Update: April 4, 2017 NYSED Appeal Number 20602 Samuel L. Radford, et al vs. Carl Paladino, et al Regarding the Removal of Carl Paladino from the Buffalo Board of Education and the Replacement of the Board with a Receiver
Buffalo Parent 306 Petitioners In NYS Education Application For Removal of Carl Paladino
FOR IMMEDIATE RELEASE Contact:
Samuel L. Radford, III In the Matter of Samuel L. Radford, III vs. Carl Paladino NYS Education, Appeal No. 20602 Buffalo, NY 716-578-3571 Franklin Redd, Jr. In the Matter of Samuel L. Radford, III vs. Carl Paladino NYS Education, Appeal No. 20602 Buffalo, NY (716) 948-8113
BUFFALO ATTORNEY DENNIS VACCO CALLS FOR HALT IN ALBANY LAWSUITS TO REMOVE CARL PALADINO AND GIVES NOTICE OF INTENT TO FILE FEDERAL LAWSUIT. PARENTS CONTINUE TO CALL FOR THE DISTRICT TO BE PUT UNDER THE CONTROL OF A RECEIVER. April 4, 2017, Buffalo, New York---Buffalo attorney Dennis Vacco, representing School Board Member Carl Paladino in a series of petitions calling for the removal of Mr. Paladino from office by the NYS Education Commissioner, has called for a halt in the continuation of the actions filed by the Board of Education, the Buffalo Parent Teacher Organization and the NYS Teachers Union. By letter and affidavit dated March 30, 2017, Mr. Vacco raises serious questions of conspiracy, collusion and the violation of Mr. Paladino’s civil rights by members of the Buffalo Board of Education and parties to three of the four petitions filed to remove Mr. Paladino from office. Citing an unprecedented look at a billing statement of attorney Frank Miller, who is representing the Buffalo School Board, Mr. Vacco gives notice of his intent
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-more to immediately file a lawsuit in federal court and putting an end to the Albany actions against Mr. Paladino. By letter dated April 4, 2017, parents, headed by Samuel L. Radford, III, filed a fourth petition seeking the removal of Mr. Paladino and the entire School Board. The petition filed by the parents was not included in the allegations filed by Mr. Vacco. Parents continue to call for the Commissioner to replace Mr. Paladino and the entire Buffalo School Board with a receiver. For access to complete inventory of relevant documents, click the following link: https://www.yumpu.com/s/DXYqIFGdiNO3tKf9 -End-
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Parent Petitioners’ April 4, 2017 Response to Dennis Vacco, Esq. March 30, 2017 Letter
District Parent Coordinating Council April 4, 2017 VIA FAX (518) 474-4188 & FIRST CLASS MAIL MaryEllen Elia, Commissioner NYS Education Department Office of Counsel NYS Education Department, Room 112ED State Education Building 89 Washington Avenue Albany, NY 12234 Tina Urbiatis, Appeals Coordinator NYS Education Department Office of Counsel NYS Education Department, Room 112ED State Education Building 89 Washington Avenue Albany, NY 12234 Re: Samuel L. Radford, III, et al vs. Carl Paladino, et al SED Appeal Number 20602 Commissioner Elia and Ms. Urbiatis: For reasons that follow, and good cause shown, pursuant to 8 NYCRR Section 276.5, the undersigned petitioners kindly request that: (1) that the above referenced Appeal be STAYED, consistent with the request of Dennis C. Vacco, attorney for Mr. Carl Paladino in SED Appeals Numbered 20601, 20604 and 20596. A copy of Mr. Vacco’s letter, dated March 30, 2017 is annexed as EXHIBIT A; and (2) that the records of SED Appeals Numbered 20601, 20604 and 20596 be fully incorporated, by reference, into the record of the above referenced Appeal, including the two applications made by Mr. Vacco, on behalf of Mr. Paladino, dated March 17, 2017 and March 30, 2017 to provide additional supporting evidence; and
MaryEllen Elia, Commissioner Tina Urbiatis, Appeals Coordinator Page 2 (Continued) (3) that Mr. Vacco’s request that SED Appeals Numbered 20601, 20604 and 20596 be STAYED is granted so that the serious allegations raised in his March 30, 2017 are fully investigated. The undersigned petitioners represent the interests of our children, along with the interests of similarly situated parents and children within the Buffalo Public Schools District. Ab initio, the interests of the other parties in the related petitions to remove Mr. Paladino, along with questions of duty of loyalty raised by attorneys for the Buffalo Board of Education and the individual Board Members have triggered numerous questions about collusion and conflicts of interests. For this very reason, cause is shown that the request of the undersigned petitioners should be granted.
Moreover, and in addition, the undersigned petitioners’ request herein should be
granted because if the March 30, 2017 allegations of Mr. Vacco are true, then the ultimate determination by the Commissioner, in all four of the pending petitions to remove Mr. Paladino from the Buffalo Board of Education, will be tainted and subject to years of litigation with the resulting enormous legal costs. See, EXHIBIT B, invoices of attorney Frank Miller representing the Buffalo School Board, except Carl Paladino.
It is also the position of the undersigned petitioners that Mr. Vacco’s March 30, 2017
allegations, if true, would further support the petitioners’ request in SED Appeal 20602, that the entire Board is dysfunctional and should be immediately replaced by a receiver. It is also the petitioners’ position that the allegations raised by Mr. Vacco in his March 30, 2017 letter supports the position of the undersigned that the 306 Appeal process is
MaryEllen Elia, Commissioner Tina Urbiatis, Appeals Coordinator Page 3 (Continued) fruitless and violates the Due Process and Equal Protection clauses of the 14th Amendment to the U.S. Constitution. Should Mr. Paladino initiate a federal court action based on the “Illegal Cases� Mr. Vacco alleges have been filed with SED to remove Mr. Paladino, the undersigned will seriously consider intervening in such action pursuant to Rule 24(a)(2) of the Federal Rules of Civil Procedure.
For reasons set forth above, the undersigned kindly request the relief requested. Thank you, /s/ Samuel L. Radford, III _________________________________________________________ Samuel L. Radford, III, Petitioner 1423 Fillmore Avenue Buffalo, NY 14211 (716) 578-3571 (716) 332-1015(fax) /s/ Patricia A. Elliott Patton _______________________________________________________ Patricia A. Elliott Patton 1423 Fillmore Avenue Buffalo, NY 14211 (716) 578-3571 (716) 332-1015(Fax) /s/ Kevin Lafferty _______________________________________________________ Kevin Lafferty 1423 Fillmore Avenue Buffalo, NY 14211 (716) 578-3571 (716) 332-1015 (Fax) /s/Franklin Redd, Jr. _________________________________________________________ Franklin Redd, Jr. 1423 Fillmore Avenue Buffalo, NY 14211 (716) 578-3571 (716) 332-1015 (Fax)
Certification of Service The undersigned, _____________________________________, hereby certify that a true copy of
the annexed letter, with attachments have been forwarded by first class mail, postage prepaid to the following and deposited on April 4, 2017 at a post office of the U.S. Postal Service in Buffalo, New York. By: ______________________________________________ Name: _______________________________________ Address: _______________________________________
Mailed to: Dennis C. Vacco, Esq. (via U.S. Mail) Frank W. Miller, Esq. (via U.S. Mail) Richard T. Ross, Esq. (via U.S. Mail) Raymond Audain, Esq. (via U.S. Mail) Jalina J. Hudson, Esq. (via U.S. Mail) Richard E. Casagrande, Esq. (via U.S. Mail) Bethany A. Centrone, Esq. via U.S. Mail)
_______________________________________
EXHIBIT A
EXHIBIT B
 
Dennis Vacco, Esq. March 30, 2017 Letter To NYS Education Commissioner Seeking Halt To Three Petitions Filed Against Carl Paladino


Dennis Vacco, Esq. March 30, 2017 Affidavit To NYS Education Commissioner Seeking Halt To Three Petitions Filed Against Carl Paladino
 
Original 306 Petition Filed By Parent Advocates Seeking Removal of Carl Paladino and Appointment of Receiver To Replace Entire Buffalo School Board
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The toxic tone and tenor of the atmosphere within the Buffalo Public
Schools District-antithetical to the best interests of our children-is illustrated by this flyer--which circulated within the City of Buffalo two years ago:
You are Cordially Invited to a Board of Education Circus Performance Featuring
“The KRAZY KARL KLAN” Buffalo: America the Beautiful
Wednesday January 28, 2015 Performing Arts High School – Buffalo, New York Pre-Show Rally at 4:00 pm - Performance begins at 5:00 pm
Witness “Sam The Rafter” swing from his monkey bars!
____________________________________________________ Starring (In Order of Self Importance)
Carl “Bull Connors” Paladino
CRITICS ARE RAVING! “An exciting performance---a fiasco that can only be seen in Buffalo, New York. A true artistic work of political theater.” --- The Buffalo Daily Snooze
“A major showcase of social themes like ‘the disassembly of Buffalo Public Schools’ and ‘how to violate black people’s rights.’ A must see event for all self-respecting white people.” Larry “George the Wallace” Quinn
--- W BEE E IN Radio
“This is just what Buffalo needs…more plans plays like this. I would score this performance a 0 out of 10 and rate it highly effective! Mandatory for the whole world. Let’s test!” --- Dr. John Charter King
James “David the Duke” Sampson
“Even kids in poverty will appreciate this performance. Don’t blame the teachers if the kids miss this educational opportunity of a lifetime! I really loved the scene where the teacher gets a facelift, tummy tuck and boob job and the school district was forced to pay for it.” --- Fill Ruin Moore
Jay “Mason-Dixie” McCarthy
ADMISSION
Free (Parents with EBT card) $10,000 (Supporters of Charter Schools with Ben Done Bennett Vouchers) $15,000 (Supporters of Charter Schools with Kuomo Tax Credits)
If you BELIEVE…make a donation! Insparaciallional music and dance by the
Donations may be tax deductible – Ask Mike Dealee or Larry Scottch
4 SISTAS OF SOUL Singing there smash Gospels hit
“WE AIN’T NEVA GONNA BEES FREE LORD”
Photo: The sistahood, circa 1968, Buffalo East-Side
A Special Guest Appearance by Patty “Rubberstamp” Pierce in the Recurring Role of Peppermint Patty
Underwritten by The Piss-On-Your-Broken-Promise Neighborhood Group Bob Wiltsomemore (M&Tea Party Bank), The OSHIT Foundation & The Buffalo Daily Snooze
A Buffalo School Board Production where our motto is: “we produce drama instead of education”
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Petitioners bring this action in the context of a district described as failing
by the Governor, in violation of fundamental rights of students as guaranteed by the Civil Rights Act of 1964, where noted educational experts are ignored and ridiculed, and public racialize politics is the norm. Facts Related To Relief Requested 26.
On or about December 23, 2016, Buffalo School Board Member Carl P.
Paladino caused the followed article to be published nationally in ARTVOICE newspaper:
Carl Paladino DEVELOPER, SCHOOL BOARD MEMBER, POLITICAL ACTIVIST 1. Obama catches mad cow disease after being caught having relations with a Herford. He dies before his trial and is buried in a cow pasture next to Valerie Jarret, who died weeks prior, after being convicted of sedition and treason, when a Jihady cell mate mistook her for being a nice person and decapitated her. 2. Michelle Obama. I’d like her to return to being a male and let loose in the outback of Zimbabwe where she lives comfortably in a cave with Maxie, the gorilla. 3. Someone with a brain, a set of balls and a lack of fear who has enough money so as not to owe anyone anything once elected and who believes in a market economy. 4. We need a $50 million dollar train station as much as we need parasitic people like Lou Ciminelli, 80% of the school board and the dizziness of socialistic progressive politicians who never signed the front of a paycheck. At best 400 people a day take a train. They are not complaining about exchange or Depew. We are already the laughingstock of America for having the dumbest elected leaders ever. Why add to it.
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