February 1, 2021

Mr. Robert Ainslie

President
Ithaca City School District Board of Education
Via email: robert.ainslie@icsd.k12.ny.us

Dear Mr. Ainslie:

We are writing today as a committed group of Ithaca City School District parents and family
members, residents, taxpayers, and business and community leaders who are extremely
concerned, frustrated and upset about several developments in recent weeks related both to
the employment status of Dr. Luvelle Brown, ICSD superintendent, and the Board of Education’s
conduct on recent matters connected to Dr. Brown’s employment status.

On Jan. 12, 2021, Dr. Brown publicly announced that he had accepted a new position
elsewhere, and would be departing his superintendent position as of today (Feb. 1, 2021). Yet,
just two weeks later, in the middle of a Board of Education (BOE) meeting on Jan. 26, Dr. Brown
surprised attendees by announcing that he was not resigning after all.

Within 24 hours of his initial Jan. 12 announcement, the Ithaca Voice and other local
publications reported on some extremely problematic allegations that had arisen mainly from a
child custody dispute between Dr. Brown and his former partner, Ms. Anjanette Brown. In a
Jan. 5 letter to New York State’s Interim Commissioner of Education, three of Ms. Brown’s
advocates (Peyi Soyinka-Airewele, Mojubaolu Okome, and Hafsat Abiola) provided a lengthy
and extraordinarily detailed list of actions that Dr. Brown was alleged to have taken during an
ongoing custody battle with his former partner.

We agree that certain details of Dr. Brown’s divorce proceedings and custody battle are private
and should remain so to protect the privacy of all involved; however, many of these alleged
incidents involve abuse of power and lack of accountability, and are a matter of public concern
due to their impact on the district as a whole.

Some of these many allegations include the following troublesome examples:

1. The hiring in 2015 of Erica Kueffer — who until her hiring by the ICSD had been serving
as a paralegal and office manager for the Children’s Law Guardian, a position that is
intended to serve as an unbiased and neutral party in this type of custody dispute — as
 Dr. Brown’s administrative assistant.

a. Worse, there were even more disturbing allegations of an improper personal

relationship between Dr. Brown and Ms. Kueffer. Ms. Kueffer herself apparently
admitted to this relationship under oath, also admitting that this relationship
was already occurring at the time of her hire, and continued for some time
thereafter.

b. The Jan. 5 letter alleges that the ICSD Board of Education (BOE) specifically
approved this hiring action on June 23, 2015. Furthermore, this same letter
alleges that you (Mr. Ainslie) denied any knowledge or memory of any of these
actions or the circumstances under which they occurred.

2. The Jan. 5 letter details a disturbing alleged incident of aggressive, bullying behavior
and possible knowingly false statements made by Kate Reid in her capacity as ICSD
general counsel, a position whose salary — like Dr. Brown’s — is funded by this
community’s taxpayer dollars.

a. The letter states: “Ms. Brown has provided documentation of Kate Reid, the ICSD
attorney, informing her that she had no rights to her children’s school records,
and insisting that she (attorney Reid) was representing the district in making
such a stipulation. After Ms. Brown, through her attorney, challenged this absurd
statement by point of law, Ms. Reid then backed down and acknowledged that
Ms. Brown had a right to have her children’s school records sent to her directly
and withdrew her initial absurd claim.”

3. The Jan. 5 complaint letter details numerous examples of Dr. Brown allegedly abusing
his position of power and utilizing school resources (human, financial and/or
otherwise) to benefit him personally in the custody battle against the mother of his
children. A few examples:

a. That letter alleges that “the superintendent compelled teachers to let him into
the children’s physical classrooms, again in defiance of the court order, that
sought to allow the children to study, like other students, without the emotional
and psychological distress they were experiencing.”

b. The letter further alleges that Dr. Brown specifically directed ICSD teachers to set
up FaceTime calls with his daughter during the school day using the teacher’s
personal cell phone. If this is true, it would be in violation of ICSD policies

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 regarding the use of cell phones during school hours.

c. Similarly, he is alleged to have asked staff to use school resources to create

“fake” Google classrooms in the ICSD digital environment that, again, if true
would be a violation of ICSD policy regarding the use of computer/digital
resources.

4. During the Jan. 26 BOE meeting, held virtually via Zoom, there were credible reports by
multiple witnesses who stated that certain members of the Board of Education have,
on multiple occasions, deliberately and directly silenced the voices of their own BOE
student representatives. In addition, you (Mr. Ainslie) have falsely maintained that
these allegations were merely a “family matter” which had nothing to do with the ICSD
or Dr. Brown’s professional work.

a. In the video footage from that Jan. 26 meeting, evidence of this behavior can be
seen in the following segments: 10:28–21:45 and again from 1:09:17 through the
end of the meeting. Several times, the student representatives interjected,
requesting that these very serious allegations be discussed, but were told that
the topic would be covered in the next portion of the meeting, but they were
not. One of those student reps said later that “we were completely ignored and
dismissed.”

b. Especially concerning is what occurred later in the meeting, when BOE member
Erin Croyle brought up the issue for the third time, asking that these students’
concerns finally be addressed. Mr. Ainslie responded that he had conducted an
investigation by sending the allegations to the school district’s attorney, who
concluded that the allegations were ‘entirely unfounded’.” By all accounts, the
attorney performing this “investigation” was Kate Reid — the same attorney
who was accused of being directly involved in this alleged unethical behavior in
the Jan. 5 complaint. (See item #2, above.) In addition, you (Mr. Ainslie) stated
that “there was nothing there that was going to impact the district.” This is false.
There is, in fact, quite a clearly defined conflict of interest, and it is entirely
unacceptable.

c. During that meeting, you (Mr. Ainslie) told the students “not to believe
everything you see on social media,” which was puzzling since the topic of social
media had not even been mentioned up until that point in the conversation. You
can see Mr. Ainslie’s statement to that effect in the video footage (1:11:18–end).

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 Mr. Ainslie’s dismissive tone has led many in the community to question
whether he and the board truly respect students and value their opinions.

Many parents have voiced similar complaints about their children signing up to be
BOE representatives in the past, only to be treated in the same condescending,
dismissive manner by you (Mr. Ainslie) and certain other BOE members. Is this how
you set an example for our young leaders of tomorrow? By excluding them from actual
decision making, and then demeaning and sidelining them when they object?

5. In the same Jan. 26 BOE meeting described in #4 above, Dr. Luvelle Brown announced
that he would not be resigning from his superintendent position after all, despite his
earlier announcement just two weeks prior on Jan. 12.

a. None of Dr. Brown’s public statements nor any official BOE statement contained
any specifics about the reasons for his departure in the middle of a school year;
zero acknowledgement of whether his departure was related even in part to the
damning allegations listed in the Jan. 5 complaint letter, which had just become
widely circulated in the local community; and very little detail regarding how the
ICSD BOE planned to fill the suddenly vacant superintendent position, other than
a vague statement indicating that deputy superintendent Lily Talcott would likely
fill that role on an interim basis.

b. In Dr. Brown’s Jan. 26 remarks during the BOE virtual meeting, which occurred
about 26 minutes into the meeting, and which shocked many of those in
attendance, he once again made no reference to the reason(s) for his sudden
change of heart, nor did he acknowledge any connection to allegations listed in
the Jan. 5 complaint that are connected to Dr. Brown’s professional conduct (and
not just his family custody dispute).

c. Furthermore, immediately following Dr. Brown’s reversal, you (Mr. Ainslie)

provided the extremely dubious — if not downright absurd — excuse that Dr.
Brown’s resignation was never technically finalized because he had not
delivered a written, formal resignation letter to you in your role of board
president, in accordance with the terms of his employment contract.

To put it mildly, this utter lack of transparency and public accountability, combined with a
pattern of non-response to repeated questions from the community surrounding Dr. Brown’s
resignation and sudden reinstatement, point to a troubling, consistent pattern conduct by
you (Mr. Ainslie), by several of your Board of Education colleagues, and by Dr. Luvelle

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Brown — all of which raises serious ethical questions about this board’s collective conduct.

The allegations described above would be concerning enough if they were being reported as
isolated incidents. Yet, over and over again, we are hearing from parents, teachers, staff and
others who have experienced similar misconduct, a similar silencing of dissent, and even
retaliation by Dr. Brown and certain BOE members. The Jan. 5 complaint letter summarized it
best:

“There is a sense of fear and anxiety in the community about speaking out against Dr.
Brown. Indeed, most community members who contributed to a GofundMe supporting
Ms. Brown’s legal needs felt compelled to do so anonymously, with private notes
explaining their fear of retaliation. Over the past few years, several lawyers have
expressed similar reservations. This should not be so.”

Again, if these allegations are true, they constitute severe and repeated violations of the
Board’s duty to the citizens of their community, the citizens who elected them to serve our
community’s best interests. To claim otherwise can only be seen as disingenuous and facetious.

As I am sure you know, the code of conduct of the New York State School Board Association
(NYSSBA) states in part that, by serving as an elected representative of their local community,
all school board members:

● “agree to honor our positions and the people who elected us by maintaining high ethical
standards and by not engaging in any activity which presents a conflict of interest, or an
appearance of impropriety”;

● “strive to procure, when the vacancy exists, the employment of a superintendent who is
best qualified for the job and who represents the interests of our communities”; and

● “strive step by step toward ideal conditions for most effective school board service to
our communities, in the spirit of teamwork and devotion to public education in a
manner which serves as a role model to our students and which demonstrates that
school board service is the greatest instrument for preservation and perpetuation of our
representative democracy.”

In addition, NYSSBA’s Model Code of Ethics states in part that all school board members:
● have a duty to “communicate and interact in a civil and professional manner with fellow
board members, the superintendent and district stakeholders with the aim of serving as

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 role models for all students”; and

● “should not engage in any personal or commercial activity which presents a conflict of
interest or an appearance of impropriety which would bring discredit upon the school
district, its staff and/or its students.”

Given the incidents documented above, in the linked materials, and elsewhere, we — as
parents and/or taxpaying residents of the Ithaca City School District whom you are legally
obligated to serve — demand the following actions to be taken immediately by the ICSD
Board of Education:

1) We demand an immediate and full investigation by a third party, one with the
required expertise and experience, into these matters involving Dr. Brown and the
Board of Ed. The board, intentionally or otherwise, has completely abandoned even the
most basic principles regarding conflict of interest, public transparency, and ethical
behavior. You and the BOE have demonstrated a complete lack of either willingness or
initiative, and have thus lost all credibility in the matters described above. Your
attempts to “explain away” these extremely dubious actions, and then take aggressive,
retaliatory actions against those who have rightfully questioned those decisions and
actions, further demonstrate your lack of integrity.

2) We demand the immediate and permanent termination of any current or ongoing

professional service agreement between the ICSD and attorney Kate Reid. Any
attorney who made it past their first year of law school should understand the
inappropriate nature of the conflict of interest described in item #4b above — and
should understand that even the appearance of such impropriety is still considered to
be a violation of NYSSBA’s ethical standards and professional code of conduct.

3) We demand a full, detailed, and immediate public explanation from Dr. Luvelle Brown
and Mr. Robert Ainslie into the circumstances surrounding Dr. Brown’s sudden
resignation in early January 2021, followed 14 days later by an equally sudden change
of heart. At the very least, we are owed a full explanation of this series of events,
especially given that this is not the first time that Dr. Brown has threatened to go
elsewhere, only to be lured back by the possibility of a more lucrative compensation
package. As you know, Dr. Brown is one of the most highly-paid superintendents in New
York State; given this fact, the Board of Education must fulfill its fiduciary role in
ensuring that taxpayer dollars are not being mismanaged due to inept or unwise
personnel decisions.

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We acknowledge that Dr. Brown has made positive contributions to the ICSD and the greater
Ithaca community in his role; however, the allegations and complaints against him are so
numerous, so serious in nature, and so troubling that it is no longer possible for Dr. Luvelle
Brown to continue serving as a credibly effective superintendent — or to serve in any official
capacity within the school district — until these allegations are fully investigated and cleared
by an independent third party, and made fully public as expeditiously as possible.

In order for the community to move forward with confidence in the leadership of our school
district we demand transparency into the process around investigating these allegations,
many of which, as noted, are not simply related to personal family matters. It is not
acceptable to just tell the community that the issue has been investigated and to move on;
for us to have trust, the Board of Education’s communication around this process must be
timely, open, and transparent.

In sum: your actions in these matters are unprofessional, unacceptable, and an unexpected
embarrassment to us, our children, and our entire community. We are calling upon you to
meet our demands listed above, as our children’s educational success depends directly on
your leadership. If you are not able or willing to meet these responsibilities with integrity and
transparency, then we have no choice but to demand your immediate resignation as
president of the Ithaca City School District’s Board of Education.

We look forward to your prompt written response, which we respectfully request to receive by
Monday, February 8, 2021 at 5:00 p.m.

A lack of response, or a response that is lacking in full detail, is not acceptable and will result in
the subsequent filing of a formal complaint with the New York State Department of Education.

Sincerely,
The Following Parents and Community Members (listed in alphabetical order):

Sarah Alabi Mirit Bessire Edna Brown

Janelle Alvstad-Mattson Breton Bienvenue Erin Buchanan
Florencia Ardon Jennifer Lawrence Darlene Campbell
Aimee Bacon Birnbaum Lucía Cárdenas-Aceves
Laurel Beard Hillary Boucher Farr Carey
Mary Beer Rebecca Bowes Bruce Carter
Sasha Beram Kelly Boyko Kathryn Cernera
Elizabeth Bergman Rachel Brill Rodney Chinn
Brian Bessire Anjanette Brown Didier Chinn-Ardon

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Margot Chiuten Jamie Lykins Jett Brian Rahm
Michelle Ciaschi Tim Jett Armando Suarez Romero
Justin Coffman Jenna Kain Gretchen Ryan
Gina Cusano-McLaughlin Meghan Kennedy Adam Saar
Betty Davis Summer Killian Gideon Saar
Maria DiFrancesco Jodessia Krager Yael Daphna Saar
Kathryn Dimpfl Cheryl Kramer Barbara Schmitt
Laura Dolch Mark Lawrence Christopher Scofield
Angela Jensen Ehmke Sophia Lux Elizabeth Scofield
Helen Dyess English Sue Mann Jonathan Shaw
Kelly Evans Jeff Marion Maya Soto
Christine Finnigan Melissa Marion Dirk Swart
Dawn Forman Lyza Maron Ellice Switzer
Allen Foster Neil Mattson Joel Switzer
Theresa Fraser Kristin McCarthy Verne Thalheimer
Russell Friedell April Mendez Leticia Thomson
Nancy Fuchs Jason Mendez Scott Thomson
Gina Gaffney-Foster Lynne Merchant-Pryor Robin Ridley Tilling
Mimi Goldman Shawnae Milton Lisa Trent
Elena Goloborodko Sue Haas Mueller Rebecca Utz
Greg Goodrich Breelan Nash Melissa Vanderhoof
Tracy Goodrich Carrie Nolan Eric Wiessinger
Rachel Graham Kristie O’Connor Kasey Wiessinger
Hardy Griffin Leah O’Connor Ernest Williams
Mary Hause Yxi Ojeda Katie Williams
Shari Haldeman Tara O’Malley Laurie Williams
Thomas Herman Suzette Pabit Emily Workman
Melissa Hoffman Sarah Pallor Simon Workman
Rebecca Holland Denise Park Ayami Yamaguchi
Alita Trouble Howard Laurie Pattington Lillian Yavits
Adam Jacobstein Christopher Pollock
Raadha Jacobstein Danielle Prince

CC: Tricia Beresford, ICSD District Clerk

Dr. Luvelle Brown, ICSD Superintendent
Dr. Sean Eversley Bradwell, Vice President, ICSD Board of Education
Erin Croyle, Member, ICSD Board of Education

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Eldred V. Harris, JD, Member, ICSD Board of Education
Nicole LaFave, Member, ICSD Board of Education
Moira Lang, Member, ICSD Board of Education
Christopher A. Malcolm, Member, ICSD Board of Education
Svante Myrick, Mayor, City of Ithaca
Ann Reichlin, Member, ICSD Board of Education
Kate Reid, attorney
Lily Talcott, Deputy ICSD Superintendent
Dr. Patricia Wasyliw, Member, ICSD Board of Education