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TEL.: (404) 654-0288
FAX: (404) 592-6225

July 28, 2014

Sent Via U.S. Mail to Office Address, Home Address, and Email to:
Dr. Meria Carstarphen
Superintendent, Atlanta Public Schools
130 Trinity Ave.
Atlanta, Georgia 30303
Sent Via Email to:
Mr. Jason Esteves
Ms. Leslie Grant
Mr. Bryan Amos
Mr. Matt Westmoreland
Ms. Nancy Meister
Mr. Steven Lee
Ms. Eshe’ P. Collins
Mr. Courtney English
Ms. Cynthia Briscoe Brown
Mr. Erroll Davis
Dear Superintendent Carstarphen:
Greetings, we welcome you to Atlanta and are hopeful that you, alongside the newly elected Atlanta
Board of Education will bring the change that has been so urgently needed to APS. Over the years we
have observed a status quo culture that sweeps systemic problems under the rug in a way that mitigates
risk of legal liability rather than chooses to address real ethical concerns; one that punishes scapegoats
rather than perpetrators; and one that reacts to corruption with cover-up rather than rooting out the real
poison that seems to fester on.
This can be most reflected in the case I am about to tell you about.
But before I do, I ask that each of you as the new Superintendent and Board of Education carefully
read this letter and exercise your leadership appropriately by intervening on the current retaliation

that is occurring against Dr. Tori Reynolds Jackson, who to date, presently suffers harsh retaliation due
to her whistleblower activity from reporting child abuse within the Atlanta Public Schools. Despite
APS being repeatedly notified of a problem, the child abusers were not removed from the classroom
nor arrested and charged until Dr. Reynolds Jackson forced the issue. Dr. Reynolds Jackson was
compelled to notify Atlanta Police Department herself along with bringing the attention to the media
which included the AJC, CBS local television news, national shows like Nancy Grace, CNN, and
exploded into the international media this past summer. (See Exhibit 1, p. 9 section 2.) Nevertheless,
Dr. Reynolds Jackson believed this was the only way she could protect these children in her classroom
from such violent criminal acts. She paid the price for her whistleblower activity by subsequently
being retaliated against most severely. Not only was her good name defamed by being wrongly
accused of failing to report such abuse in a timely manner, APS took away her job, placed her teaching
certification at risk before the PSC, and is currently seeking to deny her the ability to put food on her
family’s table by depriving her of basic unemployment benefits.
Factual History:
Dr. Reynolds Jackson came from Gwinnett County School District with excellent credentials and
spotless record just last fall. She started APS during the 2013-2014 school year as a special education
teacher at Harper Archer Middle School. Her classroom was composed of two paraprofessionals, a
behavioral specialist, and a nurse, each of them assigned to students with severely profound,
intellectual disabilities. Most of her students required around the clock care which included use of
feeding tubes and diaper changes. Many were visually and auditory impaired, and some exhibited
violence towards themselves and others requiring physical restraining at times.
She was immediately struck by what appeared to be a non-caring atmosphere for these children. The
room was ill equipped. There was no adequate place for the students to lay down. A bed was braced
upon the wall and untreated infestations of bugs would regularly crawl on the students. The School
District Nurse and the Supervisory Nurse were both called into look at the situation and both said to
her: “This is deplorable.”
While every other teacher had curriculum set in place, Dr. Reynolds Jackson was given absolutely no
curriculum. Early in the semester, Principal Jermaine Dawson sat her down and asked her what her
opinion was of her co-workers. He informed her that other teachers had complained he was a tyrant
who micromanaged. She herself had observed him telling the entire faculty that if he caught any
teacher gossiping about him, he wouldn’t renew them or allow them to obtain tenure.
She was not sure how to respond to her Principal’s question, but she truthfully reported her concerns
regarding the substandard care and lack of resources provided to her classroom. She reported to him
that the services required by law as noted on the students IEP’s were not made available, for example
assisted communication devices. She also informed him that her staff members were refusing to
comply with her directives and were refusing to do anything for the students---that they would sit their
in classroom and watch movies from their computer laptops doing nothing all day despite her
instructing them otherwise.
Dr. Reynolds Jackson repeatedly made these complaints to her Principal throughout the fall semester.
Each time the Principal would call the staff into a meeting and they would adamantly deny it. At no
time did the Principal go by Dr. Reynolds-Jackson’s classroom to observe the situation or to confirm
what she was reporting was in fact occurring. When Dr. Reynolds Jackson would email her LEAD
teacher (Patrice Stokes) for assistance concerning the services to be provided on her students IEP’s, her

requests would be ignored.
The para-professional that caused Dr. Reynolds the most trouble for her was Ms. Kesha Smith. From
the start, Ms. Smith wanted to take charge over the classroom and pressure other staff members to
follow her lead rather than Dr. Reynolds Jackson’s. Dr. Reynolds Jackson describes Ms. Smith’s
perspective as if she was babysitting a medical ward. In Ms. Smith’s mind, the children could never
walk, learn or eat by themselves, so she would do nothing for them.
Dr. Reynolds Jackson informed the Principal repeatedly that the situation was “horrible, that the staff
members were not following any of her instructions, and all they wanted to do was to sit down and do
nothing but watch Lifetime movies from their laptops.” The Principal’s response to her first complaint
was to call a meeting on. August 28th. The meeting was attended by Principal Jermaine Dawson,
Theresa Andrews (Asst. Principal, direct supervisor), another Asst. Supervisor (Gerilyn Harper), Miss
Patrice Stokes (LEAD teacher.) Miss Kesha Smith (paraprofessional ) and Miss Marie Bennett
(paraprofessional.) At the meeting, Dr. Reynolds Jackson outlined all of her concerns about how the
staff neglected their job duties. They didn’t want to help her lift and change the students. If the students
soiled themselves the staff would just leave them there despite Dr. Reynolds Jackson’s directives. It
was okay in their opinion for a student to stay soiled for seven hours straight, changing them only right
before the parents came to pick them up. The staff viewed movies and videos on personal computer
throughout the entire day. They were disrespectful to her as teacher, telling her things like “no one
cares about your title or what you say.”
After she outlined all her concerns, Principal Dawson asked the staff: “What do you have to say for
yourselves?” In response, the staff outright lied, denying it completely, and stated that it was “Dr.
Reynolds Jackson,” blaming her for everything that she accused them of.
In response, Principal Dawson, rather than conducting observations of the classroom to learn who was
telling the truth, simply informed them “you all need to work together.” Unfortunately, however the
staff’s behavior became worse. They refused to follow the schedule Dr. Reynolds Jackson had put in
place, informing her “they don’t need a schedule, they know how to do their job.”
Shortly after the first meeting paraprofessional Ms. Smith claimed a workers compensation injury and
informed Dr. Reynolds Jackson she now could not change any of the students diapers. Dr. Reynolds
Jackson was at her wits end with the entire staff in effect having declared a mutiny against her.
Sometimes Dr. Reynolds Jackson found herself trying to push two wheelchairs at once while holding
onto one child, with her staff sitting there doing nothing to assist her. Each time she would raise her
concerns to Principal Dawson, her staff would deny this was happening and instead accuse Dr.
Reynolds Jackson of whatever she claimed they were doing wrong. Rather than observing the
classroom, Principal Dawson informed her “he was tired of anymore meetings” and that he would fire
everyone if the problem did not resolve itself. Consequently on September 27th Dr. Reynolds Jackson
informed Principal Dawson that rather than meeting, she would go to the LEAD special education
teacher Mrs. Stokes and try to resolve issues through her.
Dr. Reynolds Jackson did meet with Mrs. Stokes. She explained that she was unable to communicate
with her students properly because there were no communication assistive devices as mandated on
their IEP’s. She filled out paperwork requesting these assisted devices per the IEPs. She also informed

him that one of the children had very self injurious behavior and that he required a one on one person
to be with him, speech therapy, adaptive PE, and assisted technology but none of these were being
provided pursuant to the IEP. After expressing her concerns to Mrs. Stokes and submitting the
paperwork for the assisted devices, none were provided. As a result, Dr. Reynolds Jackson emailed Mr.
Thomas Munn who was in charge of special education at central office who forwarded the email to
Mrs. Stokes. Mrs. Stokes confronted Dr. Reynolds Jackson reprimanding her: “you can’t ever be
sending emails like this, if Principal Dawson knew about this you would be in so much trouble.
Whatever issues you have, you have to keep it in the building.”
In January of 2014, Dr. Reynolds Jackson was at her wits end. She noticed the staff getting looser with
the children. She observed them physically touching the children more casually although not in a
manner that was abusive or caused her to suspect abuse at this time. This was a difficult assessment to
make because some of the children, particularly those violent toward themselves or others, required
physical restraint at times. Others, who could not see and hear, required physical direction also in order
to get them to where they needed to go.
Nevertheless while she did not yet suspect abuse yet, she wished to prove to Principal Dawson the
problems she had complained of in the classroom were really occurring i.e. paraprofessionals sitting all
day watching Lifetime movies from their computers without interacting with the children. She knew
she had to be very careful because anything she ever reported against her staff, they in turn would deny
it and accuse her of doing the exact same thing. Thus, she knew the only way she could protect her
students would be to videotape the classroom to show the administration who still she questioned
whether they would do anything. During the three formal classroom observations she had, the
Assistant Principals all saw the support staff on their desks sitting at their computers not doing
anything as she had complained of, yet did not do anything about this.
Reports of Violent Physical Abuse:
On February 19th, Dr. Reynolds Jackson set up a camera with the objective to prove to Principal
Dawson the problems she had complained of in the classroom, i.e. paraprofessionals sitting all day
watching movies without interacting with the children. After work each day she only skimmed a
portion of the videos and did not witness abuse. On the late evening of February 24th however, she
viewed the videotape and observed horrendous physical abuse of the children. She was sickened,
mentally traumatized, horrified and became severely distressed. The morning of February 25th, at 10:27
a.m. she immediately emailed her Principal stating: “I am writing to inform you per Georgia law and
Atlanta Public School policy that I witnessed events that happened on February 24th at approximately 2
p.m. that may be constituted as child abuse. The events involved Keisha Smith, paraprofessional and
Al Smith, behavioral specialist and RB student. Mr. Coleman placed RB in a headlock position and
appeared to choke the student while Ms. Smith stood in close proximity and laughed at the
incident. A short time later Mr. Coleman slapped RB with such force that it caused him to fall
out of his chair multiple times. Please investigate this matter pursuant to Georgia law and APS
policy.” (Exhibit 2, page 30)
On Wednesday, February 26th at 4:59 a.m. Principal Dawson emailed Dr. Reynolds Jackson and
informed her that she must speak to the social worker. At this point, Dr. Reynolds Jackson was

suffering from extreme psychological and mental trauma from the stress of observing such violent
incidents in addition to the stress compounded from all year long. She would require immediate
medical treatment and was urged to obtain the assistance of Attorney Janet Scott, a well-known
education lawyer who was a former defense attorney at the law firm which regularly represents Atlanta
Public Schools. Ms. Scott advised her that she had fulfilled her legal obligations under Georgia law by
reporting the specific abuse in writing within the mandated 24 hours. Ms. Scott also urged her not to be
verbally interviewed or to report the incident orally because “APS would only pressure you to
change your story and will likely intimidate you into doing so.”
Nevertheless, on February 26th at 12:18 p.m., she received an email from the social worker who stated
to her “I will later be in contact” [with you.] As such, Dr. Reynolds Jackson decided to wait to hear
from the social worker to contact her regarding this matter. At the same time, Dr. Reynolds Jackson
began experiencing symptoms of a nervous breakdown due to the stress. Her husband insisted she seek
immediate medical treatment where a physician diagnosed her as having an “acute stress disorder” due
to the trauma she had observed.
Shortly thereafter, she was informed that the social worker closed the investigation “due to lack of
evidence” despite no one ever personally calling Dr. Reynolds Jackson to interview her regarding the
incident she had observed. By this time, there was no way Dr. Reynolds Jackson could go back into
the same classroom and work with a staff that she knew was physically abusing her children. Dr.
Reynolds Jackson also knew she would have to report the matter to the police along with the providing
them the videos (rather than relying on APS to do so). She believed this was the only way she could
protect the children from the abuse since APS would not remove her staff from the classroom or even
determine that abuse had occurred.
As such, Dr. Reynolds Jackson met with the police department along with her attorney. At the same
time, her attorney filed an EEOC charge on her behalf and requested a temporary FMLA leave as Dr.
Reynolds Jackson was now undergoing intensive treatment for her Acute Stress Disorder, and
requested reasonable accommodations of a transfer to a different classroom as the abusers were still
working inside the classroom. In response, she was informed that her transfer would not be granted.
By mid April, because APS had still failed to address the issue of child abuse in her classroom, Dr.
Reynolds Jackson felt compelled to go to the media in order to save these children from physical
injury. She was interviewed by CBS local news and by Nancy Grace of CNN national news amongst
having it reported in multiple newspapers. The story picked up international coverage. Three days
later, for the first time, APS requests a meeting to interview her to discuss allegations of child abuse.
Subsequently, Dr. Reynolds-Jackson began working with the Assistant District Attorney after staff was
arrested and later prosecuted.
APS Retaliates Against A Whistleblower With Accusations that Dr. Reynolds Jackson Failed to
Report Abuse---Outrageously False and Retaliatory Claims:
Shortly after being interviewed by APS, she was placed on administrative unpaid leave by APS.
Shortly thereafter, on May 16th she was sent a letter stating that her contract was non-renewed for
failure to report child abuse. The letter that Mr. Erroll Davis sent her stated that on February 19th, 21st,

and 24th that she was present when the abuse occurred but failed to intervene. This was a misleading,
false, and reprehensible accusation. Any abuse that occurred as can be seen from the videos, only
occurred when Dr. Reynolds Jackson was not present in the room, or if Dr. Reynolds Jackson
was in the room, the abuse was outside of her eye-shot and occurred while she was distracted on
her computer or with another child and not aware of what was occurring.
Finally, Dr. Davis’ letter refers to an interview she had with investigators at the Office of Employee
Relations where she admits to observing Ms. Smith “being really physical” back in January and not
reporting it. Fortunately for Dr. Reynolds Jackson, she had audiotaped this entire interview and
in reviewing the recording, at no time did Dr. Reynolds Jackson ever admit that she had observed or
suspected child abuse occurring back in January of 2014. What she stated she did notice was one of the
paras (Ms. Smith) being more physical with a student. This was the student who was extremely violent
and a danger to himself and others and as such paraprofessionals would grab him at times to prevent
him from certain physical actions on his part. While she did not feel comfortable with any of Ms.
Smith’s interventions with children and believed her to be inappropriate in every interaction (whether
it be leaving a child soiled in a diaper for seven hours or ignoring children to watch her Lifetime
movies), she at no time suspected abuse. February 24th was the very first time she became aware of the
egregious abuse and she reported what she specifically observed in writing within 24 hours as
mandated by Georgia law.
APS Not Only Took Away Dr. Reynolds Jackson Employment, But They Falsely Reported Her
To The PSC and Currently Are Disputing Her Unemployment Benefits With the Department of
Labor Causing Her Grave Hardship:
Not only has APS filed false allegations against Dr. Reynolds Jackson to the PSC putting her teaching
certification at risk and hence jeopardizing her ability to obtain gainful employment in the future; they
have also spitefully sought to deny her unemployment benefits. Most recently, APS has defamatorily
reported to GA DOL that: “during investigation is was found that Ms. Jackson observed co-workers
dragging students across the classroom, grabbing and hitting students, and throwing students on the
floor. Ms. Jackson failed to report this to management.” This is an utterly false and reprehensible
APS Needs To Start Doing What Is Ethically Expeditious Rather Than Just Legally Expeditious:
For too long, a culture has pervaded within APS of covering up systemic problems rather than rooting
out the source; or, blaming scapegoats rather than perpetrators, behavior which mitigates risk of legal
liability rather than chooses to address real ethical concerns. It is Dr. Reynolds Jackson’s
understanding that the parents of these children have now filed lawsuits. It may be legally expeditious
as a defense counsel strategy to try and blame Dr. Reynolds Jackson and attempt to make her the
scapegoat. Nevertheless, it is not ethically expedient because what it has done is send a message to
every other APS educator that nothing has really changed. That you will still be punished if you buck
the system, if you blow the whistle, that we care more about public perception than classroom reality,
and that we continue to promote a culture that prefers to cheat our children or put lipstick on a pig in
an effort to avoid negative, public spotlight.
Dr. Reynolds Jackson’s courageous decision to blow the whistle on this child abuse received both
national and international spotlight. APS employees and educators watched how APS responded to Dr.

Reynolds Jackson’s actions by blaming her instead. This sent a very loud and clear message that the
status quo still applies.
Dr. Reynolds Jackson reported individuals committing graphic abuse occurring on a specific date and
time (putting a child in a headlock, slapping a child so it fell from his chair multiple times on Feb. 24th
at 2 p.m.) Yet these employees were never fired, or removed from the classroom even to be suspended
on leave while pending investigation. It took Dr. Reynolds Jackson having to report this cover-up of
corruption herself to the Atlanta Police Department and the media for APS to finally take appropriate
action and have these staff members removed from the classroom.
To date, other staff members who were part of this environment remain employed. The Principal, who
received complaints all year long yet not once decided to observe the classroom himself remains in a
leadership position. The students remain subjected to neglect, deprived of their special education
services including their communication assisted devices as mandated by their IEP’s in violation of
Section 504 and the IDEA. The room remains as the school district nurses described in “deplorable”
conditions. A culture remains to exist where the LEAD special education teacher ignores a teachers
repeated complaints and then reprimands them for reporting these issues to central office
administration: “Whatever issues you have, you have to keep it in the building.” To date, a social
worker who failed to appropriately investigate reports of child abuse and determined no evidence
existed to support such a finding remain in charge of protecting our APS children in the future. A
Principal who failed to place individuals on leave pending an investigation after being informed they
were placing children in “headlocks” and “slapping” children in faces till they fell from their chairs
exactly at 2 p.m. on February 24th, and who failed to appropriately respond to complaints of special
education violations all year long, remains in charge of a school that provides such “deplorable”
conditions to its disabled youth. The Office of Civil Rights for the Department of Education will be
notified of these actions.
This is a Symptom of a Much Larger Problem: a Systemic Culture of Cover-up That Exists:
APS remains a culture where educators are afraid to come forward to report unlawful actions and
violations that harm children and our community. APS remains a culture that sends messages to its
employees that it chooses to punish whistleblowers who embarrass them in the media by exposing and
reporting illegal acts, including those that harm children and place them in danger. APS continues to be
a culture that sends a message that if you seek to expose APS we will punish you, and we will not only
take away your job, but potentially your livelihood, both your teaching certification, and your ability to
even put food on your family’s table by depriving you of unemployment benefits.
APS demands leadership that refuses to act not in a way that is solely legally expeditious but rather
does that what is most ethically expeditious. That which sends a message to the APS community at
large that we will protect our whistleblowers, not persecute them.
As an attorney who represents educators, I have read the APS transcripts in past where investigators
have employed with police style interrogation tactics into obtaining statements that can unfairly be
twisted into admissions of guilt, or as Dr. Reynolds Jackson was warned by APS’ former legal counsel
not to ‘agree to provide an oral statement or give an interview’ because “APS would only pressure
you to change your story and will likely intimidate you into doing so.”

It appears that at this point, Dr. Reynolds Jackson has claims against APS under the Family Medical Leave
Act 29 USC § 2601, the Georgia Whistleblower Act, O.C.G.A. § 45-1-4 and the Rehabilitation Act of
1973, Section 504, 29 USC § 794. At this point however, prior to filing suit and before the statute of
limitations runs, she will need to focus on her defense before the Professional Standards Commission in
addition to subpoenaing witnesses and documents from APS for her unemployment hearing before the
Georgia Department of Labor.
We urge the Superintendent and Local Board of Education to exercise your leadership to intervene in
this matter and to see that APS really and truly addresses this issue, only individually by ceasing and
desisting from all further retaliation against Dr. Reynolds Jackson including but not limited to denying
her unemployment benefits, but systemically in a way that addresses this underlying culture that
remains even in spite of the many changes Dr. Erroll Davis has seen fit to make.
While Dr. Reynolds Jackson would propose that the Local Board grant her all non-futile administrative
remedies including an 1160 hearing, we would also suggest that the Superintendent and Local Board
agree to mediation with Dr. Reynolds Jackson to resolve her whistleblower action and Section 504
claims in addition to this dispute over unemployment benefits.
This letter places the District, all its employees, and the Board of Education on notice to NOT destroy,
conceal or tamper with any communications including but not limited to your text messages, emails,
reports, records, all documents, memos, voicemail, faxes, letters, forms, and meeting minutes
particularly regarding matters as mentioned in this letter. This includes all communications that are
stored on personal phones and computers, work phones and computers, and private email address
Additionally, we demand that you preserve all paper or electronic files including data generated and/or
stored on relevant computers and storage media (e.g., servers, hard disks, floppy disks, backup tapes),
including voice mail.
As you know, a Court may sanction you, severely, for spoliation of evidence due to your failure to
comply with this notice. That means, if a Court determines that you have deleted, destroyed altered, or
concealed various emails or texts, or other pertinent information pertaining to this legal matter, the
Court will either strike your entire legal pleading and thus enter judgment against you. Or, the Judge
would instruct the jury to presume that all deleted, concealed, or altered information was unfavorable
to your case.
Remember, we will ensure that our computer/digital forensic specialists examine your relevant
media/informational systems. Notably, our computer forensic experts are able to identify whether you
have deleted or altered vital information from, for example, your company’s server. Georgia and
federal courts have held that all information available on electronic storage media is discoverable,
whether readily readable (“active”) or “deleted” but recoverable.
To assure that your client meets its legal obligation to preserve documents and things, please forward

notice to all relevant people including the Principal and special education personnel within APS and
Harper Archer Middle School, information technology personnel, and anyone else who may have
custodial responsibility for relevant information to this case.
Finally, regarding the attached Open Records Act demands, if there is an estimated cost for any
request, this too should be delineated separately and individually per each response. Our law firm is
prepared to pay reasonable search and retrieval fees if necessary. Nevertheless, we fully expect that
you will show good faith and comply with the law by not charging us an excessive or unreasonable
amount for these records. If you respond to us with an unreasonable amount we will consider this to be
in violation of the Georgia Open Records Act and will have no choice but to file suit.
The records are to be produced for inspection or copies within three business days, the time
required under Georgia law. O.C.G.A. § 50-18-71(b)(1)(A). In the event that the requested records
cannot be made available within three business days of this request, a written description of such
records, together with a timetable for their inspection and copying, must be provided within that
period. Id. To the extent that you take the position that any records responsive to these request are not
subject to the Open Records Act or if access to such records is denied, in whole or in part, you are
directed to specify in writing the specific legal authority exempting each record from disclosure, by
Code section, subsection, and paragraph, within three business days as required by O.C.G.A. § 50-1871.
PLEASE DO NOT OMIT ANYTHING FROM YOUR RECORDS. If you cannot provide any part of
the requested information, then, by law you are required to provide a legally sufficient reason why
you cannot provide the excluded information. As you are well aware, pursuant to O.C.G.A. §50-1874(a): “Any person knowingly and willfully violating the provisions of this article by failing or
refusing to provide access to records not subject to exemption from this article or by failing or refusing
to provide access to records within the time limits set forth in this article shall be guilty of a
I look forward to hearing from you.
Very truly yours,



TEL.: (404) 654-0288
FAX: (404) 592-6225

July 28, 2014
Dear Superintendent:
Pursuant to the Georgia Open Records Act O.C.G.A. § 50-18-70 we demand copies of:
All documents and records that support or concern APS’ allegations that Dr. Tori Reynolds Jackson
failed to report child abuse in a timely manner or knew of child abuse or observed child abuse and
failed to intervene or report it.
Please advise your employees that all communications (including her text messages) are considered to
be governmental records according to the statute and a public official that commits destruction of such
governmental records (i.e. by deleting them) shall be guilty of a felony and, upon conviction thereof,
shall be punished by imprisonment and labor in the penitentiary for up to ten years. O.C.G.A. §45-111.1
Thank you for your cooperation and I look forward to your reply.
Very truly yours,


Examples of this in Georgia can be found here:,