H.

BACKGROUND

21 M.H. was three-years old during the events of this case. See Complaint (“Compl.”) [Dkt. 22 No. 1-1] ¶ 9. Putative plaintiff Lisbeth Zamora is his mother and guardian ad litem. Id. ¶ 2. In 23 August 2020, M.H. enrolled at defendant Montessori School at Washington Avenue, Inc. (“the 24 School”). Id. ¶ 11. Defendant Pamela Zell Rigg was director of the School. Id. ¶ 4. 25 According to the complaint, M.H. has been “diagnosed with a speech delay” and his 26 parents had concerns about his “speech and socialization skills.” Id. ¶ 12. Zamora informed the 27 School of this in September 2020. Id. In October 2020, M.H.’s teacher informed Zamora that M.H. “was not socializing or communicating much, but that it was too early to raise concerns about any disability that M.H. might suffer from.” Id. ¶ 13. In December 2020, the teacher said that M.H. was improving and the School was working on his speech. Id. ¶ 14. In February 2021, a school administrator expressed concerns to Zamora about M.H.’s speech and development and asked for him to be evaluated. Id. ¶ 15. About a week later, that administrator informed Zamora that “would not…