| 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>, Abony.Alexander@ed.gov, LCSO_FOIA@loudoun.gov, TitleIXCoordinator@lcps.org, "jamie.braxton@lcps.org" <jamie.braxton@lcps.org> |
Via Email
FORMAL ADMINISTRATIVE TRANSMISSION: EXHIBIT G-8 (DOMINION HS ZERO NIGHT SOLICITATIONS & CONTINUOUS NTO WAIVER)TO: Marc Bergin, Chief of Staff; John Clark, Director of Safety & Security; CC: Dr. Aaron Spence, Superintendent; Loudoun County School Board; Loudoun County Sheriff's Office; Leesburg Police Department; U.S. Department of Education, Office for Civil Rights (OCR); John Brewer, Principal (DMH.noreply@lcps.org); Jamie Braxton, Assistant Principal (Jamie.Braxton@lcps.org) DATE: August 12, 2026 SUBJECT: ADMINISTRATIVE DEPOSIT OF EXHIBIT G-8 — FORENSIC NOTICE OF BAD-FAITH CAMPUS SOLICITATIONS BY DOMINION HS ADMINISTRATION AND CONTINUOUS OPERATIONAL WAIVER OF NO-TRESPASS ORDER Mr. Bergin, Mr. Clark, and Division Counsel, et al. Please find attached Forensic Exhibit G-8 (comprising four primary transmissions: 260712 Gmail - Save the Date for Zero Night.pdf,
260806 Gmail - DOMINION HIGH SCHOOL - PREPARING FOR ZERO NIGHT.pdf,
260806 Gmail - DOMINION HIGH SCHOOL - Corrected Dinner Link.pdf, and
260811 Gmail - DOMINION HIGH SCHOOL - Zero Night, Student Schedules.pdf).
These official communications, issued directly by Dominion High School Principal John Brewer and Assistant Principal Jamie Braxton, forensically document an aggravated administrative contradiction and an uncontradicted operational waiver of the February 24, 2026 No-Trespass Order (NTO): Direct Subordinate Delegation & Bad-Faith Communication Routing: While Central Office leadership remains completely non-responsive to formal legal notices and whistleblower grievances, LCPS administrators are routing broadcast communications through Dominion High School leadership. Principal John Brewer was explicitly copied on the February 24, 2026 NTO (cc: John Brewer, Principal). Allowing Principal Brewer and his direct report, Assistant Principal Jamie Braxton, to repeatedly issue direct invitations to the Complainant soliciting physical attendance at "Zero Night" on Wednesday, August 12, 2026 (including dinner at 4:00 PM and campus schedule walk-throughs at 6:00 PM) constitutes an improper administrative trap or, in the alternative, a total operational waiver of the order. Entrapment Risk vs. Legal Waiver: LCPS cannot legally sustain a criminal lockout under Va. Code § 18.2-119 premised on a "security threat" while its high school leadership continuously issues broadcast solicitations urging the Whistleblower to enter campus facilities, park in the main lot, meet teachers, and walk student schedules. Attempting to enforce an NTO after sending repeated, un-rescinded invitations to a parent creates severe 42 U.S.C. § 1983 liability for bad-faith law enforcement activation and administrative entrapment.
MANDATORY ADMINISTRATIVE REMEDIESIn light of these continuous dispatches from Dominion High School leadership, the Complainant reiterates the following mandatory demands: Immediate Rescission of the Retaliatory NTO: Formally vacate the February 24, 2026 order signed by Director John Clark, dissolve the digital blockade, and restore complete, unhindered joint legal custodial access to all physical and digital educational environments across all LCPS facilities. Immediate Termination Proceedings: Initiate termination proceedings for Seneca Ridge MS Principal Nick Cottone and Director of Safety & Security John Clark for bad-faith retaliation, civil rights violations, and abuse of authority under color of state law. Cease Administrative Traps: Issue an immediate administrative directive instructing Dominion High School leadership (Principal John Brewer and Assistant Principal Jamie Braxton, among others) to cease sending contradictory campus invitations while the NTO remains unresolved on the record. Procurement Integrity Debarment (Policy 2350): Enforce LCPS Policy 2350 to immediately terminate all commercial sponsorships with Khanna Law, PLLC, on the Lowes Island Elementary PTO platform and initiate debarment proceedings against software vendor QlikTech. Delivery of Converted Public Records: Secure the immediate, unhindered transmission of all 1,141 responsive VFOIA records owed across multiple requests, for which processing fees were paid and accepted. Notice of Accrued Claim for Damages: Formal notice of ongoing, accrued damages in the amount of $2,148,000.00 and continuing, resulting from bad-faith civil rights violations, custodial deprivation, and administrative conversion of public assets.
These files have been permanently preserved, time-stamped, and appended to the active case file with the U.S. Department of Education Office for Civil Rights (OCR) and Congressional oversight records. Sincerely, Steven Rubis Joint Legal Custodian (214) 681-7991 (202) 997-4815
 | Steven Rubis <stevenrubis@gmail.com> |
| Steven Rubis <stevenrubis@gmail.com> | Wed, Aug 12, 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>, Abony.Alexander@ed.gov, LCSO_FOIA@loudoun.gov, TitleIXCoordinator@lcps.org, "jamie.braxton@lcps.org" <jamie.braxton@lcps.org> | Via Email
FORMAL ADMINISTRATIVE TRANSMISSION: EXHIBIT G-8 (DOMINION HS ZERO NIGHT SOLICITATIONS & CONTINUOUS NTO WAIVER)TO: Marc Bergin, Chief of Staff; John Clark, Director of Safety & Security; CC: Dr. Aaron Spence, Superintendent; Loudoun County School Board; Loudoun County Sheriff's Office; Leesburg Police Department; U.S. Department of Education, Office for Civil Rights (OCR); John Brewer, Principal (DMH.noreply@lcps.org); Jamie Braxton, Assistant Principal (Jamie.Braxton@lcps.org) DATE: August 12, 2026 SUBJECT: ADMINISTRATIVE DEPOSIT OF EXHIBIT G-8 — FORENSIC NOTICE OF BAD-FAITH CAMPUS SOLICITATIONS BY DOMINION HS ADMINISTRATION AND CONTINUOUS OPERATIONAL WAIVER OF NO-TRESPASS ORDER Mr. Bergin, Mr. Clark, and Division Counsel, et al. Please find attached Forensic Exhibit G-8 (comprising four primary transmissions: 260712 Gmail - Save the Date for Zero Night.pdf,
260806 Gmail - DOMINION HIGH SCHOOL - PREPARING FOR ZERO NIGHT.pdf,
260806 Gmail - DOMINION HIGH SCHOOL - Corrected Dinner Link.pdf, and
260811 Gmail - DOMINION HIGH SCHOOL - Zero Night, Student Schedules.pdf).
These official communications, issued directly by Dominion High School Principal John Brewer and Assistant Principal Jamie Braxton, forensically document an aggravated administrative contradiction and an uncontradicted operational waiver of the February 24, 2026 No-Trespass Order (NTO): Direct Subordinate Delegation & Bad-Faith Communication Routing: While Central Office leadership remains completely non-responsive to formal legal notices and whistleblower grievances, LCPS administrators are routing broadcast communications through Dominion High School leadership. Principal John Brewer was explicitly copied on the February 24, 2026 NTO (cc: John Brewer, Principal). Allowing Principal Brewer and his direct report, Assistant Principal Jamie Braxton, to repeatedly issue direct invitations to the Complainant soliciting physical attendance at "Zero Night" on Wednesday, August 12, 2026 (including dinner at 4:00 PM and campus schedule walk-throughs at 6:00 PM) constitutes an improper administrative trap or, in the alternative, a total operational waiver of the order. Entrapment Risk vs. Legal Waiver: LCPS cannot legally sustain a criminal lockout under Va. Code § 18.2-119 premised on a "security threat" while its high school leadership continuously issues broadcast solicitations urging the Whistleblower to enter campus facilities, park in the main lot, meet teachers, and walk student schedules. Attempting to enforce an NTO after sending repeated, un-rescinded invitations to a parent creates severe 42 U.S.C. § 1983 liability for bad-faith law enforcement activation and administrative entrapment.
MANDATORY ADMINISTRATIVE REMEDIESIn light of these continuous dispatches from Dominion High School leadership, the Complainant reiterates the following mandatory demands: Immediate Rescission of the Retaliatory NTO: Formally vacate the February 24, 2026 order signed by Director John Clark, dissolve the digital blockade, and restore complete, unhindered joint legal custodial access to all physical and digital educational environments across all LCPS facilities. Immediate Termination Proceedings: Initiate termination proceedings for Seneca Ridge MS Principal Nick Cottone and Director of Safety & Security John Clark for bad-faith retaliation, civil rights violations, and abuse of authority under color of state law. Cease Administrative Traps: Issue an immediate administrative directive instructing Dominion High School leadership (Principal John Brewer and Assistant Principal Jamie Braxton, among others) to cease sending contradictory campus invitations while the NTO remains unresolved on the record. Procurement Integrity Debarment (Policy 2350): Enforce LCPS Policy 2350 to immediately terminate all commercial sponsorships with Khanna Law, PLLC, on the Lowes Island Elementary PTO platform and initiate debarment proceedings against software vendor QlikTech. Delivery of Converted Public Records: Secure the immediate, unhindered transmission of all 1,141 responsive VFOIA records owed across multiple requests, for which processing fees were paid and accepted. Notice of Accrued Claim for Damages: Formal notice of ongoing, accrued damages in the amount of $2,148,000.00 and continuing, resulting from bad-faith civil rights violations, custodial deprivation, and administrative conversion of public assets.
These files have been permanently preserved, time-stamped, and appended to the active case file with the U.S. Department of Education Office for Civil Rights (OCR) and Congressional oversight records. Sincerely, Steven Rubis Joint Legal Custodian (214) 681-7991 (202) 997-4815
#drtroymohler #leesburgsterlingfamilypractice
|
|
|
|
Comments
Post a Comment