Santa Clara County Grand Jury • 2017-2018

Alum Rock Union Elementary School District*

Published: October 18, 2018 31 pages Consolidated Report

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Findings 7 findings

Alum Rock Union Elementary School District Board Trustees Herrera, Marquez and Tran by action and/or inaction, have subjected the District to financial peril, public scorn and distrust. District Response to Finding 1. Disagree. The District is comprised of approximately 11,270 students. According to the California Department of Education's Data Reporting Office, approximately 86.5% of the students are Latino and 79.2% qualify for free and reduced lunch. On June 7, 2016, the District asked the voters of Alum Rock to approve a bond measure titled, "Alum Rock Union School District, California, Bond Issue, Measure I (June 2016). ("Measure I"). The following question appeared on the ballot: To improve local neighborhood schools, fix leaky, deteriorated roofs, improve fire safety, repair/upgrade classrooms, improve student safety and security, renovate outdated restrooms, upgrade heating/ventilation/electrical systems for energy efficiency, and computer technology, shall $139,999,671.60 of Alum Rock Union Elementary School District bonds approved by the voters in June 2008, be reapproved at legal rates to renovate, acquire, construct, repair classrooms, sites, facilities/equipment, with independent audits, citizens' oversight, no money for administrator salaries and all money controlled locally? (emphasis added). A fifty-five (55%) supermajority vote was required for the approval of measure I. The Alum Rock voters responded to the bond measure with a resounding, "yes" and approved Measure I by 78.75%- significantly higher than the statutorily required supermajority. Despite the loud mandate by the Alum Rock taxpayers to fix the local schools, the governing Board's efforts to move forward with their bond program has been largely derailed due to the Santa Clara County Office of Education and the County Superintendent, Mary Ann Dewan's consistent interference with the governing Board's attempt to comply with the voter mandate. Board President Herrera, and Trustees Marquez and Tran who were duly elected by the voters of the Alum Rock community to the District's Board of Education have been diligent stewards of tax payer dollars and made decisions they believe are in the best interest of the students and families of the District. Board President Herrera, and Trustees Marquez and Tran are cognizant of the demographics of the families the District serves-immigrant, working class, and the mandate of the voters who approved their bond program. Pursuant to the Constitution, the voters of Alum Rock decide who will be entrusted with the oversight of their local schools. They have spoken loud and clear, time and time again. Board President Herrera has been re-elected to his seat by the voters of Alum Rock six times. Trustee Marquez has been reelected to her seat on the Board three times. On two of the three occasions, Trustee Marquez received the most votes out of all candidates. Trustee Tran ran for a congressional seat in June 2018 and came in third, countywide, on the ballot against a sitting Congressional incumbent. Honorable Lucas October 18, 2018

District's legal counsel concluded that Measure I and Measure J Construction Management contracts between the District and Del Terra likely violate Government Code section 1090. District's Response to Finding 2. Agree that the District's previous legal counsel Rogelio Ruiz from Rehon & Roberts prepared a memorandum in which he stated, "there is a material risk that a fact finder could reasonably conclude that the referenced contracts violate Government Code section 1090." "Material risk" is not to be confused with a legal determination by judge or jury. "Material risk" means instead that there is a potential that the contracts in question might run afoul of Government Code section 1090. It means that it is also possible that a finder a fact could conclude the contracts do not run afoul of Government Code section 1090. That determination, as referenced in the Ruiz opinion, should be left to a "fact finder" in a court of competent jurisdiction, where a judge should make that legal determination. Therefore, disagree with the conclusion that the contracts likely violate Government Code section 1090. The District and governing Board relied on the legal guidance of the attorney's retained by the District at that time, in awarding, drafting and approving the contracts referenced in Mr. Ruiz' legal opinion. The alleged legal deficiencies were never brought to the Board's attention when the contracts were awarded. It is also important to note, that in an effort of full transparency, the governing Board voted to waive the attorney-client privilege and disclose the Rehon & Roberts memorandum.

The District does not consistently use best practices in awarding contracts. District's Response to Finding 3. Agree that District staff would benefit from training on public entity contracting. After going through the last several years with six interim Chief Business Officials ("CBO"), the District has now hired a permanent CBO. The Board is confident that with a permanent CBO coupled with training for staff the District contract awarding practices will follow statutorily prescribed laws and regulation.

Using the same contractor for both Construction Management and Program Management is not an accepted best practice, and according to the District's legal consultant, can put the district in financial and legal jeopardy. District's Response to Finding 4. Disagree. School districts and community college districts throughout the State award construction management and program management contracts to the same contractor. Through its wisdom, the Legislature has authorized various project delivery models and delegated to local school governing boards the ability to select among the various construction delivery models which option best fits the Honorable Lucas October 18, 2018 needs of the district. There are four project delivery methods available to school districts: (1) design/bid/build, (2) design/build, (3) lease-lease back, and (4) construction management. (See Education Code §17400 et. seq.; Government Code §4525). School construction in California, using any of these delivery models, is governed by comprehensive and complex laws and regulations and requires school districts to employ experts in numerous fields including, architecture, finance, environmental, legal, etc. Thus, many school districts, such as Alum Rock do not have the staff capacity to manage multi-million-dollar school construction programs in house and rely on a construction delivery method that provides for a company that manages both the bond program side and the construction side of the bond program-a legally permissible and frequently used project delivery method. Inherently, a multi-million-dollar construction project, for a private company or any public entity carries with it the possibility of legal exposure. However, it is absolutely an incorrect conclusion that a construction management/program management delivery option per se, puts the district any more "in financial and legal jeopardy" then any other construction delivery model. Prior to the Santa Clara County Office of Education's involvement in the District's bond program, the litigation or threat of litigation related to the bond program was minimal, if at all.

The Board has repeatedly not followed the Brown Act requirements. District's Response to Finding 5. Disagree. The Ralph M. Brown Act ("Brown Act") codified in the Government Code requires that all meetings of a legislative body be open and public, except under limited situations. Cal. Gov't. Code §§54950 et. seq. The Brown Act allows a legislative body during a meeting to convene a closed session in order to meet privately with its advisors on specifically enumerated topics. The Report identifies two instances where the Santa Clara County's Office of Education's ("SCCOE") fiscal advisors wrote to the Board President regarding what they alleged were Brown Act violations. The Report states, "the violation occurred when Trustees attempted to discipline the District Superintendent without giving her proper notification." The second alleged violation occurred with the "Board's Facilities/Bond Projects Committee . . . failed to provide proper notice and minutes." The alleged violation was written in a letter from SCCOE's fiscal advisor. It is worth noting that the fiscal advisor is not an attorney. The letter suggests a complete lack of understanding of the Brown Act. The Brown Act does allow closed session related to personnel matters. Relevant here and most importantly, the Brown Act also allows closed session to discuss anticipated litigation. The Board discussed an ongoing investigation regarding potential illegal conduct under anticipated litigation as legally permitted under Government Code section 54956.9(d)(2). Although the agenda also included an agenda item titled, Public Employee Discipline/Dismissal/Release (Government Code Section 54957), the Board did not have a discussion under this item. Even assuming the Board had discussed personnel matters, which it did not, the Courts have held that a notice requirement to an employee only apply when the proceeding is adjudicative in character. See Fischer v. Los Angeles Unified Sch. Dist., 70 Cal. App. 4th 87, 93 (1999); Furtado v. Sierra Cmty. Coll., 68 Cal. App. 4th 876, 879 (1998); Bollinger v. San Diego Civil Serv. Com., 71 Cal. App. 4th 568, 571 (1998); Kolter v. Comm'n. on Prof'l. Competence of Los Angeles Unified Sch. Dist., 170 Honorable Lucas October 18, 2018 Cal. App. 4th 1346., 1349 (2009). Not only was SCCOE's fiscal advisor's letter incorrect as to the law, his role as a fiscal advisor to the District calls for him to act in a neutral, objective capacity. The District cannot address the broad, general alleged second violation since the Report does not provide any examples of when and how notice for the Facilities subcommittee was not properly given, nor is it clear to the District how the minutes relate to the alleged noncompliance with the Brown Act.

The Board failed to follow their own Board By-Laws on numerous occasions. District's Response to Finding 6. Disagree. The Report's alleged finding related to awarding of a construction contract based on a vote of three in favor and two against. The Reports finding claims that Board By-Law 9005, "which in part states, to 'maximize Board effectiveness and public confidence in district governance, board members are expected to govern responsibly and hold themselves to the highest standard of ethical conduct" was violated. The alleged supporting fact for this finding is nonsensical. In an effort to be responsive, the District responds that the governing Board has acted in a manner that addresses first and foremost the educational needs of the students. As outlined in response to Finding 4, the Board has complied with the complex statutory regulations governing school construction projects. They have done so in a thoughtful and ethical manner in full compliance with Board By-Law 9005.

The Board did not adequately vet all applicants in the selection of the current General Counsel. District's Response to Finding 7. Disagree. On October 27, 2017 the District released a Request for Proposals for Legal Services, (RFP No. 1718-BUS02) (Exhibit 1). The purpose and intent stated in the RFP was "to competitively solicit firms." The responses to the RFP were due to the District on November 22, 2017. The District received six (6) responsive proposals from law firms statewide. The Board members received copies of the proposal to review and analyze. The Board agendized the awarding of the contract at three (3) public hearings before awarding the contract. The successful firm was selected at the Board's February 8, 2018 Board meeting, four months after the RFP was issued and three months after all the responsive proposal were distributed to the Board and staff. The Legislature has broadly authorized contracting for specified "special" services and codified such exception at Government Code section 53060, which provides: "The legislative body of any public or municipal corporation or district may contract with and employ persons for the furnishing of the corporation or district special services and advice in financial, economic, accounting, engineering, legal or administrative matters if such persons are specially trained and experienced and competent to perform the special services required." (emphasis added) Although the governing Board was not legally required to competitively bid legal services, it did. It did so, through a very comprehensive, public and competitive process requiring detailed information on the prospective law firm's legal experience. Of the thirty-two (32) school districts in Santa Clara Honorable Lucas October 18, 2018 County, including the Santa Clara County Office of Education, one would be hard pressed to find an RFP for general counsel services. The District's governing Board went above and beyond what is legally required to obtain the most qualified law firm for their immediate legal needs. The selection process lasted months in order to ensure a thorough vetting and significant public input.

Recommendations 14

R1

Trustees Herrera, Marquez and Tran Should immediately resign their positions on the Board. District's Response to Recommendation 1. Given that the grand jury does not have the legal authority to dictate who should hold an elected position on Alum Rock Union School District's governing Board, this recommendation will not be implemented. The District will not agree to strip the voters of the Alum Rock community of their constitutional right to elect Trustees to govern their local school district. The District has requested that the Presiding Judge determine if this recommendation is a violation of the constitutional rights of the individual Trustees and the voters of the Alum Rock community; notably, in light of the fact that the grand jury calling for the resignation of three of the five governing Board Members is comprised of an all-white jury, not reflective of the Alum Rock community.
R2

Narrative and Biographical Information (up to 12 pages) - Provide a description of your qualifications for providing legal services in the area(s) of specialization you desire to perform services. Include descriptive and supportive evidence of how your firm will maintain a close working relationship with the District. Indicate ongoing commitments to the professional education of staff members, association with school connected organizations (i.e. CASBO, CASH), total number of permanent employees, and any other data that may assist the evaluation team in understanding your qualifications and expertise. The narrative should outline the tasks and services your firm will perform for each area of specialization. Include a short biographical vita on each member of the firm you propose to assign to the District for each area of specialization you are responding to. This section shall contain no more than 12 pages: two-page maximum per area of specialization with a maximum of 12 pages total if responding to aJI six areas of specialization.
R2a

The Board should terminate the Measure I and Measure J Construction Management contracts between the District and Del Terra by October 1, 2018. District's Response to Recommendation 2a. The Board has a fiduciary obligation to consider any legal risk associated with terminating a contract, evaluate the implications to its bond program related to the delay in selecting a new construction company, consider increasing costs associated with school construction delay and ultimately how these issues impact the educational needs of the students. As a responsible elected body, the District will not rush to terminate its contract with the District's bond's Construction Management company by an arbitrary date. It is the Board's obligation to act as prudent stewards of the Alum Rock tax payer's monies, and to manage the construction program in a manner that is most beneficial to the students and families of Alum Rock. The recommendation with an arbitrary date to terminate the contract will not be implemented. In addition, the grand jury is legally precluded from inquiring as to the merit, wisdom or expediency of policy determinations which fall exclusively within the Board's authority. Any such consideration by the Board of this recommendation will be done in a duly noticed meeting in full compliance with the Ralph M. Brown Act ("Brown Act").
R2b

The District should retain an outside legal consultant by October 1, 2018, to consider options to evaluate remedies against Del Terra. Honorable Lucas October 18, 2018 District's Response to Recommendation 2b. As described in response to Finding 7, the District issued a Request for Proposals and solicited proposals from law firms across the State. Retaining new legal counsel was further done in response to the Fiscal Crisis Management Assistance Team ("FCMAT") recommendation. However, as stated in response to Recommendation 2a, the District will not agree to rush and get involved in costly, protracted litigation. The Board will continue to be prudent and thorough in evaluating how to proceed in the best interest of the students, families and taxpayers of Alum Rock. The recommendation directing the District to get involved in costly protracted litigation will not be implemented. Any further consideration of this recommendation will be done at a duly noticed meeting in full compliance with the Brown Act.
R3

The District should immediately begin using competitive bidding (e.g. RFP/RFQ) for all construction projects and professional services. District's Response to Recommendation 3. As a public entity, the process by which contracts are awarded are statutorily regulated, including but not limited to the requirement that all contracts be ratified by the Board at a duly noticed meeting. In addition to ensuring that the District fully complies with all legal requirements in awarding contracts, the Board takes into consideration which contracting approach best meets the needs of the District, as way of example, piggybacking of the approved list of vendors from another local, state or federal agency. In addition, state law permits, and the educational needs of students demand that in instances of emergencies, as way of example, using an RFP/RFQ would be detrimental to the educational needs of the students. This broad sweeping recommendation is unreasonable and impractical and therefore will not be implemented.
R4

Fees/Services Schedule - Respondent is requested to submit a proposal to furnish all of the labor, materials, and other related items required for the performance of the contract resulting from this RFP on a labor rate basis. Be as thorough and specific as possible as this will form the basis of any contract for services that may be presented by the District. Provide your fees on the Pricing Sheet included with this RFP ( ).
R4a

The District should enact a Board policy prohibiting the award of future Construction Management and Program Management contracts to the same company by December 1, 2018. District's Response to Recommendation 4a. In making decisions on which school construction delivery model to use, the Board will be guided not only by what is legally permitted, but also by what is in the best interest of the District. Please see response to Finding 4 for additional information. This recommendation will not be implemented. In addition, the grand jury is legally precluded from inquiring as to the merit, wisdom or expediency of policy determinations which fall exclusively within the Board's authority.
R4b

The District should award all future Construction Management and Program Management contracts to unrelated contractors. District's Response to Recommendation 4b. In making decision on which school construction delivery model to use, the Board will be guided not only by what is legally permitted, but also by what is in the best interest of the District. Please see Honorable Lucas October 18, 2018 response to Finding 4 for additional information. This recommendation will not be implemented. In addition, the grand jury is legally precluded from inquiring as to the merit, wisdom or expediency of policy determinations which fall exclusively within the Board's authority.
R5

The Board should obtain a comprehensive Brown Act training from a qualified third party, by December 31, 2018, and of the swearing in of new Trustees. District's Response to Recommendation 5. The members of the governing Board already participate in Brown Act trainings from statewide and national organizations, including, but not limited to the California School Boards Association and the National School Board's Association. The Board will continue taking such trainings and will encourage newly elected Board members to do the same. Legally, this Board cannot impose the training requirement on future elected Board members. The permissible portion of this recommendation has already been implemented. The District does agree that District staff and all consultants assigned to work for the District, including but not limited to the SCCOE fiscal advisors should receive training on the Brown Act.
R6

All current Board members should sign a declaration saying they have read, understood and will comply with the Board By-Laws, and any subsequent revisions, by September 30, 2018. Future Trustees should sign the same declaration of their swearing in. District's Response to Recommendation 6. The members of the governing Board already comply with and are legally required to comply with their own adopted By-Laws. Signing an arbitrary declaration, by an arbitrary date, saying they will do what they must do by law does not add any further force or effect to a legally required mandate. This governing Board does not have the legal authority to impose conditions for holding office for future Board members. There is no need to implement this recommendation given that the compliance portion of the recommendation has already been implemented.
R7

The Board should terminate the contract with its General Counsel and use a competitive process (RFP/RFQ) that includes a proper vetting mechanism to hire new General Counsel by December 31, 2018. District's Response to Recommendation 7. As discussed in more detail in response to Finding 7, on October 27, 2017 the District released a very comprehensive and thorough Request for Proposals for Legal Services, (RFP No. 1718-BUS02). The responses to the RFP were due to the District on November 22, 2017. District staff and the Board members took nearly three months to review and vet the responsive proposals. The District does not see the need to implement this recommendation by reissuing a new RFP for legal services since the Honorable Lucas October 18, 2018 EXHIBIT 1 Alum Rock union School REQUEST FOR PROPOSAL RFP No. 1718-BUS02 FOR LEGAL SERVICES Deadline: 3:00 p.m., Wednesday, November 22, 2017 (NOTE: The time clock in the Purchasing Department will be used as the official time.) Alum Rock Union Elementary School District 2930 Gay Avenue San Jose, CA 95127 http://www.arusd.com For Information Contact: Kolvira Chheng Assistant Superintendent, Business Services 2930 Gay Avenue San Jose, CA 95127 408-928-6847 [email protected] REQUEST FOR PROPOSAL FOR LEGAL SERVICES INVITATION AND BACKGROUND NOTICE IS HEREBY GIVEN that the Alum Rock Union Elementary School District ("District") is seeking proposals from qualified firms to provide legal services in conjunction with the District's operations, and to support its educational and facilities programs. The District will receive sealed proposals for the award of contract(s) for legal services effective no later than, 3:00 p.m. on November 22, 2017. The Alum Rock Union Elementary School District serves students in grades TK - 8th, as well as special education and preschool programs. The District has 22 campuses, along with a central district office. The expenditures for legal fees and costs for 2016-2017 were approximately $600,000.00 District demographics and quick facts: Enrollment 10,000 Grades TK - 8 Employees 1,212 (approx.) Operating Budget 138,492,459 Board of Trustees Five elected board members Instructional Days 180 Website http://www.arusd.com PURPOSE AND INTENT The purpose of this Request For Proposal (RFP) is to competitively solicit firms and establish a bench of specialized consultants for advice and legal counsel. INSTRUCTIONS All proposals shall be submitted in the format specified by the District as defined in this RFP. Four (4) paper copies and one (1) electronic PDF version on a flash drive of the proposal shall be submitted in a sealed envelope, no later than 3:00 p.m. on November 22, 2017 and clearly marked RFP No. 1718-BUS02. Each firm is responsible for the delivery of their proposals. If the proposal is delivered to the wrong office, by any delivery method, the bidder bears full responsibility. No fax or phone proposals will be accepted. Proposals received after the above stated time and date will be returned to vendor unopened. The selection process will include a screening review and evaluation of proposals by District staff members. The time clock in the Purchasing Department will be used as the official time. Sealed proposals will be received at: Alum Rock Union Elementary School District Purchasing Department 2930 Gay Avenue San Jose, CA 95127 Attn: Mr. Kolvira Chheng, Assistant Superintendent Business Services District office hours are Monday through Friday, 7:30 a.m. to 4:30 p.m. Questions regarding this proposal should be submitted to Mr. Kolvira Chheng, via email at [email protected]. Mr. Chheng can also be reached at 408-928-6847. All proposals received as part of this solicitation become the property of the District and shall be considered public record. The cost to prepare and submit the proposals is at the sole expense of each firm. The emphasis of your proposal should be on completeness, adherence to directions and format requirements, brevity, and clarity of content. The District reserves the right to reject any and all proposals and to waive informalities and minor irregularities in any proposal reviewed. The District may reject any proposal that does not conform to the instructions herewith. Additionally, the District reserves the right to negotiate all final terms and conditions of any preliminary agreement entered into with the legal firm. The District makes no representations that any contract will be awarded to any respondent. Contact with any individual(s) in the District, other than the individual(s) specifically named herein, is prohibited, and may result in rejection of the proposal. TENTATIVE TIMELINE The anticipated schedule for completion of this RFP is shown below. Please note: Dates are subject to change: Milestone Date Release of Request For Proposal (RFP) October 27, 2017 Deadline for Questions/Clarifications November 10, 2017 Responses to Request for Clarification November 17, 2017 Proposal Due Date November 22, 2017 Screening/Interviews/Reference November 27 - 30, 2017 Checks/Contract Negotiations Board Approval December 14, 2017 INSTRUCTIONS FOR SUBMITTING PROPOSALS FOR LEGAL SERVICES SCOPE OF SERVICES TO BE PROVIDED - AREAS OF SPECIALIZATION Your response to this Request for Proposal must include sufficient evidence to document the firm's capability to perform, such as the experience and qualifications pertinent to the requirements of this request for qualifications. Areas of Specialization - Requirements 1) Human Resources - Labor and Employment Contractor shall provide, as requested, legal advice related to labor and employment law including, without limitation: union negotiations, contractual arbitration, matters before the Public Employee Relations Board, disputes, collective bargaining, California Labor Code, Personnel Commission rules, employment contracts, State and Federal law, and labor-related matters in Superior or Federal court. Legal service may include, without limitation: filing complaints, answers, and motions. preparing and responding to discovery, representing the District in jury or court trials, and representing the District on appeal. In addition, the Contractor may be called upon to retain experts when related to advice or service requested. 2) General Education Law Contractor shall provide, as requested, legal advice related to general education law including, without limitation: child custody, child abuse, academic calendars, charter school law, Federal and State implementation and compliance of categorical programs, desegregation and civil rights law, disputes, and school law enforcement. Legal service may include, without limitation: filing complaints, answers, and motions, preparing and responding to discovery, representing the District in jury or courts trials, and representing the District on appeal. In addition, the Contractor may be called upon to retain experts when related to advice or service requested. 3) Facilities Services Contractors shall provide, as requested, services in the following areas: Land acquisition and real estate matters a. b. Construction and construction delivery methods Public Works and Public Contract Code C. d. Construction litigation California Environmental Quality Act (CEQA) and DTSC Compliance e. f. Construction related labor relations support Facility mitigation agreements, developer fees, Mello Roos and Community g. Facility Districts Public Finance: Bond/Debt obligations, regulatory compliance and school finance h. 4) Special Education Contractor shall provide, as requested, services in the following areas: a. General Special Education compliance advice and training including, but not limited to: Charter/private schools, non-public school placement, issues involving appropriate educational programs, jurisdictional questions, applicability of Individuals with Disabilities Education Act (IDEA), provision of related services, Section 504 issues, state compliance investigations, suspension and expulsion of Special Education students, and IDEA procedural issues. b. Free and Appropriate Public Education (FAPE) negotiations, Special Education due process proceedings, and Special Education litigation support. Represent the District at Special Education Due Process hearings regarding the delivery of educational services to children with physical, emotional and learning disabilities. Advise the District with respect to its rights and obligations to students with disabilities. The work may include: legal research, case analysis, preparation of statutory offers, drafting and responding to motions, preparing and interviewing witnesses for Due Process Hearings, preparing for and advocating on behalf of the District at Due Process Hearings, drafting pleadings and relevant legal documents related to Due Process Hearings. In addition, expertise is required to support and manage Special Education litigation as well as negotiate and draft language for mediation agreements, contracts, and settlement agreements. 5) Business and Procurement Services - Contract Support Contractor shall provide, as requested, legal advice and legal services related to drafting, reviewing, negotiating, and enforcing the contracts pursuant to which the District procures goods and services, including professional services, computer hardware and software, machinery, equipment, furniture, utilities, material, supplies, and vehicles. Contractor shall provide legal advice and legal services related to enforcing contracts, or otherwise representing the District's interests in connection with contracts entered into by the District and other contract matters. 6) Government Relations Contractor shall provide, as requested, services in the following areas: a. Board of Trustees Counsel and Support: Contractor shall provide, as requested, legal advice and legal services related to Board matters, including, but not limited to, Board policies, election issues, media relations, individual Board Member liability, and communication with the public and media by Board Members. b. Brown Act: Contractor shall provide, as requested, legal advice and legal services related to Brown Act matters, including, but not limited to: open meeting law, agenda requirements, closed session law, participation in public meetings, distribution of documents, and Robert's Rules of Order. Public Law: Contractor shall provide, as requested, legal advice and legal services C. related to public law, including, but not limited to: public agency conduct and meetings, election and political issues, Public Records Act requests, ethics and conflicts of interest, and intergovernmental relations. Legal service should also include analyses and advice related to mandated cost issues. END OF SCOPE OF SERVICES TO BE PROVIDED PROPOSAL FORMAT Each respondent should submit one (1) proposal for any or all areas of specialization listed herein. Proposals should be organized in the following manner and limited to the following number of pages for each section. Section Page(s)
R8

IRS Form W-9 - All Proposals must include the following Internal Revenue Service form: IRS Form W-9 Request for Taxpayer Identification Number and Certification (Revised December, 2014). Form W-9 is available at: www.irs.gov/pub/irs-pdf/fw9.pdf
R9

Conflict of Interest Certification - Complete, sign, and date the enclosed Conflict of Interest certification included with this RFP (pages 17 & 18).
R10

Letters of Recommendation (three pages) - Include no more than three recent letters of recommendation from school district clients. END OF PROPOSAL COMPONENTS AWARD

* This report's PDF did not contain easily extractable text and required Optical Character Recognition (OCR) for analysis. There may be minor errors in the extracted findings and recommendations due to OCR limitations with scanned documents.