Letter to #LCPS School Board and Administration about Administrative Fraud and Collusion with Private Counsel Involving Nick Cottone and Troxel Leigh

 I will be sending this updated formal complaint to LCPS on January 12, 2026. . . 

TO: LCPS Superintendent and School Board

FROM: Steven Rubis

DATE: January 12, 2026

SUBJECT: Formal Complaint of Administrative Fraud, Collusion with Private Counsel, and Retaliatory Subversion of IEP/504 Rights

I. THE FOUNDATIONAL FRAUD (Principal Nick Cottone) Evidence enclosed (Exhibits A and B) proves that Principal Nick Cottone knowingly submitted a False Official Statement to LCPS leadership on October 13, 2023. This is a direct violation of LCPS Policy 8030 (Employee Conduct), which mandates honesty and integrity. This fraud was used to facilitate unauthorized legal coordination with the private law firm Troxell Leigh P.C. and the weaponization of a School Resource Officer (SRO) to harass me while I was 700 miles away (Exhibit D). Such actions constitute an Abuse of Process and a violation of the SRO Memorandum of Understanding (MOU), which prohibits the use of law enforcement for administrative or private civil matters.

II. UNAUTHORIZED COLLUSION WITH PRIVATE COUNSEL (Troxell Leigh P.C.) Principal Cottone and SRO Deputy Iversen engaged in direct coordination with the private law firm Troxell Leigh P.C. on or around October 24, 2023. This collusion was legally invalid and constitutes a breach of the Virginia Government Data Collection and Dissemination Practices Act (Va. Code § 2.2-3800), which protects against the unauthorized disclosure of parental records to third parties.

• Abuse of Police Power: The 700-mile retaliatory phone call (Exhibit G) initiated without a criminal predicate violates Loudoun County Sheriff’s Office General Orders and constitutes Retaliation under the First Amendment, as it was a "show of force" intended to silence my VFOIA advocacy.
• Conflict of Interest: Cottone allowed a private law firm to influence school actions, violating Va. Code § 2.2-3103 (State and Local Government Conflict of Interests Act).
• Absence of Legal Grounds: At the time of this coordination (Oct 24, 2023), no legal action had been filed by Lindsay Mohler or Troxell Leigh P.C. against me. Principal Cottone and SRO Iversen were engaging with a private firm to build a case and initiate a police "show of force" (Exhibit G) prior to the existence of any active litigation. This proves the school administration, including LCPS and LCSO employees, was acting as an investigative arm for a private entity to manufacture a legal conflict, rather than responding to a court-ordered mandate.

III. CIVIL RIGHTS SUBVERSION (Dr. Puschak/Ridgeway) Dr. Puschak (Ridgeway) has willfully bypassed prior corrective actions by SPED Supervisor Chrystal Thompson (Exhibit I). By intentionally appointing a Case Manager previously identified as a source of exclusion, Dr. Puschak has engaged in Retaliation under Section 504 of the Rehabilitation Act and a denial of Free Appropriate Public Education (FAPE) under the Individuals with Disabilities Education Act (IDEA). This constitutes Predetermination, a violation of federal law that strips a parent of their right to meaningful participation in the IEP process.

IV. SYSTEMIC OBSTRUCTION (Dan Adams/FOIA) FOIA Officer Dan Adams has engaged in targeted records suppression to shield Principal Cottone from accountability. Most notably:

• Bad-Faith "No Records" Responses: Mr. Adams issued a "No Records Found" response for documents LCPS previously produced in 2024 (Exhibit L), a physical impossibility that suggests a "sanitization" of the current administrative file.
• Unilateral Evidence Withholding: Regarding Request R002438-121125, Mr. Adams has unilaterally withheld a singular, high-value email between Principal Cottone and private attorney Lindsay Mohler (Troxell Leigh P.C.).
• Invalid Privilege Claims: Mr. Adams is asserting "Attorney Work Product" over a communication with a private third-party law firm. As Troxell Leigh P.C. does not represent LCPS, and LCPS is not a party to the underlying civil litigation, this privilege is legally non-existent. This is a deliberate attempt to obstruct my access to proof of the "Shadow Administration" and the origins of the retaliatory 12/12/23 SRO activation.

FORMAL DEMANDS FOR IMMEDIATE REMEDY:

1. IMMEDIATE TERMINATION of Nick Cottone: Pursuant to LCPS Policy 8030, for documented fraud and record suppression.
2. ADMINISTRATIVE PLACEMENT: To ensure safety and compliance with IDEA/504 anti-retaliation provisions.
3. EXPUNGEMENT OF RECORDS: Removal of falsified 12/12/25 safety records to correct the student's educational record under FERPA (34 CFR § 99.20).
4. ADMINISTRATIVE REMOVAL: Immediate removal of Dr. Puschak and Mara Moreland for documented Conflict of Interest.

SECTION 1: THE FRAUD & EXECUTIVE SUMMARY

• Executive Summary: Analysis of the "Shadow Administration."
• Anatomy of a Lie: Side-by-Side Comparison (EXHIBIT A vs EXHIBIT B).
• EXHIBIT A: The 18-Page Email Cache (VFOIA R001605-042624).
• EXHIBIT B: The Oct 13, 2023 False Official Statement (Cottone's Denial).
• EXHIBIT C: April 2024 Subpoena Proof of Service.

SECTION 2: POLICE MISUSE & COLLUSION

STATEMENT REGARDING EXTRINSIC FRAUD & MANUFACTURED LITIGATION

The records in this section document a "Litigation Ruse" perpetrated by LCPS Principal Nick Cottone and private counsel Lindsay Mohler/Troxell Leigh P.C. in late 2023.

1. Manufacturing the Narrative: On October 24, 2023—prior to any formal legal filing—Principal Cottone coordinated with private counsel to utilize a School Resource Officer (SRO) as a tactical asset.
2. The Resulting Ruse: This coordination resulted in the 12/12/23 SRO activation (Exhibit G), where a police officer was directed to "warn" a parent located 700 miles away despite an admitted lack of any criminal predicate.
3. The Impact: These manufactured "safety concerns" were utilized in 2024 proceedings to damage the father's credibility.
4. The Fraud: The foundational "independence" of the school administration was a fiction. As proven by Exhibit A and B, the Principal was an active partner of the opposing party while representing himself to the District and the Court as a neutral third party.

• EXHIBIT D: Notice of Collusion with Troxell Leigh P.C.
• EXHIBIT E: LCSO Discovery Notice (VFOIA request for coordination logs).
• EXHIBIT F: Proof of Out-of-State Residency (Chicago, IL).
• EXHIBIT G: SRO Deputy Iversen Transcript (The 700-mile phone call).
• EXHIBIT H: Email between Cottone and Ex wife where Cottone offers help, which occurred same day that Troxel Leigh spoke with Deputy Iversen

SECTION 3: RETALIATION & IEP SUBVERSION

• EXHIBIT I: Formal Demand for Removal Letter (to Tedra Richardson).
• EXHIBIT J: May 2024 Email Chain (Prior intervention by Chrystal Thompson).
• EXHIBIT K: 2025 Case Manager Assignment (Willful bypass of corrective action).
• EXHIBIT L: Yahoo news article on cottone
• EXHIBIT M: Notice of Fear Transcript (11/11/25 Notice to Ridgeway).
• EXHIBIT N: Formal HR copmlaint against Ridgeway
• EXHIBIT O: COTTONE MEET AND GREET
• EXHIBIT P: retaliation against son
• EXHIBIT Q: Retaliation against son email
• EXHIBIT R: EMAIL FROM EX WIFE CORROBORATING SON
• EXHBIIT S: Rae Mitchell ban letter
• EXHIBIT T: correspondence with ridgeway

SECTION 4: FOIA OBSTRUCTION & STATE ESCALATION

• EXHIBIT U: The 1/5/26 "No Records Found" Response.
• EXHIBIT V: FOIA Officer Refusal (1/6/26 Dan Adams letter).
• EXHIBIT W: Virginia FOIA Council Appeal (Advisory Opinion Request).
• EXHIBIT X: HRTD Workforce Complaint against Dan Adams.

SECTION 5: ADMINISTRATIVE HISTORY

• EXHIBIT Y: Prior LCPS Validation of Retaliation by Nick Cottone.
• EXHIBIT Z: Record of Administrative Silence (2024–2025).

#NickCottone #SMRS #SenecaRidgeMiddleSchool #LCPS #LoudounCountyPublicSchools #LoudounCounty #AaronSpence #LoudounCountySchoolBoard #TitleIX #retaliation #LindsayMohler #TroxelLeigh

#LCPS #LoudounCountyPublicSchools #NickCottone #SenecaRidgeMiddleSchool #SMRS #LowesIslandElementarySchool #LIES #DominionHighSchool #DHS #AaronSpence #LoudounCounty #TroxelLeigh #LindsayMohler #GarethBowen