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Docket Number: C54-17

SCH RECEIVED BY
PATRICIA ANN LICATA, OOL ETHl~S co~ THE SCHOOL
Complainant 1011 JUN 2: p ETHICS COMMISSION
v. :2 chF ~W JERSEY
RYAN CURIONI, SCHOOL ETHICS ACT
Respondent
COMPLAINT

I, PATRICIA ANN LICATA, residing at 15 North Woodside Avenue, Lodi, New Jersey,
07644 (201) 694-7587., request the School Ethics Commission to consider a complaint against
the above-named Respondent whose home address is 76 Liberty Street, Lodi, New Jersey,
07644, in accordance with the authority of the School Ethics Commission to entertain such
complaints under N.J.S.A. 18A: 12-21 et seq.

The facts upon which this complaint is based are as follows:

1. Statement of facts:

Patricia Ann Licata is a teacher in the Lodi, N ew Jersey School District.

Date of occurrence: September 1, 2003

2. Statement of facts:

Ryan Curioni is a Board Trustee on the Lodi Board of Education whom was sworn into
office during the Board of Education' s reorganization meeting.

Date of occurrence: January 4, 2017

3. Statement of facts:

The Board of Education unanimously approved the Code of Ethics of the New Jersey
School Boards Association. Mr. Curioni was present and voted for the Code of Ethics
that was read, discussed, and approved by the entire Board of Education.

Date of occurrence: January 4, 2017

4. Statement of facts:

Mr. Curioni operates a public blog with over 700 posts to date. He is the sole contributor
of the content on this blog entitled "Lodi By the Numbers" in which he comments upon
various matters related to the Lodi School District.

A link to Mr. Curioni's blog may be found at http ://lodioverhaul.blogspot.com/.

Date of occurrence: August 25, 2013

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Docket Number: C54-17 ..

5. Statement of facts:

Since being sworn in as a Board Trustee, Mr. Curioni has posted many entries
referencing the Lodi Board of Education, the administrators, and Board of Education
employees.

6. Statement of facts:

The posts on Mr. Curioni ' s blog are private action as defined under the School Ethics
Act. (See Exhibit 1)

I assert this to be a violation of: N.J.S.A.18A: 12-24.1 (e). I assert this to be a violation
of N.J.S.A.18A: 12-24.1 (e) because this blog is private action in which the statements
and posts on this blog reference the Lodi Board of Education members, its administrators,
and its employees. It attacks and publically demeans the functions of Board of Education
and the school employees as a whole.

7. Statement of facts:

Mr. Curioni posted a blog entry entitled, "If you don't like it, don't read it." That blog
entry contained allegations stating that Mrs . Licata, along with other "Politicians/school
employees" behaved like "animals" at the May 24, 2017 Board of Education meeting.
The post also contained a statement indicating that Mrs. Licata had "some union
leadership" make Mr. Curioni "their target." (See Exhibit 2). These allegations made by
Mr. Curioni are completely false and violate the Code of Ethics for School Board
Members.

A link to the post may be found at: http://lodioverhaul.blogspot.com/2017/05/if-you-dont-


like-it-dont-read-it. html

Date of occurrence: May 24, 2017

I assert this to be a violation of: N.J.S.A. 18A: 12-24.1 (e), (i), and (j). I assert this to be
a violation of N.J.S.A. 18A: 12-24.1 (e) because the individual attacks made by Mr.
Curioni against Mrs. Licata are private action and undermine Mrs. Licata as a Lodi Board
of Education employee and is referencing that Mrs. Licata and other "politicians/school
employees" behaved like "animals" and made Mr. Curioni their "target" which is false. I
assert this to be a violation of N.J.S.A. 18A: 12-24.1 (i) because Mr. Curioni is not
supporting Mrs. Licata in the school district and violates Mr. Curioni's responsibility as a
Board Member to protect and respect the performance of Mrs. Licata's duties as a Lodi
school teacher. I assert this to be a violation of N.J.S.A. 18A: 12-24.1 (j) because Mr.
Curioni did not file a complaint with the Lodi Superintendent of Schools, Frank
Quatrone, nor other administrators regarding the statements on this blog post.

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Docket Number:-C54-17

8. Statement of facts:

Mr. Curioni posted a blog entry entitled, "A councilwomanl"teacher" picketing on a


board member's property? Normal?" That blog entry stated that Mrs. Licata only "sells
pencils in the Wilson school store" and is "miserable." This post also contains a photo of
Mrs. Licata and her son, Joseph Licata, surrounded by $100.00 dollar bills. (See Exhibit
3). Mr. Curioni is indicating that Mrs. Licata is being compensated, which is completely
false. These statements violate the Code of Ethics for School Board Members.

A link to the post may be found at: http://lodioverhaul.blogspot.com/2017/05/a-


councilwomanteacher-picketing-on.html

Date of occurrence: May 28, 2017

I assert this to be a violation of: N.J.S.A. 18A: 12-24.1 ( e), (i), and (j). I assert this to be
a violation of N.J.S.A. 18A: 12-24.1 (e) because the personal attacks made by Mr.
Curioni against Mrs. Licata are private action and undermine Mrs. Licata as a Lodi Board
of Education employee. I assert this to be a violation of N.J.S.A. 18A: 12-24.1 (i)
because Mr. Curioni is not supporting Mrs. Licata as an employee of the school district
and violates Mr. Curioni's responsibility as a Board Member to protect and respect the
performance of Mrs. Licata's duties as a teacher, by stating that Mrs. Licata only "sells
pencils in the Wilson School store" and that she is "miserable." He is also belittling her
as a school employee with his statements, and false allegations that indicate that Mrs.
Licata is being compensated. His photo on this blog post displays a hurtful and
demeaning picture to the public of Mrs. Licata and her son surrounded by money, which
is in violation of this statue. I assert this to be a violation of N.J.S.A. 18A: 12-24.1 (j)
because Mr. Curioni did not file a complaint with the Lodi Superintendent of Schools,
Frank Quatrone, nor other administrators regarding the statements on this blog post.

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Docket Number: C54-17

\\THEREFORE, I, as Complainant, request that the School Ethics Commission find and
determine that the above-named Respondent(s) has violated the School Ethics Act and that he or
she be subject to such penalty as provided by the Act.

, ahf'ee~
Signature of Complainant
or his or her Attorney

CERTIFICATION UNDER OATH

PATRICIA AJ\TN LICATA, of full age, being duly sworn upon his or her oath according to
law deposes and says:

1. I am the complainant in this matter.

2. I have read the complaint and aver that the facts contained therein are trne to the best of
my knowledge and belief and I am aware that the statute that created the School Ethics
Commission authorizes the School Ethics Commission to impose penalties for filing a frivolous
complaint. N.J.S.A. 18A: 12-29(e). I am aware that if the respondent alleges that the complaint
is frivolous, I shall have 20 days from receipt of the answer to respond to the allegation.

3. The subject matter of this complaint is not pending in any court of law or administrative
agency of this State. I will advise the School Ethics Commission if I subsequently become
aware that it is pending elsewhere.

ANITA OPARAKU
ID# 2312522
NOTARY PUBLIC
Swo(j;;~tobeforem this J~f :-\({he,2017. STATE OF NEW JERSEY
My Commission Expires April 08 , 2019

Notice: All final decisions i sued in connection with complaints that come before the
School Ethics Commission for review and determination are public records uniformly
posted on the Department of Education's website at pttp:/1\vwn'.ni. . .gQy/e ducation/fo~,Aff. As
a general rule, selective requests to remove a particular decision for reasons of personal
preference are not enterta.ined.

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6/12/2017

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Sunday,Junell,201 7 Blog Archive

"Y 2017 (175)

Lodi education should be top priority ... ~ June (23)

"Y May (52)


"We arc already protecting the
taxpayers, " board m ...

Vinny Ma rti n should never have


been allowed on the ...
"I am here as the
Don't be fooled! 1 called this
mayor of Lodi." years ago.
Joseph Licata 's time line ...

F.m ii Cara fa Dominic Miller was promo ted


just months after reco ...

Crush it in November'
Why wasn't the Lodi softball
"I am here from the team invited to march ..
NJEA ." I challenge the two union bosses
to a debate .

Too much politi cs and union


activity at Washi ngton ..

Debra Kwapn iewski wants a


larger co ntract ra ise th ...
If you were at the last board meeting, you heard Mr. Carafa say "In a free society, there should
he was there as the mayor of Lodi. You heard Ms. be no forced asso ...
Kwapniewski say she was there as a representative of the Teachers can save money and
NJEA. still receive union re .. .

A councilwornan/"tcacher"
picketing on a board memb ...
Introductions weren't necessary. They are Washington School The union wants Dominic
employees no matter what hat they chose to wear that night. !Vii Iler back on negoti ation ..
Cost of this union bully:
$100,686 +a whole lot ...
One was there for Lodi politics. The other for the union. Debbie Downer. What would
make her happy9

Borough bills are ava ilabl e for


Both had priorities that night. Lodi education wasn't one of May ...
them. It 's ti me to turn our focus to
educat ion ... Chi ldren ..

A comp letely inequitable


Posted by RC ;it 9.:17..!'M. distribution across past ..
G!-1 RE-comrncnd this on Goog!(,
"When school children start
pay ing union dues ... "

Home Older Post Nothi ng orig in al from uni on


bullies ...

Good Ncwsl

Lodi uni on leader gets paid


$9 5,8 86 to teach pre-k .. .

How does River Vale get away


with a "personnel com ...

http://lodioverhaul.blogspot.com/2017/06/lodi-education-should-be-top-priority.html 1/3
6/8/2017 Lodi by the Numbers: If you don't like it, don't read it.
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Lodi by the Numbers

Wednesday, May 24, 2017 Blog Archive

.... 20 17 ( 168)

If you don't like it, don't read it. ... June ( 16)

'f' May (5 2)
"We arc already protecting th e
1axpayers," board rn ...

Vinny Martin should never have


been allowed on the ...
v-J \N \'-\ER Or
\\.\~ GOLDEN Don't be fooled! I called this

SNOWflP..KE years ago.

~'WARD GOES Joseph Licata 's time line ...

\0 If/ Dominic Mi ller was promoted

______) just months after reco ...

Crush it in N ovc rn he r1

Why wasn't th e Lodi soi'tb31l


team invited to march ...

T cha ll enge the twl' union bosses


FOR to a debate .
..., r-c.T
Too much pc)litics and un ion
activi ty at Wash ington ...
Politicians/school employees Licata, Carafa, and their Debra Kwapniewski w:rnts a
cheerleaders behaved like animals tonight. They don't la rger contract ra ise th ...
like this blog, so they had some union leadership make me " ln a free soci ety, there shou id
be no forced asso ...
their target.
Teachers can save money and
still receive union re ...

Once again, I ran to improve our schools. I ran to A council woman/"teacher"


picketing on a board rnemb ...
provide a form of checks and balance. I sought
The union warrts Dominic
nothing; for myself. Mill er back on nego tiation ...

Cost of this union bully:


$ l 00,686 + a who le lot ...
I represent the real people of Lodi. Debbie Downer. W hat would
make her lrnppy?

Borough bills are availab le for


I know Lodi has some great employees. I feel sorry for May ...
them. They weren't represented well toni2ht. It's time to turn ou r focus to
education ... Children ...

,4, comp letely inequ itable


Since I was targeted, I will point out a few concerns that I di stribution across past ...

have kept to myself: "When school children st<lrt


paying union dues ... "
No thing original from uni (in
bullies ..
1) It's unprofessional to wear black union t-shirts in the
classroom. There should be a dress code enforced by Goocl News '

administrators . Students are wearing khakis and polo Lodi union leader gets paid
$95,886 to teach pre- k...
shirts and educators are wearing t-shirts. What's wrong
How does River Vale get away
with this picture? with a "personnel com ...

http://lodioverhaul.blogspot.com/2017/05/i f-you-dont- 1i ke-it-dont-read-it.htm I


-....
6/8/2017
- Lodi by the Numbers: If you don't like it, don't read it.

If you don't like it, don't read it.

Board of Ed Meeting
2) It's unconscionable for union leadership to tell Wednesday ...

dedicated teachers to stop providing extra help. It's not Teachers deserve more money
in their pockets. Too ...
their business to tell dedicated teachers not to attend
events supporting children. $400,000

Ballot resolution to be re-voted


on Wednesday...

3) It's mob-like to march on two board members' Wall Street or Hunter Street?

properties in order to "send a message". How were those H!Bstervention had too many
glitches. Say it isn' ...
board members chosen? I am new to the board. I am not
First pension contributions vs
doing negotiations. I never said anything negative actual start date- ...
towards our educators.
If you don't want to be the;e ....
Why the November 7th
referendum is necessary:
It's wrong to hurt children in order to achieve a goal. It's
Lodi tax bill explained by
wrong to harass in order to achieve a goal. That's typical Kristie Cattafi:
NJEA. Try earning something on merit! Some positives and negatives
from tonight's works ...

The Lod i politicians won't like


How about behavin2 like adults? How about findin2 this bill ..
common 2round? How about settin~ a ~ood example May agenda for the Lodi Board
for our youth? of Education:

$25, 108 bonuses shou ldn 't be


handed out like candy ...

I will always be objective and represent everyone fairly Paramus BOE awarded ONE
YEAR contracts for the fol. ..
despite the disrespect of the loud mouths and crybabies.
Should hiring practices be
scrutinized? The publi ...

Where are the requests for


And I will continue to post on this blog. qualifications?

Has Mayor Carafa's opinion on


the building changed ...
Posted by RC at l.Q:.QJ..IM
Buried in debt and bonding
G..,1 RecCJmmend this on Google
away ..

"Voters w ill not have a say on


Newer Post Home Older Post new Lodi building"

Timing of Jason Ciofalo 's letter


is suspect.

Who is Jamie Ciofalo's brother


referring to?

"Un ited for Lodi " campaign


contributors spend big ...

"We either have an attendance


policy or we don't." ...

" ... the 8-0 vote to remove


Esteves followed."

Lodi Mayor & Council should


follow Woodland Park

Dominic Miller quietly


"nego tiated" another 2% rai ...

..,_ April (26)

..,_ March (31)

..,_ February (17)

..,_ January (26)

http://lodioverhaul.blogspot.com/2017/05/if-you-dont-I i ke-i t-dont-read-i t.htm I ?/':!.


6/8/2017 Lodi by the Numbers : A councilwoman/''teacher" picketing on a board member 's property? Normal?

G+1 More Next Blog Create Blog Sign In

Lodi by the Numbers

Sunday, May 28, 2017 Blog Archive

T 2017 (168)
A councilwoman/"teacher" picketing on a ~ June (16)
T May (52)
board member's property? Normal? "We arc already protecting the
taxpayers," board m ..
Vinny Martin should never have
been allowed on the ..
Don't be fooled! I called this
years ago.

Joseph Licata 's time line ..


Dominic Miller was promote;d
just months after reco ..
Crnsh it in November'

Why wasn't the Lodi softball


team invited to rnarch ...

J challe nge the two union bosses


to a debate.
Too much po litics and union
How difficult is it to sell pencils in the Wilson school activity at V/ashinglon ..

Debra Kwapn ie wski V/ants a


store? larger contract raise th ...

"ln a free society, there should


be no forced asso ..
I don't thinks its Patty's job or contract that is
Teachers can save money and
making her so iniserable. still receive union re ...
A councilwornan/"teacher"
Post<XI by RC at 0:.21 . PM picketing on a board memb ..
G d Recomrnend this un Goo9le
The union wants Dominic
Miller back on negotiation ..

Newer Post Home Cost of this union bully:


$100,68,6 + a whole lot ...

Debbie Downer. What would


make her happy'

Borough bills are avai lable for


May ...
It's time to turn our focus to
ech1cation . . Children ...

/\. completely mequitable


distributi on across past .

"When sc hool children start


paying union dues ... "
Nothing original from union
bullies.

Good Ncwsr
Lodi union leader gets paid
$95,886 to teach pre-k ...

How does River Vale get away


with a "personnel com ...

htto://lodioverhaul.bloasoot.com/2017/05/a-councilwomanteacher-oicketinq-on.html 1/3