UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA

TALLAHASSEE DIVISION

JAMI CLAIRE et al.,

Plaintiffs,

vs. Case No. 4:20-cv-00020-MW/MAF 

FLORIDA DEPARTMENT OF 

MANAGEMENT SERVICES et al., 

Defendants.

_______________________________/

PLAINTIFFS’ UNOPPOSED MOTION FOR LEAVE TO FILE REPLY TO 

DEFENDANTS’ RESPONSE TO PLAINTIFFS’ SUPPLEMENTAL BRIEF 

Pursuant to Federal Rule of Civil Procedure 27(a)(4) and Local Rule

7.1(I), Plaintiffs hereby move for leave to file a short Reply to Defendant’s 

Response (ECF 183) to Plaintiffs’ Supplemental Brief (ECF 182). Plaintiffs 

are prepared to file their Reply within seven days of the Court’s granting of 

this motion.

Plaintiffs believe this Court would be benefited by a Reply because

Defendant’s Response is the first filing in which Defendant has raised the 

argument that Congress has not abrogated the states’ Eleventh Amendment 

immunity under Title VII, and the first time Defendant has asked this Court to 

employ a “congruence and proportionality analysis.” (ECF 183, at 8-15). 

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Plaintiffs have addressed Eleventh Amendment immunity only with regard to 

the Equal Protection claims, which Defendant Allende raised and briefed

(ECF 125, at 33-34), but Defendant Allende is no longer party to this case 

and Plaintiffs’ Equal Protection claims against Defendant Allende were 

dismissed. However, this defense was never briefed by Defendant DMS nor 

with regard to Plaintiffs’ Title VII claims, and Plaintiffs seek to respond to this 

new argument.

Additionally, Plaintiffs seek to clarify a misstatement by Defendant 

regarding the personal benefit conferred upon Plaintiff Lane by the Court’s 

granting of permanent injunctive relief in this case. (ECF 183, at 4-8). 

Respectfully submitted on this 15th day of October, 2024.

/s/ Simone Chriss 

SIMONE CHRISS 

Fla. Bar No. 124062

simone.chriss@southernlegal.org

JODI SIEGEL 

Fla. Bar No. 511617

jodi.siegel@southernlegal.org

Southern Legal Counsel, Inc.

1229 NW 12th Avenue

Gainesville, FL 32601

(352) 271-8890

DANIEL TILLEY

Fla. Bar No. 102882

dtilley@aclufl.org

Case 4:20-cv-00020-MW-MAF Document 184 Filed 10/15/24 Page 2 of 4
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CAROLINE MCNAMARA

Fla. Bar No. 1038312 

cmcnamara@aclufl.org

ACLU Foundation of Florida

4343 West Flagler St., Suite 400, 

Miami, FL 33134

(786) 363-2714

ATTORNEYS FOR ALL PLAINTIFFS

JEFFREY HEARNE

Fla. Bar No. 512060

jhearne@legalservicesmiami.org

JOCELYN ARMAND

Fla. Bar No.44264

jarmand@legalservicesmiami.org

Legal Services of Greater Miami, Inc.

4343 W Flagler Street, Suite 100

Miami, FL 33134

(305) 438-2403

ATTORNEYS FOR PLAINTIFF 

MURPHY 

CERTIFICATE OF WORD COUNT

Pursuant to N.D. Loc. R. 7.1(F), I certify this Motion for Leave to File a 

Reply to Defendants’ Response to Plaintiffs’ Supplemental Brief (ECF 183) 

contains 233 words, which includes headings, footnotes, and quotations, but 

does not include case style, signature block or Certificates of Word Count 

and Service.

/s/ Simone Chriss

Counsel for Plaintiffs

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CERTIFICATE OF SATISFATION OF

ATTORNEY CONFERENCE REQUIREMENT

Pursuant to Local Rule 7.1(B), counsel for the Plaintiffs conferred with

counsel for the Defendant on October 14, 2024. Counsel for Defendant 

indicated that Defendant does not oppose the relief sought.

/s/ Simone Chriss

Counsel for Plaintiffs

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