Via Email
FORMAL ADMINISTRATIVE TRANSMISSION: EXHIBIT G-10
TO: Marc Bergin, Chief of Staff; John Clark, Director of Safety & Security; Jennifer Division Counsel
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)
DATE: August 13, 2026
SUBJECT: ADMINISTRATIVE DEPOSIT OF EXHIBIT G-10 — FORENSIC NOTICE OF UNCONSENTED DIRECT SMS SOLICITATION, DYNAMIC TRACKING LINK, AND CONTINUOUS SYSTEMIC RETALIATION BY PRINCIPAL NICK COTTONE
Mr. Bergin, Mr. Clark, and Division Counsel,
Please find attached Forensic Exhibit G-10 (260813 SMS & Smore Dispatch - Seneca Ridge Middle School_ Principal Newsletter.pdf), documenting a direct, unconsented text message received by the Complainant on August 13, 2026, containing an embedded Smore tracking link ([https://app.smore.com/n/hdstb](https://app.smore.com/n/hdstb)) bearing the official signature of Seneca Ridge Middle School Principal Nick Cottone.
This direct mobile dispatch forensically documents an aggravated administrative trap, active surveillance, and a continuous operational waiver of the February 24, 2026 No-Trespass Order (NTO):
I. FACTUAL & EVIDENTIARY CROSS-WALK ON THE ADMINISTRATIVE RECORD
The Complainant explicitly deposits the following uncontradicted factual record regarding Principal Nick Cottone and the ongoing administrative default of Loudoun County Public Schools (LCPS):
- Documented Threats of Physical Violence: The Complainant has repeatedly documented on record that Principal Nick Cottone communicated threats of physical violence against the Complainant.
- False Statements to Division Superiors: Official records establish that Principal Cottone transmitted false statements to LCPS executive leadership regarding the nature and extent of his personal involvement with the Complainant’s family.
- Retaliatory Disclosures Regarding SRO Activation: Principal Cottone executed public-facing retaliatory narratives following the Complainant's public comments exposing the bad-faith, improper activation of SRO Deputy Iversen in December 2023.
- Unlawful State-Actor Collusion: Official records confirm that Principal Cottone engaged in unauthorized collusion with private adverse counsel Lindsay Mohler (Troxell Leigh P.C.) to inflict domestic and legal injury on the Complainant.
- Filing of Over 30 Workforce Grievances: Between January 2025 and March 2026, the Complainant filed no fewer than thirty (30) formal HRTD workforce complaints detailing administrator misconduct, the majority specifically naming or implicating Principal Cottone.
- Formal HRTD Substantiation (Case 12812): On multiple occasions (including May 16, 2025), LCPS HRTD formally validated the Complainant’s workforce complaints, confirming internal personnel action was initiated against Principal Cottone.
- Documented Fear of Physical Harm: The Complainant has repeatedly served explicit written notice to LCPS personnel establishing that he is in fear of imminent bodily harm from Principal Cottone.
- Institutional Attacks Following Physical Safety Disclosures: LCPS leadership retaliated against the Complainant for raising legitimate physical safety concerns, directly contributing to severe distress and documented self-harm in September 2024.
- Misrepresentations by Lowes Island ES Leadership: Principal Kate Ridgeway explicitly represented that she would assist the Complainant in navigating safety concerns regarding Seneca Ridge Middle School and his son’s matriculation.
- Bad-Faith "Meet and Greet" Trap: Principal Ridgeway subsequently issued false statements and hosted an on-site "Meet and Greet" explicitly inviting the Complainant to interact directly with Principal Cottone despite active, validated safety disclosures.
- Unanswered ADA / Section 504 Accommodation Requests: The Complainant has submitted numerous high-level requests for neutral administrative accommodations away from Seneca Ridge Middle School and Principal Cottone, to which LCPS has remained completely non-responsive.
- Retaliatory NTO Execution (February 24, 2026): LCPS issued a division-wide criminal NTO explicitly copying Principal Cottone (cc: Nick Cottone, Principal) less than nine months after HRTD validated the Complainant’s complaints, and in direct retaliation for a Federal OCR filing.
- Unlawful Contact After Consent Revocation: Following the formal revocation of consent for student campus visits, Principal Cottone sought physical proximity and inappropriately touched the Complainant’s minor child during an unconsented campus event.
II. AGGRAVATED SMS SOLICITATION, DYNAMIC SURVEILLANCE, & 149-MINUTE TIMELINE OF DEFIANCE
The August 13, 2026 SMS transmission exacerbates the division's legal exposure by establishing a time-stamped record of willful administrative defiance:
- The 149-Minute Temporal Window: At 8:01 AM ET on August 13, 2026, the Complainant served Central Office Leadership, Division Counsel Jennifer Painter, Director John Clark, and Principal Nick Cottone with a formal administrative demand (Exhibit G-9) explicitly prohibiting non-consented communication channels, rejecting third-party tracking portals, and demanding direct written email communications. Exactly 149 minutes later, at 10:30 AM ET, Principal Nick Cottone directly transmitted an unconsented SMS text message to the Complainant’s personal mobile device. Executing prohibited conduct within 149 minutes of receiving direct legal notice proves willful, bad-faith defiance of parental rights and active civil rights retaliation under 34 C.F.R. § 100.7(e).
- Digital Tracking & Privacy Infringement: The embedded Smore link ([https://app.smore.com/n/hdstb](https://app.smore.com/n/hdstb)) dynamically logs IP addresses, device metadata, timestamped opens, and location metrics. Bypassing standard email loops to send targeted mobile dispatches containing digital trackers to a reporting whistleblower—after receiving explicit notice prohibiting such tracking—constitutes bad-faith administrative surveillance.
- Facial Waiver of NTO Predicate: Directing SMS solicitations to the Complainant’s personal mobile device urging physical attendance at Seneca Ridge Middle School events completely obliterates any claim that the February 24, 2026 NTO is grounded in a bona fide "security risk".
III. REITERATED MANDATORY REMEDIES
- Immediate Rescission of the Retaliatory NTO: Formally vacate the February 24, 2026 order signed by Director John Clark, dissolve all digital blockades, and restore complete, unhindered joint legal custodial access across all LCPS facilities.
- Immediate Termination Proceedings: Initiate immediate termination proceedings for Seneca Ridge MS Principal Nick Cottone and Director of Safety & Security John Clark for bad-faith retaliation, civil rights violations, abuse of authority, and willful violation of LCPS conduct standards.
- Cease Direct Unconsented Dispatches & Surveillance: Issue an immediate directive instructing Principal Nick Cottone to cease all direct SMS messaging, tracking dispatches, and unconsented mobile communications.
- Halt Automated Matriculation Pending ADA/504 Review: Immediately pause all middle school placement milestones for minor child Charlie Rubis until a neutral accommodation plan away from Seneca Ridge Middle School is executed.
- Procurement Integrity Debarment (Policy 2350): Enforce LCPS Policy 2350 to immediately terminate all commercial relationships with Khanna Law, PLLC, and initiate formal vendor debarment proceedings against software vendor QlikTech, Inc., for data spoliation, infrastructure cross-contamination, and administrative record falsification.
- Delivery of Converted Public Records: Secure the immediate transmission of all 1,141 responsive VFOIA records owed across multiple requests, including the 172 pages of withheld Mohler-LCPS correspondence.
- 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.
This exhibit has 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
Now I will provide the evidence that the communication was inappropriate and mean to track my presence
Exhibit 1: Text Message from Nick Cottone
Source: LCPS, Verizon Wireless, Steve Rubis
The text message represents another attempt at entrapment by inviting me to SMRS in person. If I were to follow the text message and website, I would be arrested and charged with a misdemeanor. It is unlawful for LCPS to continue to attempt to have Nick Cottone have me arrested. I have undertaken legally protected whistleblower activity involving Nick Cottone. Now LCPS is retaliating against me by allowing Nick Cottone to seek retaliation by an attempt to entrap me and have me arrested. Nick Cottone has been trying to have me arrested since October 13, 2023, when I accused him of having an inappropriate relationship with my ex wife. His actions clearly illustrate a guilty conscience.
Exhibit 2: SMRS Event Invite Website
Source: Google, LCPS, Nick Cottone, Seneca Ridge Middle School, Steve Rubis
Exhibit 3 illustrates the tracking mechanism on the communication sent to me by Nick Cottone and LCPS.
Exhibit 3: Tracking Data
Source: Google, LCPS, Nick Cottone, Steve Rubis
#NickCottone #SMRS #SenecaRidgeMiddleSchool #LCPS #LoudounCountyPublicSchools #LoudounCounty #AaronSpence #LoudounCountySchoolBoard #TitleIX #retaliation #LindsayMohler #TroxellLeigh
#drtroymohler #leesburgsterlingfamilypractice
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