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New York City Teacher Theodore "Teddy" Smith and the Perfect Storm of Injustice
Teddy Smith is just one of hundreds of teachers, public school staff, parents and children who have been maliciously prosecuted by the corrupt New York City Board of Education-SCI-OSI-Corporation Counsel Complex. We ask that Joel Klein resign or that Mayor Michael Bloomberg fire him along with dissolving the offices of SCI and OSI due to a pattern and practice of fabricating evidence and for violating the due process rights of New York City staff, parents and children who work in or attend NYC public schools. NYC at present has established no oversight or management for the investigation process, leading to a fraudulent free-for-all immunity from reprimand for NYC BOE administrators and principals. No one should be placed above the law. By Betsy Combier
          
   NYC BOE Attorney Susan Jalowski   
The Special Commissioner of Investigation, Richard Condon, and his group of former police officers/investigators must be fired, and the Department of Investigation must be re-organized. Teddy Smith is just one of hundreds of teachers, public school staff, parents and children who have been maliciously prosecuted by the corrupt New York City Board of Education-SCI-OSI-Corporation Counsel Complex. We ask that Joel Klein resign or that Mayor Michael Bloomberg fire him along with dissolving the offices of SCI, the Administrative Trials Unit (ATU) and OSI due to a pattern and practice of fabricating evidence and for violating the due process rights of New York City staff, parents and children who work in or attend NYC public schools. NYC at present has established no oversight or management for the investigation process, leading to a fraudulent free-for-all immunity from reprimand for NYC BOE administrators and principals. No one should be placed above the law. By Betsy Combier

Black’s Legal Dictionary defines “corruption” as:
An act done with an intent to give some advantage inconsistent with official duty and the rights of others. (p.345)

fraud” is described as:
An intentional perversion of truth for the purpose of inducing another in reliance upon it to part with some valuable thing belonging to him or to surrender a legal right. A false representation of a matter of fact, whether by words or by conduct, by false or misleading allegations, or by concealment of that which should have been disclosed, which deceives and is intended to deceive another so that he shall act upon it to his legal injury." (p. 660)

We are creating an online record of the battle between Theodore Smith, known as “Teddy”, and the New York City Board of Education (“NYC BOE” ) because the story is unfolding as the model of “rubberization” and as an example of how one teacher who was caught in the NYC BOE perfect storm of injustice is escaping the unjust punishment ‘they’ have in store for him. This ‘punishment’ consists of more than two years in a “rubber room” followed by, ‘they’ hope, termination for reporting that he was hired to teach physical education to 100 children in a gym at Manhattan’s Museum School that was not equipped with proper safety equipment during the 2004-2005 school year. The corrupt Richard Condon and his untrained attack dogs, the SCI investigators, couldn’t get a handle on how to end Teddy’s career (testimony at his 3020a hearing consistently spoke about what a caring man and a great teacher Teddy was) so they used an unproven, confidential conversation between Teddy and his former Attorney, David Kearney, to scathe Teddy, malign his character, and end his career. Condon issued a report on October 4, 2007 that stated Teddy threatened to kill his 3020a arbitrator Jack Tillem, according to his Attorney David Kearney. The allegation should never have made it into the press, but Condon went ahead anyway, exhibiting what I call an “arrogance of immunity”(see the 9/17/07 article about Condon published in The Black Star News) . The SCI office issued a press release on October 9, 2007 about this alleged threat, and both the Daily News and The Chief published the report without speaking with Teddy - who has always denied threatening to kill anyone.

Teddy’s new Attorney, William A. Gerard, wrote High School Superintendent Francesca Pena a brilliantly written letter on November 23, 2007, which highlighted the incompetence of the investigators, and the unethical conduct of David Kearney; below are some exerpts:

“the Arbitrator's contemporaneous notes of his conversation with Kearney on May 8, 2007 show that Kearney specifically told him that, Smith sent him an E-Mail denying he ever said any of those things.
SCI's apparent disregard of these internal contradictions and inconsistencies discloses an inexcusable lack of attention to the very details that are critical to the integrity of its findings. The report's conclusions are necessarily dependent on the truthfulness and accuracy of the statements of Kearney and Europe, yet SCI failed to notice or resolve these inconsistencies within its own report.

Failure to Investigate Facts

The SCI report is replete with obvious inconsistencies and inaccuracies, demonstrating a lack of investigational integrity that undermines the report's conclusions. The record shows that there was much valuable and reliable information that they either failed to pursue, or disregarded.
For instance, Mrs. Smith attended the SCI interview with Ted Smith on July 16, 2007, but SCI refused to interview her or even allow her in the interview room. This failure is inexplicable, considering that according to Kearney's affirmation, she was a party to the conversation during which the threats were allegedly made. As a result, the report's findings about Smith's threats appear to be based solely on Kearney's affirmation, since SCI did not interview Smith or his mother about that conversation, and the report does not quote anything said by Kearney on this subject during his SCI interview. As previously mentioned, Kearney's affirmation is demonstrably false, and it was supplied to SCI in the futile hope that a proper inquiry would confirm this. If SCI had been at all inclined to investigate the affirmation's allegations, they would have learned that this document does not provide viable support for their conclusions.
One of the stated grounds for Kearney's motion to be relieved as Smith's attorney in the Federal case against DOE is the claim that Smith violated the retainer agreement by failing to pay for the attorney's services. Although there was a written retainer agreement between Smith and Kearney's firm, it was a contingent fee agreement, awarding the attorney a percentage of the amount recovered in the Federal case, and it did not call for any payments to the lawyers. Kearney's demand for attorney's fees was instead based on the claim that Smith had orally agreed to pay an hourly rate for his representation in the disciplinary proceeding, however, Smith denies this, and an attorney is not permitted to enter such an arrangement with a client unless the agreement is in writing (see 22 NYCRR 1215.1).
Concerning when the alleged threats were actually made, Kearney's affirmation places them on March 23, 2007, during a conversation concerning the production of a character witness and Smith's failure to obtain certain medical records that were required in connection with proposed medical testimony. In actuality, that conversation occurred on March 8, 2007, because that is the day that the subject medical records were needed for the scheduled testimony of Smith's doctors, and that is also the day that the character witness testified. The transcript of the disciplinary hearing of March 8, 2007 confirms this, and quite remarkably, Kearney elicited testimony that day from the character
Witness that he had never heard Smith say the F-word in the twenty years he had known him. (Mr. Herb Robinson)
Considering that an attorney is ethically bound not to elicit sworn testimony that he knows to be false, incorrect or deliberately misleading, it defies reason to believe that several hours earlier on that same morning, Smith had engaged in a conversation with Kearney laced with the threats and profanities described in Kearney's affirmation. Under the circumstances, the conclusion is inescapable that Kearney is either lying about Smith's threats, or he is an unethical attorney who presented knowingly false testimony on March 8, 2007. In either case, the testimony provided by him in this matter must be viewed as inherently unreliable.
Kearney continued representing Smith, and his affirmation indicates that as the proceedings neared an end in the latter part of April, 2007, he wrote that "Smith refused to pay us anything for our time and efforts, and disclaimed any obligation to pay us for vindication of " (his) rights."
Kearney's complaints about this fee dispute were ignored by SCI, however, there is ample evidence that this dispute was the likely motivation for Kearney's revelations to the Arbitrator about Smith's alleged threats of two months earlier.”
(Gerard, pp. 5-7).

“After engaging in improper ex-parte discussions with the attorneys on May 8, 2007, a telephone conference was had on May 10, 2007, where the Arbitrator followed an agreed script, and recused himself on a pretext. The record shows that the Arbitrator and Kearney both followed the plan, however, the DOE attorney (Theresa Europe –Ed) unexpectedly insisted that the real reason be put on the record.
At this point, the attorneys and the Arbitrator left Smith holding on the phone for over a half an hour while they conferred on other lines about what to do. When they returned to the record, the Arbitrator confessed that his real reason for recusal, was that "as an ethical requirement of his profession" Smith's attorney had told him that Smith had made death threats against him, resulting in his unwillingness to continue as an arbitrator. (Ed: Kearney was clearly unhappy with Tillem's admission of the 'real' reason for his recusal).

The Arbitrator's willingness to engage in these ex-parte discussions, and to welcome the disclosure of confidential information from a conflicted attorney, led him to agree to falsify the record of the Arbitration proceeding by placing a fictitious ruling on the record. No greater misconduct exists for an Arbitrator, considering that it is his sworn duty as a Judge to insure that the proceedings are honest, fair and just. An. Arbitrator who shows the slightest inclination to engage in such conduct should be fired as an Arbitrator, and disbarred as an attorney.

CONCLUSION

It is abundantly clear that the SCI report is yet another self-serving document prepared by the DOE, and for the DOE, in order to assist them in their ongoing litigation with Smith. SCI reported Smith to the Police even before conducting the investigation, and the only purpose served by this report is to manufacture a basis to discharge Smith and resolve the pending cases.
Its conclusions about Smith are unsupported by the credible evidence, and its recommendations are utterly baseless and totally devoid of legal support. Under the circumstances, it should be disregarded and a decision should be reached that no further action is warranted.

Thank you for your courtesy and assistance.” (Gerard, pp. 18-19)

The entire letter to Ms. Pena dated November 23, 2007 is well worth reading, (as is the decision of Brooklyn Supreme Court Judge Yvonne Lewis, who also criticized the investigation of the allegations against Booker T. Washington MS 54 teacher Neil Lovinger: “Neil Lovinger, Former Teacher at Booker T. Washington, Sues and Wins”).
Former Principal Lindley “Lindy” Uehling told Teddy throughout the 2004-2005 school year that his job was to teach PE to the children, and NYC DOE Attorney Susan Jalowski said that teaching 100 kids in a class was not illegal (April 18 3020a transcript):

“The -- I don't believe there is an issue of
7 notice, the oversized classes, as we know, is
8 allowed by the contract…

11 MS. JALOWSKI: So, there's no
12 illegal oversized class and there was -- there
13 was an illegal lunchroom class. She had
14 open -- Ms. Uehling had allowed the kids to
15 have gym during lunch.” (Susan Jalowski, on the record)

Teddy testified that the program went on as is throughout the 2004-2005 school year. (April 18 record, p. 654).

Another lesson to be learned here is what not to do if you are an employee of the New York City Board of Education. The administrative trials unit of the NYC DOE and Attorneys Theresa Europe and Susan Jalowski, and 3020a arbitrator Howard Edelman are, it seems, in a quandary, now that their tale of incompetence, insubordination, and wrong-doing by Teddy, (as in allegedly threatening to kill his former 3020a arbitrator Jack Tillem), is proving to be as false as the professionalism and ethics of Mr. David Kearney, Teddy’s former Attorney.

Shakespeare wrote the following (exerpt from As You Like It 2/7): “All the world’s a stage, after all, and all the men and women merely players; They have their exits and their entrances; And one man in his time plays many parts…”

For purposes of this story, Teddy Smith started as a physical education teacher at The Museum School in Manhattan under Principal Lindley “Lindy” Uehling, in September 2004. He took the job because Principal Uehling promised him that he would get a job in the administration. Then, after he discovered that he was supposed to teach oversized classes up to 75 students in addition to the 100 students in the gym program to make up the 25 hours of teaching, he notified Principal Uehling in December 2004, and also notified Michael LaForgia and Peter Heaney at the District level, that he noticed unsafe conditions, and that he wanted a transfer. Teddy was not given a transfer, and Uehling continuously threatened him that the safety of the students was his responsibility, and also told him that if there was an accident it would be his fault. Teddy tried to do everything that he could to follow the directives of Uehling, but he continuously tried to resolve the safety issues, in vain. Thus, in December 2004 Teddy blew the whistle on the corruption and fraud being perpetrated by the NYC BOE, Special Commissioner of Investigation For the NYC School District Richard Condon, and Mr. Joel Klein, the CEO of the corporate entity known as the New York City Department of Education, Inc. He became a whistleblower as well as a victim of the collusion of the biggest local newspapers (The Daily News and The Chief) with the NYC BOE.

While at The International Whistleblower Conference in Washington DC in May 2008, I asked others in attendance how a person becomes a “whistleblower” and, does a person ‘become’ a whistleblower? Based upon our personal stories of speaking out about wrong-doing and the subsequent retaliation in our lives, we concluded that most people do not think about becoming a whistleblower, but simply are “bell-ringers of wrong-doing”, “truth-tellers”, or whatever you want to call someone who cannot be silent when he/she sees a situation or action that could potentially bring harm to another person. Teddy is just this kind of person. His concern was for the 100 children he was given to teach in an unsafe PE class, and he could not stay silent about the unsafe conditions at The Museum School during the 2004-2005 school year. He did not think of his own well-being, but placed the welfare of the kids in the school, first.

When Teddy was hired in September 2004, he was a 10-year tenured teacher with the NYCBOE who had never received a U rating or unsatisfactory observation. He has also taught at the after-school program at the United Nations for 13 years. On March 1 2007, the Director of the program, Virginia Olney, testified on Teddy's behalf that he was an excellent and caring teacher. His background is described in more detail in previous articles: “Theodore "Teddy" Smith Wins His NY State Supreme Court Appeal To Overturn Arbitrator Howard Edelman's 3020a Decision and Award”; NYC Rubber Room Reporter.

In the March 8, 2007 transcript of Teddy Smith’s 3020a hearing, his witness Mr. Nick Ragusa, who taught with Teddy 2-3 periods/day for two years at Chelsea High School 2002-2004, told arbitrator Jack Tillem for the record that Teddy was an excellent teacher and the kids loved him:

“A. I thought he was an excellent
8 teacher. I personally learned a lot from
9 working with him when it came to health issues
10 and exercises. And Mr. Smith had extensive
11 training in Marshall Arts and the kids looked
12 to him for that. Not that he bragged about it,
13 but you know, of course the kids find out. And
14 he was just a caring -- a caring man. He was
15 always there to help the students in the class.
16 He was always there to help me. He also did a
17 nice job with the junior varsity basketball,
18 which he did for two seasons; I'm the athletic
19 director.
20 I wish he was still at
21 Chelsea. I was very sorry to see him go.” (p. 578).

John Lachky, who was an Assistant Principal at the High School for Art and Design and worked with Teddy while he was there, testified:

“A. You know I'm not -- well,
16 I -- in general, yes. I remember I gave him a
17 very good obser -- a positive observation
18 report. He did -- as a matter of fact, I know
19 that he did a very good job for us --.
20 MS. JALOWSKI: Objection.” (Transcript of April 18, 2007, p. 695).

Victor Kurniaputra, a math teacher at the Museum School from February 2005, was told by Uehling to assist Teddy in the PE classes. He testified on March 8 as well that the Principal asked him to spy on Teddy, and come up with actions that she could give him an unsatisfactory rating “U” for:

“A. She would ask me about
15 details in Mr. Smith class and she is
16 particularly interested in subjects that finds
17 incriminating evidence for Mr. Smith…

A. She would ask if Ted Smith
23 did something that, you know, I don't like,
24 that feels wrong. (p. 591)

A. I told her that I'm -- I am
10 in the Museum School for teaching, not to be a
11 spy.
12 Q. And how did she react to
13 that?
14 A. She wasn't very happy about
15 it.” (p. 592)

Mr. Kurniaputra resigned in September 2005, even though Ms. Uehling was no longer Principal:

“Q. But Lindy wasn't -- wasn't
3 the principal in 2005, correct -- in September
4 of 2005.
5 A. No. He -- she told me that I
6 wouldn't be teaching there anymore because --
7 well, it was -- it was confusing really.
8 Q. So it's your opinion that
9 it -- is it your feeling that she just rated
10 you unsatisfactory because you wouldn't spy
11 on -- on Ted Smith?
12 A. Yes.
13 Q. It had nothing to do with
14 your ability as a math teacher?
15 A. No.” (p. 606)

Mr. Howard Edelman, in his decision, wrote that Mr. Kurniaputra’s testimony was not credible – even though he never heard it in person.

Teddy received an emailon January 29, 2005 (middle of the school year) from a woman by the name of Fay Pallen:

“You need to get the next letters written and in his file. In addition is Ramsey going to write? You cannot get him out this year to my understanding because he is tenured. You need 2 U annual performance reviews unless it is so dangerous that the safety of the students is in question and bypi must document that. Try to limit the time you spend on him. Fay”

In the stunning email, Ms. Pallen is giving advice to The Museum School Principal on how to get Teddy removed from his position. He believes she sent this email to him by accident. Suffice it to say here that Teddy Smith came to Principal Uehling as a tenured teacher with wonderful references and glowing recommendations, but was not liked as soon as he started asking why the classes he had were so oversized, and why there was insufficient safety equipment available for the kids. Two weeks after the start of school in September 2004 there was a leak in the roof of the gym, so Principal Uehling closed the gym for repairs. For the next 8 weeks Teddy had to find other rooms to provide the children the PE required. In November 2004 he told Uehling about his medical condition known as atrial fibrillation (AF or afib). This is a medical condition known to cause cardiac arrhythmia (abnormal heart rhythm) that involves the two upper chambers (atria) of the heart. Atrial fibrillation is often asymptomatic, and is not in itself generally life-threatening, but may result in palpitations, fainting, chest pain, or congestive heart failure.

As Principal Uehling gave Teddy an assistant only occasionally, his medical issue became problematic, especially since Uehling refused to give Teddy any accommodations, although he asked constantly. Uehling testified on February 8, 2007:

A. I discussed with him the
14 difficulty that -- that Ted Smith and I were
15 facing with these oversized classes and that I
16 was asking him a number of questions relative
17 to conducting phys ed. (p. 1014)

And, on p. 1169 line 13:
A. That was part of his job

p. 1170:
Q. And why -- did Mr. Smith, at
6 some point, tell you that he was unwilling to
7 teach a hundred students single-handedly, --
8 A. Yes.
9 Q. -- without assistants?
10 A. Yes.
11 Q. And you didn't accuse him at
12 that time of insubordination, did you?
13 A. No. I closed the gym.
14 Q. And you did that because
15 someone advised you that that wasn't proper;
16 isn't that a fact?
17 A. I did it because I no longer
18 had anyone to cover the gym.

In fact, the Principal and the NYC BOE decided to pursue Teddy for not treating the illegal venue as a robot would: provide PE to 100 children in an unsafe environment without concern for the safety and welfare of the students who possibly could be harmed while in the gym. Testimony of all of Teddy’s witnesses state for the record that he is a caring man, and that the kids love him for this. According to Teddy, Lindy Uehling confronted him daily at the school and threatened him about the safety of the students as his responsibility. Uehling also placed a letter in Teddy’s file every week and submitted student class rosters to the NYC DOE that had been downsized (she altered the roster for the class with 65 students and made it around 50).

Witness Marissa Russo Aragonez testified that she saw Teddy making xerox copies of his lesson plans to give to the Principal every Monday, and she thought this was very unusual. She had never heard of anyone having to do this. (March 20 2007 hearing).

The current state of affairs inside the NYC BOE star chamber is that high scores on tests, increases in numbers of students who graduate, and silence about wrong-doing (in violation of the mandated reporter policy) are the most important criteria for what “they” call ‘good’ teachers to focus on. Caring for students’ health, safety and welfare comes into play dead last, if at all. The Special Commissioner’s role is to enforce these priorities, even if it means to create false allegations and “facts” about a person, no matter what role this person plays at the school – teacher, secretary, paraprofessional, custodian, etc., it really doesn’t matter. SCI investigators, most of whom are retired from the NYC Police Department, are adept at “proving” that whatever the victim of a NYC BOE crime or error says, it is always not credible. Time and time again I have heard from teachers placed in temporary re-assignment centers, or “rubber rooms” that, after they told the SCI or OSI (Office of Special Investigations) investigators about an incident or crime, a few days or weeks later these same investigators come back to the school with the conclusion that the reporter of the wrong-doing is actually guilty of the crime.

This process is as old as time itself. There are countless reports of the ancient Greeks killing the messenger; we now call this “whistleblower retaliation”, and, thankfully, legislation is currently being written in Washington DC to prevent or stop this kind of “if you tell you’ll be sorry” practice. Most of us have come to realize that almost everyone who works in a job wants to keep working and making a salary; kids and parents often want to succeed in school, even if the “A” or “Level 3” score is bought or traded for false testimony and is not earned. People can, and do, trade honesty for rewards that meet an immediate need. The NYC BOE has fine-tuned this phenomenon into an art form, because the education business can suffer harmful financial consequences if the profits and results are not up to “par” (‘their’ standard, of course). No one who works in a public school in NYC is immune to the fear of failure that causes people to lie, cheat and steal in order to achieve even a false reality for Joel Klein and his cronies.

Please note as you read Teddy’s story that the SCI investigators claim that Teddy had threatened to kill arbitrator Jack Tillem, but during their investigation, Teddy says, THE INVESTIGATORS NEVER ASKED TEDDY WHETHER OR NOT HE ACTUALLY MADE THIS STATEMENT. Teddy wrote two emails to Theresa Europe, on May 10, 2007 and then sent an email on May 14 to Europe and Tillem to report that the alleged threats were false and he wanted to meet with an investigtor, but no one responded. On May 22 Teddy wrote to Mr. Richard Condon, also saying that the allegations about the threats were untrue, but Condon ignored him. See Condon’s report, p. 12:

“Conclusion and recommendations
Theodore Smith threatened the life of the arbitrator presiding over a disciplinary
proceeding against him. His attorney’s accounts of Smith’s threats are entirely credible;
Smith’s denials are the complete opposite.”

Following this conclusion dated October 4, 2007, Condon’s press office issued the press release on October 9 that both Carrie Melago at the Daily News and Richard Steier at The Chief picked up and published. If after David Kearney had released the information that Teddy had threatened to kill arbitrator Jack Tillem and he, Kearney, had really believed this, he should have immediately gone to the police or the Manhattan District Attorney. But he did not do that. Condon, in his report, wrote that he had “advised” the DA of the situation. Basically, no one believed the alleged threats were valid or true.

I suggest that the SCI investigators were so anxious to get Teddy’s character maligned that they could not allow that most important question to be asked…what if he told them “no, I never said that”? The case SCI hoped to build against Teddy would have been thrown out by this answer, so the strategy was not to ask whether or not the threat was made. We may never know the true motive, as no NYC BOE personnel is allowed to admit error in any situation.

Also, let’s not forget that conversations between an Attorney and his/her client are protected by the Attorney-Client Privilege. Wikipedia says this about Attorney-client privilege: “…a legal concept that protects communications between a client and his or her attorney and keeps those communications confidential. The policy underlying this privilege is that of encouraging open and honest communication between clients and attorneys, which is thought to promote obedience to law and reduce the chance of illegal behavior, whether intentional or inadvertent. As such, the attorney-client privilege is considered as one of the strongest privileges available under law. In regards to the attorney client privilege as applied to legal representation in pending judicial claims and defenses, the United States Supreme Court has ruled that the privilege generally does not terminate upon the client's death and continues on into perpetuit. Duties attendant to this privilege are directly connected to the attorney's duties of loyalty, competence, and due care to his clients. See Swidler & Berlin v. United States. …An attorney speaking publicly in regard to a client's personal business and private affairs can be reprimanded by the ABA and/or disbarred, regardless of the fact that he or she may be no longer representing the client. Airing of a client's or past client's dirty laundry is viewed as a breach of fiduciary responsibilities.”

David Kearney evidently wanted to end his representation of Teddy Smith, and thought that the easiest way to do that would be to tell a story that would be so outrageous as to make Teddy dismiss him, or he, Kearney, would be released from his obligations to Teddy because Teddy was insane, and a “psycho”. David couldn’t keep his erroneous “facts” straight, however. He gave different dates for Teddy making his threat: to Judge Buchwald in the US Federal Court, Second Circuit, (case 06 CV 4613) he said the threats were made on March 23, 2007; DOE Attorney Susan Jalowski said the date was May 2007 (October 1 transcript); to Tillem, it was April 12. Kearney also informed Jack Tillem and Richard Condon that Teddy was a “psycho” similar to Norman Bates in the movie “Psycho”. Kearney furthered his goal to have the NYC BOE and Mr. Tillem fearful of Teddy by stating on the record (and in a May 23, 2007 affidavit to Federal Judge Buchwald) that Teddy never went through security at the front door of 49-51 Chambers Street, where the 3020a hearings are held. Thus, Kearney was hoping all parties would believe that Teddy, being a “psycho,” could very well be bringing in the building a knife, meat cleaver or submachine gun. This is, of course, ridiculous, because Teddy has no "DOE" pass and always goes through security like everyone else. This could have been easily checked. His strategy worked. Mr. Tillem recused himself after citing the potential danger of being near Teddy, and second arbitrator Edelman did not give Teddy – represented by a new Attorney, Mr. Gerard – a new hearing. In Condon’s report there are notes written by Jack Tillem, who called DOE Attorney Theresa Europe on May 11, 2007:

“Europe telephoned Tillem and advised him of her conversation with Kearney. The arbitrator subsequently telephoned Kearney, and asked about his security request. Tillem and Kearney consistently testified at SCI that he replied, “There’s some information that I need to tell you.” Kearney then told Tillem of Smith’ s threat to har

 
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