Lennox S. Hinds, Esq. (NY Bar 8196) 

STEVENS, HINDS & WHITE, PC 

116 West 111th Street 

New York, NY 10026-4026 

Telephone: (212) 864-4445 

Facsimile: (212) 222-2680 

lawfirmshw@yahoo.com 

 

Counsel for Plaintiff Sherrie Russell-Brown 

IN THE UNITED STATES DISTRICT COURT FOR THE 

DISTRICT OF NEW JERSEY 

---------------------------------------------------------X 

SHERRIE RUSSELL-BROWN, : 

 : 

 Plaintiff, : Civil Action No. 2:10-cv-04017-SDW-MCA 

v. : 

 : 

THE UNIVERSITY OF FLORIDA, : RETURN OF SERVICE EXECUTED

BOARD OF TRUSTEES, : 

THE UNIVERSITY OF FLORIDA, : 

LEVIN COLLEGE OF LAW, : 

ROBERT H. JERRY, II, in his : 

individual and official capacities as : 

Dean of the University of Florida, : 

Levin College of Law, THE : 

UNIVERSITY OF OXFORD, : 

OXFORD UNIVERSITY : 

DEVELOPMENT (NORTH AMERICA), : 

INC., ALM MEDIA, LLC, WILLIAM : 

L. POLLAK and KAREN SLOAN, : 

 : 

Defendants. : 

 : 

---------------------------------------------------------X 

 LENNOX S. HINDS hereby certifies and says: 

1. I am a partner in the law firm of Stevens, Hinds & White, P.C., attorneys for Plaintiff 

Sherrie Russell-Brown in the above-captioned matter. I am personally familiar with the facts set 

forth herein. 

2. On August 5, 2010, Ms. Russell-Brown filed a Complaint (Doc. 1) for declaratory, 

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injunctive and equitable relief, as well as monetary damages, to redress Defendants’1

 unlawful 

conduct, including their unlawful retaliation for Ms. Russell-Brown having engaged in and continuing 

to engage in protected activity, in violation of the Civil Rights Act of 1866, 42 U.S.C. § 1981 

(“Section 1981”), Title IX of the Education Amendments of 1972, 20 U.S.C. §§ 1681 et seq. (“Title 

IX”), Title VI of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000d et seq. (“Title VI”), and the First, 

Fifth and Fourteenth Amendments to the U.S. Constitution pursuant to 42 U.S.C. § 1983. 

3. Service of process of the Summons and Complaint upon Defendant Oxford was 

effected by two methods. On August 13, 2010, service of process of the Summons and Complaint 

upon Oxford was effected by delivering a copy of each by UPS, signature required, directly to its 

executive offices in the U.K. (Doc. 4). On August 24, 2010, service of process of the Summons and 

Complaint upon Oxford was effected by delivering two copies of each by UPS, signature required, to 

CT Corporation, 1209 Orange Street, Wilmington, Delaware 19801, for directing to Oxford 

University Development (North America), Inc. (file # 2182294) (“Oxford NA”) and Oxford 

University Press (file # 0791971) (“OUP”), as agents authorized by appointment or by law to receive 

service of process on Oxford’s behalf (Doc. 8, ¶ 3, Exhibit A). 

4. On August 31, 2010, Ms. Russell-Brown filed an Amended Complaint (Doc. 7), 

adding new facts as well as a new defendant, Oxford NA (collectively, with Oxford, referred to as the 

“Oxford Defendants”). 

5. On September 2, 2010, service of process of the Summons and Amended Complaint 

upon Defendant Oxford NA was effected by delivering a copy of each by UPS, signature required, to 

CT Corporation, 1209 Orange Street, Wilmington, Delaware 19801, an agent authorized by 

appointment or by law to receive service of process (Doc. 8, ¶ 5, Exhibit B). 

 

1 Jointly and severally, the University of Florida Board of Trustees (“UF”), the University of Florida, Levin College of 

Law (“Levin College of Law”), Robert H. Jerry, II (“Jerry”), in his individual and official capacities as Dean of the Law 

School (collectively, the “Gainesville Defendants”), and the University of Oxford (“Oxford”).

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6. Service of process of the Amended Complaint upon Defendant Oxford was effected 

by three methods. On August 31, 2010, service of process of the Amended Complaint upon Oxford 

was effected by electronically serving a copy to its attorneys, using the CM/ECF system. On 

September 2 and 3, 2010, service of process of the Amended Complaint upon Oxford was effected, 

respectively, by delivering two copies by UPS, signature required, to CT Corporation, 1209 Orange 

Street, Wilmington, Delaware 19801, for directing to Oxford NA and OUP, as agents authorized by 

appointment or by law to receive service of process on Oxford’s behalf and by delivering a copy by 

UPS, signature required, directly to its executive offices in the U.K. (Doc. 8, ¶ 6, Exhibit C). 

7. On September 24, 2010, Ms. Russell-Brown filed a First Amended Complaint (Doc. 

20), adding new facts regarding retaliation by the Gainesville and Oxford Defendants, subsequent to 

the filing of the Amended Complaint, as well as new defendants, ALM Media, LLC, William L. 

Pollak and Karen Sloan (collectively, the “Media Defendants”). 

8. On September 24, 2010, service of process of the First Amended Complaint upon the 

Oxford Defendants was effected by electronically serving a copy to their attorneys, using the 

CM/ECF system. 

9. By September 27, 2010, counsel for the Media Defendants was authorized to accept 

service and by September 29, 2010, service of process of the Summonses and First Amended 

Complaint was effected on the Media Defendants. 

10. Undersigned counsel for Ms. Russell-Brown and counsel for the Media Defendants 

agreed to an enlargement of time of 45 days, for the Media Defendants to respond to Ms. RussellBrown’s First Amended Complaint. 

11. On November 24, 2010, in response to the Oxford and Media Defendants’ Motions 

to Dismiss, filed October 8, October 12 and November 15, 2010 (Docs. 24, 26 and 36, respectively), 

Ms. Russell-Brown filed a Second Amended Complaint (Doc. 39) against all of the Defendants. 

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12. On November 24, 2010, service of process of the Second Amended Complaint upon 

the Oxford and Media Defendants (supra paragraphs 4 and 7) was effected by electronically serving a 

copy to their attorneys, using the CM/ECF system. 

13. By November 30, 2010, counsel for the Gainesville Defendants (supra note 1), Mr. Ian 

Marx, Esq., was authorized to receive service on his clients’ behalf and on November 30, 2010, 

service of process of the Summonses and Second Amended Complaint was effected on the 

Gainesville Defendants. 

14. Mr. Marx and undersigned counsel for Ms. Russell-Brown have agreed to an 

enlargement of time of 60 days, until January 28, 2011, for the Gainesville Defendants to respond to 

Ms. Russell-Brown’s Second Amended Complaint. 

 I hereby certify and declare, under penalty of perjury, under the laws of the United States of 

America that the foregoing information contained in the Return of Service Executed is true and 

correct. 

s/ Lennox S. Hinds

Lennox S. Hinds, Esq. 

New York Bar No. 8196 

Stevens, Hinds & White, PC 

116 West 111th Street 

New York, NY 10026-4206 

(212) 864-4445 

(212) 222-2680 (fax) 

lawfirmshw@yahoo.com 

Executed on: November 30, 2010 

 New York, New York 

 

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on November 30, 2010, the foregoing has been filed with the 

Clerk of the Court and served electronically by using the CM/ECF system, upon the following: 

Zoë Eva Jasper, Esq. 

SATTERLEE STEPHENS BURKE & BURKE LLP 

33 Wood Avenue South 

Iselin, New Jersey 08830 

212-818-9200 

zjasper@ssbb.com 

Attorneys for Defendants the University of Oxford and Oxford University Development (North America), Inc. 

Bruce Rosen, Esq. 

MCCUSKER, ANSELMI, ROSEN & CARVELLI, P.C. 

210 Park Avenue, Suite 301 

P.O. Box 240 

Florham Park, New Jersey 07932 

BRosen@marc-law.com 

973-635-6300 

Attorneys for Defendants ALM Media, LLC, William L. Pollak and Karen Sloan 

s/ Lennox S. Hinds

Lennox S. Hinds 

 Attorney for Plaintiff 

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