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IN THE
UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT

Case No. 18-1108

EDWARD RICHARDSON,

Appellant,

v.

PRINCE WILLIAM COUNTY GOVERNMENT,

et al.,

Appellees.

Appeal from the United States District Court

for the Eastern District of Virginia
Alexandria Division
The Honorable Claude M. Hilton, Senior Judge
1:17-cv-00761-CMH-TCB

APPELLANT’S INFORMAL REPLY

BRIEF IN SUPPORT

Edward Richardson, Appellant, Pro Se

1819 Meadow Drive
Fredericksburg, Virginia 22405
P. 540/207-1666
E. edwardrichardson27@yahoo.com
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APPELLANT’S INFORMAL REPLY BRIEF IN SUPPORT

Plaintiff/Appellant Edward Richardson, Pro Se, hereby respectfully submits

his Informal Reply Brief in Support of his Opening Informal Brief, D.E. 21, and in

support states as follows:

SUPPORTING FACTS1

Pursuant to this Honorable Court’s informal briefing schedule and this

Honorable Court’s Local Rule 34(b), the Appellant filed his Informal Opening

Brief on March 13, 2018, leaving a 14 day response period for the

Defendants’/Appellees’ to file their informal response briefing no later than March

27, 2018, if they chose to do so. The Appellees’ have expressly waived informal

briefing as the deadline has now passed, therefore conceding to the issues on

appeal and the indisputable facts presented in the Appellant’s Opening Briefing.

The Appellant’s informal briefing is based on sufficient and irrefutable facts and

events that are proven true and characterizes an ongoing scheme of pretext racial

discrimination, harassment, retaliation, prejudice and bias. The Appellant’s Reply

1
The Appellant failed to mention in his Opening Brief that during the initial pretrial conference
held on January 3, 2018, the District Court questioned the Plaintiff’s unwillingness to have his
deposition taken at any facility owned by Defendant County, based on the defendants’ violent
and ongoing harassing and retaliatory conduct against the Plaintiff. The District Court informed
the Plaintiff that he did not have to worry about the defendants’, which in itself was quite
peculiar and as if there had been prior one-sided contact between the district court and the
defendants’. The district court’s prejudicial and biased position clearly sought to undermine the
posited facts of the case, in addition to undermining the essential purpose of the Plaintiff’s TRO
which was left pending on the District Court’s docket and subsequently dismissed as moot.
2
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Brief in Support is hereby filed timely and in compliance with the informal

briefing schedule requirements per Local Rule 34(b).

CONCLUSION

Based on all of the foregoing reasons and for all of the reasons set forth in

the Appellant’s Opening Informal Brief, D.E. 21, the Appellant respectfully

requests that this Honorable Court vacate and reverse, in toto, the adverse rulings

of the district court. The Appellant also respectfully requests that any subsequent

informal briefings filed by either of the Appellees’ be regarded as untimely and to

not be taken under consideration by this Honorable Court.

Dated: March 28, 2018

Respectfully submitted:

/s/ Edward Richardson

Edward Richardson, Appellant, Pro Se
1819 Meadow Drive
Fredericksburg, Virginia 22405
P. 540/207-1666
E. edwardrichardson27@yahoo.com

3
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CERTIFICATE OF SERVICE

I HEREBY DECLARE that on this 28th Day of March 2018, I served the

foregoing on the following by CM/ECF notification; FedEx; United States Postal

Service; electronic mail, and / or hand delivery:

MICHELLE R. ROBL, ESQ.

Prince William County Attorney

JEFFREY R.B. NOTZ, ESQ.

Asst. Prince William County Attorney
1 County Complex Court, Suite 240
Prince William, Virginia 22192
Legal Counsel for the Defendants’
Prince William County, Barry M.
Barnard, Stephan M. Hudson,
Timothy Rudy, Scott A. Vago,
Jay Lanham, Michael A. Fernald,
Charlie T. Deane

/s/ Edward Richardson

Edward Richardson, Appellant Pro Se