LOUDOUN COUNTY PUBLIC SCHOOLS
(571) 252-1020 21000 Education Court | Ashburn, VA 20148 lcps.org/feedback
February 24, 2026
Steven Rubis
2513 N. Newland Ave.
Chicago, IL 60707
Dear Mr. Rubis,
You have been sent two letters from LCPS staff (September 2024 and December 2025),
requesting you refrain from sending staff inappropriate communications multiples times per day,
many of which were focused on staff members and not concerns related to your children
(My note: the communications I have sent are actually about and concerning my childrens education).
In spite of those requests, those communications continue and include personal attacks, and are
otherwise unproductive, including those with matters that have previously been resolved.
(my note: these issues have not been resolved as I am being relentlessly subjected to reprisals on behalf of LCPS and its state-actor nexus of Lindsay Mohler and Qlik. Furthermore, I have requested my children be removed from the presence of Nick Cottone and I have been ignored)
Your proclivity to make disruptive and personal comments has also caused us to abruptly end large
group virtual meetings meant to foster conversation among families and school administration.
Because of your ongoing and extensive inappropriate conduct, we are constrained to take further
action.
(My note: the justification in the previous sentence is clearly fictitious. I requested clarification from John CLark and he expressly refused to provide any clarification. All subsequent attempts have been ignored by LCPS to obtain clarification)
Therefore, on behalf of the Loudoun County School Board, you are hereby notified that
you are forbidden to trespass or enter upon the property of any LCPS facility or to attend any
school-sponsored activity, unless specifically authorized by me or my designee in advance in
writing, effective immediately.
School property includes all school property, outdoor grounds, playing fields, parking
lots, pathways traversing school board grounds, school buses, as well as permanent or temporary
buildings and structures located thereon. School-sponsored activities, as defined by Policy 8020,
are activities or events planned, organized, controlled, supervised, and supported by the school.
School property also includes LCPS systems, networks, and virtual resources, including
learning management systems, video conferencing tools, online portals, and any other digital
environments maintained by the division. In accordance with Regulation 7566-REG regarding
acceptable use, all users must utilize these networked resources strictly for instructional purposes
or school business. Furthermore, Regulation 6620-REG prohibits specific conduct on LCPS
property, including disturbing operations or classes, failing to adhere to laws and policies, and
directing threats of bodily harm toward any student or employee, whether in person or via
electronic means.
Notwithstanding the foregoing, you may continue to access your ParentVue account for
information related to your children, and you may use LCPS e-mail for communications
regarding your children. You will also continue to receive communications from LCPS related
to your children currently enrolled in our schools.
If you violate these conditions, you will be deemed a trespasser and appropriate law
enforcement assistance may be called. This restriction is always in effect during day and
nighttime hours, regardless of whether school is in session, and further forbids your entry on said
property for the purpose of attending events and meetings conducted on school property without
prior written consent.
This No-Trespass Letter will terminate on February 24, 2027.
(My note: the timing of the NTO was set explicitly so that I could not contradict any testimony that Dr. Aaron Spence might given to COngress on June 10, 2026)
This notice is given under the authority of Va. Code § 18.2-119. Should you disregard
this notice, you may be found guilty of trespass, punishable as a misdemeanor.
(my note: LCPS has criminalized my joint legal custodial rights without any due process or legal predicate.)
In the event you feel that this action is not appropriate, you may send me a written
statement detailing your reasons for disagreeing with this action. I will review and consider your
statement and may modify this letter based on the information you provide. If after you receive
my decision, you are dissatisfied, you may request a review by sending your written concerns to
the Chief of Staff, 21000 Education Court, Ashburn, Virginia, 20148.
If the school is used as a polling location by the Board of Elections, you may come to the
polling portion of the school for the sole purpose of voting, and once completed, you are to
vacate the property without delay. Similarly, you may attend public School Board meetings and
religious services, but once over, you are to vacate the property without delay.
Thank you for your cooperation.
Issued this 24th day of February, 2026.
John Clark
Director of Safety & Security
cc:
Marc Bergin, Chief of Staff
Rae Mitchell, Chief of Schools
Neri Gonzales, Director of High School Education
Beth Robinson, Supervisor of Middle School Education
W. John Brewer, Principal, Dominion High School
Nick Cottone, Principal, Seneca Ridge Middle School
Kate Ridgeway, Principal, Lowes Island Elementary School
Loudoun County Sheriff’s Office
Leesburg Police Department
Exhibit 4: Analysis of the NTO
The document lacks actual details for justification of the NTO.
The document cites a letter sent to me from September 2024 and December 2025
The september 2024 letter was submitted as part of an HRTD complaint as I was sent the letter in resonse to me notifying LCPS that I was deathly afraid of Nick Cottone and attempted to self-harm less than a week after receiving the letter.
The December 2025 letter was submitted as part of an HRTD complaint, and as part of my Federal OCR complaint filed in February 2026, and my VA DOE complaint filed in February 2026.
The NTO was issued to me by John Clark on behalf of the LCPS School Board without any sort of legal due process and was issued without any legal predicate or justification.
There have been no legal actions or arrests to justify the NTO or to revoke my parental rights as has occurred under the NTO.
Most importantly, the NTO covers both physical and digital assets. Such restrictions are patently absurd given that I live over 700 miles away in Chicago, IL.
Furthermore, I have been subjected to no less than seven solicitations for either donations or volunteer time at LCPS schools since the NTO was issued, and I have been expressly prohibited from participating in my children's IEP processes or any disciplinary action involving my children.
Lastly, the timing of the NTO occurred to prevent me from contradicting any testimony Dr. Aaron Spence might give before Congress on June 10, 2026, as well as to explicitly protect the State-ACtor nexus involving private attorney Lindsay Mohler, her firm Troxel Leigh P.C., and Federal and State vendor QlikTech, Inc. (QLIK).
The only reason I would be subjected to the extreme activity exhibited by LCPS is that the documents I have uncovered via FOIA requests are so damaging to LCPS that the organization has resorted to breaking Federal and State law to silence me.
The NTO was sent to Nick Cottone a person who has and continues to undertake aggravated retaliation against me for filing Federal OCR complaints and attempting to advocate for my children. Most importantly, Nick COttone inappropriately touched my child on February 12, 2026, during a field trip to Seneca Ridge Middle School. I sent a revocation of consent to this field trip on February 9, 2026. Despite, Nick Cottone claiming he did not know my children, he explicitly sought out my son to initimidate him and me, and knew who my child was. Mr. Cottone undertook these actions to send me a message that he and LCPS are in charge and that my parental rights and the safety of my child do not matter whatsoever.
In Exhibit 5, I reproduce the emails I sent to LCPS in February 2026, alerting them to the fact that I filed both a Federal OCR complaint and complaint with VA DOE.
Exhibit 5: Email to LCPS Notifying of Federal OCR and VA DOE Filing
 | Steven Rubis <stevenrubis@gmail.com> |
NOTICE OF FILING: FEDERAL (OCR) & STATE (VDOE) INVESTIGATIONS - SELECTIVE DATA SPOLIATION (Charles Rubis)
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| Steven Rubis <stevenrubis@gmail.com> | Mon, Feb 9, 2026 at 6:48 PM |
To: Aaron Spence <aaron.spence@lcps.org>, Schoolboardemail <lcsb@lcps.org>, legal@lcps.org, Lisa Boland <lisa.boland@lcps.org>, Rae Mitchell <Rae.Mitchell@lcps.org>, Tedra Richardson <tedra.richardson@lcps.org>, Paige Carter <paige.carter@lcps.org>, Andrew.Davis@lcps.org, LCPS-SUP-Ombuds <ombuds@lcps.org>, Shontel Simon <Shontel.Simon@lcps.org>, Kate Ridgeway <Kate.Ridgeway@lcps.org>, Jennifer Painter <Jennifer.Painter@lcps.org>, Celesta Lewis <celesta.lewis@lcps.org>, Kelsey Goodnight <Kelsey.Goodnight@lcps.org>, caroline.longacre@lcps.org, Cheryl Shotwell <cheryl.shotwell@lcps.org> Cc: omni-sped@doe.virginia.gov, ocr.dc@ed.gov |
Subject: NOTICE OF FILING: FEDERAL (OCR) & STATE (VDOE) INVESTIGATIONS - SELECTIVE DATA SPOLIATION (Charles Rubis) TO: Dr. Aaron Spence (Superintendent); LCPS Legal; Gus Martinez (Executive Principal) CC: Dr. Kate Ridgeway; Celesta Lewis; Kelsey Goodnight; VDOE (omni-sped@doe.virginia.gov); OCR (OCR.DC@ed.gov) DATE: February 9, 2026 Dear Dr. Spence and LCPS Legal, Be advised that as of 6:45 PM today, I have formally escalated the matter of the "Digital Blockade" regarding Charles Rubis’s federal educational records to the following authorities: U.S. Department of Education, Office for Civil Rights (OCR): A formal Retaliation and Disability Discrimination complaint has been filed (Ref: Submission dated Feb 9, 2026). The complaint specifically cites the manual suppression of my access to Charles’s records following my 8:00 AM whistleblower disclosure. Virginia Department of Education (VDOE): An Emergency Administrative Appeal has been filed regarding the constructive denial of records access under 34 CFR § 300.613.
Notice of Litigation Hold & Stay: I am formally renewing my demand for an Immediate Administrative Stay of the February 12, 2026, transition tour at Seneca Ridge Middle School. Any attempt to proceed with this transition while federal records are being suppressed will be documented as a willful act of Actual Malice and Administrative Fraud. Furthermore, the District is under a formal duty to preserve all system audit logs for the Virginia IEP Connect and Synergy portals for February 9, 2026, to identify the User ID responsible for the manual restriction of my parental access. I await confirmation that access has been restored and the transition activities have been stayed pending the outcome of these investigations. Sincerely, Steven Rubis |
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In Exhibit 6, I provide an email from Ashley Stocks an employee of LCPS alerting me to the fact that my December 2025 HRTD filing was accepted and being reviewed. The December letter referenced in the NTO issued to me by LCPS was a major part of the validated HRTD complaint. Therefore, any NTO that attempts to use said December 2025 letter to justify the revocation of my parental rights represents a violation of LCPS anti-retaliation policy.
Exhibit 6: HRTD Email from Ashley Stocks
| Steven Rubis <stevenrubis@gmail.com> |
Incident Report Received
1 message |
| Ashleigh Stocks <Ashleigh.Stocks@lcps.org> | Wed, Dec 17, 2025 at 4:08 PM |
Reply-To: reply-lcpstitleix+6942d36a72bc5d3bb9071b42-694329c07aaba8445206b242-0@mg.guardianconduct.com To: stevenrubis@gmail.com |
 | Loudoun County Public Schools Workplace Relations Department of Human Resources and Talent Development Telephone: 571-252-1100 (Toll Free): 888-204-1622 Hi Mr. Rubis, We have received your reported concerns, and they are currently under review.
Report Details for Case 18422 Reported by: Steven Rubis Date Reported: 12-17-25 Time Reported: 10:59 AM Date of Incident: 12-17-25 Time of Incident: 9:54:am Location of Incident: Off Campus, Seneca Ridge MS Loudoun County Public Schools-Workplace Relations Team Ashleigh Stocks
CONFIDENTIALITY / PRIVACY NOTICE – This email and attachments may contain confidential and/or legally protected information. If you are not the intended recipient, or the person responsible for providing the information to the intended recipient, you are notified that any disclosure, copying, distribution of this information, and any other use of or reliance upon it, are strictly prohibited. If you have received this email or attachments in error, please notify the sender immediately. All correspondence with Loudoun County Public Schools, including email, may be subject to disclosure in accordance with the Virginia Freedom of Information Act. |
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In Exhibit 7, I provide a copy of my email sent to John Clark on Wednesday, March 4, 2026, stating I filed a workforce complaint naming him with LCPS.
Exhibit 7: Filing of HRTD complaint against John Clark
| Steven Rubis <stevenrubis@gmail.com> |
| Steven Rubis <stevenrubis@gmail.com> | Wed, Mar 4, 2026 at 9:43 AM |
To: John Clark <John.Clark@lcps.org> Cc: mark.bergin@lcps.org, Rae Mitchell <Rae.Mitchell@lcps.org>, Paige Carter <paige.carter@lcps.org>, Nick Cottone <Nick.Cottone@lcps.org>, Kate Ridgeway <Kate.Ridgeway@lcps.org>, "W. John Brewer" <john.brewer@lcps.org>, neri.gonzales@lcps.org, beth.robinson@lcps.org, sheriff@loudoun.gov, police@leesburgva.gov |
TO: John Clark CC: Marc Bergin; Rae Mitchell; HRTD Workplace Relations Subject: NOTICE OF FILING: Formal HRTD Workforce Complaint - Steven Rubis v. John Clark, et al. Mr. Clark, Please be advised that I have formally filed a Workplace Relations Complaint with LCPS HRTD today, March 4, 2026, regarding the No-Trespass Order issued by your office on February 24, 2026. The complaint documents the following: Administrative Fraud: The reliance on fabricated virtual events as a pretext for the order. Aggravated Retaliation: The timing of the order relative to my protected whistleblower activity and the scrubbing of my son’s educational data. Larceny by Trick: The use of police power to block access to $559.70 in paid FOIA records. Spoliation of Records: The withholding of critical suicide risk assessments from the 20lb physical IEP package postmarked on February 25.
This notice is provided to ensure that all relevant digital metadata, attendee logs for the cited virtual meetings, and internal communications regarding this order are preserved for the pending HRTD, VDOE, and Federal OCR investigations. I remain committed to a forensic resolution of these matters through the appropriate administrative channels. I have attached a copy of the HRTD intake form and confirmation of my submission as incident number 21548 for your knowledge and records. Regards, Steven Rubis [Quoted text hidden]
| 2 attachments |  | | 260304 Guardian _ Loudoun County Public Schools HRTD complaint number 21548.pdf
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| | | 260304 HRTD Complaint form regarding John Clark and no trespass order.pdf
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In Exhibit 8, I provide a copy of John Clark's email response to my initial appeal of the NTO. The response is clearly retaliatory and suggests a predetermined outcome, as the appeal rejection came 110 minutes after notifying John Clark of the HRTD complaint I filed regarding the NTO and that named him. As the reader can vividly see, there is no further explanation or details or clarifying points regarding the justification of the NTO. I have followed the instructions to appeal again and have sent 24 USPS Certified Mail return receipt letters to LCPS and have gotten no response.
LCPS has arbitrarily decided that it is allowed to unilaterally revoke my parental rights and that it does not need to recognize a court ordered MSA and my joint legal custodial rights to my children. LCPS has unilaterally and arbitrarily decided that it hates me and that its employees are allowed to retaliate against me for identifying and exposing massive fraud and unlawful activity being conducted at LCPS. Specifically, LCPS continues to act on behalf of and to protect both a private attorney Lindsay Mohler, her firm Troxel Leigh PC, and vendor QlikTech, Inc. in order to protect the unlawful activity being taken against me. Both Linsday MOhler and Qlik ahve been using LCPS to retaliate against me for taking legally protected action that exposes unlawful and fraudulent actions taken by these State-Actors.
Exhibit 8: John Clark's Retaliatory Response
| Steven Rubis <stevenrubis@gmail.com> |
| John Clark <John.Clark@lcps.org> | Wed, Mar 4, 2026 at 12:33 PM |
| To: "stevenrubis@gmail.com" <stevenrubis@gmail.com> |
Mr. Rubis, I have reviewed your appeal request. After careful consideration, I will not be modifying the attached letter. Please follow the instructions within the letter if you wish to further appeal this matter. I appreciate your cooperation, thank you. John Clark | Director of Safety & Security Loudoun County Public Schools 21000 Education Ct., Ashburn, VA 20148 Office 571-252-1740 CONFIDENTIALITY / PRIVACY NOTICE – This email and attachments may contain confidential and/or legally protected information. If you are not the intended recipient, or the person responsible for providing the information to the intended recipient, you are notified that any disclosure, copying, distribution of this information, and any other use of or reliance upon it, are strictly prohibited. If you have received this email or attachments in error, please notify the sender immediately. All correspondence with Loudoun County Public Schools, including email, may be subject to disclosure in accordance with the Virginia Freedom of Information Act. |
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In Exhibit 9, I provide a copy of one of my initial responses to John Clark's email issuing the NTO.
Exhibit 9: Email to John Clark
| Steven Rubis <stevenrubis@gmail.com> |
| Steven Rubis <stevenrubis@gmail.com> | Thu, Feb 26, 2026 at 10:09 PM |
To: John Clark <John.Clark@lcps.org> Cc: mark.bergin@lcps.org, Rae Mitchell <Rae.Mitchell@lcps.org>, Paige Carter <paige.carter@lcps.org>, Nick Cottone <Nick.Cottone@lcps.org>, Kate Ridgeway <Kate.Ridgeway@lcps.org>, "W. John Brewer" <john.brewer@lcps.org>, neri.gonzales@lcps.org, beth.robinson@lcps.org, sheriff@loudoun.gov, police@leesburgva.gov |
FORMAL FORENSIC OBJECTION & DEMAND FOR INTERNAL INVESTIGATIONTO: John Clark, Director of Safety & Security, Loudoun County Public Schools CC: Marc Bergin, Chief of Staff; Rae Mitchell, Chief of Schools; Loudoun County Sheriff’s Office RE: SUPPLEMENTAL OBJECTION TO NO-TRESPASS ORDER; NOTICE OF CIVIL RIGHTS CONSPIRACY DATE: February 26, 2026 NOTICE OF PROTECTED SPEECH & RESERVATION OF RIGHTSThis correspondence constitutes a "Petition for Redress of Grievances" protected under the First Amendment of the U.S. Constitution and the Constitution of Virginia. Any attempt to utilize this objection as a basis for criminal prosecution or civil litigation will be met with a motion for dismissal and sanctions under the Virginia Anti-SLAPP statute (Va. Code § 8.01-223.2) and a counter-claim for Malicious Prosecution and Abuse of Process. Dear Mr. Clark, This letter serves as a formal update to my previous correspondence regarding the No-Trespass Notice issued on February 24, 2026. Following a meticulous forensic analysis of the Notice and the surrounding material facts, I am submitting this supplemental objection to establish a comprehensive and indisputable administrative record. This order—issued under the purported authority of Va. Code § 18.2-119—is a fraudulent instrument of extrajudicial harassment and a coordinated civil rights conspiracy. I. ADMINISTRATIVE FRAUD & RETALIATORY CONTACT WITH MINORSThe No-Trespass Notice is facially fraudulent as it relies upon fabricated events to justify the deprivation of my rights: Fabricated Event: The notice claims my comments caused the "abrupt end [of] large group virtual meetings". LCPS has provided zero details regarding the date, time, platform, or specific comments attributed to me to substantiate this material claim. Documented Perjury & Fraud: On October 13, 2023, Principal Nick Cottone (Seneca Ridge MS) claimed in writing to LCPS superiors he did not know my family. This is demonstrably false; I possess over 20 pages of correspondence between Cottone and my ex-wife spanning the 20 months prior to his fraudulent disclaimer. The "Show of Force" Ruse: Billing records from Troxell Leigh P.C. (Invoice #50961) definitively show that on October 24, 2023, attorney Gareth Bowen coordinated with Deputy Iversen (LCSO) to discuss an "investigation and what kind of relief we are pursuing". This ruse was executed despite Deputy Iversen's admission that there was no criminal predicate for the contact. Targeted Retaliation against Charles Rubis: Following my Federal OCR complaint (filed Feb 9, 2026) and a formal Revocation of Consent (submitted Feb 9, 2026, 8:00 AM ET), Nick Cottone personally targeted my son, Charles Rubis, on February 12, 2026. Despite the revocation of consent for transport to Seneca Ridge MS, Cottone singled out the child, interrogated him regarding his sibling's identity, and initiated unsolicited physical contact. This constitutes aggravated witness intimidation and occurred subsequent to the initial administrative fraud of October 2023.
II. DUE PROCESS VIOLATIONS: CONCEALED SUBPOENASLCPS has actively concealed legal proceedings to facilitate a private-public strike: Undisclosed Service: On April 24, 2024, subpoenas were served on Nick Cottone (Seneca Ridge) and Kate Ridgeway (Lowes Island). Procedural Breach: LCPS failed to notify me of these services. Furthermore, the matters in the subpoenas were unrelated to my children, proving school administrators were utilizing public offices to assist private attorneys in a "fishing expedition" for private litigation.
III. VENDOR CORRUPTION & AGGRAVATED RETALIATIONThe timing of this order confirms a retaliatory motive to protect QlikTech, Inc., a current LCPS vendor, from a debarment inquiry: The Qlik Quid Pro Quo: Qlik’s Feyi Obafemi altered my settled historical termination record to remove evidence of my reports regarding threats of physical violence. This was a "quid pro quo" to assist Lindsay Mohler (Troxell Leigh P.C.) in active litigation. Obafemi received a corporate promotion within 60 days of this fraudulent redaction. Whistleblower Suppression Timeline: Feb 9, 2026: Filed Federal OCR Complaint naming Nick Cottone and LCPS. Feb 12, 2026: Reported retaliatory witness intimidation of my son by Principal Cottone. Feb 19, 2026: Filed Debarment Petition with LCPS explicitly naming Obafemi and the record alteration. Feb 23, 2026 (AM): Filed formal complaint with the NJ OAE regarding Obafemi. Feb 24, 2026 (AM): Filed Qlik Debarment Evidence with the Virginia OAG (Civil/Consumer) and filed a complaint with the PA Bar. Feb 24, 2026 (PM): LCPS issued this No-Trespass Order within hours of my reports to state and federal authorities. Feb 25, 2026: Filed an official complaint with the Office of the Inspector General (OIG). Feb 26, 2026 (AM): Filed updated petitions with the Virginia OAG, documenting this No-Trespass Order as an act of illegal retaliation.
DEMAND FOR REMEDYI demand the immediate rescission of this fraudulent order. Be advised that I have engaged in multiple instances of legally protected activity regarding Nick Cottone and other LCPS administrators, including the filing of numerous workforce complaints with Human Resources and Talent Development (HRTD). Several of these complaints have been substantiated by LCPS. Consequently, the issuance of this No-Trespass Notice represents a blatant and documented violation of LCPS Anti-Retaliation Policy, as I am being served a No-Trespass Notice based on the letters of September 2024 and December 2025 that were the direct subject of and to the protected activity I describe here. All rights are reserved, including the right to seek damages for Deprivation of Civil Rights (42 U.S.C. § 1983) and Larceny by Trick (Va. Code § 18.2-178). Sincerely, Steven A. Rubis [Quoted text hidden]
| | 250209 Troxel Leigh Legal Bill.pdf
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In Exhibit 10, I provide a second email sent to John CLark outlining my concerns and objections prior to his rejection of my appeal request on March 4, 2026.
Exhibit 10: Second Letter of Objection and COnerns Sent to John CLark
| Steven Rubis <stevenrubis@gmail.com> |
| Steven Rubis <stevenrubis@gmail.com> | Mon, Mar 2, 2026 at 10:06 AM |
To: John Clark <John.Clark@lcps.org> Cc: mark.bergin@lcps.org, Rae Mitchell <Rae.Mitchell@lcps.org>, Paige Carter <paige.carter@lcps.org>, Nick Cottone <Nick.Cottone@lcps.org>, Kate Ridgeway <Kate.Ridgeway@lcps.org>, "W. John Brewer" <john.brewer@lcps.org>, neri.gonzales@lcps.org, beth.robinson@lcps.org, sheriff@loudoun.gov, police@leesburgva.gov |
As a professional courtesy, I am emailing to alert you, and those CCed, that I sent a hard copy of my formal response, illustrated below, to your letter on Saturday, February 28, 2026, via USPS Certified Mail with Return Receipt Requested.
Today's email updates the administrative record.
The package send on Saturday marks the seventh USPS Certified Mail with Return Receipt Requested communication I have sent to LCPS. The previous six have yet to elicit a response from LCPS.
USPS Tracking number: 9589071052700045352390
USPS Return Receipt Tracking Number: 9590940292924295980467
The hard copy response contained in that package is shown below:
FORMAL OBJECTION AND DEMAND FOR RECISION OF NO-TRESPASS ORDER SENT VIA USPS CERTIFIED MAIL – RETURN RECEIPT REQUESTED TO: John Clark, Director of Safety & Security, Loudoun County Public Schools 21000 Education Court, Ashburn, VA 20148 CC: Marc Bergin, Chief of Staff; Rae Mitchell, Chief of Schools; Neri Gonzales, Director of High School Education; Beth Robinson, Supervisor of Middle School Education; W. John Brewer, Principal (DHS); Nick Cottone, Principal (SMRS); Kate Ridgeway, Principal (LIES); Loudoun County Sheriff’s Office; Leesburg Police Department DATE: February 28, 2026 RE: NOTICE OF AGGRAVATED RETALIATION, CONSTITUTIONAL VIOLATIONS, AND THE FORENSIC BLOCKADE OF PAID PUBLIC RECORDS Dear Mr. Clark, I am filing this formal Notice of Disagreement and Demand for Recision based on a fundamental legal bedrock: a parent cannot be "trespassed" for the "crime" of being a whistleblower. This No-Trespass Order is an unlawful attempt to criminalize my legally protected advocacy and my mandate to establish an Administrative Record of District misconduct. My conduct—the reporting of waste, fraud, and civil rights violations—is not only "not wrong," but is a mandated response to the District's own documented patterns of administrative fraud and data spoliation. I. FORENSIC REFUTATION OF "SAFETY" PRETEXT AND FABRICATED EVENTS The No-Trespass Notice issued February 24, 2026, is facially fraudulent as it relies upon fabricated and unresolved events to justify the deprivation of my rights: - Fabrication of "Virtual Events": Your letter cites a "proclivity to make disruptive and personal comments" that caused the abrupt end of "large group virtual meetings." I have no knowledge of this event, have not participated in LCPS virtual meetings since 2023, and demand the immediate production of specific details (date, time, platform) to substantiate this claim.
- Criminalization of Investigative Journalism: To the extent "proclivities" refers to my investigative reporting via nickcottone.blogspot.com or public comments on news articles, LCPS has violated my First Amendment rights as an investigative publisher.
- Failure to Rectify and Lack of Resolution: Your letter claims my communications are "unproductive" regarding matters "previously resolved." I explicitly deny that any issue I have brought forth has been resolved. LCPS has provided zero details regarding actions undertaken to rectify documented malfeasance. Until my children are removed from the power of Nick Cottone, who has violated my rights, all reported violations remain active and unresolved.
- Retaliatory Use of Prior Notices:
- September 2024 Notice: This was a notice that I was "deathly afraid" of Nick Cottone. I filed an HRTD complaint regarding this letter and have received zero response. Utilizing this as a basis for a police ban is a blatant violation of LCPS Policy 7561 (Anti-Retaliation) and the ADA.
- December 2025 Notice: This letter from Rae Mitchell attempted to conflate IEP violations with my reporting of administrative fraud. My advocacy involved the denial of accommodations for my son, who was mocked by staff for his disability and punished for my formal complaints. Because LCPS has provided zero response to the HRTD complaint filed against this letter, its use here violates LCPS Policy 7561 and 34 C.F.R. § 100.7(e).
II. VENDOR CORRUPTION AND THE QUADRIPARTITE COLLUSION This order is an ultra vires instrument manufactured to provide "color of law" cover for a coordinated civil rights conspiracy: - Documented Collusion and Administrative Fraud: I have reported proven unlawful collusion between attorney Lindsay Mohler (Troxell Leigh P.C.), LCPS, Nick Cottone, and the LCSO. This is evidenced by the administrative fraud conducted by Nick Cottone on October 13, 2023, and the subsequent "show of force" call conducted by SRO Timothy Iversen on 12/12/23 at Cottone's direction.
- Public-Private Nexus Admission: I have provided proof of collusion between Mohler, Troxel Leigh, and QlikTech, Inc. (Feyi Obafemi). This No-Trespass Order explicitly ties these acts together and represents an admission that LCPS is under the control of a private law firm and its vendor, Qlik.
- Aggravated QlikTech Retaliation: This ban was issued within hours of my reporting vendor violations to the Virginia Office of the State Inspector General (OSIG) and the Virginia OAG. Furthermore, this represents Aggravated Retaliation for the debarment position regarding Qlik sent to LCPS on February 19, 2026, wherein I explicitly stated any future retribution would be treated as such.
- Larceny by Trick and Forensic Blockade (Va. Code § 18.2-178): LCPS accepted payment for FOIA records totaling $559.70 (Requests R002480, R002437, R002450) and then utilized police power to block their delivery. These documents likely include significant incriminatory evidence of the collusion claims outlined in this response. I demand the immediate release of these records and the restoration of my access to all LCPS digital platforms.
III. STRATEGIC TIMELINE OF RETALIATION The following timeline establishes the District’s total failure to respond to protected activity, followed by the immediate weaponization of this No-Trespass order: - [Feb 9, 7:00 AM]: Served Final Cease & Desist and Notice of Willful Misconduct on LCPS Leadership.
- [Feb 9, 9:14 AM]: Documented that Charles's history was selectively scrubbed from the Virginia IEP Connect portal within 74 minutes of service (Violation of 20 U.S.C. § 1232g).
- [Feb 12, 11:41 AM]: Successfully resubmitted Formal State Special Education Complaint to the VDOE (Case #C26-393).
- [Feb 18, 8:42 AM]: VDOE formally notified LCPS that information regarding the Feb 12 complaint would be sent by Feb 24, 2026.
- [Feb 24, 5:04 PM]: LCPS issued the No-Trespass Order on the exact day of the VDOE deadline to preempt the state's findings.
- [Feb 25, Postmark]: In a blatant act of Constructive Evasion, LCPS mailed a 20lb physical package of IEP records requested on Feb 12. By waiting until after the No-Trespass order was issued to postmark these records in a non-digital format, LCPS has willfully obstructed my right to digital audit trails and metadata preserved under FERPA.
IV. PARENTAL ERASURE AND RETALIATION AGAINST A MINOR The timing of this notice served as a calculated punishment for my son, Charles Rubis: - The Lowes Island Variety Show: This ban was timed to prevent my attendance at the Lowes Island Elementary School Variety Show (held at Dominion HS) on February 27, 2026, where my son was requested to perform at the height of his clinical vulnerability.
- Custodial Violations and Parental Erasure: By barring access to ParentVue and digital platforms (Violation of 34 CFR § 99.10), LCPS is facilitating parental erasure and violates my rights to joint legal custody.
V. COMPREHENSIVE SAFE HARBOR AND ANTI-RETALIATION DECLARATION This correspondence constitutes a "Petition for Redress of Grievances" protected under the First Amendment of the U.S. Constitution and the Constitution of Virginia. Any attempt by LCPS or its agents to utilize this objection, my reporting, or this No-Trespass Order as a basis for criminal prosecution, civil litigation, or family court retaliation by Lindsay Mohler (Troxell Leigh P.C.) will be met with: - A motion for dismissal and sanctions under the Virginia Anti-SLAPP statute (Va. Code § 8.01-223.2).
- Counter-claims for Malicious Prosecution and Abuse of Process.
- Formal Notice of Protected Activity under Section 504 of the Rehabilitation Act, the IDEA, VA Code § 2.2-3011, and LCPS Policy 7561.
I demand the immediate and total recision of this No-Trespass Order. Sincerely, Steven Rubis |
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In Exhibit 11, I provide the email I sent to LCPS that outlines the fact that the NTO issued by LCPS represents defacto retaliation.
Exhibit 11: VA ODRAS Respsonse
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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Mon, May 11, 2026 at 7:00 AM
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To: John Clark <John.Clark@lcps.org>,
mark.bergin@lcps.org, Rae Mitchell <Rae.Mitchell@lcps.org>, Paige
Carter <paige.carter@lcps.org>, Nick Cottone
<Nick.Cottone@lcps.org>, Kate Ridgeway <Kate.Ridgeway@lcps.org>,
"W. John Brewer" <john.brewer@lcps.org>,
neri.gonzales@lcps.org, beth.robinson@lcps.org, sheriff@loudoun.gov,
police@leesburgva.gov, dan.adams@lcps.org, Mara Moreland
<Mara.Moreland@lcps.org>, Celesta Lewis <celesta.lewis@lcps.org>,
Aaron Spence <aaron.spence@lcps.org>, Schoolboardemail <lcsb@lcps.org>,
legal@lcps.org, LCPS-SUP-Ombuds <ombuds@lcps.org>, Jason Allison
<jason.allison@lcps.org>
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VIA EMAIL (URGENT - FORENSIC RECORD)
DATE: May 11, 2026
TO: Marc Bergin, Chief of Staff; John Clark,
Director of Safety & Security; Dr. Aaron Spence, Superintendent, LCPS
administration, LCPS School Board, Loudoun County Sheriff’s Office (LCSO),
Leesburg Police
FROM: Steven Rubis (Joint Legal Custodian)
SUBJECT: SUPPLEMENTAL NOTICE OF AGGRAVATED
RETALIATION AND OBSTRUCTION OF STATE MEDIATION (THE ODRAS SMOKING GUN)
To the Loudoun County Public School (LCPS)
Administration:
This letter serves as a formal supplement to the
forensic record regarding the February 24, 2026, No-Trespass Order. I am
formally incorporating the February 24, 2026 (4:28 PM) email
from the Virginia Department of Education (VDOE) ODRAS as
definitive proof of Aggravated Retaliation and Obstruction
of Justice.
I. THE 16-HOUR RETALIATORY STRIKE
The temporal proximity between the state’s
recommendation for mediation and the District’s issuance of a criminal ban
constitutes a "Smoking Gun" of administrative malice:
- Feb
24, 4:28 PM: ODRAS issued a formal notice to both parties
"highly encouraging" state-sponsored mediation to resolve my
complaints.
- Feb
25, 8:32 AM: Less than 16 hours after the ODRAS notice, and while
I remained 700 miles away in Chicago, John Clark issued the
No-Trespass Order.
- Forensic
Conclusion: LCPS utilized the window immediately following state
intervention to manufacture a "Security" pretext,
effectively sabotaging the state-administered process and
criminalizing my participation in the recommended mediation.
II. WILLFUL OBSTRUCTION OF ADMINISTRATIVE SERVICES
The No-Trespass Order purports to ban my "digital
presence" and use of "virtual resources". By issuing this
order immediately following the ODRAS proposal, LCPS willfully obstructed a
state-administered negotiation process. This is a documented violation of
the Virginia Fraud and Abuse Whistle Blower Protection Act (Va.
Code § 2.2-3011) and a bad-faith interference with a student’s
right to a Free Appropriate Public Education (FAPE).
III. WAIVER OF SECURITY PREDICATE VIA CONTINUED
SOLICITATION
The District’s claim that this ban was necessitated by a
"threat" is forensically invalidated by the fact that LCPS has
issued six (6) distinct solicitations for my participation in
"Titan" fundraising and "Donuts with Grownups" events
since the ODRAS email was received. The District cannot simultaneously
obstruct state mediation via a "security" ban while soliciting my
physical and financial presence on school grounds.
IV. WAIVER OF SECURITY PREDICATE: THE CAREER DAY
SOLICITATION
The District’s claim that this ban was necessitated by a
"threat" is forensically invalidated by the fact that LCPS has
now issued six (6) distinct solicitations for my
participation in fundraising and school events since the ODRAS email was
received, my Federal US DOE OCR complaint was filed, and LCPS issued the
fraudulent and retaliatory No-Trespass Order against me on February 24,
2026. The most recent outreach being from Cheryl Shotwell on
May 6, 2026.
- The
Invite: Shotwell invited me to serve as a Career Day
Volunteer to address fourth and fifth-grade
students—including Beau and Charles Rubis—on May 22, 2024.
- Forensic
Absurdity: LCPS cannot legally sustain a "security"
ban while simultaneously soliciting a parent to lead classroom lessons
for minors. This invitation constitutes a full administrative
waiver of the NTO's safety predicate.
V. NOTICE TO FEDERAL OCR AND VDOE
This evidence of "Circular
Retaliation"—wherein LCPS utilized a state intervention as the trigger
for a criminal ban—is being provided to U.S. Department of
Education OCR and ODRAS as proof of Actual
Malice and Administrative Fraud.
REQUIRED IMMEDIATE ACTION:
VI. MANDATORY REMEDIES & ADMINISTRATIVE DEMANDS
- Immediate
Termination Proceedings: For Nick Cottone and John
Clark.
- Immediate
Administrative Suspension: For Marc Bergin and Rae
Mitchell.
- Unconditional
Rescission of NTO: A formal retracted notice stating the NTO
was issued without a factual or legal basis. Full restoration
of my parental rights that have been revoked by LCPS without due cause
or any legal proceeding occurring.
- Remediation
of FOIA Larceny: Immediate electronic release of the 944
records (R002510). DELIVER the 1,141+
FOIA records ($559.70) that LCPS has withheld as part of this
retaliatory blockade.
- Financial
Restitution: Notice of claim for $2,148,000.00 and
continuing.
Sincerely,
Steven Rubis (Joint Legal Custodian)
(214) 681-7991
(202) 997-4815
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2 attachments
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260224 Gmail - C26-398 Letter of Inquiry C.R.
Loudoun.pdf
140K
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260506 Gmail - C04E00-402 - Gr 4 School Counselor
Classroom Lessons (Beau Rubis), C05E00-505 - Gr 5 School Counselor
Classroom Lessons (Charles Rubis) - Career Day Volunteers.pdf
136K
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#NickCottone #SMRS #SenecaRidgeMiddleSchool #LCPS #LoudounCountyPublicSchools #LoudounCounty #AaronSpence #LoudounCountySchoolBoard #TitleIX #retaliation #LindsayMohler #TroxelLeigh
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