Case 1:16-cv-00540-AJT-MSN Document 37 Filed 07/28/17 Page 4 of 20 PageID# 3260 budget, and violations of federal privacy laws designed to protect student privacy. 3 Davison also filed four complaints against LCSB in Loudoun County Circuit Court, requesting that the state court require LCSB to comply with VFOIA disclosure laws and production requirements and Virginia’s conflict of interest law. Id. ¶ 24d. Davison claims that Defendants used county funds and the powers and authority afforded to them by their employment with LCPS to prevent Davison from speaking at meetings, posting in public forums, participating in his children’s education, and attending public events. 4 In January 2015, Defendant Eric Hornberger (“Hornberger”), Davison’s representative on LCSB, deleted Davison’s comments that were critical of Hornberger from Hornberger’s Facebook page without any advance notice. Hornberger subsequently banned Davison from posting any comments at all on his LCSB Facebook page. Id. ¶ 30c. Some LCSB members, including Hornberger, did not hold open forums or community events, and so their Facebook pages became the primary means by which their constituents communicated with them. After Davison brought Hornberger’s Facebook ban to public attention, Hornberger accused Davison of threatening his life, which led to Defendant Suzanne Devlin (“Devlin”), the LCPS district security supervisor, surveilling Davison at future LCSB meetings and contracting with law enforcement to provide security at LCSB meetings as well. Id. ¶ 30d. In March 2015, Davison requested a complete list of Loudoun County teacher salaries via VFOIA. Davison eventually filed a complaint in Virginia state court seeking those records, which resulted in a general denial of his VFOIA request and a much more narrowly focused 3 At times during the open comment sessions, Davison disagreed with other commenters or ridiculed the Defendants and other LCSB employees for their refusal to discuss issues or efforts to suppress information. During those discussions, Davison threatened to post the disagreements in a publicly viewable online forum or take them to court. Davison does not appear to have ever threatened physical harm or to have suggested violence, however, and he generally complied with rules regulating speaking time and other conduct. 4 The Amended Complaint notes numerous occasions on which Plaintiff was not given the opportunity to ask questions during the designated question and answer time. 4