For Agency Use Only

Docket Number: _______

RYAN CURIONI

v.

:
:

BEFORE THE SCHOOL

ETHICS COMMISSION
OF NEW JERSEY

JOSEPH LICATA

SCHOOL ETHICS ACT

COMPLAINT FORM

President of the Lodi Board of Education

_________________________________

I, Ryan Curioni, residing at 76 Liberty Street, Lodi NJ 07644, request the School Ethics Commission to
consider a complaint against the above-named Respondent(s) whose home address is 42 Riverview Ave, Lodi
NJ 07644, 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: (Please print additional pages as needed.
Students should be identified by initials only. )
1.

Statement of facts: Joseph Licata has been using a Lodi BOE administrator, Jamie Ciofalo, during
school days to generate money for his employer the Lodi Boys and Girls Club. Licata is the contact
person for Ciofalos activities at the Club during school days. The Lodi taxpayers are paying Ciofalo
to work in our schools while he is with Licata at the Club. Ciofalo is not using his personal, vacation,
or sick days when he is at the Club. BOE records show that he is using days that are not granted
contractually, yet he is not being docked.
http://lodioverhaul.blogspot.com/2015/09/theft-of-time-lodi-taxpayers-paid.html
Ciofalo happens to be the President of Lodi Boys and Girls Club Board of Directors. That Board just
promoted Licata and made him the Executive Director. The last Executive Director was also a Lodi
BOE Trustee and was earning $122,520 three years ago. Ciofalo is technically Licatas boss and Licata
is technically Ciofalos. Both have used their respective positions to benefit each another financially
with jobs, promotions, and unwarranted privileges. Ciofalo received a promotion in the Lodi schools a
few months before Licata received a promotion at the Club. Licata continues to secure unwarranted
privileges for his good personal friend. Time sheets, contracts, and other OPRA-ed documents can be
found on the following website (search the top left corner: Ciofalo and Licata)
http://lodioverhaul.blogspot.com/

Date of occurrence: 2/13/14, 4/30/14, 5/1/14, 10/16/15, 11/13/15, multiple other days
I assert this to be a violation of: N.J.S.A. 18A:12-24(b)
1

For Agency Use Only

Docket Number: _______
2.

Statement of facts: For years, Joseph Licata has been omitting many income sources from his annual
financial disclosure statements. Jamie Ciofalo is a member of the Lodis Municipal (Drug) Alliance.
He has directed thousands of dollars (alliance funding) to Joe Licata for consulting fees. Licatas
mother is the Deputy Mayor of Lodi and her administration has approved those consulting fees when
the Mayor and Council vote on their monthly bills resolutions. Joseph Licata has never disclosed
those consulting fees on his annual financial disclosure statements.
Joseph Licata is also employed by DJ Express. That business is owned by a Lodi BOE employee.
Licata has never disclosed this source of income on his annual financial disclosure statements.
http://lodioverhaul.blogspot.com/2015/11/unethical-boe-president-omits-lots-of.html

Date of occurrence: 1/22/15, 1/16/14

I assert this to be a violation of: N.J.S.A. 18A:12-25

3.

Statement of facts: On November 26, 2013, BOE President Joseph Licata voted Yes to approve the
labor agreement between the Board of Education and the Lodi Education Association. Licatas
mother, Patricia Licata is a teacher in the Lodi schools whose contract was part of that labor
agreement. Joseph Licata was living in his mothers house at the time. After I raised his conflict of
interest publicly, Licata changed his vote the following month. Prior to that, Licata had voted Yes
on contracts and benefits directly affecting his mother. He continues to vote Yes on health benefits
directly affecting his mother, wife, and himself after invoking doctrine of necessity. But on
November 26, 2013, he voted Yes without invoking doctrine of necessity.
http://lodioverhaul.blogspot.com/2014/02/unethical-behavior-on-full-display-both.html

Date of occurrence:11/26/13.
I assert this to be a violation of: N.J.S.A. 18A:12-24(c)

4.

Statement of facts: Joseph Licata has been voting Yes to give Lodi Superintendent Frank Quatrone a
$25,108 merit bonus each year despite the fact the Lodi is performing at the bottom of the County
academically and Lodi failed its QSAC review this year. Licata has been approving the merit criteria
which in itself has been very controversial. Licatas mother (Patricia Licata) and his wife (Nikki Licata)
are both employed by the Lodi BOE as teachers. The NJ Department of Education has issued many
advisory opinions that Board members with immediate family members employed in the district should
not be voting on compensation, evaluation, or other post-employment matters pertaining to the
Superintendent.

Date of occurrence: 5/27/15, 8/26/15, multiple other dates.

I assert this to be a violation of: N.J.S.A. 18A:12-24(c)

For Agency Use Only

Docket Number: _______
WHEREFORE, I, as Complainant, request that the School Ethics Commission find and determine that the
above-named Respondent(s) has violated the School Ethics Act and that he or she be subject to such penalty as
provided by the Act.

Date ____________________________________

________________________________
Signature of Complainant
or his or her Attorney

CERTIFICATION UNDER OATH

Ryan Curioni of full age, being duly sworn upon his or 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 allegation.
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
Educations 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.