Requestor
Dylan Herink
Organization/Agency
The Law Offices of Keith L. Howard, PLLC
Requested Information
Pursuant to the Maryland Public Information Act (MPIA), Md. Code Ann., General Provisions ยงยง 4-101 et seq., I respectfully request access to and copies of the records described below. The MPIA provides that, except as otherwise provided by law, all persons are entitled to have access to information about the affairs of government and the official acts of public officials and employees.
For each request below, please provide records created, maintained, received, in effect, or applicable at any time from January 1, 2020, through the date this request is processed.
Please treat each numbered item below as a separate request. If records responsive to one item are unavailable or exempt from disclosure, please continue processing the remaining requests.
Please also provide all responsive records electronically whenever possible. If any responsive records exist in electronic format, please produce them in their native electronic format or as searchable PDF files. Please send all responsive records to: info@khowardlaw.com
Requested Records
1. Insurance policies
Copies of all liability insurance policies, excess liability insurance policies, umbrella insurance policies, risk management policies, self-insurance plans, pooled risk coverage agreements, or any documents to this effect that provided coverage to the school district, board of education, district employees, officers, or agents for claims, lawsuits, administrative proceedings, or other legal actions.
2. Agreements regarding payment of claims or judgments
Copies of all agreements, contracts, memoranda of understanding, participation agreements, indemnification agreements, risk-pool agreements, cost-sharing agreements, or any documents to this effect that identify, govern, allocate, or describe responsibility for paying claims, settlements, judgments, awards, defense costs, attorneys' fees, or litigation expenses arising from lawsuits or administrative proceedings involving the district.
3. Documents concerning immunity and waiver of immunity
Copies of all policies, resolutions, board actions, insurance-related documents, legal memoranda, guidance documents, agreements, or any documents to this effect concerning governmental immunity, sovereign immunity, governmental liability, waiver of immunity through the purchase of insurance, waiver of immunity through participation in a risk pool, or any other circumstance under which the district's immunity may be waived or limited.
4. Litigation coverage documents
Copies of documents identifying insurance coverage, risk-pool coverage, defense obligations, indemnification obligations, or any documents to this effect applicable to claims or litigation involving the district, including documents describing when a third party is responsible for defending or indemnifying the district.
5. Settlement agreements in special education matters
Copies of all settlement agreements, resolution agreements, mediation agreements, due process settlement agreements, administrative settlement agreements, negotiated agreements, or any documents to this effect resolving disputes involving special education, disability accommodations, Section 504, the Individuals with Disabilities Education Act (IDEA), exceptional children services, or related educational disability claims.
6. Settlement agreements in personal injury matters
Copies of all settlement agreements, releases, settlement and release agreements, negotiated resolutions, claims settlements, litigation settlements, administrative settlements, or any documents to this effect resolving personal injury claims, bodily injury claims, negligence claims, premises liability claims, student injury claims, employee injury claims, or other tort claims involving the district.
7. Settlement registers, logs, or tracking documents
Copies of any settlement logs, settlement registers, claims databases, litigation tracking spreadsheets, claims summaries, reports, or any documents to this effect that identify settlements entered into by the district.
For each request below, please provide records created, maintained, received, in effect, or applicable at any time from January 1, 2020, through the date this request is processed.
Please treat each numbered item below as a separate request. If records responsive to one item are unavailable or exempt from disclosure, please continue processing the remaining requests.
Please also provide all responsive records electronically whenever possible. If any responsive records exist in electronic format, please produce them in their native electronic format or as searchable PDF files. Please send all responsive records to: info@khowardlaw.com
Requested Records
1. Insurance policies
Copies of all liability insurance policies, excess liability insurance policies, umbrella insurance policies, risk management policies, self-insurance plans, pooled risk coverage agreements, or any documents to this effect that provided coverage to the school district, board of education, district employees, officers, or agents for claims, lawsuits, administrative proceedings, or other legal actions.
2. Agreements regarding payment of claims or judgments
Copies of all agreements, contracts, memoranda of understanding, participation agreements, indemnification agreements, risk-pool agreements, cost-sharing agreements, or any documents to this effect that identify, govern, allocate, or describe responsibility for paying claims, settlements, judgments, awards, defense costs, attorneys' fees, or litigation expenses arising from lawsuits or administrative proceedings involving the district.
3. Documents concerning immunity and waiver of immunity
Copies of all policies, resolutions, board actions, insurance-related documents, legal memoranda, guidance documents, agreements, or any documents to this effect concerning governmental immunity, sovereign immunity, governmental liability, waiver of immunity through the purchase of insurance, waiver of immunity through participation in a risk pool, or any other circumstance under which the district's immunity may be waived or limited.
4. Litigation coverage documents
Copies of documents identifying insurance coverage, risk-pool coverage, defense obligations, indemnification obligations, or any documents to this effect applicable to claims or litigation involving the district, including documents describing when a third party is responsible for defending or indemnifying the district.
5. Settlement agreements in special education matters
Copies of all settlement agreements, resolution agreements, mediation agreements, due process settlement agreements, administrative settlement agreements, negotiated agreements, or any documents to this effect resolving disputes involving special education, disability accommodations, Section 504, the Individuals with Disabilities Education Act (IDEA), exceptional children services, or related educational disability claims.
6. Settlement agreements in personal injury matters
Copies of all settlement agreements, releases, settlement and release agreements, negotiated resolutions, claims settlements, litigation settlements, administrative settlements, or any documents to this effect resolving personal injury claims, bodily injury claims, negligence claims, premises liability claims, student injury claims, employee injury claims, or other tort claims involving the district.
7. Settlement registers, logs, or tracking documents
Copies of any settlement logs, settlement registers, claims databases, litigation tracking spreadsheets, claims summaries, reports, or any documents to this effect that identify settlements entered into by the district.
Date Received
Status
Submitted