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8. Petitioner has demonstrated a likelihood of success on the merits of his claims, including
violations of procedural due process, retaliation for protected First Amendment activity,
and interference with constitutionally protected parental rights.
9. The balance of equities favors Petitioner, as he seeks only narrow relief to preserve
access to his children鈥檚 access to education, and Respondents have offered no
justification for the continued denial and scope of access.
10. Petitioner affirms that he will refrain from entering the Newport News Public Schools
administration building during the pendency of this action and seeks only access
necessary to perform essential parental functions.
WHEREFORE, Petitioner respectfully requests that the Court:
A. Issue a temporary injunction prohibiting Respondents from enforcing the April 14, 2025,
temporary property ban as it applies to student pickup and drop-off at;
B. Issue a temporary injunction prohibiting Respondents from initiating or enforcing any
further disciplinary action, exclusion, or permanent ban arising from the April 4, 2025
incident or related protected activities, until this matter is resolved.
C. Require Respondents to provide a written process for parental access during the pendency of
this litigation; and
D. Grant such other relief as the Court deems just and proper.
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