instruction:
Given a document, generate a short title of the document. The title should convey the main idea/event/topic about which the document is being written. Note that URLs in the text have been replaced with [Link].
question:
MIAMI --  Tropical Storm Philippe  is approaching extreme southern Florida as it continues to dump heavy rain on central Cuba and the Bahamas.
The center of  Philippe  is expected to move across the northwestern Bahamas Sunday morning.
 Philippe 's maximum sustained winds are near 45 mph  with higher gusts.
Some strengthening is forecast during the next 48 hours. However   Philippe  is expected to become a post-tropical cyclone on Monday.
answer:
Tropical Storm Philippe heads toward southern Florida


question:
Even though the most recent deaths come nearly a month after the facility was evacuated   attorney Bill Dean  who is representing several of the surviving patients   said a good attorney will argue that the conditions immediately after the storm  as well as the evacuation  led to the deaths.  He  said the nursing home should be held responsible for any other deaths in the near future.
"I think it's tragic  I think it's sad  " Dean  said. "All of this was preventable by the nursing home."
 Dean  said  he 's concerned the patients might see little money in civil cases.  He  added that  he 's worried that even if the 145 patients or their family members were to win lawsuits against the facility  there wouldn't be enough money to pay the damages.
"Ultimately those cases would be worth pennies on the dollar "  Dean  said.
answer:
2 More Dead from Florida Nursing Home That Lost AC in Irma


question:
Police busted  Michael Cognato   35  on Thursday for violating an order of protection barring him from any contact with the student.
 Cognato  is accused in the original October case with sending the girl naked pictures and at least 15 videos of  himself  masturbating between August and October.
 He  had taught the teen while she was in eighth grade at Intermediate School 93 in Ridgewood and the two remained in contact when she went on to high school.  Cognato  tutored the teen and often contacted her via Facebook messaging and Skype  officials said.
 He  soon began sending explicit photos of  himself  and convinced the teen to send  him  back naked pictures of herself  cops said.
In October police charged  Cognato   of Bethpage  L.I.  with using a child in a sexual performance  promoting a sexual performance by a child and acting in a manner injurious to a child after the teenâs mother contacted cops.
Education Department officials said  Cognato  began working as a teacher at IS 93 in 2001.  He  has no previous disciplinary history.
After  his  arrest   he  was taken out of IS 93 and transferred to a central Education Department office for administrative duties. Meanwhile  Education Department officials began the process of taking  him  off the payroll.
answer:

Teacher busted for contacting student after sending her nude pics