For Agency Use Only Docket Number: ___________

Patricia DelGiudice, Board President, Hamilton Township Board of Education Mercer County, New Jersey Complainant vs. Jeffrey Hewitson, Hamilton Township Board of Education Mercer County, New Jersey Respondent

BEFORE THE SCHOOL ETHICS COMMISSION OF NEW JERSEY

SCHOOL ETHICS ACT COMPLAINT FORM

I, Patricia DelGuidice, residing at 4 Connor Court, Hamilton, New Jersey 08691, request the School Ethics Commission to consider a Complaint against the above-named Respondent whose home address is 33 Sedona Boulevard, Hamilton, New Jersey 08690, 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 follows: facts upon which this Complaint is based are as

1. Statement of Facts: Board member Jeffrey Hewitson as a member of the Superintendent Search Committee breached the confidentiality of not only himself but of other Board members by disseminating the names of the two finalists. New Jersey.com and the Trenton Times printed articles prior to the June 9, 2011 School Board meeting naming the Districts two finalists for the Superintendents position. Mr. Hewitson is quoted in both articles indicating that Barbara Frascella and Lou Goldstein were the two finalists and that Lou Goldstein was poised to become the successor to retiring Hamilton Superintendent Neil Bencivengo. This violation breached the confidentiality of the Superintendent Search Committee at which time all members were told and advised in numerous emails from Superintendent Search Committee Chair Person, Patricia DelGuidice that this procedure is confidential and privacy must be maintained to the utmost. Date of occurrence: June 2011 I assert this to be a violation of N.J.S.A. 18A:12-24.1(g)

For Agency Use Only Docket Number: ___________

2. Board member Jeffrey Hewitson removed confidential material from the Board Solicitors office without proper authority. On March 18, 2011 Jeffrey Hewitson as a member of the Hamilton Township Board of Education and Anthony Celentano, a Hamilton Township School District employee, presented themselves at Destribates & Campbell. Mr. Hewitson requested information pertaining to two candidates for Superintendent. Mr. Hewitson retrieved the information and reviewed the information and at that point requested from the Board Solicitor a copy of documents as he was on his way out of town. The Solicitor advised Mr. Hewitson that he was not going to disclose any of the information or resumes with anyone and he was further advised he was not to copy the documents. Mr. Hewitson indicated to the solicitor that he had the authority to receive the copies and at that time the Solicitor complied with Mr. Hewitsons request and presented him with copies of the candidates resumes. On Saturday, March 19, 2011 the Board Solicitor spoke with Vice President Patricia DelGuidice who was the Chair of Superintendents Search Committee who informed the Solicitor that Mr. Hewitson was only approved to review the documents in private and was not to remove any of the documents. Shortly thereafter Mr. Hewitson appeared at the Solicitors office and told him he did not release any of the information to anyone and then returned the documents. This is in violation of Breech of confidentiality again by Mr. Hewitson with regard to the Superintendent search. Date of Occurrence: March 2011 I assert this to be a violation of N.J.S.A. 18A:12-24.1(g) 3. Statement of facts: Jeffery Hewitson and Anthony Celentano advised me that in June 2011 that if I did not vote for the internal candidate for superintendent he would be filing an Ethics Complaint against me with regard to my role as Chairperson of the Superintendent Search Committee. This threat was proven correct by the June 8, 2011 article in NJ.com where Mr. Hewitson indicates that he was filing an Ethics Complaint against Patricia DelGuidice, Chairperson of the Superintendent Search Committee. This article appeared on June 8, 2011 one day prior to the June 9, 2011 Board meeting in which the Board of Education had placed on the Agenda the appointment of Lou

For Agency Use Only Docket Number: ___________

Goldstein as Superintendent for the Hamilton Township School District. This article in the newspaper one day prior to the appointment of Lou Goldstein was done in a malicious and inappropriate manner to impugn my integrity and tarnish the process of the District naming Lou Goldstein as Superintendent. Date of occurrence: June 2011 I assert this to be a violation of N.J.S.A. 18A:12-24.1(f)(g) 4. Statement of Facts: On or about March 2011 Jeffrey Hewitson scheduled a meeting with Vince McKelvy, the president of the Hibernians, as well as Tony Celentano to discuss the upcoming election. I was confronted by Mr. McKelvy with the names of the candidates for the Hamilton Township Board of Education Superintendents position. This is a complete violation of the Breach of Confidentiality in that Mr. Hewitson was disseminating the names of the individuals who applied for the position to become Hamilton Township Board of Education Superintendent. Date of occurrence: March/April 2011 I assert this to be a violation of N.J.S.A. 18A:12-24.1(g) 5. Statement of Facts: On or about August 11, 2010 Hamilton Township School Board member Jeffrey Hewitson voted for a contract for the Mercer County Arc. Mr. Hewitson is a Trustee at Mercer County Arc and therefore violated N.J.S.A. 18A:12-24(c) wherein he has acted in his official capacity in a matter where he has a personal involvement that creates some benefit to himself as a Board of Trustee member for Arc. Date of occurrence: August 2010 I assert this to be a violation of N.J.S.A. 18A:12-24.1 WHEREFORE, I, as Complainant, request that the School Ethics Commission find and determine that the above-named Respondent has violated the School Ethics Act and that he be subject to such penalty as provided by the Act.

Date: __________________

_____________________________ Signature of Complainant Or her Attorney

For Agency Use Only Docket Number: ___________

CERTIFICATION UNDER OATH

Patricia DelGuidice, of full age, being duly sworn upon 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 true 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 allegations. 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.

____________________________ Signature of Complainant Date: ______________

Sworn and subscribed to before me this _____ day of ____________ Notice: All final decisions issued in connection with complaints that come before the School Ethics Commission for review and determination are public records uniformly posted on the Department of Educations website at http://www.nj.gov/education/legal. As a general rule, selective requests to remove a particular decision for reasons of personal preference are not entertained.