IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF PENNSYLVANIA 

MARIA C., a minor, by and through her parent : CIVIL ACTION 

and natural guardian, IRIS NEREIDA CAMACHO : 

 :

 v. :

 :

THE SCHOOL DISTRICT OF PHILADELPHIA : NO. 02-4336 

DEFENDANT’S OBJECTION TO PLAINTIFFS’ 

REPLY AND SUPPLEMENTAL FILINGS

Defendant School District of Philadelphia (the “District”) by its undersigned attorney 

hereby objects to and respectfully requests this Honorable Court to disregard Plaintiffs’ filings 

with the Court subsequent to Defendant’s Response filed on October 29, 2003, and in support 

thereof states as follows: 

1. In response to the Order of Court dated October 1, 2003, Plaintiff filed on October 

10, 2003, “Plaintiff’s Response to Court’s Order for Plaintiffs’ Attorney’s Final Hours Expended 

on Behalf of Maria C.” (Doc. No. 19), and later on October 20, 2003 – more than the ten days 

permitted by the Order – Plaintiffs filed papers titled “Plaintiffs’ Completed Record and Factual 

Narrative” (Doc. No. 20). 

2. On October 29, 2003, the District complied with the Court’s Order by filing 

“Defendant’s Response in Opposition to Plaintiffs’ Final Statement of Plaintiffs’ Claim for 

Attorneys’ Fees and Expenses” (Doc. No. 21). 

3. On November 3, 2003, without leave of Court or consent of the Defendant, 

Plaintiffs filed “Plaintiffs’ Response to Defendant’s Memorandum of Law in Opposition to 

Plaintiffs’ Final Claim for Attorneys’ Fees and Completed Record in Support Thereof” (Doc. 

No. 22). 

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4. On November 25, 2003, also without leave of Court or consent of the Defendant, 

Plaintiffs filed “Plaintiff’s Attorney’s Updated Final Hours Expended on Behalf of Maria C.” 

(Doc. No. 23). 

5. Plaintiffs’ filings of November 3, 2003 (supra, para. 3) and November 25, 2003 

(supra, para. 4) violate F.R.C.P. Rule 15(a) and 15(d) because Plaintiffs did not obtain leave of 

court through a motion, or the District’s written consent, to amend or supplement their statement 

and explanation of October 20, 2003 (supra, para. 1). The November filings are clearly not 

permitted by the Court’s Order of October 1, 2003, which made absolutely no provision for 

filings subsequent to the District’s Response that was filed on October 29, 2003. 

6. The District hereby incorporates by reference as though fully set forth herein the 

argument in Section II (C) (1) of its Response in Opposition to Plaintiffs’ Final Statement of 

Plaintiffs’ Claim for Attorneys’ Fees and Expenses (supra, para. 2). 

WHEREFORE, Defendant School District of Philadelphia requests this Honorable Court 

to disregard Plaintiffs’ filings with the Court subsequent to Defendant’s Response filed on 

October 29, 2003. 

 RESPECTFULLY SUBMITTED, 

/s/ C. Reginald Johnson

 C. REGINALD JOHNSON, ESQUIRE 

 Assistant General Counsel 

 School District of Philadelphia 

 Office of General Counsel 

 2130 Arch Street, 5th Floor 

 Philadelphia, PA 19103-1390 

 (215) 299-7676 

 

Attorney for Defendant, 

 School District of Philadelphia 

Dated: November 26, 2003

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CERTIFICATE OF SERVICE

I hereby certify that the attached Defendant’s Objection to Plaintiffs’ Reply and 

Supplemental Filings has been filed electronically on November 26, 2003, and is available for 

viewing and downloading from the ECF system and that counsel for plaintiffs has consented to 

electronic service: 

justluisesq@att.net 

Luis P. Diaz, Esquire 

1118 Lombard Street, Suite 5 

Philadelphia, PA 19147 

Attorney for Plaintiffs 

 /s/ C. Reginald Johnson 

 C. Reginald Johnson, Esquire 

 Assistant General Counsel 

 Attorney for Defendant, 

 School District of Philadelphia 

Dated: November 26, 2003

Case 2:02-cv-04336-JF Document 24 Filed 11/26/2003 Page 3 of 3