Part II
On May 29, 2026, I submitted my testimony to the U.S House Committee on Educatoin and The Workforce.
You can see a copy of my initial submission in part I, link:
https://nickcottone.blogspot.com/2026/06/congressional-testimony-submission.html
Below, I illustrate the contents of my initial testimony provided to Congress.
This testimony was provided to refute the false testimony and statements that were made by Dr. Aaron Spence and on behalf of the Loudoun County School Board.
EXHIBIT A: THE CHRONOLOGICAL RECORD OF DIGITAL BLOCKADE
AND ADMINISTRATIVE RETALIATION
DOCUMENT 1: COMMUNITY-WIDE BROADCAST FROM DR. AARON
SPENCE
- Sender:
Loudoun County Public Schools <donotreply@lcps.org>
- Recipient:
Steven Rubis <stevenrubis@gmail.com>
- Date:
Tuesday, May 12, 2026, at 11:05 AM
- Forensic
Note: This digital transmission was directed to the Complainant
exactly 28 hours after the formal forensic notice of ODRAS
mediation sabotage was served to Dr. Spence’s cabinet. It documents the
Superintendent publicly categorizing systemic civil rights complaints and
federal oversight as "distractions."
- The
100 pages of evidence included herein explicitly contradicts the public
proclamation LCPS and Dr. Spence sent via community wide email on May
12, 2026, and serves as a stark contradiction to the reality of how Dr.
Spence and LCPS actually handles parental rights in real time.
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Steven Rubis <stevenrubis@gmail.com>
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Important Community Message
1 message
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Loudoun County Public Schools <donotreply@lcps.org>
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Tue, May 12, 2026 at 11:05 AM
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Reply-To: donotreply@lcps.org
To: stevenrubis@gmail.com
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Loudoun County Public Schools
Dear LCPS Family,
I want to share with you that I will be testifying
before the U.S. House Committee on Education & Workforce on June 10,
2026.
I welcome this opportunity and look forward to speaking
with the committee about the extraordinary environment we have built
together here in Loudoun County Public Schools. Each and every day, our
students learn, grow, and achieve at remarkable levels, supported by
dedicated staff and engaged families. These accomplishments are not
possible without the strong partnerships we share with our families and the
broader community.
At
LCPS, we are committed to ensuring every student feels a sense of
belonging, value, and opportunity in our schools. We believe all students
deserve to be supported, challenged, and prepared for success, and we
remain focused on creating learning environments where every child can
thrive. In doing so, we follow both state and federal laws, uphold the
rights of all students, and work each day to provide safe, welcoming, and
academically strong schools for every member of our community.
While
I recognize that this moment brings heightened attention and, at times,
increased politicization, I remain firmly focused on what matters most: our
students. Distractions will not deter us from continuing to make LCPS one
of the finest school divisions in the country.
It is truly a privilege to serve this community and I
value the opportunity to engage with our students, staff, and families
every day. As always, I am grateful for your continued support.
Sincerely,
Dr. Aaron Spence
Superintendent
Loudoun County Public Schools
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DOCUMENT 2: LCPS SAFETY DIRECTOR NO-TRESPASS ISSUANCE
- Sender:
John Clark <John.Clark@lcps.org>
- Date:
Wednesday, Feb 25, 2026, at 8:32 AM
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Steven Rubis <stevenrubis@gmail.com>
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John Clark <John.Clark@lcps.org>
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Wed, Feb 25, 2026 at 8:32 AM
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To: "stevenrubis@gmail.com"
<stevenrubis@gmail.com>
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Sir,
Please see attached. Thank you for your cooperation.
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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No Trespass - Rubis - All Facilities.pdf
218K
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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Wed, Feb 25, 2026 at 2:15 PM
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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
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FORMAL FORENSIC NOTICE OF DISAGREEMENT AND DEMAND FOR
IMMEDIATE RECISION
TO: John Clark, Director of Safety &
Security, Loudoun County Public Schools
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.
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. This order is an ultra
vires instrument manufactured to provide "color of law"
cover for Lindsay Mohler (Troxell Leigh P.C.) and vendor QlikTech, Inc., to
suppress evidence of systemic fraud and facilitate the professional and
parental erasure of a whistleblower.
EXECUTIVE SUMMARY OF ADMINISTRATIVE MISCONDUCT AND
RETALIATION The February 24 No-Trespass Order is not a safety
measure—as I reside 700 miles away in Chicago and have never made a
threat—but is the final stage of a Coordinated Retaliatory Pincer
Movement. This movement consists of: (1) Financial Retaliation through
punitive fee-shifting; (2) Digital Spoliation via the
manual "locking" of federal records; (3) Administrative
Fraud via false official statements by Principal Nick Cottone; and
(4) Obstruction of Justice by issuing a police ban on the
exact day of a VDOE investigation deadline. Furthermore, the timing was
explicitly calculated to prevent me from attending the Dominion
High School Variety Show this weekend at the request of my son,
Charles—a cruel act of retaliation against a student with a documented
Emotional Disability.
SAFE HARBOR & ANTI-RETALIATION DECLARATION Let
this submission serve as a formal Notice of Protected Activity under Section
504 of the Rehabilitation Act, the IDEA, VA Code §
2.2-3011, and LCPS Policy 7561. My communications are
strictly limited to the reporting of misconduct. Furthermore, the volume of
this correspondence is not "nuisance"; it is forensic evidence
illustrating a severe deficiency in response by LCPS. This
volume highlights the District’s total failure to discuss or rectify the
proven misconduct I have cited. Any attempt to utilize the volume of these
constitutionally protected petitions as a basis for further sanctions will
be documented as Aggravated Retaliation for a
communication crisis manufactured by the District’s own non-responsiveness.
NOTICE OF AVAILABILITY OF EVIDENCE I possess
comprehensive PDF evidence, metadata, and exhibits for every timestamp and
factual claim asserted below. Due to volume, they are not attached here but
will be provided immediately upon request by any investigating authority
acting in good faith.
I. Strategic Sabotage of State/Federal Investigations
and The Forensic Timeline of Retaliation
- [Feb
4, 11:46 AM]: In response to Dr. Spence’s community message, I
issued a Formal Demand for the Application of 14th Amendment
and FERPA Standards to the Rubis Family. I explicitly challenged
the District’s "Selective Equal Protection" and noted the
hypocrisy of claiming FERPA protection while LCPS FOIA records (the
944 records) likely document the illegal sharing of my family’s
private dynamics with private attorneys Lindsay Mohler and Gareth
Bowen. I identified the weaponization of SRO Timothy Iversen,
who, at the direction of Nick Cottone, initiated an
extrajudicial "show of force" interrogation of a parent 700
miles away in Chicago in Dec 2023. Iversen admitted there was no
criminal predicate or legal reason for the call, establishing a clear
violation of my 4th and 14th Amendment rights.
- [Feb
9, 7:00 AM (Zero Hour)]: I served a Final Cease &
Desist and Notice of Willful Misconduct (Exhibits 1-113) on
LCPS Leadership. I formally revoked consent for the
Seneca Ridge transition, cited Nick Cottone’s Administrative
Fraud (VA Code § 18.2-468), and documented $2,148,000.00+
in economic damages resulting from the "Public-Private
Nexus" between LCPS and Lindsay Mohler. I explicitly warned that
proceeding with the transition tour would be viewed as Actual
Malice and Deliberate Indifference toward a documented
multi-year record of safety conflicts.
- [Feb
9, 9:14 AM]: I issued a Formal Notice of Digital
Spoliation and Targeted Records Blackout. I documented that at
9:00 AM—74 minutes after my 8:00 AM whistleblower service—Charles’s
multi-year history (dating back to March 2022) was selectively
scrubbed from the Virginia IEP Connect portal, while records for my
son Beau remained visible. I identified this as a violation of
the IDEA and FERPA (20 U.S.C. §
1232g) and demanded the preservation of the Synergy Audit
Trail to identify the administrator who modified these settings.
- [Feb
9, 9:18 AM]: I issued a formal Request for Historical IEP
Records (2022–present) to Counselor Kelsey Goodnight. Despite
a consistent history of professional compliance, this request—and all
subsequent attempts to obtain my son's clinical history—remained
unacknowledged. This confirms that a top-down directive was issued to
implement a Total Records Blackout immediately
following my 8:00 AM whistleblower disclosure.
- [Feb
9, 2:13 PM]: I issued a Second Notice of Targeted Records
Withholding and Constructive Denial of Access. I provided forensic
evidence that the Virginia IEP Connect system was
fully operational—as LCPS staff had successfully updated records for
my son Beau that same morning—while manually "locking" or
"filtering" Charles’s educational file. I formally
identified this as Actual Malice and a willful
violation of 34 CFR § 99.10 (FERPA).
- [Feb
9, 6:48 PM]: I formally served the Superintendent and LCPS Legal
with a Notice of Filing: Federal (OCR) & State (VDOE)
Investigations. I placed the District under a Formal
Litigation Hold, demanding the preservation of all system audit
logs for the Virginia IEP Connect and Synergy portals to identify the
User ID responsible for the manual restriction of my parental access.
- [Feb
9, 10:24 PM]: I filed an URGENT SAFETY ADDENDUM &
CONSENT FORM with the Office for Civil Rights (OCR).
I alerted federal investigators that the "Digital Blockade"
was suppressing life-safety records for a student
with a primary disability of Emotional Disability. I cited
Charles's April 2025 IEP (Pages 3-4) documenting his clinical
vulnerability to anxiety and depression.
- [Feb
10, 7:00 AM]: I issued a Notice of Procedural Failure and
Rejection of Administrative Ambush. I formally rejected the Dec
19, 2025, letter from Rae Mitchell (Chief of Schools) as
an attempt to bypass 8VAC20-81-170. I documented the
failure of Dr. Kate Ridgeway to report a physical
safety incident for four days and the illegal isolation of my son (a
student with an Emotional Disability) for "reflective
writing" without an IEP team member present.
- [Feb
12, 11:41 AM]: I successfully resubmitted my Formal State
Special Education Complaint to the VDOE (ODRAS), curing all
procedural deficiencies noted in Case #C26-393. The District was
simultaneously served with this filing, placing them on notice of a
formal state investigation.
- [Feb
13, 8:44 AM]: I filed a Demand for an Administrative Stay with
ODRAS to prevent a "Predetermined Placement" of my son while
I remained under a "Digital Blockade."
- [Feb
13, 1:14 PM]: I issued a formal Data Preservation Notice regarding
"raw" MAP assessment data to the Office of Assessment
Services and LCPS Administration. I explicitly cited the risk of spoliation
of evidence during an active OCR investigation and
warned that altering records would be construed as a violation
of FERPA.
- [Feb
13, 1:33 PM]: I filed a Formal Notice of Vendor Conflict
of Interest & Data Integrity Concern. I alerted the District
that its admission of "extracting and deleting" data on
the Qlik platform (a hostile vendor) constituted a
forensic emergency. I demanded an Integrity Audit to
ensure this deletion did not target Charles Rubis’s suicide
intervention records.
- [Feb
17, 7:15 AM]: I filed a Supplemental VDOE Filing (ODRAS) providing Exhibit
L (Transcript), which clinically impeached Principal Nick Cottone.
The transcript proved his October 13, 2023, statement to the District
(claiming no relationship to the family) was a Material
Misrepresentation and a violation of VA Code §
18.2-468.
- [Feb
18, 7:00 AM]: I sent a Final Notice of Statutory Breach
and Intent to Litigate to Dr. Aaron Spence and Division
Counsel. I formally notified the District that I was engaging local
Virginia counsel to file a Petition for Mandamus and
Injunction in Loudoun County General District Court to compel
the production of the 944 records for which payment was delivered on
Feb 12.
- [Feb
18, 7:00 AM (Concurrent)]: I filed a formal Request for
Vendor Debarment (QlikTech, Inc.) and a Demand for
the Termination of Nick Cottone for Administrative Fraud
under VA Code § 2.2-4321 and LCPS Policy 7561.
- [Feb
18, 8:42 AM]: The Virginia Department of Education (ODRAS) formally
notified LCPS (cc: Paige Carter) that information regarding my
February 12 complaint would be sent by February 24, 2026.
This No-Trespass order was issued on the exact day of the
VDOE's deadline to preempt the state's findings.
- [Feb
18, 11:46 AM]: The Virginia FOIA Advisory Council (via
Staff Attorney Matteo Murrelle) formally intervened in Case
#23, acknowledging the "critical role that time plays"
regarding LCPS’s constructive denial of records.
- [Feb
19, 11:53 AM]: I filed a Comprehensive OCR Addendum reporting
the "Digital Blockade" and the Mass Data Deletion of
my son’s life-safety records (specifically suicide intervention
history) coinciding with the February 9 federal filing.
- [Feb
23, 7:00 AM]: I provided LCPS with a formal Notice of
Administrative Risk, warning that any "manufactured safety
narratives" or "suppression of records" would be
documented as Aggravated Retaliation under 34
C.F.R. § 100.7(e).
- [Feb
23, 8:37 AM]: I filed a formal Attorney Ethics Grievance with
the New Jersey OAE against Feyi Obafemi
(QlikTech, Inc.) regarding the retroactive manufacture of
fraudulent employment records.
- [Feb
24, 2:26 PM]: The Virginia OAG formally referred my
complaint regarding QlikTech and Troxell Leigh to the Office
of the State Inspector General (OSIG) and the Virginia
State Bar.
- [Feb
24, 5:04 PM]: I sent a formal Objection to the Unilateral
Academic Career Plan (ACP), citing the administrative fraud of
Nick Cottone.
II. Forensic Refutation of "Safety" Pretext
and Fictitious Virtual Events
- Geographic
Reality: I reside in Chicago, Illinois, over 700 miles away. I
have never made a physical or verbal threat.
- Factual
Fabrication of "Virtual Events": Your letter cites the
cancellation of a "large group virtual meeting" as
justification. I have no knowledge of this event. I demand the
immediate production of the specific details of this alleged event.
III. Analysis of Retaliatory "Prior
Notices" (Sept 2024 & Dec 2025)
- September
2024 (Medical Crisis Notice): This was a notice that I was deathly
afraid of Nick Cottone. Using a victim's cry for safety as a
basis for a police ban is a violation of the ADA.
- December
2025 (IEP Violation Report): Reporting a violation of the IDEA is
a protected activity.
IV. Forensic Blockade: Larceny by Trick &
Obstruction of the Qlik Investigation LCPS accepted payment for
records on Feb 12/19, 2026, and subsequently utilized police
power to block their delivery. Payment was remitted for:
- Paid
Request R002480-012526: $376.80 (944 records
regarding coordination with Lindsay Mohler).
- Paid
Request R002437-121125: $153.08 (Records
involving Kate Ridgeway and Nick Cottone).
- Paid
Request R002450-122925: $29.82 (Halloween Bingo
records).
- Pending
Request R002510-021526: This request seeks Data Deletion
Logs, Vendor Ethics Disclosures, and internal
correspondence regarding QlikTech, Inc. By issuing a
No-Trespass ban, the District is attempting to avoid the production of
logs that would document the February 13 mass data deletion
event.
- Financial
Bad Faith: Under Va. Code § 18.2-178, obtaining funds
for FOIA production with the intent to block delivery via a police
order constitutes Larceny by Trick.
V. Evidence of Collusion, Administrative Fraud, and
Data Spoliation
- Documented
Fraud: Principal Nick Cottone’s false 2023 narrative has been
forensically impeached by physical evidence (Exhibit L).
- Audit
Log Evasion: This ban was issued specifically to avoid production
of the system audit logs which would reveal the
specific personnel responsible for the Feb 9 data scrub.
VI. Unlawful Criminalization of Protected
Whistleblower Advocacy The issuance of this No-Trespass Order is a
direct violation of my legal rights.
- Whistleblower
Protection: I have done nothing wrong; I am an investigative
publisher and a parent documenting systemic misconduct. This ban
represents a de facto act of Aggravated
Retaliation for taking legally protected action.
- State-Action
Collusion: This ban inappropriately intervenes in my private civil
matters. The mere existence of this letter illustrates private
collusion with Lindsay Mohler and Qlik designed
to suppress evidence and tip the scales of ongoing domestic
litigation.
- Parental
Alienation: The timing was calculated to prevent my attendance at
the Dominion HS Variety Show at my son's request. By
barring my access to ParentVue and SchooLinks,
LCPS is acting as an un-deputized agent of a private firm to
facilitate parental erasure.
DEMAND: I demand the immediate and total
recision of this No-Trespass Order. The use of police power to facilitate a
records blockade, hide the spoliation of life-safety data, and punitively
separate a father from his son's school performance is a Heinous Breach of
Public Trust.
Sincerely,
Steven Rubis
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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Wed, Feb 25, 2026 at 7:19 PM
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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
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Subject: SUPPLEMENTAL FORENSIC EVIDENCE: NOTICE OF
UNANSWERED CERTIFIED CORRESPONDENCE – Ref: Feb 24 No-Trespass Protest
Dear Mr. Clark,
In further refutation of your claim that my
communications are a "nuisance," please be advised that Loudoun
County Public Schools (LCPS) has a documented history of Administrative
Non-Responsiveness to formal, certified legal notices.
I hold six (6) USPS Certified Mail Return
Receipt "Green Cards" confirming that LCPS Leadership
was served with formal notices regarding the safety and rights of my
children, to which they have provided zero (0) responses. The
"volume" of my electronic communication is the direct result of
the District’s failure to acknowledge the following certified deliveries:
- Delivered
12/12/25: Tracking #9589071052700045357616 (Recipient: Aaron
Spence)
- Delivered
12/12/25: Tracking #9589071052700045357623 (Recipient: Aaron
Spence)
- Delivered
12/15/25: Tracking #9589071052700045357654 (Recipient: Aaron
Spence)
- Delivered
12/15/25: Tracking #9589071052700045357708 (Recipient: Aaron
Spence)
- Delivered
12/15/25: Tracking #9589071052700045357678 (Recipient: Kate
Ridgeway)
- Delivered
01/05/26: Tracking #9589071052700045357357 (Recipient: Aaron
Spence)
The District cannot ignore certified mail and then
weaponize police power to ban a parent for following up on the very safety
issues LCPS refused to address. This supplement is now a permanent part of
the administrative record.
Sincerely,
Steven Rubis
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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Wed, Feb 25, 2026 at 7:21 PM
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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
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Subject: URGENT CORRECTION: Forensic Tracking Data
for Certified Mail Receipts – Ref: Feb 24 No-Trespass Protest
Dear Mr. Clark,
Please find the corrected and complete USPS Tracking
Numbers for the six (6) Certified Mail notices delivered to LCPS
Leadership. The previous transmission contained truncated numbers; the
following are the verified 22-digit identifiers for the "Green
Cards" in my possession:
- Delivered
12/12/25: Tracking #9589 0710 5270 0045 3576 16 (Recipient: Aaron
Spence)
- Delivered
12/12/25: Tracking #9589 0710 5270 0045 3576 23 (Recipient: Aaron
Spence)
- Delivered
12/15/25: Tracking #9589 0710 5270 0045 3576 54 (Recipient: Aaron
Spence)
- Delivered
12/15/25: Tracking #9589 0710 5270 0045 3577 08 (Recipient: Aaron
Spence)
- Delivered
12/15/25: Tracking #9589 0710 5270 0045 3576 78 (Recipient: Kate
Ridgeway)
- Delivered
01/05/26: Tracking #9589 0710 5270 0045 3573 57 (Recipient: Aaron
Spence)
I maintain my demand for the immediate recision of the
No-Trespass order. The District’s documented failure to respond to these
specific certified deliveries remains the primary cause of the ongoing
communication volume.
Sincerely,
Steven Rubis
[Quoted text hidden]
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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Thu, Feb 26, 2026 at 10:09 PM
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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
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FORMAL FORENSIC OBJECTION & DEMAND FOR INTERNAL
INVESTIGATION
TO: 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
RIGHTS
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 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 MINORS
The 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 SUBPOENAS
LCPS 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 RETALIATION
The 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 REMEDY
I 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]
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250209 Troxel Leigh Legal Bill.pdf
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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Mon, Mar 2, 2026 at 10:06 AM
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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
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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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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Wed, Mar 4, 2026 at 9:43 AM
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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
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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]
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2 attachments
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260304 Guardian _ Loudoun County Public Schools
HRTD complaint number 21548.pdf
71K
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260304 HRTD Complaint form regarding John Clark
and no trespass order.pdf
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Steven Rubis <stevenrubis@gmail.com>
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John Clark <John.Clark@lcps.org>
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Wed, Mar 4, 2026 at 12:33 PM
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To: "stevenrubis@gmail.com"
<stevenrubis@gmail.com>
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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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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Fri, Mar 6, 2026 at 4:06 PM
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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
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This communication is being distributed to all
parties included in the February 24, 2024 correspondence to ensure a
complete administrative and forensic record. A hardcopy of this email will
be sent to Mark Bergin via USPS Certified Mail return receipt requested on
Saturday, March 7, 2026.
TO: Marc Bergin, Chief of Staff, Loudoun
County Public Schools
FROM: Steven Rubis
DATE: March 6, 2026
RE: FINAL NOTICE OF ADMINISTRATIVE DEFAULT
AND RATIFICATION: Criminal Obstruction of Statutory Investigations and
Tortious Interference
I. EXECUTIVE SUMMARY This is a final formal
escalation regarding the summary rejection of my February 28, 2026, appeal
by Director John Clark. On March 4, 2026, within 110 minutes of
being served with LCPS HRTD Workforce Complaint #21548, Mr.
Clark issued a summary denial. This sequence establishes a prima facie case
of Aggravated Retaliation for protected activity. By
failing to address or rebut the forensic evidence presented, the District
has Ratified a multi-agency conspiracy to protect the
private interests of QlikTech, Inc. and Lindsay
Mohler (Troxell Leigh P.C.).
II. THE DIGITAL BLOCKADE AS VENDOR PROTECTIONISM The
"Digital Blockade" issued on February 24, 2026, is a defensive,
retaliatory strike on behalf of government vendor QlikTech, Inc. and
its Associate General Counsel, Feyi Obafemi.
- Criminal
Obstruction: This blockade was issued within 48 hours of my
filing with the NJ Office of Attorney Ethics and
the Pennsylvania Disciplinary Board. By barring access to
the FOIA portal, the District is actively obstructing a statutory
investigative process.
- Larceny
by Trick & Conversion: LCPS accepted $559.70 for FOIA
Request R002510-021526. Utilizing police power to withhold
paid-for records constitutes Conversion and Larceny
by Trick (Va. Code § 18.2-178).
- Impediment
of Debarment: This blockade serves no safety purpose; its
sole function is to impede my whistleblower debarment petition against
QlikTech by suppressing integrity-related audit trails and the 944
records due on March 9.
- The
"365-Day" Investigatory Blackout: The one-year
duration is strategically calculated to "toll" active Bar
investigations and criminalize my constitutionally protected reporting
via Va. Code § 18.2-119.
III. CONSPIRATORIAL MISUSE OF POLICE POWER The
District has "rented" the enforcement power of the Loudoun
County Sheriff's Office and Leesburg Police to
facilitate a private legal advantage for Lindsay Mohler.
- The
12/12/23 Incident: Principal Nick Cottone coordinated
with Officer Timothy Iversen (LCSO) to unlawfully
interrogate me without a criminal predicate while I was in Chicago.
The planning of this interrogation occurred when no legal grounds
existed for such collaboration; it was a conspiratorial misuse of
police power to gain a private legal advantage for Ms. Mohler.
- State
Action Doctrine: This coordination establishes that LCPS is
operating as a State Actor on behalf of a private law
firm in violation of the 14th Amendment and 42
U.S.C. § 1983.
IV. TARGETED RETALIATION AGAINST A MINOR CHILD
(SECTION 504/ADA) The District is utilizing my son, Charles
Rubis, a student on an active IEP, as a retaliatory pawn.
- Targeting
of a Student: My son Charles Rubis confirmed that Principal
Nick Cottone singled him out during a Seneca Ridge Middle
School field trip (Feb 2026), specifically identifying him as
"Rex’s brother" to intimidate me during an active grievance.
- Milestone
Obstruction: The timing of the No-Trespass order (2/24) was
purposefully calculated to prohibit my attendance at Charles's Lowes
Island Elementary Variety Show (2/27) following my Federal
OCR Complaint on Feb 9. This constitutes Proximate
Retaliation against a child with a disability.
V. UNAUTHORIZED SURVEILLANCE AND ATTEMPT TO
"STARVE OUT" WHISTLEBLOWER The District’s retaliation
has extended beyond school boundaries into Professional Tortious
Interference with a business expectancy.
- Unauthorized
Professional Surveillance: Between February 24 and March 3,
2026, Loudoun County Public Schools emerged as one of
the top five most frequent searchers of my professional LinkedIn
profile.
- Intent
to "Starve Out": In the absence of a legitimate
educational or safety predicate, this surveillance is a malicious
attempt to "starve out" a whistleblower by
interfering with my job search. As communicated to Jennifer Painter
and Kate Ridgeway, this unauthorized stalking is actively impacting my
livelihood.
VI. COORDINATION WITH EXTERNAL INVESTIGATIONS &
DEMAND FOR ARTICULATION The District's non-responsiveness serves
as a Constructive Admission that LCPS is protecting its
vendor, QlikTech, Inc., and private counsel, Lindsay
Mohler.
- Demand
for Articulated Threat: I hereby demand the District articulate
the specific, credible threat I allegedly posed. Failure to
do so by March 9 will be treated as an admission that the security
pretext is a fraudulent fabrication.
VII. FINAL DEMAND FOR RELIEF Non-performance
by March 9, 2026, constitutes a final administrative default. I
hereby demand:
- Immediate
Rescission of the February 24 No-Trespass Order.
- Full
Delivery of the 944 paid FOIA records (R002510) and all other
pending FOIA requests.
- An
Independent Audit of all communications between LCPS
Administration, Principal Cottone, Officer
Iversen, Lindsay Mohler, and QlikTech (Qlik).
- Immediate
Preservation of all Synergy and FOIA portal audit logs.
VIII. NOTICE OF EVIDENTIARY AVAILABILITY AND
ANTI-RETALIATION SAFE HARBOR A comprehensive forensic file
supporting every assertion in this notice is maintained and available for
immediate inspection.
- Anti-Retaliation
Notice: This communication constitutes a protected activity
under Section 504 of the Rehabilitation Act, the ADA,
and Virginia whistleblower protection statutes.
- Whistleblower
Safe Harbor: Pursuant to federal and state law, the District
and its agents are hereby placed on notice that any further adverse
actions—including but not limited to continued digital obstruction,
professional surveillance, or the targeting of my minor child, Charles
Rubis—will be treated as willful acts of witness
intimidation and aggravated retaliation.
Respectfully,
Steven Rubis
[Quoted text hidden]
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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Fri, Mar 6, 2026 at 4:25 PM
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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
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Notice of Evidence Preservation
TO: Dan Adams, FOIA Officer, Loudoun County
Public Schools
CC: Marc Bergin, Chief of Staff; Jennifer
Painter, Division Counsel
RE: FORMAL NOTICE OF EVIDENCE PRESERVATION:
Records Cited in March 6 Rebuttal
DEAR MR. ADAMS,
Pursuant to the Final Notice of Administrative
Default served upon Marc Bergin today, you are hereby directed
to immediately preserve all electronically stored
information (ESI), metadata, and original records related to the following
forensic points:
- FOIA
R002510-021526: Preserve all 944 records identified for
production, including original metadata, audit trails, and version
histories to prevent spoliation prior to the March 9 deadline, as well
as all evidence associated with outstanding FOIA requests.
- Digital
Platform Access Logs: Preserve all login and activity logs
for the LCPS FOIA portal and ParentVUE (Synergy) from February 9,
2026, to the present.
- Surveillance
Metadata: Preserve all District-managed logs and search
histories regarding the monitoring of my professional LinkedIn profile
between February 24 and March 3, 2026.
- Coordinated
Communications: Preserve all communications (emails, SMS,
internal messaging) between LCPS Administration, Principal Nick
Cottone, and QlikTech, Inc. (specifically regarding
Feyi Obafemi), and Troxel Leigh P.C., including but not limited to
Lindsay Mohler and Gareth Bowen.
LEGAL WARNING: Any "routine
purging" or deletion of this data following this notice will be
documented as Willful Spoliation of Evidence in upcoming
state and federal proceedings.
Sincerely, Steven Rubis
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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Fri, Mar 6, 2026 at 4:39 PM
|
|
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
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TO: Marc Bergin, Chief of Staff
CC: Jennifer Painter, Kate Ridgeway, Dan
Adams, LCSO/Leesburg Police
DATE: March 6, 2026
RE: SUPPLEMENTAL NOTICE OF AGGRAVATED
RETALIATION: Immediate Targeting of Minor Child Beau Rubis
MR. BERGIN,
At approximately 4:25 PM ET today, I served you with
a Final Notice of Administrative Default regarding the
criminalization of my civil rights and the targeting of my son, Charles
Rubis.
At 4:34 PM ET—less than 10 minutes later—I
received a disciplinary email from Dr. Kate Ridgeway regarding
my other son, Beau Rubis, imposing an "alternate
recess" for Monday.
I. PROXIMATE RETALIATION The arrival of a
disciplinary notice regarding a second minor child within minutes of a
formal legal escalation against the District is a clear act of Proximate
Retaliation. This sequence proves that LCPS is utilizing its
disciplinary authority over students with disabilities as a weapon to
intimidate a whistleblower parent.
II. EXPANSION OF FORENSIC RECORD This
incident is being immediately added to:
- The
Federal OCR Complaint: As evidence of a District-wide pattern
of retaliating against the siblings of a student whose rights were
already violated.
- The
NJ and PA Bar Complaints: As proof of the "Aggravated
Malice" used by LCPS and its vendor-proxies to coerce a witness.
III. DEMAND FOR PRESERVATION I hereby demand
the immediate preservation of all internal communications (email, SMS, and
messaging) between Kate Ridgeway, Nick Cottone, and yourself between
4:00 PM and 4:40 PM ET today. The "10-minute window" between my
legal notice and this disciplinary action will be utilized as forensic
proof of State-Sanctioned Harassment.
IV. CEASE AND DESIST The District is hereby
ordered to Cease and Desist all retaliatory actions
against my minor children. Any attempt to alter Beau Rubis’s educational
environment or recess status on Monday will be treated as a willful
violation of the Anti-Retaliation Safe Harbor notice
served earlier this afternoon.
Respectfully,
Steven Rubis
[Quoted text hidden]
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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Fri, Mar 6, 2026 at 8:40 PM
|
|
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
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This communication is being distributed to all
parties included in the February 24, 2024 correspondence to ensure a
complete administrative and forensic record. A hardcopy of this email will
be sent to Mark Bergin via USPS Certified Mail return receipt requested on
Saturday, March 7, 2026.
TO: Marc Bergin, Chief of Staff
CC: Dan Adams, John Clark, Rae Mitchell,
Paige Carter, Nick Cottone, Kate Ridgeway, W. John Brewer, Neri Gonzalez,
Beth Robinson, LCSO/Leesburg Police
RE: ADDENDUM TO FINAL NOTICE: Material
Breach and Administrative Bad Faith
MR. BERGIN,
To complete the record for the weekend, please note the
following additional forensic discrepancies which further establish a
pattern of Coordinated Retaliation:
- Material
Breach of FOIA Contract: As noted in preliminary discussions
with the Virginia FOIA Advisory Council, the District’s acceptance
of $559.70 followed by the tactical use of a
"No-Trespass" order to block delivery constitutes a Material
Breach and implicates Va. Code § 18.2-178 (Larceny by
Trick). The District cannot "police-power" its way out
of a financial contract.
- Conflict
of Interest (John Clark): Director John Clark’s summary
rejection of my appeal—issued within 110 minutes of
being served with an HRTD complaint naming him—is a forensic admission
of Pre-Determined Bias. A decision rendered in such a
timeframe, while under an active workforce investigation, is a nullity
and a violation of administrative due process.
- Newsletter
Irregularity: I have noted that Principal Nick Cottone has
ceased all public newsletter communications since February 8,
2026, coinciding exactly with my Federal OCR filing on
February 9, 2026. This suggests an internal redirection of staff
to prioritize "litigation defense" over educational
transparency.
The District is reminded that "Incompetence"
is not a legal defense for the systematic targeting of a whistleblower's
children and the conversion of paid-for state records.
All deadlines previously cited for March 9, 2026,
remain in effect.
Respectfully,
Steven Rubis
[Quoted text hidden]
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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Mon, Mar 9, 2026 at 11:00 PM
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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
|
|
This communication is being distributed to all
parties included in the February 24, 2024 correspondence to ensure a
complete administrative and forensic record. A hardcopy of this email will
be sent to LCPS via USPS Certified Mail return receipt requested on Friday,
March 13, 2026.
Subject: FINAL NOTICE OF ADMINISTRATIVE
DEFAULT: Expiration of March 9 Deadline and Certification of Unrebutted
Facts
To: Marc Bergin, Dan Adams CC: Jennifer
Painter, Kate Ridgeway, Nick Cottone, John Clark, Rae Mitchell, Paige
Carter, W. John Brewer, Neri Gonzalez, Beth Robinson, LCSO/Leesburg Police
MR. BERGIN,
The deadline of March 9, 2026, set forth in my March 6
forensic rebuttal and supplemental addendum, has expired. The District has
failed to rescind the retaliatory No-Trespass order, deliver the 944
records (R002510), or rebut the forensic evidence of coordinated fraud.
I. NOTICE OF ADMINISTRATIVE DEFAULT AND RATIFICATION
- This
certification of default follows the summary rejection of my February
28, 2026, appeal by Director John Clark.
- On
March 4, 2026, within 110 minutes of being served
with LCPS HRTD Workforce Complaint #21548, Mr. Clark
issued a summary denial.
- This
sequence establishes a prima facie case of Aggravated
Retaliation for protected activity.
- By
failing to address or rebut the forensic evidence presented, the
District has Ratified a multi-agency conspiracy to
protect the private interests of QlikTech, Inc., Qlik
Associate General Counsel Feyi Obafemi, and Lindsay
Mohler (Troxell Leigh P.C.).
II. THE DIGITAL BLOCKADE AS VENDOR PROTECTIONISM The
"Digital Blockade" issued on February 24, 2026, is a defensive,
retaliatory strike on behalf of government vendor QlikTech, Inc. and
its Associate General Counsel, Feyi Obafemi.
- Criminal
Obstruction: This blockade was issued within 48 hours of my
filing with the NJ Office of Attorney Ethics and
the Pennsylvania Disciplinary Board.
- By
barring access to the FOIA portal, the District is actively
obstructing a statutory investigative process.
- Larceny
by Trick & Conversion: LCPS accepted $559.70 for FOIA
Request R002510-021526.
- Utilizing
police power to withhold paid-for records constitutes Conversion and Larceny
by Trick (Va. Code § 18.2-178).
- Impediment
of Debarment: This blockade serves no safety purpose; its
sole function is to impede my whistleblower debarment petition against
QlikTech by suppressing integrity-related audit trails and the 944
records due on March 9.
- The
"365-Day" Investigatory Blackout: The one-year
duration is strategically calculated to "toll" active Bar
investigations and criminalize my constitutionally protected reporting
via Va. Code § 18.2-119.
III. CONSPIRATORIAL MISUSE OF POLICE POWER The
District has "rented" the enforcement power of the Loudoun
County Sheriff's Office (LCSO) and Leesburg Police to
facilitate a private legal advantage for Lindsay Mohler.
- The
12/12/23 Incident: Principal Nick Cottone coordinated
with Officer Timothy Iversen (LCSO) to unlawfully
interrogate me without a criminal predicate while I was in Chicago.
- The
planning of this interrogation occurred when no legal grounds existed
for such collaboration; it was a conspiratorial misuse of police power
to gain a private legal advantage for Ms. Mohler.
- State
Action Doctrine: This coordination establishes that LCPS is
operating as a State Actor on behalf of a private law
firm in violation of the 14th Amendment and 42
U.S.C. § 1983.
- Sheriff's
Office Blockade: The LCSO is currently being utilized as an
instrument of obstruction to prevent my retrieval of paid FOIA records
regarding the Mohler-Cottone-Iversen nexus,
effectively criminalizing the retrieval of evidence of their own
misconduct.
IV. TARGETED RETALIATION AGAINST A MINOR CHILD
(SECTION 504/ADA) The District is utilizing my son, Charles
Rubis, a student on an active IEP, as a retaliatory pawn.
- Targeting
of a Student: My son Charles Rubis confirmed that Principal
Nick Cottone singled him out during a Seneca Ridge Middle
School field trip (Feb 2026), specifically identifying him as
"Rex’s brother" to intimidate me during an active grievance.
- Milestone
Obstruction: The timing of the No-Trespass order (2/24) was
purposefully calculated to prohibit my attendance at Charles's Lowes
Island Elementary Variety Show (2/27) following my Federal
OCR Complaint on Feb 9.
- This
constitutes Proximate Retaliation against a child
with a disability.
- Retaliation
Against Beau Rubis: Within 10 minutes of my
March 6 legal filing, I received a disciplinary notice from Dr.
Kate Ridgeway regarding my other son, Beau Rubis,
imposing an "alternate recess".
- This
sequence serves as a forensic marker of state-sanctioned harassment
against all children in the household.
V. UNAUTHORIZED SURVEILLANCE AND ATTEMPT TO
"STARVE OUT" WHISTLEBLOWER The District’s retaliation
has extended beyond school boundaries into Professional Tortious
Interference with a business expectancy.
- Unauthorized
Professional Surveillance: Between February 24 and March 3,
2026, Loudoun County Public Schools emerged as one of
the top five most frequent searchers of my professional LinkedIn
profile.
- Intent
to "Starve Out": In the absence of a legitimate
educational or safety predicate, this surveillance is a malicious
attempt to "starve out" a whistleblower by
interfering with my job search.
- This
unauthorized stalking is actively impacting my livelihood.
VI. PRIMA FACIE EVIDENCE OF VENDOR PROTECTIONISM AND
MATERIAL BREACH
- Administrative
Default of Certified Notices: This certification of default
is the result of LCPS’s failure to respond to seven (7) USPS
Certified Mail communications.
- This
creates an unrebutted record of Constructive Evasion.
- Evidence
from March 9 Invoice: At 4:23 PM today, FOIA
Officer Dan Adams issued Invoice #INV26-R002510-1 for $65.14 regarding
correspondence between LCPS and Qlik.
- This
invoice constitutes prima facie evidence that the
February 24 "Digital Blockade" was a retaliatory strike
issued on behalf of government vendor QlikTech, Inc. and
its employee, Feyi Obafemi.
- The
Litigation Paradox: The District’s willingness to continue
FOIA "business"—specifically regarding records documenting
collusion—while maintaining a police-enforced "security"
ban, proves the No-Trespass order is a retaliatory legal
fiction.
VII. FINAL DEMAND FOR RELIEF AND STATUS OF THE RECORD The
forensic record is now closed. The District’s non-responsiveness serves as
a Constructive Admission that LCPS is protecting QlikTech,
Inc., Qlik Associate General Counsel Feyi Obafemi, private
counsel Lindsay Mohler, and her law firm Troxell Leigh
P.C..
- Demand
for Articulated Threat: The District's failure to articulate
a specific, credible threat by the March 9 deadline is treated as an
admission that the security pretext is a fraudulent
fabrication.
- Certification
of Default: This record—supported by the District's own March
9 invoice—is being immediately submitted to the NJ Office of
Attorney Ethics, the PA Disciplinary Board, the VA
Office of the Attorney General, and the Federal OCR.
- Service
of Process: A hardcopy of this certification of default will
be served via USPS Certified Mail - Return Receipt Requested to
Marc Bergin on Friday, March 13, 2026.
VIII. COMPREHENSIVE SAFE HARBOR AND ANTI-RETALIATION
DECLARATION This communication constitutes a formal "Petition
for Redress of Grievances" protected under the First
Amendment of the U.S. Constitution and the Constitution of
Virginia.
- Protected
Activity: This notice is a protected activity under Section
504 of the Rehabilitation Act, the ADA, Va.
Code § 2.2-3011, and LCPS Policy 7561.
- Notice
of Witness Intimidation: Any attempt to utilize this forensic
record as a basis for criminal prosecution, civil litigation, or
family court retaliation by Lindsay Mohler, Feyi
Obafemi, Troxell Leigh P.C., the attorneys of
Troxell Leigh P.C., or QlikTech, Inc. will be
documented as a willful act of witness intimidation and
met with counter-claims for Abuse of Process and Malicious
Prosecution.
Respectfully,
Steven Rubis
[Quoted text hidden]
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260309 - FOIA request invoice created.pdf
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260309 - FOIA emails from LCPS - Gmail - LCPS
Service Request Updated __ R002510-021526.pdf
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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Wed, Mar 11, 2026 at 10:20 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
|
|
This communication is being distributed to all
parties included in the February 24, 2024 correspondence to ensure a
complete administrative and forensic record. A hardcopy of this email will
be sent to LCPS via USPS Certified Mail return receipt requested on Friday,
March 13, 2026.
Subject: FINAL CERTIFICATION OF ADMISSION
AND ENTRAPMENT: Forensic Confirmation of Public-Private Nexus and Demand
for Production
To: Marc Bergin, Dan Adams CC: Jennifer
Painter, Kate Ridgeway, Nick Cottone, John Clark, Matteo Murrelle,
LCSO/Leesburg Police
MR. BERGIN,
Following the expiration of the March 9 deadline and the
certification of your administrative default at midnight, the District’s
FOIA response at 3:26 PM, on Tuesday, March 10, 2026, serves as a Forensic
Admission of the State-Actor Collusion led by Lindsay Mohler and Troxell
Leigh P.C. This nexus explicitly includes QlikTech, Inc., its Associate
General Counsel Feyi Obafemi, the Loudoun County Sheriff’s Office (LCSO),
and LCPS.
I. ADMISSION OF STATE-ACTOR COLLUSION (R002480)
- Forensic
Admission of Nexus: By withholding 172 pages of correspondence
with private attorney Lindsay Mohler under a claim of Attorney-Client
Privilege (Va. Code § 2.2-3705.1(2)), the District has formally
admitted to an unlawful legal coordination with a private third party.
- Unlawful
Assertion of Privilege: I hereby certify for the record that
Lindsay Mohler, Troxell Leigh P.C., and their associated attorneys are
not employees of LCPS and do not represent LCPS in any official
capacity. LCPS has no legal claim to exert privilege over
communications with an unrelated private attorney regarding private
civil matters involving myself and my ex-wife.
- Prima
Facie Admission of the "Renting" of Public Resources:
The assertion of privilege represents a prima facie admission of the
"renting" of LCPS and LCSO to facilitate private legal
interests and cause me physical and legal harm in December 2023. There
was no legal or safety predicate for Mohler to be in communication
with Nick Cottone (Principal, Seneca Ridge MS) or Timothy Iversen
(LCSO); rather, legal billing records and Cottone’s October 13, 2023
administrative fraud (falsifying reports to superiors to create a
"threat" profile) illustrate that this privilege is being
asserted solely to shield the unlawful coordination between LCPS,
LCSO, Mohler, and Troxell Leigh P.C.
- Motive
for Lawless Obstruction: By claiming attorney-client privilege
over these communications and issuing a retaliatory No-Trespass order,
LCPS is explicitly admitting to a State-Actor relationship. The only
reason LCPS would claim false privilege and issue a No-Trespass order
is to ensure I am unable to obtain the evidence uncovered regarding
these FOIA requests; the contents are so damaging to LCPS and the
other actors, including but not limted to Lindsay Mohler, Gareth
Bowen, Troxel Leigh P.C., QlikTech, Inc., Qlik associate counsel Feyi
Obafemi, and LCSO, involved that the District has chosen to break the
law to block the release of this data. This represents a significant
Civil Rights violation under 42 U.S.C. § 1983.
- The
Digital Link to Qlik and Obafemi: The expansion of the February 24
No-Trespass order to encompass all LCPS digital platforms serves as
the explicit forensic link to QlikTech, Inc. and Feyi Obafemi. By
utilizing police power to terminate my access to the FOIA portal, the
District is performing a defensive, retaliatory strike on behalf of
its vendor to suppress integrity-related audit trails and the 944
records currently in default, as well as additional FOIA requests
which now encompass 1,141+ responsive records.
II. INCORPORATION OF FOIA COUNCIL OPINION
- Individual
Liability (§ 2.2-3714): The Council notes that courts hold
individuals accountable for "willful and knowing" violations
based on their specific actions.
- Bad
Faith Stonewalling: The decision to withhold 944 paid records
while inviting further payment constitutes the type of
"stonewalling" and "bad faith" penalized in Harki
v. VDOC.
- Contractual
Material Breach: Utilizing a police-enforced
"No-Trespass" order to void a financial contract is a
Material Breach (4A M.J. Contracts § 73).
III. NOTICE OF ENTRAPMENT AND DEMAND FOR PHYSICAL
PRODUCTION
- Refusal
to Participate in Digital Entrapment: I will not log in to the
portal, as the February 24 No-Trespass order prohibits my access to
LCPS digital platforms. Any invitation to log in is a bad-faith
attempt to manufacture a "trespass" violation.
- Consolidated
Demand for Physical Delivery: I hereby demand the immediate
physical mailing of all 1,141+ responsive records from R002510,
R002480, R002437, and R002450.
- Larceny
by Trick: Retention of my $559.70 while seeking further payments
for Qlik-related records constitutes Larceny by Trick (Va. Code §
18.2-178).
IV. SAFE HARBOR AND NOTICE OF PRESERVATION
- First
Amendment Protection: This communication is a protected Petition
for Redress of Grievances under the U.S. and Virginia Constitutions.
- Anti-Retaliation
Safe Harbor: This notice is a protected activity under Section
504, the ADA, and Va. Code § 2.2-3011.
- Evidence
Preservation: You are hereby directed to preserve all native
files, metadata, and communications involving Lindsay Mohler, Troxell
Leigh P.C., QlikTech, Inc., Feyi Obafemi, and the Loudoun County
Sheriff's Office.
Respectfully,
Steven Rubis
[Quoted text hidden]
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2 attachments
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VA FOIA Council - Informal Opinion Final -
Rubis.docx
23K
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260310 Gmail - LCPS Service Request Updated __
R002480-012526.pdf
108K
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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Fri, Mar 13, 2026 at 8:57 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
|
|
This communication is being distributed to all
parties included in the February 24, 2024 correspondence to ensure a
complete administrative and forensic record. A hardcopy of this email will
be sent to LCPS via USPS Certified Mail return receipt requested on Friday,
March 13, 2026.
FORMAL OBJECTION TO PROPOSED IEP MEETING AND NOTICE
OF AGGRAVATED RETALIATION
DATE: March 13, 2026
VIA: USPS Certified Mail – Return Receipt
Requested
RE: CANCELLATION OF APRIL 7 IEP MEETING; OBJECTION TO
RETALIATORY MATRICULATION; AND NOTICE OF PERSONAL LIABILITY
This communication serves as a formal objection to the
communications received from Mara Moreland and Cheryl Shotwell on March
12/13, 2026. These communications are being incorporated into my
pending Federal OCR Complaint and VDOE/ODRAS filings
as evidence of a coordinated effort to deprive me of my Parental Rights
under the IDEA and Section 504.
I. VOIDANCE OF UNILATERAL SCHEDULING (PROCEDURAL
VIOLATION) Ms. Moreland’s email stating she has
"scheduled" a meeting for April 7 is a violation of the IDEA’s
requirement for "Meaningful Parental Participation."
1. Administrative Accommodation Ignored: I
have repeatedly requested administrative accommodations regarding Ms.
Moreland due to her history of excluding me from IEP proceedings (Nov
2023).
2. The Digital Trap: Ms. Moreland
provided only a virtual Google Meet link. As of February 24, 2026, I am
under a No-Trespass Order from John Clark that prohibits my access to "all
LCPS digital platforms." By forcing me into a digital-only
meeting while threatening me with criminal trespass for using digital
platforms, LCPS is engaged in Bad-Faith Entrapment.
3. Conflict of Interest: Ms. Moreland
is the subject of an active workforce complaint. Her continued involvement
in my son’s file is a retaliatory strike.
II. OBJECTION TO RETALIATORY MATRICULATION (SENECA
RIDGE) Any discussion or presumption that my son, Charles, will
matriculate to Seneca Ridge Middle School represents Aggravated
Retaliation against both myself and my minor child.
- Safety
Predicate: Principal Nick Cottone (Seneca Ridge) is a named
respondent in my Federal OCR complaint and a primary actor in the
fraudulent "Paper Trap" coordination with LCSO.
- Prior
Retaliation: On February 12, 2026, Mr. Cottone targeted and
interrogated my son in retaliation for my protected advocacy.
- Notice
of Objection: I formally object to any placement that puts my
child under the administrative authority of Nick Cottone. Any attempt
by LCPS to force this matriculation will be treated as a willful act
to cause emotional and educational harm to a student with a disability.
III. NOTICE OF PERSONAL LIABILITY Be advised
that the "Shield of Office" does not protect individual employees
who willfully violate established Civil Rights and Federal Safeguards.
- **
Mara Moreland, Cheryl Shotwell, Dr. Kate Ridgeway and involved
supervisors are hereby put on notice:** Your participation in this
coordinated "Digital Blockade" and the attempt to force a
retaliatory school placement opens you to personal liability under
42 U.S.C. § 1983 for the deprivation of rights under color of law.
- Safe
Harbor: This response is a protected activity under Va.
Code § 2.2-3011 and the Anti-Retaliation provisions
of the ADA.
IV. DEMAND FOR REMEDY
- Rescind the
April 7 meeting notice immediately.
- Remove Mara
Moreland from my son’s case per my previous accommodation requests.
- Provide an
alternative, neutral matriculation path that bypasses Seneca Ridge
Middle School to ensure my son’s safety and my ability to participate
in his education without the threat of retaliatory police
intervention.
Sincerely,
Steven Rubis
[Quoted text hidden]
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2 attachments
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260313 Moreland email about IEP meeting.pdf
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260313 shotwell seneca ridge email.pdf
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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Fri, Mar 13, 2026 at 2:39 PM
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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>
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This communication is being distributed to all
parties included in the February 24, 2024 correspondence to ensure a
complete administrative and forensic record. A hardcopy of this email will
be sent to LCPS via USPS Certified Mail return receipt requested on Friday,
March 13, 2026.
FORMAL OBJECTION TO PREDETERMINED IEP MEETING AND
NOTICE OF DIGITAL ENTRAPMENT (BEAU RUBIS)
DATE: March 13, 2026
VIA: USPS Certified Mail – Return Receipt
Requested
RE: CANCELLATION OF APRIL 13 IEP MEETING; NOTICE OF
PROCEDURAL SAFEGUARD VIOLATIONS; AND AGGRAVATED RETALIATION (BEAU RUBIS)
This communication serves as a formal objection to the
email received from Celesta Lewis on March 13, 2026, regarding my son, Beau
Rubis. This notice is being incorporated into my pending Federal
OCR Complaint as further evidence of a coordinated effort by
Loudoun County Public Schools (LCPS) to utilize a "Digital
Blockade" to facilitate the parental erasure and professional
harassment of a whistleblower.
I. BAD-FAITH DIGITAL ENTRAPMENT The
scheduling of this meeting for April 13 represents a calculated attempt at
legal entrapment.
- The
Conflict of Orders: Ms. Lewis has provided a Google Meet
virtual link for a mandated IEP meeting. However, the February
24, 2026, No-Trespass Order issued by John Clark explicitly forbids my
access to "all LCPS digital platforms" and "virtual
resources".
- The
Trap: By providing a virtual-only link for a mandatory parental
meeting while maintaining a criminal ban on my use of digital
resources, LCPS is attempting to manufacture a criminal trespass
violation. I will not participate in this digital entrapment.
II. VIOLATION OF PROCEDURAL SAFEGUARDS &
PREDETERMINATION
Under the IDEA, parents must be afforded "Meaningful
Participation" in the IEP process.
- Unilateral
Scheduling: Dictating a meeting time without regard for
parental availability or the current administrative blockade
constitutes Predetermination and a systemic failure
of procedural safeguards.
- Constructive
Exclusion: By maintaining a police-enforced ban that prevents
me from accessing the digital data required for IEP preparation—and
then scheduling a meeting via those same banned platforms—LCPS has
constructively excluded me from my son’s educational team.
III. NOTICE OF PERSONAL LIABILITY & AGGRAVATED
RETALIATION This communication follows my recent formal reports of
administrative fraud and vendor collusion involving QlikTech, Inc. and
LCPS.
- Retaliatory
Pincer: Using my second son’s IEP meeting as a tool for
further harassment constitutes Aggravated Retaliation.
- Personal
Liability: Celesta Lewis and her supervisors are hereby put
on notice: Participation in a coordinated "Digital Blockade"
to strip a parent of civil and educational rights under color of law
carries personal liability under 42 U.S.C. § 1983.
IV. DEMAND FOR REMEDY
- Rescind the
April 13 meeting notice for Beau Rubis immediately.
- Cease all
attempts to utilize digital-only "virtual links" as a
substitute for meaningful participation while the digital No-Trespass
order remains in effect.
- Provide a
neutral, third-party physical or non-LCPS digital venue for all future
meetings to ensure the safety and participation of all parties.
Sincerely,
Steven A. Rubis
[Quoted text hidden]
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260313 lewis about Beau IEP.pdf
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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Sat, Mar 14, 2026 at 8:38 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>
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Subject: SUPPLEMENTAL NOTICE: Forensic
Admission of Visitation Interference and Multi-Pronged Retaliation
(R002480-012526)
TO: Marc Bergin, Dan Adams CC: Jennifer
Painter, Kate Ridgeway, Nick Cottone, John Clark, Matteo Murrelle,
LCSO/Leesburg Police
MR. BERGIN,
I am in receipt of the March 13 correspondence
(attached) regarding the cancellation of my court-ordered visitation for
the weekend of March 20–22. This cancellation is the direct and intended
result of the Public-Private Nexus and the
retaliatory No-Trespass order maintained by the District.
I. ADMISSION OF INTERFERENCE WITH PARENTAL RIGHTS
- Manufactured
Conflict: Sporting events for my children have been scheduled
at LCPS facilities during my legally prescribed visitation. Because
the District maintains a pretextual No-Trespass order against me—an
order that was expanded to digital platforms to block FOIA access—I am
physically and legally barred from these locations.
- State-Actor
Nexus in Family Law: The District’s refusal to rescind this
order, while simultaneously coordinating with private attorney Lindsay
Mohler (as evidenced by the 172-page
"privileged" correspondence admission), has resulted in
the de facto termination of my parental visitation.
II. BLATANT RETALIATION AGAINST PROTECTED STUDENTS
& WHISTLEBLOWER
- Retaliation
Against Charles and Beau Rubis: This interference constitutes
blatant retaliation against my children, both of whom are protected
under IEPs.
- Retaliation
for Protected Activity: This conduct is a direct response
to Charles Rubis reporting the intimidation he
endured at the hands of Nick Cottone on February 12,
2026, immediately following my Federal OCR complaint against
Mr. Cottone on February 9.
- Violation
of Consent: On February 12, the District willfully violated
my revocation of consent regarding Charles’s transport to Mr.
Cottone’s school. The subsequent No-Trespass order and the current
denial of my visitation are the "secondary strikes" intended
to silence these reports.
- Corporate
Protectionism (Qlik/Obafemi): This "Digital
Blockade" is also blatant retaliation for my debarment
request against QlikTech, Inc. and the Bar Complaints filed
against Feyi Obafemi. The District is utilizing police
power to protect a corporate vendor and its employees from statutory
oversight and ethical accountability.
III. NOTICE OF ENTRAPMENT AND DEMAND FOR REMEDY
- Immediate
Rescission: I hereby demand the immediate rescission of
the February 24, 2026 No-Trespass order. It is being utilized as a
mechanical tool for parental alienation, corporate protectionism, and
student retaliation.
- Material
Breach & Larceny by Trick: Retention of my $559.70 while
utilizing a No-Trespass order to block access to the records
constitutes Larceny by Trick (Va. Code § 18.2-178) and
a Material Breach of contract.
- Consolidated
Demand for Production: I reiterate my demand for the physical
mailing of all 1,141+ responsive records from the
defaulted FOIA requests to my address in Chicago.
IV. SAFE HARBOR AND NOTICE OF PRESERVATION
- First
Amendment Protection: This communication is a protected Petition
for Redress of Grievances.
- Anti-Retaliation
Safe Harbor: This notice is a protected activity under Section
504, the ADA, and Va. Code § 2.2-3011.
- Evidence
Preservation: You are hereby directed to preserve all
communications involving Nick Cottone, Lindsay Mohler, Feyi
Obafemi, and QlikTech, Inc. regarding the
coordination of this obstruction and visitation interference.
Respectfully,
Steven Rubis
[Quoted text hidden]
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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Fri, Mar 27, 2026 at 5:16 PM
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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>
|
|
COMPREHENSIVE MASTER NOTICE: CERTIFICATION OF
AGGRAVATED RETALIATION, ADMINISTRATIVE FRAUD, AND SYSTEMIC STATUTORY
VIOLATIONS
DISTRIBUTION NOTICE: This communication is
being distributed to all parties included in previous correspondence, as
well as Superintendent Dr. Aaron Spence, the Loudoun
County School Board, LCPS Legal Counsel, and the LCPS
Ombuds to ensure a complete administrative and forensic record. A
hardcopy of this notice will be sent to Marc Bergin via USPS
Certified Mail - Return Receipt Requested on either March
30, 2026.
Date: March 27, 2026
Subject: COMPREHENSIVE MASTER NOTICE:
Certification of No Legal Predicate, Selective Enforcement, and
Multi-Pronged Statutory Violations (R002480 / No-Trespass 2/24)
TO: Marc Bergin, Dan Adams
CC: John Clark, Rae Mitchell, Paige Carter,
Nick Cottone, Kate Ridgeway, W. John Brewer, Neri Gonzales, Beth Robinson,
LCSO, Leesburg Police, Dan Adams, Mara Moreland, Celesta Lewis, Aaron
Spence, LCPS School Board, LCPS Legal, LCPS Ombudsman
MR. BERGIN,
I am in receipt of the return receipt "green
card" confirming your delivery of my March 13 certified mail on March
20, 2026. This represents the ninth (9th) USPS Certified Mail communication
sent to the District that has failed to elicit a response. Your continued
administrative silence certifies a bad-faith "Public-Private
Nexus" in violation of the following:
- Federal: 42
U.S.C. § 1983; 29 U.S.C. § 794 (Section 504); 42 U.S.C. § 12132 (ADA).
- State
of Virginia: Va. Code § 2.2-3700 (VFOIA); Va. Code § 18.2-178
(Larceny by Trick); Va. Code § 2.2-3011.
- LCPS
Policy: 1030 (Parental Involvement); 8040 (Student Rights);
2350 (Conflict of Interest).
I. CERTIFICATION OF ABSOLUTE LACK OF LEGAL PREDICATE
- Zero
Jurisdictional History: I hereby certify for the record that
there are no active legal cases or actions, and
there never have been any such actions in the past,
involving my children, my parental rights, or my custody situation
within the Loudoun County Court system.
- Unlawful
Nexus: Consequently, there is no lawful reason or legal
predicate for the existence of 1,141+ responsive records of
communication between private attorney Lindsay Mohler and LCPS.
- Fraudulent
Privilege Claim: Because Ms. Mohler is a private attorney
with no representative contract or employment with LCPS, the assertion
of Attorney-Client Privilege in the March 10 FOIA
response (withholding 172 pages) is false, fraudulent, and an unlawful
attempt to shield state-actor collusion.
- Administrative
Fraud (Ridgeway): This lack of predicate stands in direct
contrast to the multiple workforce complaints I have filed
against Principal Dr. Kate Ridgeway for explicit,
retaliatory comments stating that I should "expect to have [my]
parental rights changed."
II. EVIDENCE OF SELECTIVE ENTRAPMENT & AGGRAVATED
RETALIATION
- Solicitation
of Funds (Brewer): At 6:05 PM CT on March 25, 2026,
I received a voicemail from John Brewer (Principal,
Dominion HS), an individual explicitly copied on the February 24
No-Trespass order, soliciting me for financial sponsorship for the
"Dominion Golf Classic." Under LCPS Policy 2350,
the District cannot logically define an individual as a
"threat" necessitating police-enforced exclusion while
simultaneously soliciting that individual for capital and community
partnership. This solicitation waives any claim of a safety predicate.
- Coordinated
State Harassment (VA DSS): On March 20—the same day LCPS
received my ninth certified mail—a retaliatory threat was issued
via VA DSS alleging I was in "arrears" for
support. I certify that I am not in arrears; this administrative
"error" is documented as Aggravated Retaliation timed
to my protected activity with LCPS.
- SchooLinks/IEP
Entrapment (March 27): The District issued a demand today for
"critical" participation in Charles Rubis’s course
plan and Beau Rubis's IEP via digital platforms I am
currently blocked from accessing. Providing Google Meet links for
mandatory meetings while maintaining a criminal ban on my use of
digital resources constitutes Bad-Faith Entrapment and
a violation of Section 504/ADA mandates.
III. SYSTEMIC RETALIATION AGAINST PROTECTED STUDENTS
& WHISTLEBLOWER
- Retaliation
Against Charles and Beau Rubis: This interference constitutes
blatant retaliation against my children, both of whom are protected
under IEPs.
- The
February 12 Incident: The current "Digital
Blockade" is a secondary strike for Charles Rubis reporting
intimidation by Nick Cottone on February 12, 2026,
following my Federal OCR complaint. The District's willful
violation of my revoked consent for transport on that date constitutes
a continuous retaliatory strike.
- Corporate
Protectionism (Qlik/Feyi Obafemi): This blockade is a
defensive strike on behalf of vendor QlikTech, Inc. and
its Associate General Counsel, Feyi Obafemi, to suppress
integrity-related audit trails and my pending debarment
request. This blockade was issued within 48 hours of my filing
with the NJ Office of Attorney Ethics and the Pennsylvania
Disciplinary Board against Ms. Obafemi.
IV. MATERIAL BREACH & LARCENY BY TRICK
- Retention
of Funds: Retention of my $559.70 while
utilizing a No-Trespass order to block access to records
constitutes Larceny by Trick (Va. Code § 18.2-178) and
a Material Breach of contract, as supported by the
informal opinion of the Virginia FOIA Advisory Council.
- Conspiratorial
Misuse of Police Power (12/12/23): Principal Nick
Cottone coordinated with Officer Timothy Iversen
(LCSO) to unlawfully interrogate me without a criminal
predicate while I was in Chicago to gain a private legal advantage
for Lindsay Mohler.
V: FINAL DEMAND FOR REMEDY
- Immediate
Rescission: I reiterate my demand for the immediate
rescission of the February 24, 2026 No-Trespass order.
- Administrative
Accommodation: I demand immediate administrative
accommodation for all matters involving my children’s education,
including SchooLinks and IEP processes, to be handled by a neutral
party away from the influence and authority of Nick Cottone,
Kate Ridgeway, and Seneca Ridge MS. As documented in my
previous notices and active workforce complaints, the continued
involvement of these individuals—given the 12/12/23 interrogation and
subsequent retaliatory acts—constitutes a systemic conflict of
interest and a violation of LCPS Policy 2350.
- Physical
Production: Produce all 1,141+ records via
physical mail to my address in Chicago.
- Waiver
of Fees: I demand the waiver of all additional fees for the
Qlik-related records (R002450) as a partial cure for the District’s
default.
- Evidence
Availability: Comprehensive forensic evidence supporting
every claim in this notice is available upon request.
- Non-Waiver: My
participation in any mandated student proceedings via restricted
digital platforms is done under duress and does not constitute
a waiver of my standing objection.
VI. SAFE HARBOR AND NOTICE OF PRESERVATION
This is a protected Petition for Redress of
Grievances. You are directed to preserve all native files and
communications involving Nick Cottone, Lindsay Mohler, Feyi
Obafemi, Kate Ridgeway, John Brewer, Troxel Leigh P.C., and
QlikTech, Inc. regarding this coordination.
Respectfully, Steven Rubis
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Steven Rubis <stevenrubis@gmail.com>
|
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Steven Rubis <stevenrubis@gmail.com>
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Fri, Mar 27, 2026 at 5:28 PM
|
|
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>
|
|
ADMINISTRATIVE NOTE: This communication
represents an update to the administrative record to correct an error
in the previous email regarding the specific forensic details of FOIA
Request R002480-012526.
COMPREHENSIVE MASTER NOTICE: CERTIFICATION OF
AGGRAVATED RETALIATION, ADMINISTRATIVE FRAUD, AND SYSTEMIC STATUTORY
VIOLATIONS
DISTRIBUTION NOTICE: This communication
is being distributed to all parties included in previous
correspondence, as well as Superintendent Dr. Aaron Spence,
the Loudoun County School Board, LCPS Legal Counsel,
and the LCPS Ombuds to ensure a complete
administrative and forensic record. A hardcopy of this notice will be
sent to Marc Bergin via USPS Certified Mail - Return Receipt
Requested on either March 30, 2026.
Date: March 27, 2026
Subject: COMPREHENSIVE MASTER NOTICE:
Certification of No Legal Predicate, Selective Enforcement, and
Multi-Pronged Statutory Violations (R002480 / No-Trespass 2/24)
TO: Marc Bergin
CC: John Clark, Rae Mitchell, Paige
Carter, Nick Cottone, Kate Ridgeway, W. John Brewer, Neri Gonzalez,
Beth Robinson, LCSO, Leesburg Police, Dan Adams, Mara Moreland, Celesta
Lewis, Aaron Spence, LCPS School Board, LCPS Legal, LCPS Ombudsman
MR. BERGIN,
I am in receipt of the return receipt "green
card" confirming your receipt of my March 13 certified mail on
March 20, 2026. This represents the ninth (9th) USPS Certified Mail
communication sent to the District that has failed to elicit a response.
Your continued administrative silence certifies a bad-faith
"Public-Private Nexus" in violation of the following:
- Federal: 42
U.S.C. § 1983; 29 U.S.C. § 794 (Section 504); 42 U.S.C. § 12132
(ADA).
- State
of Virginia: Va. Code § 2.2-3700 (VFOIA); Va. Code §
18.2-178 (Larceny by Trick); Va. Code § 2.2-3011.
- LCPS
Policy: 1030 (Parental Involvement); 8040 (Student
Rights); 2350 (Conflict of Interest).
I. CERTIFICATION OF ABSOLUTE LACK OF LEGAL
PREDICATE
- Zero
Jurisdictional History: I hereby certify for the record
that there are no active legal cases or actions, and
there never have been any such actions in the past,
involving my children, my parental rights, or my custody situation
within the Loudoun County Court system.
- Unlawful
Nexus (R002480): Per the District’s March 10 response,
LCPS located records of correspondence between private
attorney Lindsay Mohler (@tllawpc.com) and the
District's executive and administrative staff. These records were
identified using the specific search terms "Steven
Rubis," "Seneca Ridge Middle School," and "workforce
complaint." Because there is no litigation in
Loudoun County, and these records involve myself and my children,
there is no lawful reason or legal predicate for the existence
of 1,141+ responsive records of communication
between private attorney Lindsay Mohler and LCPS.
- Fraudulent
Privilege Claim: Because Ms. Mohler is a private attorney
with no representative contract or employment with LCPS, the
assertion of Attorney-Client Privilege in the
March 10 FOIA response (withholding 172 pages) is false,
fraudulent, and an unlawful attempt to shield state-actor
collusion.
- Administrative
Fraud (Ridgeway): This lack of predicate stands in direct
contrast to the multiple workforce complaints I have filed
against Principal Dr. Kate Ridgeway for explicit,
retaliatory comments stating that I should "expect to have
[my] parental rights changed."
II. EVIDENCE OF SELECTIVE ENTRAPMENT &
AGGRAVATED RETALIATION
- Solicitation
of Funds (Brewer): At 6:05 PM CT on March 25,
2026, I received a voicemail from John Brewer (Principal,
Dominion HS), an individual explicitly copied on the February 24
No-Trespass order, soliciting me for financial sponsorship for the
"Dominion Golf Classic." Under LCPS Policy 2350,
the District cannot logically define an individual as a
"threat" necessitating police-enforced exclusion while
simultaneously soliciting that individual for capital and
community partnership. This solicitation waives any claim of a
safety predicate.
- Coordinated
State Harassment (VA DSS): On March 20—the same day LCPS
received my ninth certified mail—a retaliatory threat was issued
via VA DSS alleging I was in "arrears"
for support. I certify that I am not in arrears; this
administrative "error" is documented as Aggravated
Retaliation timed to my protected activity with LCPS.
- SchooLinks/IEP
Entrapment (March 27): The District issued a demand today
for "critical" participation in Charles Rubis’s course
plan and Beau Rubis's IEP via digital platforms I
am currently blocked from accessing. Providing Google Meet links
for mandatory meetings while maintaining a criminal ban on my use
of digital resources constitutes Bad-Faith Entrapment and
a violation of Section 504/ADA mandates.
III. SYSTEMIC RETALIATION AGAINST PROTECTED
STUDENTS & WHISTLEBLOWER
- Retaliation
Against Charles and Beau Rubis: This interference
constitutes blatant retaliation against my children, both of whom
are protected under IEPs.
- The
February 12 Incident: The current "Digital
Blockade" is a secondary strike for Charles Rubis reporting
intimidation by Nick Cottone on February 12,
2026, following my Federal OCR complaint. The
District's willful violation of my revoked consent for transport
on that date constitutes a continuous retaliatory strike.
- Corporate
Protectionism (Qlik/Feyi Obafemi): This blockade is a
defensive strike on behalf of vendor QlikTech, Inc. and
its Associate General Counsel, Feyi Obafemi, to
suppress integrity-related audit trails and my pending debarment
request. This blockade was issued within 48 hours of my filing
with the NJ Office of Attorney Ethics and
the Pennsylvania Disciplinary Board against Ms.
Obafemi.
IV. MATERIAL BREACH & LARCENY BY TRICK
- Retention
of Funds: Retention of my $559.70 while
utilizing a No-Trespass order to block access to records
constitutes Larceny by Trick (Va. Code § 18.2-178) and
a Material Breach of contract, as supported by
the informal opinion of the Virginia FOIA Advisory Council.
- Conspiratorial
Misuse of Police Power (12/12/23): Principal Nick
Cottone coordinated with Officer Timothy Iversen
(LCSO) to unlawfully interrogate me without a criminal
predicate while I was in Chicago to gain a private legal advantage
for Lindsay Mohler.
V. FINAL DEMAND FOR REMEDY
- Immediate
Rescission: I reiterate my demand for the immediate
rescission of the February 24, 2026 No-Trespass order.
- Administrative
Accommodation: I demand immediate administrative
accommodation for all matters involving my children’s education,
including SchooLinks and IEP processes, to be handled by a neutral
party away from the influence and authority of Nick
Cottone, Kate Ridgeway, and Seneca Ridge MS. As
documented in my previous notices and active workforce complaints,
the continued involvement of these individuals—given the 12/12/23
interrogation and subsequent retaliatory acts—constitutes a
systemic conflict of interest and a violation of LCPS
Policy 2350.
- Physical
Production: Produce all 1,141+ records via
physical mail to my address in Chicago.
- Waiver
of Fees: I demand the waiver of all additional fees for
the Qlik-related records (R002450) as a partial cure for the
District’s default.
- Evidence
Availability: Comprehensive forensic evidence supporting
every claim in this notice is available upon request.
- Non-Waiver: My
participation in any mandated student proceedings via restricted
digital platforms is done under duress and
does not constitute a waiver of my standing
objection.
VI. SAFE HARBOR AND NOTICE OF PRESERVATION
This is a protected Petition for Redress of
Grievances. You are directed to preserve all native files and
communications involving Nick Cottone, Lindsay Mohler, Feyi
Obafemi, Kate Ridgeway, John Brewer, Troxel Leigh P.C., and QlikTech,
Inc. regarding this coordination.
Respectfully,
Steven Rubis
|
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|

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Steven Rubis <stevenrubis@gmail.com>
|
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Steven Rubis <stevenrubis@gmail.com>
|
Mon, Mar 30, 2026 at 2:51 PM
|
|
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>
|
|
Dear Mr Bergin,
I just called and left you a voice mail message in
regards to the non responsiveness of LCPS to my nine USPS Certified Mail
return receipt requested letters sent to LCPS.
Additionally, my voice mail inquites about the
fraudulent no trespass order issued by your office on February 24, 2026.
Here is the tracking number for my 9th USPS Certified
Mail return receipt requested letter to LCPS
Tracking: 9589071052704032075408
Please advise as to when I can expect a response. At
this point, LCPS has committed several acts of aggravated retaliation
against me in response to my undertaking legally protected action. The
fraudulent no-trespass order among them. LCPS has failed to provide any
clarification or justification of the no trespass order illustrated by this
email chain.
Steve Rubis
|
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|

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Steven Rubis <stevenrubis@gmail.com>
|
|
Steven Rubis <stevenrubis@gmail.com>
|
Wed, Apr 1, 2026 at 4:05 PM
|
|
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>
|
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SUPPLEMENTAL NOTICE: CERTIFICATION OF FINANCIAL
LARCENY, ADMINISTRATIVE ENTRAPMENT, AND TORTIOUS INTERFERENCE
ADMINISTRATIVE NOTE: This communication
represents a formal update to the administrative record and is a
protected Petition for Redress of Grievances.
Date: April 1, 2026
Subject: SUPPLEMENTAL NOTICE: Forensic
Admission of Selective Communication, Financial Larceny, and Professional
Surveillance (Reference # R002480-012526)
TO: Marc Bergin
CC: Dr. Aaron Spence, LCPS School Board,
LCPS Legal, LCPS Ombuds, HRTD, LCSO, Leesburg Police, et al.
MR. BERGIN,
I am in receipt of an automated "Negative Meal
Account Balance Notice" dated April 1, 2026, demanding $8.60.
This communication, sent while the District ignores nine certified notices
(this email will mark 10 notices) and 20 pages of forensic evidence,
certifies the following:
I. FINANCIAL LARCENY AND MATERIAL BREACH
- Retention
of FOIA Funds: The District continues to retain $559.70 of
my personal funds for records (R002450) while utilizing the February
24 No-Trespass order to block my access to those very records.
- Bad-Faith
Financial Demands: It is a violation of Va. Code §
18.2-178 (Larceny by Trick) for the District to withhold over
$500 in paid services while simultaneously issuing automated demands
for an $8.60 meal debt.
II. PROFESSIONAL TORTIOUS INTERFERENCE AND ECONOMIC
DAMAGES
- Systemic
Blacklisting: I have applied to over 1,835
executive-level roles for which I am highly qualified, yet I
have been rejected from all. This is a direct result of the District’s
fraudulent "threat" label and police-enforced exclusion.
- Unauthorized
Stalking: Between February 24 and March 3, 2026, LCPS was
documented as a primary viewer of my professional LinkedIn profile.
This surreptitious monitoring constitutes Tortious
Interference with Business Expectancy.
III. CONSTITUTIONAL DEPRIVATION OF DUE PROCESS (VFOIA
PORTAL)
- Statutory
Infringement: Because LCPS requires the use of a digital
portal to submit and retrieve records, the "Digital
No-Trespass" order effectively criminalizes my exercise of rights
under the Virginia Freedom of Information Act (Va. Code §
2.2-3700).
- Due
Process Violation: Utilizing police power to block a
citizen's access to the mandatory statutory portal for government
transparency constitutes a Deprivation of Due Process under
the 14th Amendment. The District cannot legally utilize a local
administrative order to nullify a state-mandated statutory right.
IV. ADMINISTRATIVE ENTRAPMENT AND SOLICITATION OF
CRIME
- Solicitation
of Trespass: The 4/1/26 notice directs me to pay by
"logging into your student's meal account". Since the
District's "Digital Blockade" criminalizes my access to LCPS
platforms, this demand constitutes a documented attempt to solicit
a misdemeanor trespass violation.
- Selective
Enforcement: The District’s ability to automate financial
demands while claiming a "security-based" inability to
respond to forensic evidence of fraud proves the No-Trespass order is
a fraudulent instrument of retaliation.
V. SAFE HARBOR AND ANTI-RETALIATION PROTECTIONS
- Whistleblower
Status: This filing is a protected activity under Va.
Code § 2.2-3011 and LCPS Policy 7561. Any
"adverse action" taken by LCPS, Marc Bergin, private
counsel Lindsay Mohler, QlikTech, Inc. (Qlik),
or Feyi Obafemi in response to this notice will be
documented as Aggravated Retaliation.
- Non-Waiver: My
response to your financial solicitations is done under duress to
preserve my children's access to nutrition and does not constitute
a waiver of my standing objection to the No-Trespass order.
VI. FINAL DEMAND FOR REMEDY Rescind the
No-Trespass order immediately and produce physical copies of the
1,141+ responsive records and all responsive records associated with all of
my outstanding FOIA requests to my address in Chicago. The
District has placed me in an illogical and illegal position: LCPS refuses
to respond to my evidence, yet if I exercise my parental rights, comply
with your financial demands, or attempt to exercise my statutory rights
under VFOIA, I face criminal prosecution. This is an unlawful and
unconstitutional use of police power to suppress a citizen's protected
activity.
Respectfully, Steven Rubis
|
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Steven Rubis <stevenrubis@gmail.com>
|
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Steven Rubis <stevenrubis@gmail.com>
|
Mon, Apr 6, 2026 at 12:19 PM
|
|
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>
|
|
VIA EMAIL AND USPS CERTIFIED MAIL (RETURN RECEIPT
REQUESTED)
DATE: April 6, 2026
RE: FORMAL OBJECTION TO IEP MEETING SCHEDULED FOR
APRIL 7, 2026; NOTICE OF PROCEDURAL VIOLATIONS; AND DECLARATION OF
PERSONAL LIABILITY
To the Loudoun County Public School (LCPS)
Administration:
This letter serves as a formal objection and Notice
of Non-Participation regarding the Individualized Education
Program (IEP) meeting unilaterally scheduled for my son, Charles Rubis,
on April 7, 2026. Please be advised that any attempt to convene this
meeting in my absence—or under the current conditions of digital and
physical exclusion—constitutes a willful violation of federal and state
law, including the Individuals with Disabilities Education Act (IDEA),
Section 504 of the Rehabilitation Act, and the Virginia Administrative
Code (8VAC20-81-170).
I. Timeliness of Objection and Administrative
Estoppel
LCPS is hereby estopped from claiming this objection
is untimely or that the District was unaware of my scheduling conflict. I
provided immediate written notice of my objection to this meeting via
email on March 13, 2026, less than 48 hours after the initial
notice was sent by Mara Moreland. Furthermore, I sent formal
documentation and a restatement of this objection via USPS
Certified Mail (Return Receipt Requested), which was confirmed as
received by LCPS on March 20, 2026.
LCPS has had sixteen (16) days to respond to my
objection and has willfully chosen to remain silent. By ignoring these
communications and attempting to proceed with the meeting on April 7,
LCPS is engaging in a "bad-faith" maneuver intended to manufacture
a record of "parental non-cooperation" while I am being
actively ignored by administration.
II. Violation of Mandated Parental Participation
(IDEA & 8VAC20-81-170)
Under federal law (34 CFR § 300.501) and state
regulation (8VAC20-81-170), LCPS is legally mandated to ensure
that the parent of a child with a disability is a member of any group
that makes decisions on the educational placement of the child.
Furthermore, 8VAC20-81-170(B) requires LCPS to schedule
meetings at a "mutually agreed on time and place."
By dictating a date and time without consultation and
refusing to acknowledge or respond to my March 13th and March 20th
notices, LCPS is in direct violation of these procedural safeguards. I
have Joint Legal Custody as affirmed in my Marital
Settlement Agreement (Case No. CL21-6851) and the resulting Final Order
of Divorce. My participation is a non-discretionary legal requirement;
proceeding without me is a calculated attempt to bypass federal law and
predetermine my son’s educational outcomes.
III. The "Digital Trap" and the
Fraudulent No-Trespass Order
On February 24, 2026, John Clark issued a
"No-Trespass" order that purports to cover all physical and
digital platforms of LCPS. While I have timely appealed this
order—appeals which were summarily denied in under 110 minutes or ignored
entirely—it remains in effect as a tool of administrative exclusion.
By providing a Google Meet link for a
mandatory meeting while simultaneously forbidding my access to all LCPS
digital platforms under the February 24 order, LCPS has created a
"Digital Blockade" and a "Bad-Faith Entrapment." I
cannot "attend" a virtual meeting on a platform from which I am
legally barred by your own Security Director. This is a manufactured
effort to exclude me from my son’s IEP process.
IV. Documented Pattern of Systematic Exclusion
(2023-2026)
The current exclusion is not an isolated incident but
a continuation of a pattern previously acknowledged by LCPS. As
documented in correspondence with Dr. Kate Puschak and Chrystal Thompson
in May 2024, LCPS was previously put on notice regarding "unprofessional
and biased behavior" and the failure to provide documentation prior
to IEP meetings for over two years.
My records from May 1 and May 7, 2024, prove that
staff had already established a history of discriminatory behavior based
on my status as a divorced father. Repeating these exact failures in
2026, after they were formally brought to your attention in 2024,
demonstrates a willful and systematic violation of civil
rights. Furthermore, I formally object to the participation of Mara
Moreland, who is the subject of open workforce complaints and a
history of prohibiting my participation (dating back to November 2023),
creating a clear conflict of interest under LCPS Policy 2350.
V. State-Actor Nexus, Administrative Fraud, and
Obstruction (Va. Code § 2.2-3011, § 18.2-460)
On March 10, 2026, Dan Adams (LCPS)
issued a FOIA response explicitly claiming attorney-client
privilege over communications between the District and Lindsay
Mohler of the firm Troxel Leigh P.C. Because
Lindsay Mohler and Troxel Leigh P.C. are private counsel for my ex-wife
and do not represent LCPS, this claim is a legal impossibility and an
explicit admission of a state-actor nexus.
This collusion is a "backdoor" attempt to
bypass the IDEA Procedural Safeguards (34 CFR § 300.501),
which mandate parental inclusion in decision-making groups. Furthermore,
I cite Va. Code § 18.2-460 (Obstructing Justice), as this
collusion with private counsel is a clear attempt to impede the
administration of justice in my ongoing legal matters. This constitutes
"Abuse" under the Virginia Fraud and Abuse Whistle
Blower Protection Act (Va. Code § 2.2-3011), defined as the arbitrary
use of an agency to serve the personal purpose of a third party.
VI. Retaliation and Physical Misconduct (ADA &
Va. Code § 22.1-289.044)
There is an active Federal OCR complaint regarding
Principal Nick Cottone. This complaint includes a recent
incident where Mr. Cottone inappropriately sought out my son and physically
touched him during an event for which I had explicitly revoked
consent for my son's participation.
Under Section 504 of the Rehabilitation Act and Va.
Code § 22.1-289.044, it is unlawful for a school division to
retaliate or discriminate against any person who in good faith complains
regarding the treatment of a student with a disability. The physical
interference with my son by an administrator currently under investigation
for retaliation—coupled with the fraudulent No-Trespass order—represents
an egregious breach of safety and law.
VII. Notice of Personal Legal Liability
"Qualified Immunity" does not protect
officials who willfully violate clearly established constitutional and
statutory rights. Each participant in the April 7 meeting is hereby
placed on notice that they are acting outside the scope of their authority
and are subject to personal civil liability for First Amendment
retaliation and witness intimidation. I intend to seek all available
remedies, including "SLAPP-back" litigation
under Virginia’s updated Anti-SLAPP statutes and personal civil actions
against the individuals named herein.
VIII. Safe Harbor and Whistleblower Declaration
This communication is a Protected Activity and
a report of suspected wrongdoing under Va. Code § 2.2-3011.
It is sent in good faith to correct a record of administrative abuse. Any
attempt to use the volume of these filings as a basis for further
"nuisance" sanctions will be documented as Aggravated
Retaliation for a communication crisis manufactured by the District’s own
non-responsiveness.
REQUIRED ACTION:
- CANCEL the
IEP meeting scheduled for April 7, 2026.
- RESCHEDULE for
a date and time that is mutually agreeable.
- VACATE the
No-Trespass order to allow for my meaningful participation.
- REMOVE Mara
Moreland from this case immediately.
Failure to comply will result in an immediate filing
of a Due Process Complaint and the inclusion of these events in all
pending Federal OCR investigations, and future Federal OCR Complaint
filings.
Sincerely,
Steven Rubis
(Joint Legal Custodian)
(202) 997-4815
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|

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Steven Rubis <stevenrubis@gmail.com>
|
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Steven Rubis <stevenrubis@gmail.com>
|
Tue, Apr 7, 2026 at 2:05 PM
|
|
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>
|
|
VIA EMAIL (URGENT - FORENSIC RECORD)
DATE: April 7, 2026
RE: NOTICE OF PROCEDURAL BUST; FORMAL OBJECTION TO
SHAM IEP PROCEEDINGS; AND SUPPLEMENTAL EVIDENCE OF PREDETERMINATION
To the Loudoun County Public School (LCPS)
Administration:
This letter serves as a formal follow-up to the IEP
meeting LCPS unilaterally attempted to convene today, April 7, 2026, at
1:30 PM. As established in my notices dated March 13, March 20, and April
6, I was not available for this meeting, and my participation was
effectively prohibited by the District’s own "Digital Blockade."
Any results from today's meeting are void ab initio.
I. Timeliness of Objection and Actual Notice to
Leadership
LCPS is hereby estopped from claiming ignorance of my
scheduling conflicts or the fraudulent nature of these proceedings. I
provided immediate written notice of objection on March 13, 2026,
and formal documentation via USPS Certified Mail (Return Receipt
Requested) confirmed as received by LCPS on March 20, 2026.
Furthermore, in mid-March 2026, I left a
detailed voicemail for Chief of Staff Marc Bergin—as directed
by the appeal process in the February 24 No-Trespass letter—specifically
referencing the USPS certified documents and the retaliatory nature of the
No-Trespass order. LCPS leadership has had "Actual Notice" for
over two weeks and chose to remain silent until four hours before today's
meeting.
II. Denial of Review Time and Contact Information
Manipulation
At 9:36 AM today, less than four hours prior to the 1:30
PM meeting, Mara Moreland emailed a draft IEP. Providing a document of this
legal magnitude on the morning of a meeting is a per se denial of
"meaningful parental participation" under 34 CFR §
300.501. No parent can forensically review an IEP or consult with
counsel in a four-hour window, especially when LCPS has ignored my
objections for sixteen (16) days. Dr. Coranassario’s voicemail today
requesting a "call back" further highlights the administrative
hypocrisy of demanding digital participation while maintaining a
"Digital Blockade."
Additionally, Dr. Coranassario placed a call today to
my 214-681-7991 number. This proves that LCPS possesses my
correct contact data in ParentVUE, yet for the period of 2023–2025, LCPS
willfully listed my ex-wife’s cellular number as my own contact
information. This historical manipulation of my records, combined with the
current "Digital Blockade" preventing me from verifying my own
data in ParentVUE, is evidence of a long-term strategy to interfere with my
custodial rights and parental standing.
III. Supplemental Evidence of Predetermination (The
Shotwell Email)
The email from Cheryl Shotwell sent
yesterday, April 6, at 1:28 PM, serves as a "smoking gun." By
finalizing course requests and assigning my son to "Seneca Middle
school counselors" 24 hours before today’s transition
meeting, LCPS has admitted that today's proceedings were a
"sham." You cannot "discuss" a transition that you have
already officially finalized in your internal systems
(SchooLinks/ParentVue). This is Administrative Fraud.
IV. Documented Pattern of Systematic Misconduct
(2023-2026)
As established in May 2024 correspondence with Dr. Kate
Puschak and Chrystal Thompson, LCPS was previously put on notice regarding
the "unprofessional and biased behavior" and the failure to
follow IEP protocols. Mara Moreland’s admission today of a
"delay" in providing the draft is a continuation of this pattern.
Furthermore, I renew my objection to the participation of Ms. Moreland, who
is the subject of open workforce complaints for previously excluding me
from the IEP process.
V. State-Actor Nexus & Anti-SLAPP Protection (Va.
Code § 8.01-223.2)
The collusion between Dan Adams (LCPS) and
private counsel Lindsay Mohler (Troxel Leigh P.C.), as admitted
in the March 10 FOIA response, establishes a State-Actor Nexus.
You are using the machinery of the state to assist a private party in
violating my parental rights.
This communication is a Protected Statement regarding
matters of public concern under Virginia’s Anti-SLAPP Statute (Va.
Code § 8.01-223.2). Any attempt to use my volume of speech or the
"No-Trespass" order to silence this advocacy will result in
"SLAPP-back" litigation where I will seek recovery of all
attorney fees and punitive damages against the individuals involved.
VI. Criminal Obstruction & Personal Liability
(Va. Code § 18.2-460)
By using a fraudulent "No-Trespass" order to
prevent me from participating in a federal IEP process, you are Obstructing
Justice (Va. Code § 18.2-460) and impeding the administration of
the IDEA. "Qualified Immunity" does not protect officials who
willfully violate clearly established constitutional and statutory rights.
Every participant in today’s 1:30 PM meeting is acting outside the scope of
their authority and is subject to personal civil liability for First
Amendment retaliation and witness intimidation.
VII. Retaliation and Physical Misconduct (Nick
Cottone)
There is an active Federal OCR complaint regarding
Principal Nick Cottone, including a recent incident where he
inappropriately sought out and physically touched my son
during an event where I had explicitly revoked consent for participation.
Forcing matriculation to Seneca Ridge under these circumstances is a
violation of Va. Code § 22.1-289.044.
VIII. Safe Harbor and Whistleblower Declaration
This communication is a Protected Activity and
a report of "Abuse" under Va. Code § 2.2-3011,
defined as the arbitrary and capricious use of an agency to serve the
personal purposes of a third party (Lindsay Mohler/Troxel Leigh P.C.).
REQUIRED IMMEDIATE ACTION:
- VOID all
minutes, decisions, or placement changes from the April 7, 2026,
meeting.
- RE-OPEN the
Course Planner and provide a non-digital alternative for my
participation.
- RESCHEDULE the
IEP for a mutually agreeable time with a lawful review period.
- REMOVE Mara
Moreland from this case.
Sincerely,
Steven Rubis
(Joint Legal Custodian)
(214) 681-7991
(202) 997-4815
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|
|

|
Steven Rubis <stevenrubis@gmail.com>
|
|
Steven Rubis <stevenrubis@gmail.com>
|
Wed, Apr 8, 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>
|
|
VIA EMAIL (URGENT - FORENSIC RECORD)
DATE: April 7, 2026
RE: FORMAL OBJECTION TO IEP MEETING FOR BEAU RUBIS
(APRIL 13, 2026); NOTICE OF PROCEDURAL NON-COMPLIANCE; AND EVIDENCE OF
SELECTIVE COMMUNICATION
To the Loudoun County Public School (LCPS)
Administration:
This letter serves as a formal objection and Notice
of Non-Participation regarding the IEP meeting for my son, Beau
Rubis, scheduled for Monday, April 13, 2026. This response is necessitated
by the email received from Celesta Lewis today at 3:14 PM and supplements
my prior objections sent on March 13, March 20, and April 6, 2026.
I. Timeliness of Objection and Actual Notice
LCPS has been in possession of my formal objection to
the April 13, 2026, meeting date for nearly four weeks. I provided
immediate notice via email on March 13, 2026, and formal
documentation via USPS Certified Mail (Return Receipt Requested),
confirmed as received by LCPS on March 20, 2026. Furthermore,
my mid-March voicemail to Chief of Staff Marc Bergin explicitly
referenced these documents and the fraudulent nature of the No-Trespass
order. Celesta Lewis’s email today proves that LCPS intends to willfully
ignore these scheduling conflicts and proceed in a manner that deprives me
of my right to "meaningful participation" under 34 CFR §
300.501.
II. Evidence of Selective Communication and
Administrative Fraud
Today, Dr. Lucy Coranassario placed a
phone call to my 214-681-7991 number. Additionally, at
2:09 PM today, I received an automated instructional update from
"Coach Dixon" via the Remind system. These actions prove that
LCPS possesses the technical means and verified contact information to
communicate with me.
Despite this, LCPS continues to willfully ignore my
legally significant communications, including my USPS Certified Mail.
Furthermore, the fact that LCPS utilized my 214 number today proves the
District has had access to my correct data, exposing the period from
2023–2025—where LCPS listed my ex-wife’s cellular number as my own—as a
period of intentional identity obfuscation and
interference with my Joint Legal Custody (Case No.
CL21-6851).
III. The "Digital Blockade" as
Administrative Entrapment
Ms. Lewis’s email provides a "link for you to
attend via video conference." As I have repeatedly informed LCPS,
the February 24, 2026, No-Trespass Order issued by John
Clark purports to bar my presence from "all digital platforms."
By scheduling a meeting exclusively via video conference while maintaining
a legal order that criminalizes my digital presence, LCPS is engaging
in Administrative Entrapment. You are attempting to manufacture
a record of "non-attendance" while simultaneously maintaining a
digital blockade that prevents my entry into the virtual meeting space.
IV. State-Actor Nexus & Anti-SLAPP Protection
(Va. Code § 8.01-223.2)
The collusion between Dan Adams (LCPS) and
private counsel Lindsay Mohler (Troxel Leigh P.C.), as admitted
in the March 10 FOIA response, establishes a State-Actor Nexus.
This communication is a Protected Statement regarding
matters of public concern (child welfare and governmental abuse)
under Virginia’s Anti-SLAPP Statute (Va. Code § 8.01-223.2).
Any attempt to use my volume of speech or the "No-Trespass" order
to silence this advocacy will result in "SLAPP-back" litigation.
V. Criminal Obstruction & Personal Liability (Va.
Code § 18.2-460)
By using a fraudulent "No-Trespass" order to
prevent me from participating in a federal IEP process, you are Obstructing
Justice (Va. Code § 18.2-460) and impeding the administration of
the IDEA. "Qualified Immunity" does not protect officials who
willfully violate clearly established constitutional and statutory rights.
Every administrator who proceeds with a meeting for Beau Rubis on April 13
without my participation is acting outside the scope of their authority and
is subject to personal civil liability.
VI. Safe Harbor and Whistleblower Declaration
This communication is a Protected Activity and
a report of "Abuse" under the Virginia Fraud and Abuse
Whistle Blower Protection Act (Va. Code § 2.2-3011).
REQUIRED IMMEDIATE ACTION:
- CANCEL the
IEP meeting for Beau Rubis scheduled for April 13, 2026.
- RESCHEDULE for
a date and time that is mutually agreeable, as mandated by 8VAC20-81-170(B).
- VACATE the
No-Trespass order and provide an administrative accommodation that
ensures my lawful participation in my children’s education.
Sincerely,
Steven Rubis (Joint Legal Custodian) (214)
681-7991 (202) 997-4815
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|
|

|
Steven Rubis <stevenrubis@gmail.com>
|
|
Steven Rubis <stevenrubis@gmail.com>
|
Mon, Apr 13, 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>
|
|
NOTICE OF FORENSIC ADMISSION AND DEMAND FOR IMMEDIATE
ADMINISTRATIVE CURE
ADMINISTRATIVE NOTE: This communication is a
protected Petition for Redress of Grievances under the
First Amendment and is submitted in the public interest.
DATE: April 13, 2026
RE: VFOIA Request R002480-012526 /
Certification of State-Actor Nexus and Retaliatory Obstruction
MR. BERGIN,
The March 10, 2026, FOIA response (R002480) issued by
Dan Adams constitutes a self-authenticating forensic admission of
administrative fraud and civil rights violations. This response provides
the "smoking gun" proof that the February 24 No-Trespass order is
a retaliatory tool utilized to protect private interests and obstruct the
release of records for which I have already provided payment.
I. ADMISSION OF THE STATE-ACTOR NEXUS (172 PAGES) The
District has withheld 172 pages of records citing Attorney-Client
Privilege (Va. Code § 2.2-3705.1(2)) regarding correspondence with
private attorney Lindsay Mohler and Troxell Leigh
P.C..
- The
Forensic Fact: There are no active or past legal matters
involving my children or custody in the Loudoun County Court system.
- The
Legal Admission: By asserting privilege over communications
with a private third party who has no representative standing in this
jurisdiction, LCPS has admitted to a Public-Private Nexus.
This coordination transforms Lindsay Mohler into a State Actor
under 42 U.S.C. § 1983.
II. PROFESSIONAL TORTIOUS INTERFERENCE AND
WHISTLEBLOWER DEBARMENT
- Temporal
Proximity of Retaliation: On February 19, 2026, I
submitted a formal request for the Administrative Debarment of QlikTech,
Inc. (Qlik) to LCPS, documenting the fraud committed by Feyi
Obafemi. Just five days later, on February 24, 2026,
the District issued the No-Trespass order. This timeline establishes
a prima facie case of retaliation for whistleblower
activity.
- Notification
of Litigation (Case # 2024-17511): My debarment request
included the Notice to Defend – Civil (Montgomery County, PA) filed
against Qlik. While this matter was withdrawn without prejudice to
avoid the financial duress of meritless sanctions, the underlying
forensic facts of the fraud remain active and were formally reported
to the District as a predicate for debarment.
- The
Bar Complaint Trigger: I filed formal Bar Complaints against
Feyi Obafemi in Pennsylvania within and New Jersey on within hours and
days of the District’s decision to issue the No-Trespass order. The
District’s attempt to criminalize my digital presence is an
extra-legal effort to interfere with these active licensing
investigations and protect a vendor from the consequences of its
documented fraud.
- Statistical
Proof of Economic Sabotage: As of April 12, 2026, I have been
rejected from 1,915 executive-level roles. My conversion
rate has collapsed to an 85% rejection rate in April 2026.
This surge in rejections correlates directly with LCPS’s decision to
utilize police power to shield Qlik and Lindsay Mohler from the legal
petitions I have filed against them.
II. NO-TRESPASS AS A TOOL OF EVIDENCE
SUPPRESSION AND UNLAWFUL PROTECTION The February 24 No-Trespass
order and the "Digital Blockade" serve no legitimate safety
purpose. They are tactical instruments of Retaliatory Obstruction designed
to:
- Unlawful
Protection of Private Parties: To provide a state-enforced
shield for private entities, including but not limited to Lindsay
Mohler, Troxell Leigh P.C., and the District's
vendor QlikTech, Inc. (Qlik), thereby obstructing
whistleblower oversight and legal accountability.
- Facilitate
Financial Larceny: To block my access to the FOIA portal to
prevent me from retrieving records for which LCPS has already accepted
and retained $559.70 in payment. This
constitutes Larceny by Trick under Va. Code § 18.2-178.
III. STATUTORY AND CONSTITUTIONAL PROTECTIONS (SAFE
HARBOR)
- Whistleblower
Protection: This communication is protected under Va.
Code § 2.2-3011 and LCPS Policy 7561.
- Anti-SLAPP
Immunity: Statements made herein regarding LCPS, Lindsay
Mohler, Qlik, and Feyi Obafemi are
protected by Va. Code § 8.01-223.2, as they concern
matters of public concern and the reporting of government misconduct.
- Due
Process Violation: Because LCPS requires a digital portal for
FOIA, the "Digital No-Trespass" order criminalizes the
exercise of my rights under the Virginia Freedom of
Information Act (Va. Code § 2.2-3700).
IV. ADMINISTRATIVE CONTRADICTION AND GEOGRAPHIC
ABSURDITY The District’s claim that I am a "security
threat" is forensically invalidated by the District’s own actions and
the physical reality of my domicile:
- Geographic
Impossibility: I reside in Chicago, IL,
over 700 miles from Loudoun County. The assertion
that a non-resident parent living half a continent away poses a
physical "threat" to school buildings is an administrative
absurdity. The "Digital No-Trespass" is clearly a tool of
evidence suppression and unlawful protection of private parties, not
security.
- Financial
Solicitation: On March 25, Principal John Brewer solicited
me for financial sponsorship, a violation of the integrity standards
in LCPS Policy 2350.
- Selective
Demands: On April 1, the District issued a demand for
an $8.60 meal balance in contradiction of the relief
procedures in LCPS Policy 6130.
- Professional
Surveillance: Between Feb 24 and March 3, LCPS conducted
surreptitious LinkedIn surveillance of my
professional profile while I remained rejected from 1,835 jobs due
to the District’s fraudulent "threat" label.
V. PROFESSIONAL TORTIOUS INTERFERENCE AND AGGRAVATED
ECONOMIC DAMAGES
- Statistical
Proof of Blacklisting: As of April 12, 2026, I have been
rejected from 1,915 executive-level roles for which I
am objectively qualified. My rejection metrics show a statistically
anomalous surge: while my rejection conversion rate was 8% in 2025, it
escalated to 35% in Q1 2026, and has reached a staggering 85%
in April 2026 to date.
- Correlation
with Unauthorized Surveillance: This 85% rejection surge
directly correlates with the period in which LCPS was documented as a
primary viewer of my professional LinkedIn profile (Feb 24 – March 3,
2026). I am attaching the March Investor Relations (IR) Job
Market Stats presentation deck as forensic evidence of the
market landscape and the targeted nature of this interference.
- Intentional
Interference with Business Expectancy: The District’s
maintenance of a fraudulent "security threat"
label—maintained despite my 700-mile geographic distance in Chicago—is
a calculated attempt to sabotage background checks and executive
vetting processes. This constitutes Tortious Interference with
Business Expectancy with measurable damages exceeding
millions in lost executive compensation.
- The
"Starve Out" Strategy: The District has the
capacity to monitor my professional profile and automate demands
for $8.60, yet it utilizes a "Digital Blockade"
to obstruct my whistleblower debarment petition and my parental
rights. This is a bad-faith effort to "starve out" a
whistleblower by sabotaging my professional reputation.
VI. FINAL DEMAND FOR REMEDY Rescind the
No-Trespass order immediately and produce physical copies of the
responsive records associated with all of my outstanding FOIA requests to
my address in Chicago. The District has placed me in an illogical and
illegal position: LCPS refuses to respond to my evidence, yet if I exercise
my parental rights, comply with your financial demands, or attempt to
exercise my statutory rights under VFOIA, I face criminal prosecution.
STRICTLY CERTIFIED: This represents an unlawful and
unconstitutional use of police power to suppress a citizen's protected
activity and a total deprivation of Due Process.
VII. RATIFICATION OF MISCONDUCT AND STATE-ACTOR NEXUS
(COTTONE & IVERSEN)
- Administrative
Shielding of Physical Misconduct (Nick Cottone): The
No-Trespass order and "Digital Blockade" function as a
retaliatory shield for Principal Nick Cottone. As
documented in the active Federal OCR complaint, Mr.
Cottone inappropriately sought out and physically touched my son
during a school event where I had explicitly revoked consent for
participation. LCPS has utilized the No-Trespass order to prevent me
from seeking an administrative remedy for this physical violation,
thereby ratifying Cottone's misconduct.
- Evidence
of Collusion (Tim Iversen): The FOIA response of March 10,
2026, which admits to withholding 172 pages of coordination with Lindsay
Mohler, provides the forensic link to the actions of Tim
Iversen. Mr. Iversen’s role in the administrative
"blacklisting" and his coordination with private counsel to
manipulate school records represents a clear State-Actor Nexus under 42
U.S.C. § 1983.
- The
"Disruption" Pretext: It is a manifest absurdity
for LCPS to characterize the reporting of physical misconduct
(Cottone) and legal collusion (Iversen) as a "nuisance" or
"disruption." I am not "disrupting" school
operations; I am documenting the District’s refusal to follow its own
safety and legal protocols, including LCPS Policy 2350 and Policy
7561.
VIII. RATIFICATION OF UNLAWFUL THREATS AND
ADMINISTRATIVE DEFAULT
1. Forensic
Deposit of Evidence: I am providing a Summary PDF highlighting
the specific subset of emails and Google Meet transcripts where Dr.
Kate Ridgeway and my ex-wife issued incendiary threats to
terminate my parental rights. The full 454-page Workforce Complaint
Record is provided via the secure download link below as a
forensic deposit, as LCPS has ignored this evidence no fewer than ten (10)
times in the past year.
2. Ratification
via No-Trespass: The February 24 No-Trespass order represents a
formal administrative ratification of these private threats. LCPS has
knowingly utilized its "police power" to execute a private legal
objective shared by my ex-wife, her counsel Lindsay Mohler, and
Dr. Ridgeway.
- Forensic
Record of Premeditated Threats: I have previously submitted
a 454-page PDF documenting explicit threats from my
ex-wife and Dr. Kate Ridgeway to LCPS leadership no
fewer than ten (10) times over the past year. This record establishes
a clear timeline of intent to terminate my parental rights and
interfere with my visitation.
- Explicit
Threats by Dr. Kate Ridgeway: Between 2024 and 2025, Dr.
Ridgeway utilized both email and Google Meet sessions to issue
incendiary threats regarding my parental standing, acting in direct
coordination with my ex-wife’s private legal objectives.
- The
"Unprofessional" Pretext as a Shield: LCPS’s
characterization of my advocacy as "unprofessional" in the
February 24 No-Trespass order is a fraudulent administrative shield.
You are attempting to utilize a "conduct" label to justify a
total refusal to investigate documented violations of state and
federal law.
- Ongoing
Administrative Default: Because LCPS has failed to provide
any resolution or findings regarding the 454 pages of evidence, these
workforce complaints remain Open and Active. The
No-Trespass order is not a security measure; it is the Administrative
Ratification of these previously documented threats.
IX. FORENSIC DOCUMENTATION OF SHAM IEP PROCEEDINGS
AND PREDETERMINATION
- Notice
of Procedural Bust (April 7 & 13, 2026): LCPS
unilaterally convened IEP meetings for my sons on April 7 and April
13, 2026, despite receiving formal, timely objections on March
13, March 20, and April 6, 2026.
- The
"Digital Blockade" as Administrative Entrapment: By
scheduling meetings exclusively via video conference while maintaining
a February 24 No-Trespass order that criminalizes my "digital
presence," LCPS is engaged in Administrative Entrapment.
You are attempting to manufacture a record of
"non-attendance" while simultaneously maintaining a blockade
that prevents my entry into the virtual meeting space.
- The
Shotwell "Smoking Gun" (Predetermination): On April
6, 2026, Cheryl Shotwell sent an email finalizing
course requests and school assignments 24 hours before the
transition meeting was even convened. This proves the IEP meetings
were a "sham"; the District had already finalized decisions
in SchooLinks/ParentVue, rendering parental
"meaningful participation" under 34 CFR § 300.501 impossible.
- Denial
of Review Time: For the April 7 meeting, LCPS provided a
draft IEP less than four hours prior to the start
time. No parent can forensically review a document of this legal
magnitude in such a window, especially when LCPS has ignored standing
objections for sixteen (16) days.
X. RATIFICATION OF IDENTITY OBFUSCATION AND LEGAL
MALICE
- History
of Record Manipulation: Between 2023 and 2025, LCPS willfully
listed my ex-wife’s cellular number as my own contact information in
official records.
- Evidence
of Actual Notice: On April 7, 2026, Dr. Lucy
Coranassario placed a call to my verified 214-681-7991 number,
proving the District has possessed my correct data while intentionally
utilizing a "Digital Blockade" to prevent me from verifying
this data in ParentVUE.
- Prohibition
of Prior Written Notice (PWN) as Retaliation: Any attempt by
LCPS to serve me with Prior Written Notice (PWN) or
"Administrative Closures" following these sham meetings will
be viewed as Aggravated Retaliation and Fraud. Given the
documented timeline of non-responsiveness and the District’s refusal
to acknowledge ten (10) certified letters, any PWN is a fraudulent
instrument intended to paper over a pre-existing conspiracy with Lindsay
Mohler to eradicate my parental rights.
- Personal
Liability (Va. Code § 18.2-460): By using a fraudulent
No-Trespass order to impede a federal IEP process, administrators are
acting outside the scope of their authority and are subject to
personal civil liability for Obstructing Justice and
First Amendment retaliation.
XI. EXPANDED SAFE HARBOR, ANTI-RETALIATION, AND
NON-WAIVER PROVISIONS
- Anti-Retaliation
Declaration: This communication is a protected activity under
the Virginia Fraud and Abuse Whistle Blower Protection Act
(Va. Code § 2.2-3011) and LCPS Policy 7561. Any
adverse action—including but not limited to additional
"security" restrictions, the filing of criminal trespass
charges, or the initiation of civil litigation by Lindsay
Mohler, Troxell Leigh P.C., or QlikTech, Inc.
(Qlik)—will be documented as Aggravated Retaliation for
the reporting of government corruption.
- Anti-SLAPP
Immunity (Broad Application): Pursuant to Va. Code §
8.01-223.2, the undersigned is immune from civil liability for all
statements made in this petition regarding matters of public
concern. This immunity specifically extends to all documented
facts regarding the conduct and coordination of Lindsay Mohler,
Troxell Leigh P.C., and QlikTech, Inc. (Qlik) as it relates
to the deprivation of my parental and statutory rights.
- Non-Waiver
of Constitutional Rights: Participation in mandated school
functions (e.g., attempting to satisfy the $8.60 meal
debt or attending "video conference" IEP meetings) is
performed under Administrative Duress to preserve my
children's access to nutrition and education. Such participation
does not constitute a waiver of my standing objection
to the fraudulent February 24 No-Trespass order, nor does it represent
an "agreement" to the District’s unlawful digital
restrictions.
- Criminal
Entrapment Disclaimer: Any automated or manual direction from
LCPS instructing me to "log in" to a portal that the
District has simultaneously criminalized is a formal act of Administrative
Entrapment. I reserve the right to present these conflicting
directives as a complete defense against any purported
"violation" of the No-Trespass order.
Respectfully,
Steven Rubis
|
|
|

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Steven Rubis <stevenrubis@gmail.com>
|
|
Steven Rubis <stevenrubis@gmail.com>
|
Wed, Apr 15, 2026 at 8:22 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>
|
|
Via Electronic Mail and USPS Certified Mail
DATE: April 15, 2026
TO: Dr. Lucy Cora Nazario
CC: Marc Bergin, et al.
RE: NOTICE OF PROCEDURAL BUST, ADMINISTRATIVE FRAUD,
AND WILLFUL VIOLATION OF THE IDEA
Dr. Cora Nazario,
It has come to my attention that LCPS proceeded with an
IEP meeting for my son, Beau, on April 13, 2026, in my absence.
This action represents a willful and egregious violation
of the IDEA (34 CFR § 300.501) and a total disregard for
the formal, timely notices I provided to the District.
I. CHRONOLOGY OF NOTICE AND WILLFUL DISREGARD
LCPS had actual notice of my unavailability for the
unilaterally dictated April 13 meeting date. I provided this notice through
multiple channels to ensure a forensic record of the District's bad faith:
- March
13, 2026: Initial notice provided to the District that I was
unavailable for the unilaterally scheduled time.
- March
20, 2026: USPS Certified Mail notice delivered to
LCPS reiterating my unavailability and the procedural hurdles created
by the District.
- April
6, 2026: Second USPS Certified Mail notice
delivered to LCPS confirming my inability to attend and demanding a
reschedule based on my parental rights.
- April
13, 2026 (12:30 PM ET): Formal email notice outlining
the Procedural Impossibility of the meeting due to
the digital blockade and withheld records.
II. EVIDENCE OF ADMINISTRATIVE FRAUD AND IDENTITY
OBFUSCATION
The outreach from your office on April 13 further
documents a pattern of administrative fraud:
- The
9:30 AM Email Fraud: You emailed claiming to have left a
voice message regarding Charles. Forensic audit of my
primary devices (214-681-7991 and 202-997-4815)
proves no such call occurred.
- The
1:12 PM "Beau" Conflict: Forty-two minutes after my
12:30 PM formal notice, you called regarding Beau,
claiming you were "expecting" me. This proves that LCPS is
either willfully ignoring legal notices or is so administratively
disorganized that it cannot distinguish between my sons’ files or
respect my documented unavailability. I notified LCPS on March 13,
2026, with USPS Certified Mail follow ups on March 20, 2026, and April
6, 2026, that I was unable to attend the meeting. I then followed up
with the procedural impossibility email sent at 12:30 pm CT on
Tuesday, April 14.
III. FINANCIAL LARCENY AND WITHHOLDING OF MANDATED
RECORDS
- Larceny
by Trick (Va. Code § 18.2-178): LCPS continues to
retain $559.70 for 1,141+ responsive records (Request
R002480-012526). The District utilized the fraudulent February 24
No-Trespass order to block my access to the LCPS FOIA portal,
preventing the retrieval of these documents.
- The
March 10 Admission: The District’s admission that it is
withholding an additional 172 pages based on
coordination with a private third party (Lindsay Mohler) proves
a State-Actor Nexus.
- Procedural
Impossibility: Under 34 CFR § 300.501, I have a
federal right to inspect all records prior to a meeting. Holding an
IEP meeting while withholding these paid-for records renders the
meeting void ab initio.
IV. ANTI-SLAPP SAFE HARBOR (Va. Code § 8.01-223.2)
This communication and all prior notices are
protected Petitions for Redress of Grievances. Pursuant
to Va. Code § 8.01-223.2, I am immune from civil liability for
these statements. Any attempt by LCPS or private third parties (Lindsay
Mohler, Troxell Leigh P.C., QlikTech, Inc.) to characterize this
forensic documentation as "harassment" or "disruption"
will be met with a motion for dismissal and a request for attorney fees
under the statute.
V. FORMAL DEMAND FOR CURE
LCPS cannot "reschedule" or "paper"
its way out of a Constitutional violation. I demand the following cures
immediately:
- Vacate
the April 13 IEP Result: All decisions made during the
unauthorized meeting for Beau must be vacated.
- Rescind
the No-Trespass Order: Rescind the fraudulent February 24
order in its entirety.
- Deliver
All Records: Deliver the 1,141+ FOIA records and the 172
pages of withheld coordination.
- Restore
Digital Access: Restore full access to all portals,
including ParentVUE, SchooLinks, the FOIA Portal, and HRTD systems.
FORENSIC NOTICE: Any attempt to finalize
Beau’s IEP based on the April 13 meeting will be documented as a fraudulent
administrative action performed in the absence of a Joint Legal Custodian
who was actively being barred and ignored by the District.
The full email chain regarding the procedural bust of
both IEP processes for my son's is attached as a PDF and originally
included several people on this email chain.
Sincerely,
Steven Rubis (Joint Legal Custodian)
|
|
|

|
Steven Rubis <stevenrubis@gmail.com>
|
|
Steven Rubis <stevenrubis@gmail.com>
|
Mon, Apr 20, 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>
|
|
VIA EMAIL (URGENT - FORENSIC RECORD)
DATE: April 18, 2026
TO: Dr. Lucy Cora Nazario; Mara Moreland;
Celesta Lewis; John Clark, Director of Safety & Security; Marc Bergin,
Chief of Staff, LCPS Administration.
RE: FORMAL REJECTION OF FRAUDULENT VDOE FILINGS;
NOTICE OF LARCENY BY TRICK AND FOIA OBSTRUCTION; AND SEVENTH NOTICE OF
PROCEDURAL BUST
To the Loudoun County Public School (LCPS)
Administration:
This letter serves as a formal rejection of the
"Pending Action Notifications" received via the Virginia
Department of Education (VDOE) portal on April 17, 2026, at 11:23 PM and
11:26 PM ET. These notifications represent a gross attempt by Dr. Lucy Cora
Nazario and LCPS to codify Administrative Fraud and engage in Larceny
by Trick to bypass my Joint Legal Custody.
I. DOUBLE LARCENY BY TRICK AND ADMINISTRATIVE FRAUD
The District is currently engaged in two distinct acts
of Larceny by Trick (Va. Code § 18.2-178):
- Financial
Larceny: LCPS has accepted and retained $559.70 in
payment for 1,141+ responsive records (Request
R002480-012526). Despite this payment being finalized, the District
has utilized the fraudulent February 24 No-Trespass order to block my
access to the LCPS FOIA portal, preventing the retrieval
of these documents. This is a criminal deprivation of paid-for
property.
- Parental
Standing Larceny: The upload of IEP documents for
"action" via the EDPlan Connect portal is
an attempt to trick the state’s management system into recording
"parental consent" or "completion" for meetings
held in willful violation of 34 CFR § 300.501. You are
attempting to "steal" my legal standing through an automated
process while maintaining a "Digital Blockade" that
criminalizes the entry required to review the documents.
II. SYSTEMATIC FOIA OBSTRUCTION, THE QLIK NEXUS, AND
DEBARMENT
As established in the March 10, 2026, FOIA response from
Dan Adams, LCPS is willfully withholding 172 pages of
documents demonstrating a State-Actor Nexus between the
District and private attorney Lindsay Mohler.
- The
Forensic Link: Evidence from Civil Action No.
2024-17511 (Montgomery County, PA) proves that Feyi
Obafemi (QlikTech) coordinated with Lindsay Mohler on
May 10, 2024, to misrepresent my termination as "voluntary".
- Contractual
Fraud and Debarment: This coordination constitutes a willful
misrepresentation of fact by a government contractor (QlikTech,
Inc.) to a state actor (LCPS). This breach of business integrity
is the predicate for my active Debarment Petition against
Qlik. By shielding these records, LCPS is facilitating a contractor's
violation of the Virginia Public Procurement Act.
- Obstruction
of Licensing Investigations: I have filed formal grievances
with the State Bars of New Jersey and Pennsylvania against Feyi
Obafemi. By blocking my digital access to the evidence of this
fraud, LCPS is actively obstructing these state licensing
investigations to protect a private vendor.
III. EXHAUSTION OF ADMINISTRATIVE REMEDIES & 12
IGNORED CERTIFIED LETTERS
I have now sent twelve (12) separate USPS
Certified Mail (Return Receipt Requested) letters regarding these
procedural violations, the missing FOIA documents, and the fraudulent
No-Trespass order. LCPS has acknowledged receipt of all 12 notices via USPS
tracking, yet has willfully ignored 100% of this legal correspondence. This
silence is a direct violation of the Virginia Fraud and Abuse
Whistle Blower Protection Act (Va. Code § 2.2-3011).
IV. WILLFUL MATRICULATION INTO A HOSTILE ENVIRONMENT
(NICK COTTONE)
The documents in the portal attempt to finalize the
placement of Charles Rubis at Seneca Ridge Middle School.
LCPS takes this action with full knowledge of the active Federal
OCR complaint regarding Principal Nick Cottone, which
includes a documented incident of Mr. Cottone physically touching my son
without consent. Forcing this placement—ratifying the Illegal
Predetermination established in the Cheryl Shotwell email
of April 6—is a willful disregard for student safety and a violation
of Va. Code § 22.1-289.044.
V. THE "DIGITAL TRAP" AND IDENTITY
OBFUSCATION
- Geographic
Absurdity: I currently reside in Chicago, IL,
over 700 miles from Loudoun County. The assertion
that a non-resident parent living half a continent away poses a
physical "threat" justifying a No-Trespass order is a
manifest administrative absurdity.
- Administrative
Perjury: Dr. Cora Nazario sent an email at 9:30 AM on April
13 claiming to have left a voice message regarding Charles.
Forensic audit of my devices (214-681-7991 and 202-997-4815)
confirms no such message was received.
- Willful
Disregard: Despite my formal notice of Procedural
Impossibility served at 12:30 PM on April 13, Dr. Cora
Nazario placed a call at 1:12 PM regarding Beau, claiming
she was "expecting" me. This proves LCPS is attempting to
manufacture a record of "non-participation" while
maintaining a blockade that criminalizes my entry into the system.
VI. CRIMINAL OBSTRUCTION & ANTI-SLAPP PROTECTION
This collusion and the filing of fraudulent records
constitute a willful violation of Va. Code § 18.2-460 (Obstructing
Justice). This communication is a Protected Statement regarding
governmental abuse under Virginia’s Anti-SLAPP Statute (Va. Code §
8.01-223.2). Any attempt to interpret my refusal to log into a
"forbidden" portal as "lack of interest" will be
documented as Aggravated Retaliation.
REQUIRED IMMEDIATE ACTION:
- WITHDRAW the
fraudulent IEP documents from the Virginia IEP/EDPlan portal
immediately.
- PRODUCE the
missing 1,141+ FOIA records and the 172
"privileged" pages.
- RESPOND to
the 12 pending USPS Certified letters sent by this office.
- VACATE the
results of the April 7 and April 13 sham meetings.
Evidence Supporting All Claims (Job Statistics, Bar
Complaints, Debarment Petitions, and Lawsuit Records) is Available Upon
Request.
Sincerely,
Steven Rubis (Joint Legal Custodian) (214) 681-7991
(202) 997-4815
|
|
|

|
Steven Rubis <stevenrubis@gmail.com>
|
|
Steven Rubis <stevenrubis@gmail.com>
|
Mon, Apr 20, 2026 at 9:00 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>
|
|
VIA EMAIL (URGENT - FORENSIC RECORD)
DATE: April 20, 2026
TO: Marc Bergin, Chief of Staff; John Clark,
Director of Safety & Security
CC: LCPS Administration, LCPS School Board,
LCSO, Leesburg Police, et al.
RE: NOTICE OF AGGRAVATED RETALIATION, ADMINISTRATIVE
ENTRAPMENT, AND WHISTLEBLOWER VIOLATION
Dear LCPS,
On Sunday, April 19, 2026, at 5:15 PM, I received a
formal solicitation from Dominion High School signed by Principal John
Brewer, inviting me to "Get involved," "Volunteer," and
"Join Us for Dinner" at the Dominion Golf Classic.
This outreach, occurring after I filed a formal Workforce
Complaint naming Dr. Brewer for previous unsolicited financial
solicitations, and explicit and willful violation of the fraudulent
no-trespass order issued to me by LCPS, when Dr. Brewer was copied on the
order, constitutes Aggravated Retaliation and Administrative
Entrapment.
I. THE "SECURITY THREAT" CONTRADICTION Loudoun
County Public Schools maintains a fraudulent February 24, 2026, No-Trespass
order and a total "Digital Blockade" against me, predicated on
the claim that I—a resident of Chicago, 700 miles away—pose a
"threat" to the school community.
- The
Forensic Fact: You cannot legally maintain a No-Trespass
order while simultaneously inviting the subject of that order to
"Join us for dinner" and "Volunteer" at a
high-profile community event.
- Admission
of Fraud: This solicitation is a de facto admission by a
senior LCPS administrator that the District’s "security"
concerns are a pretextual lie used to facilitate the deprivation of my
parental and civil rights.
II. ADMINISTRATIVE ENTRAPMENT AND LARCENY BY TRICK Soliciting
my physical and financial presence at an LCPS event while I am under a
threat of arrest for "trespass" is documented as Administrative
Entrapment.
- Larceny
by Trick (Va. Code § 18.2-178): This is a continuation of the
District’s pattern of attempting to "solicit" participation
or funds while blocking the legal and digital rights I have already
paid for—specifically the $559.70 in undelivered FOIA
records.
III. WHISTLEBLOWER RETALIATION (Va. Code § 2.2-3011) This
outreach is a direct response to my protected activity of filing a
workforce complaint naming you. It is a "taunt" designed to
demonstrate that you and the District feel immune to the Virginia
Fraud and Abuse Whistle Blower Protection Act.
IV. IDENTITY OBFUSCATION Utilizing a noreply@lcps.org address
to bypass my filters and continue financial solicitations while I am
blocked from ParentVUE, SchooLinks, and the FOIA
portal is documented as a willful act of Identity
Obfuscation.
FORENSIC DEMAND:
- Immediate
Cease and Desist: Stop all financial and community
solicitations directed at me until the fraudulent No-Trespass order is
rescinded in its entirety.
- Administrative
Consistency: If I am a "threat," explain on the
record why you are inviting me to volunteer at a community dinner. If
I am a "Fellow Titan" invited to volunteer, rescind
the No-Trespass order and the Digital Blockade immediately.
This communication is a Protected Statement under
Virginia’s Anti-SLAPP Statute (Va. Code § 8.01-223.2).
Sincerely,
Steven Rubis (Joint Legal Custodian) (214) 681-7991
(202) 997-4815
|
|
|

|
Steven Rubis <stevenrubis@gmail.com>
|
|
Steven Rubis <stevenrubis@gmail.com>
|
Tue, Apr 28, 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>
|
|
VIA EMAIL AND USPS CERTIFIED MAIL
DATE: April 28, 2026
TO: Marc Bergin, Chief of Staff; John Clark,
Director of Safety, Loudoun County Schools Administration, LCSO, and
Leesburg Police
RE: CERTIFICATION OF MAIL FRAUD, WITNESS
INTIMIDATION, AND AGGRAVATED RETALIATION; NOTICE OF DEFECTIVE SERVICE
To the Loudoun County Public School (LCPS)
Administration:
This letter serves as a formal forensic certification
that the No-Trespass order issued by John Clark on February 24, 2026, and
delivered via USPS Certified Mail, constitutes a willful act
of Mail Fraud (18 U.S.C. § 1341) and Witness
Intimidation (18 U.S.C. § 1512).
I. THE PREDICATE OF FRAUD AND CIRCULAR RETALIATION
The February 24 No-Trespass order explicitly cites a
December 2025 communication from the District as a primary justification
for my exclusion.
- Forensic
Conflict: This December 2025 letter was already under formal
review by LCPS Workplace Relations (Case 18422) as of
December 17, 2025.
- Federal
Nexus: Furthermore, this exact December communication was a
core exhibit in my Federal OCR Complaint filed in
February 2026.
- The
Violation: Utilizing the U.S. Postal Service to deliver a
criminal threat (the No-Trespass order) predicated on evidence
currently being adjudicated by a federal agency and your own HR
department is a bad-faith attempt to utilize federal resources to
intimidate a witness and whistleblower.
II. NOTICE OF DEFECTIVE SERVICE AND ADMINISTRATIVE
MALFEASANCE
The No-Trespass order was delivered to my parents'
residence in Chicago via USPS Certified Mail.
- Defective
Service: While the package was physically received, the USPS
Return Receipt (Green Card) was never detached or returned to
LCPS.
- Legal
Implication: As the Green Card remains in my possession, LCPS
lacks a verified "Proof of Service" required for the
enforcement of a criminal trespass warning. Any attempt to enforce
this order is predicated on a defective administrative record.
III. MAIL FRAUD AND LARCENY BY TRICK
The use of the mail to deliver this order facilitated
a Larceny by Trick (Va. Code § 18.2-178). The District
accepted $559.70 for 1,141+ FOIA records and
then utilized the mail-delivered No-Trespass order to
"criminalize" my access to the digital portal where those
paid-for records are held. Utilizing the federal mail system to execute a
financial deprivation under a fraudulent "security" pretext is a
significant unlawful act.
IV. PROTECTED PETITION AND ANTI-SLAPP SAFE HARBOR
This notice is a protected Petition for Redress
of Grievances regarding governmental abuse and the reporting of
mail-based crimes. Pursuant to Va. Code § 8.01-223.2, I am immune from
civil liability for documenting these forensic facts.
REQUIRED IMMEDIATE ACTION:
- RESCIND the
February 24 No-Trespass order immediately as it is a fraudulent
instrument of witness intimidation.
- DELIVER the
1,141+ records and the 172 "privileged" pages via physical
mail to my Chicago address.
- ACKNOWLEDGE the
administrative default regarding the 14 previously ignored certified
letters.
A copy of this certification is being forwarded to
the Federal OCR investigator as supplemental evidence of mail-based
retaliation.
Sincerely,
Steven Rubis
(Joint Legal Custodian)
(214) 681-7991
(202) 997-4815
|
|
|

|
Steven Rubis <stevenrubis@gmail.com>
|
|
Steven Rubis <stevenrubis@gmail.com>
|
Tue, Apr 28, 2026 at 7:30 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>
|
|
VIA EMAIL (URGENT - FORENSIC RECORD)
DATE: April 28, 2026
TO: Dr. Kate Ridgeway, Principal; Dr. Lucy
Coranassario; John Clark, Director of Safety & Security; Marc Bergin,
Chief of Staff; LCPS Administration, LCSO, Leesburg Police
RE: REJECTION OF BAD-FAITH ATTEMPT TO ALTER THE
ADMINISTRATIVE RECORD; DEMAND FOR RESTORATION OF RIGHTS AND PRODUCTION OF
WITHHELD FOIA RECORDS
To Dr. Ridgeway and LCPS Administration:
I am in receipt of your email dated April 27, 2026. Your
attempt to characterize the documented deprivation of my parental rights as
"separate issues" from the IEP—and your sudden offer to
reschedule after months of administrative silence—is rejected as a
bad-faith maneuver to retroactively alter the administrative record for
the benefit of the active Federal OCR investigation. These matters are
explicitly and inextricably linked. You cannot claim the IEP is a separate
discussion when the District’s own criminal No-Trespass order and
"Digital Blockade" are the direct mechanisms being used to
prevent my participation in that very process. No meeting can or will be
convened until LCPS addresses the standing legal record of non-compliance
and the historical pattern of retaliation that has now culminated in an
active Federal investigation.
I. Certification of Administrative Abandonment (14
Ignored Certified Letters)
To date, I have dispatched fourteen (14)
separate legal communications via USPS Certified Mail – Return Receipt
Requested to the LCPS Superintendent, Chief of Staff, and Division
Counsel. These letters provide meticulous documentation of explicit
violations of my children’s rights and the targeted obstruction of their
IEPs. LCPS has acknowledged receipt of all 14 packages via USPS tracking,
yet the District remains in total administrative default,
having failed to respond to a single inquiry. Meaningful participation is a
legal impossibility so long as the District refuses to respond to legally
documented issues regarding the children's safety and educational standing.
Your current email does not constitute a response to these 14 certified
legal notices; it is a documented effort to bypass the established record
of District misconduct.
II. Linkage to Original Federal OCR Complaint and
Documented Retaliation
As a primary recipient of my December 2025
correspondence, you are fully aware that the current "Digital
Blockade" is an escalation of the retaliatory pattern established
following my initial HR complaint against you on December 10, 2025. This record,
now part of an active Federal OCR Investigation, documents the
following:
- Active
IEP Deprivation and Mockery: My son, Charles, was mocked by a
substitute teacher when he explicitly asked for the accommodations
afforded to him under his IEP. He was subsequently punished because
the school failed to honor the legal mechanisms outlined in his IEP
when he requested support, effectively penalizing him for his
documented Emotional Disability and Specific
Learning Disability.
- Safety
Notification Failure: The failure to notify me of Charles’s
physical altercation on December 12, 2025, for four days—a direct
violation of LCPS Policy 8210 and standard safety protocols.
- Weaponization
of Student Records: The attempt to utilize Charles’s
"reflective writing"—conducted in a state of distress—as a
disciplinary threat rather than a clinical symptom of his disability.
- Procedural
Sabotage: The willful bypass of notification protocols and IEP
protections immediately following my protected advocacy.
III. Administrative Conflict Across the "Feeder
Pattern"
I have filed numerous formal workforce and
administrative complaints against the leadership of every school in this
feeder pattern: Lowes Island Elementary (Dr.
Ridgeway), Seneca Ridge Middle School (Nick Cottone),
and Dominion High School (Dr. John Brewer). By willfully
matriculating my son into a middle school where he was inappropriately and
physically singled out by Principal Nick Cottone—after I had explicitly
revoked consent for his participation—LCPS is demonstrating a reckless
disregard for student safety and parental authority.
IV. Rejection of "Administrative
Entrapment" and Illegal Predetermination
As I reside in Chicago, any meeting requires digital
access. By maintaining a criminal ban on my digital presence while
proposing "links" to connect, you are engaged in Administrative
Entrapment. Furthermore, any meeting is a forensic sham so long as
the Illegal Predetermination issued by Cheryl Shotwell on
April 6—matriculating my son to Seneca Ridge—remains the
"de-facto" position of the District.
FINAL ADMINISTRATIVE DEMANDS (PREREQUISITES FOR
ENGAGEMENT):
- Written
Response to 14 Certified Letters: LCPS must provide a formal,
written response to each of the 14 outstanding USPS Certified packages
regarding documented violations of my children's rights.
- Full
FOIA Production: LCPS must immediately produce all outstanding
records for all FOIA requests submitted by me,
including the 172 pages of correspondence with private attorney Lindsay
Mohler currently suppressed under a fraudulent claim of
privilege.
- Administrative
Accommodation for Placement (Charles & Beau Rubis): LCPS must
provide a written administrative accommodation for the matriculation
of both Charles and Beau Rubis to a school removed
from the influence of Nick Cottone and the Seneca Ridge administration.
As Beau will enter 5th grade next year and matriculate in two years, a
safe path must be ensured for both immediately.
- Vacatur
of Digital Blockade: LCPS must immediately vacate the fraudulent
No-Trespass order and restore my digital access to all digital
platforms controlled by LCPS, including ParentVue, the IEP portal, and
the FOIA portal. The District’s use of this order to
criminalize my ability to raise concerns about the unlawful behavior
of employees is a per se violation of my First and Fourteenth
Amendment rights.
I am ready to participate the moment LCPS ceases its
unlawful obstruction and restores my rights. Until then, any further
"proposals" that ignore these requirements will be documented as
continued Aggravated Retaliation.
Sincerely,
Steven Rubis
(Joint Legal Custodian)
(214) 681-7991
(202) 997-4815
|
|
|

|
Steven Rubis <stevenrubis@gmail.com>
|
|
Steven Rubis <stevenrubis@gmail.com>
|
Tue, Apr 28, 2026 at 7:30 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>
|
|
VIA EMAIL AND USPS CERTIFIED MAIL
DATE: April 28, 2026
TO: John Brewer, Principal; Marc Bergin,
Chief of Staff; John Clark, Director of Safety & Security, LCSO,
Leesburg Police, LCPS Administration
RE: SUPPLEMENTAL NOTICE OF ONGOING AGGRAVATED
RETALIATION AND ADMINISTRATIVE ENTRAPMENT (APRIL 27 SMS)
To the LCPS Administration:
This letter serves as a formal supplement to the
forensic record regarding the February 24, 2026, No-Trespass order. On the
morning of April 27, 2026, at 7:00 AM, I received a text message
solicitation from Dominion High School regarding the "Dominion HS
Online Auction."
I. CONTINUOUS RETALIATION FOLLOWING WORKFORCE
COMPLAINT
This outreach represents the third documented instance
in April 2026 where the District has solicited my financial and digital
participation while maintaining a criminal ban on my use of LCPS digital
platforms.
- The
Retaliatory Chain: I filed a formal Workplace
Relations complaint naming Principal John Brewer specifically
in response to the initial solicitation for the "Dominion Golf
Classic".
- Aggravated
Malice: The District’s decision to continue these
solicitations via SMS—after being placed on notice of the conflict and
the ongoing workforce investigation—constitutes Aggravated
Retaliation for protected whistleblower activity under Va.
Code § 2.2-3011.
II. ADMISSION OF FRAUD AND DIGITAL ENTRAPMENT
The Contradiction: By inviting me to
"win great prizes" and browse school-sponsored auction sites, the
District has forensically waived any claim that I pose a credible threat to
the school community.
Administrative Entrapment: Directing me to
access a school-managed auction link while I am under a police-enforced
"Digital Blockade" is a bad-faith attempt to manufacture a
criminal trespass violation.
III. LARCENY BY TRICK AND WHISTLEBLOWER OBSTRUCTION
This solicitation follows the District’s retention
of $559.70 for 1,141+ FOIA records that
remain undelivered due to the digital blockade. Utilizing automated systems
for financial gain while suppressing evidence of State-Actor
Collusion—including the 172 "privileged" pages involving
private counsel Lindsay Mohler—is a willful violation of Va. Code §
18.2-178 (Larceny by Trick).
IV. NOTICE TO FEDERAL OCR
This SMS solicitation will be forwarded to the Office
for Civil Rights as supplemental evidence of ongoing harassment.
The District’s continued "Titan" solicitations demonstrate a
total lack of internal coordination and a willful disregard for the active
federal investigation into Case #18422 and the Cottone physical misconduct
incident.
REQUIRED IMMEDIATE ACTION:
1. RESCIND the fraudulent February 24
No-Trespass order immediately.
2. DELIVER all 1,141+ FOIA records via
physical mail to my Chicago address.
3. VACATE the results of the
"sham" April 7 and April 13 meetings held in my absence.
Sincerely,
Steven Rubis
(Joint Legal Custodian)
(214) 681-7991
|
|
|

|
Steven Rubis <stevenrubis@gmail.com>
|
|
Steven Rubis <stevenrubis@gmail.com>
|
Tue, Apr 28, 2026 at 3:45 PM
|
|
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>
|
|
VIA EMAIL (URGENT - FORENSIC RECORD)
DATE: April 28, 2026
TO: Dr. Jason Allison, Assistant Principal,
Dominion High School
CC: Marc Bergin, Chief of Staff; John Clark,
Director of Safety & Security; W. John Brewer, Principal; LCSO;
Leesburg Police; Abony Alexander (OCR)
RE: NOTICE OF PROCEDURAL IMPOSSIBILITY AND DEMAND FOR
WRITTEN SPECIFICITY REGARDING "REX RUBIS"
Dr. Allison,
I am in receipt of your email sent at 4:01 PM ET today,
April 28, 2026, regarding a purported "incident" involving my
son, Rex.
I. NOTICE OF PROCEDURAL IMPOSSIBILITY Loudoun
County Public Schools (LCPS) maintains a February 24, 2026, No-Trespass
order issued by John Clark that prohibits my access to "all digital
platforms" and "virtual resources".
- Administrative
Entrapment: Soliciting a phone call or digital engagement
while maintaining a criminal ban on my digital presence is documented
as Administrative Entrapment. I will not participate in a
phone call that LCPS could later characterize as a violation of this
order.
II. DEMAND FOR WRITTEN RECORD Given the
documented history of Identity Obfuscation and Administrative
Fraud by LCPS, I demand that all information regarding this
"incident" be provided immediately in writing via email. I
require a specific forensic accounting of the following:
- The
exact time and location of the incident.
- The
names of all LCPS staff and students involved.
- A
detailed description of the event and any disciplinary or safety
actions taken.
III. NOTICE OF AGGRAVATED RETALIATION This
vague outreach follows three separate forensic legal notices I served to
LCPS leadership this morning (April 28, 2026) regarding Mail Fraud, Larceny
by Trick, and the State-Actor Nexus involving private
counsel Lindsay Mohler. The timing of this "incident"
report—immediately following protected whistleblower activity—is documented
as Aggravated Retaliation.
IV. SAFE HARBOR AND ANTI-SLAPP PROTECTION This
communication is a protected Petition for Redress of Grievances regarding
governmental abuse. Pursuant to Va. Code § 8.01-223.2, I am
immune from civil liability for documenting these facts.
REQUIRED IMMEDIATE ACTION: Provide the full
written details of the incident involving Rex Rubis via email immediately.
I will determine the appropriate response once a verifiable written record
is established.
Sincerely,
Steven Rubis
(Joint Legal Custodian)
(214) 681-7991
|
|
|

|
Steven Rubis <stevenrubis@gmail.com>
|
|
Steven Rubis <stevenrubis@gmail.com>
|
Wed, Apr 29, 2026 at 7:05 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>
|
|
FORENSIC ADMINISTRATIVE RECORD AND FORMAL COMPLAINT
TO: Loudoun County School Board; Dr. Aaron
Spence, Superintendent; Marc Bergin, Chief of Staff
CC: Tedra L. Richardson, Assistant
Superintendent for Student Services; LCPS Legal Counsel; LCPS Office of the
Ombuds
FROM: Steven Rubis (Joint Legal Custodian)
DATE: April 28, 2026
SUBJECT: FORENSIC RECORD OF AGGRAVATED
RETALIATION, PROCEDURAL ENTRAPMENT, AND SYSTEMIC DUE PROCESS VIOLATIONS
REGARDING STUDENT REX RUBIS (ID: 1018528)
I. PREAMBLE: THE DOCTRINE OF PRIOR NOTICE
This record is predicated on the fact that Loudoun
County Public Schools (LCPS) and the administration of Dominion High School
(DHS) have been on formal, certified notice since July 12, 2025, regarding
my communication expectations and the requirements of my
court-ordered Marriage Settlement Agreement (MSA). Furthermore,
LCPS was served with a Notice of Liability on December 18,
2025, explicitly stating that any further attempts to restrict
communication or obstruct my child's access to mandated education would be
viewed as a continuing and willful violation of state and federal law.
II. CHRONOLOGY OF THE APRIL 28, 2026, INCIDENT
- Morning
Protected Activity: Between 8:00 AM and 12:00 PM ET, I served
three forensic legal notices to LCPS leadership regarding Mail
Fraud, Larceny by Trick, and the State-Actor
Nexus involving private counsel.
- The
Retaliatory Strike: At 3:01 PM CT (4:01 PM ET), Dr. Jason
Allison sent a vague email soliciting a phone call regarding an
"incident".
- The
Notice Lag: I spoke with my son at 7:00 PM CT, who confirmed
he had already been suspended for five (5) school
days.
- Forensic
Conclusion: The suspension was implemented prior to
parental notification, mirroring the "Intentional Obstruction of
Intervention" documented in the November 21, 2025, suspension
incident.
III. COMPREHENSIVE RECORD OF ADMINISTRATIVE
MALFEASANCE
1. Violation of the December 8, 2025, Case Transfer
Mandate
- Fact: On
December 8, 2025, I formally demanded that all disciplinary matters
involving Rex be transferred to the Assistant Superintendent
for Student Services due to the documented bias and
retaliatory history of Dr. John Brewer and Dr. Jason Allison.
- Malfeasance: By
allowing Dr. Allison to adjudicate today’s incident, LCPS has
willfully ignored a formal administrative safeguard intended to ensure
neutrality. This constitutes Administrative Malfeasance and
a violation of LCPS Policy 7560 (Professional Ethics).
2. Procedural Entrapment and the No-Trespass Order
- Fact: LCPS
maintains a February 24, 2026, No-Trespass Order issued
by John Clark that prohibits my access to "all digital
platforms" and "virtual resources".
- Malfeasance: Dr.
Allison’s solicitation of a phone call or digital engagement is a
documented act of Administrative Entrapment.
- Violation: Soliciting
engagement while maintaining a criminal ban on my digital presence is
a bad-faith maneuver designed to strip me of my parental rights via
a Procedural Impossibility.
3. Statutory Due Process Violations (Va. Code §
22.1-277.04)
- Violation: Under
Virginia law, a student may only be suspended after being given notice
of the charges and an opportunity to explain their version of events.
- Failure: LCPS
implemented a major disciplinary action (5-day suspension) without
providing me, a joint custodian, a "meaningful opportunity to be
heard". This repeats the Due Process Violations documented
on November 24, 2025.
4. Aggravated Retaliation and Whistleblower Reprisal
- Fact: Today’s
adverse action followed my morning reports of governmental
abuse and identity obfuscation.
- Violation: Pursuant
to Va. Code § 8.01-223.2, I am immune from civil liability
for documenting these facts in a Petition for Redress of
Grievances. The timing of this suspension constitutes Aggravated
Retaliation.
IV. STANDING DEMANDS FOR CORRECTIVE ACTION
Given the Identity Obfuscation and Administrative
Fraud historically demonstrated by this administration—including
the future-dating of legal documents and "no-shows" to scheduled
meetings—I demand the following:
- Immediate
Stay of Suspension: The suspension must be stayed pending an
independent review by the Assistant Superintendent for Student
Services.
- Full
Written Specificity: I demand a forensic accounting of the
incident (time, location, involved parties, and evidence) provided
immediately in writing via email to avoid the entrapment of the
No-Trespass order.
- Expungement
of Record: This action must be expunged due to the
documented Procedural Defects and the school’s
failure to adhere to the communication mandates acknowledged by
Principal Brewer on July 14, 2025.
V. ABSENCE OF POLICY ACKNOWLEDGMENT AND CONSENT Please
be advised that for the 2025–2026 academic year, I have not signed,
acknowledged, or authorized any policy statements, student
handbooks, or "Student Rights and Responsibilities" documents via
ParentVue or any other medium.
LCPS is attempting to adjudicate my son under a
regulatory framework (Policy 8220.1) that I have not legally acknowledged,
while simultaneously violating the court-ordered MSA that
I have provided and which remains the governing authority
over his education.
- The
Violation: Any attempt to cite "school protocol" as
a defense for failing to consult me is legally void, as I have
explicitly withheld consent for such protocols in favor of my
statutory and court-ordered rights.
This document is served as a forensic legal record. I
expect a written response within two (2) business days.
Steve Rubis
Joint Legal Custodian
(214) 681-7991
|
|
|

|
Steven Rubis <stevenrubis@gmail.com>
|
|
Steven Rubis <stevenrubis@gmail.com>
|
Wed, Apr 29, 2026 at 9:10 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>
|
|
VIA EMAIL (URGENT - FORENSIC RECORD)
DATE: April 29, 2026
TO: Dr. Aaron Spence, Superintendent; Marc
Bergin, Chief of Staff; John Clark, Director of Safety & Security;
Loudoun County School Board
CC: Loudoun County Sheriff’s Office (LCSO);
Leesburg Police Department; Tedra Richardson, Assistant Superintendent; Dr.
Jason Allison; Abony Alexander (OCR)
FROM: Steven Rubis (Joint Legal Custodian)
SUBJECT: NOTICE OF ADMINISTRATIVE
ENTRAPMENT, PROCEDURAL IMPOSSIBILITY, AND AGGRAVATED RETALIATION — REX
RUBIS (ID: 1018528)
To the Loudoun County Public School (LCPS)
Administration:
This letter serves as a formal rejection of the
disciplinary actions communicated by Dr. Jason Allison and a Notice
of Aggravated Retaliation.
This correspondence is a protected Petition for
Redress of Grievances regarding governmental abuse and the
reporting of administrative fraud pursuant to the First Amendment and the
Virginia Fraud and Abuse Whistle Blower Protection Act.
I. NOTICE TO LAW ENFORCEMENT REGARDING ADMINISTRATIVE
ENTRAPMENT
This correspondence serves to formally notify the
Loudoun County Sheriff’s Office and the Leesburg Police Department of a
documented attempt at Administrative Entrapment by LCPS
administrators.
- The
Conflict of Orders: LCPS maintains a February 24, 2026,
No-Trespass Order issued by John Clark that purports to ban my
"digital presence" and use of "virtual resources".
- The
Bait: At 8:48 AM ET today, April 29, 2026, Dr. Jason Allison sent
an email soliciting my engagement and "questions" regarding
a disciplinary matter.
- Forensic
Conclusion: Soliciting digital or telephonic interaction while
maintaining a criminal ban on my digital presence is a bad-faith
maneuver designed to bait a technical violation of the No-Trespass
order.
II. RECURRING PROCEDURAL DEFECTS AND MSA VIOLATIONS
The suspension communicated by Dr. Allison is void
ab initio due to willful procedural failures and the deprivation
of my parental rights:
- Violation
of MSA: The suspension was implemented without the "Good
Faith Consultation" required by my court-ordered Marriage
Settlement Agreement (Case No. CL21-6851).
- Notice
Lag Strategy: The suspension was implemented prior to my
notification, repeating the "Notice Lag" strategy previously
documented by this office in November 2025.
- Lack
of Authorization: I have not signed or acknowledged any 2025-2026
policy documents or ParentVUE handbooks. I do not recognize the
authority of Dominion High School (DHS) administrators to adjudicate
my son under a framework I have explicitly refused to authorize,
particularly when utilized as a tool for Aggravated
Retaliation.
III. VIOLATION OF CASE TRANSFER MANDATE AND
AGGRAVATED RETALIATION
LCPS remains in willful non-compliance with my December
8, 2025, demand that all disciplinary matters involving my children be
transferred to the Assistant Superintendent for Student Services.
- Temporal
Nexus: This disciplinary strike occurred immediately following my
three forensic notices served at 7:00 AM and 7:30 AM ET on April 28,
2026.
- Conflict
of Interest: Dr. Allison and Dr. Brewer are subjects of
active Workforce Complaints and documented bias.
Their continued adjudication of my son’s education represents a Hostile
Administrative Environment and Whistleblower
Retaliation under Va. Code § 2.2-3011.
IV. SAFE HARBOR AND ANTI-SLAPP PROTECTION (Va. Code §
8.01-223.2)
This communication is a protected statement regarding
matters of public concern and the reporting of government misconduct.
Pursuant to Va. Code § 8.01-223.2, I am immune from civil
liability for documenting these forensic facts. Any attempt to characterize
this record as "harassment" or "disruption" will be met
with a motion for dismissal and a request for attorney fees under the
statute.
V. STANDING DEMAND FOR ADJUDICATION AND REMEDY
I formally demand that Marc Bergin and Tedra Richardson
immediately execute the following:
- Immediate
Rescission of the No-Trespass Order: The February 24, 2026, order
must be rescinded in its entirety. The District cannot legally or
ethically solicit my "meaningful participation" in a
five-day suspension process while simultaneously maintaining a
criminal ban on my digital and physical presence.
- Stay
the Suspension: Halt all disciplinary action against Rex Rubis
pending an independent review of the Temporal Nexus between
my whistleblower activity and this retaliatory strike.
- Cease
Solicitation: Direct Dr. Allison and Principal John Brewer to
cease all solicitations for engagement that contradict the standing
No-Trespass order.
- Produce
Forensic Records: Provide a full written record of the
incident—including all staff statements and any physical evidence—to
the Joint Legal Custodian immediately.
Sincerely,
Steven Rubis
(Joint Legal Custodian)
(214) 681-7991
(202) 997-4815
|
|
|

|
Steven Rubis <stevenrubis@gmail.com>
|
|
Steven Rubis <stevenrubis@gmail.com>
|
Wed, Apr 29, 2026 at 11:14 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>
|
|
Subject: RE: [Master Record] RE: Policy 8220
— SUPPLEMENTAL RECORD OF ADMINISTRATIVE OBFUSCATION
TO: Dr. Aaron Spence; Marc Bergin; John
Clark; Loudoun County School Board
CC: LCSO; Leesburg Police; Dr. Jason Allison
NOTICE OF ATTEMPTED RECORD OBFUSCATION
I am re-anchoring the following communication from Dr.
Jason Allison (received at 9:46 AM CT via a separate, detached email chain)
back into the Forensic Record. This tactic of initiating new,
context-free email chains is a documented attempt to obscure the history
of Aggravated Retaliation and the involvement of Law
Enforcement in this matter.
Dr. Allison’s attached communication (April 29, 2026,
9:46 AM CT):
"Hi Rubis, Please see the attached policy 8220.
Thank you."
Forensic Rebuttal:
- 1.
Documentation of Procedural Cure Attempt: This late provision
of Regulation 8220.1 serves as a written admission
that Dr. Allison failed to provide the mandated regulations at the
time of the suspension, as I previously documented. Providing this
document only after a formal appeal was filed is a
documented attempt to cure a Procedural Defect after
the fact.
- 2.
Persistence of Administrative Entrapment: Despite being put
on notice that I cannot engage in digital/telephonic
"discussions" due to the No-Trespass Order, Dr.
Allison continues to initiate detached, informal emails. This
persistent solicitation is a bad-faith maneuver designed to bait a
technical violation of said order.
- 3.
Professional Misconduct: I reiterate my demand to be
addressed as "Mr. Rubis." The continued use of
"Rubis" is a persistent act of professional disrespect
and Identity Obfuscation.
- 4.
Standing Demand: The "random" provision of a policy
document does not resolve the Notice Lag, the MSA
violation, or the Aggravated Retaliation. I reiterate
my demand for a Stay of Suspension and an immediate
transfer to the Assistant Superintendent.
Steven Rubis
Joint Legal Custodian
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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Thu, Apr 30, 2026 at 7:05 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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TO: Dr. Aaron Spence; Marc Bergin; John
Clark; Loudoun County School Board
CC: LCSO; Leesburg Police; Dr. Kate
Ridgeway; Tedra Richardson
SUBJECT: RE: [Master Record] NOTICE OF AGGRAVATED
RETALIATION AND IEP VIOLATION — BEAU RUBIS
I. DOCUMENTATION OF SYSTEMIC RETALIATION
I am re-anchoring this communication from Dr. Kate
Ridgeway (received at 6:15 PM CT) into the Forensic Record.
Within 24 hours of my serving forensic legal notices regarding government
abuse, LCPS has implemented disciplinary sanctions against two of my
children (Rex and Beau) under procedurally defective conditions.
II. WILLFUL BYPASS OF THE MSA AND DUE PROCESS
Dr. Ridgeway’s intent to proceed with an In-School
Restriction (ISR) on April 30, 2026, without producing the requested
evidence or consulting me as a joint legal custodian is a documented Breach
of Contract (MSA) and a violation of Va. Code §
22.1-277.04.
- Self-Incrimination
of a Minor: Dr. Ridgeway cites a "confession" from
a minor student as the sole basis for bypassing parental consultation.
- IEP
Interference: As Beau is a student on an IEP, any
removal from his regular educational setting—including ISR—must be
analyzed for its impact on his mandated services. Dr. Ridgeway’s
refusal to stay this action represents a continuing Hostile
Administrative Environment and a violation of the IDEA.
III. PERSISTENCE OF ADMINISTRATIVE ENTRAPMENT
Dr. Ridgeway continues to refer to "ParentVue"
for details despite being on notice that the district’s No-Trespass
Order prohibits my access to that platform. This is a documented
act of Administrative Fraud and Larceny by Trick,
as you are purposefully withholding exculpatory evidence behind a digital
blockade you created.
IV. STANDING REJECTION OF POLICY AUTHORITY
As with my son Rex, I have not signed or
acknowledged any LCPS handbook or ParentVue policy documents for
the 2025-2026 school year. I do not recognize the authority of Dr. Ridgeway
to enforce a "Code of Conduct" that I have explicitly refused to
authorize, especially in violation of my superior parental rights under
the MSA.
DEMAND FOR ACTION:
I demand an immediate Stay of the ISR for
Beau Rubis and the production of all witness statements and teacher
observations cited by Dr. Ridgeway. Any implementation of this sanction
tomorrow will be added to the pending Civil Rights and Workforce
Complaints regarding Aggravated Retaliation.
Steven Rubis
Joint Legal Custodian
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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Thu, Apr 30, 2026 at 7:30 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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TO: Dr. Aaron Spence; Marc Bergin; John Clark;
Loudoun County School Board
CC: LCSO; Leesburg Police; Dr. Jason Allison; Dr.
Kate Ridgeway; Tedra Richardson
FROM: Steven Rubis (Joint Legal Custodian)
DATE: April 29, 2026
SUBJECT: RE: [Master Record] EVIDENCE OF
COLLUSION AND WILLFUL BYPASS OF COURT-ORDERED MSA
NOTICE OF EVIDENTIARY DOCUMENTATION
I am adding the following communication from Elizabeth
Entsminger (received April 29, 2026, at 4:16 PM CT) to the Forensic
Record. This correspondence serves as a formal admission of the ongoing
collusion between LCPS administrators and the children's mother to bypass
my court-ordered Marriage Settlement Agreement (MSA).
Key Evidentiary Admissions in the Attached
Communication:
- Willful
Breach of MSA: The mother asserts that a 5-day suspension—a major
educational decision—"was not a decision that required or asked
for parental consent". This is a direct admission of an intent to
violate Section III, Paragraph B of our MSA, which
mandates good-faith consultation on all major educational issues.
- Confirmation
of Unequal Access: The mother confirms she was notified and
engaged in "addressing the matter directly" with the
administration while LCPS willfully withheld information from me until
the punishment was implemented. This confirms a violation of FERPA and LCPS
Policy 7560.
- Facilitation
of Administrative Entrapment: The mother explicitly directs me to
"discuss directly with the school" via phone, despite the
standing No-Trespass Order prohibiting my
digital/virtual presence. This confirms a coordinated effort to bait a
technical violation of a criminal trespass order.
- Unilateral
Educational Alteration: The mother admits to unilaterally
assigning educational curricula (Schindler’s List report) as a
disciplinary adjunct to the school's action. Under joint legal
custody, this is a major educational decision that required my prior
input.
CONCLUSION:
LCPS administrators are not merely "following
protocol"; they are actively facilitating the serial violation of
a Virginia Court Order. I reiterate my demand for an
immediate Stay of all Suspensions/Restrictions and the
transfer of these files to the Assistant Superintendent for
independent adjudication.
Steven Rubis
Joint Legal Custodian
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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Mon, May 4, 2026 at 7:05 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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NOTICE OF FORMAL COMPLAINT: AGGRAVATED RETALIATION
& OBSTRUCTION OF JUSTICE
TO: LCPS Department of Human Resources and
Talent Development (HRTD)
FROM: Steven Rubis, Joint Legal Custodian
DATE: May 4, 2026
RE: CASE #21548 – Retaliatory No-Trespass
Order Issued by John Clark
I. EXECUTIVE SUMMARY OF VIOLATIONS
This complaint serves as formal notice that John
Clark (Director of Safety & Security), acting on behalf of
the Loudoun County School Board, utilized the United
States Postal Service to execute a scheme of Aggravated
Retaliation and Obstruction of Justice. On February
24, 2026, LCPS issued a No-Trespass Order (NTO) that specifically cites
communications currently under investigation in HRTD Case #18422 (confirmed
active Dec 17, 2025) and central to a Federal OCR Complaint (filed
Feb 9, 2026).
The use of the USPS to deliver a fraudulent instrument
intended to interfere with a federal civil rights proceeding
constitutes Mail Fraud (18 U.S.C. § 1341) and Witness
Intimidation (18 U.S.C. § 1512). This action was designed to facilitate
a State-Actor Nexus with private attorney Lindsay
Mohler (Troxell Leigh P.C.) and vendor QlikTech, Inc.,
effectively "renting" police power to shield private interests
from statutory audit and ethics investigations.
II. STATEMENT OF MATERIAL FACTS: THE "OPEN AND
SHUT" EVIDENCE
- Utilization
of USPS for Administrative Fraud: John Clark utilized USPS
Certified Mail (Tracking #9589071052702620534290) to deliver
the NTO. The "Green Card" (PS Form 3811) remains in the
complainant's possession, proving a failure of service and a
"process trap." The NTO contains Material
Misrepresentations, citing "virtual events" the
complainant never attended, to justify a physical and digital
blockade.
- Direct
Obstruction of HRTD Case #18422: On December 17, 2025,
Ashleigh Stocks (LCPS HRTD) confirmed Case #18422 was active. The NTO
explicitly references the communications forming the basis of that
investigation. Issuing an NTO to "ban" a complainant from
the premises of an active internal investigation is a per se
act of retaliation.
- Interference
with Federal OCR Investigation: The NTO was issued exactly
fourteen days after LCPS received a Notice of Filing regarding
a Federal OCR investigation. By barring the complainant from the
digital Synergy and FOIA portals, LCPS is actively suppressing the
life-safety records and behavioral logs central to that federal
inquiry.
- The
Unlawful State-Actor Nexus (Mohler/Troxell Leigh): LCPS
officials coordinated with private attorney Lindsay Mohler to
facilitate a warrantless interrogation by Officer Timothy
Iversen (LCSO) on Dec 12, 2023. Further, in a FOIA response
dated March 10, 2026, LCPS fraudulently invoked Attorney-Client
Privilege to shield communications with Ms. Mohler—a private
attorney who does not represent the District.
- Larceny
by Trick & Conversion: LCPS accepted $559.70 for
FOIA Request R002510-021526. Utilizing the NTO to withhold records for
which payment was delivered and accepted constitutes Larceny
by Trick (Va. Code § 18.2-178).
- Predetermined
Appeal Rejection: John Clark’s summary denial of the appeal
on March 4, 2026, occurred within 110 minutes of his
being served with HRTD Case #21548, proving the appeal process was a
fraudulent sham with a predetermined outcome.
- Administrative
Silence: LCPS has maintained a policy of non-responsiveness
regarding sixteen (16) USPS Certified Letters (Attachment
E), while simultaneously using the complainant's attempts at formal
legal communication as the "pretext" for the trespass order.
III. TIMELINE OF PROTECTED ACTIVITY & SYSTEMIC
RETALIATION
- October
2023 – November 6, 2025: Ongoing reporting of Nick
Cottone's misconduct; reignited by protected speech regarding
a Yahoo! News article.
- December
17, 2025 (4:08 PM): Received confirmation of HRTD
Case #18422 regarding IEP violations and Nick Cottone's
behavior.
- February
9, 2026 (7:00 AM): Served LCPS with a Final Cease
& Desist and Revocation of Consent for
Charles to participate in the Seneca Ridge MS field trip.
- February
9, 2026 (6:48 PM): Served Dr. Spence and the School Board
with Notice of Filing regarding a Federal OCR
Complaint and VDOE Investigation.
- February
12, 2026: In direct violation of the Revocation of Consent,
LCPS transported Charles to Seneca Ridge MS. Nick Cottone specifically
sought out Charles, high-fived him, and asked, "Are you Rex's
brother?"—committing inappropriate physical touch and
witness intimidation.
- February
18, 2026: Filed a formal Request for Vendor Debarment of QlikTech,
Inc. and ethics complaints against Lindsay Mohler regarding
the use of fraudulent Qlik data.
- FEBRUARY
24, 2026: John Clark issued the NTO via USPS Certified Mail,
citing the very complaints under investigation by the OCR and HRTD.
- February
28, 2026: Served a Formal Objection and Demand for
Rescission to John Clark, detailing the aggravated
retaliation.
- March
4, 2026 (12:33 PM): John Clark issued a summary denial of the
appeal within 110 minutes of being served with HRTD
Complaint #21548.
- March
6, 2026: Served Final Notice of Administrative
Default and Ratification to Marc Bergin and the School Board
regarding the criminal obstruction of statutory investigations.
- March
10, 2026: LCPS responded to FOIA requests by fraudulently
citing Attorney-Client Privilege to hide
communications with private attorney Lindsay Mohler.
- I
have received no response to my escalation of my appeal to Mark Bergin
LCPS Chief of Schools.
III. LEGAL & POLICY CITATIONS
- Virginia
Anti-SLAPP Protection (Va. Code § 8.01-223.2): Virginia law
provides immunity for statements made regarding matters of public
concern and the right to petition the government. The NTO is a
retaliatory administrative instrument designed to chill protected
speech regarding vendor fraud and child safety.
- Federal
Retaliation (34 C.F.R. § 100.7(e) & 104.61): LCPS is
prohibited from intimidating or coercing any individual for
participating in an investigation. Because the NTO cites letters used
in the OCR filing, it is prima facie evidence of retaliation.
- Obstruction
of Justice (Va. Code § 18.2-460): By barring the complainant
from school grounds, digital systems, and the FOIA portal immediately
following a notice of investigation, the District has knowingly
attempted to impede a legal official investigation.
- Mail
Fraud (18 U.S.C. § 1341): The use of the USPS to deliver a
document based on misrepresented facts to advance a retaliatory scheme
and a sham appeal process introduces federal criminal liability.
- Violation
of LCPS Policy 8040 & 1040: The District has violated its
own mandates regarding Parental Rights and Non-Discrimination by
stripping a joint legal custodian of access without due process.
- Tortious
Interference: Maliciously emerging as a frequent searcher of
the complainant's LinkedIn profile to "starve out" a
whistleblower during a job search that has faced 1,900+
rejections.
IV. IDENTIFICATION OF ACCOMPLICES & INSTITUTIONAL
RATIFICATION
The following individuals and entities were formally
served with the NTO dated February 24, 2026. Their failure to rescind this
retaliatory instrument constitutes Institutional Ratification of
a federal civil rights violation. Furthermore, these officials have
maintained a policy of Administrative Silence regarding sixteen
(16) USPS Certified Letters (Tracking numbers:
70231500000004928130, 8154, 8147, 8161, 8185, 8178, 8192, 8208, 8222, 8215,
8239, 8246, 8253, 8260, 8284, 8277), confirming a coordinated effort to
ignore formal legal correspondence:
- Dr.
Aaron Spence (Superintendent): Chief executive bearing
ultimate responsibility for the retaliatory use of District resources.
- Marc
Bergin (Chief of Staff): Direct knowledge of the ongoing
legal record disputes, the "Notice of Filing," and the Final
Notice of Administrative Default (March 6, 2026) which LCPS
ignored.
- Rae
Mitchell (Chief of Schools): Previous author of restrictions
(Exhibit C), demonstrating a pattern of using bans to avoid federal
compliance.
- Neri
Gonzales & Beth Robinson: Oversight officials who allowed
the NTO to interfere with high school and middle school transition
mandates.
- W.
John Brewer (Principal, DHS), Nick Cottone (Principal, SRMS), and Kate
Ridgeway (Principal, LIES): Site-level enablers who have
utilized the NTO to block communication regarding IEP implementation
and SMS solicitations.
- Loudoun
County School Board: The governing body on whose behalf John
Clark explicitly claimed to be acting.
- Loudoun
County Sheriff’s Office & Leesburg Police Department: Involved
as third-party instruments of intimidation to provide a "veneer
of law enforcement" to a civil rights violation and a private
legal advantage for LCPS counsel.
- Nick
Cottone (Principal, SRMS): The genesis actor who coordinated
with Lindsay Mohler and targeted a minor child (Charles) during an
active grievance.
- Lindsay
Mohler & Troxell Leigh P.C.: Private actors utilizing
District resources to bypass constitutional protections.
- QlikTech,
Inc. (Qlik): Beneficiary of the retaliatory suppression of
FOIA audit trails.
V. MANDATORY REMEDIES & ADMINISTRATIVE DEMANDS
To mitigate further institutional and personal
liability, and to begin the remediation of the documented constitutional
and statutory violations, I demand the following immediate actions:
- Immediate
Termination Proceedings for Genesis Actors: I demand the
immediate commencement of disciplinary proceedings, up to and
including termination, for Nick Cottone (Principal, SRMS).
This demand is predicated on his foundational role in the systematic
rights deprivation of my son, Charles, the orchestration of
retaliatory actions following protected speech, and the unlawful
coordination with private third parties to gain a legal advantage
under color of law.
- Immediate
Termination Proceedings for Issuing Official: I demand the
immediate commencement of disciplinary proceedings, up to and
including termination, for John Clark (Director of Safety
& Security). This demand is based on his willful misuse of
office, the fraudulent and predetermined appeal process (the
"110-minute rejection"), and the utilization of the USPS to
execute a scheme of administrative fraud.
- Immediate
Administrative Suspension of Ratifying Officials: I demand
the immediate suspension of Marc Bergin (Chief of Staff) and Rae
Mitchell (Chief of Schools) pending a full independent
investigation. This demand stems from their roles in ratifying
aggravated retaliation and facilitating a "Digital Blockade"
while having actual knowledge of active Federal OCR and HRTD
investigations.
- Unconditional
Rescission & Notice of Retraction: LCPS must issue a
formal, written retraction of the February 24, 2026, No-Trespass Order
to all parties and law enforcement agencies copied on the original
correspondence. This notice must explicitly state the NTO was issued
without a factual or legal basis and was not necessitated by
any credible safety or security threat.
- Remediation
of FOIA Larceny & Conversion: I demand the immediate
electronic release of the 944 paid-for public records (Request
R002510). Continued withholding of these records, for which the
District accepted and processed a payment of $559.70,
constitutes Larceny by Trick (Va. Code § 18.2-178) and
will be treated as an ongoing act of conversion.
- Rescission
of Retaliatory Privilege Assertions: I demand the immediate
release of all communications involving Lindsay Mohler and
Troxell Leigh P.C., which were unlawfully withheld in the FOIA
response dated March 10, 2026. As Ms. Mohler is a private third-party
attorney with no legal standing to represent LCPS, no
"Attorney-Client Privilege" exists; the assertion of such is
a fraudulent misuse of statutory exemptions to shield a state-actor
nexus.
- Restoration
of Parental and Digital Access: Immediate and unrestricted
restoration of all physical access to school grounds and digital
access to the ParentVue/Synergy portals. This is
required to fulfill my statutory duties as a joint legal custodian and
to monitor the life-safety mandates and IEP compliance for my son,
Charles.
- Notice
of Claim for Financial Restitution: LCPS and the named
individuals are hereby placed on formal notice of a claim for damages
in the amount of $2,148,000.00 and continuing. This sum
reflects the documented economic impact of the District’s sustained
campaign of tortious interference and professional surveillance, which
has directly resulted in over 1,900 job rejections and
the systematic destruction of my professional reputation.
- Establishment
of Independent Oversight: I demand the appointment of an
independent, third-party auditor to oversee the preservation of all
system audit logs for the Virginia IEP Connect and FOIA portals to
ensure no further Selective Data Spoliation or record
scrubbing occurs during the pendency of active investigations.
VI. NOTICE OF PERSONAL LIABILITY & NON-IMMUNITY
TO ALL RECIPIENTS: Take notice that
under 42 U.S.C. § 1983, government officials who violate
clearly established statutory or constitutional rights are not
entitled to qualified immunity. By proceeding with this NTO after
receiving the "Notice of Filing" and the Qlik debarment request,
you have acted with Actual Knowledge and Malice, exposing
yourselves to personal financial liability.
VII. SAFE HARBOR STATEMENT & NOTICE OF NON-WAIVER
This complaint is filed under the Safe Harbor provisions
of federal and state whistleblower and civil rights statutes. Nothing in
this document shall be construed as a waiver of any rights, claims, or
remedies available under law or equity. This document serves as a Notice
of Claim under the Virginia Tort Claims Act and a formal record to
preserve the right to seek further judicial relief in Federal and State
courts.
IV. SAFE HARBOR AND ANTI-SLAPP PROTECTION (Va. Code §
8.01-223.2)
This communication is a protected statement regarding
matters of public concern and the reporting of government misconduct.
Pursuant to Va. Code § 8.01-223.2, I am immune from civil
liability for documenting these forensic facts. Any attempt to characterize
this record as "harassment" or "disruption" will be met
with a motion for dismissal and a request for attorney fees under the
statute.
VIII. FINAL FORENSIC DEMAND
You have 48 hours from the receipt of
this document to confirm in writing that the NTO has been rescinded and the
demands for termination/suspension have been acknowledged. Failure to
respond will be viewed as a further act of Aggravated Retaliation and
will be immediately reported to UD DOE OCR and the United States
Department of Justice.
Steve Rubis
Joint Legal Custodian
214-681-7991
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12 attachments
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Attachment 2a - LCPS USPS certified envelope.jpg
3434K
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Attachment 2b - LCPS USPS green return receipt
addressed to john clark side.jpg
3859K
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Attachment 2c - LCPS USPS green return receipt
opposite side.jpg
3866K
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Attachment 1 - LCPS NTO.pdf
180K
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Attachment 3 - 251217 LCPS HRTD confirmation from
Asley Stocks.pdf
93K
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Attachment 5 - 260219 - petition for debarment of
Qlik and LCPS vendor.pdf
129K
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Attachment 4 - 260209 Notice of Federal OCR filing
sent to LCPS.pdf
239K
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Attachment 6 - 260310 LCPS FOIA response about Mohler
and Troxel Leigh.pdf
83K
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Attachment 7a - 260304 JOhn Clark 110 minute appeal
rejection.pdf
243K
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Attachment 7b - Response to John Clark Appeal
REjection.pdf
160K
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Attachment 8 - USPS certified return receipt letters
sent to LCPS Log.pdf
108K
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Attachment 9 - 260215 Charles Rubis Recounts Field
Trip to Seneca Ridge Middle School.pdf
160K
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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Mon, May 4, 2026 at 12:00 PM
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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 4, 2026
TO: Marc Bergin, Chief of Staff; John Clark,
Director of Safety & Security; Dr. Aaron Spence,
Superintendent CC: Nick Cottone, Principal (LIES); John Brewer,
Principal (DHS); LCSO; Leesburg Police, et al.
FROM: Steven Rubis (Joint Legal Custodian)
SUBJECT: SUPPLEMENTAL NOTICE OF ADMINISTRATIVE
FRAUD, ENTRAPMENT, AND WAIVER OF SECURITY PREDICATE (MAY 4 SOLICITATIONS)
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. On the
morning of Monday, May 4, 2026, I received two distinct
solicitations for engagement:
- 7:00
AM (SMS): A solicitation from Dominion High School for the
"Dominion HS Online Auction".
- 10:09
AM (Email): A formal invitation from Lowes Island Elementary
School to "Join us for our annual Donuts with Grownups
Event".
I. DE FACTO RESCISSION VIA ADMINISTRATIVE WAIVER These
solicitations constitute a de facto waiver of any "security"
predicate for my exclusion.
- Lowes
Island Invitation: By inviting me to attend a "Grownups"
event on-site, Lowes Island Elementary—the home school of
Principal Nick Cottone—has forensically admitted that the
District does not believe I pose a threat to staff or students.
- Inconsistency
of Police Power: The District cannot utilize the Loudoun
County Sheriff’s Office to enforce a criminal ban while
simultaneously utilizing its own communication platforms to solicit my
physical and financial presence.
II. CONTINUED ADMINISTRATIVE ENTRAPMENT Directing
me to "RSVP here" via a digital link while maintaining a criminal
"Digital Blockade" is a bad-faith maneuver designed to bait a
technical violation of the No-Trespass order. This is a willful act
of Administrative Entrapment.
III. LARCENY BY TRICK AND FEDERAL OBSTRUCTION These
solicitations occur while LCPS remains in default on 1,141+ FOIA
records for which they accepted $559.70. Utilizing
school resources for "Auction" fundraising while suppressing
evidence of State-Actor Collusion with private
attorney Lindsay Mohler is a violation of Va. Code §
18.2-178 and the Virginia Whistle Blower Protection Act.
IV. NOTICE TO FEDERAL OCR These May 4
communications are being forwarded to the Office for Civil Rights as
further evidence of Aggravated Retaliation. The District’s
pattern of inviting me to "social" and "fundraising"
events while excluding me from my son’s IEP and disciplinary proceedings
is a manifest violation of Section 504 and the ADA.
REQUIRED IMMEDIATE ACTION:
- RESCIND the
fraudulent February 24 No-Trespass order immediately.
- DELIVER all
paid-for FOIA records via physical mail to my Chicago address.
- VACATE the
retaliatory five-day suspension of Rex Rubis.
Sincerely,
Steven Rubis (Joint Legal Custodian)
(214) 681-7991
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2 attachments
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260504 Dominion HS online auction text message.pdf
101K
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260504 Gmail - Upcoming Event! RSVP for Donuts with
Grownups.pdf
2182K
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Steven Rubis <stevenrubis@gmail.com>
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Steven Rubis <stevenrubis@gmail.com>
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Mon, May 4, 2026 at 4:42 PM
|
|
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>
|
|
TO: Dr. Kate Ridgeway, Principal, Lowes
Island Elementary
CC: Dr. Aaron Spence; Marc Bergin; John
Clark; LCSB; LCSO; Leesburg Police; Tedra Richardson
DATE: May 4, 2026
RE: FORMAL OBJECTION TO ILLEGAL DISCIPLINARY SANCTION
— BEAU RUBIS; NOTICE OF AGGRAVATED RETALIATION AND IEP INTERFERENCE
Dr. Ridgeway,
I am in receipt of your 4:01 PM email regarding a
purported incident in the library. This communication, and your intent to
proceed with an In-School Restriction (ISR) on April 30, is formally
rejected as procedurally defective and retaliatory.
1. Violation of Federal IDEA Mandates Beau
is a student protected by a social-emotional IEP. Per LCPS
Regulation 8220.1 and the IDEA, you are prohibited
from implementing disciplinary removals without first conducting a
Manifestation Determination Review (MDR). Your unilateral imposition of
ISR—following my 7:05 AM notice regarding your role in Aggravated
Retaliation—is a documented attempt to interfere with mandated
educational services.
2. Persistent Administrative Entrapment You
direct me to ParentVue for "further information." You were
formally served notice this morning (7:05 AM and 12:00 PM) that the
February 24 No-Trespass Order bars my access to all digital platforms. By
referencing a blocked platform to satisfy a due process requirement, you
are engaged in Administrative Fraud and Larceny by
Trick.
3. Breach of Court-Ordered MSA The Marriage
Settlement Agreement (MSA) requires "Good Faith
Consultation" prior to major educational decisions. Implementing a
sanction within hours of a manufactured "incident"—and without
providing the Joint Legal Custodian a meaningful opportunity to review
evidence—is a Material Breach of a Virginia court order.
4. Temporal Nexus of Retaliation This
"incident" occurred within hours of my serving LCPS leadership
with a Notice of Formal Complaint: Aggravated Retaliation. The
timing is documented as a retaliatory strike against a minor child to
silence a whistleblower.
REQUIRED IMMEDIATE ACTION:
- STAY the
ISR immediately pending a formal MDR and review by the Assistant
Superintendent.
- DELIVER all
witness statements and the specific policy code violated via physical
mail or direct PDF attachment to bypass the digital blockade you have
enabled.
Sincerely,
Steven Rubis
Joint Legal Custodian
(214) 681-7991
|
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Steven Rubis <stevenrubis@gmail.com>
|
|
Steven Rubis <stevenrubis@gmail.com>
|
Wed, May 6, 2026 at 9:00 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 and USPS Certified Mail Return Receipt
Requested
TO: Marc Bergin, Chief of Staff; John Clark,
Director of Safety; LCPS School Board
CC: Loudoun County Sheriff’s Office;
Leesburg Police, et al.
DATE: May 6, 2026
RE: SUPPLEMENTAL CERTIFICATION OF COORDINATED
RETALIATION AND WITNESS INTIMIDATION (May 4, 2026 Event)
I. THE 175-MINUTE RETALIATION WINDOW
Take formal notice of the following forensic sequence
documented on May 4, 2026, which establishes a prima facie case of Unlawful
Information Exchange and Administrative Collusion:
- 07:05
AM: Complainant served LCPS Leadership with a formal Master
Forensic Complaint documenting Federal Crimes (18
U.S.C. § 1341 & § 1512) and naming government
vendor QlikTech, Inc. and private attorney Lindsay
Mohler as co-conspirators.
- 10:00
AM: Within exactly 175 minutes, the other
parent—represented by the aforementioned Lindsay Mohler
(Troxell Leigh P.C.)—issued a targeted legal threat stating she
would "direct my counsel to file a rule of show cause
against you." Forensic Analysis of the "10:00 AM
Strike": The temporal proximity of this threat is
forensically impossible without a direct "tip-off" from LCPS
administration to private counsel. By signaling to Lindsay Mohler that
a formal criminal and civil rights complaint had been filed, LCPS officials
effectively triggered a secondary front of family court harassment to
serve as a "counter-strike." This coordination intended to
compel the complainant to withdraw his protected HRTD and OCR
complaints constitutes Witness Intimidation (18
U.S.C. § 1512) and Conspiracy Against Rights (18
U.S.C. § 241).
II. CONTINUING STATE-ACTOR NEXUS & LACK OF SAFE
HARBOR
The District’s continued utilization of Lindsay
Mohler as an unofficial enforcement arm confirms the State-Actor
Nexus previously identified in this record. By "renting"
the litigation power of a private firm to execute a "starve-out"
strategy against a whistleblower, LCPS has moved beyond administrative
overreach into Deprivation of Rights Under Color of Law (18 U.S.C.
§ 242).
The threat of a "Rule to Show Cause" issued
while the complainant was under the explicit protection of Federal
Safe Harbor and Anti-SLAPP provisions is a toxic,
unlawful act of retaliation that LCPS leadership has now ratified through
its coordination.
III. DEMAND FOR DISCLOSURE & PRESERVATION
I hereby demand the immediate disclosure of all
communications—including but not limited to emails, SMS/text messages, and
phone logs—between Marc Bergin, John Clark, or Nick Cottone and Lindsay
Mohler/Troxell Leigh P.C. occurring between 07:00 and
11:00 on May 4, 2026.
Be advised that any deletion of these records following
the 07:05 AM filing will be treated as a willful act of Spoliation
of Evidence in a federal matter. Failure to produce these records
or provide a credible, non-retaliatory explanation for the 175-minute
window will be treated as an admission of Conspiratorial
Coordination.
I hereby demand the immediate disclosure of all
communications between Marc Bergin, John Clark, or Nick Cottone and Lindsay
Mohler occurring between 07:00 and 11:00 on May 4, 2026. Failure
to produce these records will be treated as an admission of conspiratorial
coordination. You have 48 hours to confirm rescission of
the NTO.
IV. FINAL NOTICE OF PERSONAL LIABILITY
TO ALL RECIPIENTS: Every official involved
in the "May 4 Tip-Off" is hereby placed on notice that they have
stepped outside the scope of their official duties to facilitate private
legal harassment. Under 42 U.S.C. § 1983, you are NOT
entitled to qualified immunity for the intentional coordination of
witness intimidation.
V. ANTI-SLAPP PROTECTION & SAFE HARBOR
DECLARATION
This communication and all prior filings constitute
a "Petition for Redress of Grievances" protected
under the First Amendment of the U.S. Constitution and
the Constitution of Virginia.
- Virginia
Anti-SLAPP (Va. Code § 8.01-223.2): Any attempt by LCPS,
Lindsay Mohler, or Troxell Leigh P.C. to utilize the "Rule to
Show Cause" threat as a basis for legal retaliation is a
violation of Virginia’s Anti-SLAPP statute. Statements made regarding
the misconduct of LCPS and QlikTech are matters of public concern and
are subject to statutory immunity.
- Whistleblower
Safe Harbor: Pursuant to Section 504 of the
Rehabilitation Act and VA Code § 2.2-3011, any
further adverse actions—including coordinated domestic litigation—will
be treated as willful acts of witness intimidation.
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.
- Remediation
of FOIA Larceny: Immediate electronic release of the 944
records (R002510).
- Financial
Restitution: Notice of claim for $2,148,000.00 and
continuing.
Steve Rubis
Joint Legal Custodian
214-681-7991
Ex Wife's Legal Threat
|
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|

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Steven Rubis <stevenrubis@gmail.com>
|
|
Steven Rubis <stevenrubis@gmail.com>
|
Wed, May 6, 2026 at 9:00 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 and USPS Certified Mail Return
Receipt Requested
TO: Marc
Bergin, Chief of Staff; John Clark, Director of Safety; LCPS School
Board
CC: Loudoun
County Sheriff’s Office; Leesburg Police, et al.
DATE: May
6, 2026
RE: SUPPLEMENTAL CERTIFICATION OF COORDINATED
RETALIATION AND WITNESS INTIMIDATION (May 4, 2026 Event)
I. THE 175-MINUTE RETALIATION WINDOW
Take formal notice of the following forensic
sequence documented on May 4, 2026, which establishes a prima facie
case of Unlawful Information Exchange and Administrative
Collusion:
- 07:05 AM: Complainant
served LCPS Leadership with a formal Master Forensic
Complaint documenting Federal Crimes (18 U.S.C. §
1341 & § 1512) and naming government vendor QlikTech,
Inc. and private attorney Lindsay Mohler as
co-conspirators.
- 10:00 AM: Within
exactly 175 minutes, the other parent—represented by
the aforementioned Lindsay Mohler (Troxell Leigh P.C.)—issued
a targeted legal threat stating she would "direct my
counsel to file a rule of show cause against you." Forensic
Analysis of the "10:00 AM Strike": The temporal
proximity of this threat is forensically impossible without a
direct "tip-off" from LCPS administration to private
counsel. By signaling to Lindsay Mohler that a formal criminal and
civil rights complaint had been filed, LCPS officials effectively
triggered a secondary front of family court harassment to serve as
a "counter-strike." This coordination intended to compel
the complainant to withdraw his protected HRTD and OCR
complaints constitutes Witness Intimidation (18
U.S.C. § 1512) and Conspiracy Against Rights (18
U.S.C. § 241).
II. CONTINUING STATE-ACTOR NEXUS & LACK OF
SAFE HARBOR
The District’s continued utilization of Lindsay
Mohler as an unofficial enforcement arm confirms the State-Actor
Nexus previously identified in this record. By
"renting" the litigation power of a private firm to execute a
"starve-out" strategy against a whistleblower, LCPS has moved
beyond administrative overreach into Deprivation of Rights
Under Color of Law (18 U.S.C. § 242).
The threat of a "Rule to Show Cause"
issued while the complainant was under the explicit protection of Federal
Safe Harbor and Anti-SLAPP provisions is a
toxic, unlawful act of retaliation that LCPS leadership has now
ratified through its coordination.
III. DEMAND FOR DISCLOSURE & PRESERVATION
I hereby demand the immediate disclosure of all
communications—including but not limited to emails, SMS/text messages,
and phone logs—between Marc Bergin, John Clark, or Nick Cottone and Lindsay
Mohler/Troxell Leigh P.C. occurring between 07:00 and
11:00 on May 4, 2026.
Be advised that any deletion of these records
following the 07:05 AM filing will be treated as a willful act of Spoliation
of Evidence in a federal matter. Failure to produce these
records or provide a credible, non-retaliatory explanation for the
175-minute window will be treated as an admission of Conspiratorial
Coordination.
I hereby demand the immediate disclosure of all
communications between Marc Bergin, John Clark, or Nick Cottone and Lindsay
Mohler occurring between 07:00 and 11:00 on May 4, 2026.
Failure to produce these records will be treated as an admission of
conspiratorial coordination. You have 48 hours to
confirm rescission of the NTO.
IV. FINAL NOTICE OF PERSONAL LIABILITY
TO ALL RECIPIENTS: Every official involved in the "May
4 Tip-Off" is hereby placed on notice that they have stepped
outside the scope of their official duties to facilitate private legal
harassment. Under 42 U.S.C. § 1983, you are NOT
entitled to qualified immunity for the intentional
coordination of witness intimidation.
V. ANTI-SLAPP PROTECTION & SAFE HARBOR
DECLARATION
This communication and all prior filings
constitute a "Petition for Redress of Grievances" protected
under the First Amendment of the U.S. Constitution and
the Constitution of Virginia.
- Virginia Anti-SLAPP (Va. Code § 8.01-223.2): Any attempt by LCPS, Lindsay Mohler, or
Troxell Leigh P.C. to utilize the "Rule to Show Cause"
threat as a basis for legal retaliation is a violation of
Virginia’s Anti-SLAPP statute. Statements made regarding the
misconduct of LCPS and QlikTech are matters of public concern and
are subject to statutory immunity.
- Whistleblower Safe Harbor: Pursuant to Section 504 of the
Rehabilitation Act and VA Code § 2.2-3011,
any further adverse actions—including coordinated domestic
litigation—will be treated as willful acts of witness
intimidation.
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.
- Remediation of FOIA Larceny: Immediate electronic release of the 944
records (R002510).
- Financial Restitution: Notice of claim for $2,148,000.00
and continuing.
Steve Rubis
Joint Legal Custodian
214-681-7991
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2
attachments
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260504 Gmail -
Expense Reimbursement.pdf
238K
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260504 Gmail -
LCPS Letter - NTO email chain.pdf
1160K
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Steven Rubis <stevenrubis@gmail.com>
|
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Steven Rubis <stevenrubis@gmail.com>
|
Thu, May 7, 2026 at 7:05 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>
|
|
TO: Dr. Aaron Spence; Marc Bergin; John
Clark; Loudoun County School Board
CC: LCSO; Leesburg Police; Dr. Jason
Allison; Dr. John Brewer; Tedra Richardson
DATE: May 6, 2026
SUBJECT: RE: [Master Record] ADMISSION OF PROCEDURAL
MALFEASANCE & SELECTIVE USPS RESPONSIVENESS — REX RUBIS
I. DOCUMENTATION OF EX POST FACTO DUE PROCESS
I am re-anchoring this 12:57 PM communication from Dr.
Jason Allison into the Forensic Record. This email, which
provides the underlying "evidence" for a suspension that has
already concluded, is a de facto admission of Procedural Fraud.
- The
Violation: LCPS Regulation 8220.1 requires the
"explanation of facts known to school personnel" be provided
to the parent to facilitate an appeal. Withholding the statement and
drawings until May 6—after Rex served a suspension that began April
29—rendered the "right to appeal" a fraudulent sham.
II. SELECTIVE RESPONSIVENESS TO USPS CERTIFIED MAIL
This production occurred immediately following the
delivery of my 15th and 16th USPS Certified Letters to Dr. Brewer and Mr.
Bergin.
- The
Malfeasance: This proves that LCPS leadership is capable of
responding to certified legal notices but has maintained a policy
of Administrative Silence regarding the previous 14
letters to shield Nick Cottone and John
Clark, as well as, Lindsay Mohler, her firm Troxel Leigh P.C., and
QlikTech, Inc. (Qlik) from accountability.
III. CUSTODIAL INTERFERENCE & MSA VIOLATION
The production of these documents to me today confirms
that LCPS provided "Real-Time Notification" to the mother on
April 28 while willfully bypassing the Joint Legal Custodian.
- The
Proof: The mother was able to "address the matter
directly" and implement unilateral "discipline"
(Schindler's List report) because LCPS provided her the evidence they
concurrently withheld from me. This is a documented State-Actor
Nexus used to facilitate Custodial Interference and
a breach of my MSA.
IV. VOIDANCE OF THE "VOLUNTARY" STATEMENT
I formally reject and void the "Statement
Form" dated April 28, 2026. Taking a statement from a minor student
regarding "hate speech" charges without notifying or inviting the
Joint Legal Custodian—particularly while I am under a retaliatory No-Trespass
Order—constitutes Administrative Entrapment and a
violation of parental rights.
V. STANDING DEMAND
The belated "cure" of this procedural defect
does not absolve the District of Aggravated Retaliation. I
reiterate my demand for the immediate expungement of this suspension from
Rex's record due to the documented Failure of Due Process.
Steven Rubis
Joint Legal Custodian
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|

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Steven Rubis <stevenrubis@gmail.com>
|
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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
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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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I have sent 24 USPS certified letters return receipt
requested to LCPS. The letters contained the emails listed above. Here are the
USPS details
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Green Return Receipt Cards
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Tracking #
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Person
|
Organization
|
Date Delivered
|
Green Cards
|
|
24
|
9590-9402-0106-6058-4029-34
|
Mark Bergin
|
LCPS
|
5/18/2026
|
|
|
23
|
9590-9402-0106-6058-4029-27
|
Mark Bergin
|
LCPS
|
?
|
|
|
22
|
9590-9402-0106-6058-4029-10
|
Mark Bergin
|
LCPS
|
5/18/2026
|
Yes
|
|
21
|
9590-9402-0106-6058-4028-73
|
Mark Bergin
|
LCPS
|
5/18/2026
|
Yes
|
|
20
|
9590-9402-0106-6058-4028-97
|
Mark Bergin
|
LCPS
|
?
|
|
|
19
|
9590-9402-0106-6058-4028-80
|
Mark Bergin
|
LCPS
|
?
|
|
|
18
|
9590-9402-0106-6058-4029-03
|
Mark Bergin
|
LCPS
|
5/18/2026
|
Yes
|
|
17
|
9590-9402-0106-6058-4029-65
|
Mark Bergin
|
LCPS
|
?
|
|
|
16
|
9590-9402-9292-4295-9894-77
|
Mark Bergin
|
LCPS
|
5/12/2026
|
Yes
|
|
15
|
9590-9402-9292-4295-9894-84
|
John Brewer
|
LCPS
|
5/13/2026
|
Yes
|
|
14
|
9590-9402-0106-6058-4029-72
|
Mark Bergin
|
LCPS
|
5/1/2026
|
Yes
|
|
13
|
9590-9402-0106-6058-4029-41
|
Mark Bergin
|
LCPS
|
5/1/2026
|
Yes
|
|
12
|
9590-9402-0106-6058-4030-54
|
Mark Bergin
|
LCPS
|
4/24/2026
|
Yes
|
|
11
|
9590-9402-0106-6058-4030-61
|
Mark Bergin
|
LCPS
|
4/24/2026
|
Yes
|
|
10
|
9590-9402-9292-4295-9800-78
|
Mark Bergin
|
LCPS
|
4/10/2026
|
Yes
|
|
9
|
9590-9402-9292-4295-9804-43
|
Mark Bergin
|
LCPS
|
3/24/2026
|
Yes
|
|
8
|
9590-9402-9292-4295-9803-68
|
Mark Bergin
|
LCPS
|
Delivered
|
Yes
|
|
7
|
9590-9402-9292-4295-9804-67
|
John Clark
|
LCPS
|
3/11/2026
|
Yes
|
|
6
|
9590-9402-9292-4295-9815-70
|
Aaron Spence
|
LCPS
|
1/8/2026
|
Yes
|
|
5
|
9590-9402-9292-4295-9817-47
|
Aaron Spence
|
LCPS
|
12/20/2025
|
Yes
|
|
4
|
9590-9402-9292-4295-9817-23
|
Aaron Spence
|
LCPS
|
12/20/2025
|
Yes
|
|
3
|
9590-9402-9292-4295-9817-30
|
Kate Ridgeway
|
LCPS
|
12/19/2025
|
Yes
|
|
2
|
9590-9402-9292-4295-9812-59
|
Aaron Spence
|
LCPS
|
12/17/2025
|
Yes
|
|
1
|
9590-9402-9292-4295-9815-49
|
Aaron Spence
|
LCPS
|
12/18/2025
|
Yes
|
|
My Correspondence to LCPS
|
|
|
Tracking #
|
Person
|
Organization
|
Date Delivered
|
|
|
9589-0710-5270-2519-0030-36
|
Mark Bergin
|
LCPS
|
5/15/2026
|
10:39 am et
|
|
9589-0710-5270-2519-0030-43
|
Mark Bergin
|
LCPS
|
5/18/2026
|
12:08 pm et
|
|
9589-0710-5270-2519-0030-50
|
Mark Bergin
|
LCPS
|
5/14/2026
|
12:35 PM ET
|
|
9589-0710-5270-2519-0030-29
|
Mark Bergin
|
LCPS
|
5/14/2026
|
12:35 PM ET
|
|
9589-0710-5270-2519-0030-05
|
Mark Bergin
|
LCPS
|
5/14/2026
|
12:37 pm ET
|
|
9589-0710-5270-2519-0030-12
|
Mark Bergin
|
LCPS
|
?
|
|
|
9589-0710-5270-2519-0030-92
|
Mark Bergin
|
LCPS
|
?
|
|
|
9589-0710-5270-2519-0029-47
|
Mark Bergin
|
LCPS
|
5/7/2026
|
12:55 pm ET
|
|
9589-0710-5270-3374-1553-35
|
Mark Bergin
|
LCPS
|
5/7/2026
|
12:54 pm ET
|
|
9589-0710-5270-3374-1562-71
|
John Brewer
|
LCPS
|
5/5/2026
|
11:45 am ET
|
|
9589-0710-5270-2519-0027-63
|
Mark Bergin
|
LCPS
|
4/27/2026
|
12:36 pm ET
|
|
9589-0710-5270-2519-0027-70
|
Mark Bergin
|
LCPS
|
4/27/2026
|
12:37 pm ET
|
|
9589-0710-5270-4032-0762-52
|
Mark Bergin
|
LCPS
|
4/21/2026
|
12:13 pm ET
|
|
9589-0710-5270-4032-0762-69
|
Mark Bergin
|
LCPS
|
4/21/2026
|
12:13 pm ET
|
|
9589-0710-5270-4032-0754-08
|
Mark Bergin
|
LCPS
|
4/6/2026
|
|
|
9589-0710-5270-0045-3539-53
|
Mark Bergin
|
LCPS
|
3/19/2026
|
|
|
9589-0710-5270-0045-3536-18
|
Mark Bergin
|
LCPS
|
3/12/2026
|
|
|
9589-0710-5270-0045-3523-90
|
John Clark
|
LCPS
|
3/4/2026
|
|
|
9589-0710-5270-0045-3573-57
|
Aaron Spence
|
LCPS
|
1/5/2026
|
|
|
9589-0710-5270-0045-3576-54
|
Aaron Spence
|
LCPS
|
12/15/2025
|
|
|
9589-0710-5270-0045-3577-08
|
Aaron Spence
|
LCPS
|
12/15/2025
|
|
|
9589-0710-5270-0045-3576-78
|
kate ridgeway
|
LCPS
|
12/15/2025
|
|
|
9589-0710-5270-0045-3576-16
|
Aaron Spence
|
LCPS
|
12/12/2025
|
|
|
9589-0710-5270-0045-3576-23
|
Aaron Spence
|
LCPS
|
12/12/2025
|
|
Exhibit B
In Exhibit B, I provide excerpts from a billing statement
provided to my by Lindsay Mohler, and her firm Troxel Leigh P.C. Ms. Mohler
serves as council for my ex wife against me. The billing documents illustrate
illegal and unlawful collusion between her, her firm and LCPS. I have raised
these concerns to LCPS and have been retaliated against by LCPS, and Ms. Mohler
and her firm Troxel Leigh.

The following billing entries illustrate collusion between
private attorney Lindsay Mohler, and her firm Troxel Leigh with both LCPS and
LCSO employees in a private civil matter, where no legal predicate existed for
such communication

The following billing entry illustrates that no legal
predicate existed for the communications between Mohler and LCPS and LCSO in
October 2023, as these communications occurred prior to an actual legal action,
and furthermore, illustrate that Lindsay Mohler and Troxel Leigh P.C. utilized
LCPS and LCSO to manufacture and obtain an advantage in creating a legal action
against me which is a significant Civil Rights violation

Subsequent to these actions, Lindsay Mohler and Troxel Leigh
P.C. served the principal of Lowes Island Elementary School and Seneca Ridge
Middle School, both LCPS schools, where my three children were attending. LCPS
failed to notify me in anyway shape or form that the principals of these
institutions were subpoenaed regarding a legal action against me. More
importantly, the legal action did not involve my children or my custodial
rights, and therefore, the supboenas were inapprorpriate and the non-disclosure
to me unlawful

Then on March 10, 2026, in response to a FOIA request
regarding communications between Lindsay Mohler, Troxel Leigh P.C., and LCPS,
LCPS denied to provided responsive records and cited attorney client privilege.
Ms. Mohler is council for my ex wife, she does not work for LCPS and does not
represent LCPS. Therefore, it is unlawful and highly suspect for LCPS to assert
a claim of privilege over the identified communications. The only reason for
LCPS to take such a position is that the documents are so damaging to Mohler,
Troxel Leigh, LCPS, and LCSO, that LCPS is willing to break the law to withhold
the information.
|

|
Steven Rubis <stevenrubis@gmail.com>
|
|
LCPS Service Request Updated :: R002480-012526
|
|
Loudoun County Public Schools Public Records <lcps@govqa.us>
|
Tue, Mar 10, 2026 at 3:26 PM
|
|
To: "stevenrubis@gmail.com"
<stevenrubis@gmail.com>
|
|
--- Please respond above this line ---
RE: PUBLIC RECORDS REQUEST of January 25, 2026,
Reference # R002480-012526.
Dear Steven Rubis,
Loudoun County Public Schools received a public
information request from you on January 25, 2026 for the following:
“TO: Dan Adams (Acting Public Information Officer /
VFOIA Officer)
DATE: January 25, 2026
RE: VFOIA Request – Private Legal Coordination and Executive Correspondence
Request Text: Pursuant to the Virginia Freedom of Information Act (Va. Code
§ 2.2-3700 et seq.), I request copies of any and all correspondence
(including but not limited to emails, text messages, and internal memos)
between the following parties for the period of January 1, 2023, to the
present:
External Parties:
Lindsay Mohler (lmohler@tllawpc.com)
Gareth Bowen (gbowen@tllawpc.com)
General domain: @tllawpc.com
Internal LCPS Parties:
Executive/Legal: Dr. Aaron Spence, Shontel Simon, Rae Mitchell, Paige
Carter, Gus Martinez.
Administrative/School: Dr. Kate Ridgeway, Nick Cottone, John Brewer, Andrew
Davis.
Investigative/Oversight: Devina Martin, Ashley Stocks, Lisa Boland, Tedra
Richardson, the LCPS School Board (lcsb@lcps.org), and the LCPS Ombudsman.
Keywords/Search Terms: This search should include, but not be limited to,
the names "Steven Rubis," "Timothy Iversen," and
references to "Seneca Ridge Middle School," "Lowes Island
Elementary," or "incident report/workforce complaint."
Request for Fee Waiver: As an investigative publisher (nickcottone.blogspot.com),
these records are requested in the public interest to document the
intersection of private legal entities and public school administration. I
request a waiver of all fees; should fees exceed $25.00, please provide an
itemized estimate before proceeding.”
Loudoun County Public Schools has reviewed its files and
has located responsive records to your request. Please log in to the Public
Records Center to retrieve the appropriate responsive
documents. In addition, 172 pages of records contain the written
advice of legal counsel and other information protected by attorney-client
privilege, withheld from disclosure under Va. Code § 2.2-3705.1(2); 34
pages contain investigative notes and other correspondence, and information
furnished in confidence with respect to an investigation, withheld from
disclosure under Va. Code §§ 2.2-3705.3(3) and 2.2-3705.3(5); 5 pages
contain the working papers and correspondence of the Superintendent,
withheld from disclosure pursuant to Va. Code § 2.2-3705.7(2); and 5 pages
contain information that would reveal security, operational, procedural or
tactical plans or protocols, the disclosure of which would jeopardize the
safety or security of any person; governmental facility, building, or
structure or persons using such facility, building, or structure, and are
withheld from disclosure pursuant to Va. Code § 2.2-3705.2(14)(c).
Public Records Request - R002480-012526
If you have any questions, or wish to discuss this
further, please contact me at (571)252-1040 or LCPSFOIA@lcps.org.
Sincerely,
Dan Adams
FOIA Officer
Loudoun County Public Schools
|
|
Exhibit C
In Exhibit C, I illustrate several emails sent to
LCPS, which included both Dr. Aaron Spence and the LCPS School Board, notifying
them that I had filed a Federal OCR complaint and a complaint with Virginia
DOE.
|

|
Steven Rubis <stevenrubis@gmail.com>
|
|
NOTICE OF FILING: FEDERAL (OCR) & STATE (VDOE)
INVESTIGATIONS - SELECTIVE DATA SPOLIATION (Charles Rubis)
|
|
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
|
|
I then sent the following email as a supplement to Dr. Aaron
Spence and the LCPS School Board among others:
|

|
Steven Rubis <stevenrubis@gmail.com>
|
|
NOTICE OF FILING: FEDERAL (OCR) & STATE (VDOE)
INVESTIGATIONS - SELECTIVE DATA SPOLIATION (Charles Rubis)
|
|
Steven Rubis <stevenrubis@gmail.com>
|
Mon, Feb 9, 2026 at 8:37 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: URGENT SUPPLEMENT: Clinical Safety
Data & Emotional Disability Classification (Charles Rubis)
TO: Dr. Aaron Spence (Superintendent); LCPS
Legal; Gus Martinez (Executive Principal) CC: Dr. Kate
Ridgeway; VDOE (omni-sped@doe.virginia.gov);
OCR (OCR.DC@ed.gov)
Dear Dr. Spence and LCPS Legal,
Further to my previous notice regarding the digital
records blockade for Charles Rubis, I am attaching the student’s April
2025 IEP for your immediate review.
The District must recognize that the records currently
being suppressed are not merely academic—they are life-safety
records. As documented on Pages 1 and 3-4 of the
attached IEP:
- Primary
Disability: Charles is classified under Emotional
Disability.
- Clinical
Vulnerabilities: The IEP documents symptoms of "perfectionism,
anxiety, depression, and a low level of frustration tolerance."
- Specific
Risk: The District has identified that his disability results
in "shutting down" and "destructive
behavior."
By manually terminating my parental access to this
behavioral and mental health data within 60 minutes of my whistleblower
disclosure, the District has knowingly obstructed my ability to monitor the
emotional stability of a student at high clinical risk.
This attachment serves as a formal notice that the
District is now in possession of the specific clinical reasons why this
"Digital Blockade" constitutes a threat to student safety.
Steven Rubis
[Quoted text hidden]
|

|
|
CHarles RUbis IEP for 2025.pdf
223K
|
|
|
|
Here is the email submission I sent to VA DOE
|

|
Steven Rubis <stevenrubis@gmail.com>
|
|
EMERGENCY: Consolidated Complaint - Record Suppression
(Charles Rubis / LCPS)
2 messages
|
|
Steven Rubis <stevenrubis@gmail.com>
|
Tue, Feb 10, 2026 at 9:17 PM
|
|
To: Hank.Millward@doe.virginia.gov,
Samantha.Hollins@doe.virginia.gov
|
|
CONSOLIDATED EMERGENCY FILING
DATE: February 10, 2026 TO: Hank.Millward@doe.virginia.gov; Samantha.Hollins@doe.virginia.gov; special-education.complaints@doe.virginia.gov FROM: Steven
Rubis, Parent / Joint Legal Custodian RE: Emergency
Complaint: Record Suppression and Multi-Year Rights Deprivation (Charles
Rubis / LCPS)
Dear Mr. Millward and Dr. Hollins,
I am filing this consolidated emergency notice because
your department's automated servers are rejecting individual transmissions
(Error 550: Access Denied). Attached to this email are four critical
evidence chains documenting a 48-hour campaign of record suppression by
Loudoun County Public Schools (LCPS).
Summary of Attached Evidence:
- Attachment
1 (IEP Addendum): Clinical context regarding Charles’s Emotional
Disability and the safety risks of withholding his behavioral
data.
- Attachment
2 (Data Spoliation Notice): Proof that LCPS was served with
a Litigation Hold to preserve audit logs before the
historical records were removed.
- Attachment
3 (Administrative Gaslighting): Documentation of LCPS
leadership reframing reported civil rights violations as
"unprofessional personal attacks".
- Attachment
4 (Forensic Audit Request): Evidence that as of February 10,
the April 2025 IEP and all records dating back to
2022 have been forensically scrubbed from my portal view.
Legal Context: These actions are the latest
escalation in a multi-year campaign to bypass my joint legal custody
rights. The District intentionally exploits a
"One-Signature" policy to allow the other parent to sign off on
high-stakes changes—including a forced transition tour this Thursday,
February 12—while suppressing the legal documents required for my review.
Required Action: I request an immediate
forensic audit of the Virginia IEP system logs to identify the User ID
responsible for scrubbing these records. I further demand an
immediate Administrative Stay of the February 12
transition until my full access is restored.
Respectfully submitted,
Steven Rubis
|
4 attachments
|
|

|
|
260210 Gmail - URGENT_ Forensic Audit Requested -
Systematic Erasure of Records and Multi-Year Rights Deprivation
(Charles Rubis).pdf
176K
|
|
|
|

|
|
260209 Gmail - NOTICE OF FILING_ FEDERAL (OCR)
& STATE (VDOE) INVESTIGATIONS - SELECTIVE DATA SPOLIATION (Charles
Rubis).pdf
152K
|
|
|
|

|
|
260209 Charles Rubis IEP addendum email.pdf
102K
|
|
|
|

|
|
260210 Gmail - NOTICE OF ADMINISTRATIVE
GASLIGHTING AND PROCEDURAL NON-COMPLIANCE.pdf
103K
|
|
|
|
|
|
DOE - ODRAS <ODRAS@doe.virginia.gov>
|
Wed, Feb 11, 2026 at 8:33 AM
|
|
To: "stevenrubis@gmail.com"
<stevenrubis@gmail.com>
|
|
Hello –
Thank you for your inquiry. The Virginia Department of
Education is in receipt of your correspondence and
will forward it to staff in the Office of Special Education
Dispute Resolution for review. Department staff will follow up
accordingly. For direct assistance, you may contact the
Office of Dispute Resolution and Administrative Services at (804) 750-8143
or via email at odras@doe.virginia.gov.
Information regarding special education dispute resolution can be
found on the VDOE website at Resolving Disputes.
Thank you,
|
|
Here is my submission to Federal OCR:

Here are the emails representing the initial submission and
subsequent updates in February 2026:
|

|
Steven Rubis <stevenrubis@gmail.com>
|
|
URGENT SAFETY ADDENDUM & CONSENT FORM: Charles
Rubis (Emotional Disability / Retaliation Case)
4 messages
|
|
Steven Rubis <stevenrubis@gmail.com>
|
Mon, Feb 9, 2026 at 10:24 PM
|
|
To: ocr.dc@ed.gov
|
|
Subject: URGENT SAFETY ADDENDUM &
CONSENT FORM: Charles Rubis (Emotional Disability / Retaliation Case)
To the OCR Investigator:
Please find my signed OCR Complaint Consent Form attached,
along with the following Exhibits supporting my complaint
filed on February 9, 2026. This addendum highlights the urgent safety risks
created by the "Digital Blockade" enacted by Loudoun County
Public Schools (LCPS).
The records currently being suppressed by the District
are life-safety records for a student with a primary
disability of Emotional Disability. According to his April 2025
IEP (Page 3-4):
- Clinical
Vulnerability: Charles is documented as having symptoms
of "anxiety, depression, and a low level of frustration
tolerance."
- Identified
Risk: The District has documented that his disability
presents as "shutting down" or "destructive
behavior."
- Specific
Concern: In October 2025, the other parent reported Charles
returning home "depressed." Despite this, the District has
refused to provide daily behavioral logs or mental health progress
data.
Pattern of Administrative Retaliation (Evidence
Attached): The manual termination of my records access today
occurred within 60 minutes of a whistleblower disclosure. This is
consistent with the District's prior conduct:
- Exhibit
A (April 2025 IEP): Proves the District has long-standing
knowledge of Charles’s Emotional Disability and safety triggers.
- Exhibit
B (December 17, 2025 Email): Documented notice to LCPS
regarding a physical safety incident on Dec 12, where staff mocked the
student’s disability and delayed notification to me for four days.
- Exhibit
C (December 19, 2025 "Ambush" Letter): A letter
from Chief of Schools Rae Mitchell attempting to silence my reports of
these IEP violations by characterizing them as "unprofessional
attacks."
The Danger of the Blockade: By blocking my
access, the District is preventing me—a joint legal custodian—from
monitoring the daily emotional stability of a student at high clinical
risk. This is a direct retaliatory strike designed to facilitate a forced
school transition on February 12 without parental oversight of safety data.
I request that OCR prioritize this case due to the
imminent risk of emotional harm caused by the intentional suppression of
disability-related safety data and the documented pattern of administrative
intimidation.
Sincerely,
Steven Rubis (Phone: 202-997-4815)
|
5 attachments
|
|
|
|
260209 OCR Consent Agreement - Rubis.jpg
3467K
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Exhibit A - April 2025 IEP for Charles Rubis.pdf
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Exhibit C - 251218 ambush letter from rae
mitchell in response to my concerns about charles and nick cottone.pdf
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Exhibit C - Rae MItchell Correspondence and
Communication Ban.pdf
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Exhibit B - 251217 urgent response to dec 12
incident and notice of policy violations 446 PM.pdf
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Steven Rubis <stevenrubis@gmail.com>
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Tue, Feb 17, 2026 at 7:00 AM
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To: ocr.dc@ed.gov
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TO: OCR Investigator
DATE: February 17, 2026
RE: NOTICE OF AGGRAVATED RETALIATION
(TEMPORAL PROXIMITY) – CASE REF: CHARLES RUBIS
To the OCR Investigator:
I am filing this second urgent addendum to document
retaliatory acts occurring within 72 hours of my February 9, 2026 (6:45 PM
ET) formal filing. Despite the "Urgent Safety Addendum"
previously provided to your office, Loudoun County Public Schools (LCPS)
willfully proceeded with the unauthorized transport of my son, Charles
Rubis, to a location where he was personally targeted by an administrator
named in my complaint.
I. Documented Post-Filing Retaliation
- Temporal
Proximity: On Thursday, February 12—less than 72 hours after
my OCR filing—the District transported the Student to Seneca Ridge
Middle School (SRMS) in direct defiance of a formal Cease & Desist
and Revocation of Consent served on February 9.
- Targeted
Intimidation (Exhibit L): Principal Nick Cottone—the
individual named in my complaint for administrative fraud—personally
singled out the Student. As the attached transcript (Exhibit L)
confirms, Mr. Cottone utilized his knowledge of my family to identify
the Student by relation to his sibling (Rex Rubis). This
contact occurred while the Parent was subjected to a "Digital
Blockade" that concealed the trip itinerary.
- Hostile
Educational Environment: Following the interaction with the
Principal, the Student (who has an Emotional Disability)
was subjected to arbitrary punitive discipline by staff, resulting in
emotional distress and clinical "shutdown" consistent with
the disability markers identified in his April 2025 IEP.
- Spoliation
of Evidence (Exhibit N): On February 13, the District
admitted to "extracting and deleting" student data from
the Qlik platform—a vendor with a documented history
of adversarial coordination with Lindsay Mohler and Troxel
Leigh P.C. targeted at the Parent.
II. Demand for Priority Review The
District’s actions confirm a pattern of using unauthorized school
transitions as a venue for whistleblower intimidation. I request that OCR
immediately intervene to address this documented retaliation and the
ongoing suppression of disability-related safety records.
Sincerely,
Steven Rubis
[Quoted text hidden]
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7 attachments
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Exhibit K - 260209 Office for Civil Rights
Discrimination Complaint Form _ OCR.pdf
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Exhibit L -
260215_Transcript_Dad_and-CHarles_Discuss_SMRS_Field_trip.pdf
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Exhibit J - 260209 Gmail - FINAL CEASE &
DESIST AND NOTICE OF WILLFUL MISCONDUCT_ Exclusion of Charles Rubis
from Seneca Ridge Middle School Transition.pdf
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Exhibit K - 260209 ocr_complaint_consent_form.pdf
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Exhibit M - 260211 - Gmail - 005E00-505 - Grade 5
(Charles Rubis) - 2_12 Field Trip - Blank Email.pdf
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Exhibit O - 260213 Gmail - NOTICE OF TOTAL
PAYMENT UNDER PROTEST – Ref_ R002450-122925, R002437-121125,
R002480-012526.pdf
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Exhibit N - 260213 Gmail - 005E00-505 - Grade 5
(Charles Rubis) - 2_13 Weekly Memo - email states Charlie went to
SMRS.pdf
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Steven Rubis <stevenrubis@gmail.com>
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Wed, Feb 18, 2026 at 7:15 AM
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To: ocr.dc@ed.gov
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UPDATED NOTICE OF AGGRAVATED RETALIATION &
EVIDENCE SUPPRESSION
RE: NOTICE OF CONSTRUCTIVE DENIAL AS ONGOING
RETALIATION
I am formally notifying your office that as of 4:00 PM
ET on February 17, 2026, Loudoun County Public Schools (LCPS) has entered a
state of Constructive Denial regarding 944 responsive
records regarding a FOIA request I submitted weeks ago. These records
detail the coordination between District officials and private counsel
(Lindsay Mohler/Troxell Leigh P.C.)—the precise 'Public-Private Nexus' I
allege is responsible for the ongoing suppression of my son's historical
IEP and life-safety records.
Despite my remittance of payment on February 12, 2026,
the District has ceased all communication and refused to provide a
production timeline. This obstruction is explicit retaliation for
my February 9 filings with the VDOE and OCR. Given the extreme temporal
proximity, this 'financial ghosting' represents a bad-faith effort to
suppress evidence material to your investigation while maintaining the
'Digital Blockade' of my son’s educational data. This suppression serves as
a continuation of the retaliatory environment that led to the unauthorized
targeting of my son at Seneca Ridge Middle School on February 12.
Furthermore, LCPS has ceased all communication with me
as a parent of three children enrolled in their schools, with two of the
three on active IEPs. LCPS has unilaterally acted to erase me and impinge
upon my parental rights to be an advocate for my children.
[Quoted text hidden]
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Steven Rubis <stevenrubis@gmail.com>
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Thu, Feb 19, 2026 at 11:53 AM
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To: ocr.dc@ed.gov
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OCR ADDENDUM: COMPREHENSIVE EVIDENCE OF COORDINATED
RETALIATION & SYSTEMIC DATA SUPPRESSION
TO: Office for Civil Rights (OCR)
Investigator
DATE: February 19, 2026
RE: SUPPLEMENTAL EVIDENCE OF ONGOING RETALIATION –
OCR COMPLAINT FILED FEB 9, 2026
This filing provides critical forensic evidence
supporting my February 9, 2026, complaint regarding administrative
retaliation and the discriminatory suppression of my son's records. The
evidence documents a multi-year, coordinated 'Pincer Movement' involving
LCPS vendor QlikTech, Inc. and private counsel Lindsay
Mohler (Troxell Leigh P.C.) designed to facilitate the financial
destruction of a whistleblower parent and the administrative erasure of a
disabled student’s life-safety history.
I. The Forensic Foundation: Historical Vendor-Counsel
Fraud (May 2024)
- Exhibit
ELE 0032 (May 10, 2024): LCPS data vendor QlikTech, Inc.
provided a manufactured 'self-volunteered' narrative to Lindsay Mohler
regarding my professional departure. This statement directly
contradicted Qlik’s own internal legal and severance records verifying
a 'Termination' due to a Reduction in Force.
- Weaponization
of Fraud (May 15, 2024): Attorney Lindsay Mohler immediately
utilized this fraudulent data to coerce an unfavorable settlement and
justify the denial of support in Case No. CL21-6851-02.
This proves the vendor and counsel collaborated to manufacture adverse
evidence for the purpose of financial and reputational harm.
II. The 2026 'Digital Blockade' and Systemic
Spoliation of Evidence: The documented history of collusion
informs the current, aggravated suppression of my son's clinical and
educational records:
- The
944-Record Constructive Denial: Following my payment on
February 12, 2026, LCPS entered a state of Constructive Denial regarding
944 responsive records detailing coordination with Lindsay Mohler.
This mirrors the LCSO's ongoing tolling of similar
requests, suggesting a unified effort to protect the private interests
of Troxell Leigh P.C. over the safety of a student.
- Mass
Data Deletion & Portal Erasure (February 13, 2026): Four
days after my federal filing, LCPS admitted to a 'Data Deletion' event
on the Qlik platform. This event coincides with the total
disappearance of my son's historical record from the Virginia IEP
Connect portal, including:
- Missing
Life-Safety Records: Documentation of three
interventions for suicide attempts in late 2022 and early
2023.
- Historical
IEP Documentation: All IEP-related records dating back to
2023 are currently unavailable.
- April
2025 IEP Data: Crucial life-safety/itinerary data material
to the active investigation remains missing.
- Aggravated
Retaliation: I allege these records were willfully extracted
and/or deleted to prevent the OCR from discovering the District's
failure to provide FAPE and life-safety oversight.
III. FORMAL REQUESTS FOR INVESTIGATIVE ACTION: The
District is leveraging its relationship with Troxell Leigh and QlikTech
Inc. to 'scrub' the administrative record of life-safety failures. I
request that the OCR take the following immediate actions:
- Forensic
Recovery Demand: Order LCPS to perform an immediate forensic
recovery and production of the 2022-2023 suicide intervention records
and all historical IEP data missing from the Virginia IEP Connect
portal.
- Federal
Subpoena of 944 Records: Issue a subpoena for the 944
coordination records currently being withheld by LCPS under
'Constructive Denial' to prevent further spoliation.
- Expansion
of Investigation: Expand the scope of the investigation to
include QlikTech, Inc. as an adverse actor in the
selective suppression of clinical history during an active federal
civil rights investigation.
- Audit
of 'Data Deletion' Event: Conduct an independent audit of the
February 13, 2026, Qlik platform 'deletion' event to determine if
specific clinical data or safety itineraries were targeted for
removal.
- Interim
Protective Measures: Implement measures to ensure the
immediate restoration of parental access to the student’s portal to
mitigate ongoing safety risks.
[Quoted text hidden]
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3 attachments
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Qlik lawsuit.pdf
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240515 Mohler uses Qlik to force a settlement
with Rubis Using Fraudulent Data supplied by Qlik.pdf
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qlik subpoena response.pdf
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Here is the most recent submission to US DOE regarding
my OCR complaint:
VIA EMAIL AND USPS CERTIFIED MAIL
April 21, 2026
Abony Alexander Office for Civil Rights, Washington
DC (Metro) U.S. Department of Education 400 Maryland Avenue, SW Washington,
D.C. 20202-1475
RE: Case Number: [Insert Case Number] – URGENT FORENSIC
SUPPLEMENT: RECORD OF SYSTEMIC RETALIATION, ADMINISTRATIVE ABANDONMENT, AND
PROCEDURAL FRAUD
Dear Ms. Alexander,
Enclosed please find the physically signed OCR Complaint
Consent Form (Section A). In addition to this form, I am submitting this Forensic
Supplement (37 pages) and a Certification of Unresponsive Correspondence.
This submission serves as an immutable record of the aggravated retaliation and
systemic civil rights violations executed by Loudoun County Public Schools
(LCPS) since the filing of my initial complaint.
I. CERTIFICATION OF ADMINISTRATIVE ABANDONMENT As of
April 21, 2026, I have dispatched fourteen (14) separate legal
communications via USPS Certified Mail – Return Receipt Requested to the
LCPS Superintendent, Chief of Staff, and Division Counsel.
- The
Original Record: Packages #1 through #6 (December 2025–January 2026)
represent the formal complaints and administrative attempts to resolve the
issues cited in my original Federal OCR filing.
- The
Supplemental Record: Packages #7 through #14 represent the forensic
documentation of the District’s escalated retaliation as detailed in the
attached 37-page evidentiary chain.
- Forensic
Default: LCPS has failed to respond to a single inquiry. This silence
represents a willful decision by the District to remain in administrative
default to facilitate the ongoing deprivation of my parental and civil
rights.
II. FORENSIC RECORD OF SPECIFIC VIOLATIONS
1. Aggravated Retaliation Against a Minor Child (The Feb
12 Incident): Immediately after naming Principal Nick Cottone (Seneca Ridge
MS) in my Federal OCR complaint and revoking consent for my son, Charles, to
attend a field trip at Seneca Ridge Middle School led by Mr. Cottone, Mr.
Cottone physically singled out my child and engaged in inappropriate physical
contact. This act occurred in direct retaliation for my protected advocacy and
served as the catalyst for the District's subsequent campaign to "shield"
Mr. Cottone via a fraudulent No-Trespass order.
2. The Fraudulent No-Trespass Order (Feb 24, 2026):
Following my FOIA requests into vendor fraud (QlikTech, Inc.) and the Cottone
incident, LCPS issued a one-year No-Trespass order citing a fictitious
"virtual meeting" pretext. This order explicitly bans my access to "all
digital platforms," a forensic blockade designed to prevent my receipt
of 944 paid-for FOIA records ($559.70) documenting state-actor collusion.
3. Direct Retaliatory Linkage to Initial OCR Complaint
(The Mitchell Letter): The February 24, 2026, No-Trespass order explicitly
cites a letter issued by Rae Mitchell in December 2025 as a primary
justification. This December 2025 letter was a core exhibit in my initial
Federal OCR filing. By utilizing a contested OCR exhibit to justify a criminal
ban, the District has engaged in a "Circular Retaliation" loop,
proving the ban is a punitive strike against my federal petition for redress.
4. Bad-Faith "Digital Entrapment" and
Procedural Sabotage: The District has utilized the "Digital
Blockade" to constructively exclude me from my sons' education. LCPS
unilaterally scheduled "Transition" and "Annual" IEP
meetings for Charles (April 7) and Beau (April 13) via virtual links. Because
the No-Trespass order criminalizes my access to digital platforms, providing
only digital links for mandatory meetings is an act of Criminal Entrapment.
5. Evidence of Predetermination (The April 6 Sham):
The enclosed supplement proves that on April 6, 2026, Cheryl Shotwell finalized
my son’s school assignment 24 hours before the mandated transition
meeting, rendering the IEP process a forensic sham in violation of Federal
Safeguards.
6. Forensic Admission of State-Actor Collusion (The March
10 Default): On March 10, 2026, LCPS admitted to withholding 172 pages of
correspondence with private attorney Lindsay Mohler (Troxell Leigh P.C.) under
a fraudulent claim of "Attorney-Client Privilege." As Ms. Mohler is a
private third-party attorney, this is a prima facie admission of the
"renting" of public resources to facilitate a private legal vendetta.
III. THE "TITAN" CONTRADICTION As
documented on April 20, 2026, the District continues to solicit me for
financial donations (referencing me as a "Fellow Titan") while
simultaneously labeling me a "security threat." This contradiction
confirms the "security" narrative is a bad-faith fabrication.
IV. RECORD OF CORRESPONDENCE AND ADMINISTRATIVE DEFAULT
(USPS CERTIFIED) The following ledger documents the correspondence
delivered to LCPS for which the District remains in default:
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Pkg #
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Correspondence Tracking #
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Delivery Date
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Green Card Tracking #
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Green Card Status
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1
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9589-0710-5270-0045-3576-23
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2025-12-12
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9590-9402-9292-4295-9815-49
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Delivered (12/18)
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2
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9589-0710-5270-0045-3576-16
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2025-12-12
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9590-9402-9292-4295-9812-59
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Delivered (12/17)
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3
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9589-0710-5270-0045-3576-78
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2025-12-15
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9590-9402-9292-4295-9817-30
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Delivered (12/19)
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4
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9589-0710-5270-0045-3577-08
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2025-12-15
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9590-9402-9292-4295-9817-23
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Delivered (12/20)
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5
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9589-0710-5270-0045-3576-54
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2025-12-15
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9590-9402-9292-4295-9817-47
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Delivered (12/20)
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6
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9589-0710-5270-0045-3573-57
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2026-01-05
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9590-9402-9292-4295-9815-70
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Delivered (01/08)
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7
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9589-0710-5270-0045-3523-90
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2026-03-04
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9590-9402-9292-4295-9804-67
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Delivered (03/11)
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8
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9589-0710-5270-0045-3536-18
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2026-03-12
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9590-9402-9292-4295-9803-68
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Delivered
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9
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9589-0710-5270-0045-3539-53
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2026-03-19
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9590-9402-9292-4295-9804-43
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Delivered (03/24)
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10
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9589-0710-5270-4032-0754-08
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2026-04-06
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9590-9402-9292-4295-9800-78
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Delivered (04/10)
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11
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9589-0710-5270-4032-0762-69
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2026-04-21
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9590-9402-0106-6058-4030-61
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In Process
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12
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9589-0710-5270-4032-0762-52
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2026-04-21
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9590-9402-0106-6058-4030-54
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In Process
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13
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9589-0710-5270-2519-0027-70
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2026-04-21
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9590-9402-0106-6058-4029-41
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In Process
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14
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9589-0710-5270-2519-0027-63
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2026-04-21
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9590-9402-0106-6058-4029-72
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In Process
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V. FORENSIC NEXUS: LCPS RETALIATION AS A SHIELD FOR
VENDOR FRAUD AND PRIVATE COLLUSION
1. Retaliatory Pincer Following Ethics Disclosures:
Subsequent to the filing of my initial Federal OCR complaint, I engaged in
further protected activity including a Formal Request for Vendor Debarment
(QlikTech, Inc.) on Feb 19, a NJ Bar Ethics Grievance on Feb 21, and a PA
Bar Ethics Grievance on Feb 23 against Qlik Associate General Counsel Feyi
Obafemi. The District’s issuance of the No-Trespass Order on Feb 24 serves as a
direct retaliatory strike designed to protect a multi-million dollar vendor and
its executive from professional accountability.
2. Suppression of Vendor Integrity Records: The
No-Trespass order suppresses my ability to access responsive records regarding
Qlik and vendor integrity identified by LCPS through my specific FOIA requests.
This order was implemented to criminalize my access to these digital records;
despite my formal requests for physical production to resolve this blockade,
LCPS has remained in total administrative default.
3. State-Actor Nexus and the "Renting" of
Police Power: The 1,141 responsive records identified in my FOIA requests
involve the illicit state-actor nexus between private attorney Lindsay
Mohler, LCPS, and the Loudoun County Sheriff’s Office (LCSO). On 12/12/23,
I was subjected to an extrajudicial police call from Officer Tim Iversen
(LCSO) at the behest of Ms. Mohler and Nick Cottone. In a recorded
statement, Officer Iversen admitted there was no legal predicate for his
interrogation. This coordination was executed to violate my 14th Amendment
rights without due process.
4. Fraudulent Assertion of Privilege: Lindsay Mohler
is a private attorney representing my ex-wife; she is not an LCPS employee and
does not represent the District. There are no legal filings in existence
regarding my parental rights or custody that would justify her coordination
with the School Board. The District’s decision to claim "Attorney-Client
Privilege" over communications with this private third party is a prima
facie admission of a fraudulent legal partnership used to shield a private
legal vendetta from discovery.
I request that OCR take immediate jurisdiction over this
matter to prevent the permanent erasure of my parental rights and the ongoing
harassment of my minor children.
Section VI: Systemic Pattern and Practice of Civil Rights
Violations (2023–2026)
The current retaliatory strike is the culmination of a
three-year pattern of systemic administrative lawlessness and the willful
deprivation of parental and student rights by LCPS.
1. Exhaustion of Internal Remedies (Workforce
Complaints): Over the past 36 months, I have filed over a dozen formal
workforce and administrative complaints regarding egregious policy violations,
the infringement of my parental rights, and the denial of a Free Appropriate
Public Education (FAPE) for my children. LCPS has consistently failed to
adjudicate these matters in accordance with its own policies, choosing instead
to escalate its hostility toward my family.
2. History of Parental Exclusion: The District’s
current "Digital Blockade" is an escalation of previous tactics. As
documented in my records, LCPS staff, including Principal Ridgeway and Mara
Moreland, explicitly prohibited me from attending a mandated IEP meeting as far
back as November 2023. The 2026 No-Trespass order is simply a police-enforced
formalization of a long-standing practice of parental exclusion.
3. Willful Indifference to Documented Misconduct:
Despite providing clinical evidence of administrative fraud and the
inappropriate interrogation of my minor child by District personnel, LCPS has
refused to investigate or discipline the actors involved. Instead, the District
has utilized the Office of Safety and Security to criminalize my reporting of
these incidents.
4. Incorporation of Prior Complaints: I am formally
incorporating the records of these prior dozen+ workforce complaints into this
federal filing to illustrate a "Pattern and Practice" of retaliation.
These prior acts establish that the District acted with Knowledge and Malice
when it issued the February 24, 2026, criminal ban.
Sincerely,
Steven A. Rubis
Exhibit E
In Exhibit E, I illustrate the May 2025 email
admission of my ex wife about placing a tracking device on me in October 2023.
Her placing the tracking device on me is what generated the entire series of
events where my civil rights have been attacked and I have been erased by a
parent by LCPS on behalf of Lindsay Mohler, ex wife council, and her firm
Troxel Leigh P.C.
The issue is that I then sought an emergency order of
protection from the VA Magistrate on October 9, 2023, and then a sought a
restraining order from Loudoun County Court on October 11, 2023. I was denied
my request. Lindsay Mohler and her firm then used my protective request to
retaliate against me and create false pretense that I was a safety threat in
conjunction with LCPS.
The admission of my ex wife placing the tracking device on
my in May 2025, serves to impeach any color of law pretext used to paint me as
a security threat by LCPS (I live in Chicago, IL, over 700 miles away)
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Steven Rubis <stevenrubis@gmail.com>
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Elizabeth Entsminger <elizabeth.entsminger@gmail.com>
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Fri, May 9, 2025 at 9:16 AM
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To: Steven Rubis <stevenrubis@gmail.com>
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Steve,
As I mentioned previously, I am willing to honor the two
additional days in the summer as a make-up for the February reschedule.
That offer still stands, and it is entirely up to you whether you’d like to
use those days. You’ve expressed a desire to have more time with the boys,
so I’m unclear on why you might decline this opportunity, but I respect
your choice either way. Outside of that prior accommodation offered, I am
holding to the current custody agreement unless and until a new formal
agreement is signed.
Regarding the air tags placed in the children's
backpacks in October 2023 — this step was taken only after you refused to
provide the address where the boys would be staying that weekend, which was
a violation of the MSA. Rather than involving law enforcement and
disrupting your visitation, I opted for a solution that prioritized the
boys’ comfort and security. I have no interest in tracking you personally —
only in ensuring I am aware of where our children are staying, which is my
right outlined in our signed agreement. Unfortunately, this issue has
persisted, as you did not follow through with your stated intention to
provide full address details during Spring Break. I never received
communication on where the boys were staying on Saturday, 4/19.
I’d also like to clarify that legal action on my end was
only taken after you contacted my employer on three separate occasions with
either false claims or personal matters intended to interfere with my
employment. My attorney acted on my behalf to protect against further
harassment. I was unaware that you attempted to file a restraining order,
and as I was never served, I assume the court did not find sufficient cause
to proceed. My only communications to you have been related to parenting
matters.
Finally, earlier this week you instructed me to contact
you only during business hours (8am CT/9am ET - 5pm CT/6pm ET). I’d like to
clarify whether this is an expectation for both parties, as you have not
adhered to that standard yourself including this morning's communication.
As co-parents, it’s reasonable to allow communication at any time, with the
understanding that each of us can choose when to review and respond
appropriately.
Respectfully,
Liz
[Quoted text hidden]
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#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 #JohnWhitbeck #whitbeckbeglis #whitbeckbennett
#LoudounCounty #Loudoun #LoudounCountyVirginia #LoudounCountyCourt #OfficeofCivilRights #departmentofeducation #OCR #virginiadepartmentofeducation
#qlik #QLIK #thomabravo #qliksense #dennisjohnson #mikecapone #debbielofton #orlandobravo
#timwalberg #housecommitteeoneducationandworkforce #committeeoneducationandworkforce #USCongress
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