To: Members of the Board of Education, Columbus City Schools

Cc: James Barnes, Esq., Columbus City Schools General Counsel

From: Jessica Philemond, Esq., Scott Scriven LLP
Re: Investigation of Complaint Against Board Member Simmons
Date: June 4, 2024

At the direction of Board President Christina Vera, I was asked to investigate a

complaint against Board Member Simmons made by the Columbus Education
Association and Columbus Education Justice Coalition on May 21, 2024, in which
demands were made of the Board of Education and Board Member Simmons and “legal
action” was threatened. (See “An Open Letter to Columbus City Schools Board of
Education Members,” Exhibit 1, hereinafter referred to as “The Complaint.”). At issue in
The Complaint was a document titled “Taking Control of the Task Force Narrative,” dated
May 10, 2024, that Board Member Simmons presented at a meeting on May 10, 2024.
(Exhibit 2, hereinafter referred to as the “Simmons Document.”) As a part of this
investigation, I was asked to determine whether Board Member Simmons alone authored
the Simmons Document, and, if not, whether any authors were members of the Board of
Education or administration. It is important to note that the investigation thus far has been
limited to internal witness interviews and related documents.

Overview of the Investigation

As a part of the investigation, I interviewed all seven (7) members of the Board. All
but one board member (Board Member Brandon Simmons) cooperated fully and provided
documents as requested. Board Member Simmons was not cooperative. He refused to
provide a complete interview and answered almost no substantive questions, discussed
in further detail below. With regard to documents, Board Member Simmons was asked
to produce all related public records in his possession but refused to do so prior to the
Board’s motion to file legal action. After that time, Board Member Simmons provided
limited records but continued to refuse to produce public records that would be of
significant relevance to this investigation. In addition, it appears that Board Member
Simmons has destroyed (or attempted to destroy) relevant evidence and possibly given
other evidence to another individual or individuals to maintain. Further details regarding
these requests are discussed later.

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 In addition to board members, I interviewed several members of the administration
and staff, including the District Superintendent, the Superintendent’s Chief of Staff,
members of the District Communications Team, Board Services Team, and others present
at events relevant to the investigation.
Summary of the Initiating Concern

On May 10, 2024, a briefing meeting was held at the Columbus City Schools
administrative offices for the sole purpose of providing an update regarding Task Force
communications and engagement. After the Superintendent and Chief Communications
Officer provided an update, Board Services discussed the Board of Education
Engagement Plan they had prepared. After they were done, Board Member Simmons
asked to share his ideas and passed out a document dated May 10, 2024 titled “Taking
Control of the Task Force Narrative.” (The Simmons Document, Exhibit 2). While
Simmons collected some copies of the document several days later, not all were
retrieved. The Simmons Document was then distributed by Board Member Ingles on May
17, 2024, given to union leadership and others that say day, and then later distributed to
media, eventually being published in media articles on May 21, 2024.

At the already-scheduled board meeting on May 21, 2024, Board Member

Simmons left twice to make statements to the press, once before the meeting and once
during the meeting. In those statements, he said that the Simmons Document was a
collaboration of multiple people from multiple meetings and from multiple sources,
including key stakeholders. He also said that there were various versions (earlier and
later) and that he wanted to emphasize how sorry “we are” that the document was seen
by folks and that “it certainly was not the Board President’s intention when they saw the
first version – I don’t think it was the Superintendent’s intention when they saw the first
version.” (See Exhibit 3, link to video and transcript of Board Member Simmons’
statements on May 21, 2024). Those comments raised questions regarding who actually
wrote the Simmons Document or its various versions.
Limitation of Report – Witness Cooperation

As mentioned above, all witnesses were cooperative in the investigation except for
Board Member Simmons. I spoke with Simmons on May 22 and 23, and then again on
May 30, 2024. Simmons was asked questions related to the press statements he made
on May 21, 2024, including who was involved in the collaboration he was claiming and
whether any of them were board members or district staff. His answer to all of those
questions was, “I don’t want to answer this question.” Simmons ignored multiple requests
to produce the public records in his possession. It was not until the Board’s action on
May 29, 2024, instructing legal counsel to initiate legal action against Simmons if he failed
to provide records, that Simmons agreed to meet at the District administrative offices to
produce records. At that meeting on May 30, 2024, Simmons provided select documents
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only. Simmons described many records as “being no longer in [his] possession,” and
said, “I don’t have an obligation to create records,” suggesting that his legal obligations
went away with the records.

Explained below, Simmons created the Simmons Document on his personal

Google Drive and, when asked to produce the Google Document, he admitted to deleting
it. Board Member Simmons was given instructions to recover the Google Document and
was offered assistance, but he has still not produced the Google Document. Obviously,
if Board Member Simmons’ claim that many individuals collaborated in drafting the
document is true, the Google Document and its corresponding data would be highly
relevant to this investigation.

Findings of Fact

At the Board of Education’s May 7, 2024 meeting, recommendations were made

by the Superintendent’s Community Facilities Task Force (“Task Force”) regarding
recommended school buildings for closure. The District’s communications team was
assigned the responsibility of communicating on these recommendations throughout the
community and establishing opportunities for community engagement and feedback.
Several board members expressed dissatisfaction with the initial roll out of
communications on May 7th and so Superintendent Dr. Angela Chapman scheduled a
meeting with the communications team for the morning of May 10, 2024, for the purpose
of discussing Task Force communications and opportunities for community feedback and
engagement throughout the month of May. Dr. Chapman also scheduled a second
meeting for that afternoon to update a few members of the Board with her team.

The investigation found that, while the administration was preparing its
communications and engagement plans, Board Member Simmons was sharing his
opinions on Task Force communications as well. Board Member Simmons sent the
following texts to Board Member Pierce on May 9, 2024 at 10:17 am, one after the other,
as follows:1

“We need to fight back against the misinformation from CEA. They
are taking us down the same road as the strike.”

“Every false truth needs to be corrected at the next Board meeting.

*Play the video of the lie
*Play the video of the truth.”

“We need testimonials from all task force members and everyone
who sits at that table to speak in support of the effort.”

1Before this text, the next most recent communications between the two was on May 8, 2024 and had to
do with an unrelated matter.

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Board Member Pierce responded with this text: “??? What happened”

Board Member Simmons then responded “Tuesday. We have to start fighting back. Just
taking it is not going to work” and Pierce responded “Yes.”

Simmons then texted once more:

“It’s their strike strategy. Misinform, accuse of wrong doing, destroy

the process so it can’t produce any outcomes.”

Dr. Pierce did not respond. (See Text Communication, Exhibit 5). Within minutes of his
texts to Dr. Pierce, Board Member Simmons also sent an audio message to Board
President Vera, expressing frustration with misinformation being spread, wanting to fact-
check that misinformation from the CEA, and explaining his feeling that the Board needed
to be laser-focused on the Task Force work.2 Board President Vera responded “I 100%
agree.” (Text Communications, Exhibit 4). When asked about this exchange and what
Board President Vera thought Board Member Simmons meant when he referenced
misinformation from the CEA, she explained that weeks prior there had been
misinformation spread claiming that the District had never mentioned school building
closures before passing the levy. She explained that this was not true; the Board’s
Statement of Facts Resolution adopted in public session on September 19, 2023 stated
in the General Funds Assumptions “[c]onsolidation of buildings to reduce overall building
cost.” (Statement of Facts, slide 17, Exhibit 12).

On the evening of May 9, 2024, Board Member Simmons called Board Member
Cole. Board Member Simmons complained about the CEA and said “we need to get back
at them.” He shared other ideas that Board Member Cole did not agree with, such as
attempting to cause a rift between the unions. Boad Member Cole told Board Member
Simmons to calm down, that there was no need to engage in a “clap back,” and said that
at the end of the day, the Board makes the final decision on the Task Force
recommendations. On the same evening, May 9, 2024, a student recognition ceremony
was held at The Ohio State University. Board President Vera was asked to speak at the
ceremony, and Dr. Chapman attended with her. At 5:29 pm, Board Member Simmons
sent a text to Board President Vera that said “I wrote a communications plan, I would like
you to look at tonight after event. Please.” She responded “Sounds good.” (Text
Communications, Exhibit 4). After the ceremony ended, Board Member Simmons
approach Board President Vera and Superintendent Dr. Chapman as they were leaving.
The three of them sat down in the seating area in the lobby area outside of the ceremony
at Ohio State. Simmons had a notebook that he opened with papers inside with
typewriting and hand-written notes on them, but he did not share them with Dr. Chapman

2The transcript of the audio found in Exhibit 4 was auto-generated by Board Member Simmons’ phone
and he has stated the transcript contains some word inaccuracies.

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or Board President Vera.3 Simmons told them that he felt that the District was not
communicating its vision of the Task Force very well; saying “we can’t be out-
communicated.” Simmons then began complaining about the Columbus Education
Association (CEA) and specifically said that he “wanted to go to war with John Coneglio,”
the CEA President. Vera said, “we are not interested in going to war with the union” and
Simmons said, “they are already starting with us.” Before they left, Simmons handed Dr.
Chapman a copy of a document dated May 9, 2024, with the title “Taking Control of the
Task Force Narrative.” (Exhibit 6). They did not review the document at that time, but Dr.
Chapman took it with her as they left. Because Simmons was interested in Task Force
communications, Dr. Chapman offered to brief him and Board President Vera the
following afternoon at the administrative offices. Board President Vera invited Board
Member Adair to attend as well, and she accepted. After the meeting, Board President
Vera sent Board Member Simmons a text thanking him for offering his ideas and for
working on an outline. When asked about this communication, Board President Vera
explained that when they met she saw that Board Member Simmons had a hand-written
outline of ideas inside of his portfolio. Board Member Simmons wrote back “I will have
more things added to it tomorrow.” (Exhibit 4).

Dr. Chapman left Ohio State feeling disappointed in Simmons’ suggestion that he
wanted to “go to war” with CEA. She explained that no one on her team had voiced that
type of adversarial or confrontational language, and she felt that if Board Member
Simmons had his way, they would be paying for it for years to come. She worried that
Simmons was going to dismantle the hard work and efforts she had made since taking
on the role of Superintendent.

Although Board Member Simmons was uncooperative in this investigation, he

answered some limited questions on May 22 and 23, 2024 in phone calls. With regard to
the conversation on May 9th at Ohio State, Simmons confirmed that Vera and Chapman
both expressed that they were not interested in fighting with the Union. Simmons also
said “all 3 people sitting down on the 9th agreed with that sentiment,” apparently including
himself, which does not align with the Simmons Document he passed out the following
day suggesting “fighting,” “hitting back” and refusing to reach any resolutions with CEA
leadership for the remainder of the year, among other tactics. (Exhibit 2).

When Dr. Chapman arrived at her office on May 10, 2024, she gave her assistant
a copy of the document Board Member Simmons had handed her the night before. Dr.
Chapman asked her to scan it and send it to the staff who would be in their meeting with
the three board members at 3:30 pm that day, and she did. (See Exhibits 6 and 7). The
Task Force communications update then took place at 3:30 pm that day at the
administrative offices as planned. Those present were Christina Vera, Jennifer Adair,

3 Board Member Simmons stated that this record is no longer in his possession.

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Brandon Simmons, Angela Chapman, Lydia Wiggins, Letrece Griffin, Tyler Carter,
Jacqueline Bryant, Elizabeth Hess, Carl Williams, and Amy Dawson (Fahlgren).

As everyone arrived for the meeting, Board Member Simmons asked Carl
Williams, Board Clerk, to make copies of a document for him. Simmons sent Mr. Williams
a link to his personal Google Drive at 3:31 pm, with the subject line “print please.” (Exhibit
8). Mr. Williams then made enough copies for everyone at the meeting and gave them to
Board Member Simmons. Board Member Adair was seated next to Dr. Chapman and
saw that Dr. Chapman had with her at the table a document that said “May 9th” at the top
and the heading “Taking Control of the Task Force Narrative.” (Exhibit 6). Adair heard
Simmons say to Dr. Chapman when he arrived “I revised the document” before he asked
Carl Williams to make copies.

Superintendent Dr. Chapman and Letrece Griffin, Chief Communications &

Engagement Officer, opened the meeting with an update to the board members on what
the communications team would be doing moving forward – they discussed the gallery
walk, the imagery, the community engagement, interviews, etc. The conversation then
moved to Board Services and a discussion about how the Board could be more involved
in the Task Force communications process. Lydia Wiggins and Beth Hess presented the
Board of Education Engagement Plan and discussed the several different “Scenarios” of
engagement for board members to choose. This Board of Education Engagement Plan
was printed out for everyone in the meeting and it was also sent to the three board
members in attendance. (See Document Share and Board of Education Engagement
Plan, Exhibit 13).

The group discussed whether the location of the next board meeting (on May 21,
2024) should be moved from Hilltonia Middle School to 3700 South High Street. There
were two concerns. The first had to do with the impact on students, because when a
board meeting is held in a school building, the auditorium is not usable the day prior to
allow set up all of the audio visual equipment needed. With end of the year programming
and awards in school buildings, the group discussed that the end of the school year was
probably not an appropriate time to hold a board meeting in a school building. Second,
there was a discussion of space and whether the middle school would have the space
necessary should the audience be as large as it was the meeting prior. The group overall
felt the meeting should be moved and discussed that, moving forward, meetings should
not be held in school buildings during the month of May. The meeting was then moved
to 3700 South High Street and a Media Alert notifying the public of the change was issued
on May 14, 2024. (Exhibit 14).

After the Communications Team and Board Services shared their communications
plans, Board Member Simmons said that he had ideas that he wanted to present. He
handed a copy of the Simmons Document (Exhibit 2) to every person in the room and

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then sat at the table and went through the document. Overall, he spoke for about 20
minutes and by every account was “fired up.” Simmons saw Jacqueline Bryant (Interim
Executive Director of Communications) shaking her head “no,” and said, “I see you
shaking your head, Jackie, but I’ll come back to you.” Simmons acknowledged out loud
that he knew they “weren’t going to do some of these things.” As Simmons worked his
way through the document and expressed ideas that seemed to many as unprofessional
or childish tactics to take against the CEA, Board Member Adair said to Board Member
Simmons “who wrote this?” He responded, “I did,” a comment uniformly recalled by
witnesses. He also said, “the things in this document are my ideas, my thoughts” and “it’s
a collaboration, I’m not making a suggestion that we do all the things, I know some of
these things we’re not gonna do.” When Simmons discussed targeting the Union and
John Coneglio, Adair made the comment “it sounds like you don’t want to be endorsed
again, do you?” (Simmons was an endorsed candidate by the CEA). Simmons
responded with something along the lines of “I might be just a one-term board member”
and that he was fine with that because he believed in what he was doing.

As Board Member Simmons continued through the document, witnesses were

surprised at what they heard and described faces in the room as “looking shocked.” Some
of those present verbally said “no” and shook their heads, but no one stopped Simmons
from proceeding through the document. When Simmons mentioned an idea about racial
division, Board Member Adair said “whoa, we can’t do that, that’s not gonna happen.”
Jacqueline Bryant said “Can I say something? We’re not going to do any of these things,
we are never going to target the media that way.” Then others said things like “this isn’t
how we want to handle labor relations.” Simmons explained that there was a lot of
misinformation out there, and brought up the issue involving the Levy Statement of Facts,
discussed above. Dr. Chapman felt threatened when Simmons suggested that if the
communications for the Task Force went wrong “you’ll be the next Talisa Dixon.” Board
President Vera described feeling the same when Board Member Simmons said also that
she would be “the next Carol Beckerle.”
The meeting ended sometime around 5:30 pm. Board Member Adair left a bit
earlier than others in order to head to another obligation. As they walked out, Vera said
to Simmons “you gotta be light.” She said she meant that he needed to ease up on the
Union. That was the end of their communication and they went their separate ways. That
night, Board President Vera called Vice President Pierce and told her that Simmons had
pulled out a document at their meeting with “crazy ideas,” and “talking about going to war
with CEA.” She said to Pierce “you need to get your boy under control.” Board Member
Simmons sent Dr. Pierce a text at 6:39 pm asking her to give him a call, and she returned
his call about three hours later. Dr. Pierce told Simmons that Board President Vera had
called her to tell her about the meeting and that she said he presented some “crazy shit.”
He told her about it and Dr. Pierce said to him “no Brandon, we are not doing that.” Dr.

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Pierce asked him what exactly he passed out at the meeting, and so he said he would
send it to her. Simmons then sent to Dr. Pierce an e-mail with a link to the Google Doc,
but Dr. Pierce said she never opened it that night or after. (See, Exhibit 9).

On May 11, 2024, a CEA Teacher Retirement Recognition Dinner was held. Board
members Ingles, Vera, and Simmons attended. Superintendent Dr. Chapman and Chief
of Staff Mike DeFabbo also attended, and all were seated at a table next to the CEA
leadership. During the dinner, Simmons pulled Mike DeFabbo aside (only about 5 feet
away from Coneglio) and said, “we need to destroy John Coneglio politically.” DeFabbo
said, “I don’t think anyone is looking to pick a fight with the union” and then said, “we
should absolutely correct false statements.” DeFabbo described feeling shocked and
appalled by the statements by Board Member Simmons and said that he left the dinner
in haste at the end of the event. Other witnesses confirmed Simmons saying at the dinner
“I’m taking John [Coneglio] down.”

On Monday, May 13, 2024, Board Member Simmons went to the District
administrative offices to collect the copies of the Simmons Document he handed out at
the meeting on May 10th. Beth Hess collected the documents from Carl Williams, Lydia
Wiggins, Latrece Griffin, Jacqueline Bryant, and Tyler Carter and returned them to Board
Member Simmons. Board Member Simmons explained that some of the copies had
handwritten notes on them. However, he did not produce any of these copies to legal
counsel, stating that they are “no longer in [his] possession.” Regarding other copies of
the Simmons Document, Board Members Adair and Vera took their copies with them
when the meeting ended. Board Member Adair kept hers; Board Member Vera threw
hers away that weekend.

After having his copy collected on May 13, 2024, Mr. Williams attempted to access
the Google Document from the link Board Member Simmons had sent him on May 10th,
but the document was no longer available, having presumably been blocked or deleted
by Board Member Simmons. Board Member Simmons continued his attempts to collect
the document. On May 16, 2024, Simmons arrived at the administrative offices in
advance of the evening community engagement session and went into Chief of Staff
DeFabbo’s office. He shut the door and said that he had passed a document out at a
meeting the week prior and asked DeFabbo if he would try to get it back for him from
Board Member Adair. Simmons then said, “there’s also a question of whether or not the
document is a public record, but we’ll deal with that later.” DeFabbo never asked Adair
for the document. Later that evening, Board Member Ingles was on the phone talking to
Board Member Adair when Adair told her about the communications meeting the week
prior. She said, “Simmons passed out this crazy document, talking about dividing the
union, race division, you should have seen the look on people’s faces.” Ingles asked
Adair to send it to her.

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 Board Member Adair took photos of each page of the Simmons Document and
sent them to Board Member Ingles at 9:32 pm via text. Ingles felt the document was
worse than she had expected. The next morning (Friday, May 17, 2024) she spoke to her
friend Jamie Shumaker, who serves as Executive Secretary for the AFL-CIO Central
Labor Council, and they arranged to meet that morning at 9:30 am. Ingles sent Shumaker
the copy of the Simmons Document she had received by text. By the afternoon of May
17, 2024, several individuals were aware of the Simmons Document, seemingly all local
politicians. It appears that Board Member Simmons learned sometime between 4:00 and
6:00 pm on May 17th that the Simmons Document was being shared publicly.
After May 17th, it seems that colleagues were largely not speaking to Board
Member Simmons or returning his calls. Dr. Chapman answered Simmons’ call on
Saturday, May 18, 2024, however. He told her that he wanted to “set up a meeting with
board members and the administration” on Sunday (the following day) and he wanted to
tell CEA that they were “going to pause the Task Force” among other things. Simmons
explained that if they did that, he thought CEA would “forget about” his document.
Simmons said “if we don’t do this by 8 am on Monday, it’s going to be ugly.” Dr. Chapman
told Simmons that he really needed to be talking to the board president. Simmons tried,
but Vera did not return his call. Vice President Pierce understood that no other board
members were talking to Simmons. She did not speak with him on Saturday May 18th,
but she did speak with him on Sunday, May 19 th. Simmons told Dr. Pierce that “many
people helped create the document, with many meetings.” Dr. Pierce asked who they
were, and Simmons would not say. Dr. Pierce told him “you need to get the many people
to help you now.”

On May 21, 2024, CEA sent all board members the document “Open Letter to
Columbus City Schools BOE Members.” (Exhibit 1). Before noon, the Simmons
Document was published in the media. That evening, Board Member Simmons sought
out the press and made statements on two occasions, discussed above. (Exhibit 3). The
following day, Board Vice-President Dr. Pierce spoke to Simmons on the phone and asked
him who he was talking about when he said “many people” helped him with the Simmons
Document. Simmons said “that question goes away when we move forward. We could
have moved beyond that if we had just moved forward.” She asked him again, “do you
have a ‘many’?” He responded by saying “I always have something in my back pocket.”
Simmons eventually said to Dr. Pierce that he did have a “many,” but said “please don’t
ask me who it is.” Board Member Simmons then issued a press statement on May 23,
2024 that suggested he was an unwilling participant in the Simmons Document and that
he “should have said no.” (Exhibit 15). Board Member Simmons called me just before
making the press statement to give notice of it. He read one paragraph from the
statement which suggested that he was an unwilling participant in creating the document.
I said to him that it sounded like he was saying that he was used by someone; that he

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was just a pawn in someone else’s plan. He said the statement was “an apology” and
would not answer who the person or persons were that he was now alleging forced his
hand.

Throughout the investigation, only two versions of “The Simmons Document” were
identified – the May 9 version (Exhibit 6) and the May 10 version (Exhibit 2). The May 9
version (Exhibit 6) was handed to Dr. Chapman by Board Member Simmons on the
evening of May 9, 2024 at Ohio State. The May 10 version (Exhibit 2) was passed out by
Board Member Simmons at a district meeting on May 10 at 3:30 pm and later disclosed
in the CEA “Open Letter.” (Exhibit 1). When I met with Board Member Simmons on May
30, 2024, he brought with him two additional copies – one was dated May 10, 2024 the
other May 13, 2024. Simmons said the second May 10, 2024 version was created after
the 3:30 pm meeting that day ended. Simmons said the May 13, 2024 version was
created after a leadership meeting on the morning of May 13. (See, Exhibits 10 and 11,
respectively). I followed up with the others present at the May 13 leadership meeting
(Superintendent Dr. Chapman, Board President Vera, and Vice-President Dr. Pierce) and
all of them explained that Board Member Simmons was not scheduled to attend, but was
sent the Zoom link at the tail end of the meeting. While he joined the Zoom, he did not
have his camera on and he did not share any documents. He did not mention the
Simmons Document and neither did anyone else. The two topics discussed after Board
Member Simmons joined the meeting were (1) the Task Force update to City Council that
they were providing the following day; and (2) the tour of Columbus Alternative High
School (CAHS) that was also taking place the following day.

Board Member Simmons was asked whether he showed the second May 10
version or the May 13 version of his document to anyone else, and he would not answer.
He was asked if anyone else helped him write those two documents or the previous two,
and he would not answer. He was asked whether anyone else physically typed into the
document and he said “that did not happen.” He was asked whether he gave access to
the Google Document to anyone else. He said he gave access to Carl Williams on May
10, 2024 so that Mr. Williams could make copies of it and that he gave access to Dr.
Pierce after 10:00 pm on May 10, 2024 when she asked him what he had passed out at
the meeting. As explained above, Dr. Pierce stated that she never clicked on the Google
Document link or viewed the document.

Investigation Findings

The following findings are based upon the evidence and testimony available at this
time, recognizing that the investigation is incomplete without Board Member Simmons’
full cooperation and production of documents, particularly without access to the Google
Document. With that understanding, I reach the following findings of fact:

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1. Board Member Simmons on his own authored all versions of the document he
titled “Taking Control of the Task Force Narrative.”
2. Board Member Simmons saved the document on his personal Google Drive
and no other board members or District administrators accessed it except one
staff member accessed the document one time on May 10, 2024 to make
copies of it after he was asked to do so by Board Member Simmons.
3. The ideas set forth in the May 9, 2024 Simmons Document were those
expressed by Board Member Simmons. He expressed those ideas in his text
to Board Member Pierce that morning, in his audio message to Board President
Vera that morning, and later when he met with Dr. Chapman and Board
President Vera that evening. (Exhibit 6).
4. The ideas set forth in the May 10, 2024 Simmons Document were those
expressed by Board Member Simmons. He told board members and District
staff at the May 10th meeting that he alone had authored it and that they were
“his ideas.”
5. Prior to receiving criticism during the May 10, 2024 meeting, Board Member
Simmons was enthusiastic about the ideas set forth in both the May 9 and May
10 versions of the Simmons Document. After many of his ideas were shot down
by the group on May 10, 2024 and staff explained to Simmons why some of
them were so harmful, Board Member Simmons became defensive and
attempted to recover the document so that it would not be seen by others.
6. Board Member Simmons deleted the Google Document or disabled the link for
the Google Document sometime between Friday, May 10, 2024 at 10:00 pm
and Monday, May 13, 2024 at noon.
7. No version of Board Member Simmons “Taking Control of the Task Force
Narrative” was approved as a communications plan for the District.
8. The District’s Communications team and Board Services team created the
District’s official Task Force communications plan, titled the “Board of Education
Engagement Plan” and the District has been operating under that Plan. (Exhibit
13).
9. No other Columbus City Schools Board Member or employee knew, prior to
May 9, 2024, that Board Member Simmons was preparing written ideas in what
is now referred to as the Simmons Document.
10. The first time the Simmons Document was seen by any Board Member or
District employee was May 9, 2024 after 8:00 pm, when Board Member
Simmons approached Board President Vera and Superintendent Dr. Chapman
to tell them about his ideas.
11. Board Member Simmons’ comments to the media about collaborating to create
the Simmons Document are unsupported by the evidence and testimony, at
least as it relates to any Board members or District employees.

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12. No board members or district employees were aware that Board Member
Simmons continued to draft versions of the Simmons Document after he
presented it at the meeting on May 10th, even if he did continue.
13. Board Member Simmons has public records in his possession that are the
property of Columbus City School District, and he has refused to produce them
despite several requests.
14. If Board Member Simmons’ statements are true regarding many meetings and
many stakeholders being involved in the creation of the Simmons Document, it
appears that he is referring to individuals outside of Columbus City Schools.

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