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Office of the Attorney General

One Ashburton Place
Boston, MA 02108
Please note that all fields are required unless otherwise noted.

Your Contact Information:

First Name: Richard

Last Name: Cohen

Address: P.O. Box 351

City: Lanesborough
Phone Number:

State: MA

Zip Code: 01237



Organization or Media Affiliation (if any):

Are you filing the complaint in your capacity as an individual, representative of an organization, or media?
(For statistical purposes only)




Public Body that is the subject of this complaint:





Name of Public Body (including city/ Chairs Committee, Williamstown-Lanesborough Tri-District

town, county or region, if applicable):
Specific person(s), if any, you allege
committed the violation:
Date of alleged violation:

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Dan Caplinger, Regina Dilego, Carrie Greene, Doug Dias

May 13, 2016

Description of alleged violation:

Describe the alleged violation that this complaint is about. If you believe the alleged violation was intentional, please say so and include
the reasons supporting your belief.
Note: This text field has a maximum of 3000 characters.

Williamstown Elementary(WES), Lanesborough Elementary (LES) and Mt Greylock Reg. H.S. (MG)--share a superintendent as the
Tri-District. The three districts are each governed by their own elected school committee (SC). The SCs established 2 committees to
facilitate their cooperative arrangement: (1) Superintendency Union 71 (SU71) consists of 3 members from each of the elementary SCs,
and (2) the Administrative Review Subcommittee (ARS), composed of the WES SC chair, Dan Caplinger, and the LES chair, Regina
Dilego, and two members of the MG SC, including its chair, Carrie Greene. All 4 members of ARS must be present for a quorum, and 3
are a voting majority.
In violation of OML, a Chairs Committee (CC) -- Mr. Caplinger, Ms. Dilego, and Ms. Greene -- have been regularly deliberating
and taking collective action in private, without posting agendas or recording minutes. At least some of the time, Superintendent Dr. Dias
also participates.
For example, on 3/4/16, at 9:13am. Dr. Dias emailed the CC asking for approval to pursue the possibility of his serving as the
part-time superintendent for three other towns. The CC voted by reply all emails during the next 90 minutes. Dilego at 9:36: "I'm glad
this is moving forward." Caplinger at 9:37: Im fine.... Ms. Greene at 10:49: Agreed with all of the above. They collectively edited
the letter and Dr. Dias submitted it on 3/7 on Tri-District letterhead. The MG SC as a whole had no knowledge of this matter until an
executive session on 3/15 (called for a completely unrelated matter) was misused to discuss it. The MG SC was told that the matter was
being revealed because news of the letter would be appearing that day in the Berkshire Eagle.
Although MG SC members expressed outrage during the executive session that the Chairs and Superintendent acted without their
knowledge, the CC continued to take collective actions in secret. For example, Ms. Greene wrote to the other CC members and Dr. Dias
at 9:06am on 5/13, about the process of evaluating the superintendent: Lets discuss at todays meeting. Later that day, as part of the
same email thread, statements were issued by Ms. Green at 4:02pm and by Ms. Dilego at 10:51pm, acting on the agreed outcome of the
CC meeting. Note that ARS has jurisdiction over the process of evaluating superintendent, but the fourth member of ARS was not made
aware that the CC was meeting.
The CC also took concerted action by secretly engaging the districts legal counsel against MG members that expressed dissenting
opinions such as complaints about the decision-making process on whether the Superintendent expand his responsibilities by taking
on administration of additional school districts. (Greene email to CC at 4:20pm 5/13) MG SC policy BDG prohibits access to the
districts legal counsel by individual SC members (including the chair) unless the purpose receives prior approval from the whole

What action do you want the public body to take in response to your complaint?
Note: This text field has a maximum of 500 characters.

I hope and expect this complaint can be resolved locally to give the public confidence that district
governance will be conducted in a democratic manner that doesnt exclude the eyes of the public and
the voices of dissent. If we need the three chairs to take collective action, lets agree to a process
consistent with Open Mtg Law that ensures the district administration does not have an alternative to
fully engaging school committees and the public on educational policy and budget priorities.

Review, sign, and submit your complaint

I. Disclosure of Your Complaint.
Public Record. Under most circumstances, your complaint, and any documents submitted with your complaint, will be considered a
public record and available to any member of the public upon request. In response to such a request, the AGO generally will not disclose
your contact information.
II. Consulting With a Private Attorney.
The AGO cannot give you legal advice and is not able to be your private attorney, but represents the public interest. If you have any
questions concerning your individual legal rights or responsibilities you should contact a private attorney.
III. Submit Your Complaint to the Public Body.
The complaint must be filed first with the public body. If you have any questions, please contact the Division of Open Government by
calling (617) 963-2540 or by email to
By signing below, I acknowledge that I have read and understood the provisions above and certify that the information I have provided is
true and correct to the best of my knowledge.

Signed: ___________________________________________

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May 24, 2016

For Use By Public Body
For Use By AGO
Date Received by Public Body: Date Received by AGO: