BEFORE THE OREGON GOVERNMENT ETHICS COMMISSION

Complaint Statement

Silver Falls School District (SFSD)

Executive Session Violations

Submitted by
Charles Sheketoff
June 15, 2020

The Silver Falls School District (SFSD) has violated Oregon’s Public Meetings Law at executive
sessions on at least two occasions.

SFSD appears to have violated requirements for executive sessions on May 14, 2018 and May
13, 2019 in one or more of the following ways:

(a) Failed to state the proper statutory authority for an executive session as required by
both ORS 192.640(2) and ORS 192.660(1);
(b) Failed to give proper notice of a principal subject of an executive session agenda item
as required by ORS 192.640(1)1, a statutory prerequisite for holding a valid executive
session in a public meeting;
(c) Failed to keep the discussion within the statutory purpose of the executive session as
required by ORS 192.660(2);
(d) Failed to have counsel present when discussing litigation likely to occur as required
by ORS 192.660(2)(h); and
(e) Engaged in discussions in executive session on topics not authorized as allowable for
executive sessions by ORS 192.660(2).

Two exhibits are attached.

1. The SFSD superintendent is an unelected, non-voting, ex officio

board member equally responsible for the violations as elected
members of the board

While the Oregon Government Ethics Commission must take appropriate action against the
SFSD’s school board members, the district’s superintendent at the time of the infractions should

1
Agendas with an executive session must meet the “principal subject” rule in addition to the requirement that they
state the statutory basis for the executive session. Sometimes the statutory basis is the same, such as when the
subject is to discuss labor negotiations (ORS 192.660(2)(g)). When the statutory basis is more general, as in the case
of ORS 192.660(2)(h) concerning consulting with counsel about pending or likely litigation, the public body must
give the public more information – the principal subject – for them to know whether they might be interested in
observing the public portion of the meeting after the executive session to see if a final decision be made in open
session after the executive session. Moreover, if the public and board members are not aware of the principal subject
it is more difficult to identify when the board unlawfully makes decisions in executive session.
Silver Falls School District Executive Session Violations Page 2 of 7
Complaint Submitted by Charles Sheketoff, June 15, 2020

be disciplined, as well. Under the terms of his contract with the district and under district policies
at the time of the two executive sessions that violated the Open Meetings Law, then-
superintendent Andy Bellando was essentially a non-voting ex officio member of the board. Mr.
Bellando should be held accountable to at least the same degree as the elected members of the
board who followed his lead.

Mr. Bellando’s contract2 gave the superintendent “the right to attend all board meetings, except
executive sessions held to discuss the Superintendent's employment status, and all board and
citizen committee meetings. He shall serve as ex officio member of all board committees and
provide administrative recommendations on each item of business considered by each of these
groups.” As “chief executive officer of the District,” under his contract, Mr. Bellando had
“primary responsibility for execution of the District's board policies.”

The contract further established that the superintendent was to “suggest policy * * * procedures
deemed necessary for the well ordering of the District.” As detailed below, one such policy
procedure that Mr. Bellando adopted and pursued, apparently considering it “necessary for the
well ordering of the District,” was his policy to give administrators (including himself) private
sessions with a quorum of the board to complain about a particular board member. That policy of
the superintendent, of course, had no support in the Oregon Public Meetings Law.

While the contract explicitly made the superintendent an ex officio member of board committees,
official board policies also essentially made the superintendent an ex officio member of the
board when the board met in executive session as a committee of the whole.

For instance, the provisions of SFSD “board governance and operations” policy BDDC3 made the
superintendent a non-voting, ex officio member of the board. Policy BDDC made the
superintendent a co-equal with the board chair for preparing an agenda (“The superintendent and
Board chair will prepare an agenda for all regular meetings of the Board”) and establishing the
agenda following a general order in a board resolution (“The agenda will be established by the
superintendent and the Board chair following a general order established by Board resolution.”)

Policy BDDC also gave the superintendent, not the board chair, sole responsibility for screening
agenda suggestions made by other board members, not just the suggestions from district staff,
students, or residents of the district (“Items of business may be suggested by any Board member,
staff member, student or citizen of the district by so notifying the superintendent at least five
working days prior to the meeting.”) Remarkably, BDDC did not require the superintendent to
tell the board chair which items he screened from consideration as an agenda item. By having the

2
Available in agenda for the meeting when approved at https://bit.ly/2YxXDJd. A direct link to the contract is
https://bit.ly/30G1Ugd.
3
BDDC is available with all other board approved policies at https://policy.osba.org/sfalls/AB/index.asp. A direct
link to BDDC is https://bit.ly/2MZ9Zog.
Silver Falls School District Executive Session Violations Page 3 of 7
Complaint Submitted by Charles Sheketoff, June 15, 2020

power to reject board member suggested items for a board meeting agenda, the superintendent
was an ex officio member of the board.

In summary, when a superintendent attends executive sessions and board committees like a
school board member, screens out ideas for agenda items like a school board member,
prepares and establishes board meeting agendas like a school board member, initiates and
participates in executive session discussions like a school board member, and has disregard
for the Oregon’s public meetings and records law like some school board members, the
OGEC must conclude that the superintendent is an ex officio member of the school board
who can and must be held accountable for inappropriate executive sessions just as other
board members are held accountable. It would be a miscarriage of justice if the OGEC
allows an unelected, non-voting, ex officio member of a school board to escape
accountability for board violations of the Oregon Public Meetings Law.

2. The SFSD board’s discussion of the SFSD’s assistant

superintendent’s concerns about the performance of an elected
board member was neither the stated purpose nor an allowable
purpose for the SFSD executive session on May 14, 2018
On May 14, 2018, the SFSD board held a meeting that included as an agenda item “Adjourn to
Executive Session under: ORS 192.660(2)(h) - To consult with counsel concerning the legal
rights and duties of a public body with regard to current litigation or litigation likely to be filed. -
AND ORS 192.660(2)(f) - To consider information or records that are exempt by law from
public inspection -- Superintendent Evaluation.4 The agenda notice failed to state the principal
subject of the consultation with an attorney as required by ORS 192.640(1), a prerequisite to
holding a valid executive session.

An email record SFSD released in 2019 revealed to the public that Dianda “Dandy” Stevens, the
assistant superintendent in 2018, was at the executive session on May 14, 2018. Then-
superintendent Bellando was undoubtedly also there, as the executive session was being held for
the board to discuss their evaluation of him. That email record also tipped off the public that Ms.
Stevens read a statement about board member Shelly Nealon. Statement attached as Exhibit 1.
The statement had nothing to do with the evaluation of the superintendent, the purpose of the
executive session. The statement Ms. Stevens read (Exhibit 1) contained a litany of complaints
Ms. Stevens had with the performance of board member Shelly Nealon and included a threat to
file a lawsuit.

4
See agenda at https://bit.ly/2UIY3es.
Silver Falls School District Executive Session Violations Page 4 of 7
Complaint Submitted by Charles Sheketoff, June 15, 2020

The minutes of the full open meeting5 do not identify any SFSD attorney as present at the
meeting. If the minutes of the executive session6 also show that there was no SFSD attorney in
person or on the phone during the executive session portion of the meeting, to the extent that the
board discussed the litigation threat by Ms. Stevens the board violated ORS 192.660(2)(h) on
May 14, 2018.

In the Stevens diatribe about board member Nealon, Ms. Stevens stated “I am sure that many of
these comments are difficult to listen to but at least you were provided the privacy and protection
of it occurring in executive session.” While Stevens used a passive sentence to avoid identifying
who provided “the privacy and protection,” given board policy BDDC it is safe to assume it was
a joint decision by superintendent Bellando and board chair Buchholz to allow Ms. Stevens to be
at the executive session on the superintendent’s evaluation and to be able to make her statement
and engage the board in a discussion of her concerns about board member Nealon.7

A search of Ms. Stevens emails with Mr. Bellando, emails between Mr. Bellando, Mr. Buchholz,
and Debbie Valoff the board’s secretary8, and email exchanges Ms. Stevens had with Ms. Nealon
might shed further light on both the motive to hide the statement in the cloth of an executive
session and the extent to which Mr. Bellando and Mr. Buchholz jointly provided the “privacy
and protection” of an executive session to Ms. Stevens in violation of the Oregon Public
Meetings Law.

In summary, with the blessing of, if not direction or formal approval of, board chair
Buchholz and non-voting ex officio board member superintendent Bellando, and with an
intent to hide the conversation from public view, on May 14, 2018, the SFSD board, other
than Ms. Nealon who was brought into the inappropriate conversation only by being the
target of the Stevens sneak attack, engaged in a discussion in an executive session that was
neither the stated purpose of the executive session (ORS 192.660(1) and ORS 192.640(2))
nor an allowable purpose of an executive session (ORS 192.660(2)).

5
Available at https://bit.ly/2YwPMvu.
6
A public record request for the executive session minutes is pending with the agency, so they are not attached.
OGEC, however, can obtain the minutes as part of its investigation.
7
There is no evidence that either gentleman responsible for the agenda, the chair or the superintendent, tried to
protect the other members of the board from violating the law by cutting off Ms. Stevens or directing them to leave
the session.
8
Ms. Valoff is the wife of then-board member Ron Valoff.
Silver Falls School District Executive Session Violations Page 5 of 7
Complaint Submitted by Charles Sheketoff, June 15, 2020

3. The SFSD board’s discussion of the superintendent’s concerns about

the performance of an elected board member was neither the stated
purpose nor an allowable purpose for the SFSD executive session on
May 13, 2019

On May 13, 2019, the SFSD board held a meeting with an agenda item captioned “Adjourn to
Executive Session under: ORS 192.660(2)(f) - To consider information or records that are
exempt by law from public inspection -- Sick leave bank request and superintendent
evaluation.”9

The sick leave bank request item fell under that statutory provision listed on the agenda. The
superintendent’s evaluation item, however, did not cite the proper statutory authority for the
executive session. The proper citation for conducting the evaluation of the superintendent was
ORS 192.660(2)(i), not (2)(f) as cited in the agenda and read by the chair before the session.

For the board to rely on ORS 192.660(2)(i) it would have had to assume that the evaluation form
that the board members completed for the executive session discussion was confidential and
exempt from disclosure. The law, however, did not and does not support the assumption. As
SFSD now well knows, under the Oregon Public Records Act a document is not exempt from
disclosure just because it is placed in the superintendent’s evaluation file or discussed in a
superintendent’s evaluation in an executive session.10

The error in citing the wrong statutory basis for the executive session discussion of the
superintendent’s evaluation falls plainly on both the superintendent, who not only approves
agenda items but is also in charge of having the agenda prepared and posted by an underling, and
the board chair, who is equally responsible for setting and establishing the agenda under board
policy BDDC.

More importantly, during the May 13, 2019, executive session, then-superintendent Bellando
discussed a letter from his personal attorney, Nathan Rietmann, dated that day and directed to the
full board (“the Rietmann-Bellando letter”). Exhibit 2.11 The Rietmann-Bellando letter was not
exempt from disclosure as a public record simply because it was delivered at an executive
session or placed in the superintendent’s evaluation file.12 The Rietmann-Bellando letter was
nothing more than a four-page attack on board member Shelly Nealon. While the Rietmann-

9
See agenda at https://bit.ly/2MYxxty.
10
See Consent Judgment of Dismissal, Marion County Circuit Court Case No. 20CV09281, available at
https://bit.ly/37vxcb4.
11
The public learned about the existence of the Rietmann-Bellando letter from a document released to Ms. Stevens
in response to the sweeping public record request attorney Rietmann made on her behalf after she left the
employment of SFSD.
12
See Consent Judgment of Dismissal, available at https://bit.ly/37vxcb4.
Silver Falls School District Executive Session Violations Page 6 of 7
Complaint Submitted by Charles Sheketoff, June 15, 2020

Bellando letter does give readers some insight into Mr. Bellando,13 it was at best an evaluation of
board member Nealon, not of Mr. Bellando, and was neither confidential nor exempt from
disclosure as implied by the executive session agenda notice citing ORS 192.660(2)(f). 14

SFSD board chair Buchholz was apparently in on the scheme. Not only did he approve the
agenda as set forth in policy BDDC, but his summary of the May 13 evaluation makes no
mention of the superintendent having any problems getting along with board member Nealon.15
In other words, Mr. Buchholz either tried to hide the fact that the board engaged in an
inappropriate discussion or confirmed that the discussion had nothing to do with Mr. Bellando’s
evaluation.

School district superintendents are supposed to be professionals who advise, guide, and politely
direct their board to comply with executive session law; superintendents are not supposed to be
the instigators of off-topic and unauthorized discussions in executive sessions. The Rietmann-
Bellando letter is evidence that Mr. Bellando knowingly and assertively instigated and engaged
the SFSD board in an unlawful executive session discussion on May 13, 2019, by presenting the
Rietmann-Bellando letter and discussing in executive session his displeasure with board member
Nealon.

Mr. Bellando engaged the board in an inappropriate discussion with the approval of board chair
Tom Buchholz. A search of emails between Mr. Bellando, Mr. Buchholz, and Debbie Valoff, the
board’s secretary who physically types up and posts the agenda, might shed more light on Mr.
Bellando’s and Mr. Buchholz’s motives to hide the discussion in the cloth of an executive
session. Those emails may also show that chair Buchholz specifically agreed to allow Mr.
Bellando to discuss the Rietmann-Bellando letter prior to the meeting.

In summary, with the blessing of, if not direction or formal approval of, board chair
Buchholz, on May 13, 2019, the SFSD board, other than Ms. Nealon who was brought into
the inappropriate conversation only by being the target of the Bellando sneak attack,
engaged in a discussion in an executive session that was neither the stated purpose of the
executive session (ORS 192.660(1) and ORS 192.640(2)) nor an allowable purpose of an
executive session (ORS 192.660(2)).

13
Among the more illustrative statements in the letter is the one in which Mr. Bellando, a white male, asserts
(through his lawyer Nathan Rietmann) that the board member, Shelly Nealon, a white woman, was "targeting him
because of his race and gender."
14
Prior to this executive session, in an email to board member Nealon, Mr. Bellando had declared that it was district
operating policy that any document presented in executive session was exempt from disclosure.14 See
https://bit.ly/3hvsxKH. The policy he espoused, of course, was neither formally adopted nor consistent with the
Oregon Public Records Act.
15
Available in agenda for the meeting when the summary was presented at https://bit.ly/3d8tzct. A direct link to the
summary is available at https://bit.ly/2B4pnNx.
Silver Falls School District Executive Session Violations Page 7 of 7
Complaint Submitted by Charles Sheketoff, June 15, 2020

4. Summary and requested enforcement actions

The Silver Falls School District (SFSD) on at least two occasions violated Oregon’s Public
Meetings Law in executive sessions. The Oregon Government Ethics Commission must take
appropriate action against both the elected school board members who constitute the public body
and the school district superintendent who was acting in his capacity as a non-voting, ex officio
member of the board.

Superintendent Bellando not only was responsible for preparing and presenting agendas for the
two board meetings at issue, screening topics for discussion, and attending all executive sessions,
but he instigated and engaged the board in topics that were neither covered by the stated
purposes of the executive sessions nor allowable purposes for executive sessions. While Mr.
Bellando and Ms. Stevens have both left SFSD; they are now superintendents in Dallas and
Gervais, respectively. If Mr. Bellando is not held accountable for these actions, OGEC can have
little confidence that he will not similarly engage the Dallas district in inappropriate executive
sessions. It would be a miscarriage of justice if the OGEC allows an unelected, non-voting, ex
officio member of a school board to escape accountability for board violations of the Oregon
Public Meetings Law that he planned and instigated.

Mr. Bellando, as an ex officio member of the SFSD board, and the SFSD board members
other than board member Nealon, ought to be fined. As the target of the animosity of Mr.
Bellando and Ms. Stevens that comprised the inappropriate executive session discussions,
board member Nealon should not be blamed for other members of the board entertaining
the attacks in an executive session. To the extent board member Nealon participated in the
inappropriate executive session discussions, undoubtedly her comments were made in self-
defense while others on the board failed to come to her defense or failed to call a halt to the
inappropriate and sneak attacks by Mr. Bellando and Ms. Stevens.

The other board members present who failed to shut down the conversations or leave the
executive sessions should, of course, be fined if they chose to do nothing to put an end to the
inappropriate executive session conversations started by Mr. Bellando and Ms. Stevens. Those
other board members knew better and have no excuse for joining the discussion or allowing it to
continue.

Respectfully submitted:

________________________
June 15, 2020
PAGE INTENTIONALLY BLANK
 Exhibit 1, Page 1
I sit before you tonight with a heavy heart and with great concern. I fear that
this board and the district are being placed in a position of an “us” versus
“them” mentality which is only going to further divide the district and
community members. Additionally, actions by one particular board member are
also placing the district in a position which is not defendable from an
employment practice standpoint.

During Thursday night’s budget committee meeting, Board Member Shelly

Nealon violated multiple board policies, procedures and agreements. She
attempted to package her actions under following the Oregon Public Meetings
Law. It appears the board may need to revisit this law and more clearly outline
expectations for board member conduct. Shelly’s behavior reflected poorly on
the board overall and showed a level of disrespect toward employees I have not
witnessed. If a building principal had addressed a teacher in a staff meeting in
the manner in which Shelley addressed district administration during the
budget committee meeting, not only would our unions be demanding action
but the principal would be disciplined for that type of behavior.

As a district we have experience with a board member whose actions on social

media were questioned and labeled as offensive and the board took action
against that individual. I submit to you that Shelly’s behaviors are actually
more harmful. A person can choose to engage in social media posts and if he or
she does not like the interaction, remove him or herself from the situation.
While unpleasant, it more than likely does not impact the individual’s normal
day to day life. I, as well as other district administrators, am not afforded the
same opportunity. I can’t disengage from the person who attempted to
humiliate me and create an uncomfortable work environment because I must
still perform my duties which include having to sit silently in a public meeting
while my character is being disparaged and having to sit in front of her again
tonight. Shelly has been very quick and vocal to criticize her fellow board
member. I would suggest that she hold herself to the same standard of conduct
she demands from him.

Thursday night’s concerns were packaged as ethical and moral obligations she
had as a board member. However, those are trigger words used in order for her
to justify behaving in an unprofessional manner. The comments made violated
my employment rights as an employee of this district. Shelley’s statements of “I
don’t trust this administration” and “I don’t trust district administration” while
pointing to myself, Andy and Steve, during discussions of budget issues is
inappropriate and unfounded.
 Exhibit 1, Page 2
The board just received an audit which Steve reported to you. All monies are
fully accounted for by line item. Additionally, you all receive a full report every
month on expenditures. We have processes in place through our purchasing
system which require multiple “looks” and approvals by different parties. There
is no foundation for “claims” to not trust administration in relation to monetary
or budgetary issues. Despite being asked multiple times by other budget
committee members, no specific evidence or examples were given to
demonstrate a lack of trustworthy actions or of poor fiscal management.
Therefore, one can only assume that Shelley is attempting to use the budget
committee function to further her own agenda which appears to focus on
disparaging employees and attempting to impact their reputations in this
community resulting in dissension between groups. The board has received
training and direction through OSBA that your one and only employee would
be the superintendent. The board has no authority over any other employee
and all comments or criticisms especially under the category of performance
issues are supposed to go directly through the superintendent per your own
board policy.

Shelley did address with Andy a few months ago that she did not appreciate
when I “talked over” her as she asked questions during a report I made on
transportation in the fall. Perhaps this was what made me untrustworthy? I
assured Andy that I would not do that again. However, I am now going to state
why I did that. Shelley makes statements, as she did last Thursday, which are
not based on all the information, are not fully researched, are not addressed to
district staff to provide information and then she presents her opinions as if
they are fully vetted. Once she makes the statements, she creates more work
for the rest of us who are left to try and correct the misinformation. This
creates chaos and confusion in the district and the community. Case in point,
Shelley started her questioning last Thursday by asking the Director of
Teaching and Learning about the salaries of my assistant and myself.
Statements such as:

the salaries are inflated, hefty, ballooning,

“in the 90th percentile” when compared to Salem Keizer or Albany

“if these salaries were not so high maybe we could afford music”

“where is all the money going”

“There could be hundreds of thousands of dollars”

 Exhibit 1, Page 3
are examples of her use of inflammatory comments to create alarm and
dissension. I am unsure what kind of answer she was expecting to get from
that director as Jennifer has nothing to do with contracts, hiring or salaries.

I have included salary comparisons for myself and Andy. I didn’t have time to
put the rest together. These come directly from the COSA website and are
based on districts’ self-reporting. As you can see the information included here
does not put us anywhere near the 90 th percentile and in fact indicates we are
at or below average.

At the end of the meeting when Shelley included her comments about the
teachers being the lowest paid, she again put misinformation out there which
is now also streaming on the thought exchange survey we are trying to use to
determine programming needs for students.

The Statesman Journal ran a list of top 10 low paying and high paying
districts. I have included clarification with regard to this information. While it’s
technically accurate, it’s important to know the reasoning behind still having
this column available and also knowing how many employees are really
affected by this pay scale.

These statements and misinformation regarding compensation is going to be a

problem when the board goes into bargaining with the licensed association
next Spring and a perception the board needs to attempt to correct prior to
then. While I appreciate and acknowledge the right and responsibility of board
members to ask questions, there is also an obligation to do so in a manner that
fosters a common goal and desired outcome…one of unity.

Finally, I want to share what I believe is evidence of a lack of transparency and

potentially inappropriate actions by board member Nealon that could
jeopardize the integrity of this board and further drive a wedge between the
district and the community. In a recent board meeting a building administrator
observed Sarah Wietzman text a question to Shelly during the board meeting.
Once the text message was sent, the administrator watched Shelly look at her
phone and then she responded verbally either by asking the question or
making a clarifying point during the actual meeting. I believe this creates an
inappropriate line of communication between audience members and the board
while trying to conduct board business. Additionally, approximately 40 minutes
before the budget committee meeting ended on Thursday, I observed Shelly on
her phone. Twenty minutes later, at more than 2 ½ hours into the meeting
Naseem Rhaka entered the room. It is not unusual for Naseem to attend the
meetings. She frequently is in attendance at the beginning of the meeting or
 Exhibit 1, Page 4
shortly thereafter. The timing of her appearance in relation to Shelly being on
her phone is suspect. Naseem has requested a copy of the budget committee
meeting recording for an article she is writing. I believe it was important to
share this information as there has been discussion by other district
administrators regarding their concerns that Shelly and others she interacts
with are committed to fostering a hostile environment and dividing the district
and community into two distinct camps. This concern has also been expressed
by community members.

I am sure that many of these comments are difficult to listen to but at least you
were provided the privacy and protection of it occurring in executive session, a
courtesy not afforded to me or the other administrators and our experiences
will live on a recording as a public record.

I feel obligated to inform you that I have been in contact with a COSA
appointed attorney and please know that this is my initial “notice” to the board
that if necessary I will pursue action against the offending board member and
the entire board if additional situations such as what occurred Thursday night
continue. This will include taking action if I am in anyway named in a
published piece which references Thursday night’s comments made by Shelly
and further disparages my character to the community. While I can’t control
what a person decides to publish, if Shelly had followed protocols and refrained
from disparaging me, it would not be a board issue.

I expect to be able to come to work and attend meetings where all board
members, including Shelly greet me, make eye contact with me and
acknowledge me when I say hello …all behaviors Shelly currently does not
engage in with me now. I want to move forward and it’s my desire to resolve
this issue at the lowest level possible. Thank you for your time and I know that
these statements will weigh heavily on the board. I appreciate your
commitment and I am sorry that is has come to this; however, I trust the board
to resolve this issue in a manner that reflects the best interest of our students,
staff and community.
 Exhibit 2 Page 1

RIETMAHN l-AV\r, P.c.

May 13,2019

Silver Falls School Distriot

Attn: Board Members
612 Schlador St.
Silverton, Oregon 97381

Re: Board Member Shelly Nealon

Board Members:

This firm represents Andy Bellando with respect to his employment as

Superintendent of Silver Falls School District.
notifu the Board that one of its members is
conduct. Superintendent Bellando is requesting
member so that the conduct ceases and it is
forward.
The purpose of this letter is to formally
engaged in a pattern of unprofessional
that the Board address this issue with its
possible for the entire Dishict to move

Superintendent Bellando's concerns relate to the conduct of Board member Shelly

Nealon, who was elected to the Board in May of 2017. Shortly after her election, five
people approached Superintendent Bellando to inform him that Ms. Nealon has
specifically stated one of her main goals was to terminate Superintendent Bellando's
employment. Superintendent Bellando viewed this information as being very credible,
especially considering that one of the people providing the inforrration was a very close
friend of Ms. Nealon's.

Since that time, Ms. Nealon has sought to target, harass, and undermine
Superintendent Bellando in various different ways. Examples of such behavior include
the following:

o In the winter of 2017, a member of the Board informed Superintendent

Bellando that Ms. Nealon was accusing him of sexually harassing teachers and
engaging in inappropriate sexual relations with an employee. These allegations
were absolutely false and damaging to Superintendent Bellando's personal and
professional reputation. The false allegations also caused Superintendent
Bellando emotional distress. Superintendent Bellando responded to the

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 Exhibit 2 Page 2

situation by attempting to speak with Ms. Nealon directly. However, she

unconvincingly denied making the allegations and refused to engage in any
type of substantive conversation.

o In April of 2018, Ms. Nealon's publicly stated in a Budget Committee meeting

that she does not trust the District administration, pointing directly at
Superintendent Bellando and the Dishict's Assistant Superintendent while
making the comment. Superintendent Bellando informed the entire Budget
Committee that Ms. Nealon's comments were performance based and
inappropriate under District policy and the Board/Superintendent Working
Agreement. The Assistant Superintendent spoke with the District School board
regarding the matter and submitted a letter placing the District on notice of
possible legal action if Ms. Nealon continued the behavior. Subsequently, the
District's Business Manager shared public testimony at the next Board
meeting, in his capacity as a parent, conceming his dissatisfaction with Ms,
Nealon, her lack of professionalism, and her violations of District policy
surrounding employee performance. Subsequently, Superintendent Bellando
communicated similar concerns to the Board via an email.

. Subsequently, in the spring of 2018, Ms. Nealon took the position that she
would only share her concerns in public, during Board meetings, rather than
addressing them with the Superintendent. Ms. Nealon's newly adopted position
on this matter directly violated the Board/Superintendent Working Agreement.

. In December of 2018, following the Board's selection of a new mernber to the

Budget Committee, Ms. Nealon expressed her dissatisfaction with the Board's
selection by stating in a local newspaper, "we just kicked off a woman and
added another man to the budget committee." L&ter in the article, Ms. Nealon
affirmatively supports an allegation that the Board is a "good old boys club."
These statements run counter to the Board/Superintendent Working Agreement
which states that Board members will "support decisions of the majority by not
actively doing damage to the Board..." Ms. Nealon's criticism of the Board's
decision based on the gender of the person the Board selected was extremely
concerning to Superintendent Bellando personally and professionally. In fact,
these comments, when coupled with Ms. Nealonns prior false allegations
against him and other contextual information, led Superintendent Bellando to
seriously wonder whether Ms. Nealon's has been targeting him because of his
race and gender.

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 Exhibit 2 Page 3

. ln 2019, there have been numerous Board and Budget Committee meetings
where Ms. Nealon has asked directors and other administrators for information
that Superintendent Bellando has already provided her. While Ms. Nealon
likes to say she had adopted this practice to help make the public more aware
of certain information, her conduct is widely perceived as being targeted at
Superintendent Bellando and aimed at minimizing his credibility with the
Board and the public.

. In February of 2019, Superintendent Bellando extended a routine invitation to

all Board members offering to meet with members individually for the purpose
of keeping them informed and answering questions about school related
matters, as needed. Ms. Nealon eventually responded to this invitation by
stating that she would feel extremely uncomfortable and unsafe to meeting
with Superintendent Bellando, even if the Board chair was present. Ms. Nealon
oflered no reason for this comment and there is no objectively reasonable basis
for this comment.

. In April of 2019, Ms. Nealon served as the Board representative on a large

committee that had been formed to screen and interview assistant
superintendent applicants. Although the committee was formed by the
Superintendent as per his job description, Ms. Nealon sought to change the
makeup of the committee and the selection process after being assigned to it.
Her efforts ultimately required intervention by the Board chair and the Oregon
School Board Association. Thereafter; shortly before the committee was
scheduled to meet for the first time, Ms. Nealon emailed all committee
members and attempted to modi$r selection procedures. Ms" Nealon's
suggestion was rejected because it could lead to unfair hiring practices
complaints.

o In May of 2019, Ms. Nealon sought to make Superintendent Bellando and the
Dishict Business Manager look bad during a budget committee meeting by
rudely asking them rapid-fire questions. Most of the questions were ones to
which Ms. Nealon had already been provided answers. Following the meeting,
Superintendent Bellando was told by various individuals in attendance that the
questioning seemed intended to embarrass or harass Superintendent Bellando.
Regareltess, the manner of questioning was unprofessional not in keeping with
the Board/Superintendent Working Agreement, which specifically describes
how Board members are to conduct themselves during meetings.

Rid nnlary p.c.. l.ldnrR Rietrtanr. g0Chsrd<dast. NE . Sderl Orqon 9R0f

Ph: 503.561240 . Fax 1€88700-019 . ndhm@idnnrnlarucom
 Exhibit 2 Page 4

Ms. Nealon's behavior is not accidental and she is aware it is inappropriate. Since
being elected to the Board in May of 2017, Ms, Nealon has attended multiple trainings on
Board member roles and responsibilities, including the OSBA sufilmer conference, the
OSBA annual convention (twice), and three OSBA trainings specifically directed at the
Silver Falls School Board. In addition, Ms. Nealon has twice voted in favor of the
Board/Superintendent Working Agreement, which defines many of the Board member
expectations. Simply stated, Ms. Nealon is fully aware of how to conduct herself
appropriately.

Moving forward, all that Superintendent Bellando is requesting is that Ms. Nealon
conduct herself professionally in accordance with District policy and the
Board/Superintendent Agreement moving forward. To the extent Ms. Nealon is unwilling
to do this voluntarily, Superintendent Bellando is requesting that the remainder of the
Board consult with legal counsel and take action, insofar as is necessary to ensure she
does so. While Ms. Nealon is certainly entitled to maintain and express her own views
and register any dissent, it is important that she do so in a professional manner that
complies with District policy and the Board/Superintendent Working Agreement.

Sincerely,

Nafhan R. Rietmann

RiehmmLaal p.c. r nldunR. Ridnmr. 1270Chsrd<dag. NE . Sdsn Orqpn }T3UL

Ph:503{6127210 " Fax 1$&7mryg2 . nfihffiGfidnnnnlarucom