Thomas E. GauthierAttorney at Law E-mail: tgauthier@lozanosmith.com

May 14,2015

Via Regular Mail

Anton Jungherr121 Ash CourtHercules, CA 94547

Re: Alleged Brown Act Violations

Dear Mr. Jungherr:

. "Our office represents the West Contra Costa Unified School District ("District"): .The Districtreceived your May 6, 2015 letter and asked-that we respond on its behalf.' . - ~': '. < , ;

.'" '.;.', : \. :~ . ~-".'., ~ ;' ,.,l' . .~" ,_.. ~ ~

in your'rviay 6 letter, 'you allege a violation ofthe Bro~'A~t based on '~ev~ralspectfic acisof theDistrict's Board of Education (,'Board") and demand a "cure 'and correct" reinedy fa/these ' . ,alleged violations. For sake of clarity, we address the three points youraised in order and'provide the District's response accordingly.

First, you allege the Board's "Special Meeting Agenda did not properly notice the considerationof an independent forensic investigation of the bond program" and that such "consideration is nota proper close[d] session item." However.jn compliance with Government Code section 54950et seg. (the "Brown Act."), the District noticed and considered a personnel matter in closedsession. The April 29, 2015 agenda listed a closed session item as follows:

1. PUBLIC EMPLOYEE DISCIPLINE/DISMISSALIRELEASE/COMPLAINT(Government Code Section 54957)

(See also Exhibit A to your May 6 Letter.) Your letter cites to Exhibit D, a Contra Costa Timesarticle that references allegations or complaints against two District employees. The Districtmay meet in closed session to discuss certain enumerated topics, including consideration ofpersonnel matters. (Gov. Code 54957, subd.(b).) Otherwise,the Brown Actrequires "allmeetings of the legislative body of a local agency shall be openand public, 'and all persons shall ,be permitted to attend any meeting of the legislative body of a 'local agency. : ." (Gov. Code 54953, subd. (a).) The District is not authorized to discuss what happens in closed session; asyou know those matters are confidential. (Gov. Code 54963\ Ultimately, should the Boarddiscuss or act upon matters such as the bond program or construction programs in general, orretain a third party or other entity to investigate, please be assured that the District understands

Limited Liability Partnership

One Capitol Mall, Suite 640 Sacramento, California 95814 Tel 916-329-7433 Fax 916-329-9050

Anton JungherrMay 14,2015Page 2

which topics are appropriately considered in open session and follows those parameters. Ageneral statement of the Board's intent to act in the future is not a Brown Act violation.

Second, you allege "the April 29, 2015 minutes [sic] did not accurately record the action taken orthe vote on this matter," while "[t]he April 29, 2015 report of closed session action wasaccurately recorded by Contra Costa Times ... " with reference to Exhibits Band C. In ExhibitB, you appear to highlight the following text:

Report/Ratification of Closed SessionPresident Groves reported that the Board of Education will establish an independentinvestigation and have findings reported back to the Board upon completion.

For comparison, you highlight the following text from Exhibit C, the Contra Costa Times article:

"As a board, we are committed to pursuing an independent forensic examination of theissues raised in the complaint and we have set forth a process to do so," Board PresidentTodd Groves said Wednesday, after a closed session meeting to discuss an undisclosedemployee complaint. "And the public will be hearing much more about it movingforward."

It appears you allege as a Brown Act violation the absence of the word "forensic" in theDistrict's April 29, 2015 minutes. The Brown Act does not address the accuracy of minutes oreven mention minutes, so this issue cannot be a Brown Act concern. Regardless, even if wewere to accept the allegation on its face that there was a concern, the party complaining of theaction must show prejudice. (Cohen v. City of Thousand Oaks (1994) 30 Cal.App.4th 547.)There is no showing of prejudice due to the absence or presence of the term "forensic." TheDistrict disputes your allegation that the description of the action taken on April 29, 2015violated the Brown Act.

Third, you allege that "[a]t the May 6, 2015 Board meeting action was taken to amend the April29,2015 minutes to add additional information in regards to this independent forensicexamination that was not reported at the April 29, 2015 closed session." But the action taken atthe May 6, 2015 meeting you cite took place in a public meeting and was properly noticed asfollows:

B. OPENING PROCEDURESB.l Pledge of AllegianceB.2 Welcome and Meeting ProceduresB.3 Roll CallB.4 Presentation of Student Board Representative from Richmond High SchoolB.5 Report/Ratification of Closed Session *B.6 Agenda Review and Adoption (Public Comment)B.7 Minutes: April 16, 2015; April 22, 2015; April 29, 2015B.8 Request to Address the Board - Dr. Fatima AlleyneB.9 Request to Address the Board - Ari AlleyneB.10 WCCUSD Public Comment

Anton JungherrMay 14,2015Page 3

(Emphasis added.) To the extent this allegation speaks to your belief that the Brown Actviolation relates to the failure to include the term "forensic," we direct you to the District'sresponse above. Moreover, the Board's subsequent action to include the term "forensic"provides even more detail than required under the Brown Act.

In conclusion, the District disagrees with the allegations of violations of the Brown Act raised inyour May 6 letter. The Board does not intend at this time to take any action, as there is nothingto cure and correct.

Sincerely,

LOZANO SMITH: 1.~ \i ./\ '..... .

i \_,tr; 7,., ~'\ \. A.t '\

Thomas Gauthier

TEG/jf

WCCUSD Board of Education MinutesMay 6, 2015 +Page 2

B.7 Minutes. April 16, 2015; April 22, 20]5; April 29, 2015Public Comment:Tom Panas, Ben Steinberg

Board Comment:President Groves stated the comments from the public were correct and he did request an independent forensicexamination.

MOTION: Ms. Kronenberg moved to amend the Minutes of April 29, 2015 for Item C.l. replacing the words"independent investigation" with "independent forensic examination". Mr. Enos seconded. Ms. Block, Ms.Cuevas, Mr. Enos, Ms. Kronenberg, Student Representative Alejandra Barragan Hidalgo (advisory vote only),and President Groves voted yes, with no abstentions and no absences. Motion carried 5-0-0-0.

MOTION: Ms. Block moved to further amend the Minutes of April 29, 2015 for Item Cd , to include steps theBoard had previously agreed to taking toward the independent investigation process which included hiring ofan independent attorney not baving worked with the district in the past and choosing a forensic auditor. Ms.Cuevas seconded. Ms. Block, Ms. Cuevas, Mr. Enos, Ms. Kronenberg, Student Representative AlejandraBarragan Hidalgo (advisory vote only), and President Groves voted yes, with no abstentions and no absences.Motion carried 5-0-0-0.

MOTION: Mr. Block moved approval ofthe Minutes of April 16,2015 and April 22, 2015 and amendedMinutes of April 29, 2015. Ms. Cuevas seconded. Ms. Block, Ms. Cuevas, Mr. Enos, Ms. Kronenberg, StudentRepresentative Alejandra Barragan Hidalgo (advisory vote only), and President Groves voted yes, with noabstentions and no absences. Motion carried 5-0-0-0.

B.lO WCClSandiE This is a transcription, from the May 6, 2015 WCCUSD

Board meeting video tape starting at time stamp 00:017,of Ms. Block's amendment to the April 29, 2015 SpecialBoard meeting minutes:

"That we would hire an independent attorney whohaven't worked with the District before to identify threeor four forensic auditors who will then present their planfor the investigation to the Board. The Board will choosefrom that group an auditor that they feel best match theirinvestigation that we want to do and then we would hirethem to do the investigation."

The Board unanimously approved this amendment onMay 6, 2015.

The exact wording of this amendment should be includedin the April 29, 2015 Board minutes.

Anton Jungherr, May 17,2015

k seconded. Mr.mt Groves voted

MOTHEnos. Syes, Ms

to recognize student

Due to the numb

President Grovesachievements.

MOTI(Ms. Blo(advisor0-0.

~.Enos seconded.igan Hidalgo-'lotion carried 5-0-

D. AWAR!

D.1 RecogniMr. WaJHigh SclCome atZhou froSchachai

Public CNone

nd Pinole Valleyfoumament. Levston and Jun Huiston, and Sophia

Board Comment:President Groves congratulated the teams.

D.2 Class of2015 Ed Fund Scholars Recognition

24

ANT OJ JUNGHERRwccus~ ll1eged Violation of Brown ActApril 29, 2015

510.697.7212 celljungherr3@aol.com

May 6,2015

President and Members of theWest Contra Costa Unified School DistrictBoard of Trustees1108 Bissell AvenueRichmond, CA 94801

DEMAND FOR CURE OR CORRECTION; ALLEGED VIOLATIONOF BROWN ACT

This letter is to call to your attention to what I believe was a substantialviolation of a central provision of the Ralph M. Brown Act, which mayjeopardize the finality of the action, taken by the Board of Trustees of theWest Contra Costa Unified School District (WCCUSD) at a Special Meetingon April 29, 2015.

The nature of the violations are as follows:

The April 29, 2015 Special Meeting Agenda did not properly noticethe consideration of an independent forensic examination of the bondprogram. See Exhibit A. This was a violation of the Brown Act.

The consideration of an independent forensic examination is not aproper close session item. This was a violation of the Brown Act.

The April 29, 2015 did not accurately record the action taken or thevote on this matter. See Exhibit B. This is a violation of the BrownAct.

The April 29, 2015 report of closed session action was accuratelyrecorded by Contra Costa Times reporter Theresa Harrington in hervideo posted on the newspaper's website and in her April 29, 2015article. See Exhibit C.

At the May 6, 2015 Board meeting action was taken to amend theApril 29, 2015 minutes to add additional information in regards tothis independent forensic examination that was not reported at theend of the April 29, 2015 closed session. This was a violation of theBrown Act.

C:\Users\Anton\Documents\OOOO CBOC 2.11.15\Brown Act Violation Closed Session April 29, 2015-5.6.15 - aj.docx Page 1 of3

ANTON JUNGHERRWCCUSD Alleged Violation of Brown ActApril 29, 2015

510.697.7212 celljungherr3@aol.com

Brown Act Requirements:

"The intent and purpose of the Brown Act 1 is to ensure the actions (of locallegislative bodies) are taken openly and that their deliberations be conductedopenly." 2

The Brown Act provides that the public have the right to an agenda thatcontains a brief description of each item of business to be transacted. 3 Thedescription of agenda items must not be misleading.

"In Carlson v. Paradise Unified School District (1971) 18 Cal.App.3d 196,the court, commenting on the specificity required for a school board agenda,provided: [I]t is imperative that the agenda of the board's business be madepublic in some detail so that the general public can ascertain the nature ofsuch business. It is a well-known fact that public meetings of localgoverning bodies are sparsely attended by the public at large, unless an issuevitally affecting their interests is to be heard. To alert the general public tosuch issues, adequate notice is a requisite." 4

The Brown Act provides that action taken in permissible closed sessionshould be reported to the public as soon as the action is taken. Brown Actrequires the body to report all actions taken in closed session and the vote orabstention of every member present.

Background:

On April 22, 2015 Dennis Clay, an employee of the District, sent a CD ofdocuments pertaining to the 2014 Performance Audit to the School Board.He also gave these documents to the Grand Jury. See Exhibit D.

The Board responded to these documents during the April 29, 2015 closedseSSIOn.

1 California Government Code Sections 54950 through 54963.2 The Brown Act, School Boards, and Open Meeting Laws, California School Boards Association, 2009,page 4.3 Government Code section 54954.2(a).4 The Brown Act, School Boards and Open Meeting Laws, California School Boards Association, 2009,page 23.

C:\Users\Anton\Documents\OOOO CBOC 2.11.15\Brown Act Violation Closed Session April 29, 2015-5.6.15 - aj.docx Page 2 of3

ANTON JUNGHERRWCCUSD Alleged Violation of Brown ActApril 29, 2015

510.697.7212 celljungherr3@aol.com

Brown Act Remedy:

The Brown Act allows the legal remedy of judicial invalidation of illegallytaken action. Pursuant to Government Code Section 54960.1, I demand thatthe Board of Trustees cure or correct the illegally taken action as follows:formal and explicit withdrawal from any commitment made, coupled withdisclosure at a subsequent public meeting of the reasons why individualmembers of the Board of Trustees took the position that they did, release tothe public all documents supporting the April 29, 2015 meeting action withfull opportunity for informed comment by members of the public at the samemeeting, notice of which is properly included on the posted agenda.

As provided by Section 54960.1, you have 30 days from the receipt of thisdemand to either cure or correct the challenged action, or inform me of yourdecision not to do so. If you fail to cure or correct as demanded, I amentitled to seek judicial invalidation of the action pursuant to Section54960.1, in which case I would seek the award of court costs and reasonableattorney fees pursuant to Section 54960.5.

Anton Jungherr

Exhibits

A. Special Meeting Agenda, April 29, 2015B. Minutes of Special Board of Education Meeting, April 29, 2015C. Contra Costa Times Article, April 29, 2015D. Dennis Clay Email, April 22, 2015

C:\Users\Anton\Documents\OOOO CBOC 2.11.l5\Brown Act Violation Closed Session April 29, 2015 -5.6.15 - aj.docx Page 3 0[3

ANTON JUNGHERRWCCUSD ALLEGED VIOLATION OF BROWN ACTAPRIL 29, 2015

EXHIBIT AMay 6, 2015 Letter to WCCUSD Board of Education

WEST CONTRA COSTA UNIFIED SCHOOL DISTRICTBOARD OF EDUCATION

SPECIAL MEETING AGENDACLOSED SESSION

WEDNESDAY, APRIL 29, 201510:00AM

BOARD AGENDA PACKETS AND INFORMATION:

Complete Board meeting packets are available for review at the Administration Building, the District's six highschools, and at public libraries throughout West County.

Complete Board agendas and packets are available online at: www.wccusd.net.

Any writings or documents that are public records and are provided to a majority of the governing boardregarding an open session item on this agenda will be made available for public inspection in the District officelocated at 1108 Bissell Avenue, Richmond, CA 94801 during normal business hours. In addition, suchwritings and documents may be posted on the District's website as noted above.

I

Location: ALVARADO ADULT EDUCATION CAMPUSROOM I5625 SUTTER AVENUERICHMOND, CA 948054

ATTENDING BOARD MEETINGS:

The Board will convene at 10:00 AM in Room One to receive comments from anyone wishing toaddress the Board regarding closed session items (Exhlbit A). The Board will then adjourn toclosed session.

A. OPENING PROCEDURES

A.I WELCOME AND MEETING PROCEDURES

A.2 ROLL CALL

B. CONVENE TO CLOSED SESSIONThe public may address the Board regarding Closed Session items prior to the Board adjourning to ClosedSession by first providing a Request to Address the Board speaker sheet.

CLOSED SESSION

B.I CALL TO ORDER

B.2 DISCLOSURE OF ITEMS TO BE DISCUSSED IN CLOSED SESSION(Government Code 54957.7)

WCCUSD Board of EducationSpecial Meeting Agenda - April 29, 2015

2

See Exhibit A(Government Code Section 54954.5)

EXHIBIT A(Government Code Section 54954.5)

CLOSED SESSION AGENDA

April 29, 2015

1. PUBLIC EMPLOYEE DISCIPLINEIDISMISSALIRELEASE/COMPLAINT(Government Code Section 54957)

C. RECONVENE TO PUBLIC SESSION - REPORT OF CLOSED SESSION ACTIONS

C.1 REPORTIRATIFICATION OF CLOSED SESSION

D. ADJOURNMENT

E. THE NEXT SCHEDULED BOARD OF EDUCATION MEETINGLovonya Dejean Middle School- May 6,2015

ANTON JUNGHERRWCCUSD ALLEGED VIOLATION OF BROWN ACTAPRIL 29, 2015

EXHIBITBMay 6, 2015 Letter to WCCUSD Board of Education

West Contra Costa Unified School DistrictMinutes of the Special Board of Education Meeting

Closed SessionAlvarado Adult Education Campus, Room I

Richmond, CA 94804

Agenda Item B.7

April 29, 2015

A. OPENING PROCEDURESPresident Groves called the meeting to order at 10:00 A.M. The Board recessed into Closed Session. PresidentGroves reconvened the Public Session to report action taken in Closed Session at 12: J 0 P.M.

A.i Welcome and Meeting Procedures

A.2 Roll Call

Board Members Present; Liz Block, Valerie Cuevas, Randall Enos, Todd Groves, Madeline Kronenberg

Staff Present: Superintendent Bruce Harter; Debbie Haynie, Executive Secretary

Public Comment Prior to Closed Session:Anton Jungherr, Ben Steinberg, Tom Panas, Dan Romero, Linda Ruiz-Lozito, Scottie Smith

B. CONVENED TO CLOSED SESSIONc. RECONVENE TO PUBLIC SESSION - REPORT OF CLOSED SESSION ACTIONS.C.l Report/Ratification of Closed Session I

A President Groves reported that the Board of Education will establish an independent investigation and have findings} reported back to the Board upon completion.

D. ADJOURNMENTPresident Groves adjourned the meeting at 12:10 PM.

E. The Next Regularly Scheduled Board of Education MeetingLovonya Dejean Middle School - May 6, 2015

BH:dh

34----- ------.----------------------~. --_._----------

ANTON JUNGHERRWCCUSD ALLEGED VIOLATION OF BROWN ACTAPRIL 29, 2015

EXHIBIT CMay 6, 2015 Letter to WCCUSD Board of Education

1% Bail BondsLowMonthly Payments, Fast &Local ABBABail Bonds

CONTRA COSTA TIMES (http://\I\TW\I\T.contracostatimes.com)NEWS (/BREAKING-NEWS)

---- -.------ ----_.-. __ ..._--------------------

OVER 500 FRESH DEAL WEEKLYWest Contra Costa trustees to seek adetailed audit of bond program

POSTED: Q.tr.c9f201S05:17:.39PM PDT f UPDATED: d DAYS AGO

RICHMOND -. West Contra Costa trustees "ill seek a detailed audit of their bond constructionprogram in the wake of whistle-blower allegations of criminal wrongdoing and negligence by threedistrict officials.

",\s a board, we are committed to pursing an independent forensic examination of the issues raisedV in the complaint ~nil we have set fmtll a process to do so," Board President Todd Groves said 'It~ iVcdnesday, after a closed session meeting to discuss an undisclosed employee compla!~nd

the public "ill be ht;aring much more about it moving forward."

Dennis Clay, a project analystwho has worked in the districtfor 11 years, alleged in adocument sent to the boardearlier this month that he haduncovered evidence of criminalconduct by former TrusteeCharles Ramsey, "facilitation"by Superintendent Bruce Harterand negligence by Sheri Gamba.associate superintendent ofbusiness services. Clay whoperforms financial analysis forthe district, said Wednesdaythat he compiled three bindersfull of documents to back up his

claims. which he provided to outside auditors from Pleasanton-based Vavrinek, Trine, Day andCompany.

fi ..' ,~...." w' ~ ~ ': - ,"'- II' ...;.!I':-o '~1:.. . ~ . - _..

Advertisement "I had hoped that (the company) would use thedocuments given them in more than a cursoryway," Clay wrote to the board. "Like theauditors before them, Total School Solutions,they did not show much understanding, norinterest in the operational issues andcomplications involved in running a billiondollar bond program ..." Clay said that he wantsto discuss his allegations and documentationwith the independent Citizen's Bond OversightCommittee or its Audit Subcommittee, if thedistrict will allow that.

District spokesman Marcus Walton said it washis understanding that the board is hiring the auditors 10 conduct the independent investigation.He also said that Clay did not need the district's permission to talk about his documentation.

Whistleblower Service

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Groves said after the closed session that the district is taking whistle-blower protection lawsseriously and that he hoped the board would be ready to discuss its plans for a forensic audit at itsMay 6 meeting. A forensic audit is a much more detailed examination of the finances of the bondprogram.

DUling their closed session, trustees met with two outside lawyers, but excluded Harter from mostof the meeting without publicly stating why the superintendent -- who normally attends closedsessions -- was not allowed to participate ill a large portion of the discussions.

Ramsey, reached by phone late Wednesday afternoon, called the allegations "serious," aod saidthat Clay "would have to back them lip." He would not comment further and referred questions tohis attorney.

Several district residents who asked the board for an independent analysis of bond spending afterlearning of Clay's allegations praised trustees for taking the matter seriously. The residents saidtransparency is necessary to rebuild public trust in the bond program.

"This independent forensic audit is a HUGE step forward to shining light on the financialirregularities in the construction program," said resident Ben Steinberg, in an e-mail to L1Jisnewspaper.

Hercules City Councilman Dan Romero, who reminded the school board about whistle-blowerprotection laws before they went into closed session, said in an e-rnail after the meeting that hewas glad to hear the board would pursue a detailed audit.

"This is a huge step to transparency that residents in West County have 1I0t seen in over a decade,"he said.

Trustee Madeline Kronenberg said after the closed session that the FBI, which initially contactedher in relation to an SEe investigation into the bond program last fall, has not followed up withher. Trustee Val Cuevas said that the SEe investigation is ongoing.

Theresa Harrington covers education. Contact her at 925-945-4764 or. Follow her at

more Information To see whistle-blower documents, a letter from district residents seeking aforensic audit and a video clip from the meeting, visit _

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ANTON JUNGHERRWCCUSD ALLEGED VIOLATION OF BROWN ACTAPRIL 29, 2015

EXHIBITDMay 6,2015 Letter to WCCUSD Board of Education

3ubj: [WCCUSD CBOCl Fwd: 2014 Performance AuditJate: 4/24120158:26:25 A.M. Pacific Daylight TimeFrom: i\!-st~ericc;:~F!Gr:-i2i~.Gor:~:

FYI. Please do not reply to this email.

Sent from my iPhone

Begin forwarded message:

Begin forwarded message:

From; "Clay, Dennis"