PLAINTIFF, JOANNA BURKES’ BRIEF IN SUPPORT OF MOTION TO CERTIFY DISPOSITIVE INTERLOCUTORY APPEAL AND TO STAY PROCEEDINGS PENDING APPEAL             Pro se, non-prisoner Joanna Burke (“Plaintiff”) submits this Brief in Support of her Motion to Certify Dispositive Issue for Interlocutory Appeal and Stay Proceedings Pending Appeal for the following reasons: BACKGROUND On July 17, 2023,… Continue reading →