SCIARRILLO CORNELL SC Ton sremcisinlis sa June 14,2017 ‘Sent via Blectronic Malt Dominic Miller, President Lodi Board of Edation 8 Hunter Stet Lodi, New Jersey 07684 RE: LODI BOARDOF EDUCATION “Board” /“Distriet”) Board Ethles Issue Dear Mr. Miller: Pursuant to your reques, we have revised the Ethics Complaint to addres the deficiencies noted by the Commission and include the additional blog entry. Enclosed please find a copy of the revised Complaint, Please contact us with any further questions ‘Thank you, Very truly yours, SCIARRILLO, CORNELL, MERLINO, McKEEVER & OSBORNE, LLC ‘Anthpny P. Sei APS}min Enclosure SS“DOMINIGMaELER, BEFORE THE SCHOOL Complainant ETHICS COMMISSION v, OF NEW JERSEY RYAN CURIONI, : SCHOOL ETHICS ACT Respondent _ COMPLAINT. |, Dominic Miller, residing at (rome address and phone number), request the Schoo! Bthics ‘Commission to considera complaint against the above-named Respondent whosc hore uddess is home address and phone number), in accordance with the authority of the School Ethics ‘Commission to entertain such complaints under N.JS.A. 18A:12-21 et sq ‘The facts upon which this complaint i based areas follows: yun Curioai isa Board Trustee on the Lodi Board of Education. He was sworn into office 0 12nius" 7270017 12:06:20 PM RE: Lodi Board 0 Educatio/Email of Saturday, June 24, 2017 at 851 p.m, Letter o Mr. Ryan Curioni, dated 6.27.17 and aitachments. pa Me. Curioni: Auached please find Me. Searillo's correspondence dated June 27,2017 and atlchments, regarding the above “Thank you Tina Tina M. Cruikshank, Adminitrative Ass stant Sciaillo, Corel, Merlino, MeKeever & Osborne, LLC 238 St.Paul Srst | Wostild, NI 07000 (P)908.481 5000 Ext S005 | (F) 908,264 2045 ‘cnikshank@scianilolaw.ccm NOTICE: The information contained in his email and any attachments from Sciatilo, Cornel, Merino, McKeever & Osborne, LLC, may be confidential and prvieged and exempl from disclosure Under applicable law. This emails iniended forthe exclusive use of only the person or entity fo. whom itis addressed. Ifyou are not the inlonded recipient (or someone responsible for delivering this e-mail message to th intended recipient), please be aware that any use, dstbution, printing or copying of iis ema or ary attachment is stcty prohibited. I you have received this email in ero lease nolfy Sciarrilo, Corel, Merino, McKeever & Osbome, LLC immediately by return email or telephone (908-481-5000). Any U.S. federal tax advice contained inthis document (including any attachmenis) i not intended or witen to be used, and cannot be used by the recplent and any. ‘ther taxpayer, for the purpose of () avoiding penies under the internal Revenue Code, or (i) |promoting, marketing or recommending fo another party any transaction of matter addressed inthis, ‘communicationiol SCIARRILLO CORNELL June 27,2017 Mr. Ryan Curioni, Board Member Todi Board of Education 8 Hunter Street Lodi, New Jersey 07644 RE: LODI BOARD OF EDUCATION (“Board” /“Distrie”) Email of Saturday, June 24, 2017 at 8:51 pam. Dear Mr. Curioni: 11am in receipt of a copy of an email from yourself to Dominic Miller, Board President, which served asa response to Mr. Mill's email o you of Jne24, 2017 2:0 pam. In that email, you look for copies of documents that Mr. Miller and I discussed on April 28, 2017. You refer o « ‘notation in our invoice for the month of April which says a follows 28/2017 Receipt and review of emails and atechments fom D. Miller In Re: website post | apologize that the invoice notification should have road 4/28/2017 Receipt and review of emils and attachments with D. Miler In Re: website post ‘You further state that you do not believe an attachment sen to Mr. Mastrofilipo about mediation had anything todo with that invoice. That isincorect, Thats one of several emails, attachments and website pages that Mr. Miller and l poke about on that date. ‘You go further in your email to Mr. Miller... as a ustee,Thave aright to ths information without an OPRA request... 1 will not debate with you in this corespondence aso whether or net you have a right to that information, However, attached you will find copies of the documeys siscussed with Mr. Miller on that dete. 1. A copy of an email dated Monday, April 24, 2017 regarding a matter involving +8 former employee ofthe School Distt; 2g, NCBPY of comrespondence dated April 24, 2017 regarding mediation between my office and Mr. Alfonso Mastrofiipo, entitled Mediation; Lodi Board of Education and Lady Education Association” aw er Pat ara P40, Ro 481 S000 | TAX (oemjRocaage | WWWRCIARIIIIAIN pope amnsaies3. An email dated Tuesday, April 24, 2017 from Dennis Grieco requesting cetain information with respect to negotiations with the Lodi Education Assocation: 4. An email dated Tuesday, April 25, 2017 from Alfonso Mastroflipo, regarding contract disputes; 5. A website page entitled “Lodi by the Numbers” dted Wednesday, Apel 26, 2017, entitled "No Attendance, No Fthies 6.___Awebsite pagecntitied “Lodi by the Numbers” dated Wednesday, April 26,2017, éntled “Dominic Miller Secretly Negotiated Mare Capizzi's New Contact ~ No Transpreney"s 7,__A website pageentitled “Lodi by the Numbers” dated Wednesday, April 26,2017, ‘ntted “The Board Attomey Wasn't Scheduled for Tonight's Meeting”: 8. A website page entitled “Lodi by the Numbers” dated Thursday, April 27, 2017, with a tile of “Mare Capizzi had no Right to Stop my Referendum Motion ‘on Monday Night"; ‘A website page entitled “Lodi by the Numbers” dated Thursday, Apeil 27, 2017, ‘entitled “The Legal Opinion Was Based on “Esteves vs, Board of Education of Keamy’ ". 10, A website page entitled “Lodi by the Numbers” dated Thursday, April 27, 2017, ‘entitled “All Brown-Nosing, Ne Substance”; U1, A website page ented “Loui by the Numbers” dated Thursday, April 27,2017, entitled “Shuting Out. Literally”. 12, A website page entitled “Lodi by the Numbers” dated Thursday, April 27,2017, entitled “Four Board Members Took Away Yout Right to Vote Apain", ‘Thank you. Very rly yours, ‘SCIARRILLO, CORNELL, MERLINO, McKEEVER & OSBORNE, LLC Antford SseraTo Alframe cc: Frank A. Quatrone, Superitendent of Schools (via electronic mail) Mare Capiz, Business Administator/Board Secretary (via electronic mail) ‘Dominie Miller, Board President (via electronic mail) Alisa DiChiara, Esq, BoaréAttomey (vi electronic mil) assessessco Losoy natn: No mines tin Lodi by the Numbers Wednesay, apt 26,2017 No attendance, no ethics. vst ur by-laws state that a Board member can be removed if sy ar th they miss three consecutive meetings. In 2016, Trustee ee Carafa went four whole months without atlending any een ae, meetings. He missed 7 out of 16 meetings. He missed eee ‘numerous meetings in 2017. Ife missel Monday's ‘mecting. The rest of us had to sit there until | in the Ree morning. : {made the motion o remove Carafa tonight. It wasn't Dashes ae personal. it was policy. | respect and lke most of his ‘ay il relatives that work in our schools. ‘ovinBonn Before we voted, | pointed out that Mike Nardino should ol recuse himself because he absiained on issues with Carafa ara in the past being he isa cousin. He presented his conflict» 2s hhimselE. T pointed out that Dominic Miler should yeeuse 5 aes) hhimseif because Emil Carafa is technically his boss and seac promoted him last year. Emil Carafa actually passed an anc ‘ordinance changing the table of command just so Miller can be promoted, topstaoweed eppctcon 90 anc oan ww‘Tonight four Board members ignored our by-laws, isregarded attendance, and voted to kecp Carafa. ‘Carafe voted to keep himself: VERY UNETHICAL. Nardino voted Lo keep his eousin- VERY UNETHICAL ‘Mitior voted to keep bis boss" son- VERY UNETHICAL ‘Carbonetti voted to keep Carafs, Emil Carafe is the principal of Washington school. Who works there? Single ene owed yi asada sat oT sca ois ateso amo tr sy mar Ci on coc: NOTRINSPNRENEY Lodi by the Numbers Wess, Dominic Miller secretly negotiated Mare Capizzi’s new contract- NO TRANSPARENCY. 4 sincerity 8 dort corre yong tru eres oar 5 Forth Board “President” Dominic Miller secretly chose himselt (onegotiate Mare Capiz7’s new contract, re secretly met with Mr, Capizei to “negotiate” a new contact He lied about it when questioned at Monday's work {was never informed ofthe committe. 1 was never informed of the meeting, re He no exes baa testo i once ype ek Blog Acne lpn al Meco i ey stile orysb te hme Castanea yee mn oy ih since joining the Board. Nobody was caught off guard. 1 wanted the vote before the budget was passed, Mare Capiz had no right to obstruct a vote from taking place, He took away our right to vote on Monday. He took away: your right to vote in Novernber. Sins fost as Molininana econ 2070 nae pets met tmpedb lar: Tho Ay recht ig ag, Lodi by the Numbers Wedneas, Ape 26 2017 The Board Attorney wasn’t scheduled for tonight’s meeting. con-flist of in-ter-est W appears thatthe Board Attorney attended tonight's _meeting justo say that every trustee can vote on the CCarafa issue, even Carafa himself ow can a board attomey say that itis alright for Carafa to vote on a mater directly affecting himsel(? Isu't Carafa toonvaon Las nora Mec ips rot ea my rere taney 1 te tate catty te Lodi by the Numbers Thar Apt 92017 eeaanie Mare Capizzi had no right to stop my or referendum motion on Monday night. septate “eotmowese toon eee ee Cpaiadguie ea secs ‘sion te rae made @ motion on Monday night to place the referendum aon question on the November 7" ball. ene 1 as more than lear on what my motion sought. We ee voted fora referendum on January 4. { made the motion veda to sete referendum date- Novernber 7 gna, ‘The votes were there on Monday to piss the motion, oe Jonathan Carafa was absent. He docs atend work maecial sessions. Mike Nardin left early. ee Mare Capize saw two empty chars and asked us to pot Ree ‘ofthe vote ull Wednesday so he er daw up a temo fetluion a {gave hm te cosy a > imo | shouldn't have wos Imad the mation on Monday. A votesbould have ben > taken on Monday” I rough tp tense evry month mem opted gt anon mecca gt sp mye a{tb ie Monbow Thee perv bnen"xe BtEetR Lodi by the Numbers rorday Apel 27,2017 The legal opinion was based on “Esteves vs Bd of Ed of Kearny”? Jonathan Carafa voted against his removal from the bbostd. Most were shocked that he didn’t recuse himself. ‘The board attorney cited the ease “Fsteves vs Bd of Ed of ‘Keamy” to support the claim that Carafa can vote on the matter. Isthis the case? up: Awwv.nj gov/edueation legal commissioner 2016 epr H4i-Lopar Please read it. Daniel Esteves was removed by the Kearny Board of the Fiducation. The ALJ dismissed his challenge and justified his removal Nook pantie pine ene mat on Ate mtascamscnsag ‘shackle incall > de 08Lodi by the Numbers “haan Ap 2007 Bg hee All brown-nosing, no substance. vt nanan ale suck-vP! Don't he flatered, Dominic Miller kisses up to everyone that he invites to attend mectings. > mwas > wa ode Bent aude cat 2wom Losiy tenon Suge pecs sry Lodi by the Numbers huey Ape 27, 207 Blo hei Shutting the public out... literally. Fin ed ele inate Seige mpalen Twomin net yar sean § received numerous ema, text messages, and phone tain tai calls from cancemed Lodi residents that could not enter the public meeting lastnight after 7 pam. The room was filled to capccity and they coulda’t even enter the door. Afar clearly existed sigh, Dominic Mileris = mln Spots ofer, Heshoulghave town ster Thewwas ee, ‘hen dy pis eee pesent hws por odgemont Tt and eekesto hoa pubic meng in Sutton eee ‘Ther is mo pasono conduct public meetings in a small, socaloate Sttfy oom ft coud hardy ftanyone Thee clone Sst ‘meeting spaces available all throughout own- from the borough hall to every school. The Lodi potticians prefer to mect in small, stuffy rooms. reat They don’t want public participation, especially from Lodi» rb residents. As you know, they have pienty to hide. > ts 28 uyse ty Minbes Fb emt ck ey pa AN, Lodi by the Numbers herd Api, 207 poe eect Four board members took away your right "+ aww to vote AGAIN. eee “iughono nema Mecca nda Aen ay ae ‘sa bo ‘int iin Mier “Spas ‘se re Las nigh, four Board members ook ay your ight 10 sree ‘ote mNovember on whether orn! 38M Lo ix dollars Sten Should be spent ncedeslyon a new admiistaon paiement tailing ae Those members “ante hemes Domine Biller ncn ere Sonathan Carafe Phi Carbone tee “Sarai ct Nardino sn + stn ‘The Board budgeted over $7M tonight forthe bm istration Building. That money cin only be spent ony anaaay siding and nothing cle eee > 9) Lodi shouldbe outraged, > mnie woos eon a an nny in wecomo dy ears amet Ya AGA, Once ag n, motives must be questioned. Someone is controlling their votes. ‘Thing are being orchestrated behind the public’ bask Slee Freee ease tanh a mes ak ea