The letter below was delivered via email to Loudoun County Public Schools (LCSO), Loudoun County Sherrif's Office (LCSO), and the Leesburg Police department at 8:00 AM ET / 7:00 AM CT on Monday, May 11, 2026.
The letter calls out explicit factual evidence that LCPS, LCSO, Leesburg Police, as well as co-consipirators Lindsay Mohler, her firm Troxel Leigh P.C., and government vendor QlikTech, Inc. (Qlik) have committed aggravated retaliation against me for undertaking protected activity against these named entities.
On our about February 9 and 10, 2026, I filed two complaints one with the US Department of Education Office of Civil Rights (OCR) and one with the Virginia Department of Education (ODRAS). On February 24, 2026, at 4:28 pm CT, I received an email response from ODRAS recommending I seek mediation with LCPS for the concerns outlined in my complaint.
At 8:32 AM CT, the next day, February 25, 2026, I received the fraudulent no-trespass order (NTO) via email from John Clark on behalf of the LCPS School Board. The NTO specifically referenced communications that are part of open HRTD complaints and part of my Federal OCR complaint. Additionally, the letter cited a vague and seemingly made up event where I made some comments. LCPS refused to provide any clarifying details in my initial appeal. Mark Bergin, Chief of Staff, has ignored 17 USPS certified mail return receipt requested letters seeking appeal of JOhn Clark's predetermined denail of my initial appeal.
The fact pattern presented here represents prima facie evidence of administrative malice and aggravated retaliation on the part of LCPS and their co-conspirators inlcuding but not limited to LCSO, Leesburg Police, Lindsay Mohler, Troxel Leigh P.C., and QlikTech Inc. (Qlik).
The temporal proximity of the ODRAS response and LCPS NTO illustrates that there was no legitimate reason to issue an NTO that covers both physical and digital to a parent residing 700 miles away from Loudoun County Virginia.
There has never been any legitimate justification of LCPS labeling me as a threat worth of a physical and digital NTO. If anything, I have provided proof and validation of the safety concerns I initially sent to Nick Cottone on October 13, 2023, when I accused him of having an inappropriate relationship with my ex wife. I sought an emergency order of protection from the Virginia Magistrate against my ex wife on Sunday, October 9, 2023, as she placed a tracking device on me during my legally prescribed visitation. I was denied. On Monday, October 10, 2023, I sought a restraining order from Loudoun Count Court for the same reasons and was denied. In May 2025, my ex wife admitted in email that she placed the tracking device on me and that it was a bad decision and she was in a bad place.
Since my October 13, 2023, email to Nick Cottone, I have endured retaliation and reprisals on behalf of Lindsay MOhler and her firm Troxel Leigh P.C. via LCPS and LCSO. The NTO represents another blatant example of how LCSO and LCPS have been bought by Lindsay Mohler and her firm Troxel Leigh P.C. and seem to be rentable forces to attack and resolve personal civil vendettas to the liking of Lindsay Mohler and her firm Troxel Leigh.
The reason LCPS has added the digital portion to the NTO is to prevent me from obtaining the documents LCPS identified in response to my FOIA requests about the unlawful state-actor nexus involving LCPS, LCSO, LIndsay MOhler, Troxel Leigh P.C., and Qlik. Clearly, the documents identified are so damaging to LCPS and LCSO that they have chosen to act on behalf of a private attorney and government vendor versus respecting Federal or State Law.
Essentially, Federal and State of Viriginia rule of law do not exist in Loudoun County, as all government entites are available for the use of Lindsay Mohler, and her firm Troxel Leigh P.C. to unlawfully revoke parental rights and violate civil rights without accountability.
I have been told by my current lawyer and several other lawyers in Loudoun County that I am not allowed to hold Lindsay Mohler or her firm Troxel Leigh P.C. accountable. I have been told that I have no right to defend myself against blatant unlawful actions and blatant civil rights violations in Loudoun County Virginia.
I have been told that the state-actor nexus of Lindsay MOhler, Troxel Leigh P.C., QlikTech, Inc (Qlik), LCPS, and LSCO are allowed to attack, violate, and revoke my Federal Civil Rights, the civil rights of my children who are on IEPs, and my parental rights.
 | Steven Rubis <stevenrubis@gmail.com> |
| Steven Rubis <stevenrubis@gmail.com> | Mon, May 11, 2026 at 7:00 AM |
| 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> |
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
Here is a copy of the email I received from ODRAS on the evening of February 24, less than 24 hours prior to LCPS undertaking aggravated retaliation against me. As you can see, the ODRAS email included LCPS employees.
| Steven Rubis <stevenrubis@gmail.com> |
C26-398 Letter of Inquiry C.R. Loudoun
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| State Complaints (DOE) <statecomplaints@doe.virginia.gov> | Tue, Feb 24, 2026 at 4:28 PM | | To: Paige Carter <paige.carter@lcps.org>, "donna.smith@lcps.org" <donna.smith@lcps.org>, "stevenrubis@gmail.com" <stevenrubis@gmail.com> | Hello, The Office of Dispute Resolution and Administrative Services (ODRAS) is unable to investigate the received complaint as documented in the attached letter of inquiry. The complainant should review the inquiry and follow the provided instructions to ensure all concerns are addressed. Should you choose to resubmit, the complaint should be sent to odras@doe.virginia.gov. We have also attached the complaint form to assist you with submitting the complaint. You are not required to use the form. In the meantime, we highly encourage both parties to consider state-sponsored mediation to resolve the allegations outlined in the complaint. Mediation is a free, voluntary, state administered process that involves a meeting facilitated by an impartial, trained mediator to assist parents and school staff in their negotiations with each other. Additional information regarding mediation is attached. Sincerely, 
| State Complaints Office of Dispute Resolution and Administrative Services Department of Special Education and Specialized Populations Virginia Department of Education p:804.750.8143 | Statecomplaints@doe.virginia.gov |
The information conveyed in this communication is intended for the use of the original addressee(s), and may be legally privileged, confidential, and/or exempt from disclosure under applicable law. If this communication was not addressed or copied to you, then you have received it in error and are strictly prohibited from reading, copying, distributing, disseminating, or transmitting any of the information it conveys. If you received this communication in error, please destroy all electronic, paper, and other copies, and notify the sender immediately. Accidental transmission of this communication is not intended to waive any privilege or confidentiality protected under Virginia's Freedom of Information Act.
| 7 attachments |  | | Complaint Resolution Procedures.pdf
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| | | Dispute Resolution Process Comparison Chart_0.pdf
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| | | Mediation Brochure update 2023.pdf
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|  | | mediation-services-request-form.docx
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| | | State Special Education Complaint Form 2024.pdf
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| | | 260212_Formal_Complaint_Rubis_vs_LCPS.pdf
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| | | C26-398 Charles Rubis (Loudoun) 02.24.2026.pdf
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