St. Johns County insurance defense counsel SUSAN ERDELYI of MARKS GRAY law firm just told U.S. District Court Chief Judge Timothy Corrigan that it is permissible for St. Johns County to reject speech that it "disapproves" of -- namely, an LGBTQIA+ Pride Proclamation.
The only problem is that no one in St. Johns County ever noted or voted their disapproval.
And it is, at best, facetious for ERDELYI to compare a routine Gay rights proclamation to the Sons of Confederate Veterans flying the Confederate flag in a government-sponsored veterans parade.
SUSAN ERDELYI is unscholarly, dishonest and has delusions of adequacy.
My grandmother would have called her "typical of her type" -- a typical shifty, snooty mendacious corporate lawyer.
How meaningless are the lives of such ruthless people who go to law school and represent inanimate objects, looking down their distended nostrils at the rest of the world?
Pray for soulless Pharisse SUSAN ERDELYI and her 120-year old corporate varmint law firm.
And do pray for smarmy St. Johns County Commission Chairman JEREMIAH RAY BLOCKER, as lugubrious a goober as ever made a chair squeak.
BLOCKER's corporate lawyer wife, LAUREN BLOCKER, has just been appointed a County Court Judge by Governor RONALD DeSANTIS, despite the fact she never tried a case (except one as second chair).
Middle District of Florida Local Rule 3.01(i) allows supplemental authorities to be cited "without argument or comment."
Here is St. Johns County's misleading, hateful supplemental citation:
Case 3:21-cv-00575-TJC-JRK Document 20 Filed 09/30/21 Page 1 of 2 PageID 781
SARA BLOOMBERG,
Plaintiff,
v.
JEREMIAH RAY BLOCKER, in his personal and professional capacity
as the chair of St. Johns County
Board of County Commissioners,
and as Commissioner for District 4; and the St. JOHNS COUNTY BOARD OF COUNTY COMMISSIONERS
Defendants. ________________________________/
CASE NO.: 3:21-cv-00575-TJC-JRK
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
JACKSONVILLE DIVISION
DEFENDANTS’ NOTICE OF SUPPLEMENTAL AUTHORITY
IN SUPPORT OF MOTION TO DISMISS FIRST AMENDED COMPLAINT
Defendants ST. JOHNS COUNTY BOARD OF COUNTY COMMISSIONERS and JEREMIAH RAY BLOCKER, sued in his “personal” and “professional” capacities as the chair of the St. Johns County Board of County Commissioners and Commissioner for District 4 (collectively, “Defendants”), pursuant to Local Rule 3.01(i) of the Local Rules for the Middle District of Florida, submit this Notice of Supplemental Authority to apprise the Court of a recent opinion from the Eleventh Circuit Court of Appeals in Richard Leake, et al. v. James T. Drinkard, Case No. 20-13868, entered September 28, 2021. This authority
1
Case 3:21-cv-00575-TJC-JRK Document 20 Filed 09/30/21 Page 2 of 2 PageID 782
supplements the argument presented in the first paragraph on page 13 of Defendants’ Motion to Dismiss First Amended Complaint (ECF 18). Defendants submit the following quotation from the first paragraph on page 19 of the opinion in Leake:
A government cannot compel a private parade organizer to admit groups of whose views the private organizer disapproves. Id. at 574–75 (holding that the State could not compel a private parade organizer to admit a gay, lesbian, and bi-sexual advocacy group because the “parade’s organizers” had a right to choose not “to propound a particular point of view”). And we hold that a private organization cannot compel a government parade organizer to admit groups of whose views the government disapproves.
Defendants further submit the following quotation from the first full paragraph on page 20 of the opinion in Leake:
We hold that the Parade was the City’s speech. It follows that the Sons of Confederate Veterans “cannot force [the City] to include a Confederate battle flag” in the veterans parades it funds and organizes. Walker, 576 U.S. at 219.
Respectfully submitted this 30th day of September, 2021.
MARKS GRAY, P.A.
/s/ Susan S. Erdelyi
Susan S. Erdelyi, Esquire
Florida Bar No.: 0648965
1200 Riverplace Blvd., Suite 800
Jacksonville, Florida 32207 Phone: (904) 398-0900
Fax: (904) 399-8440 serdelyi@marksgray.com jmcduffie@marksgray.com Attorney for Defendants
No comments:
Post a Comment