For Agency Use Only

Docket Number: ___________

Patricia DelGiudice, Board

President, Hamilton Township

Board of Education Mercer

County, New Jersey

Complainant

vs.

Jeffrey Hewitson, Hamilton

Township Board of Education

Mercer County, New Jersey

Respondent

BEFORE THE SCHOOL ETHICS

COMMISSION OF NEW JERSEY

SCHOOL ETHICS ACT

COMPLAINT FORM

I, Patricia DelGuidice, residing at 4 Connor Court,

Hamilton, New Jersey 08691, request the School Ethics Commission

to consider a Complaint against the above-named Respondent whose

home address is 33 Sedona Boulevard, Hamilton, New Jersey 08690,

in accordance with the authority of the School Ethics Commission

to entertain such complaints under N.J.S.A. 18A:12-21 et seq.

The facts upon which this Complaint is based are as

follows:

1. Statement of Facts: Board member Jeffrey Hewitson as a

member of the Superintendent Search Committee breached the

confidentiality of not only himself but of other Board members

by disseminating the names of the two finalists.

New Jersey.com and the Trenton Times printed articles prior to

the June 9, 2011 School Board meeting naming the District’s two

finalists for the Superintendent’s position. Mr. Hewitson is

quoted in both articles indicating that Barbara Frascella and

Lou Goldstein were the two finalists and that Lou Goldstein was

poised to become the successor to retiring Hamilton

Superintendent Neil Bencivengo. This violation breached the

confidentiality of the Superintendent Search Committee at which

time all members were told and advised in numerous emails from

Superintendent Search Committee Chair Person, Patricia

DelGuidice that this procedure is confidential and privacy must

be maintained to the utmost.

Date of occurrence: June 2011

I assert this to be a violation of N.J.S.A. 18A:12-24.1(g)

For Agency Use Only

Docket Number: ___________

2. Board member Jeffrey Hewitson removed confidential material

from the Board Solicitor’s office without proper authority. On

March 18, 2011 Jeffrey Hewitson as a member of the Hamilton

Township Board of Education and Anthony Celentano, a Hamilton

Township School District employee, presented themselves at

Destribates & Campbell. Mr. Hewitson requested information

pertaining to two candidates for Superintendent. Mr. Hewitson

retrieved the information and reviewed the information and at

that point requested from the Board Solicitor a copy of

documents as he was on his way out of town. The Solicitor

advised Mr. Hewitson that he was not going to disclose any of

the information or resumes with anyone and he was further

advised he was not to copy the documents. Mr. Hewitson indicated

to the solicitor that he had the authority to receive the copies

and at that time the Solicitor complied with Mr. Hewitson’s

request and presented him with copies of the candidates’

resumes.

On Saturday, March 19, 2011 the Board Solicitor spoke with Vice

President Patricia DelGuidice who was the Chair of

Superintendent’s Search Committee who informed the Solicitor

that Mr. Hewitson was only approved to review the documents in

private and was not to remove any of the documents. Shortly

thereafter Mr. Hewitson appeared at the Solicitor’s office and

told him he did not release any of the information to anyone and

then returned the documents.

This is in violation of Breech of confidentiality again by Mr.

Hewitson with regard to the Superintendent search.

Date of Occurrence: March 2011

I assert this to be a violation of N.J.S.A. 18A:12-24.1(g)

3. Statement of facts: Jeffery Hewitson and Anthony Celentano

advised me that in June 2011 that if I did not vote for the

internal candidate for superintendent he would be filing an

Ethics Complaint against me with regard to my role as

Chairperson of the Superintendent Search Committee. This threat

was proven correct by the June 8, 2011 article in NJ.com where

Mr. Hewitson indicates that he was filing an Ethics Complaint

against Patricia DelGuidice, Chairperson of the Superintendent

Search Committee. This article appeared on June 8, 2011 one day

prior to the June 9, 2011 Board meeting in which the Board of

Education had placed on the Agenda the appointment of Lou

For Agency Use Only

Docket Number: ___________

Goldstein as Superintendent for the Hamilton Township School

District. This article in the newspaper one day prior to the

appointment of Lou Goldstein was done in a malicious and

inappropriate manner to impugn my integrity and tarnish the

process of the District naming Lou Goldstein as Superintendent.

Date of occurrence: June 2011

I assert this to be a violation of N.J.S.A. 18A:12-24.1(f)(g)

4. Statement of Facts: On or about March 2011 Jeffrey Hewitson

scheduled a meeting with Vince McKelvy, the president of the

Hibernian’s, as well as Tony Celentano to discuss the upcoming

election. I was confronted by Mr. McKelvy with the names of the

candidates for the Hamilton Township Board of Education

Superintendent’s position. This is a complete violation of the

Breach of Confidentiality in that Mr. Hewitson was disseminating

the names of the individuals who applied for the position to

become Hamilton Township Board of Education Superintendent.

Date of occurrence: March/April 2011

I assert this to be a violation of N.J.S.A. 18A:12-24.1(g)

5. Statement of Facts: On or about August 11, 2010 Hamilton

Township School Board member Jeffrey Hewitson voted for a

contract for the Mercer County Arc. Mr. Hewitson is a Trustee at

Mercer County Arc and therefore violated N.J.S.A. 18A:12-24(c)

wherein he has acted in his official capacity in a matter where

he has a personal involvement that creates some benefit to

himself as a Board of Trustee member for Arc.

Date of occurrence: August 2010

I assert this to be a violation of N.J.S.A. 18A:12-24.1

WHEREFORE, I, as Complainant, request that the School Ethics

Commission find and determine that the above-named Respondent

has violated the School Ethics Act and that he be subject to

such penalty as provided by the Act.

Date: __________________ _____________________________

Signature of Complainant

Or her Attorney

For Agency Use Only

Docket Number: ___________

CERTIFICATION UNDER OATH

Patricia DelGuidice, of full age, being duly sworn upon her

Oath according to law deposes and says:

1. I am the Complainant in this matter.

2. I have read the Complaint and aver that the facts contained

therein are true to the best of my knowledge and belief and I am

aware that the statute that created the School Ethics Commission

authorizes the School Ethics Commission to impose penalties for

filing a frivolous Complaint. N.J.S.A. 18A:12-29(e). I am aware

that if the Respondent alleges that the Complaint is frivolous,

I shall have 20 days from receipt of the Answer to respond to

the allegations.

3. The subject matter of this Complaint is not pending in any

Court of Law or Administrative Agency of this State. I will

advise the School Ethics Commission if I subsequently become

aware that it is pending elsewhere.

____________________________

Signature of Complainant

Date: ______________

Sworn and subscribed to before me this _____ day of ____________

Notice: All final decisions issued in connection with

complaints that come before the School Ethics Commission for

review and determination are public records uniformly posted on

the Department of Education’s website at

http://www.nj.gov/education/legal. As a general rule, selective

requests to remove a particular decision for reasons of personal

preference are not entertained.