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LABOR 4 EMALOYMENT LAWYERS \workerlawcom
August 10, 2018
Peter M. Haberlandt,
Director of Legal & Governmental Affairs
State of Connecticut Department of Education
Box 2219
Hartford, Connecticut 06145
Dear Mr. Haberlandt:
Please accept this communication as the Ansonia Board of Education's (‘Board") position
statement regarding the August 9, 2018 lotter to you from the City of Ansonia (‘City"). This
response is intended to place on the record the Board's position to what can only be
interpreted as the intentional misrepresentation of the facts by the City in an attempt to
obfuscate the legitimate course of activities of the Connecticut State Board of Education
(CSBE”) in dealing with the Section 10-4b complaints filed on the behalf of several City
citizens.
Dealing first with the erroneous statement that the current litigation between the Board
and the City is “to address the precise minimum budget requirement (“MBR") issues you
raise in your lotter*. There is no reference in the Board's litigation against the City seeking
relief regarding the MBR. Instead, the litigation is to address the City’s blatant violations
of both City Charter and State statutes Section 10-222. As you know, and your letter to the
City addresses, the independent Section 10-4b complaint filed by City citizens is
appropriately before the CSBE to utilize the statutory mechanism for the correction of MBR
violations that the legislature has delegated to the CSBE,
You should also be aware of the City’s additional bad faith refusal to abide by the Court-
mediated settlement agreement (“Agreement”) of the Board’s request for injunctive relieve
regarding the City’s above-referenced illegal 2017-18 budget activities. Contrary to the
Agreement, the City has neither established a settlement account, nor released funds to
pay tho agreed 2017-18 educational costs of the Board. To date, the City’s account for the
Board is in arrears by over $35,000, a figure which grows every day. Rest assured that the
Board will be pursuing additional legal action against the City for its unethical behavior.
While I am certain that the CSBE will not be intimidated by the “inappropriate and
offensive" actions of the City, if there is any additional information that your department
needs to facilitate the processing of the Section 10-4b complaint, please do not hesitate to
contact me,
Ticawet. Se?
Frederick L. DorseyWilliam Nimons
Dr, Carole Merlone
Vincent M. Marino
Mayor David S. Cassetti
John P. Marini, Esq,