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- Search the web for: Notice%3A Fourth Circuit Local Rule 36%28c%29 States That Citation of Unpublished Dispositions is Disfavored Except for Establishing Res Judicata%2C Estoppel%2C or the Law of the Case and Requires Service of Copies of Cited Unpublished Dispositions of the Fourth Circuit.heather Gamble%2C a Minor%2C by Her Parents and Next Friends%3Bron Gamble%3B Arlene Gamble%2C Plaintiffs-appellants%2C v. Maryland State Department of Education%3B Nancy S. Grasmick%2C%28officially%29 Superintendent%2C Defendants-appellees