[0:00] Understanding that may be a reasonable cause for delay in the Title IX investigation, but it doesn't mean you don't have to investigate ensuring that the parties have supported measures in a safe environment pending those investigations.

[0:15] The investigation file, and this is all that's going to be handed up to the decision maker to make the decision. You want to number one, have the policies that you considered. Number two, any interview notes, a log of those interviews, a log of, you know, the evidence.

[0:32] record of efforts to set up the document artifacts collected with a log copy of any notices.

[0:39] In essence, you know, I hate to say it and it's really hard and this is something you

[0:44] can work with your Title IX investigator to help be collecting to make sure you've got

[0:48] it all there.

[0:49] But in essence, you're putting together, you know, the pleading folder for court by putting

[0:54] all of these documents together, but you are creating the record, which shows number one,

[0:59] and how you got to the ultimate indecision,

[1:04] but the number two that you followed the process

[1:05] and this is gonna protect the school.

[1:11] So you've done your interviews,

[1:13] you've collected your evidence, you've logged it,

[1:15] now you're to the point where the parties

[1:18] and their advisors get an opportunity to inspect

[1:21] and review the evidence.

[1:24] So you send them either a secured electronic

[1:29] our heart copy is sent to the parties.

[1:33] This is when I encourage a non-disclosure agreement

[1:36] that says, hey, you're gonna get lots of evidence

[1:39] about things.

[1:41] I know you can talk about the allegations,

[1:42] but you can't post or exchange or disclose this evidence.

[1:49] Kelly, I hadn't really thought about this before,

[1:52] but suppose you interview the complainant,

[1:56] you've got notes and everything from that interview and the respondent says,

[2:00] hey, I have a right to review that evidence and I want to see it before you interview me.

[2:06] I would think it would be okay to say, I'm going to give both parties an opportunity to review

[2:11] evidence, but not until I have completed more interviews and obviously prior to initiating my

[2:18] investigation report, but I'm not going to share this interview note with you before I talked to you

[2:24] or prior to gathering more information.

[2:28] What do you think about that?

[2:29] I've had to actually do that.

[2:31] Yes, that's my approach as well,

[2:33] is that, you know,

[2:34] because to see one piece of evidence out of context,

[2:37] start, I just don't think it's helpful to the process at all,

[2:40] and I don't think it's required by the process

[2:41] at all until all the evidence is gathered.

[2:46] I would agree.

[2:48] So you get to the end of the process,

[2:50] you've gathered the evidence,

[2:51] you exchange the evidence with the parties,

[2:55] Then the parties have 10 days and I think we've written up policy 10 school days to submit

[3:01] a written response and maybe that response is, you know, you didn't, you know, include

[3:07] this or, you know, you should have, you know, talked to this person.

[3:13] Then, you know, if the investigator gets those responses back and if he thinks he missed

[3:18] a step or something he needs to go or she needs to go do it and they go do it, then they

[3:24] draft the investigative report.

[3:28] The investigative report is kind of always think about the mindset

[3:33] with the investigative report is that, you know, this is you want to enable your decision

[3:42] maker to make a decision based on facts. And these are the facts that, you know, that you

[3:49] are presenting to them in a way that enables them to make a good solid decision, understanding

[3:54] that your investigative report and the decision are going to be exhibit one in front of a court

[4:01] potentially at some point.

[4:04] So, the investigation report includes the timeline of the steps.

[4:10] You lay out the allegations. There's a summary of witness interviews. You refer to the policies.

[4:17] You know, you can provide a summary of the records.

[4:21] And then I include and encourage including, you know,

[4:23] as a appendices to the report, if you have transcripts

[4:27] of the interviews.

[4:28] If you have, you know, the policies that you looked at,

[4:30] if you have the data that you collected or the artifacts,

[4:34] the documents, anything else is an appendix to your investigative report,

[4:37] but you've laid it out in the report itself.

[4:40] And then talk about any times where, you know,

[4:42] you try to get information or interview witness

[4:45] and they were, you know, not responsive or refused.

[4:51] I do have, you know, a template for this.

[4:54] I don't know that we have the time today to go into that,

[4:58] but it, you know, kind of lays out, you know,

[5:02] all of these, you know, this checklist within the template.

[5:08] The goals, your job is not to reach conclusions,

[5:12] is to let the parties know.

[5:14] And you got to let them know that in the investigative report.

[5:16] Here is my objective evaluation or, you know, objective gathering of, you know, relevant

[5:25] evidence.

[5:26] I am not reaching any sort of responsibility, determination of responsibility.

[5:30] And like I said, what your goal is to put the decision makers in the best position to

[5:34] understand relevant evidence.

[5:37] And, you know, again, you want to demonstrate to the parties and potentially court that you

[5:42] You took these allegations seriously and responded appropriately and that this may be

[5:47] Exhibit one to multiple and OCR proceeding or a court proceeding.

[5:55] So you've done your investigative report and again, talk with your Title IX coordinator.

[6:02] You might want to run it by your Title IX coordinator.

[6:05] I know it's an attorney.

[6:06] I've looked at some of these to make sure we've hit all of the things that are required to

[6:09] be in the investigative report.

[6:10] and then you get it to the parties.

[6:13] The parties then have 10 days to respond to that investigative report.

[6:18] But at the point, when you send the investigative report to the parties,

[6:23] your job's done.

[6:24] It's the decision maker, then picks up the baton and takes it from there.

[6:30] I think that's...

[6:31] That was fast.

[6:32] I'm glad to go back.

[6:34] You guys have any questions for Kelly?

[6:37] Let's do that.

[6:43] All right.

[6:44] It does not appear that we do.

[6:45] Well,

[7:02] we didn't mean to scare you off of questions.

[7:04] We just wanted to make sure we got through all this.

[7:07] So if you do have questions about any part of this,

[7:11] hopefully we might have some time at the very end

[7:14] that we can do that.

[7:15] We do have one quick one now if there's a time.

[7:19] Sure.

[7:20] Do we need a written statement of some type from the party?

[7:24] We turn the evidence over to that acknowledges

[7:26] how many pages or the nature of documents submitted

[7:30] So that they can't later claim that they didn't get something that we know we turned over.

[7:40] Kelly, you're on the menu.

[7:41] I hadn't thought about that. It might not hurt.

[7:45] And I do a cover letter that says attached is the investigative report consisting of ex number of pages.

[7:51] I don't think that that hurts the document. How many pages you, you know, you sent them.

[7:57] But I don't know if you want to go through the process of actually getting them to acknowledge that.

[8:01] Yeah,

[8:05] certainly you could say the report consists of X pages and the following supporting documents and could be witness notes from the following well.

[8:17] That would be the investigation report. You may do the same thing when you share the evidence with the person who says I want to see all the evidence.

[8:26] If you're going to share that, you may do the same things and you know attached our following documents, something to that effect would be good.

[8:41] Okay, so decision makers, you know, really the decision makers role you would think would be, well, it's going to be a lot less involved than the Title IX coordinator.

[8:55] It's going to be less time consuming the investigator.

[8:57] and it probably is. But there are significant steps the decision-maker has to go

[9:05] through and has to comply with and understand and some are fairly legal and an

[9:11] understanding of the legal requirement and burdens of proof and standards of

[9:16] evidence.

[9:20] So appointment you know the Title IX coordinator would could a point is

[9:27] not mandated to appoint the decision-maker. I think that's appropriate because you've got to make

[9:33] sure you find an unbiased and partial decision-maker. You know, that could be worked out well in advance

[9:40] and quite frankly, I know most districts I work with are already talking about who they want to be

[9:45] a decision-maker or investigator or Title IX coordinator. And so they've had input through the

[9:53] superintendent and others with the Title IX Coordinator about who that ought to be.

[9:59] However, you may rethink that after we get through with this today as to who the decision

[10:05] maker should be.

[10:07] And again, it cannot be the Title IX Coordinator or the investigator.

[10:13] Unbiased impartial not have a conflict of interest.

[10:16] And in order to make that decision, you have to be, as a decision maker, you should be

[10:21] provided by the Title IX Coordinator or it will be included in the investigation materials

[10:28] as to who the witnesses are and the parties and their advisors and it is there a conflict

[10:34] of interest on your part.

[10:36] That has to be decided.

[10:38] It can be discussed with the Title IX Coordinator but you need to make sure you're not subject

[10:44] to bias.

[10:46] I don't mean to interrupt but I think folks are having a hard time seeing your whole screen

[10:49] for some reason it's cutting off parts I've got a green box here as well let me

[11:01] see there's any ideas let's

[11:09] see if there is a way to go back any

[11:20] ideas Brian

[11:21] or Julie? Good things is one that Julie could certainly do it share the PowerPoint if you just want to email that to her.

[11:31] You might check your view, the size that you're viewing the document.

[11:45] Okay, so on PowerPoint, the view tab along the top, and then the zoom, and you might switch the zoom to 100%.

[11:57] Let me go back into the share screen.

[12:10] Click to the next one. There you go.

[12:14] Okay, good. Sorry about that.

[12:20] Okay, so we talked about the unbiased impartial. I will give you a heads-off just a quick little

[12:28] lesson learned for a decision-makers out there.

[12:33] You look at the people involved and the

[12:37] issues need to decide, you know, I don't know these people from Adam, I don't have any bias

[12:42] or conflict and from personal experience in one situation I can tell you as a

[12:50] decision-maker after reaching a decision there was an allegation of bias on my

[12:56] part which I was surprised by but it was because I had worked with districts on

[13:02] prior occasions in dealing with teacher disciplinary matters and that was a

[13:08] basis of an appeal, and it went to the appeal decision maker along with other issues.

[13:15] What I decided to do, if I am in that role again, is as a part of the decision, I'm going

[13:21] to discuss my bias or hopefully lack thereof, and that's what it has to be.

[13:28] In other words, in this case, I don't know any of the parties.

[13:33] I don't know any of the witnesses.

[13:35] I have worked with any of these individuals on any matters.

[13:42] I have worked in my case with districts in disciplining students, in disciplining staff,

[13:49] in defending staff against parental claims on all sides of these issues.

[13:55] So, personally, I don't feel like I'm biased.

[13:58] But without doing that in the decision, when that appeal goes to the decision maker,

[14:03] The appeal decision maker has no information with which to respond to the allegation of bias or prejudice.

[14:11] So that's just kind of a practical tip that I give you based on my own experience of the decision maker on this issue.

[14:20] So you have to objectively be able to review the evidence, summarize the investigation report, keep in mind, and this is the problem.

[14:30] You don't get to do the investigation, you don't get to do any more investigation.

[14:35] You get information from the investigator and you think, geez, I wish you'd asked this

[14:40] question, or maybe we should talk to this person, that's not possible.

[14:45] That's why the role of the investigator is so important because whatever you give to

[14:50] the decision maker, that's what the decision has to be based upon.

[14:54] And if you didn't ask the question as to the impact upon that alleged victim and what...

[15:00] There are not it impacts their ability to have an access to an equal educational environment. That's a critical element. And if there's no information about it, there's no sexual harassment, because it can't be presumed if there's nothing in the record to support it. So objectively evaluate the evidence you can only evaluate what you were given. Again, no prejudgment or and no deference to any recommend

[15:29] recommendations or editorial comments of the investigator. So as Kelly included in her training

[15:36] it's not the role of the investigator to reach conclusions or make recommendations.

[15:41] But if it's there, you know, based on my investigation, I concluded that this individual

[15:47] was significantly impacted and doesn't want to attend class. Uh-uh. That's not part of

[15:53] the facts that the decision maker gets to decide. Decision maker may reach that same

[15:59] conclusion, but no difference should be given to the recommendations or editorial comments

[16:06] of the investigator.

[16:09] As Kelly mentioned, the decision-maker cannot reach a decision until the individuals have

[16:15] received the investigation report and had ten days to review it in some manner written response

[16:22] for consideration by the decision-maker.

[16:28] The decision maker is now mandated under the regulations to give each party an opportunity

[16:35] to pose written questions to the other parties and witnesses which will be responded to within

[16:43] a reasonable time frame. What I did as a decision maker is I notified the people, the parties,

[16:51] the complainant respondent that you've received the investigation report, you have 10 days to respond

[17:00] to that investigation report, and you will have 10 days from now to pose any questions you want to

[17:06] pose to the other party or to the witness. And then on receipt of those questions, if you get any,

[17:14] you have to decide are those questions relevant and if they're not relevant they won't be submitted to the party or the witness to be answered.

[17:24] In which case you have to explain why it's not relevant to the person asking the question.

[17:37] You have to allow the parties to see the responses to the questions and then you may set out a period whereby the witnesses can submit a response or follow up questions.

[17:48] The respondent wants certain questions asked of the complainant.

[17:53] You give them time to ask the questions.

[17:57] You give the questions to the complainant in that example.

[18:01] They have to have a reasonable time to respond, which may be five to ten days.

[18:06] After they respond, you've got to provide the response back to the respondent.

[18:11] They may submit a follow-up question or they may have a response.

[18:14] Well, now that she answered the question that this occurred at such and such time,

[18:20] I have proved from a video or text that I wasn't even there at that time.

[18:26] Unfortunately with that, that creates new evidence that's not part of the

[18:31] investigation report. And the regulations don't really explain how you deal with that.

[18:40] But it's information that comes in. And when you get that information,

[18:43] you have to share it with the other part, which is why these investigations sometimes are not

[18:50] going to be wrapped up in 30 days. 60 days could be pushing it if you have multiple questions and

[18:57] responses and follow-ups. But this process is in lieu of having a hearing where the compliant

[19:06] and respondents are put under cross-examination and inquiries by attorneys, which is the process

[19:14] colleges are subjected to. So thankfully, at least in the K-12 process, we don't have to go

[19:20] through that hearing and cross-examination, et cetera, that higher ed does. But this question

[19:27] to answer thing is something the decision-maker does have to facilitate and certainly can consider

[19:34] are those responses?

[19:38] Trace, someone in the Q&A asked that a Texas says that they can request the investigator

[19:43] to go back and ask additional questions.

[19:48] I don't know that.

[19:49] I don't dispute that.

[19:50] I just don't know that, you know, I just don't know the answer and maybe, you know, I need

[19:58] to look into that and get back, but unless you-

[20:00] Yeah.

[20:00] I have to say I had not heard of that either.

[20:03] It's I don't recall anything in the regulations about that it may be an interpretation someone

[20:10] that's given hopefully

[20:16] you avoid that by allowing the individual themselves to pose the question.

[20:23] And if they do that, I don't know why the investigator would have to do that.

[20:30] I'm also not aware of anything in the regulations that says that can't happen.

[20:40] So, you know, no decisions until you've received and reviewed all the evidence, at least

[20:47] it's relevant. Make a sound, reason, decision, and determine the facts based only on the

[20:55] evidence presented.

[21:02] Again, the impartiality is crucial.

[21:07] You're not swayed by prejudice or

[21:10] sympathy and nor what's the impact of this decision going to have. Jesus could ruin this guy's career.

[21:18] Wow, this could take the student as a sexual harasser or, you know, a perpetrator of sexual assault.

[21:27] You know, that does not factor into the decision. The decision simply is, does the evidence prove by

[21:36] preponderance of the evidence that every fact constitutes sexual harassment occurred and if so,

[21:44] it's substantiated and you determine responsibility for it and not what the impact of that's going

[21:50] to be.

[21:53] Weight of the evidence is something I also want to cover because I think there's a tendency

[22:00] see particularly by untrained investigators to say, you know, Joe and his friend both have told

[22:07] me that Joe didn't make this comment to Sally. Sally says it did, but they have two people that

[22:16] said it didn't. Sally only has one, therefore it didn't happen. The quality of the evidence is not

[22:24] determined by the volume of evidence or the number of witnesses or exhibits. It's the way

[22:30] of the evidence or a strength intending to prove the issue? Did Sally have a motive for

[22:35] making say in this? Was there something that Joe said that really didn't make sense? And

[22:41] quite frankly, it's not consistent with evidence or even common sense that would cause you to

[22:48] believe the credibility of Joe and his friend are really not as credible as Sally. That may be

[22:55] But you don't judge it simply on we're going to count the number of witnesses that say it did happen and count the number of witnesses that say it didn't happen and that's what decides us. That's not the way this works.

[23:12] You have to look at credibility of the witness how important do you think the testimony actually is or the facts presented are.

[23:24] Consider a reasonableness of the testimony, the probability, is there a motive?

[23:33] And you may know a person and believe them to be completely honest, but that doesn't

[23:38] mean they might not be mistaken or confused about what they saw or heard and then document

[23:47] the basis for the findings, that's going to be part of the decision. We talked about not

[23:53] considering the impact.

[24:00] So you look at all the evidence in total and making your decision.

[24:04] So as a decision maker, you have to understand and apply preponderance of the evidence. Because

[24:11] the burden of proof is not on the complainant. It's not on the respondent said. It's on the district

[24:19] that's investigating it, to substantiate that there was sexual harassment.

[24:26] And if you, as the district, through the investigator, can't prove by a proponderance of the evidence,

[24:35] every element of the allegation that creates or that defines sexual harassment, then you don't have sexual harassment.

[24:45] Now, preponderance of the evidence standard is unlike law enforcement standard, which is

[24:51] why you do conduct your own investigation, along with the fact that you're mandated by

[24:56] the regulations.

[24:57] They have to prove someone was guilty beyond a reasonable doubt.

[25:01] That's a much higher and different burden than proving by preponderance of the evidence,

[25:07] which is simply, I think it's more likely than not that this happened.

[25:12] It's greater than a 50% chance that the allegations are true.

[25:19] So there must be evidence to show by proponents of the evidence each allegation.

[25:25] So go into what the definition of sexual harassment is.

[25:30] Every element that it takes to prove sexual harassment.

[25:34] Then sort the evidence according to the element.

[25:38] This isn't a regulation but it is very effective.

[25:42] and I think it's a very good way for a decision-maker to decide if sexual

[25:47] harassment occurred. No, did it occur during a school activity? Is it unwelcome

[25:53] conduct under a reasonable person standard? Is it objectively unreasonable or

[25:59] offensive? Did it create a situation where this individual no longer has equal

[26:06] access to the education program? Those are all elements. And what evidence do we

[26:11] have that would prove by a preponderance of the evidence that that element has been proven.

[26:18] And then you do that with every allegation. The teacher said this to me during art class

[26:25] on such and such a date. The teacher said this to me during art class. It's a different class

[26:31] on a different day. Those are different incidents. The teacher did this in class. Those,

[26:39] Those, whatever the allegations are, and for every separate incident listed in the formal

[26:44] complaint, you go through this process,

[26:50] kind

[26:54] of mentioned this, and this is the one that

[26:57] I find investigations are weak on, is following up as to whether it was objectively offensive,

[27:03] excuse me, and denied the person equal access to the education program.

[27:08] that investigators, you've got to help the decision maker out, you've got to have questions, answers, and evidence on all of this.

[27:20] If there's going to be a substantiated claim of sexual harassment, or as long as you've investigated it and there is no evidence, that's great too.

[27:29] So it helps the decision maker understand that there may not be sexual harassment.

[27:37] So the decision then, when it's risked, sorry to interrupt, you can ask one question

[27:42] and go back to that.

[27:43] So if you go allegation by allegation or element by element, right?

[27:48] One statement in class may not be severe, pervasive, and objectively offensive, right?

[27:53] I mean, it could be.

[27:55] Right.

[27:56] Sometimes do you take those if there are 17 allegations of that and that creates that that

[28:00] That means that this element.

[28:03] Yeah, I would agree.

[28:04] That's a good point.

[28:05] I think you look at the evidence that each one of those separate ones happened.

[28:09] Right.

[28:10] Once they happened, I think you could say, look, yeah, based upon the

[28:17] preponderance of the evidence, at some point it became offensive.

[28:21] The first one, maybe you thought was funny.

[28:23] The second one was kind of rude.

[28:25] But at some point it became offensive to any reasonable person.

[28:29] That very good point and it could happen.

[28:36] So the decision and the decision maker's requirement to render a decision is going to involve

[28:44] multiple steps.

[28:47] So one is identify the allegations that constitute sexual harassment.

[28:53] The complaint form, depending on how verbose the complaint it is, may ramble on about a

[29:01] lot of things, but it's only the actual allegations of sexual harassment that you're identifying.

[29:08] A description of the procedural steps taken.

[29:12] This is why it's important for the investigator in the investigation file to summarize to create

[29:18] that log of steps taken, because that needs to be shared with the decision-maker so they

[29:25] can describe in the decision the procedural steps that were taken.

[29:29] No notice of this was received on such and such a date if you have that information complaint was filed and such and such a date notice of the complaint was delivered to the complainant and responded on such and such a date.

[29:43] You know the following people were interviewed.

[29:46] I think it's important to confirm that the documentary evidence was offered to be shared if they either party wants to see it that it was shit.

[30:00] If they provide a response to it, I wouldn't say I received it. I would say it was received and considered. Because I know at least in one of the investigations I dealt with, one of the contentions of the attorney advisor representing the respondent was, hey, we responded and said this. And when the investigation report didn't agree with what they said in the response.

[30:28] the allegation was procedural error because it wasn't considered so maybe at

[30:35] least as a investigator when you get that say it was received and considered by

[30:41] the investigator doesn't mean you have to agree with that or you have to

[30:45] directly respond to their accusations or respondents. A statement rash now for

[30:54] the result as to each allegation. So you're going to decide does it constitute sexual harassment?

[31:03] Is the respondent responsible for it? In other words, was it, if there's it's substantiated,

[31:11] are they responsible for that conduct? This is one that Kelly and I have debated and redebated,

[31:19] but the regulations mandate the decision include disciplinary sanctions if they're if the conduct is

[31:27] substantiated. The problem you've got unless the superintendent is the decision maker

[31:37] and I'm not advocating that that should be the case but what I would say is if it's substantiated

[31:45] and you, as a decision maker, may think that Jesus could result in expulsion of this student.

[31:53] Well, you likely don't have the lawful authority to impose expulsion because under Wyoming law,

[32:00] that's based on the recommendation of the principal and or superintendent or if it's dismissal

[32:06] from the superintendent or a board member.

[32:09] The decision maker likely can't impose that sanction.

[32:14] And that creates a difficult situation I think for decision makers and potentially a conflict

[32:21] between federal regulations and state law.

[32:25] The feds think their law trumps state law and generally they're right, but I think

[32:31] you would instantly find yourself in litigation if a decision maker says I'm going to dismiss

[32:38] this teacher and you don't go through the statutory due process requirements.

[32:42] So, um, I think it's appropriate once you've reached your decision and determined things are substantiated to share that with the Title IX coordinator and say, look, I haven't, you know, I haven't shared the decision.

[32:58] I haven't reached the final one, but I'm finding that it was substantiated.

[33:02] I'm not sure where we're going with sanctions and when I did I ultimately said I think I found some some some of the allegations

[33:11] substantiated determined that sanctions were appropriate and recommended that sanctions be imposed that may include

[33:19] something between a reprimand and dismissal so that the appropriate people in the school the superintendent could after

[33:30] looking at the decision to decide what to do. And as Kelly pointed out, the decision maker

[33:37] may say, even, you know, I think a reprimand is appropriate. Well, the superintendent may

[33:43] have information that, geez, this person is engaged in this conduct, three previous times.

[33:51] Well, that doesn't factor into this decision, but it may factor into ultimate sanctions,

[33:57] which may be different than recommended by the decision maker.

[34:01] So it's an awkward position to be in.

[34:05] You don't want to cut the feed out from underneath the administrator.

[34:11] But you are going to address sanctions somehow in the decision.

[34:17] And it likely could be, I do believe sanctions are necessary and appropriate

[34:22] it and this individual, whether it's a student or employee, should be disciplined, and you

[34:30] could recommend a sanction, or you could recommend a range of sanctions.

[34:38] But it's okay for the decision-maker to discuss that with the Title IX Coordinator.

[34:43] I'm not opposed to the Title IX Coordinator maybe talking with the superintendent about

[34:50] potential sanctions but keep in mind neither the Title IX Coordinator nor the

[34:56] superintendent get to offer any input into whether or not the allegation is

[35:02] substantiated or whether or not it's sexual harassment. That is not what you're

[35:06] doing. Only after you decide it is sexual harassment and it has been

[35:12] substantiated, would you maybe visit with the Title IX Coordinator about the

[35:17] sanction piece of it. And it would only be after you've decided sanctions which have to be imposed

[35:24] if it's substantiated are going to occur.

[35:29] So it's not the superintendent that makes the decision

[35:33] or impacts the decision. It's just I think you can get some input as a decision maker into the range

[35:41] of discipline that could come out of this, and I'm certainly okay with just saying you know

[35:50] that's a decision which I did. For those that have the lawful authority to do it, here's

[35:54] the range, and make that part of the decision. And then whether the remedies designed to restore

[36:02] preserve equal access to the district educational program, you could say absolutely, supportive

[36:09] measures are required. The district should initiate supported measures to allow this person

[36:17] to participate freely in class, to do so safely in a manner where they're not scared

[36:24] to attend class or to participate or go to these activities, whatever it might be.

[36:30] And then the decision maker must discuss the procedures and permissional, excuse me, permissible

[36:38] basis for parties to appeal the decision.

[36:44] I think it's a great idea to have the Title

[36:47] 9 coordinator and they may want their legal counsel to review the outcome prior to smitting

[36:52] to the parties because once it's out, you know, it can't be changed. And if we miss something,

[36:58] we forgot to step. It's okay to have that looked at as long as the opinions of Title 9

[37:08] coordinator or legal counsel are not substituted for the decision-maker.

[37:14] Title

[37:14] 9 coordinator will then share the notice with the parties and their advisors.

[37:20] After the Title 9 coordinator gets it from the decision-maker and you try and

[37:27] share that simultaneously. So handing it to the teacher and mailing it to the

[37:33] students' parents is not a good idea. If you can call the parents in and share it

[37:39] with them the same day you share it with the staff member, that's fine. If you

[37:44] want to call the parents of the two students involved and give it to them at the

[37:48] same time, that's fine. If you know that both parties regularly check their

[37:53] email and you can email it to them, maybe let them know it's coming to make

[37:59] sure others that may have access to that email, don't get it. I think that's

[38:05] Okay.

[38:07] But it has to be the written decision.

[38:12] And as I'm indicated, you could, you could mail it to both, obviously, one's going to get it before the other.

[38:20] And they don't have to get it at the exact time. But to the extent you can get it to them as close as possible to the same time is what your goal should be.

[38:36] Once sanctions are imposed, the Title IX coordinators should coordinate the implementation of

[38:43] remedial action for the complaint and disciplinary action. In other words, you're mandated under

[38:49] these regulations to impose sanctions. So the decision comes down, something substantiated,

[38:56] superintendent, maybe with the principal going to decide what those sanctions are.

[39:01] The title line coordinator, it's not like once the decisions made there out of the picture, title line coordinator needs to make sure that there is, in fact, follow through on those sanctions and that they are imposed because that's a part of the title line process.

[39:18] as and the same with supported measures. Let's make sure those are implemented.

[39:25] It's not a one-size-fits-all depending on the circumstances, the person's maybe other information.

[39:33] It's a case-by-case basis with those sanctions will be.

[39:38] We talked about the range of possible sanctions which will depend on the severity.

[39:46] it's no different than what you're doing now and that's based upon what you can

[39:51] do under your own policies, handbooks and applicable law. The only thing that I

[39:57] would add there Tracy is the language that I added the last sentence of

[40:00] determination will be considered good and just calls for suspension

[40:03] termination or dismissal. We're just put people on notice that I have no idea

[40:07] how a hearing officer or a court would view that. That's just me saying you know

[40:12] we as a district and a board that's adopted this policy thinks it's good and

[40:15] just calls.

[40:20] So, yeah, that's an informational component.

[40:25] And I also do not know for sure.

[40:30] So you could substantiate sexual harassment. I would like to believe that if you substantiated

[40:37] that an employee engaged in conduct that after a full due process, Title IX investigation

[40:44] was concluded to be sexual harassment that that should be good and just cause for a dismissal.

[40:52] Now, I can't guarantee you what an independent hearing officer would say, but it was

[40:57] seemed to me that sexual harassment substantiated should be grounds for dismissal or termination.

[41:05] Doesn't mandate that. I mean, sexual harassment varies. Sexual assault is one thing.

[41:13] comments that are rude, inappropriate, and offensive or something else.

[41:18] You may choose to dismiss one and not dismiss another.

[41:22] So that doesn't mean you have to engage in the dismissal process, but it would seem that

[41:29] it would be good or just cause for that should you choose to do it.

[41:34] I see we have two questions relating to the decision maker.

[41:37] The first, does the decision maker get the investigative report at the same time it goes

[41:45] out to the parties for their 10-day review?

[41:50] Again, nothing in the regulations require that.

[41:56] But the responses to the investigation report have to be considered by the decision maker.

[42:05] I don't, you know, it's not like the responses are coming back and the investigation reporter

[42:10] is going to now, oh, okay, now I'm going to change the investigation report. That's not the process.

[42:17] So in my thinking, I would think it would make sense to point the decision maker and send it

[42:26] to them at or close to the same time as it goes to the parties.

[42:33] The second question is, could

[42:36] Should the same fact pattern be reconsidered after ending in some manner?

[42:46] In other words, actually the question was, could a case be tried twice?

[42:51] Of course, it's not a criminal case.

[42:54] But is there ever a situation where a decision-maker disposes of it in some manner, but then

[43:04] either reconsiderors or brings back for new consideration or reconsideration, the facts

[43:11] of the case before them other than through appeal.

[43:19] I hadn't really thought about that and Kelly, feel free to step in.

[43:24] But my thinking is this, is that once you go through this process and render a decision and

[43:32] give the individual an opportunity to appeal it, it's over. You're not going to reopen it.

[43:39] Now, one of the basis for appeal is which I'm about to get into is discovery of new evidence

[43:46] that was not available at the time of the investigation. And if that occurs, the appeal decision-maker

[43:52] can say, I'm not going to affirm the decision of the decision-maker because this new evidence could

[44:01] change the results, in which case the appeal decision maker, and I don't think this is clear

[44:08] in the ranks either, but Kelly, if you know something or remember something I don't, I think

[44:13] the process would be to review it back or refer it back to the investigator to consider that new

[44:20] evidence and make any changes to the investigation report and then have it go back to the decision maker

[44:29] for a new decision or change if necessary.

[44:33] But if that evidence comes up a year later,

[44:39] I don't think it reopens the investigation.

[44:43] I would agree because you've got the timelines for 10 days for an appeal.

[44:48] So if it's new evidence that comes in later, I don't think you reopen it.

[44:51] I think that the only other instance that could come up is in the process of the investigation.

[44:57] and you find out that maybe there are similar comments.

[45:00] December or conduct with another student. You could have a potentially separate investigation. You would want to try to consolidate investigations if they are based upon the same set of facts, but depending upon the timing and how things go, you may have a separate investigation on very similar facts with a different complainant. One quick last question. Does the decision maker collaborate with the superintendent or principal when determining sanctions?

[45:26] Well,

[45:33] I don't know, Kelly and I spent some time on that yesterday because the regulations

[45:40] clearly do not address that.

[45:43] And quite frankly, I think that's the problem I referred to earlier about the discrepancy

[45:50] and the regulations mandating the decision maker described sanctions, but the decision maker

[45:59] not having the authority to impose sanctions. I think what we talked about really was going

[46:06] back to the Title IX coordinator and discussing it with the Title IX coordinator who may want

[46:12] to discuss it with the superintendent. And it kind of funneled it back through the Title IX

[46:18] coordinator. Kelly, what's your thoughts? Well, I think what we talked about, you know, whether

[46:24] There would be an HR issue where, you know, right, you don't have authority both for

[46:30] expulsion or word dismissal termination, but what I see this, you know, the investigative

[46:34] report and the decision is being exhibit A to a notice of recommendation for expulsion

[46:41] or a notice of recommendation for dismissal termination or suspension that may have more

[46:46] components to it, right, because we're talking just about these individual allegations.

[46:50] So I try to keep it away, I don't know how it would stand up for the officer of civil

[46:57] rights.

[46:57] I'll just preface it with that.

[46:59] But I like what Tracy has said about trying not to taint the process with too many people's

[47:05] fingers in the pot as far as sanctions because then that potentially could flow into the

[47:10] substantiation of the multiple determination.

[47:13] But if you want to go talk generally to the Title IX coordinator after you've made the determination,

[47:17] maybe get some input there, but ultimately make a recommended range of sanctions,

[47:24] you know, the two have authority to make. Now, if you think that whatever happens,

[47:29] you know, only warrants, you know, you know, a reprimand or something like that that's very clear

[47:34] and that it shouldn't go to dismissal, you need the freedom to say that,

[47:38] doesn't mean they're in a whole other case against that student or teacher,

[47:41] But I do think you want to keep that that process is untainted as possible.

[47:50] So just clarify a little bit, you know, I think most of you understand what Kelly's talking about is.

[47:57] This investigation is only focused on these allegations and these facts and the sanctions are related to this.

[48:03] And if you did as a decision-maker said, I think it

[48:08] reprimanded the appropriate.

[48:11] But the superintendent knows that this is the fifth

[48:17] in a line of five similar allegations

[48:20] that this individual was reprimanded for previously,

[48:25] the actual sanction, or not sanctioned, the sanction make,

[48:30] well, the actual discipline sanction for this

[48:32] May result in a dismissal, but it's not based only on this.

[48:36] It's based upon all the other information or other related incidents that the superintendent

[48:43] may have knowledge of that the decision-maker didn't.

[48:49] But obviously when you get to the hearing, teachers' attorneys can say, well, didn't the decision-maker

[48:56] after considering all this reach a conclusion that

[48:59] reprimand was appropriate, and why are you then recommending

[49:03] dismissal? The person that was unbiased and looked at all this clearly

[49:08] didn't think that was appropriate. Well that could happen, but that's where

[49:14] the superintendent says that's because they didn't have this information. It's

[49:19] just a pitfall that I really don't know how you avoid it. I think and I do

[49:25] agree, I'm not sure I'd be comfortable with the decision maker going to the

[49:30] superintendent. I think maybe visiting with the Title IX coordinator, I'm guessing

[49:35] the Title IX coordinators are already going to have a feel for the type of

[49:40] sanctions that would be appropriate in the district for these circumstances.

[49:46] Maybe they have a general discussion and ultimately I don't think that

[49:51] regulations prohibit the decision maker from saying determination that sanctions appropriate

[49:56] they need to be made by the persons with the statutory authority to do that. And I believe

[50:01] they could range from this to this. I think that that I'm okay that that meets the requirements

[50:09] for the decision to address sanctions.

[50:15] Another question. Any concerns with the superintendent being the Title IX coordinator?

[50:25] The only concern there, and I know, I mean, it's not fair because just smaller school districts

[50:30] don't really have a choice. But it's just what Tracey's been talking about is that you're

[50:34] going to come through this process and there are going to be some ultimate decisions made

[50:38] by the superintendent. And to have him separate from, you know, that role in not having been

[50:46] involved in the investigation probably helps you in front of an independent hearing officer

[50:51] in a tea determination matter or potentially a hearing before the board and an expulsion

[50:55] matter.

[50:55] I know that's not always feasible, but that would be my ideal if it's not the timeline

[50:59] coordinators, not the superintendent.

[51:02] You know, I know the superintendent may say, geez, I really need to fill this role.

[51:07] We don't have the money to hire another person to be Title IX coordinator, small district.

[51:12] I can do it.

[51:13] You need to think about this.

[51:14] If somebody else is the Title IX coordinator and shepherds this through, and they substantiated,

[51:23] and based on that, you make a recommendation.

[51:26] It's pretty easy for me to give you questions in that dismissal hearing about why you made

[51:32] that recommendation, level that was a full investigation, independent people decided it.

[51:37] It came to me.

[51:38] It was substantiated.

[51:39] whereas if you are the Title IX coordinator, you don't get that same luxury because you were a part

[51:47] of the process and it's really not independent of you. So I mean it's helpful if it ever comes

[51:53] to a dismissal if you weren't one of the parties to it. Not to say you can't be and we would work

[52:00] around that. It's just it's back to the old process where yes I did shepherd it through and I did

[52:09] pick the investigator and I did pick the decision maker and I did send out the notices and yes I

[52:16] did all that but I was unbiased et cetera. I mean you can still do it it's just keep that in the back

[52:22] your mind if you decide to where that have. A related question should the superintendent be the decision

[52:28] maker. And maybe that begs the question that if the superintendent plays a role in this,

[52:34] is there a better role for the superintendent to play?

[52:40] I just have the same comments I just made. If there's an independent person that

[52:47] reaches a decision that's substantiated, it's going to make the superintendent's job in any type

[52:52] of a subsequent hearing a whole lot easier. Because now you're saying, I got this decision,

[52:59] I have to act on it versus I made this decision and I stick by it now and

[53:05] After looking at everything, this is the decision I reached and I continue to believe it's a valid decision

[53:11] You can do it. It's just you got one step

[53:16] Removed and you're one step better off when you get to the hearing if you're not the decision-maker. You may have to be

[53:23] and just added that the superintendent who

[53:26] who may know about the five other instances

[53:29] that are similar to this, how can you show

[53:32] that the superintendent didn't take that into account

[53:34] and the ultimate decision or the notice of outcome?

[53:40] I'm much greater risk for a claim of bias

[53:43] in that situation.

[53:48] Okay, we have about, I don't know,

[53:51] what do we go to about 10 minutes?

[53:52] A little over to cover the appeal.

[53:54] This we can do in 10 minutes.

[53:56] But any party has right to appeal from a determination regarding responsibility and from the district or a dismissal of formal complaint.

[54:09] So it's a determination regarding responsibility that this individual is responsible or I guess it's not responsible.

[54:18] But the basis of that appeal has to be a procedural irregularity that affected the outcome of the matter.

[54:25] You didn't give me an opportunity to provide your response before the interview.

[54:31] That would be a procedure or irregularity.

[54:33] You didn't tell me that I could review all the evidence.

[54:37] You didn't give me a chance to respond once I saw all the evidence.

[54:41] You didn't give me a chance to draft a response to the investigation report.

[54:45] You forgot to allow me to ask questions that I might want to ask.

[54:50] You denied me the right to ask a question that I should have been allowed to ask.

[54:55] These are all procedural irregularities.

[54:58] This is why we did this training this morning because that's all new stuff.

[55:03] And that's all stuff that hasn't occurred in the past that has to occur now or it's

[55:08] a basis for the appeal.

[55:12] And the other ground for appeal is new evidence was not available at the time of determination

[55:17] regarding responsibility.

[55:19] In other words, when the decision maker made the decision, they didn't have this new evidence,

[55:24] or the investigator didn't have it, and therefore the decision maker, when they reached their

[55:29] decision, didn't consider it.

[55:34] And that new information has to be something that could affect the outcome, but that's a

[55:40] basis for appeal.

[55:42] And then the third one is that the coordinator investigator or the decision maker had a conflict

[55:46] of interest.

[55:47] So those are the only grounds for appeal.

[55:51] So, you know, the most common desire to appeal is,

[55:56] I don't agree with the decision.

[55:58] I think that based on the evidence that sexual harassment was not

[56:02] substantiated, that's not something you get to appeal.

[56:07] It's only the process was messed up, there's new evidence

[56:11] or there was conflict of interest or bias.

[56:14] that's the limited basis for an appeal.

[56:19] Similarly, recommendation for sanctions

[56:21] or remedies is not a basis for appeal.

[56:28] If you want an appeal, you have to

[56:30] provide written notice of appeal and we already indicated that the decision

[56:33] maker must notify the parties of their right to appeal in the process for

[56:38] that.

[56:41] The notice has to state whether it's from a determination of

[56:44] responsibility or dismissal and we are recovered early on. Hopefully you remember the grounds upon which you must dismiss and the grounds upon which you may dismiss.

[56:57] So I'm appealing from the determination this individual was not responsible or was responsible but then the grounds still have to be procedural or new evidence or bias.

[57:14] And if they don't meet the grounds, the parties will be notified in writing of the denial of the appeal and the rationale there for.

[57:28] So, once this appeal is filed, the Title IX coordinator will notify the other party.

[57:34] And if appropriate, the investigator or original decision maker, for example, allegation, original decision maker was biased.

[57:43] And they were biased because they're related to the complaint.

[57:48] Well, maybe the original decision maker says, wait a minute.

[57:52] I don't know if you're confusing me with somebody else, but I have no relationship.

[58:00] That might be a bit reason why you would want to notify the original decision maker of the appeal,

[58:05] who may submit something to the appeal decision maker.

[58:08] But those everybody has to be notified, we already covered that the decision-maker on appeal

[58:18] cannot be any one of the other three parties, the decision-maker investigator, a coordinator,

[58:25] and that within 10 days from the notification of the appeal and

[58:34] the investigator and decision

[58:38] as your maker, each party may submit a written statement

[58:41] and support or challenge in the outcome.

[58:43] So, the respondent appeals the decision.

[58:47] Notice should go out to the complainant

[58:49] and respondent that a notice of appeal has been filed.

[58:54] Here's the basis of it.

[58:56] You each have 10 days to submit a response.

[59:00] And that response is limited to the portion of the appeal

[59:03] that was approved and involves them.

[59:08] So if the appeal is that this process was not followed,

[59:15] that's the portion of the appeal

[59:19] that the response should be limited to.

[59:22] Not that I think you should have interviewed

[59:25] this other witness or anything like that.

[59:28] It's okay.

[59:30] You know what?

[59:30] this response did go to everybody. We were both copied on the email, or I think there was 10 days,

[59:39] it's 10 days, not 10 school days, or vice versa, but it's limited to the basis of the appeal.

[59:50] And then within 10 school days of receipt of the party's written submission, the decision maker will

[59:59] issue a rip.

[1:00:00] Decision. The goal being here, appeal doesn't drag this out very far. You have to render a decision on the appeal within 10 school days is the way we wrote the policy we have. So at least gives you the 10 school days, not calendar days, but that appeal decision has to be reached. And decision has to specify the finding on each grounds for appeal.

[1:00:28] ask to be in writing and delivered to the person by mail or email and at that

[1:00:34] point it's final. So there is yet another new step to this whole process that

[1:00:42] you may have to comply with.

[1:00:49] So pill decision shouldn't review the decision

[1:00:53] makers decision and say you know based on the evidence I don't agree with the

[1:00:56] decision that's not what the the pill decision maker does. You defer to the

[1:01:02] original decision except to the extent you need to refer it back because of the procedural

[1:01:09] error of the new evidence or the bias. It's not a full consideration of all the evidence. It's just

[1:01:16] the grounds for appeal.

[1:01:22] It's based on the same evidence unless it's a new review because of new

[1:01:27] evidence then you would get a chance to see that to see if it really could make a difference.

[1:01:33] Again, you don't get to substitute your judgment.

[1:01:36] It's not like the district court decided this,

[1:01:38] it's now going to the Supreme Court,

[1:01:40] and they can review this all and reach a different decision.

[1:01:42] That's not what's going on here.

[1:01:45] The decision of the decision make your sticks,

[1:01:47] unless there's bias or prejudice,

[1:01:51] new evidence or procedural error,

[1:01:53] and then you would generally kick it back for reconsideration.

[1:01:58] As

[1:02:04] far as other appeals being returned, I think what we're talking here about is if after

[1:02:10] it gets kicked back and then it's appealed again, the question of whether that's returned

[1:02:17] is at the discretion of the Title IX coordinators, whether there should be another appeal after

[1:02:22] that.

[1:02:25] Kelly, any thoughts about that?

[1:02:27] I think that only, I think it's clear what you do with this new evidence, it goes, you

[1:02:32] new evidence, then you go back to the investigator to add it to the report who then takes it back

[1:02:36] to the decision maker. But if you're bias and you're talking bias or procedural irregularity

[1:02:43] and they find those, then the town non-coordinator kind of has to figure out what do we do with this now,

[1:02:51] if that makes sense. What do we need to, you know, go back and start over with a new decision

[1:02:59] maker if there's bias. And so I think that's what it's talking about.

[1:03:06] So or it could be a procedural thing where theoretically the 10 days on the chance to respond

[1:03:13] to evidence was actually you didn't count or you counted the day they were given noticed

[1:03:20] and you shouldn't have. So they really only got nine days. But in the event they responded

[1:03:25] and the response was considered, I could see the appeal decision makers say, you know there was

[1:03:30] a procedure or irregularity it did not impact the outcome and therefore the decision should stand.

[1:03:37] I agree with that. I think the one that concerns me is the bias, right? So if they come in

[1:03:40] after the fact with the investigator and say the investigator was biased and the appeal decision

[1:03:45] maker says yes the fact the investigator was biased then you can go redo the investigation and I

[1:03:51] think that's you know kind of where that discretion is. I mean do you start over at that point?

[1:03:58] potentially?

[1:04:02] Well, we did get through them. I apologize for the rapid speed at

[1:04:08] which we went through the end. The PowerPoint will be available. Kelly and I

[1:04:13] will be available to answer questions to help you through these as they occur.

[1:04:20] We've got a few questions if you don't mind trying to hammer those out here real

[1:04:24] quick at the end. To the extent you have an answer this, what's your recommendation for which

[1:04:32] administrators serve and which roles?

[1:04:40] It is so dependent on the district. I think it's helpful.

[1:04:45] Like I said, if you have a K6 and a K612 that your principles actually could be investigators,

[1:04:54] as long as they're investigating in a different school than their own, so they come at it with

[1:04:59] fresh eyes and without, you know, kind of knowing that, you know, Johnny's a real problem

[1:05:02] students, so, you know, coming into it with that type of attitude. So I think you can

[1:05:07] work there. I think that your HR director sometimes can serve as a Title IX coordinator.

[1:05:18] If you have an HR director, I think your special ed teachers are also very good in serving

[1:05:24] in some of these types of roles, you know, you could, you know, bring in your business

[1:05:31] manager if need be, but again, I think it's helpful to try to develop a cohort with

[1:05:37] some other districts. Tracey, I'll let you.

[1:05:42] Yeah, it's just difficult, especially in small districts, but certainly I do think principals

[1:05:48] could be investigators. Possibly even decision makers, as long as it doesn't involve people, they have regular contact with.

[1:06:00] Title IX coordinator, it's not uncommon, maybe HR will fill that role possibly in a Administrator special director. I think it's going to very significantly from district to district because I think what is a superintendent.

[1:06:17] initially maybe even appointing a Title IX coordinator or superintendent and Title IX coordinator need to ask themselves is, is this person a deliberate person who can do a thorough investigation is not easily influenced or is not that can remain calm and objective throughout the process.

[1:06:44] us and we'll do a solid investigation at understanding what they are required to do and the same

[1:06:51] with the decision maker that, you know, you don't want someone that, well, geez, if I get

[1:06:56] this report from the principal, I'm going to just assume that they shouldn't be offering

[1:07:04] opinions, but the decision maker has got to be objective and impartial and not easily

[1:07:12] excited or doesn't jump to conclusions, but will be thoughtful, deliberative, and unbiased.

[1:07:19] I mean, those are probably the keys to what role do you feel?

[1:07:23] And just to add to that, I think what complicates it further is employee matters

[1:07:28] because you're potentially having a principal serve as someone who is investigating a peer,

[1:07:34] and I think that that can get difficult. And I'm not again looking to add to the expense, but

[1:07:39] especially as folks are becoming more comfortable with their roles, I'm encouraging them potentially to look at a decision-maker that is an attorney, the order to hire somebody not in the, you know, the district, whether it be an attorney.

[1:07:50] I know that some districts have also talked to retired teachers about coming in and playing and contracting them out to play in some of these roles, you know, especially investigator or decision-maker.

[1:08:02] So that's, you know, an option.

[1:08:06] I think we're out of time. We'll try to. Just this last question is about the appeals decision maker.

[1:08:13] Do they need the same training as the decision maker and is it possible that the decision the appeals decision maker be a committee rather than an individual?

[1:08:25] Well, as far as the training, they absolutely do need to be trained. Do they need the same as the decision maker?

[1:08:31] I think it would be helpful, and not just the decision maker, but investigator title.

[1:08:40] I think this whole training, it all dovetails together, because if you're going to determine

[1:08:45] if procedures were missed, you need to understand what procedures are.

[1:08:50] If you're going to determine if there's bias or prejudice, I mean, we had training about

[1:08:54] what bias is, what prejudice, confidentiality, conflict of interest, they need to understand

[1:09:00] all that and certainly the regulations mandate that they be trained so and I just think that the

[1:09:10] whole picture fits together that's why I've encouraged people whether whatever role they are to

[1:09:15] stay for the entire training as far as a committee. I don't I've seen folks do committees and I don't

[1:09:24] the regs preclude that. And I think, you know, some districts with the manpower would prefer

[1:09:32] two or three, you know, a panel to make a decision, both at the decision maker and appeal

[1:09:38] decision maker level.

[1:09:40] Well, I think we're tracing you have a last word of power out of time.

[1:09:44] I just, I know there's a drain on manpower, especially in small districts, which make that problematic.

[1:09:51] But other than the manpower, I don't see a problem with that.

[1:09:56] Let me add one more hopeful thing, Brian.

[1:09:58] Not hopeful. I don't know if it's good or bad.

[1:10:00] But one thing we are seeing is with this heightened definition.

[1:10:03] We're seeing a lot fewer cases that need to follow this policy.

[1:10:09] So it's not, you know, that is one.

[1:10:13] One reality of it.

[1:10:15] Great. Well, a big thank you to Tracy and Kelly for providing us

[1:10:20] this information today, it certainly is massive amount to try to consume and understand

[1:10:27] and appreciate you breaking it down for us. So, those of you that participated today

[1:10:31] as attendees, thank you for your time, thank you for spending your morning with us.

[1:10:38] We will be contacting your districts to verify participation and we will also get materials

[1:10:45] out to those that were verified attendees. Again, thank you all, and hope you have a good rest of

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