2012-04-27 Michelle Ungurait Sworn Statement

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

S W O R N S T A T E M E N T O F M I C H E L L E U N G U R A I T , 0 4 - 2 7 - 1 2

2

1 The sworn statement of Michelle

2 Ungurait was taken by counsel for Kevin Curtin at the

3 Hyatt Place Nashville Airport, 721 Royal Parkway,

4 Nashville, Tennessee, on Friday, April 27, 2012,

5 beginning at approximately 9:16 a.m.

6 It is agreed that Patricia W. Smith,

7 Licensed Court Reporter, Registered Professional

8 Reporter, and Notary Public for the State of Tennessee,

9 may swear the witness, take the statement, and

10 afterwards reduce same to typewritten form.

11 -------------------------------------------------------

12 INDEX PAGES

13 MICHELLE UNGURAIT:

14 Examination by Mr. Steagall ............... 3 - 56

15

16 EXHIBITS

17 (None offered.)

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NASHVILLE COURT REPORTERS (615) 885-5798


3

1 MICHELLE UNGURAIT,

2 having been duly sworn, was examined and testified as

3 follows:

4 EXAMINATION

5 BY MR. STEAGALL:

6 Q. Can you tell us your name and age, please.

7 A. Michelle Davidson Ungurait, 44.

8 Q. And where do you presently work?

9 A. I work for Sumner County Schools in

10 Gallatin, Tennessee.

11 Q. And that's a suburb of Nashville?

12 A. Yes.

13 Q. And where does your husband live?

14 A. He lives in Oak Ridge, North Carolina.

15 Q. And what does he do?

16 A. He works for Pearson Educational

17 Measurement, and he is a graduate student at the

18 University of North Carolina at Greensboro.

19 Q. Has he been in education as well?

20 A. Yes.

21 Q. How long have you two been married?

22 A. Eleven years this summer.

23 Q. And do you have children?

24 A. Yes.

25 Q. What are their ages, and where are they



4

1 located?

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

3 in Nashville, Tennessee, and a 15-year-old that lives

4 in Nashville, Tennessee. I have a daughter, who is 21,

5 that lives in Chapel Hill, North Carolina. And we have

6 a son, together, who is 8, and he lives in Oak Ridge.

7 Q. So the employment situation is you found

8 employment in Nashville, and, unfortunately, he's in

9 Oak Ridge, and you are separated during the week?

10 A. Yes, because of what occurred in Peoria.

11 Q. Tell us your educational degrees, what

12 universities, and when you got them.

13 A. I have a Bachelor of the Arts from Miami

14 University. I have a Master of the Arts from the

15 University of Arkansas. I have a Master's in Education

16 from Vanderbilt University. And I have a Doctorate in

17 Education from the University of Texas at Austin.

18 Q. And Miami of Ohio -- or that's Miami of

19 Ohio, isn't it?

20 A. Yes.

21 Q. Have you been a school teacher?

22 A. Yes.

23 Q. What did you teach?

24 A. I taught U.S. History and World Geography

25 in Nashville, Tennessee.



5

1 Q. What level?

2 A. High school.

3 Q. And when did you get into administration?

4 A. I went to the Tennessee Department of

5 Education in 2000.

6 Q. And how long did you work there?

7 A. Four years.

8 Q. What did you do there?

9 A. I was in charge of social studies

10 curriculum and verifying assessments for the state

11 level.

12 Q. Was that for the entire state of Tennessee?

13 A. Yes.

14 Q. Where did you go after the Tennessee

15 Department of Education?

16 A. I was recruited to the Texas Education

17 Agency.

18 Q. And I believe that was in Austin?

19 A. Yes.

20 Q. So you were doing -- well, that was a

21 similar government agency?

22 A. It was the same -- yeah, it was the same

23 position but for the state of Texas.

24 Q. And how long were you in Austin?

25 A. Three years.



6

1 Q. So we're looking at, what, 2004 to 2007?

2 A. Yes.

3 Q. And then where did you go after that?

4 A. I was recruited to Guilford County, North

5 Carolina.

6 Q. And you know this is about events in

7 Peoria, Illinois.

8 Guilford County, what city is that?

9 A. That's Greensboro and High Point,

10 North Carolina.

11 Q. Okay. And what -- that was the school

12 district there?

13 A. Yes.

14 Q. And what position did you take at Guilford?

15 A. I had an Executive Director position. And

16 I had different assignments while in Guilford County.

17 I was a principal of a school, I was the secondary

18 curriculum director, and I was the magnet school

19 director.

20 Q. Who was the superintendent when you were

21 there?

22 A. Dr. Terry Greer was the superintendent who

23 recruited me, and then it was Mr. Mo Green after

24 Dr. Greer left.

25 Q. And when did you leave Guilford?



7

1 A. I was asked to become associate

2 superintendent of Peoria via a phone call by

3 Dr. Grenita Lathan in July of 2011.

4 Q. And had you known Grenita Lathan before?

5 A. Not -- not well. I knew of her. When she

6 was an elementary school principal, I was the secondary

7 curriculum director, so we did not work directly with

8 each other. I did work with her school that she was

9 principal of after she left Guilford County. It was a

10 magnet school.

11 Q. Where was she at the time that she was

12 recruiting you to come to Peoria?

13 A. She was in Peoria, Illinois. She had come

14 from San Diego, California.

15 Q. Had she been a superintendent before

16 Peoria?

17 A. No.

18 Q. Do you know her position in San Diego?

19 A. I believe that she served as a type of --

20 something called an "IIO," which is an Instructional

21 Improvement Officer, but I don't know that to be for

22 sure.

23 Q. Right.

24 A. But it would be a member of, like, the

25 superintendent's cabinet.



8

1 Q. So do you know when she departed Guilford?

2 A. Yes. She went with Dr. Terry Greer

3 immediately after he took his position in San Diego.

4 Q. Okay. So that's how she transferred

5 from --

6 A. Yes.

7 Q. -- being principal to administration?

8 A. Yes.

9 Q. And so you had a phone interview in July of

10 2010?

11 A. Yes, and then -- yes.

12 Q. And what were your job duties going to be?

13 A. She had marketed it to me as to be the

14 "Number Two" for the district, and that's what I was

15 called in the newspaper. And that is in line with

16 serving on her cabinet and having different

17 assignments, to supervise certain departments within

18 the district. And I did not receive a job description

19 until well after joining Peoria School District 150,

20 but I had a general outline of knowing what an

21 associate superintendent was supposed to do.

22 Q. And you decided to take the position?

23 A. Yes.

24 Q. You are married. What about your husband?

25 A. She offered us both a position at the same



9

1 time. Both of us flew to Peoria, together and

2 separately, to look at Peoria School District 150, and

3 both of us were disappointed to not ever get to work

4 the jobs that were marketed to us.

5 Q. Okay. What job was marketed or was

6 suggested to your husband?

7 A. He worked in Guilford County Schools in the

8 assessment department. And so what was suggested to

9 him over the phone was that he would be in charge of

10 testing and assessment for Peoria School District 150.

11 When we got there, he was assigned a position within

12 curriculum versus assessment.

13 Q. And what did he do in curriculum?

14 A. He . . .

15 Q. As best you can tell, I mean.

16 A. Yeah. He spent most of his time working

17 with science-related curriculum and science teachers

18 versus standardized testing items and testing and

19 evaluation.

20 Q. And standardized testing and evaluation was

21 his expertise?

22 A. That's what he -- he has worked for Pearson

23 Educational Measurement for a number of years and then

24 Guilford County for three years in testing and

25 evaluation.



10

1 Q. What is his first name?

2 A. Bradley.

3 Q. So you both looked at and you decided to

4 accept the positions?

5 A. Yes.

6 Q. There wasn't a written job description when

7 you made the decision?

8 A. No. There was -- I had searched school

9 board policies, and there was some writings as to what,

10 you know, an assistant or associate superintendent was

11 expected to do. And that is about all I had in writing

12 to know what my job was.

13 Q. So you were relying on the word of what --

14 A. Yes.

15 Q. -- Grenita Lathan told you?

16 A. Yes.

17 Q. So was your husband?

18 A. Yes.

19 Q. So when did you come -- well, of course,

20 you had to make arrangements to move.

21 A. I flew in town when the board voted on my

22 contract and expected to see my contract on that date,

23 and I didn't. Many people knew about my contract

24 because of the newspaper and the lawsuits. I didn't

25 see my contract until the third day of work. And it



11

1 had a clause in it that I didn't know that it would

2 have in it.

3 My husband --

4 Q. How many years -- well, the contract -- the

5 reason you came -- was it a one-year contract or --

6 A. It was three years.

7 Q. And would you have made the move and

8 dislocation if you didn't have -- if you didn't have

9 assurances of being there for three years?

10 A. No. I have a son who is now in second

11 grade. It was important to me and my husband that we

12 had a commitment from an employer to, you know, have

13 some stability in his elementary years. And, you know,

14 certainly it wasn't a contract that if I had done fault

15 at work or, you know, it wasn't -- I didn't anticipate

16 having employment if I didn't perform the job. But I

17 did think I was getting a three-year commitment.

18 Q. It turned out there was a clause in the one

19 that you were given that the school district could

20 terminate on thirty days' notice --

21 A. Yes.

22 Q. -- and you were paid through the first

23 year?

24 A. Well, I was paid through -- they had to

25 give me thirty days' notice and then just pay that



12

1 amount. And the school district, on paper, demoted me

2 to teacher level, paid me at that salary, and then

3 terminated me on June 10th.

4 Q. Okay. When were you demoted?

5 A. I was escorted out of my office the second

6 week of March, and it took a couple of weeks for them

7 to demote my pay.

8 Q. Okay. So you got to Peoria, you came for

9 the board vote, and then you had to find a house?

10 A. Yes.

11 Q. And I believe the board appropriated a

12 moving allowance for you and your husband?

13 A. Yes. It cost over $10,000 to move us from

14 Greensboro to Peoria.

15 Q. And, of course, you brought your -- you had

16 an eight -- he was six then?

17 A. Yes.

18 Q. And so he started grade school.

19 A. Yeah. He went to Whittier Elementary.

20 Q. And I believe you were located in the

21 Uplands district near Bradley University?

22 A. Yes.

23 Q. So you got there when the contract was

24 voted on, got a house, and you started work

25 immediately?



13

1 A. Yes.

2 Q. You didn't have the job description, but

3 you relied on Grenita Lathan's description because

4 that's who you were working with; correct?

5 A. Yes.

6 Q. And so you thought the job was an assistant

7 superintendent; correct?

8 A. Associate.

9 Q. Associate.

10 So you would have been -- so your position

11 that it was contemplated you were taking, you were the

12 second in command?

13 A. Yes, sir.

14 Q. And would be -- have primary -- have, I

15 guess, all of the responsibility would be Grenita

16 Lathan, but you would be involved in a lot of the

17 details of management?

18 A. Yes, sir.

19 Q. With the purpose of letting her -- freeing

20 her time for policy decisions?

21 A. Yes, sir.

22 Q. What sort of position did you learn you had

23 when you got there?

24 A. I learned that I was -- the position I

25 thought I was being recruited for was not the position



14

1 that I held once I got to Peoria, in terms of

2 assignments or management or competence.

3 Q. So what -- could you describe the

4 difference? What position did you actually have? We

5 have talked about what you thought you were getting.

6 A. I had a position of minimal value to the

7 district. I was not assigned tasks to the scope that I

8 thought I was. I felt often uncomfortable because

9 people assumed I had responsibilities and more power in

10 decision-making than, in actuality, I did.

11 Q. So you weren't delegated any significant

12 authority at all?

13 A. I wasn't given a job description until

14 after a month of work. And I had requested repeatedly

15 to have weekly meetings with the superintendent so that

16 we could go over my scope of work or expectations.

17 There was a very big climate change

18 regarding me, between when I was recruited to when I

19 appeared in Peoria.

20 Q. Weekly meetings would be consistent with

21 the associate superintendent job that --

22 A. Dr. Lathan, when I first got there in the

23 fall of 2011, had something I would describe as a very

24 fluid schedule. She didn't have set meetings with

25 people on her team or people within the community. It



15

1 was very ad hoc, on a daily basis. It lacked

2 structure. And having worked in central office -- and

3 I was the only person from the North Carolina team that

4 had significant central office experience. I simply

5 was trying to replicate what I had seen in other work

6 places. And I think that my request to have some

7 structure offended the superintendent.

8 Q. Well, without those meetings, you didn't

9 really know what you were supposed to do.

10 A. Exactly.

11 Q. Was it contemplated that you would have

12 supervision over principals?

13 A. That's what I had assumed would happen. I

14 found out that a lot of my assumptions were very wrong.

15 I was assigned -- eventually I was assigned

16 departments. So I did have testing and evaluation. I

17 had special education. I had technology. I had -- I'm

18 trying to remember -- special education, technology,

19 testing and assessment, and student assignment.

20 Q. Did you participate with Dr. Lathan in any

21 evaluation or input you received from the principals

22 when you first arrived?

23 A. I had the opening day of school -- in

24 Guilford County Schools, we had a system where people

25 on the cabinet would attend every single school



16

1 district -- I mean, every single school in the

2 district, to find out -- to problem solve, to figure

3 out what was going on that a school needed immediate

4 attention to. And Superintendent Lathan had assigned a

5 number of people in her cabinet to go to those. And I

6 had assumed -- well, it was conveyed to us that we

7 would have an appointment with cabinet later in the

8 afternoon, where we would discuss all of those

9 opening-day visits. And that was the first time that I

10 was going to interact with the principals in a

11 supervisory role.

12 Q. Did that occur?

13 A. Dr. Lathan canceled the scheduled meeting

14 for cabinet to discuss the immediate problem solving

15 that could occur when cabinet members attend schools to

16 find out whether buses were late or classrooms needed

17 materials, and instead she called the principals to the

18 central office. She gave them an hour's notice, and

19 she had, I would just say, an emotional discussion with

20 them and then asked their opinion of what they wanted

21 from their schools to make them more efficient via

22 writing it down on a form, a piece of paper, and

23 dismissed the principals.

24 Q. Okay. So this was just an interview, and

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



17

1 A. No, they were not.

2 Q. So this is more of a

3 stream-of-consciousness discussion?

4 A. She called them down. She was visibly

5 emotional about a number of things that occurred on the

6 first day that she heard about. I believe her mood was

7 completely affected by Randy Simmons's wife was a

8 guidance counselor at Peoria High School and she had

9 had some interactions with Randy Simmons's wife that

10 upset her greatly, that she had talked about during the

11 day. And that affected her mood when she then later

12 talked to the principals, in my opinion.

13 Q. All right. Who is Randy Simmons? And what

14 is his wife's --

15 A. Randy Simmons used to be the principal at

16 Peoria High School.

17 Q. And what was the matter involving his wife?

18 A. She didn't like the way that his wife was

19 dressed and found it offensive.

20 Q. How was his wife dressed? Did you see her?

21 A. I did not see her.

22 Q. Was it described to you?

23 A. Yes, it was.

24 Q. And what was the description?

25 A. That she had tight clothing on and they --



18

1 she -- and Grenita Lathan and Dr. LaToy Kennedy found

2 it offensive, what she had on, and they openly mocked

3 and made fun of the way she was dressed.

4 Q. Did she work for the district?

5 A. She, I believe, was the guidance counselor

6 at Peoria High School.

7 Q. And the district had a dress code?

8 A. A funny thing is that Peoria School

9 District 150 doesn't have a dress code, in my memory,

10 in the ways that I have worked at other school

11 districts. So I was surprised at how people dressed in

12 Peoria School District 150.

13 Q. Well, of course, at the beginning of school

14 in Peoria it is very hot.

15 A. It is hot, with no air conditioning.

16 Q. Right.

17 A. Yes.

18 But I was uncomfortable with my supervisor

19 mocking an employee.

20 Q. Well, if she disagreed with the dress, it

21 was a simple enough matter just to tell her.

22 A. Yes, but this was -- she made it very

23 personal.

24 Q. Okay. So then she brings in, with one

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



19

1 A. She was concerned about two things. And

2 from -- later -- our principals' perspective, they

3 shared with me they were confused why she was so

4 visibly angry about these two things. And one was, as

5 I understand it, Peoria School District schools would

6 require students to have the proper immunizations and

7 registration before they attended school, and so she

8 let principals know they were not to turn away

9 students. And a number of principals felt that that

10 was against Illinois state law.

11 And then the second thing that she was

12 concerned about was differentiation of students that

13 didn't have money for lunches on the first day. She

14 didn't want them to receive a different type of lunch

15 than the rest of the students.

16 And I think all of those things -- those

17 two things certainly made sense from the standpoint of

18 helping students enroll in schools, but we had not

19 discussed internally, in cabinet, ways to help

20 principals or support them in either payment of those

21 lunches, since food sources are -- food is outsourced

22 in Peoria School District 150. There was no mechanism

23 to support them in either one of those concerns.

24 Q. And the principals had no notification that

25 she wanted to change this?



20

1 A. No. But they were told there at that

2 meeting, and then they were dismissed. And before they

3 were dismissed they were asked to write down their

4 concerns or wants on a piece of paper and that -- she

5 said she would review that later.

6 Q. And, of course, that was the first day.

7 They hadn't evaluated the school situation either.

8 A. No.

9 Q. Did you -- when did Kevin Curtin first come

10 to your attention?

11 A. The day previous, we had a back-to-school

12 rally/kickoff downtown, and Kevin was one of the

13 keynote speakers at that event. Dr. Lathan was, and

14 Kevin Curtin was, and Bobby Darling from the Teachers

15 Federation spoke as well.

16 And so I did not know very many principals

17 at all because I had just come in town. I did see

18 Kevin publicly speak, so I very much knew who he was.

19 Q. And where was that held?

20 A. I believe it was held at the convention

21 center downtown.

22 Q. And what was Kevin Curtin's topic, if you

23 recall?

24 A. Yeah, Kevin Curtin's topic was, largely,

25 general education and motivational in nature.



21

1 Q. And was --

2 A. And teacher appreciation.

3 Q. What were your impressions of the talk?

4 A. I thought that he was a very committed

5 principal with compassion and knowledge. I had a very

6 positive feeling about his talk.

7 Q. Did you ever talk with Dr. Lathan about her

8 impressions?

9 A. Dr. Lathan was very much more concerned

10 about how her presentation went. I was surprised that

11 she wasn't more affirmative of Mr. Curtin's talk.

12 Q. When is the next time you had occasion to

13 come in contact with Mr. Curtin?

14 A. During the principals' meeting where they

15 were asked to write down their wants and the requests.

16 Q. Did you go over those requests with

17 Dr. Lathan?

18 A. So Dr. Lathan didn't hold that cabinet

19 meeting that afternoon, and people went home from work.

20 But there were a number of people left, that had been

21 recruited from North Carolina, late, in her office, as

22 well as Mr. Tim Delinski. And there was an informal

23 meeting that was then held late into the evening, where

24 they reviewed those requests.

25 Q. And what was Dr. Lathan's reaction to Kevin



22

1 Curtin's requests?

2 A. She was not supportive of his requests.

3 She said that he should know how to run his school and

4 he should know better than to ask for a number of

5 things that he had asked for and called him a "whiner."

6 Q. Did you see anything inappropriate about

7 this --

8 A. I was terrified at that point.

9 Q. And why were you terrified?

10 A. Because the entire episode I was expecting

11 to be handled much more professionally, because we had

12 solicited requests from our principals and I was used

13 to my leaders handling things much more systematically,

14 such as if a principal requested something to make

15 their school run, honoring the request versus mocking

16 the person for asking for it.

17 Q. She was derogatory with him personally?

18 A. Yes. And she was derogatory of two other

19 principals that I remember in particular -- well,

20 actually, three in particular.

21 Q. Who were they?

22 A. The first one was Mike Barber. The school

23 that he was principal of at the time was Irving.

24 Irving, in my understanding, had been -- the property

25 had been sold for the principal -- I mean, for the



23

1 building to be demolished so that the hospital could

2 use it in whatever capacity, whether it was a parking

3 lot or not.

4 And she called him "the captain of the

5 Titanic," because Mike had volunteered to remain with

6 the school until it closed. And she said that, you

7 know, it was a sinking ship and that he was a brave man

8 for volunteering to stay to the very end, like the

9 captain of the Titanic. And so she and Tim Delinski

10 often would, you know, call him, you know, "the man

11 with the sinking ship."

12 Q. Well, of course, there were still students

13 there that needed --

14 A. Yes.

15 Q. -- to be taught.

16 A. Yes.

17 Q. Was he allowed to remain for the two years?

18 A. As I understand it, he was transferred out

19 of the school, and Mr. Curtin was transferred to

20 Irving.

21 Q. Did you ever attend a function where Kevin

22 Curtin gave a presentation at Bradley University on --

23 A. That was previous to my employment at

24 Peoria School District 150.

25 Q. You weren't there?



24

1 A. I was not there.

2 Q. Did you ever talk with Dr. Lathan about

3 that presentation?

4 A. She had told me that she attended that

5 event.

6 Q. Did she talk about Mr. Curtin's

7 presentation at all?

8 A. No.

9 Q. Were you aware of Mr. Curtin's efforts

10 involved in the community in the -- in an

11 underprivileged school that he served?

12 A. Yes.

13 Q. And had that been a success, as far as you

14 understood it?

15 A. Yes. So in the winter of 2011, one of my

16 assignments was to gather all of the data on

17 principals, as she was considering closing certain

18 schools and considering moving principals to different

19 locations. And so Mr. Bryan Chumbley and I had worked

20 on a project together to briefly summarize the

21 student-achievement data of all principals and how many

22 years they were in their building. And Mr. Curtin was

23 one of the longest-serving principals, with one of the

24 healthiest data -- student-achievement data sets in

25 Peoria School District 150, and I had presented that to



25

1 her.

2 Q. What was your conclusion? How would you

3 rate him?

4 A. I would rate him as one of the best

5 principals in Peoria School District 150 in terms of

6 maintaining student achievement in a challenging

7 environment.

8 Q. I think he was at -- was it -- what school?

9 Garfield?

10 A. He was at Garfield. And I also worked with

11 Bradley University and Mr. York Powers for the time

12 that I was assigned to Title 1, in federal programs,

13 which I had forgotten earlier to mention. And we

14 worked with the community schools, trying to regroup.

15 There was a lot of effort previous to Dr. Lathan on

16 community schools, Glen Oak and Garfield, and we were

17 trying to regroup, being a new team, understanding what

18 work had been done previous and what work was still

19 maintained. And so I knew of Mr. Curtin's work, via

20 Bradley, in that endeavor.

21 Q. I believe it's been described to me as --

22 he gave an example as it took him about six years to

23 get it started, but he would have, like, Prairie State

24 Legal Services come, he would have the animal welfare

25 people to come tell them about pets, the American Red



26

1 Cross, all sorts of community groups so the community

2 would be more involved in the school.

3 A. Yes. Mr. Curtin was widely recognized as

4 being incredibly effective at hooking community

5 resources together with the needs of his student

6 population. And he was recognized by those efforts

7 through his work with Bradley University and within the

8 community.

9 I have worked in many locations, and I

10 haven't seen quite the success that Mr. Curtin had

11 while he was at Garfield.

12 Q. So you viewed it as a situation where it

13 was a success and needed to continue?

14 A. Yes. That was a concern. When Dr. Lathan

15 was planning on closing schools because of the budget

16 situation in Peoria, Garfield was often mentioned as a

17 school to close, and I had personal sadness over

18 knowledge of that being considered because of how truly

19 effective the school and Mr. Curtin and his staff were

20 at helping students there.

21 Q. In fact, it was closed.

22 A. It was closed.

23 Q. But as I understand it, he -- I think it

24 was transferred -- the program he had initiated was

25 transferred to Trewyn.



27

1 A. I have not been in Peoria after she

2 announced the principal movement. And other than

3 knowing that my son's principal is now principal of

4 Trewyn, that's the sum total of my knowledge.

5 Q. Is that Ms. Coleman?

6 A. The principal of Trewyn?

7 Q. Yes.

8 A. It is Robin --

9 Q. Robin?

10 A. Andrews.

11 (Court reporter requests

12 clarification.)

13 BY MR. STEAGALL:

14 Q. Okay. Well, if it couldn't continue at

15 Garfield, did you have an opinion as to whether

16 Mr. Curtin should continue with the programs he

17 developed at another school?

18 A. Well, it didn't make sense to me in those

19 discussions -- and I was part of the discussions

20 regarding schools to close through January -- if

21 tangentially -- that you would transfer a principal

22 from a successful school to a school that was closing

23 in one year and not transfer that principal to where

24 his student population was going, which was Trewyn.

25 That didn't make sense, especially since Mr. Curtin had



28

1 the student-achievement data -- he had quantitative

2 data to suggest that he was an effective principal.

3 Q. And he knew those students and teachers.

4 A. You cannot qualify all of the personal

5 relationships he had. But in our field, especially

6 underneath No Child Left Behind, school leaders are

7 supposed to look at quantifiable data to make

8 decisions, and she had quantifiable data to suggest

9 that Mr. Curtin was truly effective with his students.

10 Q. Well, yeah, we can quantify it, but it

11 ultimately comes down to knowing them and showing

12 concern; correct?

13 A. Well, yeah, that was just an added bonus.

14 I mean, here you have a principal that can show that he

15 can grow children academically -- right? -- but then he

16 is well-known throughout the community, and I had

17 witnessed firsthand, in my professional opinion, that

18 he mastered the qualitative components, such as

19 relationship building, caring, and compassion.

20 Q. These were underprivileged economic areas?

21 A. Yes.

22 Q. And so the students didn't have good -- a

23 solid family or social support?

24 A. I would say that the lack of consistency in

25 family structure is one of the issues that confronted



29

1 Garfield on a daily basis.

2 Q. And so if Mr. Curtin was able to establish

3 a relationship, a personal relationship with the

4 students, that gives them structure that they're

5 missing from anyplace else?

6 A. Correct.

7 Q. We had testimony from a parent last week

8 about how she was going to have to move because of

9 jobs, and Mr. Curtin had suggested that she -- "Well,

10 you're going to culinary -- you've been to culinary

11 school. Why don't you cater something for the school?"

12 She ended up getting -- starting a catering business

13 from that and now is a chef at the Embassy Suites in

14 East Peoria. Is that something that you're talking

15 about, the personal relationships?

16 A. Yes.

17 Q. And she also talked about her son Josiah

18 had five -- or had her and four sisters around, and he

19 was having -- acting out somewhat, as boys might do.

20 And Mr. Curtin had taken personal time with him -- and

21 always knew all his students -- and was talking to him

22 and helped him through that.

23 A. Yeah, I think with Mr. Curtin it was

24 authentic and it was consistent. That's not just how

25 he would act because there might be an administrator



30

1 walking through his school, looking at them, but that's

2 how -- that's who he is as a person.

3 Q. Well, that's not -- I don't know. You were

4 talking about No Child Left Behind and a search for

5 quantifiable data. How do you quantify Mr. Curtin's

6 relationship with the community, such as Josiah, the

7 son he helped out, and this gal who needed help to stay

8 in the district?

9 A. I would say that the community had a lot of

10 confidence in Kevin because he showed results.

11 Q. Well, I guess --

12 A. Not just test results, but showed results

13 such as the story you just explained, which is, you

14 know, helping families learn how to read so that they

15 could move out of poverty, you know, guaranteeing a

16 family structure there at the school, replicating a

17 family structure at the school, since they might have a

18 broken one at home.

19 I mean, he was well-known by administrators

20 in the district and in the community for being an

21 effective administrator that really excelled at some

22 things that other administrators struggled at, which is

23 that extension from school out into the home.

24 Q. And underprivileged areas, do they have a

25 special need for that?



31

1 A. Absolutely.

2 Q. Because they don't have any -- they don't

3 have any other support like you would at --

4 A. That's right.

5 Q. -- at Kellar or something --

6 A. Well, people often don't have college

7 degrees or they don't know how to read or they will

8 have inconsistent employment. I mean, these are very,

9 very, very real conditions that they face for survival.

10 Q. Single parents?

11 A. That is one of the issues.

12 Q. And I think he said that a lot of

13 grandparents are raising the children?

14 A. Well, it's just difficult if you do have a

15 single parent. I think single parents do a great job

16 raising their children, but they often have time

17 constraints. And the school would fill in those areas

18 of time, when children were sometimes left

19 unsupervised, through having different programs and

20 outreach.

21 And he did not get paid extra for being a

22 principal like that. You make the same amount of money

23 across town in one school that the kids go home and

24 there are families for them to go to, as you do at his

25 school where you had to be creative about scheduling



32

1 programs and support.

2 Q. And he also took a lot of time to be

3 available?

4 A. Yes.

5 Q. So as far as your review, you stated your

6 opinion of his abilities. Did you have any interaction

7 with Dr. Lathan, other than what you have previously

8 described on, I think, his walking in and talking about

9 his needs, about what her reaction or her opinions were

10 of Mr. Curtin?

11 A. Not on that opening day, no.

12 Q. But after that opening day, did you?

13 A. Yes.

14 Q. And tell me what those interactions were,

15 how many, and how you came to -- were you able to draw

16 an opinion as to what her reaction was to Mr. Curtin?

17 A. Well, I noticed a pattern with Dr. Lathan

18 that she personalized relationships in her professional

19 environment, and that made me uncomfortable.

20 I had talked about the one that she -- you

21 know, the nickname she had given Mr. Barber. She

22 had -- she had imitated and mocked the Washington

23 Gifted principal, Joan Wojcikewych. And she had --

24 Q. What did she mock her about?

25 A. She would imitate speaking like her in



33

1 situations where we would talk about Washington Gifted.

2 I witnessed that on two occasions, where she

3 pretended -- she affected a white speaking voice.

4 Q. And it was not flattering?

5 A. No.

6 Q. And you were talk -- you were talking about

7 her performance when this went on, or something to do

8 with her?

9 A. Well, Joan was a great advocate for her

10 school. And so consistent with the opening day, when

11 people would ask for things for their school or, you

12 know, ask for awareness or ask to attend certain

13 events, that was the context in which she would make

14 fun of Joan. If Joan was trying to explain, maybe, her

15 perspective or why the school would do a certain thing

16 and the superintendent disagreed with it, then she made

17 it very personal instead of just saying, "I disagree

18 with the principal."

19 Q. Well, and, of course, you've got limited

20 resources. If they're not available, they're not

21 available; correct?

22 A. Yeah. And that's a special school with

23 very committed parents. And so each school has its own

24 needs, and that one being very different since it was,

25 you know -- it didn't have a zoned enrollment. It was



34

1 all through application. And so that often takes up a

2 lot of time to make sure that that is being run

3 correctly. And I think Joan was just concerned with

4 the new superintendent, that she would understand the

5 goals and the mission and the commitment of the

6 parents, and she would try to explain things to the

7 superintendent.

8 Q. And wasn't successful, apparently?

9 A. No, she was transferred out of her school

10 into another one and I believe took retirement instead.

11 Q. From what you could see, was Washington

12 Gifted School a success when Joan was running it?

13 A. Very. It -- so you had asked earlier the

14 occurrences I had with Kevin, and I bring that up to --

15 I bring Joan up, and we haven't covered Steve Ptacek,

16 but that would be another one. These are principals

17 that had great data sets from student achievement in

18 the project that Mr. Chumbley and I did, that would

19 suggest that they were effective principals. But

20 these -- all these principals were negatively impacted

21 in placement decision-making.

22 Q. Okay. So even if we're -- Joan -- what was

23 her last name, again?

24 A. Wojcikewych.

25 Q. So Joan Wojcikewych, Kevin Curtin, and the



35

1 other person that you just mentioned . . .

2 A. Yeah. There was Mike Barber, Kevin Curtin,

3 Joan Wojcikewych, and Steve Ptacek. The superintendent

4 would frequently talk about them in very personal

5 terms.

6 Q. Would she mock them? You said --

7 A. Yes.

8 Q. All three of them? Make --

9 A. She didn't mock Mike Barber other than

10 calling him "the captain of the Titanic." But she

11 imitated Joan.

12 She mocked -- Steve Ptacek, at the fall of

13 2011, because of his contentious relationship with the

14 superintendent, actually went to the emergency room for

15 heart-attack-like symptoms, and she mocked him for

16 going to the hospital and imitated him crying in front

17 of her during a meeting over that episode.

18 Q. What position did Steve Ptacek have?

19 A. He was principal over Richwoods High

20 School.

21 Q. Now, Joan Wojcikewych, Kevin Curtin, Mike

22 Barber, Steve Ptacek, for all the measurements you saw

23 in the quantitative data, their student achievements

24 were very good?

25 A. Absolutely.



36

1 Q. And they were doing everything they should

2 as far as their scores and improving student

3 achievement?

4 A. From a quantitative standpoint, these

5 principals were incredibly effective. So if you were

6 going to make assignment changes to them, it had to be

7 based on a different criteria other than if they were

8 effective in growing student achievement.

9 Q. What other basis is there, as a principal,

10 to evaluate than student achievement?

11 A. I don't know the criteria she used in

12 moving any of those principals.

13 Q. Well, you're familiar -- or from your

14 experience with education, is there -- did you see

15 any -- well, let me ask it this way. Is there an

16 accepted standard to evaluate principals' performance?

17 A. Well, the Peoria School District 150 had an

18 evaluation process. I was not part of it. Mr. Tim

19 Delinski and Ms. Revonda Johnson were tasked with

20 evaluating principals. I realized, just in sitting in

21 cabinet meetings and different meetings, that they had

22 to evaluate their principals by a certain point in 2011

23 before discontinuing their contracts. And because of

24 different reasons, Mr. Delinski and Ms. Johnson missed

25 those deadlines to evaluate a principal and give



37

1 sufficient time for the principal to remediate their

2 behavior for her to discontinue those contracts. Does

3 that make sense?

4 Q. Yes.

5 A. Okay.

6 Q. I understand.

7 A. So because they missed those deadlines,

8 they could not discontinue a number of people's

9 contracts. And, thus, I believe, in my opinion, they

10 were transferred to other schools versus being

11 terminated like me.

12 Q. Well, okay. So we've got -- you have named

13 them. One of them took retirement. Steve Ptacek left

14 Richwoods for another position.

15 A. Yes. Mr. Ptacek was under great stress by

16 Mr. Delinski and Ms. Johnson and Dr. Lathan to find

17 employment outside of the district. Both -- they --

18 they strongly encouraged him to do that and openly

19 mocked him behind closed doors. And he secured

20 employment as a superintendent downstate in January of

21 2011.

22 Q. Okay. But --

23 A. No. Yeah. Well, yeah, 2012. I apologize.

24 January 2012.

25 When he went to hand in his resignation to



38

1 Dr. Lathan and the board, after months of being

2 encouraged and pretty much told directly to leave the

3 district, Dr. Lathan refused his resignation, stating

4 that he broke his contract, and put in a process, a

5 way, to terminate him by March 1st and did not pay him

6 for the remainder of the year.

7 It was only through the involvement of his

8 lawyer, Nile Williamson, who was also my lawyer, that

9 Mr. Williamson was able to negotiate an exit for

10 Mr. Ptacek in a way that he could retain his dignity

11 and paycheck to help support his family for the rest of

12 the year.

13 Q. Well, from all the -- let me ask you this

14 way.

15 With your familiarity in education, is

16 student performance the primary method and standard

17 that educators use to evaluate principals' performance?

18 A. It is supposed to be the primary objective

19 in how we evaluate each other's performance.

20 Q. So Mr. Ptacek was essentially run out of

21 the district, yet he had superior student achievements?

22 A. From student achievement, if you consider

23 Mr. Ptacek's scores on state-mandated assessments as

24 well as advanced-placement examinations, which was

25 critically important to the parents and students of



39

1 Richwoods, he was a very effective principal.

2 Q. So what was he doing -- did you see

3 anything objective he was doing wrong?

4 A. No. She didn't like him.

5 Q. Dr. Lathan just -- she did not like him?

6 A. She did not like him.

7 Q. Mr. Curtin had similarly high -- very high

8 achievement --

9 A. Yes.

10 Q. -- for his students? Unlike Richwoods,

11 which has some of the more prosperous areas, he had

12 some of the worst underprivileged areas as far as

13 economics goes, didn't he?

14 A. Yes.

15 Q. And it had taken a long time, but he had

16 been a total success; correct?

17 A. Yes.

18 Q. And yet Dr. Lathan wasn't satisfied with

19 his performance?

20 A. No.

21 Q. From what you reviewed of it, was his

22 performance superior?

23 A. Yes.

24 Q. Same as Mr. Ptacek?

25 A. Yes.



40

1 Q. And same as Joan Wojcikewych?

2 A. Yes.

3 Q. So --

4 A. And Mr. Barber.

5 Q. Yeah, and Mr. Barber.

6 So you've got four superior-performing

7 principals and Dr. Lathan wanted to transfer or

8 terminate their employment?

9 A. Yes.

10 Q. What was her reason for that?

11 A. I don't know.

12 Q. The only thing you can -- I mean, you

13 described a personal hostility. She would continue --

14 I guess, with Mr. Barber it was, "Well, he's captain of

15 the Titanic."

16 A. Yes.

17 Q. I mean, somebody has got to serve out that

18 school, don't they?

19 A. Well, all of the personalization of the

20 administrators that I believed, through my professional

21 experience, to be effective was very disturbing and

22 unsettling to me and made me extraordinarily fearful.

23 Q. Have you ever seen that in any place else

24 you have worked?

25 A. No.



41

1 Q. So these people are being evaluated just on

2 Dr. Lathan's likes or dislikes of them personally, not

3 what they do?

4 A. Yes. And I think her opinion of whether

5 she likes a person or not is greatly affected by

6 Mr. Tim Delinski and Dr. LaToy Kennedy.

7 Q. And who is Tim Delinksi, and what is his --

8 A. He is -- I don't know what their titles are

9 exactly, but he is essentially an Instructional

10 Improvement Officer -- or like the supervisor of

11 elementary school principals.

12 Q. Did he bring her -- did she -- did he come

13 in with Dr. Lathan?

14 A. Well, he had been a principal in Peoria

15 School District 150, so he was the only Peorian on the

16 team.

17 Q. Okay. And then the other one was -- could

18 you tell me?

19 A. Dr. LaToy Kennedy.

20 Q. And what are the -- Dr. Lathan is a black

21 woman; right?

22 A. Yes.

23 Q. Tim Delinski, what is his --

24 A. He is a white man.

25 Q. A white male.



42

1 And LaToy Kennedy?

2 A. Is an African-American female.

3 Q. And then we've got Mike Barber, who is a

4 white man?

5 A. Yes.

6 Q. We've got Kevin Curtin, who is a white man?

7 A. Yes.

8 Q. And we've got Steve Ptacek, who is a white

9 man?

10 A. Yes.

11 Q. And we have Joan Wojcikewych, who is a

12 white woman?

13 A. Yes.

14 And my husband and I are Caucasian.

15 Q. Did you ever see Dr. Lathan mock any black

16 employees or principals like she did these white --

17 A. No.

18 Q. Let me ask it this way, as a way to

19 describe it. Am I correct it's -- you have never seen

20 a black person mock white people like Dr. Lathan did,

21 in employment?

22 A. I have never worked for an African-American

23 supervisor who has personally mocked their subordinate.

24 Q. Well, this mocking she did of these white

25 people, would it be similar to the characters that we



43

1 have done so much to work -- the characterizations that

2 we have done so much to work away from for black --

3 that whites make about blacks?

4 A. I found it very disturbing.

5 Q. And I guess what I'm asking is, we all know

6 the stereotypes we have had about blacks, and we have

7 struggled with those. Was this the reverse, a black

8 person doing it to white people?

9 A. I would -- I would agree with that, yes.

10 Q. And totally unacceptable in --

11 A. Yes.

12 Q. I mean, you were a subordinate. Did you

13 ever express -- well, was your discomfort when she did

14 this, was that -- was she able to tell you were

15 discomforted by that?

16 A. I think she did. And I think that's what

17 cooled -- one of the things that cooled our

18 relationship. I didn't know how to respond in that

19 unprofessional environment. I was used to schedules.

20 I was used to people speaking with respect to one

21 another. I was used to trying to support principals

22 versus trying to bring out negative aspects about

23 somebody requesting assistance. And so I was very

24 upset, and I called a number of people to seek help and

25 advice because --



44

1 Q. "How do I handle this in this job?"

2 A. Yeah.

3 Q. Okay.

4 A. I -- I -- yes. And I even -- I talked to

5 board members off-site in a meeting that they arranged.

6 Then President Debbie Wolfmeyer via Bob Gates arranged

7 an off-site meeting between me, Bob, and Debbie, and

8 Linda Butler, then vice chair, to discuss my concerns,

9 including the opening day principals' requests as well

10 as the treatment of me coming to Peoria.

11 Q. And you told -- did you tell them about the

12 racial characterization?

13 A. I told them that she mocked principals

14 personally, yes.

15 Q. What was their reaction when you told them

16 that?

17 A. They listened to me. We spoke for about

18 two hours. When we left, Linda Butler said that this

19 was a good meeting because it showed that I had due

20 process and the ability to talk to them about things.

21 After that meeting, then I was assigned a

22 project, second semester, where we had a similar

23 project, where people were supposed to -- on cabinet --

24 were supposed to go to schools and come back with

25 findings. And it was much -- I was tasked with



45

1 handling it in a very different way, where we would

2 gather the evidence in a spreadsheet format and then

3 discuss the problems.

4 I never knew if that assignment was because

5 I was listened to or if it was a punishment for

6 bringing the concern forward.

7 Q. Well, ultimately, Dr. Lathan wanted you

8 fired and the board went along with it; correct?

9 A. Yes.

10 Q. That included Linda Butler and Deb

11 Wolfmeyer?

12 A. They voted unanimously to fire me.

13 Q. Okay. When she spoke of due process, I

14 guess her process was she listened to you and then

15 fired you?

16 A. Yes.

17 Q. Well, you know, look at this -- they didn't

18 exactly -- what you experienced was not a neutral or

19 objective decision-maker?

20 A. It was -- I have never seen anything like

21 this in all my years in education.

22 Q. So you had met with them, like, before

23 March of 2011, would it be?

24 A. Yes.

25 Q. And you had told the board about these



46

1 problems with Dr. Lathan?

2 A. Yes. Well, I had told two board members.

3 Q. And that was?

4 A. Debbie Wolfmeyer and Linda Butler.

5 Q. And then you met with --

6 A. And the lawyer, Bob Gates.

7 Q. Yeah, and their attorney.

8 A. Yes.

9 Q. You told them about them. And then you got

10 this other assignment, and you're gone by March?

11 A. Yes.

12 Q. Okay. Well, they listened to you and then

13 fired you?

14 A. Right.

15 Q. Now, this thing about Mr. Barber being

16 captain of the Titanic, well, in fact, they're closing

17 that school. Those kids still needed to be educated,

18 didn't they?

19 A. It was a great sorrow to me to objectify

20 that school in those terms. There are many wonderful

21 children that attended that school, and there were so

22 many giving community partners. And just the

23 characterization of that school in those terms was one

24 of the most hurtful things that I saw.

25 Q. Well, of course, the captain of the



47

1 Titanic, if you use that example --

2 A. He died.

3 Q. Yeah. She wasn't using it in a

4 praiseworthy manner, was she?

5 A. No.

6 Q. Well, of course, the captain of the Titanic

7 did his duty, unlike the Italian captain, and stayed on

8 his ship and made sure everybody got off that could;

9 correct?

10 A. Yes.

11 I believe that she -- and this is just my

12 opinion -- she had a problem with Mike Barber applying

13 for my position as associate superintendent and didn't

14 feel that he was qualified for the job and then made it

15 very personal afterwards, you know, even in his

16 application of the job.

17 Q. And as far as you saw, there wasn't any

18 problems with Mike Barber?

19 A. Mike Barber definitely could have done my

20 job.

21 Q. Well, and he didn't get it, but he was

22 still a good principal?

23 A. He is an exceptional principal.

24 MR. STEAGALL: Okay. Let's go off the

25 record.



48

1 (Off the record.)

2 MR. STEAGALL: Now we're going back

3 on.

4 BY MR. STEAGALL:

5 Q. Was there ever a board meeting held on your

6 employment? You were talking about a February 2011

7 board meeting?

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

9 School District 150 held board meetings down on

10 Wisconsin Avenue, and on a schedule they would take the

11 board meeting on the road, to try to outreach to the

12 community. We had a board meeting at Lincoln Middle

13 School in February of 2011.

14 Q. What part of town is that located in?

15 A. I believe that's East Peoria -- no. I

16 mean, it's Lincoln Middle School. You know where

17 Lincoln Middle School is.

18 Q. Well, actually, is it below the bluff?

19 A. Yes. It's just -- it shares the same zone

20 pattern as Irving --

21 Q. Yeah.

22 A. -- Elementary, where Kevin is now.

23 Q. It's down in the valley, below the bluff?

24 A. Mm-hmm.

25 Q. The oldest section of Peoria and the most



49

1 underprivileged?

2 A. That's right.

3 Q. Yes.

4 A. It was zoned at one time for Woodruff. I'm

5 sorry. I don't remember the street names of Peoria.

6 Q. That's all right.

7 A. There's a lot I'm trying to block out from

8 Peoria.

9 Q. Well, actually, I'm not -- I'll be honest

10 with you. I don't know that I would know the street

11 number. I know that below the bluff --

12 A. It's not far from downtown.

13 Q. Yeah. Below the bluff --

14 A. It's east bluff, definitely.

15 Q. Yeah. And those are rough neighborhoods;

16 correct?

17 A. Those are challenging neighborhoods, yes.

18 Q. They have done -- south of downtown, they

19 have done some community housing and things like that,

20 cleared out a lot of the housing. But north is -- and

21 then once you get past that south, past western, it's

22 fairly rough neighborhoods there as well, isn't it?

23 A. Yes. And Lincoln Middle School is supposed

24 to be on track to be a KA Community School, similar to

25 what Kevin was trying to accomplish at Garfield.



50

1 Q. And so what happened at that meeting?

2 A. Well, Dr. Lathan had recruited a principal

3 from North Carolina, so there was a North Carolinian

4 running that school at Lincoln.

5 And previous to that February meeting, we

6 had known, behind closed doors, that we were going to

7 close Garfield for about a month. And it became very

8 apparent to me that Kevin Curtin had not been talked to

9 regarding the plans for his school or the plans for

10 him. He --

11 Well, each school on this traveling --

12 wait. I'm sorry.

13 In the previous months, Dr. Lathan had

14 scheduled schools to showcase their strengths to the

15 board of education, so any board meeting might have one

16 to three schools scheduled. And schools chose

17 different ways to do that. Some schools scheduled it

18 in children to sing, other schools had data

19 presentations and that sort of thing, and there wasn't

20 any one set way. Principals weren't directed to

21 display their school in any particular way.

22 While at Lincoln Middle School, Dr. Lathan

23 had quit giving me board packets, like the rest of the

24 board members and Comptroller Dave Kinney, so I was the

25 only person sitting on the horseshoe that didn't have



51

1 anything in front of them.

2 Q. So you didn't know what the agenda was?

3 A. I didn't know what the agenda was. And I

4 had mastered the art of just -- just adapting to the

5 situation at that point. So it had been at about two

6 meetings previous that I recognized that the board

7 secretary was directed to provide packets to everybody

8 but me. I mean, she did that to make me feel a certain

9 way and was successful in making me feel that way. So

10 I --

11 Q. Well, you didn't know -- you didn't know

12 how to prepare, so you just waited.

13 A. Well, I just attended, and I just looked at

14 the audience.

15 So because -- why that's important that I

16 didn't have a board packet is because I was very

17 attentive to paying attention to the audience since I

18 didn't have anything in front of me.

19 Q. Sure.

20 A. And Mr. Curtin gave about a 20-minute

21 presentation that was a PowerPoint.

22 The way we were sitting at Lincoln Middle

23 School as a board, we could not see the PowerPoint

24 presentation. So even though board members had a copy

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



52

1 weren't as engaged because they couldn't watch the

2 slides that Kevin was presenting.

3 Q. Well, they certainly could have asked,

4 couldn't they?

5 A. But the reason, again -- and all of this is

6 my opinion -- they weren't paying attention to the

7 degree that they did other schools because they had

8 known for a month that Dr. Lathan was closing Garfield.

9 What became apparent to me, though, was

10 that Mr. Curtin didn't know that they were closing and

11 moving Garfield. And so the entire presentation was

12 incredibly painful from the perspective of knowing what

13 was going to happen to him and his school, and the

14 board and the superintendent engaged in a type of

15 theater with him.

16 Q. So it was a -- the hearing was an entire

17 sham?

18 A. Yes.

19 Q. Okay. Well, you say your opinion, but you

20 were able to observe their personal reaction as

21 inattentiveness?

22 A. I felt that they were waiting for him to

23 end the presentation quickly because they knew he would

24 no longer have a school and that school would not be

25 open.



53

1 Q. Okay. So this chance for the school to

2 show their strengths and try to keep open is a complete

3 falsehood because the decision had already been made?

4 A. Yes.

5 Q. So they were totally misleading the

6 community?

7 A. Yes.

8 Q. Supposedly who they are there to serve?

9 A. Yes.

10 Q. Okay. Well, that's not honest, is it?

11 A. That -- that -- I don't know if it's

12 honest, but I know that I have not seen anything like

13 that in my years in education.

14 Q. Okay. And then, so in March, tell me how

15 you learned about your marching orders.

16 A. Dr. Lathan had informed principals that

17 there would be a certain cutoff date that they would

18 find out what their assignments would be for the

19 following year, and she had directed them to be by

20 their phones. And I want to say the time was from

21 10:00 p.m. to midnight, and they would get a call from

22 her or somebody at central office to find their new

23 assignment. Nobody interviewed for any particular

24 position in the district, and it was all conducted by

25 her. No positions were posted, and I was not talked to



54

1 about any of that process. I had --

2 Q. But you had just done an evaluation of all

3 of them, hadn't you?

4 A. I had just conducted a student-achievement

5 picture of each of the principals in January. And

6 Revonda and Tim had done the evaluation on a number of

7 principals, you know, the sit-down evaluation

8 instrument that they use in Peoria.

9 Since I wasn't talked to about any of this

10 process and she had already indicated to me on numerous

11 occasions that I would either be fired or demoted to

12 assistant principal, I assumed that the end was coming

13 for me quickly.

14 I had hired Nile Williamson when I watched

15 Mr. Ptacek's resignation be denied, because I was very

16 fearful that the same thing would happen to me, where

17 even though I was being pushed out by Dr. Lathan I

18 would have to -- I would be penalized for leaving the

19 district on my own will, in terms of from a contractual

20 obligation. And so Mr. Williamson sent a letter to

21 Dr. Lathan via fax. And five minutes after I received

22 it, she did a very quick evaluation and I was walked

23 out the door by security.

24 Q. Did that cause you problems finding

25 employment?



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1 A. Yes. Yes.

2 Q. So you had -- fortunately, you were able to

3 land back here in Nashville?

4 A. Well, I mean, it caused problems in that I

5 will have to explain this for the rest of my life, and

6 I had built up a reputation. So I am fortunate that I

7 had three different job opportunities on the horizon,

8 and I selected the Sumner County Schools position. So

9 it is not ideal, certainly, for my family and I not to

10 be together, but I was out of employment for one month.

11 Q. Well, yeah, career-wise you were -- but

12 you've got a husband and an 8-year-old son how many

13 hours away?

14 A. Seven and a half.

15 Q. And, of course, in your position you're not

16 like a teacher. You don't have the summers off, do

17 you?

18 A. No. And when I first joined Sumner County

19 Schools, there was a lot of interest as to why I was

20 terminated. And I anticipate having to live with that

21 for the rest of my life.

22 Q. Well, I'm certainly sorry about your

23 experience in Peoria.

24 Thank you for your time.

25 Would you waive -- do you want to sign



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1 this, or would you waive it?

2 A. No. I'm fine with waiving the signature.

3 MR. STEAGALL: Okay. That's it. It

4 was a pleasure to meet you.

5 (Proceedings adjourned at

6 10:22 a.m.)

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1 REPORTER'S CERTIFICATE

2 STATE OF TENNESSEE )

3 COUNTY OF DAVIDSON )

4 I, Patricia W. Smith, Licensed Court

5 Reporter, Registered Professional Reporter, with

6 offices in Nashville, Tennessee, hereby certify that I

7 reported the foregoing proceedings at the time and

8 place set forth in the caption thereof; that the

9 proceedings were stenographically reported by me; and

10 that the foregoing proceedings constitute a true and

11 correct transcript of said proceedings to the best of

12 my ability.

13 I FURTHER CERTIFY that I am not

14 related to any of the parties named herein, nor their

15 counsel, and have no interest, financial or otherwise,

16 in the outcome or events of this action.

17 IN WITNESS WHEREOF, I have hereunto

18 affixed my official signature and seal of office this

19 29th day of April, 2012.

20 _________________________________

21 PATRICIA W. SMITH, LICENSED COURT REPORTER, REGISTERED

22 PROFESSIONAL REPORTER, CERTIFIED COURT REPORTER, and NOTARY

23 PUBLIC FOR THE STATE OF TENNESSEE

24 LCR No. 164, Expires 6/30/12

25 Notary Commission Expires 5/8/12


Documents

2012-04-27 Michelle Ungurait Sworn Statement