Q. Okay and do you agree with me that you made the job description for CCLR more explicit as a result of consultation with the DOE employee by the name of Michael Laguna [phonetic]? A. After talking through with him the types of support that would be beneficial it seemed like it was my duty to kind of think through the possibility that even though we want all teachers to improve after the support we give them that the reality is that may not happen. And so I needed to be diligent in both giving Mr. Zucker a fair, specific and explicit description of what I was expecting. I mean not assuming that what I understood from the jobdescription was what he understood. sind yes, | needed to also ensure that if things didn't--you know if in fact he did struggle and support was given and he didn't change and we ended up needing to give a U rating that it would be clear to the hearing officer as well. Q. Okay, who is Michael Laguna? A. I don't know his exact job title. Q. Okay and who initiated the contact with Laguna or did Laguna reach out to you? A. [believe he reached out to me. Q. And how did he reach out to you? By phone or email or some other method? A. Yeah can't recall that. Q. And what was the substance of your first conversation? A. I mean I can't recall specifics, but again we talked through how to support teachers who might struggle, and to support them in a really robust fashion. Q. So is it fair to say that during that conversation he asked you who you felt had been struggling at the school during the 2011/2012 school year?A. He asked who I thought might need support during the school year, the upcoming school year. Q. Okay do you recall the month or the day that that first conversation happened? A. NoI don't. Q. And in that conversation you provided the Respondent's name to Mr. Laguna correct? A. Idid.Q. And you testified that as a result or your conversation with Mr. Agona, you changed Mr. Zucker's job description correct? A. After consulting—after having a discussion with him, yes. Q. And would you agree with me that in changing Mr. Zucker's job description you also consulted with Ms. Cruz, your Assistant Principal about that job description? A. Thad emailed her the revised job description. Q. Okay so I'm going to actually show you oe currently in evidence of Respondent's Exhibit 4, That's--Q. Right that copy is for her. Do you have a copy Mr. Hearing Officer? If you don't have a copy, [have a copy. You testified that you emailed Assistant Penal Cruz about Mr. Zucker's job description. Is that the email that you sent to Ms. Cruz? A. Noit's not. Q. Okay does that document contain the substance of the email that you sent to Ms. Cruz? A. I would have to check it exactly, but- Q. Do you have a copy of the email in your email system as of today? A. I'm not sure. Q. Okay so at this time I call for the production of the email that she sent to Ms. Cruz. THE HEARING OFFICER: Can you comply? MS. ABEL: I'll see if she has it. She does email’s. THE HEARING OFFICER: Well let me ask, do you know if in fact you sent something in somesubstance similar to this? DR. COVIELLO: Similar. THE HEARING OFFICER: Okay and do you kee your emails in any organized fashion? DR. COVIELLO: No. THE HEARING OFFICER: Would you be able to check? DR. COVIELLO: I can check. THE HEARING OFFICER: And let counsel, Ms. Abel know if you ate able to locate it. DR. COVIELLO: Okay. THE HEARING OFFICER: You can continue. Q. Okay is it fair to say that in your email to Ms. Cruz, you had indicated that Mr. Zucker's job description should be focused more on literacy? A. I mean again I would have to look at the exact email because this is not my email. Q. Okay very good. Is it fair to say that Ms. Cruz responded to the email that you sent her about Mr. Zucker's job description? A. Once again I would have to look at the exact email.Q. Okay did you meet with Mr. Agona in person about Mr. Zucker's job description? A. Imet with Mr. Agona regarding support for teacher's I thought might struggle. Q. When did that meeting occur? A. Over the summer of 2012. Q. Was it in July or August? A. I don't recall. Q. And was anyone else present at that meeting? A. No. MS. ABEL: Objection--she already answered. THE HEARING OFFICER: Go ahead. Q. Atsome point did you meet with Mr. Agona with Ms. Cruz present? A. [don't recall that. Q. Okay and you testified that you met with Mr. Agona to discuss teachers. Was Mr. Zucker one of the teachers that you discussed? A. Yes he was. Q. And what was the substance of your conversation with Mr. Agona about Mr. Zucker at thatA. I don’t recall exactly, but again the substance of our meeting was around supporting me to support teachers who I felt might struggle during the upcoming school year. Q. And what did he indicate to you, you could do to support teachers that school year? A. We discussed the type of support that ] was planning for them and thought about how this would support them in the work that they were doing. Q. And what type of support did you discuss? A. I don’t know--we talked about the staff development that I was planning. So I was planning for TC staff developers to come in. I was planning for TC inclusive classroom staff developers to come in. And network staff to come in. So we talked about that kind of support. Q. You testified that you believed Mr. Agona reached out to you concerning the teacher's at the school. Prior to him reaching out to you had you had any communication with him in your career with the DOE? A. Not to my knowledge.Q. Okay so you had never met or spoken with Mr, Agona prior to him calling you to say that he wanted to discuss teachers who were in need of support at the school? A. I don't--he may have come prior when Ms. Marsha Elliott was principal. I may have met him then you know. Q. And what was the reason for meeting him at that time? A. Well I was an interim administrator and I believe that she--I cannot say for sure, but she I believe had a meeting with him, with the assistant principal's and myself. But you know-- Q. I'm sorry, did you have something else to say? A. I can't be sure that that was him. Q. And when he was introduced to you at that time do you recall what you were told about who he was and what his job description was? A. No. Q. Okay you testified that you met with Mr. Agona during the summer of 2012. Did you continue to communicate with him during the 2012/2013 school year?jh pee pee fee ee Nn Go DIR OO CO I Dn SW Q. Okay do you know if you emailed Mr. Agona during the 2012/2013 school year about Mr. Zucker? A. Again, I can't recall that. Q. And did you have any in-person meetings or phone calls with Mr. Agona during the school year about Mr. Zucker? A. Not to my knowledge. Q. So as of today your best recollection is that you communicated with him once over the summer about Mr. Zucker and other teachers at the school? A. Yes.