Pasco v. Zimmerman et al

Filing 25

Brief / Memorandum in Opposition re 9 Brief / Memorandum in Support, 8 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM of Defendant Zimmernan. filed by Robert L. Pasco.

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF VIRGINIA
Harrisonburg Division
ROBERT L. PASCO,
Plaintiff,
v.
HANK ZIMMERMAN, et al.,
Defendant.

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CIVIL ACTION NO. 5:11cv00087-MFU

PLAINTIFF’S MEMORANDUM IN OPPOSITION TO DEFENDANT ZIMMERMAN’S
MOTIONS TO DISMISS UNDER RULE 12(b)(6)

The plaintiff Robert L. Pasco (“Pasco”), by counsel, and pursuant to Rule 12(b)(6) of the
Federal Rules of Civil Procedure, submits his Memorandum in Opposition to Defendant
Zimmerman’s Motions to Dismiss, and shows the Court as follows:
I.

Introduction and Facts.
The defendant Hank Zimmerman (hereinafter the “Zimmerman”) asserts in his Motion to

Dismiss that all of the claims against him should be dismissed. Pasco opposes the Defendant
Zimmerman’s Motion because the Defendant Zimmerman ignores the import of many of the facts
alleged in Pasco’s Complaint, and because Pasco has stated cognizable official and individual
capacity claims, as well as state law claims, against him under the plausibility standard of review.
Pasco served as the Director of the Shenandoah County Library from January 1, 2002 until
he was terminated unlawfully from his job on October 12, 2010. Defendant Hank Zimmerman was
the Chairman of the Library’s Board of Directors. Zimmerman’s actions complained of in the
Complaint were taken in the course and scope of his position with the Defendant Board of Trustees,
with the Board of Trustees’ actual or apparent authority and/or with Board of Trustees’ knowledge

and acquiescence. Dallas Moore was employed by Defendant Board of Trustees as the technology
director of the Shenandoah County Library. Moore’s actions complained of in the Complaint were
taken in the course and scope of his position with the Defendant Board of Trustees. Complaint, ¶¶
5-8. The Defendant Shenandoah County Library is a public entity under the authority of Virginia
Code Ann. § 42.1-33, et seq., as amended. By Virginia statute, funding for the Library is by a
special levy and constitutes a separate fund. Id. Moreover, the Defendant Board is authorized by
Virginia statute to manage and control the operations of the Library, and further is authorized to
receive donations and bequests for the establishment and maintenance of the Library. Complaint ¶¶
9-10. Pasco was the Library Director for almost nine years, substantially increasing services to the
public. Pasco held a legitimate expectation that he would not be terminated from his employment
absent just cause. Id., ¶¶ 12-13.
Moore was a disciplinary problem at the Library in 2010. He had taken an unnatural interest
in another Library employee, Keith Brown, causing Brown to complain of Moore’s attention.
Moore also had performance deficiencies, including tardiness which had become a habit. Id., ¶¶ 1415. On the morning of October 1, 2010, Moore was late to work and Pasco needed information for
a monthly report. Pasco, who was the head personnel officer of the Library (Complaint, ¶ 31),
reprimanded Moore and engaged in other discussions with him in the performance of his duties.
Id., ¶ 15. A personnel dispute with Moore ensued involving Moore attempting to insinuate himself
into personnel matters involving Brown. Id., ¶ 16.
Moore wanted Pasco fired from Pasco’s Director position, which made Pasco Moore’s
supervisor. Moore assaulted and battered Pasco later on the morning of October 1, 2010 in order to
seize two computer hard-drives from Pasco’s office. Id., ¶¶ 21; 16-20. One of the hard-drives
belonged to Pasco, and the other contained confidential data relating to employees. Id., ¶ 18.

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Moore was going to take the computer hard drives to the Shenandoah County Administrator to
accomplish his plan of getting Pasco fired. Id., ¶ 21. He was going to use information he falsely
claimed was on the hard-drives to assist with his plan. Id. A reasonable inference is that Moore
purportedly had such information because of his position as technology director. Moore informed
Defendant Zimmerman of this plan to go to the County Administrator in order to get Pasco fired
using information he claimed was on the hard-drives. Id. Pasco let Moore know that he was
seizing Pasco’s property, and Pasco then attempted to retrieve his property and the Library’s
property from Moore. Id., ¶ 23. Instead of relinquishing the property, Moore threw both harddrives to the ground, shattering them and destroying Pasco’s hard-drive so that the files on it were
useless and irretrievable. Id., 24-27.
Moore also shared with Zimmerman that Moore was going to file a criminal assault and
battery charge against Pasco, but Zimmerman did not share this information with Pasco. Instead,
Zimmerman asked Pasco agree to try to mediate the situation between him and Moore. Pasco
agreed, until he was confronted the next day by a Sheriff’s deputy who advised Pasco of Moore’s
criminal complaint against him based on assault and battery. Id., ¶ 30. Because of Moore’s
behavior, Pasco’s concern that Moore may harm Pasco and others, and Moore’s false statements to
law enforcement, as well as to Zimmerman, Pasco terminated Moore’s employment in accordance
with his authority as the Library Director. Id., ¶¶ 30-31. Moore filed a grievance with no content
other than to seek reinstatement, but he did not appear on October 7, 2010, the date scheduled, to
present his position and accordingly Pasco denied the grievance as he was authorized to do. Id., ¶¶
32-33. Another version of Moore’s grievance was not shown to Pasco. Id., ¶ 32.
Even before Moore’s scheduled October 7, 2010 grievance hearing, Zimmerman obtained
commitments from other members of the Boart of Trustees to terminate Pasco’s employment,

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with full knowledge that Moore had assaulted and battered Pasco and of the illegal seizure and
destruction of Pasco’s and the Library’s property. Id., ¶ 35. Zimmerman’s plan reached fruition
on October 7, 2010 when the Board met at the home of a member and voted to terminate Pasco
from his public employment. Id., ¶ 36. Moore was then reinstated to his job. The Defendants
Zimmerman, Board of Trustees and Shenandoah County Library adopted, ratified and
acquiesced in Defendant Moore’s illegal behavior as the acts of all Defendants. Id., ¶ 37.
The Complaint sets forth other facts relevant to the Motion to Dismiss.
II.

Rule 12(b)(6) Standard
The Federal Rules of Civil Procedure require that a complaint contain “a short and plain

statement of the claim showing that the pleader is entitled to relief. . . .” Fed. R. Civ. P. 8(a)(2).
That Rule does not require “detailed factual allegations.” See, Ashcroft v. Iqbal, 129 S.Ct. 1937,
1949 (2009). Moreover, there is no heightened pleading requirement for §1983 claims such as
are brought in this Complaint. Leatherman v. Tarrant County Narcotics Intelligence and
Coordination Unit, 507 U.S. 163, 166 (1993). In Leatherman Chief Justice Rehnquist, writing
for a unanimous Court, stated that the Fifth Circuit’s heightened-pleading requirement in local
government failure to train cases was “impossible to square” with the notice pleading standard of
Rule 8(a) of the Federal Rules of Civil Procedure.
The role of a 12(b)(6) motion is to test plausibility when determining whether a
plaintiff has stated a claim for which relief may be granted. Rule 12(b)(6) simply gives a
district judge a tool to screen out implausible cases. To survive a Rule 12(b)(6) motion, a
complaint “need only give the defendant fair notice of what the claim is and the grounds
upon which it rests.” Coleman v. Md. Ct. of Apps., 626 F.3d 187, 190 (4th Cir. 2010).
The plausibility requirement is met where the facts in support of a pleading allow the
Court to reasonably infer that the Defendant is liable for the conduct of which the
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plaintiff complains. Ashcroft v. Iqbal, 129 S. Ct. 1937, 1949 (2009). That standard is not
a probability requirement, but merely asks for something more than a mere possibility.
See also, Jacobsen v. Bank of Am., N.A., 2010 U.S. Dist. LEXIS 131760, **1-2 (W.D.
Va. 2010)(Moon, J.). Thus, Rule 12(b)(6) simply calls for enough allegations to raise a
plausible claim and a reasonable expectation that discovery will reveal evidence
supporting the elements of the claim. Speaker v. United States HHS CDC, 623 F.3d
1371, 1380 (11th Cir. 2010).
III.

Pasco Properly Named Zimmerman as a Defendant in His Official and Individual
Capacities.
Defendant Zimmerman has moved to dismiss the claims against him in his official

capacity as “redundant” and “unnecessary”. Zimmerman misapprehends the basis of Pasco’s
Complaint in this regard under Count One. Pasco has sued Zimmerman in his individual
capacity for compensatory and punitive damages. Pasco has sued the Board and the Library for
compensatory damages and other relief for their implementation of policy resulting in violations
of the constitution (and 42 U.S.C. §1983). Pasco seeks prospective declaratory and injunctive
relief against the individual, Zimmerman, in his official capacity. The official capacity suit is
neither “redundant” nor “unnecessary”.
The distinction between damages relief and prospective injunctive and declaratory relief
is an important one in constitutional litigation. Allegations that a public official is acting under
“color of law” are appropriate in both actions brought against a public official in his or her
individual capacity as well as one brought against a public official acting in his or her official
capacity. The former seeks damages, the latter seeks prospective injunctive and declaratory
relief. See Hafer v. Melo, 502 U.S. 21 (1991); Kentucy v. Graham, 473 U.S. 159 (1985). The
distinction is made clear in Miller v. Smith, 220 F3d, 491 (7th Cir. 2000) (where the Plaintiff
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seeks injunctive relief from official policies or customs the appropriate defendants are officials in
their official capacities; where the plaintiff alleges tortious conduct of an individual acting under
color of state law, defendant should be sued in his or her individual capacity). The Fourth
Circuit has appropriately stated the Complaint need not expressly plead the capacity in which
one is suing a defendant to state a cause of action under §1983. “A court must look to the
substance of the complaint, the relief sought, and the course of proceedings to determine the
nature of a plaintiff’s claim.” Biggs v. Meadow, 66 F 3d. 56, 58 (4th Cir. 1995).
Additionally, prospective equitable relief must be tailored to each individual official. It is
not generic in nature such that injunctive relief against the Board or the Library will suffice for
allegations against separate official capacity defendants. For this reason, the Supreme Court has
ruled that where prospective relief is sought against a public official who substitutes into the case
(as in death or election) there must be separate proof that the successor will engage in the same
unconstitutional conduct to allege prospective injunctive relief against the newly substituted
party. Spomer v. Littleton, 414 U.S. 514 (1977); Mayor of City of Philadelphia v. Educ. Equality
League 415 U.S. 605 (1974).
Pasco’s Complaint, relief sought and allegations should reveal that Pasco’s claims against
Defendant Zimmerman in his official capacity is not “unnecessary”. They merely seek a
separate form of relief available only from individuals in their official capacities.
The Defendant Zimmerman cites a number of cases as support for his position: Will v.
Mich. Dept. of State Pol., 491 U.S. 58, 70-71 (1989); Brown v. Ray, 695 F.Supp. 2d 292, 298
(W.D. Va. 2010); and Couch v. Jabe, 479 F.Supp. 2d 569, 598 (W.D. Va. 2006) and Mainstream
Loudoun v. Board of Trustees of Loudoun County Library, 2 F.Supp. 2d 783, 791 (E.D. Va.
1998). The first three cases dealt with claims for money damages against state employees in

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their official capacities, which fail for immunity reasons under 42 U.S.C. § 1983. They did not
address the situation here, where there is no claim against the state, but rather against a local
governmental entity and its official. These cases have no applicability to this argument. See
Plaintiff’s Memo. in Opposition to Defendant Board of Trustees’ Motion to Dismiss at 5-9. The
Mainstream Loudoun case does find that claims against the individual Board members are
unnecessary under the facts of that case. However, Pasco believes that the better course to
address the prospective relief in this case is for the claim to remain viable against Defendant
Zimmerman in his official capacity.
The individual capacity claim in Count One has been adequately alleged. Defendant
Zimmerman, while he did not actually seize Pasco’s computer hard-drive, adopted Moore’s
action as his own in facilitating the further deprivation alleged and the taking of Pasco’s property
through the termination of his employment. The allegations relating to Zimmerman’s
participation in Moore’s scheme to get Pasco fired, and obtaining votes of the remaining
members of the Board of Trustees with knowledge of the illegality of Moore’s conduct are
sufficient to support the claim for individual capacity liability under 42 U.S.C. § 1983. See
Plaintiff’s Memo. in Opposition to Defendant Board of Trustees’ Motion to Dismiss at 5-7.
Defendant Moore’s conduct, including his insertion into the personnel operations at the
Library through his unlawful search, seizure and taking of Pasco’s property, as well as his
reports to Defendant Zimmerman of the reason for the illegal search and seizure, were reviewed
and considered directly and almost immediately by the Defendants Zimmerman, Board and the
Library. The Defendant Zimmerman approved of Defendant Moore’s conduct, knowing of its
illegality. Complaint, ¶¶ 35-37. He and the Board adopted it as their own through their actions.
Moreover, Zimmerman directly participated in the denial of Pasco’s rights to continued

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employment based upon Pasco standing up for his rights to protect his property and Zimmerman
thereby inserted himself directly in intentional, deliberate and calculated conduct constituting a
taking of Pasco’s property. Zimmerman knew of the deliberate conduct by Defendant Moore,
and engaged in his own deliberate conduct in ratification of Moore’s conduct and the deliberate
termination of Pasco’s employment. Accordingly, the Defendant Zimmernan’s Motion to
Dismiss should be denied.
Defendant Zimmerman further argues in a footnote (Def. Memo. at 6, n.1.) that
Defendant Moore’s actions were not taken against the plaintiff under color of law and did not
constitute state action, and simply references Defendant Moore’s memorandum on this issue.
Defendant Moore’s arguments on this issue are without merit. Since no additional argument was
offered on this issue, Pasco incorporates his Memorandum in Opposition to Defendant Moore’s
Motion to Dismiss here. [Docket No. 21]
IV.

Counts Two, Three and Four – State Claims for Conversion, Assault and Battery
and Violation of the Virginia Computer Crimes Act
Insofar as the state claims in Counts Two, Three and Four allege a claim against the

Defendant Zimmerman individually, Pasco intends on seeking leave to dismiss those claims
against Defendant Zimmerman, only, under Rule 41(a), and without prejudice. This voluntary
dismissal will have no effect on the viability of those three state law claims insofar as they
currently exist against the other defendants.

V.

Pasco’s Allegations Set forth a Valid Claim for Violation of the Virginia
Constitution
Count Five states a damages claim against Defendants for their violations of Plaintiffs’

state constitutional rights. Defendant Zimmerman asserts only that he did not violate any article

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or provision of the Virginia Constitution and contends that there are no allegations relating to his
denial of Pasco’s constitutional rights.
In this Count, Plaintiff seeks monetary damages against the Defendants for the
deprivation of property, which includes the discharge from employment directly by the
Defendant Board, facilitated by Zimmerman, as well as the seizure and destruction of his
property, both of which were in violation of the provisions of Article I, § 11 of the Virginia
Constitution’s Bill of Rights. The facts alleged in the Complaint support the common law’s
application in this context in two regards: common law tort (see the discussion relating to Count
Six, the public policy wrongful discharge as applied to the rights underlying the Virginia
Constitution) and Virginia common law supporting claims under state constitutional provisions.
The common law claim asserted by Plaintiff, lying in a violation of an individual’s state
constitutional rights, is not dissimilar from the very right recognized by the U.S. Supreme Court
in Bivens v. Six Unnamed Agents, 403 U.S. 388 (1971). There, the U.S. Supreme Court held that
common law provided a damages remedy for the violation of an individuals’ federal
constitutional rights by federal agents – although the language of the federal constitutional rights
themselves do not expressly provide a monetary damages cause of action:
‘The very essence of civil liberty certainly consists in the right of
every individual to claim the protection of the laws, whenever he
receives an injury.’ Marbury v. Madison, I Cranch 137, 163 (1803).
Having concluded that petitioner’s complaint states a cause of
action under the Fourth Amendment, supra, at 390-395, we hold that
petitioner is entitled to recover money damages for any injury he
suffered as a result of the (federal) agents’ violation of the
Amendment.
403 U.S. at 396-7.
The Virginia Constitution is an affirmative grant of rights to individuals. The Virginia
Constitution’s Bill of Rights is a “Declaration of Rights made by the good people of Virginia in
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the exercise of their sovereign powers, which rights do pertain to them and their posterity, as the
basis and foundation of government.” Introductory statement to Virginia Constitution Bill of
Rights. Va. Const. Article I. Pasco’s claim relies on the Virginia Constitution’s Bill of Rights,
Article I, § 11, which states in pertinent part:
That no person shall be deprived of his life, liberty, or property
without due process of law; that the General Assembly shall not
pass any law impairing the obligation of contracts, nor any law
whereby private property shall be taken or damaged for public
uses, without just compensation, the term “public uses” to be
defined by the General Assembly . . .

Independent of the common law rights established in the Bowman line of public policy
common tort law, which is its own “executing” mechanism in the wrongful discharge context,
Virginia courts recognize a private right of action under the Virginia Constitution where the
constitutional provision relied upon is “self executing.” See Robb v. Shockoe Slip Found, 228 Va.
678, 324 S.E.2d 674 (1985). In Robb, the Supreme Court of Virginia stated that “constitutional
provisions in bills of rights and those merely declaratory of common law are usually considered
self-executing.” Id; accord Gray v. Virginia Sec’y of Transp., 276 Va. 93, 105, 662 S.E.2d 66, 72
(2008) (“Article I, Section 5 is contained in the Bill of Rights, and such constitutional provisions
are generally considered to be self-executing.”) See Kitchen v. City of Newport News, 275 Va.
378, 657 S.E.2d 132 (2008) (finding a portion of Article I, § 11 to be self-executing). Here, the
constitutional provisions that Pasco relies on are found in the Bill of Rights and as such should
“generally be considered self-executing.” Accordingly, the Virginia Constitution provides Pasco
with a valid cause of action.
In Robb, the Court also held that “[p]rovisions of a Constitution of a negative character
are generally, if not universally, construed to be self-executing.” Robb, 228 Va. at 681-682, 324

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S.E.2d at 676 (quoting Robertson v. Staunton, 104 Va. 73, 77, 51 S.E. 178, 179 (1905). Here, the
provision relied upon by Plaintiffs is of a negative character and prohibits certain conduct.
Article I, § 11 expressly states that “no person shall be deprived of his life, liberty, or property
without due process of the law.” Va. Const. art. I, § 11. Because the provision relied on by Pasco
is contained in the Bill of Rights and is of a negative character it should be “generally, if not
universally, construed to be self-executing.” Robertson, 104 Va. at 77, 51 S.E. at 179.
Finally, the Court has also quoted with approval an alternative test to determine whether
or not a constitutional provision is self-executing:
A constitutional provision may be said to be self-executing if it
supplies a sufficient rule by means of which the right given may be
employed and protected, or the duty imposed may be enforced; and
it is not self-executing when it merely indicated principles…
Robb, 228 Va. at 682, 324 S.E.2d at 676 (quoting Newport News v. Woodward, 104 Va. 58, 6162, 51 S.E. 193, 194 (1905). Here, the constitutional provision relied on by Plaintiff is not
merely a statement of “policy” but instead contains a clear directive.
Since the Defendant Zimmerman was directly involved in the discharge of Pasco,
obtaining agreement from the Board despite knowledge of the illegal conduct of Moore,
Zimmerman was involved in the ratification and adoption of Moore’s conduct and is responsible
for the seizure and destruction of Pasco’s property in violation of provisions of the Virginia
Constitution which are self-executing. Accordingly, the Defendant Zimmerman’s Motion to
Dismiss should be denied.
VI.

Pasco Sets forth a Cognizable Claim for Tortious Wrongful Discharge
Under Bowman and Post-Bowman Case Law Against Defendant Zimmerman
Defendant Zimmerman argues that he is not liable to Pasco for the claim of wrongful

termination, citing VanBuren v. Virginia Highlands Orthopaedic Spine, 728 F.Supp. 2d 791

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(W.D. Va. 2010). In that case, Judge Turk dismissed a wrongful discharge claim against a
supervisor, holding that the plaintiff was limited to suing her actual employer, not her supervisor.
This opinion is contrary to the common law and Virginia cases on this issue.
Defendant Zimmerman is a proper individual defendant to this Count regardless of the
fact that he was not the actual employing entity. The Bowman wrongful discharge claim is a tort
claim that applies to terminations of employment that violate public policy. See generally,
Bowman, supra; Shaw v. Titan, 255 Va. 535 (1998); McFarland v. Virginia Retirement Services,
Inc., 477 F. Supp. 2d 727, 739 (E.D. Va. 2007) (citing Bowman case which allowed a common
law wrongful discharge claim to proceed against those officers or agents of a company who
played a key role in contributing to the tortious conduct). The suggestion that an individual is
not a proper party to a wrongful discharge claim because he or she is not the “employer” is
grounded in the notion that the claim is quasi-contractual and arises out of the employment
relationship. It is not. The claim sounds in tort and asserts a claim for termination in violation of
the public policy underlying statutory and other expressions of policy. McClosky v. Warren
County Department of Soc. Serv., 81 Va. Cir. 35, 36 (Warren County 2010). In the Bowman and
Shaw Virginia Supreme Court cases construing this cause of action, individuals involved in the
discharges were recognized by the Court as named defendants. Indeed, when the Court first
recognized the claim in Bowman v. State Bank of Keysville, the Court stated the claim as follows:
“we hold that the plaintiffs have stated a cause of action in tort against the Bank and the named
directors for improper discharge from employment.” Bowman, 229 Va. at 540. Here,
Zimmerman is a proper party as an individual who engaged in the intentional tortious conduct
involved in the termination in violation of public policy, in addition to the Defendants Board of
Trustees and Library.

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Moreover, the fact that Zimmerman engaged in his wrongful conduct in his capacity as
Board Chairman does not insulate him from liability. This is a tort. If he had engaged in
fraudulent behavior, he would be liable for his individual conduct in perpetrating the fraud.
Here, he facilitated the tortious wrongful discharge. He is liable for his intentional conduct.
Pasco incorporates his argument on the other issues raised concerning the viability of the
underlying claim of tortious wrongful discharge set forth in his Memoranda in opposition to the
motions to dismiss of Defendants’ Board and Library. [Docket Nos. 23 and 24]
VII.

Punitive Damages
Defendant Zimmerman argues that no facts have been alleged to support a claim for

punitive damages against him. He is mistaken, and makes no reference to the standard for
punitive damage liability under 42 U.S.C. § 1983. In Smith v. Wade, 461 U.S. 30 (1983), the
Supreme Court held that punitive damages may be awarded by the fact-finder against an
individual even where the conduct is not motivated by malice or evil intent. Recklessness or
callous indifference to a plaintiff’s federally protected rights is sufficient. See also, Kolstad v.
American Dental Assn., 527 U.S. 526 (1990).
On the state claims in Counts Five and Six, punitive or exemplary damages are permitted
where there is misconduct or actual malice or such recklessness or negligence as to evince a
conscious disregard for the rights of the plaintiff, including the plaintiff’s property rights.
Xspedius Management Co. of Virginia, LLC v. Stephan, 269 Va. 421, 611 S.E.2d 385 (2005). At
the very least, Pasco’s allegations support an inference that Defendant Zimmerman engaged in
conduct in conscious or reckless disregard of his property rights when Zimmerman facilitated the
reinstatement of Moore and the termination of Pasco with full knowledge of Defendant Moore’s
illegal conduct.

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The facts alleged are sufficient to plead a claim for punitive damages under both federal
and state law.
CONCLUSION
Based on the foregoing, and for the reasons to be argued at the hearing, the Plaintiff
Pasco respectfully requests that the court deny the Defendant Zimmerman’s Motion to Dismiss
as requested.

ROBERT L. PASCO
By: s/Timothy E. Cupp
Timothy E. Cupp (VSB #23017)
Cupp & Cupp, P.C.
1951 Evelyn Byrd Avenue, Suite D
Harrisonburg, Virginia 22801
[e-mail]
[phone]
[phone] (facsimile)
Counsel for Plaintiff

CERTIFICATE
I hereby certify that on January 20, 2012, I electronically filed the foregoing Plaintiff’s
Memorandum in Opposition to Defendant Zimmerman’s Motions to Dismiss with the Clerk of
the Court using the CM/ECF system, which will send notification of such filing to the following
counsel for Defendants:
Julia B. Judkins (VSB No. 22597)
[e-mail]
Bancroft, McGavin, Horvath & Judkins, PC
3920 University Drive
Fairfax, Virginia 22030
[phone]
[phone] (fax)
Counsel for Defendant Moore

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Melisa G. Michelsen (VSB No. 40001)
J. Jay Litten (VSB No. 24567)
Litten & Sipe, LLP
410 Neff Avenue
Harrisonburg, Virginia 22801
[phone]
[phone] (fax)
Counsel for Defendants Zimmerman, Board of Trustees and Library

s/Timothy E. Cupp

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