Business Insider Delaware Freedom of Information Act request

To Whom It May Concern:

Pursuant to the Delaware Freedom of Information Act, I hereby request the following records:

-All separation agreements and settlements reached with current and former teachers who taught in the district between January 1, 2017 through the day this request is fulfilled.

-All public records relating to any and all claims of misconduct against current and former teachers who taught in the district between January 1, 2017 through the day this request is fulfilled. Such public records should include, but not be limited to, all complaints; allegations; claims; investigatory reports; analyses; summaries; memoranda and/or notes; interview recordings; transcripts and/or notes; reviews; emails, text or other electronic messages, voicemails, and/or other communications and/or correspondence; determinations; decisions; orders; resignation letters; employment reclassification documents; offers in compromise and/or settlement agreements; termination and/or transfer papers; letters of reproval and/or other disciplinary actions, whether imposed or not; referrals to law enforcement, administrative, and/or licensing agencies, departments, and/or bodies; appeals; court filings and/or rulings; and all similar materials notwithstanding the use of other terminology, nomenclature, or categorization by this or other involved public agencies.

To further clarify this request, the scope of the misconduct at issue arises from, relates to, and/or is a consequence of sexual behavior and/or activities with district students, whether currently or previously enrolled, and notwithstanding whether any such behavior and/or activities were proven to have occurred or not. The construction of this request should be understood to be liberal and expansive, such that all public records which may be remotely responsive should be produced in full and may only be withheld and/or redacted only as required by law.

I would like these records in the electronic format that they are stored in, transmitted via email or other digital method; please refrain from sending paper copies of the records.

Rather than provide all responsive records at once, I ask that you provide copies of records on a rolling basis, as they become available.

If you determine that any of the information qualifies for an exemption from disclosure, I ask you to note whether the exemption is discretionary, and if so whether it is necessary in this case to exercise your discretion to withhold the information. In any event, please provide a signed notification citing the legal authorities on which you rely if you determine that any of the information is exempt and will not be disclosed.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 15 business days, as the statute requires.

Sincerely,

Jonathan Rudenberg, a citizen of Delaware, in coordination with Insider Staff.

Good afternoon, thank you for the update. It appears there's been a misunderstanding as to the scope of my request.

With respect to the separation and settlement agreements I've requested, please confirm your understanding that I am requesting all such agreements, regardless of the underlying reason/rationale for departure. It defies logic that with some 3,000 employees, the Red Clay Consolidated School District would not have separated with a single employee since 2017.

With respect to the disciplinary and other records I've requested regarding sexual misconduct and/or abuse, what search terms did you use to process this request? And which department(s) were searched?

Please note that records regarding “activities with district students” should be interpreted to mean “Sexual Harassment,” “Unwelcome Conduct,” “Hostile Educational Environment,” and/or “Sexual Violence,” involving one or more former or current students.

By way of context, I've requested these same records from a dozen other school districts in the state, including many that are smaller than the Red Clay Consolidated School District. Yours is the only one to claim that it possesses no responsive records whatsoever.

Thank you again for your assistance.