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1
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COMPLAINT
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EXTRACTED KEY WORDS
NEWS PUBLIC SCHOOLS JAYNES EDUCATION STEFAN NEWPORT NEWS PARENTS HEARING OFFICER TESTIMONY SPECIAL EDUCATION ADMINISTRATOR CHILD EXHIBIT EXH IEP VIRGINIA REIMBURSEMENT STATES DISTRICT COURT PLAINTIFFS UNITED STATES DISTRICT UNITED STATES SCHOOL BOARD REVIEW OFFICER PACES EDUCATIONAL PROGRAM PUBLIC SCHOOLS PURSUANT DISABILITIES EDUCATION ACT STATE LEVEL LIMITATIONS IEP MEETING |
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Newport News Division
STEFAN JAYNES, a minor, )
by and through his parents, )
BRIAN D. JAYNES, )
and )
JULIANA F. JAYNES and on their own behalf, )
Plaintiffs, ) Case No. ______________
)
v. ) COMPLAINT
)
NEWPORT NEWS SCHOOL BOARD, )
Defendant. )
PRELIMINARY STATEMENT
1. Stefan Jaynes is a nine year old child with autism. On or about January 17,
1995, Stefan's parents removed him from the Newport News Public Schools and have
provided him with an education at considerable personal expense. On January 14, 1997, not
quite two years later, his parents requested a special education due process hearing against
Newport News Public Schools pursuant to 20 U.S.C. § 1415. They sought reimbursement for
their child's special education expenses. After hearing two days of testimony (Transcript of
the Special Education Due Process Hearing is referred to a "Testimony, Vol. 1 and Vol. 2"),
and receiving an extensive number of exhibits from the parents and school board (Referred to
as Due Process Hearing Parent's and Sch. Bd.'s Exh. #), on June 11, 1999 the Administrative
Hearing Officer awarded the Plaintiffs the sum of $117,979.78 to reimburse them for their
expenses. (See Decision of special education due process Administrative Hearing Officer,
attached as Exhibit A.) The Hearing Officer found ongoing and egregious violations of law by
the Newport News Public Schools. The school system appealed to a State Level Reviewing
Officer who, on September 14, 1999 upheld the findings of the Hearing Officer except that he
reduced the award to $56,090.84. (See Decision of special education due process
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