comments received on board policy boa, legal … · comments received on board policy boa, legal...

COMMENTS RECEIVED ON BOARD POLICY BOA, LEGAL SERVICES

BETWEEN NOVEMBER 12, 2019, AND JANUARY 12, 20201

Entry Id Comment on draft Board Policy BOA. Name Last

1 COMMENT WAS INTENDED FOR POLICY JEE and was included with those comments

2

I absolutely do not support the changes to this document. The BOE needs less power and not more. The document should remain as is. My tax money

should not need to fill your agenda of protecting yourselves on your reckless decisions. Allison Cullinane

3

The outside counsel hired by the BOE in special education matters must at all times treat families with respect and dignity. Outside counsel in special

education matters will insist on strict compliance with IDEA and refuse to take any action which will harm the student. Outside counsel will not insult,

disparage, or hire private investigators to invade the privacy of special education families. Lyda Astrove

4

I object to the suggested amendments expanding the scope of the BOE to retain expensive outside legal counsel at their own discretion and without the

consent and oversight of the tax paying residents of Montgomery county. Stella Koutros

5

I am a voter and believe that this policy re-write allowing unreported legal representation only serves Board Members' interests--NOT the public's. In line's

17 and 18 of the draft policy, things couldn't be more clear--the proposal is to strike "cost control and accountability"; the policy mentions cost-

effectiveness, but accountability, which is necessary for any democracy, is wholesale removed. As a taxpayer, this is unacceptable and should not be

allowed to stand. As far as I can tell, Rebecca Smodrowski is the only member who should be re-elected at this point. Tom Koval

6

A shift to costly outside counsel does not match up with the goal to be cost efficient. Board should continue to use county general counsel, rather than

spend education dollars on outside lawyers. John Seabreeze

7

I object to the BOE retaining counsel in secret, hiring expensive lawyers, and disenfranchising Montgomery County residents. You are elected by me and

are supposed to represent me, yet your actions are not taking my considerations into effect. Sharon Morris

8

I am absolutely against this action. I object to them retaining counsel in secret, hiring expensive lawyers, and disenfranchising Montgomery County

residents from relief in the courts. Ryan Worch

9 I object to the BOA retaining counsel in secret, hiring expensive lawyers, and disenfranchising Montgomery County residents from relief in the courts. Rose DeWitt

10

I object to the BOE retaining counsel in secret, hiring expensive lawyers, and disenfranchising Montgomery County residents from relief in the courts. I find

that BOE Members would be betraying the public trust if they were allowed to: 1. retain legal counsel without having to report it to the public. 2. engage

top-tier law firms for representation without the need for approval from the Superintendent. 3. settle disputes through arbitration and mediation instead

of a court of law, a change that would provide a substantial advantage to the Board. Gevorg Adamyan

11

I don't understand why a BOE member would need to retain outside legal counsel without notifying the public. Would this be at the taxpayer's expense?

Are there not competent attorneys within MCPS that can be utilized if necessary? I am opposed to any additional expenses that would be incurred in order

for BOE to retain legal services without the public's knowledge or approval. Lissa Levin

12

Board Members must report the retention of legal counsel to the public. The superintendent's approval must be required for a Board Member to engage

top-tier law firms for representation. No dispute settlement through arbitration and mediation instead of a court of law. This change would provide a

substantial an unfair advantage to the Board. Suzanne Thorpe



13

I strongly object to the BoE retaining counsel in secret, hiring expensive lawyers, and disenfranchising Montgomery County residents from relief in the

courts. Lin Qiu

14

This is totally nonsense and wasting tax payers' money. You should do your job well if you still want to be part of MOCO education system, and not asking

lawyers to cover your sloppy work. K D

15

I disagree with the need to hire outside counsel by the BOA, just because, beyond the legal services that the general counsel can provide. Why does the

BOA need this now? Is there any precedent for this?. Given that this external counsel is to be paid by taxpayers, If there is a real need for this external

counsel, then the specific reasons should be laid out in a case by case basis. If there are litigations in place or if the BOA is planning to initiate or defend

from litigations, they should be disclosed for this request. Sincerely, Damian Damian Kovalovsky

16

As a mother of young children preparing to move back to Montgomery County after years living abroad (a decision taken as a consequence of the illness of

my mother, a 44-year county resident), I have been alarmed by reports of the BoE’s recent efforts to avoid transparency and accountability in relation to

their interactions with county parents. Reading the proposed amendment to rules on engaging counsel, it is hard to construe this as anything other than a

further bid to avoid public accountability. This frankly leaves me ashamed of the civil servants allegedly working on behalf of my mother and father’s - and

soon to be my own — community. This is not the BoE whose meetings my mom used to attend when my siblings and I were children. Laura Beers

17

Thank you for the opportunity to comment on this proposed amendment to Policy BOA. As a member of the legal community, it is unclear to me that

current Policy BOA prevents MCPS and the BOE to obtain access to quality counsel, as is the case under current Policy BOA. Moreover, current Policy BOA

permits the BOE and MCPS to direct counsel to meet existing and future legal needs, defend its interests through litigation and to provide thoughtful legal

advice. Accordingly, there appears no need to amend this policy. While it is understandable to seek counsel that represents the interests and needs of the

BOE and MCPS, I do not see any reason to amend the current Policy. If the BOE or MCPS believes that it needs to change counsel, it has every ability to do

so under current policy. If, on the other hand, this change in policy is intended to provide additional support or otherwise provide additional means to

support recently amended Policy FAA or the ongoing boundary analysis, given the strong concerns raised by the community regarding BOE actions, it

would be inappropriate to amend this policy as a means to lay the foundation to engage new legal counsel whose primary purpose is to defend that policy.

Under such circumstances, it would be reasonable for the community to feel further marginalized and would demonstrate that the BOE had reached

decisions regarding boundary adjustments without having the benefit of the much anticipated boundary study. I urge the BOE to pause amendments to

policies that may be implicated by the boundary adjustment studies presently underway. Jonathan Sambur

18

A public report on the amount of money spent for outside counsel to pursue special education-related litigation should be provided at least quarterly.

Because costs for outside legal counsel are to be presented to the Board anyway, making the info publicly available does not require additional resources

and promotes transparency in the use of taxpayer resources to litigate special ed-related claims. If that info is already made publicly available, committing

to do so in the policy would be an important marker that it will continue to be so. Karen Shimp



19

Why does the Board and the Superintendent need both general counsel and outside counsel? The policy should specify the very limited circumstances

under which outside counsel would be warranted (i.e., litigation). Otherwise there will be no checks in place to ensure that taxpayer dollars are not spent

frivolously to allow Board members to “lawyer up”. Lydie Harris

20

I think the new policy is lacking transparency to the public. As a public entity, the BOE has to disclose to the public as to why they are getting council. It

creates an image as they have something to hide. I STRONGLY disagree with the BOE allowing to have all disputes resolved through mediation or

arbitration. We also have the right to know costs. Private citizens can do what they want, not a board that was appointed by citizens. It takes away all

transparency and takes away public equality. I also disagree that the highest and most expensive legal team can be acquired without public consent or

knowledge. My comment is to revert back to the original Language. Jen Dragone

21

I don't agree with the change in this policy. MCPS regularly wastes millions of dollars on outside legal counsel and over the past 5 years it has bulked up its

legal department so I am firmly against this change in policy. MCPS needs to stop wasting Montgomery County tax payer dollars for mega law firms that rip

off taxpayers. Brad Shear

22

Legal costs tend to be difficult to manage and there should be a risk assessment cited associated that would serve to rationalize cash expenditure. So if it

costs more to litigate, this should be assessed at the onset of the planning, and alternate methods of settlement should be adopted. Rich Klotz

23

The role of the Board of Education is to serve the needs of every family in Montgomery County, not its own interests or a specific segment of the

community. Today there are several families that do not support the idea of “bus in, bus out” because of the hardship it could impose in terms of time and

resource allocation. It seems contradictory that tax payer money would be used to back something that the pubic does not support or has not reached a

conclusion about. Use of outside counsel should be limited and transparent, so that the public is fully informed on how its money is spent. The Board of

Education should be restrained from using taxpayer money and should do so only if it is deemed absolutely necessary, and only as a last resort. In order to

be accountable, the Board of Education needs to be completely transparent in how taxpayer money is being spent. Most importantly, the public should

have a say in deciding can be spent on outside lawyers. To achieve this, the public should be consulted every year and have the opportunity to vote on how

much of the Board’s annual budget can be used. To save cost, when possible, the Board of Education should try to use a government agency lawyer before

seeking outside counsel. Tzuwei Chou

24

I strongly object to you retaining legal counsel in secret, hiring expensive lawyers, and disenfranchising residents from relief in the courts. This is

frighteningly un-democratic. Geri Niebauer



25

I strongly object to the language "In consultation and collaboration with the Board, the superintendent of schools, and other authorized administrators of

the school district, the general counsel of MCPS shall be responsible for overall management of legal services." Public officials should be accountable for

decisions about legal services. Language should be included requiring explicit approval and oversight by the Superintendent of Schools. - I strongly object

to the language "Conducting and supervising all aspects of litigation and administrative agency proceedings in which the Board, superintendent of schools,

or other staff acting in the course of their duties for MCPS are named as plaintiffs or defendants, including but not limited to legal support for special

education proceedings, consistent with Board Policy BLC, Procedures for Review and Resolution of Special Education Disputes." This does not offer the

public sufficient protection from having to finance the defense of public officials acting irresponsibly, unethically, with malfeasance, or in any other manner

that does not serve the public good. The public has a right to pursue legal action against officials in these cases without the secondary harm of having to

pay for their defense. This language should be replaced with language stating no county funds will be used for legal action where the Board,

superintendent or any staff are acting as plaintiffs. The revisions should include a clause stating that no county funds will be used in legal action where the

Board, superintendent or staff is accused of acting in a manner that is against the public interest. - I strongly object to the language "The factors to be

considered in the selection or retention of an attorney as outside counsel include the quality of the attorney’s work, background and relevant experience,

legal skills, commitment to diversity and equity, responsiveness and sensitivity to the client’s needs, style and presence, freedom from conflict of interest,

and management skills." These factors are purely qualitative and no reasonable evaluation metric exists to evaluate them relative to other counsel, such as

billable rates, costs related to travel / supplies / logistics, and other demonstrable factors. This language should be replaced with language emphasizing

cost efficiency, effectiveness and subject matter expertise of counsel, in keeping the spirit of "efficient and effective" management mentioned elsewhere in

this document. - I strongly object to the language "The Board will contract with the attorneys or firms selected to serve as outside counsel, subject to

renewal." Maintaining continuous, ongoing relationships with outside counsel should be limited in scope to routine matters such as land use and not

applied broadly to every legal matter the Board of Education may face. This policy should prohibit outside counsel from being retained on a continuous

basis for the defense of members of the Board of Education. - I strongly object to the proposed policy in whole and encourage the Board to continue

operating according to existing policy, with the addition of language that the General Counsel will work under the direct oversight of the Superintendent of

Schools Gordon Groisser

26

I strongly object to the language "The Board will contract with the attorneys or firms selected to serve as outside counsel, subject to renewal." Maintaining

continuous, ongoing relationships with outside counsel should be limited in scope to routine matters such as land use and not applied broadly to every

legal matter the Board of Education may face. This policy should prohibit outside counsel from being retained on a continuous basis for the defense of

members of the Board of Education. Aarti kahtri



27

I strongly object to the language "and engage in strategic decision making to promote equity and academic excellence for all students." Proscribing a

specific course of action for how Legal Services will be used is inconsistent with the goals of ensuring efficient and effective management of resources. This

language should be removed. - I strongly object to the language "In consultation and collaboration with the Board, the superintendent of schools, and

other authorized administrators of the school district, the general counsel of MCPS shall be responsible for overall management of legal services." Public

officials should be accountable for decisions about legal services. Language should be included requiring explicit approval and oversight by the

Superintendent of Schools. - I strongly object to the language "Conducting and supervising all aspects of litigation and administrative agency proceedings

in which the Board, superintendent of schools, or other staff acting in the course of their duties for MCPS are named as plaintiffs or defendants, including

but not limited to legal support for special education proceedings, consistent with Board Policy BLC, Procedures for Review and Resolution of Special

Education Disputes." This does not offer the public sufficient protection from having to finance the defense of public officials acting irresponsibly,

unethically, with malfeasance, or in any other manner that does not serve the public good. The public has a right to pursue legal action against officials in

these cases without the secondary harm of having to pay for their defense. This language should be replaced with language stating no county funds will be

used for legal action where the Board, superintendent or any staff are acting as plaintiffs. The revisions should include a clause stating that no county funds

will be used in legal action where the Board, superintendent or staff is accused of acting in a manner that is against the public interest. - I strongly object

to the language "The factors to be considered in the selection or retention of an attorney as outside counsel include the quality of the attorney’s work,

background and relevant experience, legal skills, commitment to diversity and equity, responsiveness and sensitivity to the client’s needs, style and

presence, freedom from conflict of interest, and management skills." These factors are purely qualitative and no reasonable evaluation metric exists to

evaluate them relative to other counsel, such as billable rates, costs related to travel / supplies / logistics, and other demonstrable factors. This language

should be replaced with language emphasizing cost efficiency, effectiveness and subject matter expertise of counsel, in keeping the spirit of "efficient and

effective" management mentioned elsewhere in this document. - I strongly object to the language "The Board will contract with the attorneys or firms

selected to serve as outside counsel, subject to renewal." Maintaining continuous, ongoing relationships with outside counsel should be limited in scope to

routine matters such as land use and not applied broadly to every legal matter the Board of Education may face. This policy should prohibit outside counsel

from being retained on a continuous basis for the defense of members of the Board of Education. - I strongly object to the proposed policy in whole and

encourage the Board to continue operating according to existing policy, with the addition of language that the General Counsel will work under the direct

oversight of the Superintendent of Schools. Staci Sfondouris



28
























oversight of the Superintendent of Schools. Tassos Sfondouris

29 No school redistricting! Preserve the current borders! Raisa Ionin



30

Have you all lost your minds? One bad proposal after another. I strongly object to the language "The Board will contract with the attorneys or firms



from being retained on a continuous basis for the defense of members of the Board of Education. It might be time for all board members to resign and call

new elections. I have never seen such a divisive and erratic board in my lifetime. Michael Cavey

31

- I strongly object to the proposed policy in whole and encourage the Board to continue operating according to existing policy, with the addition of

language that the General Counsel will work under the direct oversight of the Superintendent of Schools. Specifically, - I strongly object to the language

"and engage in strategic decision making to promote equity and academic excellence for all students." Proscribing a specific course of action for how Legal

Services will be used is inconsistent with the goals of ensuring efficient and effective management of resources. This language should be removed. - I

strongly object to the language "In consultation and collaboration with the Board, the superintendent of schools, and other authorized administrators of


decisions about legal services. Language should be included requiring explicit approval and oversight by the Superintendent of Schools. Ryan Worch



32

Dear BOE, Thank you for the opportunity submit comments on the proposed amendments. Before I dive in into specific objections, I would like to state

from the start that I strongly object to the proposed policy in whole and encourage the Board to continue operating according to existing policy. In

addition to my overall opposition, I would like to highlight specific issues with the following specific provisions: "and engage in strategic decision making

to promote equity and academic excellence for all students." Proscribing a specific course of action for how Legal Services will be used is inconsistent with

the goals of ensuring efficient and effective management of resources. This language should be removed. - "In consultation and collaboration with the

Board, the superintendent of schools, and other authorized administrators of the school district, the general counsel of MCPS shall be responsible for

overall management of legal services." Public officials should be accountable for decisions about legal services. Language should be included requiring

explicit approval and oversight by the Superintendent of Schools. - "Conducting and supervising all aspects of litigation and administrative agency

proceedings in which the Board, superintendent of schools, or other staff acting in the course of their duties for MCPS are named as plaintiffs or

defendants, including but not limited to legal support for special education proceedings, consistent with Board Policy BLC, Procedures for Review and

Resolution of Special Education Disputes." This does not offer the public sufficient protection from having to finance the defense of public officials acting

irresponsibly, unethically, with malfeasance, or in any other manner that does not serve the public good. The public has a right to pursue legal action

against officials in these cases without the secondary harm of having to pay for their defense. This language should be replaced with language stating no

county funds will be used for legal action where the Board, superintendent or any staff are acting as plaintiffs. The revisions should include a clause stating

that no county funds will be used in legal action where the Board, superintendent or staff is accused of acting in a manner that is against the public

interest. - "The factors to be considered in the selection or retention of an attorney as outside counsel include the quality of the attorney’s work,





effective" management mentioned elsewhere in this document. - "The Board will contract with the attorneys or firms selected to serve as outside counsel,

subject to renewal." This policy should prohibit outside counsel from being retained on a continuous basis for the defense of members of the Board of

Education. I would like to again reinstate my overall opposition to any changes. Thank you for your consideration. Best, Michaela Chen Michaela Chen



33













will be used in legal action where the Board, superintendent or staff is accused of acting in a manner that is against the public interest. - I strongly object to

the language "The factors to be considered in the selection or retention of an attorney as outside counsel include the quality of the attorney’s work,










oversight of the Superintendent of Schools. Paige Rosenfeld



34

MoCo Residents: The BOE is currently proposing a policy allowing them to hire the most expensive law firms in the US with no oversight from the Superintendent or public transparency about

who is being retained or how much it costs. It really doesn't matter how you feel about redistricting, it's bad policy to give BOE members a blank check to take county residents to court. I

strongly object to the language "and engage in strategic decision making to promote equity and academic excellence for all students." Proscribing a specific course of action for how Legal

Services will be used is inconsistent with the goals of ensuring efficient and effective management of resources. This language should be removed. I also strongly object to the language "In

consultation and collaboration with the Board, the superintendent of schools, and other authorized administrators of the school district, the general counsel of MCPS shall be responsible for

overall management of legal services." Public officials should be accountable for decisions about legal services. Language should be included requiring explicit approval and oversight by the

Superintendent of Schools. I strongly object to the language "Conducting and supervising all aspects of litigation and administrative agency proceedings in which the Board, superintendent of

schools, or other staff acting in the course of their duties for MCPS are named as plaintiffs or defendants, including but not limited to legal support for special education proceedings,

consistent with Board Policy BLC, Procedures for Review and Resolution of Special Education Disputes." This does not offer the public sufficient protection from having to finance the defense

of public officials acting irresponsibly, unethically, with malfeasance, or in any other manner that does not serve the public good. The public has a right to pursue legal action against officials in

these cases without the secondary harm of having to pay for their defense. This language should be replaced with language stating no county funds will be used for legal action where the

Board, superintendent or any staff are acting as plaintiffs. The revisions should include a clause stating that no county funds will be used in legal action where the Board, superintendent or

staff is accused of acting in a manner that is against the public interest. Furthermore, I strongly object to the language "The factors to be considered in the selection or retention of an

attorney as outside counsel include the quality of the attorney’s work, background and relevant experience, legal skills, commitment to diversity and equity, responsiveness and sensitivity to

the client’s needs, style and presence, freedom from conflict of interest, and management skills." These factors are purely qualitative and no reasonable evaluation metric exists to evaluate

them relative to other counsel, such as billable rates, costs related to travel / supplies / logistics, and other demonstrable factors. This language should be replaced with language emphasizing

cost efficiency, effectiveness and subject matter expertise of counsel, in keeping the spirit of "efficient and effective" management mentioned elsewhere in this document. I strongly object

to the language "The Board will contract with the attorneys or firms selected to serve as outside counsel, subject to renewal." Maintaining continuous, ongoing relationships with outside

counsel should be limited in scope to routine matters such as land use and not applied broadly to every legal matter the Board of Education may face. This policy should prohibit outside

counsel from being retained on a continuous basis for the defense of members of the Board of Education. I strongly object to the proposed policy in whole and encourage the Board to

continue operating according to existing policy, with the addition of language that the General Counsel will work under the direct oversight of the Superintendent of Schools. MELISSA KING



35

- I strongly object to the language "and engage in strategic decision making to promote equity and academic excellence for all students." Proscribing a























oversight of the Superintendent of Schools. Leping Wallace



36

I strongly object to the language "The factors to be considered in the selection or retention of an attorney as outside counsel include the quality of the

attorney’s work, background and relevant experience, legal skills, commitment to diversity and equity, responsiveness and sensitivity to the client’s needs,

style and presence, freedom from conflict of interest, and management skills." These factors are purely qualitative and no reasonable evaluation metric

exists to evaluate them relative to other counsel, such as billable rates, costs related to travel / supplies / logistics, and other demonstrable factors. This

language should be replaced with language emphasizing cost efficiency, effectiveness and subject matter expertise of counsel, in keeping the spirit of

"efficient and effective" management mentioned elsewhere in this document. Jing Wang



37
























oversight of the Superintendent of Schools. Tanya Mazin

38 COMMENT WAS INTENDED FOR POLICY JEE and was included with those comments



39

I strongly suggest a public hearing on this issue and I strongly object to the language "Conducting and supervising all aspects of litigation and administrative

agency proceedings in which the Board, superintendent of schools, or other staff acting in the course of their duties for MCPS are named as plaintiffs or







interest. Chen Lai

40

I strongly object to the proposed policy in whole and encourage the Board to continue operating according to existing policy, with the addition of language

that the General Counsel will work under the direct oversight of the Superintendent of Schools. Lilian Cheng

41

I strongly encourage the Board to continue operating according to existing policy, with the addition of language that the General Counsel will work under

the direct oversight of the Superintendent of Schools. Ziching Lai



42
























oversight of the Superintendent of Schools. Xiangji Wang

43

I strongly object to the language "The Board will contract with the attorneys or firms selected to serve as outside counsel, subject to renewal." Maintaining

continuous, ongoing relationships with outside counsel should be limited in scope to routine matters such as land use and not applied broadly to every

legal matter the Board of Education may face. This policy should prohibit outside counsel from being retained on a continuous basis for the defense of

members of the Board of Education. MINGJIANGXU



44

I strongly object to the language "Conducting and supervising all aspects of litigation and administrative agency proceedings in which the Board,

superintendent of schools, or other staff acting in the course of their duties for MCPS are named as plaintiffs or defendants, including but not limited to

legal support for special education proceedings, consistent with Board Policy BLC, Procedures for Review and Resolution of Special Education Disputes. Jing Hu

45
























oversight of the Superintendent of Schools. Melanie Summers



46



legal support for special education proceedings, consistent with Board Policy BLC, Procedures for Review and Resolution of Special Education Disputes."

This does not offer the public sufficient protection from having to finance the defense of public officials acting irresponsibly, unethically, with malfeasance,

or in any other manner that does not serve the public good. The public has a right to pursue legal action against officials in these cases without the

secondary harm of having to pay for their defense. This language should be replaced with language stating no county funds will be used for legal action

where the Board, superintendent or any staff are acting as plaintiffs. The revisions should include a clause stating that no county funds will be used in legal

action where the Board, superintendent or staff is accused of acting in a manner that is against the public interest. Wendy Gaona



47

I have serious concerns and strong objections to the following language: - "and engage in strategic decision making to promote equity and academic

excellence for all students". This pre-defines a specific course of action about how Legal Services will be used. It goes against the goals of ensuring efficient

and effective resource management. This language should be removed. - "In consultation and collaboration with the Board, the superintendent of schools,

and other authorized administrators of the school district, the general counsel of MCPS shall be responsible for overall management of legal services." All

elected and other public officials should be held accountable for their decisions regarding legal services. Language should be added to clarify what

accountability mechanisms are in place. - "Conducting and supervising all aspects of litigation and administrative agency proceedings in which the Board,



This language is problematic. In cases where public officials engage in unethically, irresponsible, or wrongful actions, or act in any other manner that does

not serve the public good, the public should be afforded sufficient protection from having to finance the defense of. It is a right of the public to take legal

action against officials in these cases without having to pay for their defense. Otherwise, the public would be harmed twice—once by the officials’ actions

and again by paying to defend their acts. This language should be removed. And, language should be added to make it clear that no county funds will be

used for legal action where the Board, superintendent, or any staff are acting as plaintiffs. The revised policy should include language stating that no county

funds can be used in legal action where the Board, superintendent or staff is accused of acting in a manner that is against the public interest. - "The factors

to be considered in the selection or retention of an attorney as outside counsel include the quality of the attorney’s work, background and relevant

experience, legal skills, commitment to diversity and equity, responsiveness and sensitivity to the client’s needs, style and presence, freedom from conflict

of interest, and management skills." These factors are purely qualitative and cannot be used to quantitatively compare attorneys. Factors such as billable

rates and travel costs should also be included. This language should be replaced with language that demands cost efficiency, effectiveness, and subject

matter expertise of counsel, so as to be consistent with "efficient and effective" management, which is mentioned in this document. - "The Board will

contract with the attorneys or firms selected to serve as outside counsel, subject to renewal." Maintaining continuous, ongoing relationships with outside

counsel should be limited in scope to routine matters and not applied broadly to every legal matter the Board of Education may face. The policy should not

allow the retention of outside counsel on a continuous basis for the defense of members of the Board of Education. - I strongly object to the proposed

policy in whole and encourage the Board to continue operating according to existing policy, with the addition of language that the General Counsel will

work under the direct oversight of the Superintendent of Schools. Evelyn Garland

48


that the General Counsel will work under the direct oversight of the Superintendent of Schools. Peng He



49

- I strongly object to the language "The factors to be considered in the selection or retention of an attorney as outside counsel include the quality of the

attorney’s work, background and relevant experience, legal skills, commitment to diversity and equity, responsiveness and sensitivity to the client’s needs,

style and presence, freedom from conflict of interest, and management skills." These factors are purely qualitative and no reasonable evaluation metric

exists to evaluate them relative to other counsel, such as billable rates, costs related to travel / supplies / logistics, and other demonstrable factors. This

language should be replaced with language emphasizing cost efficiency, effectiveness and subject matter expertise of counsel, in keeping the spirit of

"efficient and effective" management mentioned elsewhere in this document. Jennifer Cerny

50

- I strongly object to the language "In consultation and collaboration with the Board, the superintendent of schools, and other authorized administrators of



to the language "Conducting and supervising all aspects of litigation and administrative agency proceedings in which the Board, superintendent of schools,

or other staff acting in the course of their duties for MCPS are named as plaintiffs or defendants, including but not limited to legal support for special

education proceedings, consistent with Board Policy BLC, Procedures for Review and Resolution of Special Education Disputes." This does not offer the

public sufficient protection from having to finance the defense of public officials acting irresponsibly, unethically, with malfeasance, or in any other manner

that does not serve the public good. The public has a right to pursue legal action against officials in these cases without the secondary harm of having to

pay for their defense. This language should be replaced with language stating no county funds will be used for legal action where the Board,

superintendent or any staff are acting as plaintiffs. The revisions should include a clause stating that no county funds will be used in legal action where the

Board, superintendent or staff is accused of acting in a manner that is against the public interest. - I strongly object to the language "The factors to be

considered in the selection or retention of an attorney as outside counsel include the quality of the attorney’s work, background and relevant experience,

legal skills, commitment to diversity and equity, responsiveness and sensitivity to the client’s needs, style and presence, freedom from conflict of interest,

and management skills." These factors are purely qualitative and no reasonable evaluation metric exists to evaluate them relative to other counsel, such as

billable rates, costs related to travel / supplies / logistics, and other demonstrable factors. This language should be replaced with language emphasizing

cost efficiency, effectiveness and subject matter expertise of counsel, in keeping the spirit of "efficient and effective" management mentioned elsewhere in

this document. - I strongly object to the language "The Board will contract with the attorneys or firms selected to serve as outside counsel, subject to





Schools. Cindy Li



51

It is very odd for BOE to hire attorney for advice and representation, what do you want to do??? You are supposed to be educators,. BOE members can

represent themselves, don’t waste tax payer’s money on BOE’s legal service. I strongly object such ridiculous proposal “Draft policy BOA,legal

servies,......and effective management of legal services”. Yang Nan

52
























oversight of the Superintendent of Schools. Jianxun Dong



53

This is a really bad policy to give BOE members a blank check to take county residents to court with their tax money, ironically. - I strongly object to the

language "and engage in strategic decision making to promote equity and academic excellence for all students." Proscribing a specific course of action for

how Legal Services will be used is inconsistent with the goals of ensuring efficient and effective management of resources. This language should be

removed. - I strongly object to the language "In consultation and collaboration with the Board, the superintendent of schools, and other authorized

administrators of the school district, the general counsel of MCPS shall be responsible for overall management of legal services." Public officials should be

accountable for decisions about legal services. Language should be included requiring explicit approval and oversight by the Superintendent of Schools. - I

strongly object to the language "Conducting and supervising all aspects of litigation and administrative agency proceedings in which the Board,





secondary harm of having to pay for their defense. This language should be replaced with language stating "no county funds will be used for legal action

where the Board, superintendent or any staff are acting as plaintiffs". The revisions should include a clause stating that no county funds will be used in legal

action where the Board, superintendent or staff is accused of acting in a manner that is against the public interest. - I strongly object to the language "The

factors to be considered in the selection or retention of an attorney as outside counsel include the quality of the attorney’s work, background and relevant

experience, legal skills, commitment to diversity and equity, responsiveness and sensitivity to the client’s needs, style and presence, freedom from conflict

of interest, and management skills." These factors are purely qualitative and no reasonable evaluation metric exists to evaluate them relative to other

counsel, such as billable rates, costs related to travel / supplies / logistics, and other demonstrable factors. This language should be replaced with language

emphasizing cost efficiency, effectiveness and subject matter expertise of counsel. - I strongly object to the language "The Board will contract with the

attorneys or firms selected to serve as outside counsel, subject to renewal." Maintaining continuous, ongoing relationships with outside counsel should be

limited in scope to routine matters such as land use and not applied broadly to every legal matter the Board of Education may face. This policy should

prohibit outside counsel from being retained on a continuous basis for the defense of members of the Board of Education. To sum up, I strongly object to

the proposed policy in whole and encourage the Board to continue operating according to existing policy, with the addition of language that the General

Counsel will work under the direct oversight of the Superintendent of Schools. Hongbin Yu

54 I don’t support to use tax payers’ money to pay for any service or activity which is not publicly approved by the majority voters. This is illegal. Karen Davidson



55

- I strongly object to the language "Conducting and supervising all aspects of litigation and administrative agency proceedings in which the Board,







action where the Board, superintendent or staff is accused of acting in a manner that is against the public interest. chen runjia



56
























oversight of the Superintendent of Schools. Robert Speece

57 As an attorney and taxpayer I do not approve of any measure that allows taxpayer dollars to outgun taxpayers with minimal oversight. Seth Diamond



58

I strongly object to the language "In consultation and collaboration with the Board, the superintendent of schools, and other authorized administrators of

the school district, the general counsel of MCPS shall be responsible for overall management of legal services." The obvious lack of accountability, missing

requirement of explicit approval and oversight by the Superintended of schools is not acceptable. I strongly object to the language "Conducting and

supervising all aspects of litigation and administrative agency proceedings in which the Board, superintendent of schools, or other staff acting in the course

of their duties for MCPS are named as plaintiffs or defendants, including but not limited to legal support for special education proceedings, consistent with

Board Policy BLC, Procedures for Review and Resolution of Special Education Disputes." This does not provide the public sufficient protection from having

to finance the defense of public officials acting irresponsibly, unethically, with malfeasance, or in any other manner that does not serve the public good.

The public has a right to pursue legal action against officials in these cases without the secondary harm of having to pay for their defense. This language

should be replaced with language stating no county funds will be used for legal action where the Board, superintendent or any staff are acting as plaintiffs.

The revisions should include a clause stating that no county funds will be used in legal action where the Board, superintendent or staff is accused of acting

in a manner that is against the public interest. I strongly object to the language "The Board will contract with the attorneys or firms selected to serve as

outside counsel, subject to renewal." Maintaining continuous, ongoing relationships with outside counsel should be limited in scope to routine matters and

not applied broadly to every legal matter the Board of Education may face. This policy should prohibit outside counsel from being retained on a continuous

basis for the defense of members of the Board of Education. I strongly object to the proposed policy in whole and expect the Board to continue operating

according to existing policy, with the addition of language that the General Counsel will work under the direct oversight of the Superintendent of Schools. Tian Zhou

59


that the General Counsel will work under the direct oversight of the Superintendent of Schools. Nurit Coombe

60

- I strongly object to the language "In consultation and collaboration with the Board, the superintendent of schools, and other authorized administrators

of the school district, the general counsel of MCPS shall be responsible for overall management of legal services." Public officials should be accountable for

decisions about legal services. Language should be included requiring explicit approval and oversight by the Superintendent of Schools. G Hang

61


that the General Counsel will work under the direct oversight of the Superintendent of Schools. Olesya Gruber

62


that the General Counsel will work under the direct oversight of the Superintendent of Schools. Brian Gruber

63


that the General Counsel will work under the direct oversight of the Superintendent of Schools. Andrey Andreev



64








action where the Board, superintendent or staff is accused of acting in a manner that is against the public interest. Nina Miller

65








action where the Board, superintendent or staff is accused of acting in a manner that is against the public interest. John Moore

66



language should be removed. Sharon Kumar



67
























oversight of the Superintendent of Schools. Qing Song



68

- I strongly object to the language "Conducting and supervising all aspects of litigation and administrative agency proceedings in which the Board,







action where the Board, superintendent or staff is accused of acting in a manner that is against the public interest. Abby Johnson



69

I strongly object to the removal of language:"facilitate both cost control and accountability". It's BOA's fiduciary duty to control cost and assure

accountability of any services it acquires. Provide specific reason that these langue deletion. I strongly object to the language "and engage in strategic

decision making to promote equity and academic excellence for all students." Proscribing a specific course of action for how Legal Services will be used is

inconsistent with the goals of ensuring efficient and effective management of resources. This language should be removed. - I strongly object to the

language "In consultation and collaboration with the Board, the superintendent of schools, and other authorized administrators of the school district, the

general counsel of MCPS shall be responsible for overall management of legal services." Public officials should be accountable for decisions about legal

services. Language should be included requiring explicit approval and oversight by the Superintendent of Schools. - I strongly object to the language

"Conducting and supervising all aspects of litigation and administrative agency proceedings in which the Board, superintendent of schools, or other staff

acting in the course of their duties for MCPS are named as plaintiffs or defendants, including but not limited to legal support for special education

proceedings, consistent with Board Policy BLC, Procedures for Review and Resolution of Special Education Disputes." This does not offer the public

sufficient protection from having to finance the defense of public officials acting irresponsibly, unethically, with malfeasance, or in any other manner that

does not serve the public good. The public has a right to pursue legal action against officials in these cases without the secondary harm of having to pay for

their defense. This language should be replaced with language stating no county funds will be used for legal action where the Board, superintendent or any

staff are acting as plaintiffs. The revisions should include a clause stating that no county funds will be used in legal action where the Board, superintendent

or staff is accused of acting in a manner that is against the public interest. - I strongly object to the language "The factors to be considered in the selection

or retention of an attorney as outside counsel include the quality of the attorney’s work, background and relevant experience, legal skills, commitment to

diversity and equity, responsiveness and sensitivity to the client’s needs, style and presence, freedom from conflict of interest, and management skills."

These factors are purely qualitative and no reasonable evaluation metric exists to evaluate them relative to other counsel, such as billable rates, costs

related to travel / supplies / logistics, and other demonstrable factors. This language should be replaced with language emphasizing cost efficiency,

effectiveness and subject matter expertise of counsel, in keeping the spirit of "efficient and effective" management mentioned elsewhere in this

document. - I strongly object to the language "The Board will contract with the attorneys or firms selected to serve as outside counsel, subject to





Schools. Yunxiang Chen



70
























oversight of the Superintendent of Schools. Karen Wu



71

I strongly object to the removal of language: “facilitate both cost control and accountability". It's BOA's fiduciary duty to control cost and assure

accountability of any services it acquires. Provide specific reason that this langue deletion. I strongly object to the language "and engage in strategic

decision making to promote equity and academic excellence for all students." Proscribing a specific course of action for how Legal Services will be used is

inconsistent with the goals of ensuring efficient and effective management of resources. This language should be removed. - I strongly object to the

language "In consultation and collaboration with the Board, the superintendent of schools, and other authorized administrators of the school district, the

general counsel of MCPS shall be responsible for overall management of legal services." Public officials should be accountable for decisions about legal

services. Language should be included requiring explicit approval and oversight by the Superintendent of Schools. - I strongly object to the language

"Conducting and supervising all aspects of litigation and administrative agency proceedings in which the Board, superintendent of schools, or other staff

acting in the course of their duties for MCPS are named as plaintiffs or defendants, including but not limited to legal support for special education

proceedings, consistent with Board Policy BLC, Procedures for Review and Resolution of Special Education Disputes." This does not offer the public

sufficient protection from having to finance the defense of public officials acting irresponsibly, unethically, with malfeasance, or in any other manner that

does not serve the public good. The public has a right to pursue legal action against officials in these cases without the secondary harm of having to pay for

their defense. This language should be replaced with language stating no county funds will be used for legal action where the Board, superintendent or any

staff are acting as plaintiffs. The revisions should include a clause stating that no county funds will be used in legal action where the Board, superintendent

or staff is accused of acting in a manner that is against the public interest. - I strongly object to the language "The factors to be considered in the selection

or retention of an attorney as outside counsel include the quality of the attorney’s work, background and relevant experience, legal skills, commitment to

diversity and equity, responsiveness and sensitivity to the client’s needs, style and presence, freedom from conflict of interest, and management skills."

These factors are purely qualitative and no reasonable evaluation metric exists to evaluate them relative to other counsel, such as billable rates, costs

related to travel / supplies / logistics, and other demonstrable factors. This language should be replaced with language emphasizing cost efficiency,

effectiveness and subject matter expertise of counsel, in keeping the spirit of "efficient and effective" management mentioned elsewhere in this

document. - I strongly object to the language "The Board will contract with the attorneys or firms selected to serve as outside counsel, subject to





Schools. Yingwen Chen

72


that the General Counsel will work under the direct oversight of the Superintendent of Schools. Quin Lai



73

MoCo Residents: The BOE is currently proposing a policy allowing them to hire the most expensive law firms in the US with no oversight from the Superintendent or public

transparency about who is being retained or how much it costs. It really doesn't matter how you feel about redistricting, it's bad policy to give BOE members a blank check

to take county residents to court. The public comment period is still open. County residents to submit letters online in opposition. A description of the policy is available on

the following link, under the heading "BOARD POLICY BOA, LEGAL SERVICES": https://www.montgomeryschoolsmd.org/departments/policy/policy-for-public-

comment.aspx Letters can be submitted here: https://mcpsweb.wufoo.com/forms/rgvf7vu194ul5v/ I strongly object to the language "and engage in strategic decision

making to promote equity and academic excellence for all students." Proscribing a specific course of action for how Legal Services will be used is inconsistent with the goals

of ensuring efficient and effective management of resources. This language should be removed. I strongly object to the language "In consultation and collaboration with

the Board, the superintendent of schools, and other authorized administrators of the school district, the general counsel of MCPS shall be responsible for overall

management of legal services." Public officials should be accountable for decisions about legal services. Language should be included requiring explicit approval and

oversight by the Superintendent of Schools. I strongly object to the language "Conducting and supervising all aspects of litigation and administrative agency proceedings in

which the Board, superintendent of schools, or other staff acting in the course of their duties for MCPS are named as plaintiffs or defendants, including but not limited to

legal support for special education proceedings, consistent with Board Policy BLC, Procedures for Review and Resolution of Special Education Disputes." This does not offer

the public sufficient protection from having to finance the defense of public officials acting irresponsibly, unethically, with malfeasance, or in any other manner that does

not serve the public good. The public has a right to pursue legal action against officials in these cases without the secondary harm of having to pay for their defense. This

language should be replaced with language stating no county funds will be used for legal action where the Board, superintendent or any staff are acting as plaintiffs. The

revisions should include a clause stating that no county funds will be used in legal action where the Board, superintendent or staff is accused of acting in a manner that is

against the public interest. I strongly object to the language "The factors to be considered in the selection or retention of an attorney as outside counsel include the quality

of the attorney’s work, background and relevant experience, legal skills, commitment to diversity and equity, responsiveness and sensitivity to the client’s needs, style and

presence, freedom from conflict of interest, and management skills." These factors are purely qualitative and no reasonable evaluation metric exists to evaluate them

relative to other counsel, such as billable rates, costs related to travel / supplies / logistics, and other demonstrable factors. This language should be replaced with language

emphasizing cost efficiency, effectiveness and subject matter expertise of counsel, in keeping the spirit of "efficient and effective" management mentioned elsewhere in

this document. I strongly object to the language "The Board will contract with the attorneys or firms selected to serve as outside counsel, subject to renewal." Maintaining

continuous, ongoing relationships with outside counsel should be limited in scope to routine matters such as land use and not applied broadly to every legal matter the

Board of Education may face. This policy should prohibit outside counsel from being retained on a continuous basis for the defense of members of the Board of Education.

I strongly object to the proposed policy in whole and encourage the Board to continue operating according to existing policy, with the addition of language that the General

Counsel will work under the direct oversight of the Superintendent of Schools. W F

74

The lack of oversight on the BOE’s use and coordination of legal services is troubling. As an attorney I understand the fiduciary duty that lawyers have vis-a-

vis their clients. If the BOE is comprised of public servants and they make decisions counter to the clear majority of their constituents and need legal

representation to fight their own constituency, I’m very concerned about the use of tax payer funds to pay for this. At minimum, the BOE needs oversight

by the IG, the County Council, and state level representatives. Shari Shaw



75

NO blank checks for BOE to serve their own interests not for MC residents. - I strongly object to the language "and engage in strategic decision making to

promote equity and academic excellence for all students." Proscribing a specific course of action for how Legal Services will be used is inconsistent with the

goals of ensuring efficient and effective management of resources. This language should be removed. - I strongly object to the language "In consultation

and collaboration with the Board, the superintendent of schools, and other authorized administrators of the school district, the general counsel of MCPS

shall be responsible for overall management of legal services." Public officials should be accountable for decisions about legal services. Language should be

included requiring explicit approval and oversight by the Superintendent of Schools. - I strongly object to the language "Conducting and supervising all

aspects of litigation and administrative agency proceedings in which the Board, superintendent of schools, or other staff acting in the course of their duties

for MCPS are named as plaintiffs or defendants, including but not limited to legal support for special education proceedings, consistent with Board Policy

BLC, Procedures for Review and Resolution of Special Education Disputes." This does not offer the public sufficient protection from having to finance the

defense of public officials acting irresponsibly, unethically, with malfeasance, or in any other manner that does not serve the public good. The public has a

right to pursue legal action against officials in these cases without the secondary harm of having to pay for their defense. This language should be replaced

with language stating no county funds will be used for legal action where the Board, superintendent or any staff are acting as plaintiffs. The revisions

should include a clause stating that no county funds will be used in legal action where the Board, superintendent or staff is accused of acting in a manner

that is against the public interest. - I strongly object to the language "The factors to be considered in the selection or retention of an attorney as outside

counsel include the quality of the attorney’s work, background and relevant experience, legal skills, commitment to diversity and equity, responsiveness

and sensitivity to the client’s needs, style and presence, freedom from conflict of interest, and management skills." These factors are purely qualitative and

no reasonable evaluation metric exists to evaluate them relative to other counsel, such as billable rates, costs related to travel / supplies / logistics, and

other demonstrable factors. This language should be replaced with language emphasizing cost efficiency, effectiveness and subject matter expertise of

counsel, in keeping the spirit of "efficient and effective" management mentioned elsewhere in this document. - I strongly object to the language "The

Board will contract with the attorneys or firms selected to serve as outside counsel, subject to renewal." Maintaining continuous, ongoing relationships

with outside counsel should be limited in scope to routine matters such as land use and not applied broadly to every legal matter the Board of Education

may face. This policy should prohibit outside counsel from being retained on a continuous basis for the defense of members of the Board of Education. - I

strongly object to the proposed policy in whole and encourage the Board to continue operating according to existing policy, with the addition of language

that the General Counsel will work under the direct oversight of the Superintendent of Schools. Dalong Huang



76

The revision failed to convince why the current policy under approval and oversight by the Superintendent of Schools does not work. Using MC residents'

tax funds to be against MC residents' public interests is going to be a bad policy. No blank checks, No blank trusts for BOE. - I strongly object to the



removed. - I strongly object to the language "In consultation and collaboration with the Board, the superintendent of schools, and other authorized

administrators of the school district, the general counsel of MCPS shall be responsible for overall management of legal services." Public officials should be

accountable for decisions about legal services. Language should be included requiring explicit approval and oversight by the Superintendent of Schools. - I

strongly object to the language "Conducting and supervising all aspects of litigation and administrative agency proceedings in which the Board,







action where the Board, superintendent or staff is accused of acting in a manner that is against the public interest. yishen sun

77








action where the Board, superintendent or staff is accused of acting in a manner that is against the public interest. Pu Liu



78

- I strongly object to the language "In consultation and collaboration with the Board, the superintendent of schools, and other authorized administrators of



to the language "and engage in strategic decision making to promote equity and academic excellence for all students." Proscribing a specific course of

action for how Legal Services will be used is inconsistent with the goals of ensuring efficient and effective management of resources. This language should

be removed. - I strongly object to the language "Conducting and supervising all aspects of litigation and administrative agency proceedings in which the

Board, superintendent of schools, or other staff acting in the course of their duties for MCPS are named as plaintiffs or defendants, including but not

limited to legal support for special education proceedings, consistent with Board Policy BLC, Procedures for Review and Resolution of Special Education

Disputes." This does not offer the public sufficient protection from having to finance the defense of public officials acting irresponsibly, unethically, with

malfeasance, or in any other manner that does not serve the public good. The public has a right to pursue legal action against officials in these cases

without the secondary harm of having to pay for their defense. This language should be replaced with language stating no county funds will be used for

legal action where the Board, superintendent or any staff are acting as plaintiffs. The revisions should include a clause stating that no county funds will be

used in legal action where the Board, superintendent or staff is accused of acting in a manner that is against the public interest. - I strongly object to the

language "The factors to be considered in the selection or retention of an attorney as outside counsel include the quality of the attorney’s work,










oversight of the Superintendent of Schools. Chris Hertz



79
























oversight of the Superintendent of Schools. Maria Tsitrin

80

I vehemently object to the BOE being able to retain legal counsel in secret. The BOE is a board of PUBLIC servants, voted in and entrusted by the tax-paying

constituents of this county. The members of the BOE should be answering to the people who have put them into office. Any policy which supports

secretive tactics will prevent transparency, which we have a right to as the tax-paying voters. Furthermore, the ability of the BOE to hire the most

expensive lawyers in the county will disenfranchise Montgomery County residents from relief in courts. Jenna StecklerSteckler



81

As a resident of Montgomery County and an attorney who has worked at both an AMLAW100 law firm and as in-house counsel to large corporations, I am

deeply concerned about the prospect of giving BOE members a blank check to engage outside counsel and proscribing a specific course of action for how

legal services will be used. The specific language to which I most strongly object is set forth below. 1. Section A, lines 25-27. I strongly object to the



removed. As noted below, goals should be addressed on a case-by-case basis pursuant to the BOE’s discretion afforded by the language “sensitivity to the

client’s needs” in Section B.2(b). 2. Section B.1(a)(2), lines 48-57. I strongly object to the language "Conducting and supervising all aspects of litigation and

administrative agency proceedings in which the Board, superintendent of schools, or other staff acting in the course of their duties for MCPS are named as

plaintiffs or defendants, including but not limited to legal support for special education proceedings, consistent with Board Policy BLC, Procedures for

Review and Resolution of Special Education Disputes." This does not offer the public sufficient protection from having to finance the defense of public

officials acting irresponsibly, unethically, with malfeasance, or in any other manner that does not serve the public good. The public has a right to pursue

legal action against officials in these cases without the secondary harm of having to pay for their defense. This language should be replaced with language

stating no county funds will be used for legal action where the Board, superintendent or any staff are acting as plaintiffs. Furthermore, the revisions should

include a clause stating that no county funds will be used in legal action where the Board, superintendent or staff is accused of acting in a manner that is

against the public interest. 3. Section B.2(b), lines 122-129. I strongly object to the following language in Section B.2.b, lines 122 through 129: “The

factors to be considered in the selection or retention of an attorney as outside counsel include . . . commitment to diversity and equity . . . .” Requiring a

commitment to diversity and equity proscribes a specific course of action for how legal services will be used and is inconsistent with the goals of ensuring

efficient and effective management of resources. Diversity and equity is sufficiently covered under the language “sensitivity to the client’s needs” as the

BOE may express such as specific needs when engaging counsel. Most importantly, Section B.2.b omits entirely any mention of cost-effectiveness. This

should be a primary consideration of the BOE when spending taxpayer dollars on outside counsel. As such, the provision should be re-written to read as

follows: The factors to be considered in the selection or retention of an attorney as outside counsel include first and foremost the cost and necessity of

engaging such attorney, followed by the willingness to accept alternative billing arrangements such as maximum/fixed fees and controlled costs related to

travel / supplies / logistics and the demonstrable quality of the attorney’s work, background, relevant experience, and legal skills, and the attorney’s

responsiveness, sensitivity to the client’s needs, style and presence, freedom from conflict of interest, and management skills. Please consider these

comments when adopting any policy addressing engagement of outside counsel. Thank you. Thomas Cheplo



82
























oversight of the Superintendent of Schools. Christina Miller



83

I strongly object to the Board of Education retaining outside counsel. MCPS already has general counsel services that are included in the MCPS Operating

Budget. Those services should be used by the BoE. Where is the budget for outside counsel? And why would it be necessary? What is inadequate about

MCPS general counsel? I have some additional specific comments. Lines 17 to 19: I strongly believe the language on cost control and accountability should

be retained. Lines 25 to 27: I strongly object to the language "engage in strategic decision making to promote equity and academic excellence for all

students." This is not the subject area expertise of attorneys, they should not be making strategic educational decisions. Lines 122-126: I strongly believe

this language should be revised. Factors to be considered and retained should be “subject matter expertise, experience, background, and freedom from

conflict of interest.” Factors that should be eliminated are “Commitment to diversity and equity, responsiveness and sensitivity to the client’s needs, style

and presence, and management skills,” as they should not be relevant factors for hiring a lawyer. June Traicoff

84

There should be some discussion of a CAP on spending dedicated to the hiring of outside counsel. The board should strive to minimize this spending. I echo

the concerns I read quoted from Ms. Dixon (as noted in Bethesda Beat article) regarding the use of outside counsel recently as it pertained to the

Damascus High incident: "...spending $250,000 on the external investigation is not “good stewardship of our funds.” AND “I think a committee of staff,

parents and students, in consultation with Board members, could have come up with the same recommendations” Please do not waste education dollars

to hire expensive, outside legal counsel for this ridiculous 'boundary analysis.' Please consider all alternatives before hiring counsel and please institute a

CAP on this type of spending for a given issue. Additional oversight of this avenue of spending IS DESPERATELY NEEDED!!!! Stella Koutros

85

I have read this policy and the redline changes. I am strongly opposed to this, especially in light of the public's stated mistrust of the BOE. I believe the

BOE should have outside legal counsel when needed, and it's noted that the wording attempts to quell any concerns by emphasizing its goal of reducing

costs. However, it completely eliminates any oversight on spending. Attorneys at outside law firms can range anywhere from $300/hr. to $1,500/hr.,

depending on their level of experience. As you can imagine, legal bills can accumulate very quickly, and into the hundreds of thousands of dollars. By

removing any tool for approval, there seems to be an intention to circumvent accountability in costs. Given the mistrust of the community based on

recent actions, and the lack of oversight, this is a very inappropriate and ill advised policy. Brian D

86

No, not a good idea. If you feel you are in need of legal advice then I question why you are sitting in those seats. Ethically this is creating less transparency

and accountability on your part and that does not bode well considering the lack of faith we have in any of you at this time of turmoil. J S

87

I feel that as elected members of the BOE that you should always prioritize transparency. Please revert to the Legal Services policy’s original language

surrounding this issue. Amy Oram

88 I urge BOE to prioritize transparency and revert to the Legal Services policy original language’s original language surrounding this issue! Jing Wang

89 This is directly against transparency that a function democracy would work. Increase the opportunity for corruption from elected officials. Not good. Cheng Tu



90

The Board of Education is part of the Montgomery County government. As such, it is accountable to the residents of Montgomery County for its

expenditures of public funds and for its decisions. The proposals undermine both aspects and should be defeated. Roger Holberg

91

Study hard is the key for students get improve their grades! Good school is not the key word! The school’s performance/grade is depending on their

students! Stop wasting my tax money for non-sense equity boundary study! Liu Hao

92 I think BOE should prioritize transparency and revert to the Legal Services policy original language’s original language surrounding this issue! Dongfang Feng

93 Stop WXY’s survey. Don’t waste taxpayers’ money anymore. Try to improve all schools Tiger Mike

94

I strongly feel that the original language provides more transparency and would draw less suspection from the constituents that BOE served. Thus, I urge

BOE to revert to the Legal Services policy original language. As the current events shows, there's a deficiency in public trust. I sincerely hope BOE would

reconsider to earn the trust back. Sarah Sunday

95

I am commenting the legal service policy published on 11/12/19. I am expressing my strongest opposition to the proposed policy. It is alarming to see

how "accountability" and "cost control" are removed. It indicating the BOE is not working for us the people, instead wants to protect them on our

unlimited cost for their own interest!! I see check and balance are removed, democracy is removed. Based on the recent mive of BOE, it is clear you know

you are working against the benefit and will of your constituents, fully aware of the legality of your action is facing challenges. How despicable it is to

change the policy, asking to use our tax money (unlimited) to protect you to carry out radical endeavor against us. This is the reason I lost my trust in you

and oppose your proposal at the strongest degree. Dahui Liu

96

I am deeply concerned about all the changes the Board plan to make to policy BOA. I am not clear on the intent of several changes. It is important for the

Board to explain to the parents why they need to update the policy at this point. Otherwise I urge the Board to keep the policy as is. Fan Wang

97

It looks like overall, the BOE has more freedom with these updates to work with Legal counsel. legal services are very expensive, which add burden to the

already limited school budget. BOE has the responsibility to explain to parents and taxpayers why they need to seek such Legal services at this time. Yang Zhang

98

Please further explain why BOE found it is necessary to add “Provide advice and assistance to the Board as it carries out its quasi-judicial responsibilities in

appeals and hearings.” It especially concerns me that BOE needs the counsel to provide assistance to the Board even in the hearings. Hearings should be a

platform for parents to express their thoughts on BOE’s policies. Introducing Legal Services to the us who are not familiar with Legal matters is very

worrisome. It looks with with new updates, the Board can bypass the superintendent to directly work with the counsel. However, I feel strongly approval

from the superintendent is necessary for BOE to initiate any Legal process. It looks like overall, the BOE has more freedom with these updates to work

with Legal counsel. Legal Services are very expensive, which add burden to the already limited school budget. I feel BOE has the responsibility to explain to

parents and taxpayers why they need to seek such Legal Services at this time. heidi wei



99

I need more information to better understand why BOE added the following term to the policy: ”…in which highly specialized legal expertise is required”. I

especially worried about the cost of these Legal Service with such “highly specialized legal expertise”. Ying H

100 I am concerned, pls provide more information Lin Yuan

101

County funding should be used to promote better education, and to provide better resources to schools. It should NOT be used to defend officials that act

irresponsibly, unethically, in ways that harms the public, or officials that act negligently to a law. The public has the right to use legal action against officials

that acted in such ways, without having to worry about secondary harm of having to pay for their defense. L Z

102 I need more information to better understand why BOE added the following term to the policy: ”…in which highly specialized legal expertise is required”. Vivian Chang

103

It looks with new updates, the Board can bypass the superintendent to directly work with the counsel. However, I feel strongly approval from the

superintendent is necessary from BOE to initiate any Legal process! Wei Shi

104








action where the Board, superintendent or staff is accused of acting in a manner that is against the public interest. Donglei Yu

105

I do not understand why BOA need this service now. It is very expensive processing. Who will pay this extra cost since school budget is already very tight.

Our schools are dependent on PTA to buy some essential school items. Why do not save the money for schools and students. Jeff Zhao

106

I strongly oppose the language "The board will contract with attorneys or firms selected to serve as outside counsel, subject to renewal." Consultation with

outside law services should be limited to BOE's routine affairs such as land use, but cannot be applied to lawsuits where BOE is the plaintiff or defendant.

BOE needs to maintain regular and frequent communication with the community, and resolve confusions and disagreement through democratic ways. It is

the failure of BOE if community members have to defend their interests through lawsuits against BOE. Hongqiang Zhou

107 Who will pay the lawyer fee? Jessie Zhang

108

I'm disturbed by seeing why BOE needs to "retain attorneys for advice and representation in legal matters and sets forth a comprehensive plan for the

efficient and effective management of legal services". Where's the funding from? How much will it cost tax payers' money? I will need more thorough

transparent information to understand why this amendment is requested. Michelle Liu



109 I hope BOE can provide more information on why it is an urgent matter to update Legal Service Policy at this point. Grace Shi

110 I am strongly concerned, please clarify in more details before taking any steps further Yin Huang

111 I am deeply worried, please provide more information. Jim Ku

112

It is unclear to me and probably many Montgomery taxpayers about the need of a legal service to enforce equity and improve academic performance of

which the link has no solid data support. If the BOE has to consider using legal services to enforce equity to improve academic performance, it only means

majority of the residents don’t agree with the assumed causal effect relationship between the two events. There are better measures/strategies to be

taken to improve academic performance for all students. In addition, legal services are very expensive, which add burden to the already limited school

budget. I feel BOE has the responsibility to explain to parents and taxpayers why they need to seek such Legal Services at this time. Vivian Chen

113

So can someone from BOE give more details about how the legal service benefits the community? I’m not quite sure if this legal service is going to against

parents when they need help. What do you mean by saying: “proactive legal problem solving”? Also, since the BOE claims that some school districts

already have tight budget for daily routines like food stamps, etc. I think this legal service is not a priority at this time. Liming Lu

114

I am deeply concerned about this proposal. As a tax payer for our county, how can you use tax payer's money to against the interest of tax payer? This is

abuse of the resource and power without being transparent to the public. Totally concerned and against it. Thanks. Sindy Row

115







parents and taxpayers why they need to seek such Legal Services at this time. Hongwei Liao

116

As a long time Montgomery county resident/tax payer, I am deeply concerned about the change of the Legal Service policy. BOE should provide more

information on why it is necessary to update Legal Service policy at this point. Please explain to the public intention of these detailed updates? I need

more information to better understand why BOE added the following term to the policy: ”…in which highly specialized legal expertise is required”. I’m

deeply concerned about the hefty cost of these Legal Service with such “highly specialized legal expertise” since this cost will be covered with tax $ we pay. Linda L

117

I am totally against this proposal on using tax payer's money for BOE to seek legal advice. The information provided to the public is very limited and lacking

transparency. John Anderson



118

I am writing to express my concerns about the recent change of the Legal Service Policy. As a taxpayer, I care about how and where my tax dollars have

been spent and why; therefore, can BOE provide me some relevant information on why it is an urgent matter to update Legal Service Policy at this point,

and how the decision-making process works as well as how we as a taxpayer, can get more involved into this important process? Also, can you please

explain why BOE added the following term to the policy: ”…in which highly specialized legal expertise is required”. I as well as many others, demand

transparency in all policy changes and decision-making process. I strongly suggest BOE create a communication channel to have a better conversation

with taxpayers and stakeholders. Thank you! Eva Guo

119

What’s this policy for? Why do we spend more money on legal services when the county or BOE already have tight budget to improve the student/school

services? Lei Sun

120 I’m deeply worried about the redistribution . Vicky Xie

121 I am deeply worried, I am deeply concerned, please provide more information. Jingqi Lei

122 More transparency accountability! I deeply concerned about this policy Irene Xie

123 We are deeply concerned!! Ge Lee

124

It looks like overall, the BOE has more freedom with these updates to work with Legal counsel. We all know that legal Services could be very expensive,

which add burden to the already limited school budget. BOE has the responsibility to explain to parents and taxpayers why they need to seek such Legal

Services at this time. And how to avoid this kind of issue. Rongde Qiu

125

Deeply concerned all these aggressive policies without consulting students” parents feeling and opinions. No politics above education. No political

achievement above real change. Your guys should really think how to change and improve education quality of those underserved. Do the real work, not

superficial stuff. Michael Rao

126 I am deeply worried, I am deeply concerned, please provide more information about it. Carrie Bu

127 please provide detailed information. Please don’t waste our money do any useless work. Lixia Zhang

128

We need more information to better understand why BOE added the following term to the policy: ”…in which highly specialized legal expertise is

required”. I especially worried about the cost of these Legal Service with such “highly specialized legal expertise”. Grace Gu

129 BOE has no transparency in the policy change. I am in deep concern. Yiting Deng

130

I am deeply concerned about the change of the Legal Service policy. I hope BOE can provide more information on why it is an urgent matter to update

Legal Service policy at this point. Can BOE explain to public the intention of these detailed updates? I need more information to better understand why

BOE added the following term to the policy: ”…in which highly specialized legal expertise is required”. I especially worried about the cost of these Legal

Service with such “highly specialized legal expertise” since this cost will be from the tax we pay. Xinna Yi

131 This is non-sense. Why would BOE hire lawyers against their public. Lee Ma



132

Mongomery County BOE, You have lost the trust from the hardworking taxpayers. No credit at all. STOP wasting taxpayers money on this BS. I strongly

oppose the proposed amendments. The proposed amendments are nothing but covering your ass for doing bad and wrong things (re-redistricting, busing

in and out, and so on) to hardworking taxpayers' children. Spend your efforts and taxpayers' money on Education! Close the "gap" by improving the

students with lower performance NOT dragging down the students with higher performance. STOP putting police officers at the public hearings. What are

you afraid of? Kevin Smith

133

I am deeply concerned about the purpose of this amendment issued at the moment of controversial debate about school boundary analysis and what

already happened in upcounty and HOCO with their legal battle! Sounds like BOE already decided what they will be doing regardless of public opposition

and predict they will get the similar legal battle happen now with upcounty! This is inconsistent with BOE so called “ seeking public opinion. And listen to

the community”! I strongly object to the language "and engage in strategic decision making to promote equity and academic excellence for all students."

Proscribing a specific course of action for how Legal Services will be used is inconsistent with the goals of ensuring efficient and effective management of

resources. This language should be removed. - I strongly object to the language "In consultation and collaboration with the Board, the superintendent of

schools, and other authorized administrators of the school district, the general counsel of MCPS shall be responsible for overall management of legal

services." Public officials should be accountable for decisions about legal services. Language should be included requiring explicit approval and oversight by

the Superintendent of Schools. - I strongly object to the language "Conducting and supervising all aspects of litigation and administrative agency

proceedings in which the Board, superintendent of schools, or other staff acting in the course of their duties for MCPS are named as plaintiffs or







interest. - I strongly object to the language "The factors to be consi Ling Yan

134

I am deeply worried, I am deeply concerned, please provide more information. Their job is to serve the taxpayers. Now they just don’t want to hear any

taxpayer’s voice and do what they want to do without any public oversight. Yan Wang

135 I have concern for this. Are they afraid of public oversight? Hongwei Liao



136

This is unacceptable from our elected officials making this amendment and certain language used are very concerning for the public! We deserve to know

the rational and truth, and hold BOE accountable for taxpayer money! I strongly object to the language "and engage in strategic decision making to













that is against the public interest. - I strongly object to the language "The factors to be consi Moulay Samrakandi

137 I am deeply worried and concerned. Please provide more information. Faith Yang

138 I am deeply worried, I am deeply concerned, please provide more information Ying Hanten

139

This document indicates that the BOE needs more legal service to promote equity to improve academic performance. I would like to hear more about this

need, such as more background information about current legal standing for the BOE members, and what is the detail amendment you refer in this survey.

As the BOE emphasized in Jan 9th meeting and several mails to public that transparency and accountbility were important to your work and of course to

us, I would like to see how the BOE can do better in every aspect. At least, public hearing regarding the amendment is needed. Chen Lai

140




us, I would like to see how the BOE can do better in every aspect. At least, public hearing regarding the amendment is needed. Lilian Cheng



141




us, I would like to see how the BOE can do better in every aspect. At least, public hearing regarding the amendment is needed. Jiandong Yang

142 I want to learn more regarding this. At least, public hearing regarding the amendment is needed. Ziching Yang

143 We , as parents , are very concerned and worried about our county public schools. Please provide more details about any changes of it. Thank you! Sophia Nan

144

I’m deeply worried. Could BOE tell us how much the money has been paid and will be paid for survey and lawyers? Where these money come from? Could

BOE stop these actions? Please do not waste taxpayers’ money! Faith Yang

145




Service with such “highly specialized legal expertise” since this cost will be from the tax we pay. Yongbo Chen

146 I am deeply worried, I am deeply concerned, please provide more information. Cindy Cheng

147

As a Maryland resident and tax payer, I am deeply concerned about the amendments to BOA. Why are legal services needed in education？Why

now？Where will the money come from？The money to pay for expensive attorneys can be used to improve school resources and to close student

performance gap way more efficiently than legal actions. The state tax is not designated for such legal actions. If an amendment as such can be easily made

by BOE，the power of the BOE is abused. Cuiping Liu

148

I am deeply worried and concerned about the transparency on any decision made by BOE. Please provide more information by arranging public hearing or

town hall meeting. Wei Yue

149


especially worried about the cost of these Legal Service with such “highly specialized legal expertise”. Jian Wang

150 public hearing regarding the amendment is needed. ANJIE YANG

151

I am very concerned about the change of the Legal Service policy. I would like to request BOE to provide justification as to why it is an urgent matter to

update Legal Service policy at this point and the intention of these detailed updates. Andrea Smith

152 Please provide more information and provide public hearing dongfeng zhu

153 I am deeply worried；I am deeply concerned. Please provide more information． Hm Wolf

154 It is important to have public hearing about the amendments. Jianghong Gu

155 I am so worried on the policy’s impact on my kids and have several questions. Please schedule a town hall meeting to provide more information. Jian Song



156

I am deeply concerned that the cost on legal service would be very high and tax payer’s money will be spent on other aspects than on improving education

qualities. Beeth Chan

157

I'm deeply concerned on the motivation of this revision. And I don't think there is enough time given to the public so such significant revision can be

reviewed thoroughly by most of the tax payers. Jianfei Wang

158

So can someone from BOE give more details about how the legal service benefits the community? I’m not quite sure if this legal service is going to against

parents when they need help. Also, since the BOE claims that some school districts already have tight budget for daily routines like food stamps, etc. I

think this legal service is not a priority at this time. Qing Song

159 I am deeply concerned, please provide more information, request public hearing! Jing Fang

160


that the General Counsel will work under the direct oversight of the Superintendent of Schools. David Chan

161

I am concerned about the changes on Legal Service Policy. Can you please more info to the public your rationals about the needs for this legal service and

how can I get more involved in the decision making process? Thank you! Kevin Li

162

This document indicates the BOE has to take legal action to force equity to improve academic performance. That means most of the feedbacks are against

the idea that the equity will improve academic performance. It makes no sense why BOE holds all these informational/voting meetings since they will not

take taxpayers’ input if it is different. Karen Wu

163 I am deeply worried this amendment and request more information. All the money spent on legal service needs more transparent. Pu Liu

164

I don't understand why BOE wants to make such amendment - what's the reason for BOE to make such change? What's the intention? The description

provided is too vague. Plus, my understanding is that if BOE follows all rules and ethical standard, legal challenge should be minimal. If there is a sudden

surge of legal actions against BOE, it would indicate BOE must has done something extremely wrong. Thus, what BOE should do is obey all the legal rules

and procedures, and any changes regarding school and students should be transparent and fair, to minimize legal fees as much as possible. By doing so, it

not only helps BOE set up a good reputation, but also saves tax money so that such money could be spent more wisely. Therefore, policy BOA should

remain the same without any change. Yinan Liu

165

I am deeply concerned about the change of the Legal Service policy. BOE should provide more information on why it is an urgent matter to update Legal

Service policy at this point. Can BOE explain to public the intention of these detailed updates? I need more information to better understand why BOE

added the following term to the policy: ”…in which highly specialized legal expertise is required”. I especially worried about the cost of these Legal Service

with such “highly specialized legal expertise” since this cost will be from the tax we pay. Chi Zhang

166 I’m deeply concerned, please provide more information about how decisions are made. Thanks! Jian Zhang



167

Dear BOE members, After reading the proposed changes to the Board Policy BOA, Legal Services I object to the following policy changes I. "and engage

in strategic decision making to promote equity and academic excellence for all students." Proscribing a specific course of action for how Legal Services will

be used is inconsistent with the goals of ensuring efficient and effective management of resources. This language should be removed. II. "In consultation



included requiring explicit approval and oversight by the Superintendent of Schools. III. "Conducting and supervising all aspects of litigation and

administrative agency proceedings in which the Board, superintendent of schools, or other staff acting in the course of their duties for MCPS are named as

plaintiffs or defendants, including but not limited to legal support for special education proceedings, consistent with Board Policy BLC, Procedures for

Review and Resolution of Special Education Disputes." This does not offer the public sufficient protection from having to finance the defense of public

officials acting irresponsibly, unethically, with malfeasance, or in any other manner that does not serve the public good. The public has a right to pursue

legal action against officials in these cases without the secondary harm of having to pay for their defense. This language should be replaced with language

stating no county funds will be used for legal action where the Board, superintendent or any staff are acting as plaintiffs. The revisions should include a

clause stating that no county funds will be used in legal action where the Board, superintendent or staff is accused of acting in a manner that is against the

public interest. IV. "The factors to be considered in the selection or retention of an attorney as outside counsel include the quality of the attorney’s work,





effective" management mentioned elsewhere in this document. V. "The Board will contract with the attorneys or firms selected to serve as outside

counsel, subject to renewal." Maintaining continuous, ongoing relationships with outside counsel should be limited in scope to routine matters such as

land use and not applied broadly to every legal matter the Board of Education may face. This policy should prohibit outside counsel from being retained on

a continuous basis for the defense of members of the Board of Education. I urge the the Board to keep the existing policy, with the addition of language

that the General Counsel will work under the direct oversight of the Superintendent of Schools. L Debenport

168 I am deeply worried, I am deeply concerned, please provide more information Jessica He



169

I have concerns for the following sentence: “Provide advice and assistance to the Board as it carries out its quasi-judicial responsibilities in appeals and

hearings.” It especially concerns me that BOE needs the counsel to provide assistance to the Board even in the hearings. Hearings should be a platform for

parents to express their thoughts on BOE’s policies. Introducing Legal Services to the us who are not familiar with Legal matters is very worrisome. It

looks like overall, the BOE has more freedom with these updates to work with Legal counsel. Legal Services are very expensive, which add burden to the

already limited school budget. I feel BOE has the responsibility to explain to parents and taxpayers why they need to seek such Legal Services at this time. Xi Yang

170 I am very worried, I am very concerned, please provide more information. We ask public hearing. We want to make everything clear. Helen Zhao

171 You can not use tax payer's money to defend on tax payers! No, I am against Policy BOA Lily Fu

172

Why does county BoE feels the need for the amendments now? Is there any policy that can invite law suits? If the law suits are not by county tax payers

and hurt county taxpayer's interests, I would agree with using the county's tax payer's money. What if the law suits are by county taxpayers? I see obvious

issues in the amendments. Without accountability and supervision of tax money usage the amendments will be bad. The accountability shall be explained

to taxpayers clearly, and procedures of legal service usage be transparent with supervision. I don't see BoE has the right to enact policy to have seemingly

unlimited usage of county taxpayer's money. It has to go through our democratic process involving all taxpayers to make any such amendments. I am a

county taxpayer. I heard the community talking about certain BoE policy changes about school boundaries that potentially can hurt the interests of those

groups that paid most of the taxes and county government people's salaries. I wonder of this has to do with that. If so I suggest you to stop before this gets

out of hand. You serve who pays you - this won't change however the society evolves. Not just that - you want to be grateful for those who pay you. Jo Carr

173 I am deeply concerned, please provide more information, request public hearing, town hall. Guang Shu

174 I am deeply concerned, please provide more information. I request public hearing. Thank you. Yingwei Chen

175 I request public hearing. Thank you. Chenyu Xu

176

This policy is troubling as we all know the MCPS and BOE has much bigger resources, power, and expertise to protect the system and its legal problems.

Now making this a priority and including the budgetary impact is demonstrating BOE is far more willing to spend much needed school fundings to legal

services for its own decision making errors. A policy making body shouldn't be spending disproportionate time, energy, and budget for its own policy risk.

Because that means they might realize their policies are not that good at the first place. So maybe not making unnecessary policies is the best solution.

Save money save time and save the errors. Chris Craft



177

No way! You all have lost your minds. Don’t do stupid things that will get you sued. It’s that easy. And if you do stupid things that get you sued, you must

use the county staff lawyers. I think the whole board should resign due to the overwhelmingly gross incompetence. Seriously. Students are struggling and

you all have not done anything or proposed anything that will actually address the root issues that are leading to low income children doing poorly (the

answer is not redistricting, it’s doing something to help those with learning disabilities which includes early diagnosis and intervention, as well as

addressing the large influx of ESOL students in recent years to help them learn English and get caught up). Until you do that, expect to be sued for your

gross incompetence as you deserve it. You are failing these children! Michael Cavey

178

It looks like overall, the BOE has more freedom with these updates to work with Legal counsel. Legal Services are very expensive, which add burden to the

already limited school budget. I feel BOE has the responsibility to explain to parents and taxpayers why they need to seek such Legal Services at this time. Tian Zhou

179

It is worrisome to me that BOE needs to retain attorneys for advice and representation for legal matters. What can an attorney do to promote equity and

academic achievements of students? The money for such legal matters should be used for school resources, e.g. to hire more experienced and dedicated

teachers, to get more school counselors, to promote training programs for teachers, to increase teachers’ salaries, to buy more computers, to promote

after-school programs to help students in need academically....... These can help to promote equity and academic excellence of all students but NOT an

attorney. Weichi Xiong

180


especially worried about the cost of these Legal Service with such “highly specialized legal expertise”. Jun Zhou

181 I strongly object these changes and have deep concerns for the motivations of these changes. Diana Zou

182

I strongly oppose to this amendment. It looks with with new updates, the Board can bypass the superintendent to directly work with the counsel. However,

I feel strongly approval from the superintendent is necessary for BOE to initiate any Legal process. Jianyang Zheng

183 I’m very concerned and request public hearing about school boundary redistributing . Bradley Guhl

184

At this critical moment, I am deeply worried about this changes of Board of Education Policy BOA. I need to know more details about the proposed

amendments. A Town Hall Meeting with the presence of the BOE members and Superintendent of Schools is necessary to help the county residents to

understand the proposed changes to the Policy. We need more transparency and accountability from the BOE members and the Superintendent of

Schools. Any detrimental decisions that made by the current BOE members and the Superintendent of Schools will adversly impact the futures of tens of

thousands of public school students. The taxpayers's dollars should go to the students, teachers and Schools not to the cost of their Legal Services. Difei Wang

185

I am deeply concerned about the changes of Board of Education Policy BOA. I need to know more details about the proposed amendments. A Town Hall

Meeting with the presence of the BOE members and Superintendent of Schools is necessary to help the county residents to understand the proposed

changes to the Policy. We should use the taxpayers's dollars to the students, teachers and Schools not to the cost of their Legal Services. Bingbing Deng



186



language should be removed. Nan Zheng

187

Please let me know what makes you want to change the legal service term at this time. What are you afraid of? What do you want to do? Are you the

enemy of parents of MCPS students? Who are you? Yanning Lin

188

I am deeply disappointed and concerned you want to change the legal service term at this time. You don’t have right to use tax payers’ money to against

tax payers. Stop your wrongdoings. Qiang Wan

189 We are deeply worried. It is a terrible idea to bus kids out of their neighborhood. Sally Daii

190

I Have deep concern on This proposal. I need more information to better understand why BOE added the following term to the policy: ”…in which highly

specialized legal expertise is required”. I especially worried about the cost of these Legal Service with such “highly specialized legal expertise”. Huiqi He

191 I'm deeply concerned. Bing Xia

192 I'm deeply concerned. Jian Song

193 I'm deeply concerned. Wendy Song

194

The public comment period is still open. County residents to submit letters online in opposition. A description of the policy is available on the following link,

under the heading "BOARD POLICY BOA, LEGAL SERVICES": https://www.montgomeryschoolsmd.org/departments/policy/policy-for-public-comment.aspx

Letters can be submitted here: https://mcpsweb.wufoo.com/forms/rgvf7vu194ul5v/ When submitting letters, it's important to be precise in stating the

specific language you object to. Here are some suggestions we think will be persuasive and encourage people to consider them when writing their own

response. - I strongly object to the language "and engage in strategic decision making to promote I strongly object to the language "Conducting and

supervising all aspects of litigation and administrative agency proceedings in which the Board, superintendent of schools, or other staff acting in the course

of their duties for MCPS are named as plaintiffs or defendants, including but not limited to legal support for special education proceedings, consistent with

Board Policy BLC, Procedures for Review and Resolution of Special Education Disputes." This does not offer the public sufficient protection from having to

finance the defense of public officials acting irresponsibly, unethically, with malfeasance, or in any other manner that does not serve the public good. The

public has a right to pursue legal action against officials in these cases without the secondary harm of having to pay for their defense. This language should

be replaced with language stating no county funds will be used for legal action where the Board, superintendent or any staff are acting as plaintiffs. The

revisions should include a clause stating that no county funds will be used in legal action where the Board, superintendent or staff is accused of acting in a

manner that is against public interest. Cheryl Ottenritter

195

I am deeply worried about need of legal services for BOE. This department should listen to the voice of parents and community and help children in MCPS

to succeed. This is the department will be appreciated the most if they are doing good job. I don’t see the need of legal services here. If they do, then I am

deeply concerned about the issue behind it. Stella Zhang



196 I am deeply worried, I am deeply concerned, please provide more information. Lihua Yin

197 I am deeply concerned. Li Zhi

198 I am deeply worried, I am deeply concerned, please provide more information, request public hearing, town hall Xueyong Zhi

199 I am deeply worried, I am deeply concerned, please provide more information haiyan lei

200

These are unnecessary changes - the Board already had provisions of hiring outside counse in the current version of the policy. If the general counsel is

unable to provide appropriate advice, then why have this position at all? The amended document reads as preparation for litigation that will likely follow

the ongoing boundary study should the tool delivered to the BOE be used to actually change school assignments to fit specific demographics Julia Timofeev

201 I am deeply worried, I am deeply concerned, please provide more information christopherwang

202 I am deeply worried, I am deeply concerned, please provide more information, request public hearing, town hall！ Cindy Gu

203 I am deeply worried, I am deeply concerned, please provide more information, request public hearing, town hall . wei ding

204 Include language to exclude use of a firm from which a board member may profit (i.e. if spouse is with a legal firm, that firm should not be retained) J Cohen

205 This will have huge impact on our community and schools. Can you please provide more information by public hearing? Jenny Liu

206 I’m deeply worried and concerned about the school district rearranging due to the difficulties of adapting process the students need to go through. Xi Yingchun

207 I am deeply worried, I am deeply concerned, please provide more information to MCPS students, parents /guardians and county residents. Anne Lee



208

Dear bOE Thank you for the opportunity to comment on. I have a son with an IEP and in the past we have retained legal service to represent us and

advocate for our son and his education. So this matter is important to me. - I strongly object to the language "and engage in strategic decision making to













that is against the public interest. - I strongly object to the language "The factors to be considered in the selection or retention of an attorney as outside

counsel include the quality of the attorney’s work, background and relevant experience, legal skills, commitment to diversity and equity, responsiveness

and sensitivity to the client’s needs, style and presence, freedom from conflict of interest, and management skills." These factors are purely qualitative and

no reasonable evaluation metric exists to evaluate them relative to other counsel, such as billable rates, costs related to travel / supplies / logistics, and

other demonstrable factors. This language should be replaced with language emphasizing cost efficiency, effectiveness and subject matter expertise of

counsel, in keeping the spirit of "efficient and effective" management mentioned elsewhere in this document. - I strongly object to the language "The

Board will contract with the attorneys or firms selected to serve as outside counsel, subject to renewal." Maintaining continuous, ongoing relationships

with outside counsel should be limited in scope to routine matters such as land use and not applied broadly to every legal matter the Board of Education

may face. This policy should prohibit outside counsel from being retained on a continuous basis for the defense of members of the Board of Education. - I

strongly object to the proposed policy in whole and encourage the Board to continue operating according to existing policy, with the addition of language

that the General Counsel will work under the direct oversight of the Superintendent of Schools. Reem Shalabi

209 Please provide more detail information, such as budget, goals, procedure. Suping Wang



210







parents and taxpayers why they need to seek such Legal Services at this time. Tony Wen

211 Really concerning, need more information! Eric Cheng

212 I am deeply worried, I am deeply concerned, please provide more information ning wang

213 I am deeply worried, I am deeply concerned, please provide more information lynn Tan

214 I am very concerned about the proposal. This does not make sense at all. Please provide more information and transparency to us tax payers. Thank you! Joanne Mao

215

I am very concerned and against this proposal. I request to have a public hearing and getting the votes from the tax payers before you can use the payer's

tax dollars for your legal activities. Thanks George Wade

216 I am deeply worried, I am deeply concerned, please provide more information. Yongmei Li

217 I，I am deeply concerned, I'm deeply worried, please Provide me more Information. Cong Wang

218 I am deeply worried, I am deeply concerned, please provide more information, request public hearing, town hall Xiangji Wang

219 Fuling Li

220




Service with such “highly specialized legal expertise” since this cost will be from the tax we pay. Wei Chen

221 I am deeply concerned, please provide more information. I would like to request a public hearing on this matter. Michelle Ji

222




Service with such “highly specialized legal expertise” since this cost will be from the tax we pay. Ning Cheng

223 I am deeply concerned about the change of the Legal Service policy. BOE should give detailed explanation or a public hearing why it is necessary. Haiqing Fu



224 I am deeply worried, I am deeply concerned, please provide more information！ WEI SHEN

225 I don’t think the decision is transparent, and I am concerned. Yan Zheng

226 I am deeply concerned, please provide more detail information or a public hearing why BOE need this change. Hong Liu

227




Service with such “highly specialized legal expertise” since this cost will be from the tax we pay. Thank you! Zhen Yuan

228 I am deeply concerned, need more information Jennifer Ku

229

I am deeply concerned by the latest proposed amendments in the draft Board Policy BOA Legal Services. First, Section A. I strongly object to the language

"engage in strategic decision making to promote equity and academic excellence for all students." Proscribing a specific course of action for how Legal

Services will be used is inconsistent with the goals of ensuring efficient and effective management of resources. This language should be removed.

Second, Section B.1(a)(2). I strongly object to the language "Conducting and supervising all aspects of litigation and administrative agency proceedings in

which the Board, superintendent of schools, or other staff acting in the course of their duties for MCPS are named as plaintiffs or defendants, including but

not limited to legal support for special education proceedings, consistent with Board Policy BLC, Procedures for Review and Resolution of Special Education

Disputes." This suggests opening a blank check to a law firm to provide legal services to any issues even that it might create public harm. This should be

replaced with language that no public county funds should be used to hire legal services for cases where the Board, superintendent of schools, or other

MCPS staff are accused of acting against public interests or of personal wrong doings. Section B.2(b). I strongly object to “The factors to be considered in

the selection or retention of an attorney as outside counsel include . . . commitment to diversity and equity . . . .” Requiring a commitment to diversity and

equity prescribes a specific course of action for how legal services will be used and is inconsistent with the goals of ensuring efficient and effective

management of resources. This particular mention of "commitment to diversity and equity" should be removed. More importantly, there is no mention of

"costs" in the consideration criteria. This is very irresponsible use of public funds if "cost" is not even in the consideration criteria when hiring an outside

counsel using public funds. Please fully consider above comments. Thanks! Jeff He

230 I am concerned about the policy. We need more time to think over the impact. Should be handled in a rush! Rebecca Xiang

231

I am deeply disappointed MCPS education policy, put politics above kids, pull kids out of local community to leave friends, let kids sleep less, exercise less,

especially study less. Any kids back from college, complaining big pressure because they never have mid term and final exam. If you want every kids

successful in their life, you need to let them know how to deal with pressure from High School, still close to parents. Please not delay that anti-depression

skill till college when far away. j liu



232

I am deeply concerned by the latest proposed amendments in the draft Board Policy BOA Legal Services. Section A. I strongly object to the language

"engage in strategic decision making to promote equity and academic excellence for all students." Section B.2(b). I strongly object to “The factors to be

considered in the selection or retention of an attorney as outside counsel include . . . commitment to diversity and equity . . . .” In both sections above,

Requiring "promoting equity", and "a commitment to diversity and equity" prescribes a specific course of action for how legal services will be used and is

inconsistent with the goals of ensuring efficient and effective management of resources. Both of those mentions should be removed. Please fully consider

above comments. Thanks! Bei Tang

233

I am deeply worried, I am deeply concerned, please provide more information. Please put aside slogans and put kids’ Education first. Invest in students,

invest in the system to support students and invest in teachers. Preserve what has been proven successful! Yin Zheng

234




Service with such “highly specialized legal expertise” since this cost will be from the tax we pay. Rong Huang

235 I am deeply worried, I am deeply concerned, please provide more information. Jane Li

236


especially worried about the cost of these Legal Service with such “highly specialized legal expertise”. Henry Wong

237 I am deeply worried. Helen Yang

238 Could you provide the detail? The above descriptions, you konw, are balalbala, sounding good, but useless, can anyone understand what to do actually? Chao Chu

239




Service with such “highly specialized legal expertise” since this cost will be from the tax we pay. Qiao Zhang

240


especially study less. Any kids back from college, complaining big pressure because they never have mid term and final exam. If you want every kids

successful in their life, you need to let them know how to deal with pressure from High School, still close to parents. Please not delay that anti-depression

skill till college when far away. Wuhong Pei

241 I am deeply worried, I am deeply concerned, please provide more information. Mingjiang Xu

242


especially study less. Yan Cai



243

I am deeply concerned about the proposed Amendments to Policy BOA and the timing of this change introduced by BOE. Wondering why BOE made it an

urgent matter to update Legal Service Policy at this time amid heated discussions about county wide boundary studies and school redistricting. More

information is needed to better understand why BOE added the following term to the Policy: "...in which highly specialized legal expertise is required." Why

is such highly specialized legal expertise needed in the first place? Why not spend money on school facilities and programs? I am really worried about my

next tax bill and an increasing cost of living in Montgomery county. Jenny Chen

244

MCPS’s good intention for changes is well respected. However, please find reasonable approaches to achieve this goal. Please also consider the rights and

benefits of the students and parents who are under represented by the current BOE. Transparency and fairness should not be compromised or ignored.

Different voices should be sincerely considered. Lastly, thank you for your hard work. Rong Wang

245

I am deeply concerned, and worried about the boundary issues in our school district. We need to make this process very transparent, and make every

parent’s voice heard. Julia Chin

246

Please explain why BOE found it is necessary to add “Provide advice and assistance to the Board as it carries out its quasi-judicial responsibilities in appeals

and hearings.” Hearings and appeals are part of BOE’s responsibilities. BOE should adhere closely to existing policies and practices. There is no reason such

events would require costly counseling. Further, hearings is a platform for citizens to express their thoughts on BOE’s policies. If BOE finds it necessary to

Introduce Legal Services then it should be reciprocal. All participants to the hearing including parents, students, and residents should be entitled to such

services provided exactly the same way provided to the BOE members. I am extremely troubled by the notion that the Board intends to bypass MCPS to

directly work with the counsel, effectively issuing itself a blank check with tax payer’s money. How the county citizens are assured of the transparency and

accountability if blatant abuse of power and corruption happen in the process? Check and balance mechanisms just be put in place for BOE to initiate any

Legal process. MCPS BOE can not nilly willy change policies so it can take cover under the Legal counsel. Legal Services are very expensive, which add

burden to the already limited school budget. BOE must answer to parents and taxpayers why they need to seek such Legal Services at this time. Yiwei Li

247 I’m deeply concerned. Please provide more detailed information on the proposed amendments. Jennifer Lee

248 Feng Li

249 I am deeply worried, I am deeply concerned! Feng Li

250

This page supposedly is inviting public comments on the Policy BOA yet even a link to the policy is not provided. Intentional or simply incompetent? I am

deeply concerned about the level of transparency surrounding the actions and proposals being made by BOA. Lian Yang

251

I am very concerned about this BOE policy change. MCPS has limited budgets and many schools have very poor conditions. MCPS should allocate its budget

on these schools and shouldn’t spend unnecessary money on legal issues. Considering rankings of MCPS schools are driving down lower and lower. BOE

should focus on more academics. Eric Zhao



252







parents and taxpayers why they need to seek such Legal Services at this time. q lli

253 I am deeply worried, please provide more information. Tongtong Lang

254 The issue is concerning and more information should be presented to the public for discussion, preferably in a town hall meeting. Thank you! Beilei Ge

255







parents and taxpayers why they need to seek such Legal Services at this time. Thank you Frank Zhang

256

It looks like overall, the BOE has more freedom with these updates to work with Legal counsel. Legal Services are very expensive, which add burden to the

already limited school budget. I feel BOE has the responsibility to explain to parents and taxpayers why they need to seek such Legal Services at this time.

It will be a better use of the money on improvement of schools instead of wasting students precious time and risking their safety by busing them out of

their neighborhood schools. Weimin Ritschel

257




Service with such “highly specialized legal expertise” since this cost will be from the tax we pay. Tingting Wang

258 I am deeply worried, I am deeply concerned, please provide more information Xiaoxiao Tang

259

Deeply concerned about this request. How does BOE pay for the expense? Use tax payers’ money? Highly recommend to hold a town hall meeting and

discuss related I formation. Karen Zuchady



260

Why cannot we use the money on improving the schools so we can still go to our schools where we have our long time friends and we are close to our

houses? It is a waste and risk to bus kids to a farther away school. What is the point to spend the money on legal service at this point? Selena Ritschel

261 I am deeply worried, I am deeply concerned, please provide more information. Shaojie Chen

262

I do not agree with many of the boards decisions therefore I do not agree with this change. I feel like the board is often going against the will of the local

residents. Colette Wella

263

Please keep children in local neighborhood schools. The school quality can only be improved through teaching, extended study and parenting. Please don’t

fool tax payers. Yve Young

264 I don’t think it is appropriate. I worry very much about it! Boping Liu

265 I need more detail information. Thank you! Stanley Shiu

266

As drafted, the Policy BOA vests unfettered authority in the Board of Education and its General Counsel to engage and fund outside counsel. The cost of

such engagements is potentially enormous. Further, outside counsel are not public officials but rather private sector entities that often reside outside of

Montgomery County. It is imperative that Montgomery County taxpayers receive assurance that the Policy will not result in wasteful, runaway costs, and

that engagements of outside counsel are subjected to appropriate fiscal supervision. Accordingly, Section C of the Policy should be amended to require

the Board of Education to seek and obtain, annually from the Montgomery County Council, the specific funds it proposes to use in connection with the

retention or continued retention of outside counsel. Jenney Shen

267

The public has to understand the change of the Legal Service policy. Why BOE did not explain to public the intention of these detailed updates? What does

this mean ”…in which highly specialized legal expertise is required”. Without any clarity and transparency Iam deeply cocerned that the taxpayers' money

being irresponsibly spent under the order of a handful of people who does not necessarily represent the diversity and majority of Montgomery County. Richard Lee

268

Strongly oppose bus in bus out policy, please consider kids mental and physical health, long bus route will definitely change their time schedule for after

school activities. Min Cao

269

As a parent of two Herbert Hoover middle school students, I am very concerned about the recent proposal to re-zoning or re-districting in our school

district. The very idea that parents have no control over what public school they can attend is unconstitutional and Un-American. We all worked very hard

to achieve the American dream of sending our kids to the best schools that we can afford to provide. We left Anne arundel county and came to

Montgomery county because it has the best schools in Maryland. I am not opposed to equality among all social classes and having kids come into schools

that have capacity to hold them but don’t want my kids to be taken out of their home schools. I feel that this change will cause additional stress and

endangerment of our children that is not necessary. I hope that you would reconsider your position. Thanks Jim Chen

270

Causing more traffic! Kids are kids, even for adults this is too much. What about after school activities? This if ridiculous! Worst than the communist

government. You can’t force kids to do something this crazy, causing more problems for the parents as well. Weiwei Blaisdell



271 I am deeply worried, I am deeply concerned, please provide more information. April Huang

272
























oversight of the Superintendent of Schools. Mark Meyerovich

273

I need detailed information to better understand about ”…in which highly specialized legal expertise is required”. I especially concerned about the cost of

such “highly specialized legal expertise” since this cost will be from the tax we pay. Proving more academic resources of public school teachers maybe

helpful instead of legal services. Also please consider about some items helpful to improve the kids’ time management (when they're young) on their

study, social activities, commute, and sleeping, etc. Xinli Zhang



274


Legal Service policy at this point. Jenny Feng

275 This is really a concern for such legal services. The budget should be used for good programs! Beeth Burgass

276 I am deeply worried and concerned! Yanzhen Tian

277 I am deeply concerned with the BOE proposal. BOE operations and policies need transparency and community inputs. It is too secretive now. Guowei Zhang

278 I am deeply worried, I am deeply concerned, please provide more details, and consider all the opinions. Fengxiang Cai

279 I am deeply worried, I am deeply concerned, please provide more information. Yushan Zhao

280

Any spending (with tax payers money) should be reasonable and responsible. The superintendent, as well as the BOE, should NOT abuse the managerial

power, especially after a lot irresponsible (potentially corruptive) budget items in recent years. So they should not be allowed to spend unlimited amount

of tax money on legal services, for their own protection! John Lee

281




Service with such “highly specialized legal expertise” since this cost will be from the tax we pay. Duosha Hu

282




Service with such “highly specialized legal expertise” since this cost will be from the tax we pay. Julia Ju

283 I am deeply worried, I am deeply concerned, please provide more information, request public hearing! Carry Ma

284 I am deeply concerned, please provide more information, would like to request public hearings or something similar yi chen

285 I am concerted that updated policy will offer too much protection to the board member. They are public servants and should put people’s interest first. Lu Li

286 Do not agree! No basis for this amendment. Please stop using taxpayers’ money to divide the county. People will be disappointed and leave the county. Eileen Lee

287

Any legal service initiated by MCPS BOE should be transparent and public awared. In addtion, BOE should listen to people's voice , and should not use tax

payers' money to requst legal service against tax payers. Weiming Ouyang

288 I am deeply concerned. Please provide more information to public. Yu Wang

289 I am deeply worried, I am deeply concerned, please provide more information！Thank you! Joy Liu

290 We are deeply concerned with any legal activities initiated by MCPS BOE. They should at least be transparent Quinn Ma



291 I am deeply worried and deeply concerned, please provide more information. Pei Tan

292 I am deeply worried, I am deeply concerned, please provide more information. San Zhang

293

Honestly, I am very upset. There may be lots of issues. Why someone wants to take all kid’s lift on high risk? Why someone wants to improve all family

burden? I feel so worried. Please put everything under sunshine. Who do the analyst? How? Who will take all responsibility when accidents goes up? Who

will pay the increasing cost because of bus in bus out? Who will guarantee kid’s safe? Xinhong Zhu

294 May I have more information about the legal services information? Is there any public hearing? Zemin Wang

295 I am deeply concerned, please provide more information, request public hearing. Be more transparent. Yan Ma

296 Please provide rationale of doing it so and the details of process. Is it really necessary to pay attention to it? Yu Ding

297

Dear BOE: I am deeply worried about current school boundary issues and data provided by the consulting company. Please provide more information. I

would request public hearing or town hall meeting for all residents in this county. Your attention to my request is greatly appreciated. Shawn Nie

298 We would like more details about this policy change! Thanks Jimg Jeanne Yan

299

I need more information to better understand why. I especially worried about the cost of these Legal Service with such “highly specialized legal expertise”

since this cost will be from the tax we pay. Shan Yang

300 I am deeply concerned about the expense this will involve. Please provide more information about this. Hongmei Gou

301




Service with such “highly specialized legal expertise” since this cost will be from the tax we pay. Bingchen Du

302

As everyone knows, MCPS has a limited budget. Every penny should be used effectively to help EACH student. I don't see the point to amend this policy

now that affirms the right of BOE to retain legal services without transparency. Wei Lu

303 I am deeply concerned about this. I requested more public hearings. Tao Liu

304 Please provide more information on the reasons for the amendments and the cost of legal services. Thanks. Tao Tao

305 I greatly concerned, and extremely worried. Please hold public hearing or town hall meetings to provide more information. Huixia Zhang

306 Can BOE explain to public the intention of these detailed updates? Please save extra time and money and don't bus out our kids. Thanks bingbing li

307 I am deeply worried, I am deeply concerned, please provide more information, request public hearing, town hall Yangjun Qin

308 No more misleading Mcps parents! We need more transparency and save some money for tax payers please Hoi ha Suen

309 Please provide more details and information. It would be good to have a town hall or public hearings. Thanks Ping Li

310 I am deeply worried, I am deeply concerned, please provide more information. Qin Shu

311 Stop WXY serving,don’t waste tax payers money any more Li Zhuang



312













will be used in legal action where the Board, superintendent or staff is accused of acting in a manner that is against the public interest. Dalong Huang

313 I am deeply worried, I am deeply concerned, please provide more information, request public hearing, town hall. Georgia Qi

314

I am deeply concerned about the change of the Legal Service policy. BOE needs to provide more information on why it is an urgent matter to update

Legal Service policy at this point. Why and what aspects of current policy are not working? Can BOE explain to public the intention of these detailed

updates? I need more information to better understand why BOE added the following term to the policy: ”…in which highly specialized legal expertise is

required”. I especially worried about the cost of these Legal Service with such “highly specialized legal expertise” since this cost will be from the tax we pay.

BOE has recently not been transparent about policies and intentions, which resulted in a lack of trusts to the MC residents. No trust, no blank checks to

BOE for legal services. Yishen Sun

315 I am deeply concerned about the change of the Legal Service policy. Wan Peng

316

I am deeply concerned about the change of the Legal Service policy. hope BOE can provide more information on why it is an urgent matter to update Legal

Service policy at this point.Can BOE explain to public the intention of these detailed updates? I need more information to better understand why BOE

added the following term to the policy: ”…in which highly specialized legal expertise is required”. I especially worried about the cost of these Legal Service

with such “highly specialized legal expertise” since this cost will be from the tax we pay. Grace Zhang

317

I am writing to oppose busing students not based on distance from home. We need improving but not moving. Busing students far away will hurt students

mental and physical health and safety hurt environment, wasting county's limited budgets. It cannot solve problems but only create problems. I am also

deeply worried and concerned about the transparency of redistricting analysis and representativeness of BOE members. Qin Li



318 I am deeply concerned, please provide more information, request public hearing, or town hall meeting Li Fang

319 I am deeply worried, you guys are turning heaven into hell. For your political target, please don’t let kids to sacrifice their future. Il Juli Chang

320 I am deeply worried! Jun Zhang

321

I am deeply concerned about the change of the Legal Service policy. And I need more information to better understand why BOE added the following term

to the policy: ”…in which highly specialized legal expertise is required”. I especially worried about the cost of these Legal Service with such “highly

specialized legal expertise” since this cost will be from the tax we pay. I hope BOE can provide more information . Flora Deng

322


Legal Service policy at this point. I need more information to better understand why BOE added the following term to the policy: ”…in which highly

specialized legal expertise is required”. I fail to see why it is an appropriate use of our tax dollars to involve “highly specialized legal expertise” in this

matter. Qian Li

323

BOE, The proposed amendments are using our tax dollars against taxpayers. Stop this BS. Take care of citizens' and taxpayers' children in school first, not

illegal immigrants' children! How about offer free breakfast and lunch to taxpayers' children? How about spend our tax dollars on improving local

schools? No bus in and bus out! Stop wasting our tax dollars to hire those BS consulting companies whch only generate data and anysis to fulfill your

socialism agenda. No bus in and bus out. No redistricting. Stay focused on improving local schools. Increase salaries for hardworking teachers. It is a

shame to increase salaries for BOE members! Current BOE members are doing nothing but destroying MCPS, further, Montgomery county. Your

socialism policies are destroying home values and pushing hardworking taxpayers to leave Montgomery county. Gavin White

324




Service with such “highly specialized legal expertise” since this cost will be from the tax we pay. Shu Fu

325

I am deeply worried, I am deeply concerned, please provide more information, request public hearing。 Please really think about education and care of

our kids,they are the future of this country. Xiao Chen

326

I think the Board and MCPS should Do better job to avoid such cricumstance. Do not violate the law. That will be all. I am deeply concerned the way the

board and MCPS is handling the boundary changes. Please provide more information, and such as public hearing, town hall should be requested Alex Wu

327

I am a mom of 3 kids ,deeply worried about the boundaries resign. I am deeply concerned.why boepay halh million to hire WXY to do the report.its

nonsense!!! neighbors for neighborhood school that's the common sense. please provide more information to support what you are doing.do you have

kids? Are you grand parents? We are taxpayers,we request more hearing. God bless us! Rachel Chang



328

I am deeply worried and concerned about the draft Board Policy BOA. It is more proper to provide more information to the public. I as a parent of current

student of public school, urgent the board of Education to provide more public hearings and carry out a countrywide parent and student survey on this

matter before critical decision be made! Zhigang Kang

329

I feel very confused and concerned about this draft, I strongly suggest the board to schedule a meeting to provide more information and answer our

questions. Thanks ChuanzhongJiang

330







parents and taxpayers why they need to seek such Legal Services at this time. Ed Wang

331 Deeply concerned. Chunqing Lin

332 Request public hearings Meizhen Hou

333

I am deeply concerned with the decision on spending huge fund in studying the option of bus-in bus-out. Please be more mindful of the consequences and

have more public hearing before moving forward. After all, it is our taxpayers’ money you are spending and our children being impacted. Xuan Liu

334 Outrageous abuse of using taxpayer money. NO!! Amy Bryan

335 We Are deeply worried, I am deeply concerned, please provide more information, request public hearing, town hall , Regards, Tom Tom Jin

336 I am deeply worried, I am deeply concerned, please provide more information, request public hearing, town hall Shuwen Zhang

337 I am deeply concerned. Please provide a town hall meeting. Jun Tian

338 I am deeply worried, I am deeply concerned, please provide more information, request public hearing, town hall. Shuying Gao

339 I am deeply worried, I am deeply concerned, please provide more information, request public hearing, town hall. YING LIU

340 I am deeply worried, I am deeply concerned, please provide more information, request public hearing, town hall TINGFEN YAN

341

I am deeply worried, I am deeply concerned, please provide more information, i am requesting public hearI going or town hall meeting for the public to

voice their concerns. Shaojian Gao

342 I am deeply worried, I am deeply concerned, please provide more information, request public hearing, town hall Xu Pengyu

343

大家点一下这个链接花一分钟哪怕是写一下I am deeply worried, I am deeply concerned, please provide more information, request public hearing, town

hall Maggie Yu

344 I am deeply worried and concerned. please provide more information and allow more time for public comment. Frank Liu

345 I am deeply worried, I am deeply concerned, please provide more information, request public hearing, town hall. Kelly Zhang



346 We don’t have time to send my kids far away for school. Judith Men

347

Concerning the proposals to change school boundaries, many students, including myself, have a main objection. Although we understand some current

schools are overcrowded, we disagree on changing school boundaries to create racially diverse schools. Diversity is a good thing; but on the contrary, it

should not be a justification for changing school boundaries, as students would be forced to reluctantly change schools. In the document "The Facts About

the District wide Boundary Analysis" by MCPS, a suggestion is made about the benefits of racially diverse schools; however, the research was conducted

from The Century Foundation, which is a organization with liberal bias. We hope this bias wasn't the basis of MCPS's initiative to change school boundaries

for the purpose of racially integrated school, but if that is the case, we hope MCPS can reconsider this initiative. Alex Zhang

348 I am deeply worried, I am deeply concerned, please provide more information, request public hearing, town hall Grace Li

349

I do not understand why BOE added the following term to the policy: ”…in which highly specialized legal expertise is required”. I worried about the cost of

these Legal Service with such “highly specialized legal expertise” since this cost will be from the tax we pay. A public hearing is necessary before any action

is taken. Weijie Chen



350
























oversight of the Superintendent of Schools. Alexander Umansky



351

Even though we all have the objective for students to succeed the BOE’s lack of transparency is concerning. You have ignored facts from many other

communities and states which have failed horribly with what you are attempting. You are acting on your own political agendas like a bunch of activists. You

are supposed to represent MoCo in our democracy for what the people want and what benefits the community and students. You are blindsiding the

community's by keeping all this a secret and now ignoring all rules of a democracy and hiding behind lawyers. Maybe if you poll the community and talk to

all of us then you won't have you hid behind lawyers and have no accountability and bypass the superintendent. Are you going to build an iron curtain and

continue to ignore MoCo residents. Put magnaget programs and special need programs into under utilized schools. This keeps students in their local

communities.this maintains social services in areas which need the most. If attendance is already an issue in farm then longer rides will make students even

less likely to attend. Lack of transportation, less time to study, extracurricular, less time to work, to watch siblings etc. students already get stranded by

buses and traffic is bad enough. Changing boundaries is proven to make things worse. You will widen the gap. Students succeed when parents start

teaching at home in preschool years, push high level classes, tutors etc. we are such a diverse community. You can't legally pool together whites, asians,

Jews for the convience of making your data false. Spend money on services for farms not on lawyers and why useless studies. How about polling

community to build a common goal. Learn from all the failures in other towns and save MoCo. Put the money into programs to help farms NOT hiding

behind lawyers. Start being accountable. You are leading MoCo into a disaster if you follow this mixture. Read proven reports it doesn't work!!! These.

Students aren't being less productive due to the schools. In all areas - the ongoing boundary study and changes to BOE policy - we should strive for

transparency so we can build common ground. The MCPS BOE recently proposed changes to your Legal Services policy. You deleted references to

accountability and allow the board to bypass the superintendent when you retain attorneys for advice and representation in legal matters. By doing this,

you are not report it to the public, decreasing the ability of Montgomery County residents to participate effectively in our democracy. WE plead wth you

to prioritize transparency and revert to the Legal Services policy’s original language surrounding this issue! Karen Eisenberger

352 I am deeply worried Wenlan Huang

353 I am deeply worried, I am deeply concerned, please provide more information, request public hearing, town hall Huan Zhang

354 I am concerned, please provide more information and be transparent Minli Liu

355 We are deeply concerned about the Board Policy BOA. Hearing need to be held in current situation. Much appreciated Guoying Zeng

356 We request town hall meeting/ public hearings! Minli Liu

357 I am deeply worried, I am deeply concerned, please provide more information Michelle Ma

358 I am deeply worried, I am deeply concerned, please provide more information Yin Lin



359

Hi. I read through the proposed amendments and have significant concerns. From the draft, I feel the BoE is trying to shift the accountability and

responsibility to the outside counsels. The draft sets up for potentially very expensive legal costs and does not have a mechanism to control the cost. I am

particularly troubled by this statement:” Proactively anticipating and addressing legal issues relevant to decision making by the Board and MCPS staff,”

proactively anticipating? This policy will create a black hole for sucking up all of the mcps budget! From the draft, public hearings or town hall meetings are

necessary to explain to the community why the amendments are needed and what mechanisms will be in place to control the expanses. We demand our

tax dollars to be used on students, not lawyers!! Joe Zou

360

I’m very concerned about the amendments. I urge BOE to provide more information on the amendments and its implications and consequences. I request

more public hearings and town hall meetings so people know more. Dandan Xu

361

This is outrageous! Getting outside lawyers can cause millions of taxpayer money at the moment of expected budget deficit in 2020! Our school facilities

need to be fixed, Updated, improve teacher pay, along with so many things school needs. I cannot believe our elected officials are so selfish and abuse the

power in their hand. We need to make BOE accountable for the failure of our schools. Shame on you, BOE! Cindy Chen

362 If you bus out my kid, one lawsuit will be ready for you. Gl Kev

363

I am wondering why BOE paid so much tax payers' money for the consulting of our county education, all those work should be done by the BOE

members,you have all the resource of the county, all information of students and schools, nobody knew better than you. Also there are so many

complaints about the policy,you also knew that,why you push this policy so rush,that needs more comments and time. I just want to let BOE do something

really works for the students for their improvements. Xinmin Liu

364

I am against this proposal. Not because the Board of Education should not have outside counsel, but because accountability in spending is essential. It

does not matter that you endeavor to be prudent. You have removed all accountability. For this reason, I am STRONGLY OPPOSED to Policy BOA, Legal

Services. David Bean

365

-The Board of Education should not be able to act unilaterally with regarding to outside lawyers, which can run into the millions of dollars. It's obviously

fine to hire outside lawyers, but at a time like this, when the County is in debt, this does not seem to be in the best interest of the residents. There needs to

be a check and balance of the taxpayers' money. Najiyah Khan

366

ACTION NEEDED TONIGHT (SUNDAY) BY MIDNIGHT: There's a Board proposal that allows them to hire outside attorneys without accountability from the

Superintendent. The key points: -The Board of Education should not be able to act unilaterally regarding to outside lawyers, which can run into the millions

of dollars. It's obviously fine to hire outside lawyers, but at a time like this, when the County is in debt, this does not seem to be in the best interest of the

residents. There needs to be a check and balance of the taxpayers' money. -At a time like this, when trust and accountability is not at its highest, having a

policy that REMOVES accountability only serves to create more distrust and concern. Paige Korb



367

I strongly oppose the amendment. Any amendment should require that cost-effectiveness be the primary consideration in engaging any outside legal

counsel, and in selecting legal counsel once the decision has been made to engage legal counsel. There should be oversight on both decisions. The

county's budget is not in the position to allow for anything less than the strictest control over outside legal fees. And taxpayers deserve the strictest

oversight of the board and superintendent in connection with, and most conservative approach to, spending taxpayer funds on outside counsel. Andrea Cheplo

368

I strongly oppose the amendment. Any amendment should require that cost-effectiveness be the primary consideration in engaging any outside legal

counsel, and in selecting legal counsel once the decision has been made to engage legal counsel. There should be oversight on both decisions. The

county's budget is not in the position to allow for anything less than the strictest control over outside legal fees. And taxpayers deserve the strictest

oversight of the board and superintendent in connection with, and most conservative approach to, spending taxpayer funds on outside counsel. Thomas Cheplo

369 I strongly oppose the amendments proposed by the Board of Education. These are unnecessary expenditures. Shyam Raju

370

I object to following term being added to the policy: ”…in which highly specialized legal expertise is required”. I worried about the cost of these Legal

Service with such “highly specialized legal expertise” since this cost will be from the tax we pay. A public hearing is necessary before any action is taken. A Parent

371

ACTION NEEDED TONIGHT (SUNDAY) BY MIDNIGHT: There's a Board proposal that allows them to hire outside attorneys without accountability from the

Superintendent. The key points: -The Board of Education should not be able to act unilaterally regarding to outside lawyers, which can run into the millions

of dollars. It's obviously fine to hire outside lawyers, but at a time like this, when the County is in debt, this does not seem to be in the best interest of the

residents. There needs to be a check and balance of the taxpayers' money. Lee Stern

372

As a parent of students in MCPS, the change of Legal Service has worried me deeply. As someone who do not possess legal expertise, I hope BOE can

provide more information on why it is an urgent matter to update Legal Service policy at this point. In particular, I would like to have more information to

understand need more information on why BOE added the following term to the policy: ”…in which highly specialized legal expertise is required”. Could

you please elaborate why the BOE needs highly specialized legal services? In what area do you think these service will be? Why is this different from

previously legal services? What has caused the change? I am no legal expert but I know legal services, especially highly specialized ones do not come

cheap. Will these cost be out of the education funds of our kids? How can we provide better oversight to the legal cost consumed by the BOE going

forward? Thanks so much for consideration and I would love to stay informed. Yi Gao

373

I do NOT agree with this draft policy. The Board of Education should not be able to act unilaterally regarding to outside lawyers, which can run into the

millions of dollars. It's obviously fine to hire outside lawyers, but at a time like this, when the County is in debt, this does not seem to be in the best interest

of the residents. There needs to be a check and balance of the taxpayers' money. Also, at a time like this, when trust and accountability is not at its

highest, having a policy that REMOVES accountability only serves to create more distrust. Shara Reiter



374

MCPS seems to be facing severe budget issues with the facilities that need to be upgraded and major construction of new schools. I am opposed to

reallocating funds from students for expensive excess legal counsel. Why is this necessary? If the BOE feels that effects of Policy FAA are going to cause

mass legal issues, perhaps we should be reviewing Policy FAA instead. As a parent and a taxpayer, I expect funds to be spent on education. Not politics and

legal battles. Thank you for reading. Amy Ruther

375

I do not believe that Board of Education should not be able to act unilaterally with regarding to outside lawyers, which can run into the millions of dollars.

It's obviously fine to hire outside lawyers, but at a time like this, when the County is in debt, this does not seem to be in the best interest of the residents.

There needs to be a check and balance of the taxpayers' money. We should rely on legal staff until the County’s budget situation improves. Also I believe

that BOE actions have seriously eroded trust and Therefore accountability must not be undercut, having a policy that REMOVES accountability only serves

to create more distrust and concern. I oppose this policy change! Steven Tvardek

376

This is a terrible policy to support an indefensible policy. The lack of transparency in the Board’s action is outrageous. To allow an unlimited amount of

taxpayer dollars to hire lawyers with no accountability is not right and the parents of MCPS students will not stand for this. We will vote you out. John Franklin

377

The Board of Education should not be able to act unilaterally regarding outside lawyers, which can run into the millions of dollars. It's obviously fine to hire

outside lawyers, but at a time like this, when the County is in debt, this does not seem to be in the best interest of the residents. There needs to be a check

and balance of the taxpayers' money. Deepti Navile

378

I highly disagree with the decision to give The Board of Education less oversight and a blank check. -The Board of Education should not be able to act

unilaterally regarding outside lawyers, which can run into the millions of dollars. It's obviously fine to hire outside lawyers, but at a time like this, when the

County is in debt, this does not seem to be in the best interest of the residents. There needs to be a check and balance of the taxpayers' money. -At a time

like this, when trust and accountability is not at its highest, having a policy that REMOVES accountability only serves to create more distrust and concern.

Please click here to share your comments. Jason Makstein

379

Absolutely not. This board has not been transparent and I am opposed to allowing them to have a blank check to pursue their agendas. They are elected

officials and in my mind have completely breached their duties to their constituents. Melanie Kahn

380

This policy is wasting people's money for mistakes that BOE members make. However, it is good for BOE members to know their decisions have a lot of

consequences, not only to each parent and kids impacted, but also legal and financial risk. So the members should be very careful for wide spread

decisions. Jay Black

381

I am concerned about the language ‘ to promote equity and academic excellence for all students’ in the paragraph above. Are you anticipating legal

expenses being used just for this purpose? Why would equity seem to be a cause of legal expenses? I believe the board should not allow over spending of

legal expenses( aka tax payers money) in any certain area. And it is the Board’s responsibility to avoid legal matters before it happens. We do not wish to

see the money that could make our kids education better to be spent on law suits and just make lawyers richer. Luopeng Su



382

The Board of Education has lost my trust in the manner in which changes to Policy FAA were made, at the last minute, without notification to the public. It

is for this reason legal action will commence. It is COMPLETELY UNACCEPTABLE for you to have unlimited taxpayer funds, paid without public oversight, to

mount your defense. People acting in a non-partisan manner for the benefit of ALL students wouldn’t need lawyers anyway. Right!?! Eric Eisenman

383 A blank check to engage with lawyers without any accountability to the public is not within our students best interests Rupa Dainer

384 Opposed Laurie Asher

385

The fact that the Board feels the need to protect itself in pursuit of equity, kind of seems like you all expect to be sued. Maybe the better use of the

Board's time would be to focus on closing the achievement gap using data-driven, PROVEN methods that do not uproot families over an ideological social

engineering experiment. Not using questionable data, a firm with little experience with large school districts (WXY), and a very limited dataset that looks

like it is clearly being used to give the appearance of not relying on race alone. I am not a lawyer, but even to the layman, this approach looks dicey.

Beyond the look of it, this change looks like it will cost the county more and make the board even LESS accountable. I personally cannot support something

like this, and the process should be independently examined. Stephen Austin

386 I am opposed to this policy. We need checks and balances. We need accountability. Noah Asher

387

I believe that the Board of Education should not be able to act unilaterally regarding the hiring of outside lawyers, which can run into millions of dollars.

Currently the County is in debt, and our schools need every penny they can get. This proposed new policy does not seem to be in the best interest of the

residents. At a time like this, when trust and accountability is not at its highest, having a policy like this only furthers the distrust. I oppose this policy

change and anything like it. Deborah Vergara

388

I oppose this strongly. The Board of Education should not be able to act unilaterally regarding outside lawyers, which can run into the millions of dollars.

It's obviously fine to hire outside lawyers, but at a time like this, when the County is in debt, this does not seem to be in the best interest of the residents.

There needs to be a check and balance of the taxpayers' money. -At a time like this, when trust and accountability is not at its highest, having a policy that

REMOVES accountability only serves to create more distrust and concern. Farnaz Edwards

389 I disagree with the proposed amendment to allow the BOE to hire legal representation. There should be more oversight. Mary Schuman

390

I strongly object the amendments to Policy BOA. Although it is probably fine to hire outside lawyers sometimes, the Board of Education should not be able

to act unilaterally regarding outside lawyers, which can run into the millions of dollars. With the County is in debt and short of funding everywhere, this

does not seem to be in the best interest of the residents to waste unnecessary money on outside lawyers. There needs to be some kind of accountability

mechanism to insure our tax money is not wasted. Right now, with the boundary analysis ongoing and lots of distrust toward BOE, this kind of policy

change makes one questions the motive behind it at such sensitive time -- it appears that the board wants to do away with anything they want without any

accountability by hiring expansive outside lawyers using taxpayer's money to cover themselves. This only deepens the distrust and concerns the public has

toward BOE. Yunfan Deng

391 I am concerned. Please provide more information about the amendment. Lin Guo



392

I strongly oppose this policy to hire outside legal services. I thought the board of education is there to improve the schools but looks like you are spending

money on attorneys, can't this money be used for hiring more teachers to help low performing schools? Ganesh Murugan

393 I am deeply worried, I am deeply concerned, please provide more information, request public hearing, town hall. Jianzhong Xu

394

I am not in favor of the draft policy BOA regarding the BOE to retain attorneys for advice and representation. We are currently in a situation where the

county is in debt, and this policy does not seem to be in the best interest of county residents. Sharon Morris

395

I completely disagree with the BoE being allowed to hire outside attorneys without any accountability. The BoE has already wasted an abundance of tax

paper money. To be allowed to spend freely without and checks and balances is irresponsible. They need to take a long hard look at every dollar they are

spending. I promise you that the parents are certainly paying close attention to every single dollar spent by the BoE. The wastefulness of funds is

overwhelming. Shelley Drost

396

We shouldn’t be wasting money on expensive attorneys to defend policies that SCOTUS has already deemed unacceptable. Spend that money where you

should, in the classrooms of under performing schools. Provide more programs, pay teachers that stay in these under performing schools more, pay for a

mentoring program. Don’t underfund ESOL. Marisa Safa

397 Angela Delrio

398

A blank check for attorneys is not aligned with the values of our county or with the ability to improve education for our kids. Please reject this policy and

put in the proper checks, balances and constraints to make sure that education of kids comes first. Andrew Ross

399

Absolutely not. Having spent tens of thousands of dollars in lawyers and consultants to receive special ed services from MCPS, they should not be able to

unilaterally spend money to the thwart it's constituency without strong oversight Melayne Cohen

400

I disapprove the policy. Legal fees quicky add up and there is not an apparent way to control and assure that our tax payer dollars will be spend in the most

responsable way. Angel Delrio

401

It is absolutely ridiculous that BOE thinks they should be able to unilaterally, without checks and balances, hire outside counsel without cost control or

accountability to the Superintendant or the county taxpayers. Diana Russell

402 I am opposed to this Policy BOA. As a lawyer I know how expensive legal services can be. I think the County ought to be using its funds elsewhere. Chase Sanders

403

I am opposed to the amendment! The BOE should not have unlimited access to for lawyers to defend them for mishandling and hiding changes to our

county’s school policies. These are my tax payer dollars and I find this to be outrageous. Tim Lee

404 Do not approve Neha Rali

405 Opposed! We should not have to pay an unlimited amount to cover the incompetence of the BOE. Ge Lee

406 Disagree. Boris Levonenko

407

I oppose the changes proposed in the amendment as there is no justification for the suggested changes, which will decrease accountability and

transparency in the process. Christine Morin



408

-The Board of Education should not be able to act unilaterally regarding outside lawyers, which can run into the millions of dollars. It's obviously fine to hire


and balance of the taxpayers' money. -When trust is not at its highest, having a policy that REMOVES accountability only serves to create more distrust

and concern. Evan Silverman

409

I oppose the changes proposed in the amendment as there is no justification for the suggested changes, which will decrease accountability and

transparency in the process. ChristopherMorin

410

At such a sensitive changing boundaries time, I am very concerned about BOE's using huge taxpayer 's money to hire expensive lawyers to oppose

taxpayers. Since most of students' parents are familiar with complicated laws, what BOE's doing is to try to prohibit students' parents from freely

expressing themselves. It is against the first amendment. BOE should stop spending huge taxpayer's money to hire lawyers and WXY consults. Since BOE

claimed that MCPS is short of budget, Such big money should be wisely used for improving the high poverty schools. Jizhou Wang

411

It seems that if the board is transparent and is not utilizing public taxpayer resources for their own agendas and policy actions, there should be no need to

hire outside attorneys for counsel. It is the obligation of the Board to present all agenda items to the public and upon the public’s scrutiny and subsequent

affirmation that all is beyond reproach, the agenda can then be brought forward. However, if attorneys are necessary to push agendas forward, the

accountability of the board falls into question and the board will need to rethink these agenda items. It is not fiscally responsible, nor morally just that the

board pursued their own agenda without consultation of the public and without approval of the public. David Kuo

412

I don’t see how the board is being held accountable for spending taxpayers money in an efficient manner. Consulting others isn’t a system of checks and

balances, it’s a hoop to jump through. I don’t support this. Eileen Russell

413

-The Board of Education should not be able to hire outside counsel without approval regarding outside lawyers without going through an approval process.

Because the County is in debt, this does not seem to be in the best interest of the residents. There needs to be a check and balance of the taxpayers'

money. -When trust is not at its highest, having a policy that REMOVES accountability only serves to create more distrust and concern. Sheryl Krauthamer

414

Why should the board be allowed to hire an outside attorney when the county is already over 100 mil in debt. I thought the county had its own attorneys.

And who provides oversight on who the board can hire? Do they have a blank check to hire the most expensive lawyers? Who decides who they hire and

what the cost is? I don’t like the wording of this Jeffrey Kuntz

415

I oppose to hiring outside legal service. The board of education should use its own resources and seek free in-kind legal advice. Further more it should seek

to serve the public and the children of the county and work ethically to avoid litigation. I don’t want my tax money to go to lawyers. I want the tax that

have increased lately to benefit the children, seniors and and the people really needing the services of the county. Liliana Casas



416

I do not agree that the BOE should have the right to obtain outside counsel. There are county attorneys for this type of work and they are paid a county

salary. Hiring an outside attorney can cost millions. The BOE is already at a loss for how to manage the debt. They should not be increasing expenditures for

unnecessary services such as outside attorneys. Crystal Mullens

417

I oppose these amendments. You reap what you sow. You are going to get hit with so many lawsuits because what you are doing is unconstitutional. You

will not get away with it. J M

418

I do not support this because I do not believe it is justifiable for the BOA to be permitted to use taxpayer money for its own legal defense. Nor is it

appropriate for the BOA to draft new policy language to suit its own needs to insulate itself from legitimate legal recourse. There needs to be

accountability to prevent over-reach by the BOE and superintendent. If legal action becomes necessary by concerned parents (who would pay their own

legal fees), the same should apply to the BOE. It appears the board is quite nonchalant/dismissive about the opposing views of thousands of parents who

support community schools because it feels protected by this policy. Thanks Something is not right here. Don’t we have checks and balances at the local

level? The superintendent should not be trusted to ‘consult regarding settlement’ in any future cases — an objective, external entity (I.e. the courts)

should take such a role. Dispute resolution should not be the only recourse in all instances. Governor Hogan is emphasizing ethics and accountability for

all government employees at all levels in Maryland, including elected members of the BOE. This policy does not sound ethical. Alison Moylan

419

I do not agree with changing the language of the legal policy regarding retaining private legal counsel. Please prioritize transparency in how you are

spending our money. Revert to the previous (Legal Services) document’s language (unrevised) about retaining outside counsel. Kelly Opipari Kelly Opipari

420 Stop wasting our tax dollars BoE, no wonder we are millions on debt!! Shame on you all! John Zack

421

The proposed Amendments to Policy BOA are not a good idea and should not be adopted. The Board should not be allowed to engage outside counsel

without accountability from the Superintendent and an independent ombudsman. The Board is using tax proceeds generated from Montgomery County

taxpayers and has a responsibility to husband those resources in a responsible and transparent manner. Outside counsel may be necessary on occasion

but outside counsel are expensive, costing hundreds of dollars an hour per attorney, if not more. Moreover, the Board should not be able to use taxpayer

funds to engage outside counsel in matters that are adverse to or affect Montgomery County taxpayers without full disclosure and open deliberation about

the need to engage outside counsel in a particular matter. Given the significant attention that is currently being paid to the Board's redistricting efforts,

and given that multiple lawsuits have been filed in response to the Clarksburg/Seneca Valley redistricting steps, it appears that the Board is seeking to

adopt the proposed Amendments to Policy BOA in an effort for Board members to have legal protection for their benefit rather than the benefit of MCPS

and the Montgomery County community as a whole. The proposed amendments to Policy BOA should be rejected. David Tayman



422

I am very against our tax dollars being used unilaterally without accountable by the BOE to hire lawyers. -The Board of Education should not be able to act

unilaterally regarding outside lawyers, which can run into the millions of dollars. It's obviously fine to hire outside lawyers, but at a time like this, when the

County is in debt, this does not seem to be in the best interest of the residents. There needs to be a check and balance of the taxpayers' money. -When

trust is not at its highest, having a policy that REMOVES accountability only serves to create more distrust and concern. Melanie Makstein

423 I strongly disagree with the proposed policy. It is ridiculous for the BOE to be able to hire lawyers to protect themselves without any oversight to cost etc. Alana Aschenbach

424 I am strongly against this proposal. Giving the BOA carte blanche to spend a limitless amount of taxpayer money with no accountability is unacceptable. Carolyn Ohlbaum

425 I am deeply worried, I am deeply concerned, please provide more information, request public hearing, Lin Chen

426

I strongly oppose the edits to this policy, and the use of my tax money for the Board of Education to unilaterally retain outside lawyers, which can run into

the millions of dollars. The BOE already has a general counsel who should be able to provide the necessary legal advice it may need on these matters. BOE

should focus on putting such money into hiring teachers, and the lack of accountability on who does not seem to be in the best interest of the residents.

There needs to be a check and balance of the taxpayers' money. Oscar Delgado

427 There should be a cap on the amount allowed to be spent and it should have oversight and need approval by a higher power. Roger Butt

428 I’m deeply concerned on this move. It potentially Leads to misuse of taxpayers money for political gain. I strongly urge public hearing on this move. Wenyu Sun

429 I am deeply worried, I am deeply concerned, please provide more information, request public hearing, town hall Jing Chen

430 I am against a policy that creates less oversight. Please reconsider these changes. Elise Vernick

431 NO!!! DISAPPROVE!!! M D

432

-The Board of Education should not be able to act unilaterally regarding outside lawyers, which can run into the millions of dollars. It's obviously fine to

hire outside lawyers, but at a time like this, when the County is in debt, this does not seem to be in the best interest of the residents. There needs to be a

check and balance of the taxpayers' money. -When trust is not at its highest, having a policy that REMOVES accountability only serves to create more

distrust and concern. Maria Tsitrin

433 As a parent of a MCPS student, I'm very concerned and strongly urged for public hearing. Chun Fang

434

I do not agree with the draft policy. I don’t understand why the phrase below was modified to exclude mentioning cost control and accountability. “ The

goals of this legal services management plan shall be that will facilitate both cost control and accountability and that will promote a high quality of service.“ Andra Kovalovsky

435 BOE should not be allowed to do this without any checks and balances. What are they scared of that they need to take such preemptive measures? Jake Zemparti

436 I need more information. Yanxuan Cai



437 I am deeply worried what BOE’s proposal! It will spend huge taxpayers’s money to hire lawyers. Please provide more information, and hold public hearings Yanli Zhao

438

The Board of Education should not be able to act unilaterally regarding outside lawyers, which can run the millions of dollars. It's obviously fine to hire


and balance of the taxpayers' money. -When trust is not at its highest, having a policy that REMOVES accountability only serves to create more distrust and

concern. Jianxun Dong

439

It is not in the best interest of Montgomery County taxpayers for the Board of Education to use outside lawyers that could possibly charge large unknown

amounts. The county is facing a debt crisis. There needs to be an accountability of the taxpayers' money. Fariha Haque

440

I am deeply concerned with the amendments - added the following term to the policy: "…in which highly specialized legal expertise is required”. Since we,

the taxpayers are going to pay the cost of these “highly specialized legal expertise”, public hearings will be needed before any action is taken. Carmen Lui

441

1. The factors to be considered also need to include cost. Otherwise, this policy gives MCPS a blank check. Add low cost as a factor. 2. MCPS does not

need to hire an outside law firm for proactive legal problem solving. Remove this part. 3. What does a firm's commitment to diversity and equity have to

do with their ability? Remove this part. Jeremy Rusnock

442

I disagree with this proposal. It is not fair for BOE to hire outside attorneys and it would be so costly. That would mean using a lot of our taxes and they

never listen to our communities. We already shared our concerns on our students' well being with the BOE as their boundary change decisions could make

very negative impacts on our children and cause our communities to fall apart due to long distance bussing away from our neighborhoods. It is not

reasonable and we expect the BOE to listen to us carefully and consider it since we pay them with our taxes but they have never listened to us and ignored

us completely. That is not acceptable. Rita Owens

443

Disapprove. This significantly highlights an alarming issue that you are asking to grant unilateral approval to resolve legal issues that are resulting from the

same board that is creating the legal and dispute matters. Insanity. Especially given the budget deficit/crisis in the county and the BOE wants unilateral

approval to hire attorneys to fight the issues they have caused. This is obscene. Given the current circumstances the Superintendent approval should be

required. Jon Walsh

444

I disagree with this change in policy and do not wish to see it implemented. The BOE should not be allowed to higher lawyers and waste money on legal

fees that should be going instead to support our schools and communities. Furthermore the BOE needs more transparency not less. This is bad policy and

should not be passed. D. DeRuyver



445

Not acceptable! Hiring legal representation is not a trivial matter. The board of education needs the input of all stakeholders on hiring lawyers to assure

that legal advisors are cost effective and serve the needs of MCPS parents and students. The input of MCPS parents is needed to do that. The Board of

Education is a public trust position and to sustain this trust must not take action to reduce oversight on their activities. Legal guidance and representation

can be very costly. This policy is akin to getting into a taxi with a meter with millions of dollars in fees accruing rapidly. As a parent of MCPS students, I do

not approve of a change in policy that allows the Board of Education to spend the money intended to educate the children of Montgomery County,

Maryland on lawyers without the oversight of MCPS parents. Leslie Kenna

446 I am deeply worried, I am deeply concerned, please provide more information, request public hearing, town hall Sherru Xiong

447

The BOE should not be able to hire lawyers without approval. We are having major shortage of funding and money spent on lawyers does not make sense.

There should be more visibility and transparency by the BOE in order for there to be trust. Carolyn Chou

448

We need accountability and transparency. This proposed policy does not achieve these goals so I am against giving to the BOE the ability to freely, without

accountability, choose legal representation of their choosing. Robin Dekelbaum

449 Yong Guang

450 I strongly disagree with this amendment. Nurit Coombe

451 Public oversight is needed - especially in light of the shortfall in revenue!! David Yang

452 Seems excessive to me Rami Kandel

453

I strongly appose busing students out from our neighboring school. Imagine one day our kids miss the school bus, I parents need to drive a long way to

send their kids to a faraway school, which creates more congested traffic conditions and elevates danger to both kids and parents. Xiaoxiao Pan

454

I worried about the cost of these Legal Service with such “highly specialized legal expertise” since this cost will be from the tax we pay. A public hearing is

necessary before any action is taken. we worried, we concerned, we want you everything clear. Hong Zhao

455

Please prioritize transparency and revert to the original language regarding legal services. It seems as though the proposed changes enable less democratic

engagement! Please allow us to participate as we always in the past! Chloe Rothstein

456

The Board of Education should not be wasting money or even authorized to spend money on separate attorneys. The county budget is not so funded that

this is a good use of funds. If funds were available, it would be better spent on teachers and school resources. This policy removes transparency for the

board and makes it unhinged and antagonistic to the community it serves. Instead of hiring attorneys to handle, the board needs to address in greater

transparency and through the feedback from the community affected by proposed changes This proposal is bad in economic effect and in the unhinged

nature of a board which shows no interest in addressing community concerns or feedback. Matthew Brobson

457

This is a poor use of school money. And a very poor way to address accountability and transparency for a board that is intended to serve the communities.

I strongly oppose Matthew Brobson

458 Request public hearing Yurong Men



459 I am deeply worried and concerned. Please provide more information. Thanks! Xiaolei Huang

460

Why BOE need more tax money? Is BOE anticipating law suits from its vastly unpopular bus-in-bus-out plan and troubled boundary changes? It looks to

me, the tax payers are paying BOE to fight against taxpayers. I am deeply concerned! Tingsheng Li

461

As a tax payer, I demand more details about the justifications behind these changes and methods put in place to oversee, monitor, and revoke the changes

in the future activities when general public feel BOE abuse its power. Absolute power with unrestrained legal support means dictatorship, which should not

happen in this land! Yunxiang Chen

OTHER

I strongly object to the language "and engage in strategic decision making to promote equity and academic excellence for all students." Proscribing a specific course of action for how Legal

Services will be used is inconsistent with the goals of ensuring efficient and effective management of resources. This language should be removed.

- I strongly object to the language "In consultation and collaboration with the Board, the superintendent of schools, and other authorized administrators of the school district, the general

counsel of MCPS shall be responsible for overall management of legal services." Public officials should be accountable for decisions about legal services. Language should be included requiring

explicit approval and oversight by the Superintendent of Schools.

- I strongly object to the language "Conducting and supervising all aspects of litigation and administrative agency proceedings in which the Board, superintendent of schools, or other staff

acting in the course of their duties for MCPS are named as plaintiffs or defendants, including but not limited to legal support for special education proceedings, consistent with Board Policy

BLC, Procedures for Review and Resolution of Special Education Disputes." This does not offer the public sufficient protection from having to finance the defense of public officials acting

irresponsibly, unethically, with malfeasance, or in any other manner that does not serve the public good. The public has a right to pursue legal action against officials in these cases without the

secondary harm of having to pay for their defense. This language should be replaced with language stating no county funds will be used for legal action where the Board, superintendent or any

staff are acting as plaintiffs. The revisions should include a clause stating that no county funds will be used in legal action where the Board, superintendent or staff is accused of acting in a

manner that is against the public interest.

- I strongly object to the language "The factors to be considered in the selection or retention of an attorney as outside counsel include the quality of the attorney’s work, background and

relevant experience, legal skills, commitment to diversity and equity, responsiveness and sensitivity to the client’s needs, style and presence, freedom from conflict of interest, and

management skills." These factors are purely qualitative and no reasonable evaluation metric exists to evaluate them relative to other counsel, such as billable rates, costs related to travel /

supplies / logistics, and other demonstrable factors. This language should be replaced with language emphasizing cost efficiency, effectiveness and subject matter expertise of counsel, in

keeping the spirit of "efficient and effective" management mentioned elsewhere in this document.

- I strongly object to the language "The Board will contract with the attorneys or firms selected to serve as outside counsel, subject to renewal." Maintaining continuous, ongoing relationships

with outside counsel should be limited in scope to routine matters such as land use and not applied broadly to every legal matter the Board of Education may face. This policy should prohibit

outside counsel from being retained on a continuous basis for the defense of members of the Board of Education. Gala Meyerovich



OTHER

I oppose this policy. I resent the Board hiring expensive legal representation in secret without input from their constituencies. The Board needs to

remember that they are elected by their constituency to serve their needs not to carry out social engineering. The ability to secure xpensive legal counsel

will thwart the residents from seeking redress in the court from their decisions. The BOE appears to be making decisions based upon their own agenda not

what is best for the students. We pay high taxes in Montgomery for quality education not for legal fees to protect rhemselves from their decisions that

were not made with adequate due process. I oppose strongly!! Myrna Parker

OTHER

- I strongly object to the language "and engage in strategic decision making to promote equity and academic excellence for all students." Proscribing a specific course of

action for how Legal Services will be used is inconsistent with the goals of ensuring efficient and effective management of resources. This language should be

removed. - I strongly object to the language "In consultation and collaboration with the Board, the superintendent of schools, and other authorized administrators of the

school district, the general counsel of MCPS shall be responsible for overall management of legal services." Public officials should be accountable for decisions about legal

services. Language should be included requiring explicit approval and oversight by the Superintendent of Schools. - I strongly object to the language "Conducting and

supervising all aspects of litigation and administrative agency proceedings in which the Board, superintendent of schools, or other staff acting in the course of their duties

for MCPS are named as plaintiffs or defendants, including but not limited to legal support for special education proceedings, consistent with Board Policy BLC, Procedures

for Review and Resolution of Special Education Disputes." This does not offer the public sufficient protection from having to finance the defense of public officials acting

irresponsibly, unethically, with malfeasance, or in any other manner that does not serve the public good. The public has a right to pursue legal action against officials in

these cases without the secondary harm of having to pay for their defense. This language should be replaced with language stating no county funds will be used for legal

action where the Board, superintendent or any staff are acting as plaintiffs. The revisions should include a clause stating that no county funds will be used in legal action

where the Board, superintendent or staff is accused of acting in a manner that is against the public interest. - I strongly object to the language "The factors to be

considered in the selection or retention of an attorney as outside counsel include the quality of the attorney’s work, background and relevant experience, legal skills,

commitment to diversity and equity, responsiveness and sensitivity to the client’s needs, style and presence, freedom from conflict of interest, and management skills."

These factors are purely qualitative and no reasonable evaluation metric exists to evaluate them relative to other counsel, such as billable rates, costs related to travel /

supplies / logistics, and other demonstrable factors. This language should be replaced with language emphasizing cost efficiency, effectiveness and subject matter expertise

of counsel, in keeping the spirit of "efficient and effective" management mentioned elsewhere in this document. - I strongly object to the language "The Board will contract

with the attorneys or firms selected to serve as outside counsel, subject to renewal." Maintaining continuous, ongoing relationships with outside counsel should be limited

in scope to routine matters such as land use and not applied broadly to every legal matter the Board of Education may face. This policy should prohibit outside counsel

from being retained on a continuous basis for the defense of members of the Board of Education. - I strongly object to the proposed policy in whole and encourage the

Board to continue operating according to existing policy, with the addition of language that the General Counsel will work under the direct oversight of the Superintendent

of Schools. Weishi Yuan

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