June 18, 2009

(Via Certified and Regular Mail)

Jack Stoops, Board Chair

Willamette Education Service District
2611 Pringle Road SE
Salem, OR 97302

Re: Kathy Campbell Tort Claims Notice

Greetings:

Please be advised that this office represents Kathy Campbell with regards to her employment with
Willamette Education Service District ( “WESD ”). Ms. Campbell has claims against WESD and
its employees arising out of her employment.

Ms. Campbell has been employed by WESD since July 1, 2007 as the Director of Fiscal Services.
On or about October 6, 2008, she reported to Dave Novotney ( “Novotney”), Deputy
Superintendent, that she was concerned about the Regional backfill dollars WESD was collecting
from school districts, not expending for services, then holding the funds in the general fund. She
told him she found out this information from Jan Goerke ( “Goerke”), an Accounting Clerk in the
Business Office. Goerke told Ms. Campbell that she was going to be retiring soon, and she did not
want Ms. Campbell to be blamed for this. Ann O’Connell ( “O’Connell”) joined Novotney and
Ms. Campbell in her office, and Novotney asked O’Connell if this was true. She said “yes ” that
Maureen Casey ( “Casey ”), the superintendant, decided to assess additional charges to the school
districts even though the funds were not needed. Ms. Campbell asked her if that was what
happened in a meeting they attended in April 2008. She said that it was. Ms. Campbell said that
she recalled a meeting with Casey, Sue Foster ( “Foster ”), O’Connell, Goerke and herself. The
purpose of the meeting was to set the rates to charge school districts for the next year. Ms.
Campbell was invited as an observer, because she had not participated in this process previously.
Goerke and O’Connell told Casey that they did not need to increase the Regional backfill dollar
amount that districts contributed, because they had not even expended all of last year’s funds.
Casey said that they had to increase the contribution amount by at least 3% or it would look funny,
and the districts would ask questions. The amount was increased by 3%.
At the meeting in Ms. Campbell’s office with Novotney and O’Connell, Ms. Campbell told them
she believed this method was unethical; telling school districts they needed these funds to operate
programs when they really did not then using their funds to falsely inflate WESD’s ending fund
balance. He agreed and made a comment about something stinking around here. After O’Connell
left, he asked Ms. Campbell to set up a meeting with the auditors to get their advice on how to
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handle the situation. He told her not to put the meeting on her calendar and he would not either,
because he did not want Casey to find out. He said she would be very angry if she knew they were
doing this.
On or about October 13, 2008, O’Connell told Ms. Campbell she was facilitating a meeting on
October 10, 2008. Right before the meeting started, Casey approached her about the need for
WESD to be involved in Positive Behavior Services ( “PBS ”). O’Connell asked if she would be
able to have $25,000 from fund 698 to start the program. O’Connell said Casey became very
angry with her and told her in a loud strong voice that she could not have any of that money, and
she needed to forget about it. O’Connell told Ms. Campbell that she left the room crying.
On or about October 15, 2008, Ms. Campbell had a brief meeting with Casey and she said
O’Connell had asked her about using some funds for PBS from fund 698. She told Ms. Campbell
she was very stern and direct with O’Connell that she could not have any of the funds. She told
Ms. Campbell she was strong enough that she even got some tears out of her so hopefully she got
the message. She then asked Ms. Campbell how O’Connell found out about fund 698. Ms.
Campbell told her she did not know; maybe she had seen it on a financial report.
On or about November 3, 2008, Novotney and Ms. Campbell met with Brad Bingenheimer
( “Bingenheimer ”) of Boldt, Carlisle and Smith, LLC, WESD’s auditing firm. They shared their
concern regarding the Regional funds and ending fund balance inflation. He agreed the Regional
funds should not be co-mingled in the general fund unless they were reported separately. He could
not speak to the process of over-collecting Regional funds, but did believe those funds should be
reserved for districts and reported that way in the audit report. Novotney and Ms. Campbell agreed.
Novotney and Ms. Campbell discussed this after leaving BCS, and Novotney said he thought the
audit report would be a good way of addressing the over collecting of Regional funds and co-
mingling of funds. He was very concerned that Casey would find out they were questioning her
and appeared fearful of what her reaction might be.
Sometime during the first week of December 2008, Ms. Campbell met with Casey regarding
budgets. They discussed several different budgets, and Casey asked Ms. Campbell if she had any
concerns. Ms. Campbell told her she did regarding the Regional funds. Ms. Campbell told her
that she did not agree with them collecting funds from the school districts that they did not need and
holding them in the general fund without their permission. She became very angry with Ms.
Campbell and in a loud firm voice, while slapping the back of her hand to the other said, “you
don’t understand how things happen in an ESD. ” Casey quickly changed the subject, and Ms.
Campbell did not bring it up again at that time because of Casey’s extreme reaction.

On or about December 9, 2008, approximately five minutes prior to the start of a Board meeting,
Casey shoved the Annual Report in front of Ms. Campbell, said it was wrong, and that Ms.
Campbell needed to take all of the copies and white out the word “expense. ” Ms. Campbell told
her she did not think it was wrong, but if she wanted Ms. Campbell to do that, she would. She told
Ms. Campbell “yes ” she did and that Ms. Campbell needed to white-out the word in over 100
copies. Casey was very angry. This was very upsetting to Ms. Campbell, and she had to facilitate a
conference call with the Board and a consultant a few minutes later. Ms. Campbell was very
distraught, and it was difficult to concentrate on the task at hand after the conversation.
After the meeting, Ms. Campbell went to her office and gathered information to support how the
Annual Report information was created. Casey called Ms. Campbell to her office around 3:00 p.m.
to “discuss how to fix this report. ” Ms. Campbell entered her conference room and sat down.
Casey stood with the report in her hand, took off her glasses and in a loud angry voice said that she
almost took all of the reports and ripped the page out. She made an exaggerated ripping motion
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and threw the report on the table. She was red in the face and extremely angry. Ms. Campbell had
her information and told Casey she thought Casey was reading the wrong section. Casey continued
to disagree and argue with Ms. Campbell and slap the back of her hand onto the other several times.
Ms. Campbell continued to repeat her information. Casey was in such a rage she would not even
listen to Ms. Campbell. Ms. Campbell finally got up and took her documentation and spread it out
on the table. Ms. Campbell was shaking and had tears in her eyes. Ms. Campbell was frightened
by Casey’s anger as Ms. Campbell got closer to her to present the information. Ms. Campbell
decided to try and show her the information one last time and was going to leave if Casey continued
her rant. Casey finally sat down and took a look at the documents. She sat back and said, “oh,
okay, now I understand. ” She said Ms. Campbell did not need to make any changes, and Ms.
Campbell left.
During December 2008 and January 2009, Novotney and Ms. Campbell conversed on many
occasions about what Casey’s reaction may be when she read the audit report, and it showed the
Regional funds as “reserved. ” They were both nervous, and Ms. Campbell expressed a deep
concern to Novotney about Casey’s possible negative reaction, because Ms. Campbell had already
experienced negative interactions with her and knew that others had also. Ms. Campbell told him
she was actually afraid of how Casey may react especially after previous encounters with her.
During the week of December 29, 2008, Casey telephoned Ms. Campbell regarding a settlement
payment to be made to a former employee. She told Ms. Campbell to contact her before the
payment was made, and Casey may have an area the payment could be charged to.
On or about December 31, 2008, Ms. Campbell was in Lynda Olson’s ( “Olson ”) office and they
were preparing to create the purchase order for the settlement payment. Ms. Campbell told her she
would call Casey, because she said she may have an area to charge the payment to. Ms. Campbell
telephoned Casey on Olson’s phone with Olson present, and Casey told Ms. Campbell to check the
OMEP account. Ms. Campbell looked at a report and said, “Is that Fund 284?” Casey asked
what the balance was. Ms. Campbell told her approximately $28,000. Casey said, “Go ahead and
charge $20,000 to that account. ” Ms. Campbell asked her, “You mean the Oregon Mexico
Education Partnership Account?” Casey spoke very briskly with Ms. Campbell and was obviously
angry Ms. Campbell was questioning her. Casey said “yes, I feel perfectly fine doing that!
Charge $20,000 there! ” Ms. Campbell said “OK” and hung up. Ms. Campbell was afraid to
question her further. Ms. Campbell told Olson to charge the other $35,000 to the legal fees
account, which is where the entire amount should come from. Ms. Campbell found out later that
the revenue source for the OMEP account were federal funds. Ms. Campbell was appalled that
Casey would use these funds to pay for a completely unrelated legal settlement. Ms. Campbell
believes this is a violation of policy, rule, and law.
During the first few weeks of January 2009, Ms. Campbell met with Casey regarding budgets. Ms.
Campbell briefly mentioned to Casey her concern over the Regional funds and her concerns
regarding the co-mingling of funds. Ms. Campbell told her she had met with Northwest Regional
ESD, and they put their school district funds in a separate fund so they would not be co-mingled in
the general fund. Casey said, “We don’t want to do that! ” Ms. Campbell did not pursue the
conversation further due to Casey’s curtness.
On or about January 28, 2009, Ms. Campbell notified Novotney that she had gone to her doctor the
day before, and Ms. Campbell was going to be taking two weeks off for health reasons. Ms.
Campbell told him she did not want to tell Casey by herself, because she was afraid of Casey. He
said he understood and agreed to go with Ms. Campbell to meet with her. Casey was told of Ms.
Campbell’s leave, they discussed some arrangements, and Ms. Campbell left. Approximately
fifteen minutes later, Casey called Ms. Campbell and asked her to come back to Casey’s office.
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Ms. Campbell did as instructed, and Casey told Ms. Campbell they should talk without Novotney
present. Ms. Campbell was shaking and extremely anxious. Casey asked Ms. Campbell if she
wanted to share anything with her, or if Ms. Campbell felt there was anything she could not talk to
her about. Ms. Campbell was upset, started to tear up, and told her she really did not want to talk
right now. Casey repeated her question. Ms. Campbell told her she was not in the right frame of
mind right now, and it was not a good time to talk. Casey changed the subject for about three
minutes and said, “You know you can talk to me about anything. Is there anything you want to talk
to me about?” The pressure was intense and Ms. Campbell finally said to her that Ms. Campbell
felt there were issues she could not talk to her about. Casey asked her what those were. Ms.
Campbell said one was the Regional funds; whenever Ms. Campbell wanted to talk to her about
how these were handled Casey became angry and defensive with Ms. Campbell. Ms. Campbell
told Casey that she knew Ms. Campbell did not like how they were handled, but Casey would not
listen to Ms. Campbell. Casey told Ms. Campbell that Ms. Campbell thinks “too K-12 and not
enough like an ESD. You just don’t understand how it works. ” Ms. Campbell became too upset
and told her she needed to leave to get to a meeting.
Ms. Campbell returned from her leave on or about February 13, 2009. On or about February 16,
2009, Ms. Campbell told Novotney she was still extremely concerned about financial improprieties.
He asked Ms. Campbell if she would have lunch with him so they could meet away from the office.
When they met, Ms. Campbell asked him if the information regarding the co-mingling of funds and
ending fund balance reserves were presented at the Board meeting by Sue Foster while Ms.
Campbell was gone. He said “no, the ending fund balance was reported as one total of
approximately $1.9 million. ” He told Ms. Campbell he was concerned that the Board was not
properly informed. Ms. Campbell told him she was no longer comfortable presenting to the Board
unless they knew the actual financial standings of WESD. Ms. Campbell shared with him that she
felt she was deceived when she was hired, because she reviewed the financials of WESD and did
not know the funds were co-mingled. Ms. Campbell told him she believed the Board was also
being deceived by not knowing that information. He told Ms. Campbell he thought it was time to
meet with the Board Chair to disclose this information. Ms. Campbell agreed and he said he would
arrange a meeting.
On or about February 18, 2009, Novotney and Ms. Campbell met with Jack Stoops ( “Stoops ”) at
Denny’s Restaurant in Salem. Once again Novotney asked Ms. Campbell not to note the meeting
on her calendar. Novotney told Stoops that they were very concerned about some financial dealings
at WESD. Novotney had Ms. Campbell present a spreadsheet to Stoops showing the breakdown
of ending fund balance and the explanation of WESD withholding Regional funds in the general
fund. Ms. Campbell conveyed to Stoops that she had tried numerous times to have discussions
with Casey regarding these issues, but was received negatively and was fearful, because Casey was
very intimidating. Stoops asked Ms. Campbell if she was out for the two weeks due to stress. Ms.
Campbell told him she internalized stress and it caused back and joint pain. Ms. Campbell told him
the stressful situations she had been encountering made her have physical reactions. Stoops said he
was extremely concerned and assured Ms. Campbell he would look into these issues and would
consult legal counsel as to how to proceed. He told her she was doing the right thing and not to
worry about any retaliation for meeting with him. Ms. Campbell left and Novotney stayed to speak
with Stoops.
On or about the afternoon of February 18, 2009, Stoops telephoned Ms. Campbell to re-assure her
that her concerns would be addressed and to not worry about any retaliation. On or about February
19, 2009, Stoops telephoned Ms. Campbell to check in with her because he knew how upset she
was with this situation. He told Ms. Campbell not to worry and he would make sure there was no
retaliation for Ms. Campbell reporting this.
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On or about March 13, 2009, Casey, O’Connell and Ms. Campbell had a meeting regarding
budgets. Ms. Campbell once again voiced her concern over the Regional dollars that were being
held in the general fund. Casey became angry with Ms. Campbell again. Ms. Campbell was very
distraught and drafted an e-mail to Casey at 7:34 pm when Ms. Campbell was at home. The e-mail
once again addressed her concerns. On or about March 17, 2009, Stoops telephoned Ms.
Campbell again regarding her concerns. On or about March 18, 2009, Casey requested to meet
with Ms. Campbell. When Ms. Campbell came into her office, Casey pushed Ms. Campbell’s e-
mail that she had sent on March 13, 2009 to her. She asked Ms. Campbell in a very stern angry
voice, “what is this all about?” Ms. Campbell told her she wanted to make it clear that Ms.
Campbell supports the Regional program but not the way they are collecting unneeded funds and
holding them in the general fund to falsely boost up the balance. Ms. Campbell told her she did not
think the Board was aware of what their true ending fund balance was, and the District is not
reporting funds correctly. Casey told Ms. Campbell again, “you are too K-12 and don’t
understand how ESD’s operate. I disagree; I think the Board understands things better than you
think. You need to stop questioning this. ” Casey was so angry that Ms. Campbell just said
“fine. ” The subject was changed and Ms. Campbell left about three minutes later.
On or about April 3, 2009, Stoops telephoned Ms. Campbell to tell her they were arranging for Jim
Buck ( “Buck ”) to start an investigation. He said Buck was very good and he respected him
highly. He asked Ms. Campbell to let him or Novotney know if Casey put her in any
uncomfortable situations. Ms. Campbell asked him if Casey would be put on administrative leave
since there was an investigation underway. He told Ms. Campbell, “not at this time. ”
On or about April 13, 2009, Ms. Campbell met with Buck and provided him with information
regarding Regional funds, ending fund balance, OMEP/legal settlement charges, Fund 698
concerns and slot cost adjustment concerns. Ms. Campbell provided the following information to
Buck:
1. Regional funds: WESD has over-collected Regional backfill dollars without school district
permission and held some of the funds in the general fund. She told him that this was a
misuse of public funds.
2. General fund ending balance: Regional dollars have been held in the general fund to falsely
increase the ending fund balance. Leftover school district resolution funds are also held in
the general fund as well as school district grants. There has never been reporting to show
these funds are school district funds until the 2007-08 audit report. But, the verbal report of
the audit presented by Sue Foster did not note the reserved funds. The Board does not have
full knowledge of what is contained in the general fund. she told him that this was a misuse
and misrepresentation of public funds.
3. Fund 698: This fund was originally fund 278 and contained excess school district dollars.
Districts were charged for services and WESD either overcharged or somehow made
money off the transactions. The funds were eventually transferred over to fund 698. It has
been reported by Jan Goerke that these funds are now supporting the deficit in the 600
funds that was created by the Pentamation software debacle. She told him that this was a
misuse of public funds.
4. Oregon Mexico Education Partnership: There were federal funds received for this program.
They were not expended and carried over. They were not allowed to be carried over. They
were then used to pay a legal settlement that was not related to the program. She told him
that this was a misuse of federal funds.
5. Slot cost adjustment: School districts pay for certain programs based on the cost of a slot
for a student. In 2007-08 Woodburn school district was upset over the increase in their slot
costs. To make the Superintendent of Woodburn happy, Casey gave them a discretionary
$10,000 to reduce their costs. She told him that this was a misuse of public funds.
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6. In an unknown year transportation costs were double billed to school districts. Instead of
correcting the mistake, WESD kept the funds. She told him that this was a misuse of public
funds.

On or about April 13, 2009, Stoops telephoned Ms. Campbell to see how her interview with Buck
went. On or about April 22, 2009, Stoops telephoned Ms. Campbell and told her Buck would be
wrapping up his interviews and report soon. He told Ms. Campbell to hang in there and take care.
On or about April 23, 2009, Ms. Campbell filed a formal complaint regarding financial
improprieties and intimidation by Casey. Ms. Campbell gave the complaint to Novotney and told
him she felt she had to do this to protect herself. Ms. Campbell had brought her concerns to him in
the fall and had met with the Board Chair over two months ago, and she continued to be forced to
report to the Board, and meet with Casey regarding budgeting and finances even though Ms.
Campbell had reported improprieties. He said he would forward Ms. Campbell’s complaint to the
Board Chair and legal counsel.
On or about April 27, 2009, Novotney told O’Connell and Ms. Campbell that Casey was being
presented their complaints and said they should leave the building for a little while. O’Connell and
Ms. Campbell went to O’Connell’s home and worked from there. At approximately 3:15pm,
Stoops came to O’Connell’s residence and reported to them that Casey would not be placed on
administrative leave at that time. He told them that Ed Dodson ( “Dodson ”) was not taking their
complaints seriously and he said that Dodson thought O’Connell and Ms. Campbell were in
collusion together. Ms. Campbell reminded Stoops that she had spoke to him two months prior
regarding her financial concerns; well prior to any complaint from O’Connell. He said “oh, you’re
right, I had forgotten about that. ”
During the week of April 27, 2009, Novotney informed O’Connell and Ms. Campbell that Casey
would not be their supervisor, and he would be taking over that role. He also told them that the
Board had directed that they do not meet with Casey without him present. Ms. Campbell told
Novotney that she thought it was inappropriate that they were going to be meeting with their
component school districts to talk about their funding when there was an investigation in progress.
It was very upsetting to Ms. Campbell to meet with them and not be transparent at least about the
Regional funds. On or about April 28, 2009, meetings began with the school districts. Ms.
Campbell believed they were being forced to lie to school districts regarding Regional funds.
On or about April 29, 2009, an e-mail that was written by Casey and Foster was sent to
superintendents and business managers inviting them to an IDEA stimulus work session. Even
though Ms. Campbell’s name was signed to the bottom of the e-mail, she knew nothing of this
work session. Excluding Ms. Campbell on issues that were obviously business office issues was
retaliatory. This hurt Ms. Campbell’s credibility with school business managers, ODE officials,
and other stakeholders. Foster was established as the contact person rather than Ms. Campbell.
Foster was retired and no longer worked in the capacity of Business Director, yet she was given
authority to act as if she was.
On or about May 5, 2009, Ms. Campbell attended additional meetings with school districts. Ms.
Campbell was very uncomfortable, because she believed they were lying to the school districts
regarding Regional funds.
On or about May 4 or 5, 2009, during a meeting with Casey, Novotney and Ms. Campbell, Casey
began questioning Ms. Campbell about Regional funds. She asked how the budgets had been built
even though she had been provided this information previously. She acted like she never knew that
Regional funds from prior years had been held in the general fund. Novotney saw that Casey was
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trying to drive the conversation to clear her of any knowledge of the Regional funds being held, and
he interrupted and asked Ms. Campbell to leave the room. Ms. Campbell waited in the hall and
Novotney came to her about three minutes later. He took Ms. Campbell into the conference room
and Casey was no longer present. He said he told Casey this conversation was not appropriate, and
they would not discuss Regional funds any further. Ms. Campbell said “good, because she is just
trying to lie about it now. ” He said he understood. He brought Casey back in, and they spoke
briefly about other budgets and the meeting ended.
On or about May 5, 2009, Novotney shared with Ms. Campbell an e-mail Casey had sent him to set
up a meeting with Ms. Campbell to attempt to re-pay the districts for the Regional funds she had
been keeping over the years. Ms. Campbell told Novotney she would not participate in this
meeting, Casey knew this was part of Ms. Campbell’s complaint, and that this was exactly why
Casey should be on administrative leave. Ms. Campbell told him that Casey was being given the
opportunity to clean-up the areas of concern before the investigation was completed and that this
was absolutely wrong.
On or about May 5, 2009, Ms. Campbell telephoned Stoops and told him she could not take it
anymore, she was at the end of what she could take, and she felt like she was being forced to meet
with the school districts and not tell them the truth. Ms. Campbell also told him that Casey now
had enough information to try and cover up her wrongdoings, and as long as she was in the
capacity of Superintendent, and Ms. Campbell was forced to continue to meet with her, Casey was
able to pump Ms. Campbell for any and all information. He told Ms. Campbell over and over to
hang in there and something would happen soon. He told Ms. Campbell he knew this was very
hard on her, but he needed her to hang in there a little longer.
On or around the week of May11, 2009, Novotney shared with Ms. Campbell that he understood
through the investigation by Buck that there was a pattern of Casey ruling by fear and intimidation
and Buck commented it was a pattern repeated by several people over a period of time. He said it
was very compelling evidence to support O’Connell and Ms. Campbell’s complaints.
On or about May 20, 2009, Ms. Campbell spoke with Buck on the telephone. He wanted to clarify
that Ms. Campbell had not received an evaluation from Casey since Ms. Campbell worked there.
Ms. Campbell told him that was correct. He said Casey was saying that she did it but did not have
her secretary type it up. Ms. Campbell told him they never even met to complete it. Ms. Campbell
told him she needed to report that during a Cabinet meeting Casey tried to have Ms. Campbell keep
money in the general fund that belonged to another program. Ms. Campbell told him this was
exactly like Casey had done before. Buck asked Ms. Campbell, “Does Novotney not have enough
understanding of this to be able to stop this and say that it wouldn’t be in the best interest of the
districts?” Ms. Campbell told him that he was not willing to go up against her if he thought she
would remain in her position. Buck told Ms. Campbell that Casey did not really have any
legitimate argument for charging the legal settlement to the OMEP account. Buck also told Ms.
Campbell he had concerns regarding Casey’s abuse of power by placing retired employees in
unnecessary positions to support her, and he was going to report that it was a bad business practice.
Buck said he had almost wrapped up his report.
During the weeks of May 11 through May 22, 2009, five Cabinet meetings were scheduled.
Ordinarily there would only be two. The meetings consisted of continual discussions regarding
Regional funds and ending fund balance. During the Cabinet meeting on May 13, 2009, Casey
asked Ms. Campbell to not make the transfers to the Early Intervention fund from the general fund.
Ms. Campbell told her absolutely not. She said she would not be comfortable doing that at all. This
movement would have resulted in the exact situation as the Regional funds situation. This proved
that Casey was still being allowed to make financial decisions that are unethical and against policy,
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because she has not been placed on administrative leave. The Cabinet meeting on May 21, 2009 was
directly related to the ending fund balance. Ms. Campbell believed Casey was holding so many
frequent meetings regarding issues Ms. Campbell had concerns with to intentionally intimidate her,
harass her, and cause her stress. Ms. Campbell ended up taking Friday, May 22, 2009 off because
of the stress over these constant negative interactions. On May 21, 2009, Ms. Campbell spoke to
Novotney after the Cabinet meeting and informed him she was taking May 22, 2009 off due to the
stress.
On or about May 26, 2009, Ms. Campbell told Novotney she was not comfortable reviewing the
budget presentation with Casey. Ms. Campbell also told him she was uncomfortable doing the
presentation on Casey’s behalf at the budget meeting. Ms. Campbell told him she was being
forced into sacrificing her values and morals. It had already been told that there was a pattern of
Casey’s ruling by fear and intimidation, yet she was allowed to continue in her role and Ms.
Campbell was being forced to interact with Casey and create a budget with her knowing what Casey
had done. Ms. Campbell told him she was about to be insubordinate and refuse to do the budget
report.
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Later in the afternoon of May 28, 2009, Novotney came into Ms. Campbell’s office and said he
needed to speak to Ms. Campbell; that things had taken a turn. Ms. Campbell went to his office
and asked “turned which way?” He said “in your favor. ” He was very positive and upbeat. He
said that he, the Chair, and Vice Chair all read the investigation report. He said he was actually
going to tell Casey that he was very disappointed with what he read about her. The telephone rang
and it was Casey. He did not answer it and told Ms. Campbell he was going to be cutting down on
his communications with Casey, because she continually pumped him for information. The phone
rang again, and he answered it. It was Casey. She spoke for a moment and he responded that he
was not going to discuss it with her, and he would have to refer her to the Board Chair and hung up.
He them told Ms. Campbell that the Chair and Vice Chair would like Ms. Campbell to prepare the
budget presentation like she wanted to; with transparency and honesty regarding the ending fund
balance. He said they wanted her to educate the Budget Committee. He told Ms. Campbell to have
the presentation ready Friday afternoon for review. He said Casey would not be allowed to review
it or be in the process at all. Ms. Campbell told him she would get it ready and that finally they
were doing the right thing. He agreed.
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On or about May 29, 2009, Ms. Campbell had the presentation ready and left a copy of her
PowerPoint and narrative in Novotney’s office. He was in a meeting, so she called him around
6:00 pm to confirm he received the presentation. On or about June 1, 2009, shortly after Ms.
Campbell arrived in the office around 8:00 am, she was called to Novotney’s office. He told Ms.
Campbell that Stoops, Dodson, Greg Parker – the PR person, and WESD’s counsel had met on
Sunday and had some changes. He appeared upset, somber, and serious. He pulled out the copies
of her presentation. He told Ms. Campbell they wanted all of the slides reviewing the history and
transparency of the contents of the general fund to be removed. Ms. Campbell responded with,
“ What, why, they told me they wanted this done and wanted me to educate the committee. ” He said
he did not know what happened at the meeting yesterday, but everything had changed. He said Ms.
Campbell had until 9:30 am to make the changes, because Stoops and Dodson would be meeting
with Casey to have her review Ms. Campbell’s presentation. At that point, Ms. Campbell excused
herself and left all of her papers in Novotney’s office. Ms. Campbell went to her office and cried.
She was shaking and very upset. She called her husband and was very distraught. She then called
her doctor and made an appointment for that afternoon. Ms. Campbell went back to Novotney’s
office and he gave her the rest of the changes. Ms. Campbell made the changes by 9:30. He called
Ms. Campbell back into his office around 11:30. He said Stoops, Dodson, and Casey had met and
Casey had more changes. Ms. Campbell asked him, “why are they doing this?” He made a
sweeping action and Ms. Campbell said “sweeping it under the rug?” He nodded “yes. ” Ms.
Campbell told him she would get the changes done, and then she was leaving, because she had a
doctor’s appointment. He asked if Ms. Campbell would be coming back and giving the
presentation tomorrow. Ms. Campbell told him she did not know yet. He said he understood and
to please keep in touch. Ms. Campbell went to the doctor’s office and was placed on medical leave
which she is still on.
Ms. Campbell believes these actions were direct retaliation. Ms. Campbell feels this was done to
intentionally inflict her with emotional distress by forcing her to prepare an unethical budget
presentation.
On or about June 2, 2009, Ms. Campbell spoke to O’Connell by phone around 1:00pm.
O’Connell wanted to know how Ms. Campbell was and said Leslie Golden told her Ms. Campbell
was on leave. O’Connell said that she went to Novotney’s office and asked what was going on.
He told her Ms. Campbell had prepared her budget presentation according to the Board’s request,
had worked on it all weekend, then came in Monday and they changed it all on her. He told her
Ms. Campbell went to the doctor and was put on leave. O’Connell asked who would do the budget
presentation, and he said Casey. She said, “you’re kidding, what about the investigation. ” He said
the results of the investigation were very positive and in Ms. Campbell’s favor, and he has begged
the Board to communicate with O’Connell and Ms. Campbell. He told her they wanted to wait
until the budget process was complete, and then until the legislature was done and then they were
trying to decide whether or not to weave the complaints into Casey’s evaluation. He also told her
they were worried Ms. Campbell would bring a whistleblower claim.
While Ms. Campbell has been on medical leave, she has received regular telephone calls from
WESD asking her business related questions.
Ms. Campbell has been retaliated against for reporting fiscal improprieties of public and federal
funds on the part of WESD and Casey. She has been subjected to repeated retaliation, both alone
and in the presence of others, because of her whistleblowing activities. She has been intimidated by
Casey as well as the Board and legal counsel for the Board. Casey has abused her power
repeatedly during these interactions by intimidating and creating fear. Even though Ms. Campbell
was told that an investigation substantiated her claims, the Board decided to delay the process to
Kathy
Campbell
Tort
Claims
Notice

June
19,
2009

Page
10



mitigate exposure to WESD. They have decided to wait until the budget process and legislative
process is complete. The actions of WESD discouraged, restrained, dissuaded, coerced, and
otherwise interfered with Ms. Campbell’s whistleblowing disclosures.

ORS 30.275 provides that “No action arising from any act or omission of a public body or officer,
employee or agent of a public body within the scope of ORS 30.260 to 30.300 shall be maintained
unless notice of claim is given... ” Pursuant to ORS 30.275, please consider this letter as a formal
notice that Kathy Campbell intends to file a civil action for damages against the WESD including
one or more of its employees. This letter puts WESD on notice of monetary claims that may be
asserted against it in connection with any action it has taken contained within this letter or matters
reasonably related thereto.

This matter is still under investigation by my office and additional investigation may yield additional
facts and claims, as we may have been unable to obtain all the relevant facts on this matter at the
time of the drafting of this notice. Accordingly, my client’s potential claims are not limited to the
claims listed in this tort claims notice. The above facts and claims are set forth for the purposes of
this tort claims notice. These facts and claims are intended to be construed as broadly as possible.
It is intended to encompass all possible claims and to give notice that my client intends to file a civil
action.

Any correspondence regarding this matter should be directed to Larry L. Linder, 2245 Commercial
Street NE, Salem, Oregon 97303.

Sincerely,

Law Office of Larry L. Linder

Larry L. Linder
cc: Kathy Campbell