IN RE:

BOARD OF EDUCATION PEORIA SCHOOL DISTRICT 150 KEVIN CURTIN

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - -

SWORN STATEMENT OF MICHELLE UNGURAIT

Friday, April 27, 2012

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - APPEARANCES: For Kevin Curtin: Mr. Richard L. Steagall Nicoara & Steagall 416 Main Street, Suite 815 Commerce Building Peoria, IL 61602-1103

Reported By: Patricia W. Smith, LCR, RPR, CCR

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STATEMENT

OF

MICHELLE

UNGURAIT,

04-27-12

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The sworn statement of Michelle Ungurait was taken by counsel for Kevin Curtin at the Hyatt Place Nashville Airport, 721 Royal Parkway, Nashville, Tennessee, on Friday, April 27, 2012, beginning at approximately 9:16 a.m. It is agreed that Patricia W. Smith, Licensed Court Reporter, Registered Professional R e p o r t e r , a n d N o t a r y P u b l i c f o r t h e S t a t e o f T e n ne s s e e , may swear the witness, take the statement, and afterwards reduce same to typewritten form. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - INDEX PA G E S MICHELLE UNGURAIT: Examination by Mr. Steagall ............... 3 - 56

EXHIBITS (None offered.)

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STATEMENT

OF

MICHELLE

UNGURAIT,

04-27-12

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. STEAGALL: Q. A. Q. A.

MICHELLE UNGURAIT, h a v i n g b e e n d u l y s w o r n , w a s e x a m i n e d a n d t e s t i f i ed a s follows: EXAMINATION

Can you tell us your name and age, please. Michelle Davidson Ungurait, 44. And where do you presently work? I work for Sumner County Schools in

Gallatin, Tennessee. Q. A. Q. A. Q. A. And that's a suburb of Nashville? Yes. And where does your husband live? He lives in Oak Ridge, North Carolina. And what does he do? He works for Pearson Educational

Measurement, and he is a graduate student at the University of North Carolina at Greensboro. Q. A. Q. A. Q. A. Q. Has he been in education as well? Yes. How long have you two been married? Eleven years this summer. And do you have children? Yes. What are their ages, and where are they

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located? A. We have -- he has a 21-year-old that lives

i n N a s h v i l l e , T e n n e s s e e , a n d a 1 5 - y e a r - o l d t h a t li v e s in Nashville, Tennessee. I have a daughter, who is 21, A n d we h a v e

that lives in Chapel Hill, North Carolina.

a s o n , t o g e t h e r , w h o i s 8 , a n d h e l i v e s i n O a k R id g e . Q. So the employment situation is you found

employment in Nashville, and, unfortunately, he's in Oak Ridge, and you are separated during the week? A. Q. Yes, because of what occurred in Peoria. Tell us your educational degrees, what

universities, and when you got them. A. University. I have a Bachelor of the Arts from Miami I have a Master of the Arts from the I h a v e a M a s t e r ' s i n E d uc a t i o n A n d I h a v e a D o c t o r at e i n

University of Arkansas.

from Vanderbilt University.

Education from the University of Texas at Austin. Q. And Miami of Ohio -- or that's Miami of

Ohio, isn't it? A. Q. A. Q. A. Yes. Have you been a school teacher? Yes. What did you teach? I taught U.S. History and World Geography

in Nashville, Tennessee.

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Q. A. Q. A.

What level? High school. And when did you get into administration? I went to the Tennessee Department of

Education in 2000. Q. A. Q. A. And how long did you work there? Four years. What did you do there? I was in charge of social studies

c u r r i c u l u m a n d v e r i f y i n g a s s e s s m e n t s f o r t h e s t a te level. Q. A. Q. Was that for the entire state of Tennessee? Yes. Where did you go after the Tennessee

Department of Education? A. Agency. Q. A. Q. And I believe that was in Austin? Yes. So you were doing -- well, that was a I was recruited to the Texas Education

similar government agency? A. It was the same -- yeah, it was the same

position but for the state of Texas. Q. A. And how long were you in Austin? Three years.

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Q. A. Q. A. Carolina. Q.

So we're looking at, what, 2004 to 2007? Yes. And then where did you go after that? I was recruited to Guilford County, North

And you know this is about events in

Peoria, Illinois. Guilford County, what city is that? A. That's Greensboro and High Point,

North Carolina. Q. Okay. And what -- that was the school

district there? A. Q. A. Yes. And what position did you take at Guilford? I had an Executive Director position. And

I h a d d i f f e r e n t a s s i g n m e n t s w h i l e i n G u i l f o r d C o un t y . I w a s a p r i n c i p a l o f a s c h o o l , I w a s t h e s e c o n d a ry curriculum director, and I was the magnet school director. Q. there? A. Dr. Terry Greer was the superintendent who Who was the superintendent when you were

recruited me, and then it was Mr. Mo Green after Dr. Greer left. Q. And when did you leave Guilford?

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MICHELLE

UNGURAIT,

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A.

I was asked to become associate

superintendent of Peoria via a phone call by Dr. Grenita Lathan in July of 2011. Q. A. And had you known Grenita Lathan before? Not -- not well. I knew of her. When she

w a s a n e l e m e n t a r y s c h o o l p r i n c i p a l , I w a s t h e s e co n d a r y curriculum director, so we did not work directly with each other. I did work with her school that she was It was a

principal of after she left Guilford County. magnet school. Q.

Where was she at the time that she was

recruiting you to come to Peoria? A. She was in Peoria, Illinois. She had come

from San Diego, California. Q. Peoria? A. Q. A. No. Do you know her position in San Diego? I believe that she served as a type of -Had she been a superintendent before

s o m e t h i n g c a l l e d a n " I I O , " w h i c h i s a n I n s t r u c t i on a l Improvement Officer, but I don't know that to be for sure. Q. A. Right. But it would be a member of, like, the

superintendent's cabinet.

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Q. A.

So do you know when she departed Guilford? Yes. She went with Dr. Terry Greer

i m m e d i a t e l y a f t e r h e t o o k h i s p o s i t i o n i n S a n D i eg o . Q. from -A. Q. A. Q. 2010? A. Q. A. Yes, and then -- yes. And what were your job duties going to be? She had marketed it to me as to be the Yes. -- being principal to administration? Yes. And so you had a phone interview in July of Okay. So that's how she transferred

"Number Two" for the district, and that's what I was called in the newspaper. A n d t h a t i s i n l i n e w i th

serving on her cabinet and having different a s s i g n m e n t s , t o s u p e r v i s e c e r t a i n d e p a r t m e n t s w i th i n the district. A n d I d i d n o t r e c e i v e a j o b d e s c r ip t i o n

u n t i l w e l l a f t e r j o i n i n g P e o r i a S c h o o l D i s t r i c t 15 0 , but I had a general outline of knowing what an associate superintendent was supposed to do. Q. A. Q. A. And you decided to take the position? Yes. You are married. What about your husband?

She offered us both a position at the same

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UNGURAIT,

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time.

Both of us flew to Peoria, together and

s e p a r a t e l y , t o l o o k a t P e o r i a S c h o o l D i s t r i c t 1 5 0, a n d b o t h o f u s w e r e d i s a p p o i n t e d t o n o t e v e r g e t t o wo r k the jobs that were marketed to us. Q. Okay. What job was marketed or was

suggested to your husband? A. He worked in Guilford County Schools in the And so what was suggested to

assessment department.

him over the phone was that he would be in charge of testing and assessment for Peoria School District 150. W h e n w e g o t t h e r e , h e w a s a s s i g n e d a p o s i t i o n w i th i n curriculum versus assessment. Q. A. Q. A. And what did he do in curriculum? He . . . As best you can tell, I mean. Yeah. He spent most of his time working

w i t h s c i e n c e - r e l a t e d c u r r i c u l u m a n d s c i e n c e t e a c he r s versus standardized testing items and testing and evaluation. Q. And standardized testing and evaluation was

his expertise? A. That's what he -- he has worked for Pearson

Educational Measurement for a number of years and then Guilford County for three years in testing and evaluation.

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UNGURAIT,

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Q. A. Q.

What is his first name? Bradley. So you both looked at and you decided to

accept the positions? A. Q. Yes. There wasn't a written job description when

you made the decision? A. No. There was -- I had searched school

board policies, and there was some writings as to what, y o u k n o w , a n a s s i s t a n t o r a s s o c i a t e s u p e r i n t e n d e nt w a s expected to do. A n d t h a t i s a b o u t a l l I h a d i n wr i t i n g

to know what my job was. Q. A. Q. A. Q. A. Q. So you were relying on the word of what -Yes. -- Grenita Lathan told you? Yes. So was your husband? Yes. So when did you come -- well, of course,

you had to make arrangements to move. A. I flew in town when the board voted on my

contract and expected to see my contract on that date, and I didn't. Many people knew about my contract I d i dn ' t And it

because of the newspaper and the lawsuits. see my contract until the third day of work.

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h a d a c l a u s e i n i t t h a t I d i d n ' t k n o w t h a t i t w o ul d have in it. My husband -Q. How many years -- well, the contract -- the

reason you came -- was it a one-year contract or -A. Q. It was three years. And would you have made the move and

d i s l o c a t i o n i f y o u d i d n ' t h a v e - - i f y o u d i d n ' t ha v e assurances of being there for three years? A. grade. No. I have a son who is now in second

I t w a s i m p o r t a n t t o m e a n d m y h u s b a n d t h at w e

h a d a c o m m i t m e n t f r o m a n e m p l o y e r t o , y o u k n o w , ha v e some stability in his elementary years. And, you know,

certainly it wasn't a contract that if I had done fault a t w o r k o r , y o u k n o w , i t w a s n ' t - - I d i d n ' t a n t i ci p a t e having employment if I didn't perform the job. did think I was getting a three-year commitment. Q. It turned out there was a clause in the one Bu t I

t h a t y o u w e r e g i v e n t h a t t h e s c h o o l d i s t r i c t c o u ld terminate on thirty days' notice -A. Q. year? A. Well, I was paid through -- they had to Yes. -- and you were paid through the first

g i v e m e t h i r t y d a y s ' n o t i c e a n d t h e n j u s t p a y t h at

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amount.

A n d t h e s c h o o l d i s t r i c t , o n p a p e r , d e m o te d m e

t o t e a c h e r l e v e l , p a i d m e a t t h a t s a l a r y , a n d t h en terminated me on June 10th. Q. A. Okay. When were you demoted?

I was escorted out of my office the second

week of March, and it took a couple of weeks for them to demote my pay. Q. Okay. So you got to Peoria, you came for

the board vote, and then you had to find a house? A. Q. Yes. And I believe the board appropriated a

moving allowance for you and your husband? A. Yes. It cost over $10,000 to move us from

Greensboro to Peoria. Q. And, of course, you brought your -- you had

an eight -- he was six then? A. Q. A. Q. Yes. And so he started grade school. Yeah. He went to Whittier Elementary.

And I believe you were located in the

Uplands district near Bradley University? A. Q. Yes. So you got there when the contract was

voted on, got a house, and you started work immediately?

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UNGURAIT,

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A. Q.

Yes. You didn't have the job description, but

y o u r e l i e d o n G r e n i t a L a t h a n ' s d e s c r i p t i o n b e c a u se that's who you were working with; correct? A. Q. Yes. And so you thought the job was an assistant

superintendent; correct? A. Q. Associate. Associate. So you would have been -- so your position t h a t i t w a s c o n t e m p l a t e d y o u w e r e t a k i n g , y o u w e re t h e second in command? A. Q. Yes, sir. And would be -- have primary -- have, I

guess, all of the responsibility would be Grenita Lathan, but you would be involved in a lot of the details of management? A. Q. Yes, sir. With the purpose of letting her -- freeing

her time for policy decisions? A. Q. Yes, sir. What sort of position did you learn you had

when you got there? A. I learned that I was -- the position I

t h o u g h t I w a s b e i n g r e c r u i t e d f o r w a s n o t t h e p o si t i o n

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that I held once I got to Peoria, in terms of assignments or management or competence. Q. difference? So what -- could you describe the What position did you actually have? We

h a v e t a l k e d a b o u t w h a t y o u t h o u g h t y o u w e r e g e t t in g . A. district. I had a position of minimal value to the I was not assigned tasks to the scope that I I f e l t o f t e n u n c o m f o r t a b l e b e c a u se

thought I was.

p e o p l e a s s u m e d I h a d r e s p o n s i b i l i t i e s a n d m o r e p ow e r i n decision-making than, in actuality, I did. Q. So you weren't delegated any significant

authority at all? A. I wasn't given a job description until A n d I h a d r e q u e s t e d r e p e at e d l y

after a month of work.

t o h a v e w e e k l y m e e t i n g s w i t h t h e s u p e r i n t e n d e n t so t h a t w e c o u l d g o o v e r m y s c o p e o f w o r k o r e x p e c t a t i o n s. There was a very big climate change r e g a r d i n g m e , b e t w e e n w h e n I w a s r e c r u i t e d t o w h en I appeared in Peoria. Q. Weekly meetings would be consistent with

the associate superintendent job that -A. Dr. Lathan, when I first got there in the

fall of 2011, had something I would describe as a very fluid schedule. S h e d i d n ' t h a v e s e t m e e t i n g s w i th It

p e o p l e o n h e r t e a m o r p e o p l e w i t h i n t h e c o m m u n i t y.

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was very ad hoc, on a daily basis. structure.

It lacked

A n d h a v i n g w o r k e d i n c e n t r a l o f f i c e -- a n d

I w a s t h e o n l y p e r s o n f r o m t h e N o r t h C a r o l i n a t e am t h a t had significant central office experience. I s i mp l y

was trying to replicate what I had seen in other work places. And I think that my request to have some

structure offended the superintendent. Q. Well, without those meetings, you didn't

really know what you were supposed to do. A. Q. Exactly. Was it contemplated that you would have

supervision over principals? A. That's what I had assumed would happen. I

found out that a lot of my assumptions were very wrong. I was assigned -- eventually I was assigned departments. S o I d i d h a v e t e s t i n g a n d e v a l u a t i on . I had technology. I

had special education.

I had -- I'm

t r y i n g t o r e m e m b e r - - s p e c i a l e d u c a t i o n , t e c h n o l og y , testing and assessment, and student assignment. Q. Did you participate with Dr. Lathan in any

e v a l u a t i o n o r i n p u t y o u r e c e i v e d f r o m t h e p r i n c i pa l s when you first arrived? A. I had the opening day of school -- in

G u i l f o r d C o u n t y S c h o o l s , w e h a d a s y s t e m w h e r e p eo p l e on the cabinet would attend every single school

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district -- I mean, every single school in the d i s t r i c t , t o f i n d o u t - - t o p r o b l e m s o l v e , t o f i gu r e o u t w h a t w a s g o i n g o n t h a t a s c h o o l n e e d e d i m m e d ia t e attention to. A n d S u p e r i n t e n d e n t L a t h a n h a d a s s ig n e d a And I

number of people in her cabinet to go to those.

h a d a s s u m e d - - w e l l , i t w a s c o n v e y e d t o u s t h a t we w o u l d h a v e a n a p p o i n t m e n t w i t h c a b i n e t l a t e r i n th e afternoon, where we would discuss all of those opening-day visits. And that was the first time that I

was going to interact with the principals in a supervisory role. Q. A. Did that occur? Dr. Lathan canceled the scheduled meeting

f o r c a b i n e t t o d i s c u s s t h e i m m e d i a t e p r o b l e m s o l vi n g t h a t c o u l d o c c u r w h e n c a b i n e t m e m b e r s a t t e n d s c h oo l s t o f i n d o u t w h e t h e r b u s e s w e r e l a t e o r c l a s s r o o m s n ee d e d materials, and instead she called the principals to the central office. She gave them an hour's notice, and

s h e h a d , I w o u l d j u s t s a y , a n e m o t i o n a l d i s c u s s i on w i t h t h e m a n d t h e n a s k e d t h e i r o p i n i o n o f w h a t t h e y w an t e d f r o m t h e i r s c h o o l s t o m a k e t h e m m o r e e f f i c i e n t v ia writing it down on a form, a piece of paper, and dismissed the principals. Q. Okay. So this was just an interview, and

they weren't given any preparation or time to --

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A. Q.

No, they were not. So this is more of a

stream-of-consciousness discussion? A. She called them down. She was visibly

emotional about a number of things that occurred on the first day that she heard about. I b e l i e v e h e r m oo d w a s

completely affected by Randy Simmons's wife was a guidance counselor at Peoria High School and she had h a d s o m e i n t e r a c t i o n s w i t h R a n d y S i m m o n s ' s w i f e th a t u p s e t h e r g r e a t l y , t h a t s h e h a d t a l k e d a b o u t d u r in g t h e day. A n d t h a t a f f e c t e d h e r m o o d w h e n s h e t h e n l at e r

talked to the principals, in my opinion. Q. All right. Who is Randy Simmons? And what

is his wife's -A. Randy Simmons used to be the principal at

Peoria High School. Q. A. And what was the matter involving his wife? She didn't like the way that his wife was

dressed and found it offensive. Q. A. Q. A. Q. A. How was his wife dressed? I did not see her. Was it described to you? Yes, it was. And what was the description? That she had tight clothing on and they -Did you see her?

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s h e - - a n d G r e n i t a L a t h a n a n d D r . L a T o y K e n n e d y fo u n d i t o f f e n s i v e , w h a t s h e h a d o n , a n d t h e y o p e n l y m oc k e d and made fun of the way she was dressed. Q. A. Did she work for the district? She, I believe, was the guidance counselor

at Peoria High School. Q. A. And the district had a dress code? A funny thing is that Peoria School

D i s t r i c t 1 5 0 d o e s n ' t h a v e a d r e s s c o d e , i n m y m e mo r y , in the ways that I have worked at other school districts. S o I w a s s u r p r i s e d a t h o w p e o p l e d r e ss e d i n

Peoria School District 150. Q. Well, of course, at the beginning of school

in Peoria it is very hot. A. Q. A. It is hot, with no air conditioning. Right. Yes. But I was uncomfortable with my supervisor mocking an employee. Q. Well, if she disagreed with the dress, it

was a simple enough matter just to tell her. A. personal. Q. Okay. So then she brings in, with one Yes, but this was -- she made it very

hour's notice, just -- the principals come in.

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A.

She was concerned about two things.

And

f r o m - - l a t e r - - o u r p r i n c i p a l s ' p e r s p e c t i v e , t h ey shared with me they were confused why she was so visibly angry about these two things. A n d o n e w as , a s

I u n d e r s t a n d i t , P e o r i a S c h o o l D i s t r i c t s c h o o l s wo u l d require students to have the proper immunizations and registration before they attended school, and so she let principals know they were not to turn away students. A n d a n u m b e r o f p r i n c i p a l s f e l t t h a t th a t

was against Illinois state law. And then the second thing that she was c o n c e r n e d a b o u t w a s d i f f e r e n t i a t i o n o f s t u d e n t s th a t didn't have money for lunches on the first day. She

d i d n ' t w a n t t h e m t o r e c e i v e a d i f f e r e n t t y p e o f lu n c h than the rest of the students. And I think all of those things -- those t w o t h i n g s c e r t a i n l y m a d e s e n s e f r o m t h e s t a n d p o in t o f h e l p i n g s t u d e n t s e n r o l l i n s c h o o l s , b u t w e h a d n ot discussed internally, in cabinet, ways to help p r i n c i p a l s o r s u p p o r t t h e m i n e i t h e r p a y m e n t o f th o s e l u n c h e s , s i n c e f o o d s o u r c e s a r e - - f o o d i s o u t s o ur c e d in Peoria School District 150. T h e r e w a s n o m e c ha n i s m

to support them in either one of those concerns. Q. And the principals had no notification that

she wanted to change this?

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A.

No.

But they were told there at that A n d b e f o re t h e y

meeting, and then they were dismissed.

w e r e d i s m i s s e d t h e y w e r e a s k e d t o w r i t e d o w n t h e ir concerns or wants on a piece of paper and that -- she said she would review that later. Q. And, of course, that was the first day.

T h e y h a d n ' t e v a l u a t e d t h e s c h o o l s i t u a t i o n e i t h e r. A. Q. No. Did you -- when did Kevin Curtin first come

to your attention? A. The day previous, we had a back-to-school

rally/kickoff downtown, and Kevin was one of the keynote speakers at that event. Dr. Lathan was, and

K e v i n C u r t i n w a s , a n d B o b b y D a r l i n g f r o m t h e T e a ch e r s Federation spoke as well. And so I did not know very many principals at all because I had just come in town. I d i d s ee

Kevin publicly speak, so I very much knew who he was. Q. A. And where was that held? I believe it was held at the convention

center downtown. Q. recall? A. Yeah, Kevin Curtin's topic was, largely, And what was Kevin Curtin's topic, if you

general education and motivational in nature.

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Q. A. Q. A.

And was -And teacher appreciation. What were your impressions of the talk? I thought that he was a very committed I had a very

principal with compassion and knowledge. positive feeling about his talk. Q. impressions? A.

Did you ever talk with Dr. Lathan about her

Dr. Lathan was very much more concerned I was surprised that

about how her presentation went.

she wasn't more affirmative of Mr. Curtin's talk. Q. When is the next time you had occasion to

come in contact with Mr. Curtin? A. During the principals' meeting where they

w e r e a s k e d t o w r i t e d o w n t h e i r w a n t s a n d t h e r e q ue s t s . Q. Dr. Lathan? A. So Dr. Lathan didn't hold that cabinet Did you go over those requests with

meeting that afternoon, and people went home from work. But there were a number of people left, that had been r e c r u i t e d f r o m N o r t h C a r o l i n a , l a t e , i n h e r o f f i ce , a s well as Mr. Tim Delinski. A n d t h e r e w a s a n i n f o rm a l

meeting that was then held late into the evening, where they reviewed those requests. Q. And what was Dr. Lathan's reaction to Kevin

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Curtin's requests? A. She was not supportive of his requests.

S h e s a i d t h a t h e s h o u l d k n o w h o w t o r u n h i s s c h o ol a n d he should know better than to ask for a number of t h i n g s t h a t h e h a d a s k e d f o r a n d c a l l e d h i m a " w hi n e r . " Q. this -A. Q. A. I was terrified at that point. And why were you terrified? Because the entire episode I was expecting Did you see anything inappropriate about

t o b e h a n d l e d m u c h m o r e p r o f e s s i o n a l l y , b e c a u s e we h a d solicited requests from our principals and I was used t o m y l e a d e r s h a n d l i n g t h i n g s m u c h m o r e s y s t e m a t ic a l l y , s u c h a s i f a p r i n c i p a l r e q u e s t e d s o m e t h i n g t o m a ke t h e i r s c h o o l r u n , h o n o r i n g t h e r e q u e s t v e r s u s m o ck i n g the person for asking for it. Q. A. She was derogatory with him personally? Yes. And she was derogatory of two other

principals that I remember in particular -- well, actually, three in particular. Q. A. Who were they? The first one was Mike Barber. The school

that he was principal of at the time was Irving. I r v i n g , i n m y u n d e r s t a n d i n g , h a d b e e n - - t h e p r o pe r t y h a d b e e n s o l d f o r t h e p r i n c i p a l - - I m e a n , f o r t he

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b u i l d i n g t o b e d e m o l i s h e d s o t h a t t h e h o s p i t a l c ou l d u s e i t i n w h a t e v e r c a p a c i t y , w h e t h e r i t w a s a p a rk i n g lot or not. And she called him "the captain of the Titanic," because Mike had volunteered to remain with the school until it closed. A n d s h e s a i d t h a t , yo u

k n o w , i t w a s a s i n k i n g s h i p a n d t h a t h e w a s a b r av e m a n f o r v o l u n t e e r i n g t o s t a y t o t h e v e r y e n d , l i k e t he captain of the Titanic. A n d s o s h e a n d T i m D e l i ns k i

o f t e n w o u l d , y o u k n o w , c a l l h i m , y o u k n o w , " t h e ma n with the sinking ship." Q. Well, of course, there were still students

there that needed -A. Q. A. Q. A. Yes. -- to be taught. Yes. Was he allowed to remain for the two years? As I understand it, he was transferred out

of the school, and Mr. Curtin was transferred to Irving. Q. Did you ever attend a function where Kevin

Curtin gave a presentation at Bradley University on -A. That was previous to my employment at

Peoria School District 150. Q. You weren't there?

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A. Q.

I was not there. Did you ever talk with Dr. Lathan about

that presentation? A. event. Q. Did she talk about Mr. Curtin's She had told me that she attended that

presentation at all? A. Q. No. Were you aware of Mr. Curtin's efforts

involved in the community in the -- in an underprivileged school that he served? A. Q. Yes. And had that been a success, as far as you

understood it? A. Yes. So in the winter of 2011, one of my

assignments was to gather all of the data on p r i n c i p a l s , a s s h e w a s c o n s i d e r i n g c l o s i n g c e r t a in s c h o o l s a n d c o n s i d e r i n g m o v i n g p r i n c i p a l s t o d i f fe r e n t locations. A n d s o M r . B r y a n C h u m b l e y a n d I h a d wo r k e d

on a project together to briefly summarize the s t u d e n t - a c h i e v e m e n t d a t a o f a l l p r i n c i p a l s a n d h ow m a n y years they were in their building. A n d M r . C u r t in w a s

o n e o f t h e l o n g e s t - s e r v i n g p r i n c i p a l s , w i t h o n e of t h e healthiest data -- student-achievement data sets in P e o r i a S c h o o l D i s t r i c t 1 5 0 , a n d I h a d p r e s e n t e d th a t t o

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her. Q. rate him? A. I would rate him as one of the best What was your conclusion? How would you

principals in Peoria School District 150 in terms of maintaining student achievement in a challenging environment. Q. Garfield? A. He was at Garfield. And I also worked with I think he was at -- was it -- what school?

B r a d l e y U n i v e r s i t y a n d M r . Y o r k P o w e r s f o r t h e t im e t h a t I w a s a s s i g n e d t o T i t l e 1 , i n f e d e r a l p r o g r am s , which I had forgotten earlier to mention. And we

w o r k e d w i t h t h e c o m m u n i t y s c h o o l s , t r y i n g t o r e g ro u p . There was a lot of effort previous to Dr. Lathan on community schools, Glen Oak and Garfield, and we were t r y i n g t o r e g r o u p , b e i n g a n e w t e a m , u n d e r s t a n d i ng w h a t w o r k h a d b e e n d o n e p r e v i o u s a n d w h a t w o r k w a s s t il l maintained. And so I knew of Mr. Curtin's work, via

Bradley, in that endeavor. Q. I believe it's been described to me as --

he gave an example as it took him about six years to get it started, but he would have, like, Prairie State L e g a l S e r v i c e s c o m e , h e w o u l d h a v e t h e a n i m a l w e lf a r e people to come tell them about pets, the American Red

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C r o s s , a l l s o r t s o f c o m m u n i t y g r o u p s s o t h e c o m m un i t y would be more involved in the school. A. Yes. Mr. Curtin was widely recognized as

being incredibly effective at hooking community resources together with the needs of his student population. A n d h e w a s r e c o g n i z e d b y t h o s e e f f o rt s

t h r o u g h h i s w o r k w i t h B r a d l e y U n i v e r s i t y a n d w i t hi n t h e community. I have worked in many locations, and I h a v e n ' t s e e n q u i t e t h e s u c c e s s t h a t M r . C u r t i n h ad while he was at Garfield. Q. So you viewed it as a situation where it

was a success and needed to continue? A. Yes. That was a concern. When Dr. Lathan

w a s p l a n n i n g o n c l o s i n g s c h o o l s b e c a u s e o f t h e b ud g e t situation in Peoria, Garfield was often mentioned as a school to close, and I had personal sadness over knowledge of that being considered because of how truly effective the school and Mr. Curtin and his staff were at helping students there. Q. A. Q. In fact, it was closed. It was closed. But as I understand it, he -- I think it

w a s t r a n s f e r r e d - - t h e p r o g r a m h e h a d i n i t i a t e d wa s transferred to Trewyn.

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A.

I have not been in Peoria after she And other than

announced the principal movement.

knowing that my son's principal is now principal of Trewyn, that's the sum total of my knowledge. Q. A. Q. A. Q. A. Is that Ms. Coleman? The principal of Trewyn? Yes. It is Robin -Robin? Andrews. (Court reporter requests clarification.) BY MR. STEAGALL: Q. Okay. Well, if it couldn't continue at

Garfield, did you have an opinion as to whether Mr. Curtin should continue with the programs he developed at another school? A. Well, it didn't make sense to me in those

discussions -- and I was part of the discussions regarding schools to close through January -- if t a n g e n t i a l l y - - t h a t y o u w o u l d t r a n s f e r a p r i n c i pa l f r o m a s u c c e s s f u l s c h o o l t o a s c h o o l t h a t w a s c l os i n g i n o n e y e a r a n d n o t t r a n s f e r t h a t p r i n c i p a l t o w he r e h i s s t u d e n t p o p u l a t i o n w a s g o i n g , w h i c h w a s T r e w yn . T h a t d i d n ' t m a k e s e n s e , e s p e c i a l l y s i n c e M r . C u r ti n h a d

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t h e s t u d e n t - a c h i e v e m e n t d a t a - - h e h a d q u a n t i t a t iv e d a t a t o s u g g e s t t h a t h e w a s a n e f f e c t i v e p r i n c i p al . Q. A. And he knew those students and teachers. You cannot qualify all of the personal B u t i n o u r f i e l d , e s p e c i a ll y

relationships he had.

u n d e r n e a t h N o C h i l d L e f t B e h i n d , s c h o o l l e a d e r s ar e supposed to look at quantifiable data to make d e c i s i o n s , a n d s h e h a d q u a n t i f i a b l e d a t a t o s u g g es t t h a t M r . C u r t i n w a s t r u l y e f f e c t i v e w i t h h i s s t u de n t s . Q. Well, yeah, we can quantify it, but it

ultimately comes down to knowing them and showing concern; correct? A. Well, yeah, that was just an added bonus.

I m e a n , h e r e y o u h a v e a p r i n c i p a l t h a t c a n s h o w th a t h e c a n g r o w c h i l d r e n a c a d e m i c a l l y - - r i g h t ? - - b u t th e n h e is well-known throughout the community, and I had witnessed firsthand, in my professional opinion, that he mastered the qualitative components, such as relationship building, caring, and compassion. Q. A. Q. These were underprivileged economic areas? Yes. And so the students didn't have good -- a

solid family or social support? A. I would say that the lack of consistency in

f a m i l y s t r u c t u r e i s o n e o f t h e i s s u e s t h a t c o n f r on t e d

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Garfield on a daily basis. Q. And so if Mr. Curtin was able to establish

a relationship, a personal relationship with the students, that gives them structure that they're missing from anyplace else? A. Q. Correct. We had testimony from a parent last week

a b o u t h o w s h e w a s g o i n g t o h a v e t o m o v e b e c a u s e of j o b s , a n d M r . C u r t i n h a d s u g g e s t e d t h a t s h e - - " We l l , y o u ' r e g o i n g t o c u l i n a r y - - y o u ' v e b e e n t o c u l i n ar y school. W h y d o n ' t y o u c a t e r s o m e t h i n g f o r t h e s ch o o l ? "

S h e e n d e d u p g e t t i n g - - s t a r t i n g a c a t e r i n g b u s i ne s s from that and now is a chef at the Embassy Suites in East Peoria. I s t h a t s o m e t h i n g t h a t y o u ' r e t a l k in g

about, the personal relationships? A. Q. Yes. And she also talked about her son Josiah

h a d f i v e - - o r h a d h e r a n d f o u r s i s t e r s a r o u n d , an d h e was having -- acting out somewhat, as boys might do. A n d M r . C u r t i n h a d t a k e n p e r s o n a l t i m e w i t h h i m -- a n d a l w a y s k n e w a l l h i s s t u d e n t s - - a n d w a s t a l k i n g to h i m and helped him through that. A. Yeah, I think with Mr. Curtin it was That's not just how

authentic and it was consistent.

h e w o u l d a c t b e c a u s e t h e r e m i g h t b e a n a d m i n i s t r at o r

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walking through his school, looking at them, but that's how -- that's who he is as a person. Q. Well, that's not -- I don't know. You were

t a l k i n g a b o u t N o C h i l d L e f t B e h i n d a n d a s e a r c h fo r quantifiable data. H o w d o y o u q u a n t i f y M r . C u r t in ' s

relationship with the community, such as Josiah, the s o n h e h e l p e d o u t , a n d t h i s g a l w h o n e e d e d h e l p to s t a y in the district? A. I would say that the community had a lot of

confidence in Kevin because he showed results. Q. A. Well, I guess -Not just test results, but showed results

s u c h a s t h e s t o r y y o u j u s t e x p l a i n e d , w h i c h i s , yo u know, helping families learn how to read so that they could move out of poverty, you know, guaranteeing a family structure there at the school, replicating a family structure at the school, since they might have a broken one at home. I mean, he was well-known by administrators in the district and in the community for being an e f f e c t i v e a d m i n i s t r a t o r t h a t r e a l l y e x c e l l e d a t so m e t h i n g s t h a t o t h e r a d m i n i s t r a t o r s s t r u g g l e d a t , w hi c h i s that extension from school out into the home. Q. And underprivileged areas, do they have a

special need for that?

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A. Q.

Absolutely. Because they don't have any -- they don't

have any other support like you would at -A. Q. A. That's right. -- at Kellar or something -Well, people often don't have college

d e g r e e s o r t h e y d o n ' t k n o w h o w t o r e a d o r t h e y w il l have inconsistent employment. I mean, these are very,

v e r y , v e r y r e a l c o n d i t i o n s t h a t t h e y f a c e f o r s u rv i v a l . Q. A. Q. Single parents? That is one of the issues. And I think he said that a lot of

grandparents are raising the children? A. Well, it's just difficult if you do have a I think single parents do a great job

single parent.

raising their children, but they often have time constraints. And the school would fill in those areas

of time, when children were sometimes left u n s u p e r v i s e d , t h r o u g h h a v i n g d i f f e r e n t p r o g r a m s an d outreach. And he did not get paid extra for being a principal like that. You make the same amount of money

a c r o s s t o w n i n o n e s c h o o l t h a t t h e k i d s g o h o m e an d t h e r e a r e f a m i l i e s f o r t h e m t o g o t o , a s y o u d o at h i s s c h o o l w h e r e y o u h a d t o b e c r e a t i v e a b o u t s c h e d u li n g

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programs and support. Q. available? A. Q. Yes. So as far as your review, you stated your D i d y o u h a v e a n y i n t e ra c t i o n And he also took a lot of time to be

opinion of his abilities.

w i t h D r . L a t h a n , o t h e r t h a n w h a t y o u h a v e p r e v i o us l y described on, I think, his walking in and talking about h i s n e e d s , a b o u t w h a t h e r r e a c t i o n o r h e r o p i n i o ns w e r e of Mr. Curtin? A. Q. A. Q. Not on that opening day, no. But after that opening day, did you? Yes. And tell me what those interactions were,

how many, and how you came to -- were you able to draw a n o p i n i o n a s t o w h a t h e r r e a c t i o n w a s t o M r . C u rt i n ? A. Well, I noticed a pattern with Dr. Lathan

t h a t s h e p e r s o n a l i z e d r e l a t i o n s h i p s i n h e r p r o f e ss i o n a l environment, and that made me uncomfortable. I had talked about the one that she -- you know, the nickname she had given Mr. Barber. She

had -- she had imitated and mocked the Washington Gifted principal, Joan Wojcikewych. Q. A. And she had --

What did she mock her about? She would imitate speaking like her in

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s i t u a t i o n s w h e r e w e w o u l d t a l k a b o u t W a s h i n g t o n Gi f t e d . I witnessed that on two occasions, where she pretended -- she affected a white speaking voice. Q. A. Q. And it was not flattering? No. And you were talk -- you were talking about

h e r p e r f o r m a n c e w h e n t h i s w e n t o n , o r s o m e t h i n g to d o with her? A. school. Well, Joan was a great advocate for her And so consistent with the opening day, when

people would ask for things for their school or, you know, ask for awareness or ask to attend certain e v e n t s , t h a t w a s t h e c o n t e x t i n w h i c h s h e w o u l d ma k e fun of Joan. I f J o a n w a s t r y i n g t o e x p l a i n , m a y be , h e r

perspective or why the school would do a certain thing a n d t h e s u p e r i n t e n d e n t d i s a g r e e d w i t h i t , t h e n s he m a d e i t v e r y p e r s o n a l i n s t e a d o f j u s t s a y i n g , " I d i s a gr e e with the principal." Q. resources. Well, and, of course, you've got limited If they're not available, they're not

available; correct? A. Yeah. And that's a special school with A n d s o e a c h s c h o o l h a s it s o w n

very committed parents.

needs, and that one being very different since it was, you know -- it didn't have a zoned enrollment. It w a s

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all through application.

And so that often takes up a

lot of time to make sure that that is being run correctly. A n d I t h i n k J o a n w a s j u s t c o n c e r n e d wi t h

the new superintendent, that she would understand the goals and the mission and the commitment of the p a r e n t s , a n d s h e w o u l d t r y t o e x p l a i n t h i n g s t o th e superintendent. Q. A. And wasn't successful, apparently? No, she was transferred out of her school

i n t o a n o t h e r o n e a n d I b e l i e v e t o o k r e t i r e m e n t i ns t e a d . Q. From what you could see, was Washington

Gifted School a success when Joan was running it? A. Very. It -- so you had asked earlier the

occurrences I had with Kevin, and I bring that up to -I b r i n g J o a n u p , a n d w e h a v e n ' t c o v e r e d S t e v e P t ac e k , but that would be another one. T h e s e a r e p r i n c i pa l s

that had great data sets from student achievement in t h e p r o j e c t t h a t M r . C h u m b l e y a n d I d i d , t h a t w o ul d suggest that they were effective principals. But

t h e s e - - a l l t h e s e p r i n c i p a l s w e r e n e g a t i v e l y i m pa c t e d in placement decision-making. Q. Okay. So even if we're -- Joan -- what was

her last name, again? A. Q. Wojcikewych. So Joan Wojcikewych, Kevin Curtin, and the

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other person that you just mentioned . . . A. Yeah. There was Mike Barber, Kevin Curtin, T h e s u p e r i n te n d e n t

Joan Wojcikewych, and Steve Ptacek.

would frequently talk about them in very personal terms. Q. A. Q. A. Would she mock them? Yes. All three of them? Make -You said --

She didn't mock Mike Barber other than B u t s he

calling him "the captain of the Titanic." imitated Joan.

She mocked -- Steve Ptacek, at the fall of 2 0 1 1 , b e c a u s e o f h i s c o n t e n t i o u s r e l a t i o n s h i p w i th t h e s u p e r i n t e n d e n t , a c t u a l l y w e n t t o t h e e m e r g e n c y r oo m f o r h e a r t - a t t a c k - l i k e s y m p t o m s , a n d s h e m o c k e d h i m f or going to the hospital and imitated him crying in front of her during a meeting over that episode. Q. A. School. Q. Now, Joan Wojcikewych, Kevin Curtin, Mike What position did Steve Ptacek have? He was principal over Richwoods High

B a r b e r , S t e v e P t a c e k , f o r a l l t h e m e a s u r e m e n t s y ou s a w i n t h e q u a n t i t a t i v e d a t a , t h e i r s t u d e n t a c h i e v e m en t s were very good? A. Absolutely.

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Q.

And they were doing everything they should

as far as their scores and improving student achievement? A. From a quantitative standpoint, these So if you were

principals were incredibly effective.

going to make assignment changes to them, it had to be based on a different criteria other than if they were effective in growing student achievement. Q. What other basis is there, as a principal,

to evaluate than student achievement? A. I don't know the criteria she used in

moving any of those principals. Q. Well, you're familiar -- or from your

e x p e r i e n c e w i t h e d u c a t i o n , i s t h e r e - - d i d y o u s ee any -- well, let me ask it this way. Is there an

a c c e p t e d s t a n d a r d t o e v a l u a t e p r i n c i p a l s ' p e r f o r ma n c e ? A. Well, the Peoria School District 150 had an I was not part of it. M r . Ti m

evaluation process.

Delinski and Ms. Revonda Johnson were tasked with evaluating principals. I r e a l i z e d , j u s t i n s i t t in g i n

c a b i n e t m e e t i n g s a n d d i f f e r e n t m e e t i n g s , t h a t t h ey h a d t o e v a l u a t e t h e i r p r i n c i p a l s b y a c e r t a i n p o i n t in 2 0 1 1 before discontinuing their contracts. A n d b e c a u se o f

d i f f e r e n t r e a s o n s , M r . D e l i n s k i a n d M s . J o h n s o n mi s s e d those deadlines to evaluate a principal and give

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s u f f i c i e n t t i m e f o r t h e p r i n c i p a l t o r e m e d i a t e t he i r behavior for her to discontinue those contracts. that make sense? Q. A. Q. A. Yes. Okay. I understand. So because they missed those deadlines, Does

they could not discontinue a number of people's contracts. And, thus, I believe, in my opinion, they

were transferred to other schools versus being terminated like me. Q. them. Well, okay. So we've got -- you have named Steve Ptacek left

One of them took retirement.

Richwoods for another position. A. Yes. Mr. Ptacek was under great stress by

M r . D e l i n s k i a n d M s . J o h n s o n a n d D r . L a t h a n t o f in d employment outside of the district. Both -- they --

t h e y s t r o n g l y e n c o u r a g e d h i m t o d o t h a t a n d o p e n ly mocked him behind closed doors. And he secured

e m p l o y m e n t a s a s u p e r i n t e n d e n t d o w n s t a t e i n J a n u ar y o f 2011. Q. A. Okay. No. But -Yeah. Well, yeah, 2012. I apologize.

January 2012. When he went to hand in his resignation to

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Dr. Lathan and the board, after months of being encouraged and pretty much told directly to leave the d i s t r i c t , D r . L a t h a n r e f u s e d h i s r e s i g n a t i o n , s t at i n g that he broke his contract, and put in a process, a w a y , t o t e r m i n a t e h i m b y M a r c h 1 s t a n d d i d n o t p ay h i m for the remainder of the year. It was only through the involvement of his lawyer, Nile Williamson, who was also my lawyer, that Mr. Williamson was able to negotiate an exit for M r . P t a c e k i n a w a y t h a t h e c o u l d r e t a i n h i s d i g ni t y a n d p a y c h e c k t o h e l p s u p p o r t h i s f a m i l y f o r t h e re s t o f the year. Q. way. With your familiarity in education, is s t u d e n t p e r f o r m a n c e t h e p r i m a r y m e t h o d a n d s t a n d ar d t h a t e d u c a t o r s u s e t o e v a l u a t e p r i n c i p a l s ' p e r f o rm a n c e ? A. It is supposed to be the primary objective Well, from all the -- let me ask you this

in how we evaluate each other's performance. Q. So Mr. Ptacek was essentially run out of

t h e d i s t r i c t , y e t h e h a d s u p e r i o r s t u d e n t a c h i e v em e n t s ? A. From student achievement, if you consider

Mr. Ptacek's scores on state-mandated assessments as w e l l a s a d v a n c e d - p l a c e m e n t e x a m i n a t i o n s , w h i c h w as critically important to the parents and students of

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Richwoods, he was a very effective principal. Q. So what was he doing -- did you see

anything objective he was doing wrong? A. Q. A. Q. No. She didn't like him.

Dr. Lathan just -- she did not like him? She did not like him. Mr. Curtin had similarly high -- very high

achievement -A. Q. Yes. -- for his students? Unlike Richwoods,

w h i c h h a s s o m e o f t h e m o r e p r o s p e r o u s a r e a s , h e ha d some of the worst underprivileged areas as far as economics goes, didn't he? A. Q. Yes. And it had taken a long time, but he had

been a total success; correct? A. Q. Yes. And yet Dr. Lathan wasn't satisfied with

his performance? A. Q. No. From what you reviewed of it, was his

performance superior? A. Q. A. Yes. Same as Mr. Ptacek? Yes.

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Q. A. Q. A. Q.

And same as Joan Wojcikewych? Yes. So -And Mr. Barber. Yeah, and Mr. Barber. So you've got four superior-performing

principals and Dr. Lathan wanted to transfer or terminate their employment? A. Q. A. Q. Yes. What was her reason for that? I don't know. The only thing you can -- I mean, you S h e w o u l d c o n t i nu e - -

described a personal hostility.

I g u e s s , w i t h M r . B a r b e r i t w a s , " W e l l , h e ' s c a p ta i n o f the Titanic." A. Q. Yes. I mean, somebody has got to serve out that

school, don't they? A. Well, all of the personalization of the

a d m i n i s t r a t o r s t h a t I b e l i e v e d , t h r o u g h m y p r o f e ss i o n a l e x p e r i e n c e , t o b e e f f e c t i v e w a s v e r y d i s t u r b i n g an d u n s e t t l i n g t o m e a n d m a d e m e e x t r a o r d i n a r i l y f e a rf u l . Q. Have you ever seen that in any place else

you have worked? A. No.

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Q.

So these people are being evaluated just on

D r . L a t h a n ' s l i k e s o r d i s l i k e s o f t h e m p e r s o n a l l y, n o t what they do? A. Yes. And I think her opinion of whether

she likes a person or not is greatly affected by Mr. Tim Delinski and Dr. LaToy Kennedy. Q. A. And who is Tim Delinksi, and what is his -He is -- I don't know what their titles are

exactly, but he is essentially an Instructional Improvement Officer -- or like the supervisor of elementary school principals. Q. Did he bring her -- did she -- did he come

in with Dr. Lathan? A. Well, he had been a principal in Peoria

S c h o o l D i s t r i c t 1 5 0 , s o h e w a s t h e o n l y P e o r i a n on t h e team. Q. you tell me? A. Q. Dr. LaToy Kennedy. And what are the -- Dr. Lathan is a black Okay. And then the other one was -- could

woman; right? A. Q. A. Q. Yes. Tim Delinski, what is his -He is a white man. A white male.

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. A. Q. white man? A. Q. A. Q. man? A. Q. white woman? A.

And LaToy Kennedy? Is an African-American female. And then we've got Mike Barber, who is a

Yes. We've got Kevin Curtin, who is a white man? Yes. And we've got Steve Ptacek, who is a white

Yes. And we have Joan Wojcikewych, who is a

Yes. And my husband and I are Caucasian. Did you ever see Dr. Lathan mock any black

employees or principals like she did these white -A. Q. describe it. No. Let me ask it this way, as a way to Am I correct it's -- you have never seen

a black person mock white people like Dr. Lathan did, in employment? A. I have never worked for an African-American

s u p e r v i s o r w h o h a s p e r s o n a l l y m o c k e d t h e i r s u b o r di n a t e . Q. Well, this mocking she did of these white

p e o p l e , w o u l d i t b e s i m i l a r t o t h e c h a r a c t e r s t h at w e

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h a v e d o n e s o m u c h t o w o r k - - t h e c h a r a c t e r i z a t i o ns t h a t we have done so much to work away from for black -that whites make about blacks? A. Q. I found it very disturbing. And I guess what I'm asking is, we all know

the stereotypes we have had about blacks, and we have struggled with those. W a s t h i s t h e r e v e r s e , a b la c k

person doing it to white people? A. Q. A. Q. I would -- I would agree with that, yes. And totally unacceptable in -Yes. I mean, you were a subordinate. Did you

e v e r e x p r e s s - - w e l l , w a s y o u r d i s c o m f o r t w h e n s he d i d this, was that -- was she able to tell you were discomforted by that? A. I think she did. And I think that's what

cooled -- one of the things that cooled our relationship. I d i d n ' t k n o w h o w t o r e s p o n d i n t ha t I w a s u s e d t o s c h e d ul e s .

unprofessional environment.

I was used to people speaking with respect to one another. I w a s u s e d t o t r y i n g t o s u p p o r t p r i n c i pa l s

versus trying to bring out negative aspects about somebody requesting assistance. A n d s o I w a s v e ry

u p s e t , a n d I c a l l e d a n u m b e r o f p e o p l e t o s e e k h el p a n d advice because --

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Q. A. Q. A.

"How do I handle this in this job?" Yeah. Okay. I -- I -- yes. And I even -- I talked to

b o a r d m e m b e r s o f f - s i t e i n a m e e t i n g t h a t t h e y a r ra n g e d . T h e n P r e s i d e n t D e b b i e W o l f m e y e r v i a B o b G a t e s a r ra n g e d an off-site meeting between me, Bob, and Debbie, and L i n d a B u t l e r , t h e n v i c e c h a i r , t o d i s c u s s m y c o n ce r n s , including the opening day principals' requests as well as the treatment of me coming to Peoria. Q. And you told -- did you tell them about the

racial characterization? A. I told them that she mocked principals

personally, yes. Q. that? A. two hours. They listened to me. We spoke for about What was their reaction when you told them

When we left, Linda Butler said that this

w a s a g o o d m e e t i n g b e c a u s e i t s h o w e d t h a t I h a d du e p r o c e s s a n d t h e a b i l i t y t o t a l k t o t h e m a b o u t t h in g s . After that meeting, then I was assigned a project, second semester, where we had a similar p r o j e c t , w h e r e p e o p l e w e r e s u p p o s e d t o - - o n c a b in e t - were supposed to go to schools and come back with findings. And it was much -- I was tasked with

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h a n d l i n g i t i n a v e r y d i f f e r e n t w a y , w h e r e w e w o ul d g a t h e r t h e e v i d e n c e i n a s p r e a d s h e e t f o r m a t a n d th e n discuss the problems. I never knew if that assignment was because I was listened to or if it was a punishment for bringing the concern forward. Q. Well, ultimately, Dr. Lathan wanted you

fired and the board went along with it; correct? A. Q. Wolfmeyer? A. Q. They voted unanimously to fire me. Okay. When she spoke of due process, I Yes. That included Linda Butler and Deb

g u e s s h e r p r o c e s s w a s s h e l i s t e n e d t o y o u a n d t h en fired you? A. Q. Yes. Well, you know, look at this -- they didn't

exactly -- what you experienced was not a neutral or objective decision-maker? A. It was -- I have never seen anything like

this in all my years in education. Q. So you had met with them, like, before

March of 2011, would it be? A. Q. Yes. And you had told the board about these

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problems with Dr. Lathan? A. Q. A. Q. A. Q. A. Q. Yes. Well, I had told two board members.

And that was? Debbie Wolfmeyer and Linda Butler. And then you met with -And the lawyer, Bob Gates. Yeah, and their attorney. Yes. You told them about them. And then you got

this other assignment, and you're gone by March? A. Q. fired you? A. Q. Right. Now, this thing about Mr. Barber being Yes. Okay. Well, they listened to you and then

c a p t a i n o f t h e T i t a n i c , w e l l , i n f a c t , t h e y ' r e c lo s i n g that school. didn't they? A. It was a great sorrow to me to objectify T h e r e a r e m a n y w o n d er f u l T h o s e k i d s s t i l l n e e d e d t o b e e d u c at e d ,

that school in those terms.

c h i l d r e n t h a t a t t e n d e d t h a t s c h o o l , a n d t h e r e w e re s o many giving community partners. And just the

c h a r a c t e r i z a t i o n o f t h a t s c h o o l i n t h o s e t e r m s w as o n e of the most hurtful things that I saw. Q. Well, of course, the captain of the

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Titanic, if you use that example -A. Q. He died. Yeah. She wasn't using it in a

praiseworthy manner, was she? A. Q. No. Well, of course, the captain of the Titanic

d i d h i s d u t y , u n l i k e t h e I t a l i a n c a p t a i n , a n d s t ay e d o n h i s s h i p a n d m a d e s u r e e v e r y b o d y g o t o f f t h a t c o ul d ; correct? A. Yes. I believe that she -- and this is just my o p i n i o n - - s h e h a d a p r o b l e m w i t h M i k e B a r b e r a p pl y i n g f o r m y p o s i t i o n a s a s s o c i a t e s u p e r i n t e n d e n t a n d di d n ' t f e e l t h a t h e w a s q u a l i f i e d f o r t h e j o b a n d t h e n ma d e i t very personal afterwards, you know, even in his application of the job. Q. And as far as you saw, there wasn't any

problems with Mike Barber? A. job. Q. Well, and he didn't get it, but he was Mike Barber definitely could have done my

still a good principal? A. He is an exceptional principal. MR. STEAGALL: record. Okay. Let's go off the

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 on. BY MR. STEAGALL: Q. employment?

(Off the record.) MR. STEAGALL: Now we're going back

Was there ever a board meeting held on your Y o u w e r e t a l k i n g a b o u t a F e b r u a r y 2 01 1

board meeting? A. Yes. We had a board meeting -- Peoria

School District 150 held board meetings down on W i s c o n s i n A v e n u e , a n d o n a s c h e d u l e t h e y w o u l d t ak e t h e board meeting on the road, to try to outreach to the community. W e h a d a b o a r d m e e t i n g a t L i n c o l n M i dd l e

School in February of 2011. Q. A. What part of town is that located in? I believe that's East Peoria -- no. You know where I

mean, it's Lincoln Middle School. Lincoln Middle School is. Q. A.

Well, actually, is it below the bluff? Yes. It's just -- it shares the same zone

pattern as Irving -Q. A. Q. A. Q. Yeah. -- Elementary, where Kevin is now. It's down in the valley, below the bluff? Mm-hmm. The oldest section of Peoria and the most

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underprivileged? A. Q. A. sorry. Q. A. Peoria. Q. with you. number. A. Q. A. Q. correct? A. Q. Those are challenging neighborhoods, yes. They have done -- south of downtown, they Well, actually, I'm not -- I'll be honest I d o n ' t k n o w t h a t I w o u l d k n o w t h e s t re e t I know that below the bluff -It's not far from downtown. Yeah. Below the bluff -That's right. Yes. It was zoned at one time for Woodruff. I d o n ' t r e m e m b e r t h e s t r e e t n a m e s o f P e o ri a . That's all right. There's a lot I'm trying to block out from I'm

It's east bluff, definitely. Yeah. And those are rough neighborhoods;

have done some community housing and things like that, cleared out a lot of the housing. B u t n o r t h i s -- a n d

then once you get past that south, past western, it's f a i r l y r o u g h n e i g h b o r h o o d s t h e r e a s w e l l , i s n ' t it ? A. Yes. And Lincoln Middle School is supposed

t o b e o n t r a c k t o b e a K A C o m m u n i t y S c h o o l , s i m i la r t o what Kevin was trying to accomplish at Garfield.

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Q. A.

And so what happened at that meeting? Well, Dr. Lathan had recruited a principal

f r o m N o r t h C a r o l i n a , s o t h e r e w a s a N o r t h C a r o l i ni a n running that school at Lincoln. And previous to that February meeting, we h a d k n o w n , b e h i n d c l o s e d d o o r s , t h a t w e w e r e g o i ng t o close Garfield for about a month. And it became very

a p p a r e n t t o m e t h a t K e v i n C u r t i n h a d n o t b e e n t a lk e d t o r e g a r d i n g t h e p l a n s f o r h i s s c h o o l o r t h e p l a n s fo r him. He -Well, each school on this traveling -wait. I'm sorry. In the previous months, Dr. Lathan had scheduled schools to showcase their strengths to the b o a r d o f e d u c a t i o n , s o a n y b o a r d m e e t i n g m i g h t h av e o n e to three schools scheduled. different ways to do that. And schools chose S o m e s c h o o l s s c h e d u l ed i t

in children to sing, other schools had data p r e s e n t a t i o n s a n d t h a t s o r t o f t h i n g , a n d t h e r e wa s n ' t any one set way. Principals weren't directed to

display their school in any particular way. While at Lincoln Middle School, Dr. Lathan h a d q u i t g i v i n g m e b o a r d p a c k e t s , l i k e t h e r e s t of t h e b o a r d m e m b e r s a n d C o m p t r o l l e r D a v e K i n n e y , s o I wa s t h e only person sitting on the horseshoe that didn't have

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anything in front of them. Q. A. So you didn't know what the agenda was? I didn't know what the agenda was. And I

had mastered the art of just -- just adapting to the situation at that point. So it had been at about two

m e e t i n g s p r e v i o u s t h a t I r e c o g n i z e d t h a t t h e b o a rd s e c r e t a r y w a s d i r e c t e d t o p r o v i d e p a c k e t s t o e v e ry b o d y but me. I m e a n , s h e d i d t h a t t o m a k e m e f e e l a ce r t a i n So

w a y a n d w a s s u c c e s s f u l i n m a k i n g m e f e e l t h a t w a y. I -Q. Well, you didn't know -- you didn't know

how to prepare, so you just waited. A. Well, I just attended, and I just looked at

the audience. So because -- why that's important that I didn't have a board packet is because I was very a t t e n t i v e t o p a y i n g a t t e n t i o n t o t h e a u d i e n c e s i nc e I didn't have anything in front of me. Q. A. Sure. And Mr. Curtin gave about a 20-minute

presentation that was a PowerPoint. The way we were sitting at Lincoln Middle S c h o o l a s a b o a r d , w e c o u l d n o t s e e t h e P o w e r P o i nt presentation. So even though board members had a copy

of the PowerPoint, I believe, in my opinion, they

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w e r e n ' t a s e n g a g e d b e c a u s e t h e y c o u l d n ' t w a t c h t he slides that Kevin was presenting. Q. Well, they certainly could have asked,

couldn't they? A. But the reason, again -- and all of this is

m y o p i n i o n - - t h e y w e r e n ' t p a y i n g a t t e n t i o n t o t he d e g r e e t h a t t h e y d i d o t h e r s c h o o l s b e c a u s e t h e y ha d k n o w n f o r a m o n t h t h a t D r . L a t h a n w a s c l o s i n g G a rf i e l d . What became apparent to me, though, was t h a t M r . C u r t i n d i d n ' t k n o w t h a t t h e y w e r e c l o s i ng a n d moving Garfield. And so the entire presentation was

i n c r e d i b l y p a i n f u l f r o m t h e p e r s p e c t i v e o f k n o w i ng w h a t w a s g o i n g t o h a p p e n t o h i m a n d h i s s c h o o l , a n d t he board and the superintendent engaged in a type of theater with him. Q. sham? A. Q. Yes. Okay. Well, you say your opinion, but you So it was a -- the hearing was an entire

were able to observe their personal reaction as inattentiveness? A. I felt that they were waiting for him to

end the presentation quickly because they knew he would no longer have a school and that school would not be open.

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Q.

Okay.

So this chance for the school to

s h o w t h e i r s t r e n g t h s a n d t r y t o k e e p o p e n i s a c om p l e t e f a l s e h o o d b e c a u s e t h e d e c i s i o n h a d a l r e a d y b e e n ma d e ? A. Q. community? A. Q. A. Q. A. Yes. Supposedly who they are there to serve? Yes. Okay. Well, that's not honest, is it? Yes. So they were totally misleading the

That -- that -- I don't know if it's

honest, but I know that I have not seen anything like that in my years in education. Q. Okay. And then, so in March, tell me how

you learned about your marching orders. A. Dr. Lathan had informed principals that

t h e r e w o u l d b e a c e r t a i n c u t o f f d a t e t h a t t h e y w ou l d find out what their assignments would be for the f o l l o w i n g y e a r , a n d s h e h a d d i r e c t e d t h e m t o b e by their phones. A n d I w a n t t o s a y t h e t i m e w a s f r om

10:00 p.m. to midnight, and they would get a call from h e r o r s o m e b o d y a t c e n t r a l o f f i c e t o f i n d t h e i r ne w assignment. N o b o d y i n t e r v i e w e d f o r a n y p a r t i c u l ar

p o s i t i o n i n t h e d i s t r i c t , a n d i t w a s a l l c o n d u c t ed b y her. N o p o s i t i o n s w e r e p o s t e d , a n d I w a s n o t t a lk e d t o

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about any of that process. Q.

I had --

But you had just done an evaluation of all

of them, hadn't you? A. I had just conducted a student-achievement A nd

picture of each of the principals in January.

R e v o n d a a n d T i m h a d d o n e t h e e v a l u a t i o n o n a n u m be r o f principals, you know, the sit-down evaluation instrument that they use in Peoria. Since I wasn't talked to about any of this p r o c e s s a n d s h e h a d a l r e a d y i n d i c a t e d t o m e o n n um e r o u s occasions that I would either be fired or demoted to a s s i s t a n t p r i n c i p a l , I a s s u m e d t h a t t h e e n d w a s co m i n g for me quickly. I had hired Nile Williamson when I watched Mr. Ptacek's resignation be denied, because I was very f e a r f u l t h a t t h e s a m e t h i n g w o u l d h a p p e n t o m e , wh e r e even though I was being pushed out by Dr. Lathan I would have to -- I would be penalized for leaving the d i s t r i c t o n m y o w n w i l l , i n t e r m s o f f r o m a c o n t ra c t u a l obligation. And so Mr. Williamson sent a letter to A n d f i v e m i n u t e s a f t e r I r e ce i v e d

Dr. Lathan via fax.

i t , s h e d i d a v e r y q u i c k e v a l u a t i o n a n d I w a s w a lk e d out the door by security. Q. employment? Did that cause you problems finding

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A. Q.

Yes.

Yes.

So you had -- fortunately, you were able to

land back here in Nashville? A. Well, I mean, it caused problems in that I

w i l l h a v e t o e x p l a i n t h i s f o r t h e r e s t o f m y l i f e, a n d I had built up a reputation. S o I a m f o r t u n a t e th a t I

h a d t h r e e d i f f e r e n t j o b o p p o r t u n i t i e s o n t h e h o r iz o n , a n d I s e l e c t e d t h e S u m n e r C o u n t y S c h o o l s p o s i t i o n. So

i t i s n o t i d e a l , c e r t a i n l y , f o r m y f a m i l y a n d I no t t o be together, but I was out of employment for one month. Q. Well, yeah, career-wise you were -- but

y o u ' v e g o t a h u s b a n d a n d a n 8 - y e a r - o l d s o n h o w m an y hours away? A. Q. Seven and a half. And, of course, in your position you're not You don't have the summers off, do

like a teacher. you? A. No.

And when I first joined Sumner County

Schools, there was a lot of interest as to why I was terminated. And I anticipate having to live with that

for the rest of my life. Q. Well, I'm certainly sorry about your

experience in Peoria. Thank you for your time. Would you waive -- do you want to sign

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this, or would you waive it? A. No. I'm fine with waiving the signature. MR. STEAGALL: was a pleasure to meet you. (Proceedings adjourned at 10:22 a.m.) Okay. That's it. It

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REPORTER'S CERTIFICATE STATE OF TENNESSEE COUNTY OF DAVIDSON ) )

I, Patricia W. Smith, Licensed Court Reporter, Registered Professional Reporter, with o f f i c e s i n N a s h v i l l e , T e n n e s s e e , h e r e b y c e r t i f y th a t I r e p o r t e d t h e f o r e g o i n g p r o c e e d i n g s a t t h e t i m e a nd place set forth in the caption thereof; that the proceedings were stenographically reported by me; and that the foregoing proceedings constitute a true and c o r r e c t t r a n s c r i p t o f s a i d p r o c e e d i n g s t o t h e b e st o f my ability. I FURTHER CERTIFY that I am not r e l a t e d t o a n y o f t h e p a r t i e s n a m e d h e r e i n , n o r th e i r c o u n s e l , a n d h a v e n o i n t e r e s t , f i n a n c i a l o r o t h e rw i s e , in the outcome or events of this action. IN WITNESS WHEREOF, I have hereunto affixed my official signature and seal of office this 29th day of April, 2012. _________________________________ PATRICIA W. SMITH, LICENSED COURT REPORTER, REGISTERED P R O F E S S I O N A L R E P O R T E R , C E R TI F I E D COURT REPORTER, and NOTARY P U B L I C F O R T H E S T A T E O F T E NN E S S E E LCR No. 164, Expires 6/30/12 Notary Commission Expires 5/8/12

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