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Answer to Complaint

Paragraphs 1 and 2.

1. I agree with paragraphs 1 and 2. I am aware that Ms. K is very active in the Lodi

Education Association (LEA), the Bergen County Education Association (BCEA) and the NJEA.

Paragraph 3

2. Ms. K did receive her position in 2001 via patronage. Her brother August Defalco sat on

the Lodi Board of Education in the 1990s. He was the campaign manager for the machine

ticket in the 1999 board election. He served as campaign manager in following years when

there were contested races. His bulk mail permit (No. 35) appeared on every campaign mailing

up until 2007 (maybe even later). August Defalco was hired in the Lodi schools as District

Technology Coordinator shortly before his sister was hired as pre-k teacher.

3. In my 36 years, I have never seen an elementary teaching position advertised in Lodi. If

a position is not advertised, if there is no competition, and someone is hired for their campaign

activity, that by definition is patronage. There may be nepotism and patronage all over, but

Lodi is in a class of its own.

4. At the June 28, 2017 board of education meeting, I recommended advertising all

positions, and not just Math and Science. I pointed out that Lodi has never advertised an

elementary teaching position. I named some Bergen County districts that do advertise elementary

positions and those districts are performing well. Ms. K, Councilwoman Patricia Licata, and

some union activists heckled me for saying that.

5. Ms. K engages in dirty tactics on behalf of Lodis political machine whether it be for a

mayor and council election or board of education election. She has become even more

aggressive in recent years with Emil Carafa as mayor and Jonathan Carafa as a member of the

Lodi Board of Education. Ms. K is employed at Washington School where Lodi Mayor Emil

Carafa is principal. Ms. K tells a story to Washington School parents that she ran a day care out

of her house and Emil Carafa recruited her to teach at his school. The two have been long time

friends and share many common interests, most notably their political patronage system and their

dirty campaigns.

6. Debbie Downer is an SNL skit. I was unaware that I couldnt use any humor on a

personal blog.

Paragraph 4

7. I dont believe its the SECs role to investigate the expression: If you can read, thank a

teacher. If you cant thank a teachers union. There is a difference between a public school and

a union hall.

8. I never said anything negative towards the Lodi Education Association until May 24,

2017. On May 24th from about 6 pm to 6:45 pm, Councilwoman Licata led a protest outside of

my house and my business. In Ms. Licatas answer to the SEC (arguing why her complaint isnt

frivolous), she wrote: The LEA arranged the demonstrations and locations. That is Ms. Ks

role within the LEA.

9. I am not on negotiations and I always had a good relationship with Lodi teachers. I had

many Lodi teachers support my campaign because my platform included giving everyone a fair
opportunity at promotions, taking politics out of the workplace, and improving working

conditions at the middle school and high school. There was no reason to demonstrate at my

house. Ms. K and Councilwoman Licata organized demonstrations only at two members houses

(there are currently 8 members). Al Mastrofilipos house was the location of the other

demonstration. Mr. Mastrofilipo and I ran independently in the last board race against the


Paragraph 5

10. I never posted false information about fee paying members. I was a public school

Math teacher for 5 years and have a full understanding of union dues. Ms. K may be referring to

this article that I posted (Exhibit A) on May 23rd.

11. Ms. K spoke during the hearing of the citizens on May 24, 2017. She introduced herself

by saying, I am here from the NJEA. She then went on to attack me for posting Exhibit A on

my personal blog.

12. After Ms. K spoke, Principal/Mayor Emil Carafa attacked me for posting on my personal

blog. I found it inappropriate that two school employees would spend their time discussing a

personal blog instead of discussing real issues facing the district.

13. When I went to respond to the attacks, Ms. K and Mr. Carafa led the union members to

first turn their backs to me and then walk out of the room.

14. At the previous regular meeting (April 26th), I voted to remove Jonathan Carafa from the

board of education because he went four months without attending a meeting because he said he
was working. Mr. Carafa and Ms. K clearly used the union to target me one month after I

voted to remove the mayors son for chronic absenteeism.

15. I dont believe its the SECs role to investigate alleged statements about fee paying

members and union dues.

Paragraph 6

16. Lodi residents are constantly asking me why Ms. K attacks me at meetings and organizes

protests outside my house and business when I am not even on negotiations. I explain to them

that its all about politics, not negotiations. The picture of the lawn signs is just supporting

evidence. Ms. K is not only active in Lodi politics. She works very hard on behalf of the Bergen

County Democratic Organization and their candidates, whether it be for freeholder, state senate

and assembly, governor, congress, U.S. senate or president. Ms. K has disdain for me because I

am an independent and have expressed some conservative views.

Paragraph 7

17. Prior to joining the board, I had commented on the inequitable distribution of the teacher

salary guide. Starting teachers start lower than most districts and at 15 years are higher than

most. Teachers were receiving a $17,000 raise from Step 14 to Step 15. Raises were being

absorbed by teachers at the top. Ms. K complains at meetings about starting salaries as though

she isnt responsible for that.

Paragraphs 8 and 9
18. I am not on the negotiations committee for the teachers contract. I have no knowledge

of what has taken place during negotiations since I joined the board on January 4, 2017. I never

disclosed any confidential information about negotiations. I dont have that information.

19. The salaries I posted were either from the 2016-2017 school budget or 2017-2018 school

budget. The business administrator put together the budgets and the school board approved

them. They are public information. Everyone has the right to see them. Ms. K is aware of this

because multiple posts state that the figures are from the budgets and even list the budget pages.

Attached is Exhibit B.

Paragraph 10

20. I am posting accurate information on a personal blog. It is my first amendment right and

allowed by the Lodi Board of Education by-laws. I have exposed bad behavior by Ms. K in her

roles as political activist and union bully. I have not discussed anything confidential or related to

her performance as a pre-k teacher.


I am asking that Ms. K be fined for filing a frivolous complaint due to the following:

a. Ms. K is a close personal friend of Councilwoman Patricia Licata and a big political

backer of Board President Dominic Miller. All three filed frivolous ethics complaints

against me within a one month period. All three complaints were about my personal

blog. All three individuals could have filed one complaint together. Their political group
organized these complaints in an attempt to overwhelm me with paperwork, hoping that I

will ultimately resign from the board.

b. Everything Ms. K does is political in nature. She has been targeting the two new board

members because we are reforming things and demanding accountability. Her close

personal and working relationship with Lodi Mayor Emil Carafa cannot be ignored.

c. Ms. K used NJEA law firm Oxfeld to file a frivolous complaint which is more about

suppressing free speech (against the abuses of the NJEA) than it is about anything related

to the board of education or our schools. Both parties are aware that the SECs role is not

to investigate the expression, If you can read, thank a teacher. If you cant, thank a

teachers union.

d. Ms. Ks complaint against Trustee Mastrofilipo is completely baseless and only intended

to tarnish his image before the November 7, 2017 election. She even stooped as low as to

mention Mr. Mastrofilipos young children, students in the Lodi schools.


I, Ryan Curioni, of ful! age, certify as follows:

1. I am of the Lodi Board of Education and a Respondent in this matter.

2. I have read the Verified Answer to which this Verifying Certification is attached and the
responses set forth therein are true unless expressly stated as based upon information and

3. 1 ce11ify that the foregoing statements made by me are true. I am aware that if any of the
foregoing statements made by me. are willfully false, I am subject to punishment.

Dated: August 6, 2017

Lodi by the Numbers: Teachers deserve more money in their pockets. ... ...

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Lodi by the Numbers

Tuesday, May 23, 2017

Teachers deserve more money in their

pockets. Too much goes towards union

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"The New Jersey Education Association spends about 15 to 20 percent of its nearly
200,000 members' dues on political activities, such as campaign donations and
lobbying," Jedynak wrote in the letter to the Daily Record. "Hut while union
leadership may support the causes and politicians these donations benefit, not all
members may agree. This violates the First Amendment, which protects the free
speech and free association of everyone, union member or not."

"Have you ever looked at your union dues and thought it was a lot of money? Do
you wonder what you get for that amount? Are you uncomfortable supporting
certain political ideologies that your union supports? You may live in New Jersey,
but you still have options to reduce the costs associated with union membership and
be freed from supporting the union political agenda, "Jedynak wrote in the letter

1 of5 8/6/17, 7:49PM

Lodi by the Numbers: Teachers deserve more money in their pockets. ... ...

sent to teachers.

That letter also outlines how teachers can opt out of the payments, stating that
annual N.JEA membership fees amount to $840.

Link to article from August 2016:
parsippany-union-dues/8899065 61

This post is not anti-teacher in any way. Teachers should know how
much of their paycheck goes towards union dues and how that money is

When I was paying union dues, I did not approve of the lavish living of
the union big wigs.

I didn't approve of all the money going towards political candidates I

didn't support.

I didn't approve of all the money going towards causes that had nothing
to do with education.

There is a lot of discussion about employees bringing home less today

than years ago. Unions should acknowledge this and take less from it's

Posted by RC at 8:12 PM

Newer Post Home Older Post

2 of5 8/6/ 17, 7:49 PM

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Lodi Board of Education

School District Detail Budget
2016-2017 School Year

Years of
Line Description Account # Service Degree Amount$

SALARIES OF PRE-K TEACHERS 20-218-100-101-13

CARAF A, BARBARA 15 BA 15 $88,134
KWAPNIEWSKI, DEBRA 15 MA+30 15 $95,886
LEONE, GAETANA 20 BA 15 $91,334
SAMPERI, MICHELE 15 MA+30 15 $95,886
SANTOS, FRANCINE 23 MA+30 15 $99,086
Substitutes 20-218-100-101-23 $10,885

SALARIES OF PRE-K AIDES 20-218-100-106-13

Substitutes 20-218-100-106-14 $3,306

GENERAL SUPPLIES - PRE-K 20-218-100-600-13 $11,120

EMPLOYEE BENEFITS - PRE-K 20-218-200-200-00

Benefits for employees $71,065

NON-PUB. TEXTBOOKS 20-501-100-640-12 $9,999

CH: 192 TUITION COMP ED STUDENTS 20-502-100-560-00 $32,002

CH: 192 TUITION ESL STUDENTS 20-503-100-560-00 $2,200


CH: 193 TUIT EXAM & CLASS STUDENTS 20-507-100-560-00 $16,955

CH: 193 TUITION CORR SPEECH 20-508-100-560-00 $711

CH: 193 TUITION SUPP INST STUDENTS 20-506-100-560-00 $15,149