Minor, Matthew DeCossas;

That she is a Plaintiff in the proposed civil action

being filed against the St. Tammany Parish School Board,

et. al;

That she has read the contents, claims and allegations

contained in that aforesaid complaint and that they are

true and correct to the best of her knowledge, information,

and belief.

________________________Elizabeth Zalot DeCossas

Signed before me, Notary PublicSt. Tammany Parish, Louisiana

This ____ day of April, 2016

_____________________________

My Commission is thru________



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VERIFICATION

STATE OF LOUISIANA

PARISH OF ST. TAMMANY

Before me, the undersigned authority and notary public

for the Parish and State aforesaid, personally came and

appeared before me:

Ronald DeCossas

Who upon being placed under oath verified that he is a

citizen and major person residing in St. Tammany Parish and

the father of Minor, Matthew DeCossas;

That he is a Plaintiff in the proposed civil action

being filed against the St. Tammany Parish School Board,

et. al;

That he has read the contents, claims and allegations

contained in that aforesaid complaint and that they are

true and correct to the best of his knowledge, information,

and belief.

________________________Ronald DeCossas

Signed before me, Notary Public

St. Tammany Parish, LouisianaThis ____ day of April, 2016

_____________________________

My Commission is thru________



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JS 44 Reverse (Rev. 11/15)

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as

required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is

required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk o

Court for each civil complaint filed. The attorney filing a case should complete the form as follows:

I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, u

only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency andthen the official, giving both name and title.

(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides attime of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In lan

condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)

(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noin this section "(see attachment)".

II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.

United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.

United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.

Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendm

to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code tak

precedence, and box 1 or 2 should be marked.

Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the

citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversitycases.)

III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Marksection for each principal party.

IV. Nature of Suit. Place an "X" in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI belowsufficient to enable the deputy clerk or the statistical clerk(s) in the Administrative Office to determine the nature of suit. If the cause fits more th

one nature of suit, select the most definitive.

V. Origin. Place an "X" in one of the six boxes.Original Proceedings. (1) Cases which originate in the United States district courts.

Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.

When the petition for removal is granted, check this box.Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the fili

date.

Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.

Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers o

multidistrict litigation transfers.

Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. Section 140

When this box is checked, do not check (5) above.

VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictionstatutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service

VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.

Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.

VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docketnumbers and the corresponding judge names for such cases.

Date and Attorney Signature. Date and sign the civil cover sheet.

Case 2:16-cv-03786-NJB-MBN Document 1-1 Filed 04/29/16 Page 2 of 2


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AO 398 (Rev. 01/09) Notice of a Lawsuit and Request to Waive Service of a Summons

UNITED STATES DISTRICT COURTfor the

__________ District of __________

)

))))

Plaintiffv. Civil Action No.

Defendant

NOTICE OF A LAWSUIT AND REQUEST TO WAIVE SERVICE OF A SUMMONS

To:(Name of the defendant or - if the defendant is a corporation, partnership, or association - an officer or agent authorized to receive service)

Why are you getting this?

A lawsuit has been filed against you, or the entity you represent, in this court under the number shown above.A copy of the complaint is attached.

This is not a summons, or an official notice from the court. It is a request that, to avoid expenses, you waive formalservice of a summons by signing and returning the enclosed waiver. To avoid these expenses, you must return the signed

waiver within days (give at least 30 days, or at least 60 days if the defendant is outside any judicial district of the United States)

from the date shown below, which is the date this notice was sent. Two copies of the waiver form are enclosed, along witha stamped, self-addressed envelope or other prepaid means for returning one copy. You may keep the other copy.

What happens next?

If you return the signed waiver, I will file it with the court. The action will then proceed as if you had been servedon the date the waiver is filed, but no summons will be served on you and you will have 60 days from the date this noticeis sent (see the date below) to answer the complaint (or 90 days if this notice is sent to you outside any judicial district ofthe United States).

If you do not return the signed waiver within the time indicated, I will arrange to have the summons and complaintserved on you. And I will ask the court to require you, or the entity you represent, to pay the expenses of making service.

Please read the enclosed statement about the duty to avoid unnecessary expenses.

I certify that this request is being sent to you on the date below.

Date:Signature of the attorney or unrepresented party

Printed name

Address

E-mail address

Telephone number

Eastern District of Louisiana

Elizabeth Z. Decossas, et. al.

St. Tammany Parish School Board, et. al

16:3786

St. Tammany Parish School Board, 321 Theard Str., Covington, LA. 70434

30

05/09/2016 /s/ Fred E. Salley

Fred E. Salley

P.O. Box 3549Covington, LA. 70434

[email protected]

504-450-3880



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__________ District of __________

)

))))


Defendant








What happens next?






Printed name

Address

E-mail address

Telephone number




16:3786

Kevin R. Darouse, 321 Theard Str., Covington, LA. 70434

30


Fred E. Salley


[email protected]

504-450-3880



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__________ District of __________

)

))))


Defendant








What happens next?






Printed name

Address

E-mail address

Telephone number




16:3786

W.L."Trey" Folse, 321 Theard Str., Covington, LA. 70434

30


Fred E. Salley


[email protected]

504-450-3880



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__________ District of __________

)

))))


Defendant








What happens next?






Printed name

Address

E-mail address

Telephone number




16:3786

Peter Jabbia, 321 Theard Str., Covington, LA. 70434

30


Fred E. Salley


[email protected]

504-450-3880



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__________ District of __________

)

))))


Defendant








What happens next?






Printed name

Address

E-mail address

Telephone number




16:3786

Neal M. Hennegan, 410 Magnolia Lane, Mandeville, LA. 70471

30


Fred E. Salley


[email protected]

504-450-3880



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__________ District of __________

)

))))


Defendant








What happens next?






Printed name

Address

E-mail address

Telephone number




16:3786

Deputy Bryan Gerchow, Founainebleau Hish School, 100 Bulldog Drive, Mandeville, LA. 70471

30


Fred E. Salley


[email protected]

504-450-3880



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__________ District of __________

)

))))


Defendant








What happens next?






Printed name

Address

E-mail address

Telephone number




16:3786

Leonard Tridico, Founainebleau Hish School, 100 Bulldog Drive, Mandeville, LA. 70471

30


Fred E. Salley


[email protected]

504-450-3880



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__________ District of __________

)

))))


Defendant








What happens next?






Printed name

Address

E-mail address




16:3786

Michael Astague, Founainebleau Hish School, 100 Bulldog Drive, Mandeville, LA. 70471

30


Fred E. Salley


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504 450 3880


Matthew DeCossas Suit

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