[(vonBriesen vo & oper, a Alornee at Law July 17, 2018 ceeTiereD MAIL Curtiss W. Tolefies, Jr. RE: Termination Recommendation Hearing Before the Kenosha Unified School District Board of Education Dear Mr. Tolefree: Please be advised that the Board of Education (“Board”) for the Kenosha Unified School District ("District") will meet on a date to be determined without delay for the purpose of a Hearing to consider the District Superintendent's recommendation to terminate your employment and your Contract for Administrative Persoimnel effective immediately, Please be advised that the Hearing will be held as an evidentiary hearing with full regard to due process in accordance with Wis. Stats. §§ 19,85(1)(b) and 118.24 and all applicable Board policies, District Superintendent Suc Savaglio-Jarvis and I will present this recommendation and evidence in support thereof to the Board based on the enclosed Statement of Cherges, You have the right to participate in this Hearing, to be represented by counsel, and to present evidence in response to the recommendation. Moreover, you have the right to demand that this Hearing be held in open session. ‘Once the date of the Hearing is determined, you must notify the District in writing at least five (6) calendar days before the Hearing date as to whether you wish to have the hearing occur in ‘open session. In the absence of your request for an open session, the Board is expected to ‘conduct the Hearing in closed session as permitted under Wis, Stat. § 19.85. Effective with the date of this letter, your paid administrative leave of absence has been converted to an unpaid administrative leave. If the Board rejects the Superintendent's recommendation for termination, you will be eligible for back pay for the period of time between ‘he date of this letter and the Hearing, less any period of time for which you would serve any disciplinary suspension imposed by the Board. Please contact Chief Human Resources Officer Shannon Weyenberg without delay to make arrangements to return all District property in your possession, including any and all technology, 411 Rout Wisconsin Avenue, Site 1000 Milwaniee, WH SU2E2 Phove 414-276-1122 Pex 414-276-626)to the District. For example, laptop, cell phone, District access cards, building keys, etc., must be returned as soon as practicable. Any District property that is not retumed to the District within seven (7) calendar days of your receipt of this letter shall be deomed property maintained by you without the consent of the District and thus, a violation of Board Poticy. Such action may serve as the basis for additional disciplinary action separate from the action described in the enclosed Statement of Charges, ‘Thank you for your time and attention to this matter, ‘Very truly yours, Christine V. Hamiel Enclosure CVHsIt cc: Personnel File Dr. Sue Savaglio-Jarvis, Superintendent Shannon Weyenberg, Chief Human Resources Officer ‘Annie Petering, Human Resource Coordinator Terry Rose, Attomey sere. 1 200%BEFORE THE BOARD OF EDUCATION OF THE KENOSHA UNIFIED SCHOOL DISTRICT In the Matter of the Charges Filed Against CURTISS W. TOLEFREE, JR. By SUPERINTENDENT SUE SAVAGLIO-IARVIS STATEMENT OF CHARGES Pursuant to Wis. Stat. § 11824, Sue Savaglio-Jervis, Ph.D. (hereinafter “Dr, Savaglio- Jarvis”), Superintendent of Schools for the Kenosha Unified Schoo! District “District"), presents the following charges against Curtiss W. Toloffee, Jr. (hereinafter “Mr, ‘Tolefree”): 1. FINDINGS OF FACT 1, Mr. Toleftee is employed in the District as a Middle School Principal at bra ag eter ting eioeaapeng Ny vert akin outer es 2019. Mr. Toleftee’s employment is governed by state and federal law, Wis, Stat, § 118.24, Board Policies, and the KUSD Employee Handbook. 2. On May 24, 2018, a complaint was made to Human Resources regerdi ‘inappropriate relationship between a female subordinate employee and Mr. Toles a the ‘impact the relationship was having on the employee to perform her job responsibilities, approximately November 2015, Mr. Tolefree engaged in an pe mbucint,insuding ta cational, shy aod sexal 4, In November 2015, Mr. Tolefree engaged in sexual conduct with the subordinate in the Washington Middle School building, 5. In December 2015, Mr. Tolefree engaged in sexual intercourse in the Washington ‘Middle School conference room with the subordinate, 6. Throughout the duration of the inappropriate relationship with the subordinate (spanning November 2015 until the present), Mr. Tolefree engaged in multiple acts of sexual activity and sexual intercourse with the subordinate in the Washington Middle School building. ‘Statement of Charges against Curtiss W. Tolefree, Jr. Page I of 10