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May 27, 2015 ‘Mr. Phillip J. Trobaugh, J.D. Charter School Liaison Minnesota Department of Education 1300 Highway 36 West Roseville, MN 55113-4266 Re: St. Croix Preparatory Academy (SCPA) MDE File No.; 15.03 Dear Mr. Trobaugh: ‘Thank you for the opportunity to respond to the May 26, 2015, letter from Friends of Education regarding requiring training prior to seating newly-clected SCPA board members, ‘The analysis set forth in the Friends of Education letter is a good start, and it correctly focuses (on “qualification” as the crux of the complaint. | do not disagree with many of the points raised in the Friends of Education letter: ‘+ Boards may provide for additional training programs beyond those required under Minnesota Statutes Section 124.10, Subdivision 4(f). A person cannot assume the duties of an elected office until qualified for office. A person may not necessarily assume the duties of elected office on the first day of his or her term. ‘* Oaths of office and the satisfaction of “other qualifications” may be required prior to taking office. + The Minnesota Nonprofit Corporation Act provides for the seating of directors upon thelr election and qualification. © Election and qualification are distinct principles, * Vnate that, in Attorney General Opinion 3584-24 {1878 WL. 34236), on which Friends of Education relies, ‘Attorney General Warren Spannus also advised: {Elven though public oficers may be permitted 2 reasonable time to qualify after commencement af theic ‘terms, It's advisable that they qualify atthe earliest feasible time in their term to prevent either a hiatus in authority or ning thelr authority vis-bvls lets who ar Inue in ef ie 6 Emphasis added. Ifthe proposed SCPA training requirements are permitted, the school would be setting itself up for these types of disputes by providing for “overlapping” terms between outgoing “qualified” board members and Incoming “to-be-qualified” board members. SCPA- MDE File No.: Corbett response Page 2 Where | differ is that | do not believe that SCPA has a free hand, as a Minnesota nonprofit corporation, subj Section 1 to require training as an additional qualification prior to seating duly-elected SCPA board members. ‘The right to seek and hold elective office is a fundamental right and is articulated in Article VIL, Section 6 of the Minnesota Constitution. Minneapolis Term Limits Coalition v. Keefe, 535 N.W.2d 306, 308 (Minn, 1995); Paviak v. Growe, 284 N.W.2d 174, 176 (Minn. 1979). This constitutional provision “forcefully presents an important democratic principle — that all citizens meeting minimal, unchanging requirements are eligible for the elective positions that contra! theit government”, Paviak, 284 N.W.2d at 176 (emphasis added), and it “guarantees eligibility for public office of citizens with minimal qualifications.” Id, at 176 (emphasis added). Minnesota follows the general rule that public bodies may not establish additional qualifications for their members. Poviak, 284 N.W.2d at 179-180, citing Powell v. McCormack, 395 U.S. 486 (1969); State ex rel. Childs v. Holman, 5S N.W. 1006 (Minn, 2894); see also 3 McQuiun Municipal, Corporations § 12:97 (3d ed.) (“it is self-evident that a statute cannot change the qualifications fixed by the constitution, nor can an ordinance change those named in the charter.”).? Friends of Education correctly points out that “qualifications” is not defined in the Minnesota Nonprofit Corporation Act. It is, however, a term of art in the context of the law of public bodies. See, e.g., MCQuiLUN, supra. It is defined in this context in Minnesota case law. In Minneapolis Term Limits Coalition v. Keefe, the Minnesota Supreme Court defined a “qualification as “an element of performance requiring particular ability on the part of the person seeking the position, such as physical agility or the attainment of a particular level of ‘education.”* 535 N.W.2d at 309, ‘The challenging part of any “qualifications” analysis Is that, as in the Friends of Education letter, it often conflates de jure and de facto qualification. See also, e.g., Keefe, 535 N.W.2d at 310 ? tn Paviak, the Minnesota Supreme Court noted thatt had previously struck down statutes requiring court ‘commissioners to be learned In the law and (prior to an amendment to the Minnesota Constitution authorizing the legislature to set qualifications for certain judges) requiring municipal judges tobe learned in the law and duly ‘admitted to practice law In the state. 286 N.W.2d at 176-77. ? This treatise also notes, in its survey of the law in this section, that “disqualifications on elective officers are ‘construed strictly” and “{cJourts must resolve daubts about qualification of 8 candidate in favor of the candidate.” * after reviewing Keefe, Friends of Education may argue that the proposed additional training is to provide for “the attainment of a particular leve of education." Although ! was unable to locate any case law on point, believe that ‘argument must fl as the court seems to be Indicating a "evel of education” along the lines ofa J.D. in order to serve as a municipal judge. Regardless, such an argument by friends of Education must fal because a pubic body generally may not establish addtional qualifications for its members. SCPA- MDE File No.: Corbett response Page 3 (Gardebring, |, and Anderson, J. dissenting) ("the majority engages in a convoluted and arcane attempt to distinguish ‘qualifications’ from ‘eligibility requirements.”). That is, it conflates the question “does this person have the qualifications required to hold office” with the question “is this person qualified to do a good job in office.” De jure qualifications are generally highly factual or procedural (e.g., age, residency, citizenship/residency, and oath of office Tequirements) and are found in the operative governing document (e.g., the qualifications to be U.S. president are found in the U.S, Constitution}. The determination of de facto qualifications is the prerogative of voters. Thus, itis not uncommon for new officals, as they grow into their offices, to be qualified at law but objectively, and sometimes admittedly, unqualified in fact. The de jure qualifications to serve as a Minnesota charter school board member are set forth in ‘the operative governing document for these schoo!s, that is, Minnesota Statutes Section 1240.10, specifically, Subdivisions 4(d) and 4(g). Friends of Education may argue that SCPA’s ‘operative governing document is its bylaws.* This argument would be a winning one if SCPA were not a quasi-public entity subject to Minnesota Statutes Section 1240.10. Just as legislatures may not use statutes to provide for additional member qualifications and city councils may not use ordinances, Minnesota charter schools may not use their own bylaws. Friends of Education argues that training serves the public policy of having welkinformed and well-prepared boards, | agree. There are, however, more powerful countervailing public Policies to consider here: the constitutional guarantees of the right to seek and hold office, the ‘feed for elections to matter, to not frustrate voters, and to bring in new blood with dispatch In drafting Minnesota Statutes Section 124D.10, Subdivision 4(f], the Minnesota legislature effectively chose these policies, even at the expense of having less-than-well-trained charter school boards. Thank you for your attention to this matter. | trust that this letter is hetpful to you in your analysis of the complaint. | am happy to provide you with copies of any of the sources cited. Please feel free to contact me if | can be of further assistance as you consider this this matter. Sincerely, “eee Cohetr Tom Corbett 651.274.3067 * Taken to its logical conclusion, Friends of Education’s argument would permit SCPA to even narrow statutorily: defined quatifications, for example, to provide that a parent board member must have had a child In the schoo! for a minimum number of years. Friends of Education Authorizing Conteat-Rich Schools RE. Topolok Executive Dizector May 26, 2014 Mr. Phillip J. Trobaugh Minnesota Department of Education 1500 Highway 36 West Roseville, MN 55113-4266 RE: St. Croix Preparatory Academy (SCPA) - Thomas Corbett Complaint Dear Mr. Trobaugh: 1am responding to your May 15, 2015, letter regarding Thomas Corbett. Friends of Education appreciates the opportunity to respond to your concerns. Mr. Corbett, a candidate in SCPA’s upcoming board election, does not agree with SCPA’s imposition of training after election and before seating. Mr. Corbett identified the same ‘complaint to me on May 8, 2015, to which I responcied on May 11, 2015. As you know, Minn, Stat. 124D.10 Subd. 4(f) requires board members to attend annual training throughout the member’s term, and requires new board members to attend traning in specific areas within specific timeframes. Given the public policy served by training — having well- informed and well-prepared boards ~ we do not interpret this provision as probibiti from imposing additional training requirements." In addition, applicable law indicates that charter schools may impose qualifications prior to seating. For example, caselaw and attorney general opinions indicate that a person cannot assume the duties of an office until he ot she has qualified for the office. See State ex. rel. Webb ¥, Stratte, 86 N.W. 20 (Minn. 1901); State ex. rel. v. McIntosh, 122.N.W. 462 (Minn, 1909); ‘Staie v. Ekblad, 2004 WL 2591246 (Minn. App. Nov. 16, 2004); Minn. Op. Atty. Gen. 359A-24 (1978); Minn. Op. Atty. Gen. 471-M (1999). Attorney General Opinion 359A-24 concerned a newly elected person who did not take his or her oath of office on the first day of the person's | We alo note that Mino, Stat. 124D.10 Subs. 4(0 cequices that new board members begin the statutorily. mandated ‘eaining “within six months afier being seated” (emphasis added), aad that previous MDE personnel have advised seruly-cleeted hoasd members that tuning attended after election and peior o senting would “count” towards this Starutory requirement because Subd. 4(9 does aot prohibie individuals feom attending training psioe to seating. 200 Lake Street East, EX0-01-A, Wayzata, MN 55391 SCPA — Corbett Page 2 term. The Attorney General stated that although the term of a new office begins on a particular date, “a person elected to fill that term does not automatically assume the duties of the office on that day.” Minn, Op. Atty. Gen. 359A-24 at*2, ‘The Attorney General further stated: A person cannot assume the duties of an office until he or she has qualified for the office. Qualification requires tha at a minimum, the person take an oath of office. ‘We believe that an officer need not take the oath and assume office on the first possible day. Rather, the person may be permitted a reasonable time in which to take the oath and satisfy any other qualifications for the office he or she is to assume. ‘emphasis added, Id. Although an oath of office is not « qualification that is required of charter school board members, applicable law specifies that other qualifications may be imposed. As you know, Minn, Stat. 124D.10 requires a charter school to be organized and operated as a nonprofit corporation under chapter 317A (see Minn. Stat. § 124D.10, Subd. 4(a)), and Minn, Stat. 317.205 states: “The qualifications and method of election or appointment of directors may be imposed by ‘or in the manner provided in the articles or bylaws . .. . emphasis added) In addition, Minn, Stat. 317.207 Subd. 1(b) sets forth the succession of directors and states that the prior director retains his/her position until the successor is both elected and qualified: Unless the articles or bylaws provide otherwise, a director holds office until expiration of the term for which the director was elected or appointed and until a successor is elected cand qualified, or unti the eatlier death, resignation, removal, or disqualification of the director? (emphasis added), Because the statutes use separate terms “election/elected” and “qualification/qualified,” each term means something different, £2. qualification is not the same as elected. See e.g. State of Minnesota v, Orsello, 554 N.W.26 70 (Minn, 1996), “Canons of statutory construction require us to give effect to each word in the statute, citing Minn. Stat. 645.17(2); see also Plaut v. Spendthrift Farm, Inc, 514 U.S, 211 (1995): words ina statute will not be treated as without effect We also note that the term “qualifications” is not defined in section 317A.205, thus allowing each 317A organization to establish qualifications pertinent to it. We believe that training that is = SCPAs bylaws, Adile 1V, Section 2(), so provide: Fach diceccor shall hold office fora three @) year term or until success has been duly elected and qualified oc until the diectoe dies, esigns, is emoved, or the term otherwise expires. SCPA — Corbett Page 3 imposed after election and that is relevant to a board member's duties is an appropriate Qualification, asthe training is clearly related to serving as a director. We also note that Minn. Stat, 317A.205 is permissive, unlike many other provisions of 317A setting forth requirements, indicating that the qualifications may, but need not be, established in the bylaws.’ In order to avoid any argument that SCPA does not have the authority to impose qualifications upon elected board members, however, we have recommended to SCPA that it include any post-election qualifications in its bylaws. We trust the foregoing is responsive to your concerns. Please feel free to contact me with any additional concerns you may have. Very truly yours, * See Minn Sat (A544: ‘The following words, tem, and pha weed in Minnesota Statutes... shall hve the smoaning: given to them in thi seen, unless othe ntnon lenrly appems “ay” 8 pesmi, “ust” a ‘shall? ae mandatory, Sal (1) (15), (15), (0). Minnesota Department of Educatidén May 15, 2015 Via email only: Topoluk@tefbank.com Beth Topoluk Friends of Education 200 Lake StE EXO-01-A ‘Wayzata, MN 55391-1690 Re: St. Croix Preparatory Academy (SPCA) Our File No.: 15.03 Dear Ms. Topoluk: am writing to let you know about a complaint the Minnesota Department of Education (MDE) received on or about May 11, 2015, regarding the above charter school. As you know, Friends of Education has ongoing oversight responsibilities for its charter schools, including St. Croix Preparatory Academy. Similarly, MDE is responsible for holding authorizers accountable for the satisfactory performance of their duties in relation to their charter schools. Minnesota Statutes, § 124D.10, subdivisions 3(c) and @. ‘The complainant, Thomas Corbett, essentially complains that the school is out of legal compliance regarding board elections and requiring mandatory steps of elected but unseated board members (¢.., reading certain texts) that is outside the scope of the law. A copy of the complaint and the complainant's additional documents are attached, If true, the allegations could involve a violation of law, including but not limited to Minnesota Statutes § 124D.10, subdivision 4(f). Please provide MDE with a response to the complaint(s) no later than two weeks from the date of this letter. The response should be detailed and specific. Please also include any supporting or related documents, Please call me if you have any questions. Very truly yours, /s/ Philip J. Trobaugh Phillip J. Trobaugh, J.D. Charter School Liaison ences Co: Jim Markoe, Board chair, via email only: manitouisland@comcast.net Complainant, via email only: thomasicorbett01 @amail.com Cindy Murphy, Director Charter Center Division Marikay Litzau, Director Compliance and Assistance Division Kevin McHenry, Assistant Commissioner Charter School and/or Authorizer Complaint Submission Form 15.03 Complaint Form questions Fash submiting a complaint about [A charer school (istramel] Yes Tam sibaritng a complaint about - comment [St Grok Proparatory Academy Fam submitting @ complait about (An auihorzer fst Aare Yos ram submiting a complaint about = coment Friends of Education the complaints abeut a charler schoo, [have aeady brought my conems tthe schoo aulhorizer Yes] Yes Tite complaints about a charter school, [have aeady brought ay concer To tha sohooTs authorizor [No] Ne Trthe complaints about & charter school, Thave already brought my concerns othe schooTs authorize: [Not appleby No’ [Coniplafnant information: (Ful Name] Tom Corbett [Complainant information: [Velephore nuriberlehd [est 278 3067 [Complainant inforration [eal adress: thomasjoorbett01@gmall com [Complainant information: Maing adsress] [703 ath SiN, Suilwater, MNT SSO82 Your relationship o ether the charter school or aol Parend Yes You tlaionship to ether te charter schoo! or auroras: [Employee] No Your relationship to ener the chavir schoo) of autiorizer: (Othe) Statement of Afoged Viotion: Training in excess oF Minnesota Sialutes Section 7240.10, subd. 40) and’n velalon of base democraioprinapies, AS A qUaar {goveramont enti, the SGPA boare cannot require duy eected board mombers Io have read carain Docks inorder tobe seated. Trknove, his violates Minnesota States, secon 1240.10, Subdivsion(s] The proposed waning s inconsistent wih the inlet of Minnesota Statutes, Section 1240.10, subd. I} which requires no Walrng proc tonew board members being seated, Siatoment of Face Please see the uploaded documents. This proposed raining sin eapanee fo our parent board Mamba resigning protest earlier this spring. Pane 72 [Statement of Facis (contnced) use the fle upload to Tacude any supporing docunvents regarding your complaint. i ille7MIDE Corbet FOE SCPA background info comment" sizo™274 205" name" MDEY20Corbelt20coMpLAINLOTE 20F OEY420SCPA po "lename’"Tu_2eajdy4smpeti’ “ext pa” fecount- Stalament of Fats (Continued) use the fla upload to include any supporting documents regarding your complaint 7 [Proposed resouiion: Seat members after thay are duly elected witout ine proposed delay. Provide optional or recommeded walring in adaifon tothe state required taining. Signature zi - 7 Thomas J. Corbet ame 27e st.croix 2) /preparator oP ay Board Member Description of Duties General Purpose: Member of the governing body of St. Croix Preparatory Academy is primarily responsible for governance, fiscal accountability, student achievernent, stcategic direction, and fulfilling the mission of the school in accordance with its bylaws and founding documents, Reports To: Board ‘Hours: 3 year term; average time commitment is 8-10 hours per month with additional time required if involved in committees and project work. It is expected that board members will be involved on committees and project work. ‘The total time commitment per month will be approximately 15-20 hours. Essential Duties and Responsibifities inclade but are not limited * Governance. This includes familiarity and adherence with public charter schoo! statute (124D.10), the School's Bylaws, Open Meeting Law, Minnesota Government Data Practices Act, MDE and Authorizer compliance requirements, authorizer contract, and other related legal requirements. Board members are expected to be familiar with the Carver Governance model which the Schoo! has adhered to since its inception... + Financial Accountability. This includes annual budget review, annual report preparation, aucit review, awareness of financial metrics to ensure continued favorable review from outside business partners (¢.g, banking, investors, ee.) and to guarantee future sustainability and rogram growth, * Student Achievement. This includes an annual review of student performance in comparison ‘with state and national standardized tests and an annual evaluation of post-secondary and workforce readiness in accordance with state requirements. * Mecting Attendance. The Board meets on the third Tuesday of every month. Board members are expected 10 review their board information prior to the meeting and to meet the attendance requirements specified in Minnesota statute. * Strategic Direction. The Board is responsible for the continued strategic direction of the institution in alignment with the School's mission, definition of classical education, and implementation of the diffusions of innovation theory. Examples of strategie discussions may include the following: facility development, athletic ficld development, compensation models to censure fiscal responsibility, board poliey development, school replication, suceession planning, revenue generation opportunities, community relations, etc. * Training, Board members must mect the state mandated training requirements. In addition, ongoing training will be provided on the aforementioned items (¢.g. governance, financial accountability, student achievement, strategic direction, etc.) and the following items. © Communication Protgcol. ‘The Scioo!'s communication protocol has been in place since 2004. A board member's understanding and adherence to the protocol maintains respect for operational authority throughout the organization, © Homework Philosophy. The School's academic rigor requirements have been in place ‘since 2004. A board member’s understanding and support of this philosophy will be enhanced through this training and selected readings from Talent is Overrated | G. Colvin), The Talent Code (D. Coyle), The World is Flat (T. Friedman), Mindset (C. Dweek), Crazy U (A. Ferguson), and Dewid & Goliath (M. Gladwell) © Operational Training. Although not specifically responsible for day to day operational decisions, itis important for board members to understend the operational complexity of St. Croix Prep. This will be done through meetings with the administrative personnel (eg. Exceutive Director, CFO, Lower School Principal, Middle School Principal, Upper School Principal, Special Education Director, Activities Director, Facilities Director, Communications Director, Technology Director, ec.). In addition, newly elected board members must attend one of the prospective family Informational meetings. © Diffusions of Innovation Theory. The School has always evaluated its purpose, growth ‘model, marketing, and operations in terms of diffusions of innovation theory (developed by Everett Rogers in 1962) as presented by Geoffiey Meare in his books Crossing the Chasm and Inside the Tornado. Marketing the school, positioning/differentiating it within its market, development of “a whole product and operations (¢.g., hiring, governance models, policy developnient, recruiting, aid programming) all take into consideration the five sogments -of classification typically described in technology adoption (¢.g., innovators, early adopters, carly. majority, late muajority, and laggards). ‘This impacts the School's hiring practices, governance model; policy development, recruiting practices, etc: Board members.will be introduced to this through selected readings from Crossing ihe Chasm (G. Moore), Inside the Tornado (M. Gladwell), The Tipping Point (4. Gladwell), Built o Last (J. Collins) ‘Note: This training will be conducted on an cit-going basis'aid some will be included as a part of the regular board meeting agenda, An estimate of the time required for training is noted below: oe State mandated training on governénée,*finance, and employment law ~ 6-8 hours, Meetings with operationAl personne] ~.10 hours Informational meeting - 2 hours. of Required réading — 15 to 20 hours ‘Communication Protocol - 1 hour Homework Philosophy ~ | hour ‘Open Meeting Law=1 hour ” Minnesota Government Data Practices Act — | hour St. Croix Preparatory Academy 4260 Stagecoach Trail North Stillwater, MN 55082 We have received your board nomination form, Thank you for your willingness to contribute to the community of St. Croix Prep through your board service, This document is intended to summarize the election process and expectations of board members should you be elected. Board Election ‘The Board election will take place on June 2, 2015, Prior to this, St. Crofx Prep will publish a Voter's Guide which summarizes information about you and your candidacy. We will allow you to proof this information prior to its publication. In the earlier years of the ‘School's existence, Voter's Forums were conducted to allow the public to interact with the board candidates. The Board may opt to hold an event like this. We will keep you apprised if this decision is made, Election results will be communicated to the St. Croix Prep community on June 3, 2015, Elected Members will be seated at the August 18, 2015 Board Meeting. Inan effort to increase and improve St. Croix Preparatory Academy's governance capacity newly elected board members will not be seated until the August 18, 2015 board meeting. ‘This will allow newly elected board members to begin a training program designed to contribute to effective governance. This training will include but not be limited to the items noted in the draft of the Board Member Description of Duties. The Board reserves the right to not seat a newly elected board member who does not make a good faith effort to follow the training process. ‘Summary of Guiding Expectations ASt, Croix Preparatory Academy Board Member, as a member of the governing body of SCPA, is primarily responsible for governance, fiscal accountability, student achievement, strategic direction, and fulfilling the mission of the School in accordance with its bylaws and founding documents, For additional details, please see the Board Member Description of Duties document. In addition, itis expected that board members will abide by the Open Meeting Law (Minn, Stat. chapter 13D) and maintain confidentiality in matters noted in this ‘statute. While at the school, board members shall be mindful of the different: roles they play: arent, volunteer, board member, etc. A board member should not use thelr position of authority while acting in their parent or volunteer roles, Board members shall also Temember that stepping out of their advisory/board capacity and attempting to fulfil the role of an administrator will not be accepted. ‘The vision and mission statement of St. Croix Preparatory Academy will serve to guide and direct the board, The goal to continually improve, maintain integrity, serve SCPA families and ensure academic success for our students shall take precedence in all situations. Please sign and return a copy of this document to Nancy Reistad by May 22, 2015. By signing this document the board nominee acknowledges he/she has read the Board Member Description of Duties, understands the election and seating process, and the ‘training requirements ifelected to the SCPA Board of Directors. ‘Signed, this day of 20_. Board Member Printed Name: Topoluk Beth £ Monday, May 21, 2035 9:25 AM To: Tomcorbett ca Jgutierrer@stcroixprep org; Manitoulsland@comcastnet Subject: RE: Attn: Beth Topoluk FW: Board Member Description and Nomination Introduction Mr. Cortbett: Friends of Education's policy isto strive to respond to inquires within thirty days. We do not apprectate your intended assumption of response within two business days. While we are responding to this inquiry within the time frame you ‘fequested, you should net assume that we will do so in the future, and you are on notice that no assumption of response is appropriate. Pursuant to Minnesota law, a charter school authorizer's role vis-a-vis a charter school is limited to oversight. An authorizer does not manage or operate the charter school it oversees the school board's management and operation of the school. Specifically, the authorizer is required to monitor and evaluae the fiscal, operational, and student performance of 2 school, Minn. Stat, 124D.10 Subd. 15. Where a school is deficient in one or more of these areas, the authorizer, after complying with statutory notification and hearing requirements, many cancel the charter of the school, Mian, Stat 12AD.10 Subd, 23. Friends of Education notes thatthe Minnesota Commissioner of Education is also empowered to {terminate the charter of a school with a history of repeated or major violations of law, Minn, Stat. 124D.10 Subd. 23(@). Based on our limited oversight responsibilities, do not intervene in nonlegal issues. Based on our review of applicable law, a charter school has broad authority to establish training requirements it deems appropriate, The training to which your email refers (after board seating) i the state-mandated training, and nothing in applicable law prohibits charter schools from requiring additional training. Jn addition, training serves the public policy ‘Purpose of having well-informed and well-prepared board members, In summary, our review of applicable law does not indicate that SCPA proposed training requirements violate applicable Jaw; accordingly, we have no basis to intervene. Beth Topoluk Friends of Education Mission: 10 improve the education of children From: Tom Corbett ‘Sent: Friday, May 08, 2015 2:52 PM. To: Topoluk, Beth E;info(@impravek-12educatlon.o7a ce ora; Manitoulsiand@comeast.net ‘Subject: Attn: Beth Topoluk FW: Board Member | Description and Nomination Introduction Ms. Topotuk, | enjoyed your remorks ar St. Croix Preporatary Academy this week. fercze see Ine email below. Jon Gulienez replied 10 me eater tis wok and provided my comments fo Ihe SCPA boar, forwhich !was grateful. The poly, os drafted cna without changes, was adopted by ine SCPA bourd lost night, pam crest wiveher Flan Of Education has any conceirs ver thase poleies? if you would ploose tnely reply by $00 Peano sacar, Mey 12. | woukd appracicte Hi. IF! do nol receive a responte by ine fins, wil crsume ihe oronen& Reg Friends of Education has no cancems over the policy. Thank you, Tom Corbett “Tom Cornet | Sr. Corporate Gouncel | ® expt Low Departmen 1000 Mec all, TPS-S1S5 | Mlaneapos, MN S403 | 612.896.6162 (oh) | 612.658.

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