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STATE OF CALIFORNIA

ARNOLD SCHWARZENEGGER, Governor

PUBLIC EMPLOYMENT RELATIONS BOARD

San Francisco Regional Office 13 30 Broadway, Suite 1532 Oakland, CA 94612-2514 Telephone: (510) 622-1020 Fax: (510) 622-1027

December 10,2010

Philip A. Kok

P. O. Box 152 Malibu, CA 90265

John Bowes, Administrator

Los Angeles Unified School District 333 South Beaudry Avenue

14th Floor, Suite 238

Los Angeles, CA 90017

Re: Philip A. Kok v. Los Angeles Unified School District Unfair Practice Charge No. LA-CE-5520-E

Dear Parties:

This is to notify you that the above-referenced charge was filed on December 8, 2010 with the Public Employment Relations Board (PERB or Board) and will be screened initially by the Office of the General CounseL The following procedure will be used:

1. The charge shall be reviewed to determine whether it states a prima facie case of an unfair practice. (See PERB Regulation 32620(b)(4).)1

2. To make this determination, the Charging Party andlor the Respondent may be contacted for further information before action is taken. The Respondent is hereby notified that it may file a position statement. Any response must be signed under penalty of perjury with a declaration that the response is true and complete to the best of the Respondent's knowledge and belief and must be served on the Charging Party. If no response is filed by December 24, 2010,2 review of the charge will proceed and a complaint will issue where appropriate. (See PERB Regulation 32620(c).)

I PERB' s Regulations are codified at California Code of Regulations, title 8, section 31001 et seq. PERB' s Regulations and the statutes administered by the Board may be found

by visiting www.perb.ca.gov. Copies of the Regulations and statutes are available for purchase from PERB' s Publications Coordinator, 1031 18th Street, Sacramento, CA 95811-4124.

2 A document is "filed" on the date the document is actually received by PERB, including if transmitted via facsimile. (PERB Regulation 32135.)

LA~CE~5520~E December 10, 2010 Page 2

3. If the charge, after review, fails to state a prima facie case, it shall be dismissed. (See PERB Regulation 32620(b)(5).) The Charging Party may appeal such dismissal to the Board itself, consistent with PERB Regulations. (See PERB Regulation 32635.)

4. If a prima facie case is established, a formal complaint shall issue and the Respondent shall be informed, by letter, of its obligation to answer. (See PERB Regulations 32640 and 32644.) The answer must contain, among other things, an admission or denial of each factual allegation and a statement of any affirmative defenses. (See PERB Regulation 32644(b)(5) and (6).)

5. After issuance of a complaint, the case file will be transferred to a Board agent for an informal conference. (See PERB Regulation 32650.)

6. The purpose of the informal conference is to clarify the issues and explore the possibility of voluntary resolution and settlement of the case. (See PERB Regulation 32650.)

7. If the parties are unable to settle the case at the informal conference, the case may be set for a formal administrative hearing. (See PERB Regulations 32680 and 32690.)

Both parties in this case are requested to provide me and serve the other parties with the name, address, and telephone number of their designated representative, if any. A Notice of Appearance form is provided for your convenience. Once you receive a Notice of Appearance from another party, please communicate with that party only through its designated representati ve.

Until a complaint or dismissal is issued in this case, please address all communications concerning this matter to me at the address and telephone number shown above. Please reference the case number on all correspondence.

Sincerely,

~ti~31r-

Anita L Martinez Regional Director

Enclosure: Notice of Appearance Form

PROOF OF SERVICE

I declare that J am a resident of or employed in the County of Alameda, California. I am over the age of 18 years and not a party to the within entitled cause. The name and address of my residence or business is Public Employment Relations Board, 1330 Broadway, Suite 1532, Oakland, CA 94612-2514.

On December 10,2010, I served the Letter regarding Case No. LA-CE-5520-E on the parties listed below by

___x_ placing a true copy thereof enclosed in a sealed envelope for collection and delivery by the United States Postal Service or private delivery service following ordinary business practices with postage or other costs prepaid.

_ personal delivery.

_ facsimile transmission in accordance with the requirements of PERB Regulations 32090 and 32135(d).

Philip A. Kok

P. O. Box 152 Malibu, CA 90265

John Bowes, Administrator

Los Angeles Unified School District 333 South Beaudry Avenue

14th Floor, Suite 238

Los Angeles, CA 90017

I declare under penalty of perjury that the foregoing is true and correct and that this declarati on was executed on December 1 0, 201 0, at akland, Cali fornia.

C. E. Johnson

(Type or print name)

Los Angeles Unified School District

OFFICE OF THE GENERA L CO U NSE L ABORAND EMPLOYMENT SERVICES

333 S. Beaudry Avenue, 20th Floor, Los Angeles, CA 90017 TELEPHONE (213) 241-7600; FACSLMILE (213) 24]-3308

RAMON C. COHTINES Superintendem a/Schools

DAVlD HOLMQ 1ST General 'ounsel

KA THLEEN COLLINS Associate General Counsel jJ

February 8 2011

Via Facsimile and U.S. MajJ (510) 622-] 027

Anita L Martinez, Regional Director Public Employment Relations Board San Francisco Regional Office

1330 Broadway, Suite 1532 Oakland, California 94612-2514

Re: Philip A. Kokv. Los Angeles Unified School District AMENDED Unfair Practice Charge Nos. LA-CE-5520-E

Dear Ms. Martinez:

Thank you for granting Los Angeles Unified School District ('LAUSD") additional time to respond to the above-referenced amended unfair practice charge.

FACTUAL SUMMARY

In his amended Charge, Charging Party reiterates many of the admissions he made in his original charge, including his admission that he turned down substitute assignments because of the school sites and racial makeup of the student body and staff at such locations. As this issue was previously addressed, the District will not revisit such factual allegations herein. Rather, the only new substantive facts alleged pertain to Charging Party's series oflnadequate Service Reports (ISRs), which ultimately led to his termination as an at-will substitute teacher for the District.

At the outset, it is important to understand that during the relevant time period, the District and UTLA had in place a memorandum of understanding by which recently laid off regular teachers would receive priority in substitute assignments in order to maximize stability at schools that had suffered a loss of teachers due to the reduction in force. After the substitute teachers complained to UTLA about the agreement, it: was subsequently withdrawn. The District understands that this agreement has been the subject of a pending, or recently concluded, hearing at PERB (Raines v. UTLA, LA-CE-S482-E). To the extent that the agreement between UTLA and LAUSD impacted

Docs 203453

Anita 1. M-artinez, Regional Director

Al\1ENDED Unfair Practice Charge Nos. LA-CE-5520-E Februal1' 8, 20] 1

Page 2 of 3

the assignments offered to substitute teachers during this time frame, such impact would not constitute the sort of "adverse action" that would give rise to the retaliation claim asserted by Charging Party.

With respect to Charging Party's ultimate termination, Charging Party correctly summarizes that an independent unit within LAUSO, Employee Relations, reviewed his substitute file and determined that his repeated ISRs from different locations warranted separation. Attached as Exhibits A-C are document detailing those service reports.

First, as Exhibit A reveals, Charging Party received an ISR from Leichty Middle School stemming from his performance there on May 28,2009. As the report sets forth, Charging Party engaged an administrator in an argument in front of the students. The administrator concluded that Charging Party did not handle the matter appropriately and, as a result, he requested that Charging Party not be assigned to that location again.

Next, as Exhibit B reveals, Charging Party received an ISR from Audubon Middle School stemming from his performance there on December 17, 2009. The report reflects the fact that Charging Party arrived at the schools, refused to accept his assignment, and abruptly left the school site. Due to the disruption and inadequate performance, the administrator at the school requested that he not be reassigned to the school site again.

Finally, as revealed in Exhibit C, Charging Party received an ISR stemming from his performance at Young Oak Kim Academy on May 24-26. That report reflects that he denied a special education student's request to use the restroom, resulting in the student soiling himself at school.

These ISRs span over the course of months and were issued from different school sites. To the extent that Charging Party claims he did not receive any of the forms the District asserts that it. was his responsibility to maintain accurate address records with the District. The notices reflect that they were sent via certified mail to 1'.\'0 different, last-known addresses on file with the District at the time. It is also significant to note that subfinder records indicate that he had received an ISR in 2002, was restricted from another school (Canoga Park High School), and had a credential revoked and then cleared in 2005.

LEGAL DISCUSSION

For the reasons set forth above, Charging Party's amended Charge fails to state a prima facie case for retaliation. Indeed, to the extent that his assignment offers suffered any reduction during the time that the memorandum ofunderstanding was in place between UTLA and LAUSD, he was not alone, and was not singled out for disparate treatment. Thus, he cannot show any nexus between protected activity and adverse action, as required under the law.

Doc# 203453

Anita I. Martinez, Regional Director

AMENDED Unfair Practice Cbarge Nos. LA-CE-5S20-E February 8, 2011

Page 3 of3

Second, to the extent that he ultimately was separated from employment due to repeated ISRs, his claim also fails for lack of nexus. The reports came from administrators at three different sites, with no alleged knowledge of his protected acti vity (if any), and for legitimate, documented business reasons. Charging Party's history of poor performance ultimately led the reviewing committee within Employee Relations to conclude that his substitute employment should be terminated, as he had received repeated requests from sites not to assign him.

CONCLUSION

Charging Party again contends that he did not receive a sufficient number of assignments, but to the extent that he turned down assignments due to the racial makeup of the students and staff at the sites, and to the extent that his performance at school sites resulted in ISRs, and to the extent that substitute assignments were down overall due to a temporary agreement in place with UTLA - Charging Party simply cannot show that any adverse action resulting from these facts was in retaliation for alleged protected activity. The facts do not support the existence of any nexus as required under the law.

For the reasons set forth above, Charging Party's Charge remains completely without merit and should be dismissed for failure to set forth a prima facie case.

I declare under penalty of pel jury under the laws of the State of Calif ami a that the foregoing response is true and complete to the best of my knowledge and belief.

Executed on the 8th day of February 2011, at Los Angeles, Califomia.

Kathleen E. Collins,

Associate General Counsel for

Respondent, Los Angeles Unified School District

Doc# 203453

EXHIBIT A

Los A ngeles Unified Sch: .tl District

IUMAN RESOURCES '£RTlFlCAT£D SUBSl1TUT£ UNIT

'DMfNfSTRA TlVE OFFlCES 333 South Beaudry Avenue, J 511,0 Floor, Los Angeles, California 90017 1A fLING ADDRESS. Box 3307, Los Angeles, California 9005.1

ELEPHONE: (213) 24/·5100 FAX: (213) 241·8410

RAMON C CORTINES Superlntendenl oj Schools

DAVID R, HOLMQUIST Chief Opcl'af/"g Officer

VIVIAN K. EXClHAN

Interim Chief Human Resources Officer

MARJORIE JOSAPHAT Director

REGTNA ECHOLS Ass/slant Director

June 11, 2009

PHILIP KOK POBOX 341

MANHATTAN BEACH, CA 90267

Dear Mr. Kok,

Employee#: 704195

The purpose of this letter is to advise you of our receipt of a Certificated Day-to-Day Substitute Teacher Service Report indicating that your service at Leichty Middle School on May 28, 2009 was inadequate for the reasons listed on the attached service report. Be advised that this service report will be placed in your permanent personnel record.

The issuing administrator has requested the following:

\

(X ) Do not reassign to this location

( ) Review service record for appropriate .action

( ) Dismiss from employment as a substitute teacher

Therefore, in accordance with District policy, you will not be assigned to this location as a day-to-day substitute in the future.

Any questions regarding the content of this report should be referred to the principaJ of Leichty Middle School. Your written response to this report should be sent to the principal with a copy to the Certificated Substitute Unit.

If you have any policy or procedural questions regarding this matter, feel free to contact me at (2 13) 241'-6151.

Regin Assistant Director

RE: kIp

Cc: Employee Relations Staff Relations Principal

Substitute Unit

CERTIFIED MAIL

RETURN RECEIPT REQUESTED 70081830000327818105

MISSION STATEMENT:

"The teacnere, Bdm1nl.I'alo,a, ano fief! or tne LOI Angel •• U(ll~ed S",~ool Dltilncl b."sve In the "quel wo~h ~nd dignlly of all .Iudenls end Q,. cemmtued 10 .ducale .11 sludo~"'lo Iholr maximum OOlo"li.l.·

LOS.ANGELES UNIFIED SCHOOL DISTRICT Human Resources Division

CERTIFICATED DA Y -TO-DA Y

SUBSTITUTE TEACHER SERVICE REPORT

NAME: k+ (n(. koK PERS IDIEMP NO. 7(;· ~ I C; S-:-

SCHOOL L. e (. A ~ ,,/ vh S ORO UNlT/LOC CODE 9 (I r?Y'2 .

DATE (S) OF SERJICE S' /1 'S/ctj SUBJECT/GRADE ')?

---+,--~~----------_ ---~-----------

( /substitute provided service described as follows:

) SU bstitute arrival late:

( ) Commendable service described as follows: (~adequate service described as follows:

" Time accepted assignment

• Starting time of assignment _

• Substitute arrived:

-rh II. nlt-;;rv-1A ( .

(~I I

.\

RECOMMENDATOINS: As a result, it is recommended that the following action(s) be taken concerning

this substitute teacher. -

( ) Please reassign to this location. (X) Do not reassign to this location.

( ) Review service record for appropriate action.

( ) ~iSrz.~ss fr{:7emPloyment as a substitute teacher.

SlGNED: ~ //-"",.;..' DATE: __ S:f-1_2--+t6_u_,' f_· _

_ Principal

Note: Employee must be issued a copy of this report within ten (10) working days of the date (s) of service.

n Conference with employee held on (date): _

( ) By- telephone () in person

• Employee issued a copy of report on (date): _

. ( ) Sent by Certified Mail

c.)

1'0 To Substitute Employee: Receipt of a Service Report regarding inadequate service may cause your name to be removed from the substitute list. If you disagree with this report, you may submit a letter to the ; principal with a copy to the Certificated Substitute Unit at 333 S. Beaudry Avenue, 15th Floor, Los _ Angeles, CA 90017

o N

. __

... ~ USD/HR Form 1080-14

0'"

rev. l]/06

1111111111111111111111111111111111111111

H R 1 ~ • ~ .

Incident Report for 5/28/09 Sub: Mr. Kok #704195

1 was called to room 324 because I was told that the classroom was too dark. I walked in and some ofthe lights were not working. I asked the class: "Is it too dark in here?" The sub became very angry and agitated that I asked the class that question. He stated: "Don't ask the class-ask me!"

The sub was argumentative in front of the students. In front of the students he kept saying; "Fix the problem or I will leave right now." 1 told him a few times that we should not be talking in front of the students but he kept arguing.

I could have easily found another classroom for the sub, but he was very angry and argumentative. He created a scene in front of the class .

..... .-.,,--; '" :2

/ ;/ /

/'~-- j ----~-

Herb Rieger

- ..

EXHIBIT B

R_ ANGELES UNIFln;:v SCHOOL DISc icr

MONIC .. \ GARCIA, PRt:SlDENT )'OUE fLOR [S ACUI LAH TAMAU GAL,\TZAN

I\!lAF!CLJEHI'fE POIND[XTEIl L/IMOTI"[ NURY MARTINE

RICIlAIW A. VLADOVIC

STilVEf'I ZIMMEU

RAMON C. CORTINES S"perintendenl oj Schools

JAMES MORRIS

Chief Opera ling Officer

DAVID R. HOU1QUIST General Counsel

VIVIAN K. EKCH1AN

Chief Human Resources Officer

DEBORA ... A. IGNAGNI

A dminis Ito tor

M!M8ERSOFTHEBOARD

Human Resources Division

Certificated Employment Operations - SubstituteUni! 333 South Beaudry Avenue, 15" Floor - Los Angeles, eA 90017 Telephone: (213) 241-5100 . Fax. (213) 241-1J41 0

Mil RJOR IE J OSAI'IIA T Director

REGINA ECHOLS Assistant Director

January 14,2010

PHILIP KOK P.O. BOX 553

AGOURA HILLS, CA 91301

Dear Ms. Kok, Employee#: 704195

The purpose of this letter is to advise you of our receipt of a Certificated Day-to-Day Substitute Teacher Service Report inilicating your service at Audubon Middle School on December 17, 2009 was inadequate for the reasons listed on the attached service report. Be advised that this service report will be placed in your permanent personnel record.

The issuing administrator has requested the following:

(X) Do not reassign to this location

(X ) Review service record for appropriate action

( ) Disrnis s from employment as a substitute teacher

Therefore, in accordance with District policy, you will not be assigned to this location as a day-to-day substitute in the future.

Any questions regarding the content of this report should be referred to the principal of Audubon Middle School. Your written response to this report should be sent to the principal with a copy to the Certificated Substitute Unit. .

If you have any policy or procedural questions regarding this matter, feel free to contact me at (213) 241-6151

Assistant Director RE:kp

Cc: Employee Relations Staff Relations Principal Substitute Unit

CERT.iFIED MAIL

RETURN RECEIPT REQUESTED 7009082000016384641~

"'-';"'. 11" .• - .~, :

t _- -~---....-

.LOS ANCELES UNfF~ED SCHOOL D'ISTR~CT Hum a n Reso urces

;"

r

NAME:.

CERTIF]CATED DAY-TO-DAY,. '"' .. I)":i

SUBSTITurli: TEACH.ER SERV]CE REPORT'{~!~~

p~~_\ip tv ~L _~~EMPLOYEENUMBER lof/f(S

SCHOOL---f-....l.__~~~b~· .,<-.:..f.=-........,...--..i-....._~~-~='-., __ LOCATION CODE __ 2?4J·L...:O~~t:.....::~:::.! _

DATE (S) 0 F S E R V rc E.'~ ....-\--~"-·-4-....._,'-+-.:;..._ __ ~ S U BJ ECT/G RA DE, -----'-i';._· _

/sUbstitute arrival late:

( J S ubst itute provided service described as follows:

~.

( ) C_9.mmendablc service described as follows: ( Vnadeq uat e se rv ,j ce d escri bed as fa II ows:

· Time accepted assignment ~ _

· Stan. i n g time of ass; gn rnent

· Substitute arrived: -----

!:-'\( ko IL o.JY\ '«;).__ \ O(-\C 41) CA SSls+ t"VI (lvVlo~r So tAt t,(t+ -+1:~ SC~1uue

'c' " ;~'I

RECOMMEN DATIONS: ,<\5 a result. it, is recommended that the following actio-us) be taken concerning this subs1i!u'tfteach~<

, ... "

~Iease reassign to this location. ( ) Do not reassign to this local ion,

( J Review service record for appropriate action,

( ) Dismiss from em ploy rnent as a subs: iture teacher ..

.....-

SIGNED'~~

Principal

DATE: !2fo/ ;wzJ '7

• C...i .... ~ ;.t.~

Note' Employee must be issued J copy of Ih i s report within ten ( 10) work i ng days of the date (s) of service. "

"

,

. Conference with employee held on (dare): _

( ) By telephone ( ) in person

Em8,J.oyee issued a copy of report on (date): (\(Sen ( by Cert i lied Mai I

",',

, ~

To Substitute Eillplollee Receipt of a Service Repon regarding inadequate service may cause your name to be iemoved from the substi uue lOst t f y011 disagree with rh is report, you 1113), submit a letter to the principal with a copy \0 the Certi ficatC:.d Substitute Un it

ill 133 S. Beaud ry 15'0 Floor. Los Angeles, c,<\ 90012 :

To Administrator Prepare original and three (3) copies. Distribution: Forward Original to Cerii (jeated Substitute Unit 15,h Fl.). Copy One \0 Employee (in person or by Certified tvlail), Copy Two to Staff Relation, retain Cop\' ThreE in School File.

I,A USD/HR Form 1080-13

rev, 9/03

I,OS ANGELES UNIFIED SCI-IOOL D}:;TRI~T CERTIFICATED EMPLOYMENT OPERATIONS

K-12 SUBSTITUTE UNIT ~f

1 I

~.

,.

r

Ernai-': subdesk@lausd_net FAX (213) 241-84010

SubFi ndcr: (871) 528-7378 (213) 241-6151

~'

. '

~r:;·

,._"

DATE:

TO:

Employee/Staff Relations Office

FROM:

,Heglna Echols, Assistant Director Certificated Substitute Assignment

SUBJECT: INA,DEQUATE SERVICE REPORT CHECKLIST

{)U\L ... \ P . IJ-v

N AME: ~_ --:--1:l~~"""""'-- -=------_~K.-()__,,"'_____"'~=-- _

SCHOOL A \A1)UID~ U,S, DATE OF INCIDENT I,:k III }09

I04--\~S

El\1P. NO,.,: ______:___ _

LOCATION CODE &:Xz.t3

DATE RECEIVED 1- L[ -09

IV! ailed toe 01 p 1 oye e_\'-l1:-"8,,,--11-'.:....:l):::....._t. __

\

----;:--''----'-------I---i'"''-''- Sub F In d er po s t.e d

Delivered to Staff Relations --"-t-i~~--"'-"'"

Previous Inadequate on file:

Location'~)'f--'--I::I L~C \-----'-------Cd ~~S______.,..t-- M~L\~~_Date--------,---,:-7 ---+--' L l{~{ O~9 -+---

Location i£ ,{IS U"i3o;"l J MS: Date 12..t1111_CB

~-f~~I~~~----

Location Date

------------------

Location Date, ----ii-~~ ___

Location Date I

------------~----

Aaimililistrative Action:

.. '

,

Special Inatructions ....",'__,,_...-_

f;:

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f.

EXHIBITC

'i "

. ;, '~

"

,-.: ~" .' -

1"~~~~oN' CjC~~mN~8" ' $upef1n(end¢ni OJ S,¢hbo/s "

~~~1.~~· Mri~ts:: " . '

CbiifOp'erat'iljg Officer

, ~A.YI~;R:"f{QLMQUlSl' , 'Getier:r,<ICoume! .

"YiViAN'K. EKCHIAN

ChJe/Hwnan Resources Officer

DEBOMH A.-lGNAGNI Admtntstrator

MARJORJRJOSAPHAT

MEMBERS OF THE YJOAIfU)

• ')S ANGELES

. .\ ' ... : .

rVIOI',m':AGARcI4; PRESlD.~NT .

1·. l '

YOLIE 'll.ORES . TAMAR GALATZAN

M A RGiJim ITE POiNDEXTEr{ L .... MOlTE NURY MARTINEZ

RIClIARD A. VLADOVIC

STEVEN ZIMMER

, Human Resources DIvision ,

Certificated Emptoyment Qpe~niion9 - Sub~titutc Unit 333 South Beaudry Aveiaue,ts'hFtoor - Los AlIgCles,S::A 90017.

Telephone: (213) 241-.51.00( Fax: (213) l41~84.IO·

;:-. ..' . - '; •. I-

REGI,NA ECHOL.S . Assistant Dtrector

June 2,2010

.~- ,

, "

PHILIP'KOK P.O. BOX 553

AGOURA. HILLS, CA 91301

':; Errtp', i6,'y' ~'e#" ":'7041,'95, .. ', '. >.': ,~~' r-:

• " .~\ ~ -r • ~ '. •

The purp~se of this letter is -to advise Y~u'.~(~#i;:;~G~ipf9f.~ .(Je~~fip;~t~;dDgy-i;~Da;:·S~bstit\lt~' Teacher Service, Report indicating your ,seryice::~:ii.t,:Y6.ting":Oak:;:,Khn':A<::?defny:,.'bn.:May ;,24._:26; . 2 Q l? was. i nad e9-u,ate . for the. reason sIisted: 9,1:i,:;~I:'~! a,f~~c'r¢~)~·,Mc.~, :.rep'o.!t .~. ,Be, ldvisedt.pa£ this .: ' service report will be placed In your perffianet;tt:;p~f:sonnel,re!:()rd.·, ".:'

The issuing administrator has' requested th~~f6ti'~~kg;: ~,' .";' ".

! . -, •

Dear Mr. Kok,

';; .-

' . .'

(X ) Do not reassign to' this ,i6cation " " .

( ) Review service record for appropriate action

( ) Dismiss from employment as a substitute teacher

Therefore, in accordance with District policy, you will not be assigned to this location as a day-to-day substitute in the future.

Any questions regarding the content of this report should be referred to the principal of Young Oak Kim Academy. Your written response to this report should be sent to the principal with a copy to the Certificated Substitute Unit.

If you have any policy or procedural questions regarding this matter, feel free to contact me at (213) 241-6151:

( ;~ere~(~

'._ egi a Echols Assistant Director RE:kp

Cc: Employee Relations Staff Relations Principal Substitute Unit

CERTIFIED MAIL

RETURN RECEIPT REQUESTED 70090820000163846183

LOS ANGELES' UNIFIED SCHOOL DISTRICT Human Resources Division

( ) Sub:;.titutc amvallate:

( ) Commeadablc service described as follows; ( tI~deqUate service described as follows:

Note: Employee mllSt be issued a copy of this report withiD 'eo (10) working days of the dare (5) of service.

,~ Conference. with employee held 011 (date): .....

ytelephone () in person #()'

c fYY. ee issued a copy. of report 011 (dale): . . .

( ) Sent by Cenifled Mail

.:to Sub.!\!itute Employee: Receipt of a Service Repo.n regarding inadequate service may cause your name tc: be removed from the substitute list. If you disagree with this report, you may submit a letter to the principal with a copy to the Certificated Substitute Unit at 33~ S. Beaudty Avenue, lSlh Floor, Los A:n,gcies, CA 90017

,to :

LA. USDfHR Form 1080-)4

rev. 11/06

1111111111111111111111111111111111111111

• i't 1'1 I .11. It lit •

R~ce i "'ad J un-08-20 1 n 11 :35am

From-213 3B4 3083

To-CC'RT EMPLOYMENT OPER Pan ooa

10

1 ]

12

13

14 15

16 17 18 19 20

21

22

23

24

25 26

27

28

4

Doc# 200181

PROOF OF SERVICE (CCP §§ 1013a, 2015.5)

STATE OF CALIFORNIA )

2 ) ss

COUNTY OF LOS ANGELES )

5

I am employed in the aforesaid County, State of California; I am over the age of eighteen years and not a party to the within entitled action; my business address IS 333 S. Beaudry Avenue, zo" Floor, Los Angeles CA 90017.

On February 14, 2011, I served the foregoing document(s) Los Angeles Unified School District's Response to Amended Charges re Philip A. Kok v. LAUSD (LA-CE-5520-E) on the interested parties in this action, to the address and number listed below:

6

7

8

9

Anita I_ Martinez, Regional Director Public Employment Relations Board San Francisco Regional Office

1330 Broadway, Suite 1532 Oakland, California 94612-2514 Facsimile: 510 - 622-1027

Philip A. Kok

P.O. Box 152

Malibu, California 90265

[ X] BY MAIL: I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice, it would be deposited with U.S. postal service on that same day with postage thereon fully prepaid at Los Angeles, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit.

[X] VIA FACSIMILE: I caused a true and correct copy of the aforementioneo document to be forwarded via facsimile to the fax numbers listed above.

[X] STATE I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

[ ]

FEDERAL I declare that I am employed within the office of a member of the bar of this Court at whose direction the service was made.

Executed on Februa ry 14, 2011 at Los Angeles, Ca liforn ia. //

(~,:ad ..

Veronica Bonilla ~ __ .

LOS ANGELES UNIFIED SCHOOL DISTRICT

MEMBERS OF THE BOARD

RAMON C. CORTINES SUPERINTENDENT OF SCHOOLS

MONICA GARCIA, PRESIDENT YOLrE FLORES

TAMAR GALATZAN

JOHN E. DEASY, PH.D. DEPUTY SUPERINTENDENT

MARGUERITE POINDEXTER LAMOTTE

VIVIAN K. EKCHIAN

CHIEF HUMAN RESOURCES OFFICER

NURY MARTINEZ RICHARD A. VLADOVrC STEVEN ZIMMER

Human Resources Division Office of Staff Relations

333 South Beaudry Avenue, 14tb Floor· Los Angeles, CA 90017 Telepbone: (213) 241-6056 - Fax: (213) 241-8405

DR. JOHN BOWES, ASSISTANT CHIEF HUMAN RESOURCES OFFICER

December 27,2010

Anita L Martinez, Regional Director Public Employment Relations Board San Francisco Regional Office

1330 Broadway, Suite 1532 Oakland, CA 94612-2514

Re: Philip A. Kok v. Los Angeles UnifIed School District

Unfair Practice Charge No. LA-CE-5S20-E Date Filed 12/8/10

Dear Ms. Martinez:

Thank you for granting Los Angeles Unified School District the extension date of January 14, 2011 to respond to the above Unfair Practice Charge. The original due date to respond was December 24,2010.

Sincerely,

i~!~

c: Philip A. Kok Kate Collins

PROOF OF SERVICE BY MAIL

! declare that! am employed in the County of Los Angeles, California. I am over the age of 18 years, not a party to the within entitled cause, and the name and address of business is Los Angeles Unified School District, Office of Staff Relations, 333 South Beaudry Avenue, 14th Floor, Los Angeles, CA 90017. I am readily familiar with the ordinary practice of the business of collecting, processing and depositing correspondence in the United States Postal Service and that the correspondence will be deposited the same day with postage thereon fully prepaid.

On December 27, 2010 I served the enclosed letter regarding Case No. LA-CE-5S20-E on the parties listed below by placing a true copy thereof enclosed in sealed envelope for collection and mailing in the United States Postal Service following ordinary business practices at Los Angeles, California addressed as follows:

Anita I. Martinez, Regional Director Public Employment Relations Board San Francisco Regional Office

1330 Broadway, Suite 1532 Oakland, CA 94612-2514

And a copy to:

Philip A. Kok

P.O. Box 152 Malibu, CA 90265

I declare under penalty of perjury that the foregoing is true and correct and that this declaration was executed on December 27, 2010 at Los Angeles, California.

Irene Ybanez

~~

(Sign t re)

(Type or print name)

/

MEMBERS OF THE BOARD

LOS ANGELES UNIFIED SCHOOL DISTRICT

RAMON C. CORTINES SUPERlNTEl\1])ENT OF SCHOOLS

MONICA GARCIA, PRESIDENT YOLIE FLORES

TAMAR GALATZAN

MARGUERITE POINDEXTER LAMOTfE NURY MARTI1\'EZ

RICHARD A. VLADOVJC

STEVEN ZIMMER

JOHN E. DEASY, PH.D. DEPUTYSUPER~l\1])ENT

VIVIAN K. EKCHIAN

CHIEF HUMAN RESOURCES OFFICER

Human Resources Division Office of Staff Relations

333 South Beaudry Avenue, 14th Floor - Los Angeles, CA 90017 Telephone: (213) 241-6056 - Fax: (213) 241-8405

DR. JOHN BOWES, ASSISTANT CIDEF HUMAN RESOURCES OFFICER

December 27,2010

Anita I. Martinez, Regional Director Public Employment Relations Board San Francisco Regional Office

1330 Broadway, Suite 1532 Oakland, CA 94612-2514

Re: Philip A. Kok v. Los Angeles Unified School District

Unfair Practice Charge No. LA-CE-5520-E Date Filed 12/8/10

Dear Ms. Martinez:

Thank you for granting Los Angeles Unified School District the extension date of January 14, 2011 to respond to the above Unfair Practice Charge. The original due date to respond was December 24,2010.

Sincerely,

i~~~

c: Philip A. Kok Kate Collins

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_ 'lTE OF CALIFORNIA

Receipt OYMENTRELATIONSBOARD
ra ITIaIling. L PRACTICE CHARGE
Tracking No.: 3777I806Ul53 Dafe Filed: 121812010 3:12:14P
ge Corm with proof of service attached to each copy iu the appropriate PERB
eludes concurrent service and proof of service of the charge as required by
regional offices or PERB's website at www.perb.ca.gov. If more space is
Elf: rd number items.
InqUiries'
iteat . NO 0" If yes, Case Number:
1 EMPLOYEE ORGANIZA nON 0 EMPLOYER 0
ONLVj
J
,
J
•
charge:
TEACHER, BAlBNM.OIV, (323)-316·0244
e) EMPLOYEE ORGANIZA nON 0 EMPLOYER iii
,
tact:
lTE UNIT, (213)~241~6117
ion only if the charge is filed against an employee organization.)

ion only if the employer is the Slate of California. See Government Code section 18524.)
~ SEE REVERSE SIDE

DO NOT WRITE IN THIS SPACE:

Case No.:

Tracking No.: 4720K901 W957

Date Filed: 1/25/2011 II :39:S1A

STATE OF CALIFORNIA

PUBLIC EMPLOY.MENT RELATIONS BOARD

UNFAIR PRACTICE CHARGE

INSTRUCTIQNS: File the nriginal and one copy of this charge form with proof of service attached to each eopy .111 the appropriate PERB regional office (see PERB regulation 32075). Proper filing includes concurrent service and proof of service of the charge as required by PERB regulation 32615(c). AU forms are availahle from the regiunal offices or PERB's website at www.perb.ca .. gov. [f more space is needed for any item on this form, attach additional sheets and number items.

IS THIS AN AMENDED CHARGE?

YES Ii:!

NO 0

If yes, Case Number: LA·CE·5520·E

1. CBARG1NG PARTY:

EMPLOYEE 0

ErvrPLOYEE ORGA.N:IZATION

o

EMPLOYER 0

3. Full namec PHILIP A. KOK b. Mailing Address:

16828 CHICAGO AVE BELLFLOWER. CA 90706

c. Telephone number:

(323)·316·0244

d. Name, title, and telephone number or person li.ling charge:

PHILfP A. KOK, SUBSTITUTE TEACHER, BAlBNM.DIV, (323)-316-0244

e. Bargaining llnjt(s) involved:

UTLA

2. CHARGE FlLED AGAINST: (mark only ODe)

EMPLOYE.E ORGA."'IZATlO.'l

o

EMJ>LOYER 0"

'8. Full name:

LOS ANGELES UNIFIED SCHOOL D.ISTRICT

b. Mailing Address: 333 S_ BEAUDRY

LOS ANGELES, CA 90017 c. Telephone number: (213).241.1000

d. Name, title, and telephOlle number of agenUu contact:

MA IUORIE JOSA PHA T, DIRECTOR, SUB UNIT_ (213 )·241-61 17

3. NAJ\IfE OF EMPLOYER (Complete rhjs section only if the charge is filed against an employee organlzarlon.)

a. Full name:

b. Mailing Address:

4. APPOINTING POWER: (Complete this section only if rhe employer is the State of California. See Government Code section 18524.)

a, Full name:

b. iH ailing Address:

c. Agent:

PERB-61 (08/04)

SEE REVERSE SIDE

5. GRlEV ANCE PROCEDURE

Are the parties covered by all agreement containing a grievance procedure which ends in binding arbitration?

Yes 1>"1 No 0

6. STATEi\1ENT OF CHARGE

o Educational Employment Relations Act (EERA) (Gov. Code sec. 3540 et seq.)

o Ralph C. Dill> Act (Gov. Code sec, 3512 et seq.)

,0 Higher Education Employer-Employee Relations Act (HEERA) (Gov. Code sec. 3560et seq.)

o Meyers-Miljas-Browu Act. (MMBA) (Gov, Code sec. 3500 e! seq.)

o Los Angeles County Metropolitan Transportation Authority Transit Employer-Employee Relations Act (TEERA) (Pub. Utilities Code sec. 99560 et seq.)

o Trial Court Employment Protection and Governance Act (Trial Court Act) (Article 3: Gov. Code sec, 71630 - 71639.5)

o Trial COlIn Interpreter Employment and Labor Relations Act (Court Interpreter Act) (Gov. Code sec. 71800 et seq.)

b .. The specific Government or Public Utilities Code sectionts}, or PERB regulation sectionjs) alleged to have been violated is/are: .EERA

c. For M:MBA, Trial Court Act and Court lnterprerer Act cases. if applicable, the specific local rule(,) alleged to have been violated is/are (a copy of the applicable local rulers) MUST be attached to the charge):

1 AMENDED COJ\tIPLAINT 1/25/11

2

3 I filed an original complaint (case no. LA-CE-5520-E) on December 8,2010 versus LAUSD 4 having been encouraged by Kennon Raines to do so, & based on the fact that I was NOT

5 getting offered assignments according to my seniority level. I alleged that the LAUSD

6 retaliated against me due to my civil action against them following a miscount of my hours 7 in the 2007-08 school year that led to me losing my health benefits. However, after the re-

8 count, my benefits were restored, albeit I was unable to see my regular doctors for a period 9 of two months during a time when I was having all kinds of tests for chronic pain (cervical

10 radiculopathy) and considering surgery (as well as pain management, including physical 11 therapy). This is an AMENDED COMPLAINT due to new information Nonetheless, the 12 next year (2008-09) I received less assignments and came out below 600 ours without a

13 miscount. I remember there being strange lapses in receiving calls & assignments and

14 believe it was done intentional1y to prevent me from reaching 600 hours. The same pattern 15 occurred for 2009-10 so that 1 ended with slightly less than 600 hours and therefore the

16 district was not obligated to provide health benefits. Then, first semester of 2010-11 I was 17 receiving even fewer assignments than ever before 8 also being offered assignments to

18 locations that I have repeatedly indicated to the sub unit and these particular schools

19 themselves are NOT suitable locations for me to work on a regular basis due to lack of

20 "rapport" with either staff or students based on what I believed to be "local prejudice" (i.e. 21 racism ). I felt that they "stereotyped" me (I heard "white boy" as well as "Are you Jewish" 22 among other things. This made it difficult to work effectively as an instructor.

23

24 I also noticed that several times I would decline an assignment on the sub finder but NOT 25 get offered a second or third option as is supposed to be the standard procedure. I

26 suspected that somebody (singular or plural) was intentionally altering the subfinder 27 and/or communicating with others in ways that would negatively affect my assignment

28 options. I believe there was bias against me at the sub unit and at some of the schools and

1

1 perhaps elsewhere within the district office (333 s. Beaudry) and possibly also at the 2 employee organization (UTLA) because of the perception or misperception of me as 3 "white" and "conservative Christian" or ''from a denominational college" etc. I also

4 attended Fuller Seminary in Pasadena. After meeting with Marjorie Josaphat & Regina

5 Echols in December 2010 re the lack of adequate call volume and assignments I discovered 6 that my seniority level was NOT correctly listed. I discussed this with Regina & Marjorie,

7 & subsequently Marjorie adjusted my seniority level to its proper place (according to an

8 email from Regina Echols). At this meeting I also communicated my discomfort with some 9 experiences I've had at various schools which felt like racism andlor gender bias, and

10 noticed that even on the sub unit floor there are NO MALES nor any Anglos (either male 11 or female) as far as I could see. I also communicated my discomfort with the way I was

12 spoken to or AT by Diane & Irma (who answer calls at the sub unit) when I would

13 periodically call to see if any assignments had become available at 7 am (when I hadn't

14 gotten an assignment from the subfmder). In fact, on the day that I met with Marjorie & 15 Regina I had spoken with Diana at 7 am and she had been very condescending towards me 16 and & hung up on her. Thus, when I arrived at the sub unit and had just sat down to talk 17 with Regina, suddenly I heard Diana come on the phone talking to Regina saying she had 18 called for security to stand outside the office. I believe this was politically motivated to

19 make me appear to be an "angry, white man." I do not believe hanging up on somebody

20 who is treating me rudely justifies the need for security with another person on the same

21 floor. I was also surprised when, in response to my comment about some of my experiences 22 of racism (against "whites") (during what I thought was a private conversation) Regina

23 asked this Latino security guard to come in and speak for the entire district and say that

24 there is no racism as if that solved everything.

2

25

26 Nonetheless, after the beginning of the new year (January 2011) the first week of school I 27 began receiving regular calls at the level I was accustomed to for so many years. For two 28 weeks of this year suddenly everything seemed to be returning to normal and I was feeling

3

1 good morale at some of the schools I visited. Then, on January 20,2011 (my birthday) after 2 a day at Belmont Higb School, as I was leaving the main office, a secretary said, sternly, to 3 me, "You need to call this person" and handed me a white piece of paper with a name and

4 "employee relations" next to it. I thought it was from PERB, but it turned out to be a John 5 Braadfield (?) from employee relations at LA USD . I started walking out of the main office 6 and the secretary said, "You need to call him NOW' which seemed like a very demanding

7 and strange thing for her to say, overstepping boundaries to say the least. I had a phone in 8 my hand and could call him as I walked down the hallway or from my car, or however I

9 choose. It made me also believe that she was PRIVY to something that should have been

10 private. 11

12 So I called this fellow named John at the LAUSD and he BLUNTLY, (and I mean this is 13 the most disconcerting and what seems to be completely inappropriate way to tell

14 somebody of such a thing, without warning, after thirteen years with the district) that the 15 LAUSD had decided to "separate" me from employment. At first I thought this was a

16 prank and said so to him. He kept repeating that it was not a prank. I asked him his title 17 and academic credentials and he didn't want to talk about his credentials, if any. He

18 informed me that a decision had been made based on ISR's (Insufficient Service Reports) 19 in my file. I had NO KNOWLEDGE of any ISR's having been filed against me and told

20 him so and told him that I believed this was in retaliation for my PERB complaint. He

21 didn't seem to know what PERB was nor that PERB had authority over the LAUSD in

22 regards to matters of retaliation and EERA . I asked to speak to his supervisor. He said his 23 supervisor was Ira Berman and that he would call me.

24

25 Mr. Berman called me shortly later and said that allegedly a committee that periodically 26 reviews substitute files made decisions based on the alJeged ISR's (that I had never seen up 27 to that point) and decided to separate me from employment. I asked if I had ever been

28 reviewed before and he said he did not know. It seemed strange that he did not know. I

5

4

1 would assume that if this is a committee that reviews substitutes to protect the integrity of 2 the educational process they would have some sort of records to show when they had

3 previously reviewed a person. I asked how do they choose who to review & when & he did 4 not seem to know.

6 He gave me some of the details of the ISR's and the last ISR (of three) was filed against me 7 in January of 2010, one year ago. I wondered why this was happening a year after the fact 8 and he did not seem to know. He said, in response to my inquiry that he was aware of my

9 PERB complaint.

10

11 Mr. Berman proceeded to explain that I could appeal this in writing and another

12 committee of five (of different persons) would independently review my file along with any 13 explanation or references I provide. I rarely, if ever, see a principal in the classroom and 14 told him I don't work alongside other professional adults (although once in a while I have 15 adult assistants) and so I was not sure to whom I would go for a reference but that I would 16 talk to a few people.

17

18 On January 24, 2011, I received a can from Harvey Sterneim who works part-time for 19 UTLA as a representative (he is a retired special education teacher from Nightingale

20 Middle School). He asked to see the ISR's and encouraged me to go to the LAUSD office on 21 Beaudry to pick them up. In fact, I was already on the way there and arrived mid-morning. 22 I called ahead and Lena said to come up to the 14th floor and pick up the ISR's. Entering

23 the LA USD building I checked in and they said my name was "flagged" and she had to call 24 for permission to allow me to enter. They gave permission for me to enter. I went to the 14th 2S floor and waited for the ISR's. I also asked the first person I saw if I could talk to Ira

26 Berman. It turns out that the fellow I spoke to was "Woody" and he said he was looking for 27 Ira as well. He walked down the hallway and said he would tell him I wanted to speak to

28

1 him. A few moments passed and a lady behind the desk said she just observed Woody & 2 Ira going down the steps (it was my conclusion that they were trying to be evasive) .

3

4 I asked to speak with John B. ,a large African-American man instead (the one who told me 5 of "separation" on January 20) . I could see him behind the glass in his office speaking on

6 the phone. He apparently heard me but said be didn't know me. I said "I'm Mr. Kok" and

7 we went into his office. I asked about the ISR's and why I didn't receive notice of them and 8 he pulled them outand pointed to some certified mail numbers on the bottom of each one,

9 but didn't have any envelopes or green signature cards showing I received them or signed

10 for them. One of the ISR's had a different name typed on it and crossed out with my name 11 written in, in pen.

12

13 I noticed later that two of the three ISR's were NOT signed by the principal. Two showed 14 they had allegedly been sent to my former Agoura Hills post office (which is not my current 15 address now), and the third was allegedly sent to my former Manhattan Beach post office 16 (which is a very old address) . While we were speaking a security guard by the name of

17 John Gray appeared outside the office. I don't know what prompted him to appear, but for 18 the rest of my time he followed me around until I left the building.

5

19

20 I took the ISR's to the UTLA building and Mike (who is filling in for Jose Govea for the

21 week) . He works as a representative of some sort, but is not a former or current teacher. 22 He made copies of the ISR's and we discussed the matter. He wanted to start the grievance 23 procedure but was concerned about how old they were and why I didn't receive notice of 24 them. I repeated some of what I told Harvey on the phone about my addressees) and my 25 current address, etc. I left UTLA and sent a letter to each of the principals at the schools

26 that issued the ISR'sexpressing my hope to informally resolve this and asked them to

27 contact me so that I could meet with them.

28

1 Previously I mentioned feeling as if I was being treated with racial prejudice at some

2 schools and that I was getting repeated calls to schools that seemed more inclined to be

3 antagonistic towards me, including Liechty and also Audobon (two of the schools that filed 4 ISR's WITHOUT the principal's signature ). I was also insulted by a secretary on the day 5 of the ISR in question as well as previously by a cafeteria chef at Audobon. Calling an

6 adult man, age 44, working in a professional setting requiring mutual respect from the kids 7 and colleagues "sweetie" is an insult and derogatory, and I note that a chef at Los Angeles

8 Academy Middle School did the same in a condescending manner on January 19,2011. I

9 note that a Wendy Goldman also referred to me condescendingly as 'sweetie" at a UTLA

10 meeting in December 2010. That's prison talk, or ghetto talk, & I don't do that, nor expect 11 to be treated that way.

6

12

13 I also wonder if Irma or Diane (last names I do not know) at the Sub Unit (or even

14 Marjorie Josaphat or Regina Echols) are locals and possibly attended one of these schools 15 that I had repeatedly indicated I did not want to regularly sub at but yet they kept offering 16 assignments to these schools (as well as Mann Middle School) via the subfinder, as if

17 intentionally so. I know that there are "locals" (which I am not) who want to maintain the 18 status quo according to their comfort zone and allegiances. I also know that some have

19 "profiled" me negatively as "conservative" or "conservative Christian" based on where I 20 attended college (Calvin College) and seminary (FuUer Seminary) . A fellow substitute by 21 the name of Daryl Bohanon even called me a "Christian geek" to my face at a UTLA

22 meeting in December 2010.

23 I've also experienced anti-Semitism even though I am NOT Jewish but misperceived by

24 some as Jewish. Ironically, Jewish people, once they know I am a Christian, and not Jewish 25 do NOT think of me as "one of them."

26

27 What it ALL COMES DO"VN TO is the fact that I have successfully served the LAUSD as 28 a substitute teacher for thirteen years now (since January, 1998).

10

1 This is over 1000 hours in 100's of classrooms and 50 to 100 different schools around Los

2 Angeles. During these thirteen years I have had NO COMPLAINTS nor any ISR's that I 3 knew of until January 20, 2010. I haven't had the opportunity to defend or explain myself 4 in regards to these ISR's and all three seem unfair and unwarranted & I have good

5 explanations and also my own accusations. None of the ISR's have anything to do with

6 "abusive" behavior and nothing "criminal" , and the only one that directly involves a

7 student was about a junior high student who wet his pants during a presentation in front of 8 the class in regards to which I was unfairly blamed for allegedly not allowing him to go to

9 the restroom, which is UNTRUE.

11 I BELIEVE, base don the timing of my PERB complaint (December 2010) and the timing 12 of their alleged "review" of my file, and notification of separation (January 2010) that this 13 is RETALIATION for thinking that I, a "mere substitute teacher", have the right to file

14 anything against the "big boys" at Beaudry or others who want to try to keep treating me 15 like a little boy. I believe the move of LAUSD from the Grand Avenue location to the sky

16 rise on Beaudry went to the heads of some of the people there and they have FORGOTTE 17 the real purpose of the organization: namely, educating the students. That's what I've been 18 doing INSIDE the classroom for thirteen years, plus two prior as a regular teacher, a

19 semester in Mlchigan, and six months in Costa Rica, among other things. I do not deserve 20 to be treated poorly, rudely, or with prejudice for who I am, A GOOD PERSON with

21 GOOD INTENTIONS and the EDUCATION to back it up.

22

23 S

.--":::'::::"lfIr-IJf-+U_N-.. _ ;~1'!:TY OF PERJURY

X.( ~~OK

LOYEE #704195

24

25

26

27

POBOX 152

MALIBU, CA 90265

16828 CmCAGO AVE BELLFLO\VER, CA 90706

28

7

DECLARA nON

I declare under penalty of perjury that I have read the above charge and that the statements herein are true and complete to the best of my knowledge

Title, if any: SUBS.lTUTE TEACH.E.R,. BAlBAIM.Drv

Mailing address:

16828 CmCAGO AVE BELLFLOVVER, CA ,}0106

T elepho ne Number: (323)-316-0244

8 9 10 1 1

1

[ 1 FEDERAL I declare that I am employed within the office of a member of the bar of this Court at whose direction the service was made.

Executed on January 14,2011 at LO~~

U' Veronica Bonilla , __

PROOF OF SERVICE (CCP §§ 1013a, 2015.5)

STATE OF CALIFORNIA

)

) ss )

2

COUNTY OF LOS ANGELES

3

4

I am employed in the aforesaid County, State of California; I am over the age of eighteen years and not a partX to the within entitled action; my business address is: 333 S. Beaudry Avenue, 201 Floor, Los Angeles CA 90017.

On January 14, 2011, I served the foregoing document(s) Philip A. Kok v. LAUSD (LA-CE-5520-E) Position Statement on the interested parties in this action, to the address and number listed below:

5 6 7

Anita I. Martinez, Regional Director Public Employment Relations Board San Francisco Regional Office

1330 Broadway, Suite 1532 Oakland, California 94612-2514 Facsimile: 510 - 622-1027

Philip A. Kok

12 P.O. Box 152

Malibu, California 90265

1 .... _i

14

15

16 17 18 19 20 21 22 23

24

25

26

27

28

[ Xl BY MAIL: I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice, it would be deposited with U.S. postal service on that same day with postage thereon fully prepaid at Los Angeles, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit.

[ Xl VIA FACSIMILE: I caused a true and correct copy of the aforementioned document to be forwarded via facsimile to the fax numbers listed above.

[Xl STATE I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Anita 1. Martinez, Regional Director

Unfair Practice Charge Nos. LA-CE-5S20-E January 14,2011

Page 2 of 3

"white" people worked on the floor. He added that he was similarly encountering a lack of white people in the student body populations and school sites stan: which he found troubling.

Ms. Nichols attempted to keep the conversation on the subject of seniority, and she pointed out that Charging Party had in fact turned down an assignment call that very morning. He responded by contending that the students at particular schools wished him harm and the sites were biased.

Around that time, another administrator, Ms. Josaphat (a non-Caucasian) entered the office. Charging Party again asserted that there was a lack of "white people" working at the location and many other District locations. He continued to frame his concerns in terms of the racial makeup of offices and school sites.

Ultimately, Charging Party was informed that his seniority was lost due to a break in service. In February 2005, his credential was in professional practice division of the CI C until July 2005 - and once he was reinstated, that hired date was used. Ms. Josaphat informed him that she would place him back at his initial hiring date of January 1998. Ultimately, Charging Party left the LAUSD office. Subsequently, he sent an e-mail and card "forgiving" the administrators in the substitute office.

LEGAL DISCUSSION

Charging Party's Charge fails to set forth a prima facie case of retaliation for several reasons. First, he fails to set forth a clear protected activity in which he was engaged and for which he was retaliated. The closest allegation is his claim that he filed a writ of mandate on an unrelated issue approximately three years ago. Even if filing that writ constituted protected activity, he does not allege that the professionals in the substitute office were aware of such activity, or that they were sufficiently empowered to alter the automatic sub finder system that would provide Charging Party notifications of potential assignments. Indeed, the sub tinder system is incapable of bias because it is all automatic system.' The actions of the substitute office professionals also indicate that they were completely unaware of his background, and that they were overwhelmingly agreeable and helpful to him.

Finally, Charging Party fails to set [011h any adverse action he has suffered. The facts alleged establish that he is receiving calls to work, but that he is turning them down due to his own racial biases (See Exhibit A - Assignment Log). Clearly the LAUSD is not obligated to screen sub finder calls to ensure that Charging Party has opportunities to work at "white" schools exclusively (even if such schools still existed).

I Sub finder will call the first 200 five times in seniority order for maybe 100 jobs. He is called refuses the school so the cans keeps rotating within those 200 and if other subs accept that job (the one he refused) it would not stop and go back to him the system would keep calling the first 200 subs and if all the calls are filled be/ore it rotates back to him that was his gamble.

Doc# 200058

Anita 1. Martinez, Regional Director

Unfair Practice Charge Nos. LA-CE-5S20-E January 14,2011

Page 2 of 3

"white" people worked on the floor. He added that he was similarly encountering a lack of white people in the student body populations and school sites stan: which he found troubling.

Ms. Nichols attempted to keep the conversation on the subject of seniority, and she pointed out that Charging Party had in fact turned down an assignment call that very morning. He responded by contending that the students at particular schools wished him harm and the sites were biased.

Around that time, another administrator, Ms. Josaphat (a non-Caucasian) entered the office. Charging Party again asserted that there was a lack of "white people" working at the location and many other District locations. He continued to frame his concerns in terms of the racial makeup of offices and school sites.

Ultimately, Charging Party was informed that his seniority was lost due to a break in service. In February 2005, his credential was in professional practice division of the CI C until July 2005 - and once he was reinstated, that hired date was used. Ms. Josaphat informed him that she would place him back at his initial hiring date of January 1998. Ultimately, Charging Party left the LAUSD office. Subsequently, he sent an e-mail and card "forgiving" the administrators in the substitute office.

LEGAL DISCUSSION

Charging Party's Charge fails to set forth a prima facie case of retaliation for several reasons. First, he fails to set forth a clear protected activity in which he was engaged and for which he was retaliated. The closest allegation is his claim that he filed a writ of mandate on an unrelated issue approximately three years ago. Even if filing that writ constituted protected activity, he does not allege that the professionals in the substitute office were aware of such activity, or that they were sufficiently empowered to alter the automatic sub finder system that would provide Charging Party notifications of potential assignments. Indeed, the sub tinder system is incapable of bias because it is all automatic system.' The actions of the substitute office professionals also indicate that they were completely unaware of his background, and that they were overwhelmingly agreeable and helpful to him.

Finally, Charging Party fails to set [011h any adverse action he has suffered. The facts alleged establish that he is receiving calls to work, but that he is turning them down due to his own racial biases (See Exhibit A - Assignment Log). Clearly the LAUSD is not obligated to screen sub finder calls to ensure that Charging Party has opportunities to work at "white" schools exclusively (even if such schools still existed).

I Sub finder will call the first 200 five times in seniority order for maybe 100 jobs. He is called refuses the school so the cans keeps rotating within those 200 and if other subs accept that job (the one he refused) it would not stop and go back to him the system would keep calling the first 200 subs and if all the calls are filled be/ore it rotates back to him that was his gamble.

Doc# 200058

b. Mailing Address: 333 S. BEAUDRY

LOS ANGELES, CA 90017 e. Telepbone number:

(213)-241-1000

d. Name, title, and telephone number of agent 10 contact:

I

STATE OF CALIFORNIA

PUBLIC EMPLOYMENT RELATIONS BOARD

UNFAIR PRACTICE CHARGE

DO NOT WRITE [N THIS SPACE:

Case No.:

Tracking No.: 3777rS06UI53

Dale Filed: 121812010 3: 12:14P

INSTRUCTIONS: File the original and one copy of this charge form with proof of service attached to each copy in the appropriate PERB regional office (see PERB regulation 32075). Proper filing includes concurrent service and proof of service of the charge as required by PERB regulation 32615(c). All forms are available from the regional offices or PERB's website at www.perb.ca.gov. If more space is needed for any item on this form, attach additional sheets and number items.

IS THIS AN AMENDED CHARGE?

YES 0

NO ta

If yes, Case Number:

1. CHARGING PARTY:

EMPLOYEE Ii'!

EMPLOYEE ORGANIZA nON

o

EMPLOYER 0

a. Full name:

PHILIP k KOK (JOHN V ANDER)

b. Mailing Address:

PO BOX 152 MALIBU, CA 90265

Co Telephone nu mber:

(323)-316-0244

d. Name, tille, and telephone number ofpcnonliling charge:

PHILIP A_ KOK (JOHN VANDER), SUBSTITUTE TEACHER, BAlBAlM.DIV, (323)-316-0244

e. Bargaining unit(s) involved:

UTLA

2 .. CHARGE FlLED AGAINST: (mark only one)

EMPLOYEE ORGANIZATION

o

EMPLOYER 0

8. Full name:

LOS ANGELES UNIFIED SCHOOL D!STRlCT

MARJORIE JOSAPHA T, DIRECTOR, SUBSTITUTE UNIT, (213)-241-6117

3. NAME OF EMPLOYER (Complete this section only if the charge is filed against an employee organization.)

a. Full name:

b. Mailing Address:

4. APPOINTING POWER: (Complete this section only if the employer is the State of California. See Government Code section 18524.)

I. Full name;

b. Mailing Address:

c.Agent:

PERB-61 (08/04)

SEE REVERSE SIDE

s. GRIEVANCE PROCEDURE

Are the parties covered by an agreement containing a grievance procedure which ends in binding arbitration?

Yes 0 No 0

6. STATEMENT OF CHARGE

o Educational Employment Relations Act (EERA) (Gov. Code sec. 3540 et seq.)

o Ralph c_ Dills Act (Gov. Code sec. 3512 et seq.)

o Higher Education Employer-Employee Relations Act (HEERA) (Gov. Code sec. 3560 et seq.)

o Meyers-Milias-Brown Act (MMBA) (Gov. Code sec. 3500 et seq.)

o Los Angeles County Metropolitan Transportation Authority Transit Employer-Employee Relations Act (TEERA) (Pub Utilities Code sec .. 99560 et seq.)

o Trial Court Employment Protection and Governance Act (Trial Court Act) (Article 3; Gov. Code sec. 71630 - 71639.5)

o Trial Court Interpreter Employment and Labor Relations Act (Court Interpreter Act) (Gov. Code sec. 71800 et scq.)

b. "The specific Government or Public Utilities Code sectionts), or PERB regulation section(s) alleged to have been violated is/are 3543.5. Interference with employees' rigbts proh ibited

It is unlawful for a public school employer 10 do any of the following:

(1I) Impose or threaten to impose reprisals on employees, to discriminate or threaten to discriminate against employees, Or otherwise to interfere with, restrsiu, or coerce employees because of their exercise of rights guarsllleed by this chapter. For purposes of this subdivision, "employee" includes an applicant for employment or reemployment.

c. For MMBA. Trial Court Act and Court Interpreter Act cases, if applicable, the specific local ruie(s) alleged to have been violated islare (a copy of the applicable local rule(s) MUST be attached to the charge):

d. Provide a clear and concise statement of the conduct alleged to constitute an unfair practice including, where known, the time and place of each instance of respondent's conduct, and the name and capacity of each person involved. This must be a statement of the facts that support your claim and not conclusions of law. A statement of the remedy sought must also be provided. (Use and attach additional sheets of paper if necessary.)

The agreement between LAUSD and the substitute teachers is that substitutes will be called according to seniority. I believe that I have NOT been called according to seniority and at times have NOT been given more than one option, as recently as today (1218/10) I was called by the subfinder at 6 am and declined the first offered assignment to Mann Middle School.

The subfinder is supposed to allow you to decline up to three assignments before NOT calling anymore that morning. You can decline for one of three reasons: 1) illness, 2) personal necessity, 3) prefer another assignment. Recently, not only have i NOT been getting as many calls as I suspect I should be getting, but when I have gotten called and declined an assignment, I have NOT been getting 2nd or 3rd options.

Sometimes I must decline an assignment because certain locations (schools) have become unreceptive to me (i.e. issues with a secretary, principal, etc). Yet, for some reason, the subfinder keeps offering me assignments to these schools that I keep declining (and will continue to keep declining to return to these schools, four or five in number, a tiny percentage of the schools to which I WILL GLADLY go). Why does the subfinder keep offering assignments to schools which the sub unit ( or sub finder) knows I regularly decline and then does NOT give me second or third options? I have seniority dating back to 1998.

I just realized now that there has been a slow but sure decline in assignments offered to me ever since I filed a petition for writ of mandate in the Los Angeles Superior Court to have my health benefits reinstated three years ago. My benefits were reinstated only because I went back and found missing assignments (non-recorded by various school secretaries). When these were properly recorded, retroactively (several months later) ,my hours added up to 600 + and I received my benefits back and dropped my petition.

However, the next year (2008.09), I received even LESS assignments and did NOT make enough hours to get health benefits (with strange gaps of time that I did NOT get called; so that I came out about 50 hours below the required minimum for health benefits ). Then, last year (2009-10) , the same tbing happened, with a long lapse in assignments in February of 2010, and ultimately, once again, I came out just below the number of hours needed for health benefits.

Recently, I started writing letters & had some correspondence and contact with my employee organization (UTLA) and was given some suggestions for addressing the matters, and on 12/2110 I went to the sub unit at LAUSD and met with Regina Echols (assistant administrator at the LAUSD sub unit) as well as with Marjorie Josaphat (director of the sub unit) and complained that I wasn't getting enough assignments offered according to my seniority.

1

Regina showed me a paper for that particular day (12/2) indicating that I did get called but that I declined the first assignment. The paper also showed me that about twenty assignments were offered and accepted to subs lower than me in seniority after I declined the first English assignment. She did NOT explain why I did NOT get a second or third option. This happened again on 12/S/I0 with an initial assignment offered to Mann Middle School, which I have found to be notoriously difficult for me as a "whiten person (i.e. levels of prejudice are so high that I become almost completely ineffective in the classroom and believe I can and should be used elsewhere, where I can be more productive.

I explained some of my conerns about this to Regina and Marjorie. I also explained that I felt like I was being treated with indifference and insensitivity and at times hostility by some of the sub unit phone ladies, especially Irma, and most recently, Diane, neither of whom I have ever met in person and it was not unti112/2/10 that I identified Irma (AfricanAmerican) at the sub unit and distinctly remember Irma saying something negative/judgmental to me on the phone around 2005 when I had a interruption of service because I was appealing a decision by the California Teaching Credential Commission, which is my right to do, and which ultimately led to the restoration and clearance of my credential.

I believe there were people in the sub unit who did not understand what had happened to me ( I was actually a victim of violence in a matter not pertaining to the school district nor any school) and may still be be experiencing prejudice based on that historic event dating all the way back to 2001 (the action by the California Teaching Commission did not happen until 2005 for some inexplicable reason).

This is evidenced by the fact that I have worked for eleven years for the school district in probably more than 75 or 100 schools and have had NO insufficient service reports, and am in good standing with the law and as a member of the Christian church. Yet when I came to the sub unit on 1212/10 to meet with Regina Echols, I believe it was Diane (I heard her state loud and clear when she was on the phone with Regina that she had summoned security to stand by the door) who called for security to stand outside the door as I was meeting with Regina because they allegedly thought I might be potentially violent.

After eleven years working for the school district in good standing and having never met either Regina or Marjorie, to be treated as potentially violent is very insulting, and allegedly because I hung up on Diane earlier that morning when she snapped at me for apparently asking the same question twice?

Here I am with a BAlBAIM.Div and I am being spoken "down" to by these ladies with associate degrees? I believe it is retaliation for things I didn't do and am NOT guilty of, and may be mixed with racism and/or simply an attempt to depopularize me. Things I see and hear said or done towards me in some classrooms is not unlikely to be prejudice that is found outside the schools as well (kids often replicate parents prejudice towards others, including teachers).

2

DECLARA nON

I declare under penalty of pe~ury thai I have read the above charge and that the statements herein are true and complete to the best of my knowledge

and belief and that this declaration was executed on 1218/10 at BURBANK, CALIFORNIA.

PHILIP A. KOK (JOHN VANDER)

Title, if any: SUBSTITUTE TEACHER SA/BAlM.DIV

Mailing address:

PO BOX 152 MALIBU, CA 90265

Telephone Number: (323)-316-0244

3

PROOF OF SERVICE

I declare that 1 am a resident of or employed in the County of LOS ANGELES, State of

CALIFORNIA. 1 am over the age of 18 years and not a party to the within entitled cause. The name

and address of my residence or business is:

PO BOX 152 MALIBU, CA 90265

On 12/8110, I served the COMPLAINT on the parties at the addresses or fax number listed

below:

LAUSD SUB UNIT

333 S_ BEAUDRY

LOS ANGELES, CA 90017

by (check the applicable method or methods):

o Placing a true copy thereof enclosed in a sealed envelope for collection and delivery by the United States Postal Service or private delivery service following ordinary business practices with postage or other costs prepaid.

o Personal delivery.

o

Facsimile transmission in accordance with the requirements ofPERB Regulations 32090 and 32135(d).

Page 1 of 2

I declare under penalty of perjury that the foregoing is true and correct and that this declaration was executed on 12/8/10, at (City and State where executed) BURBANK CA.

PHIUP A. KOK (JOHN V ANDER)

(Type or print name)

(Signature)

Page 2 of2

Los Angeles Unified School District

OFFICE OF THE GENERAL COUNSEL LABOR AND EMPLOYMENT SERV1CES

333 S. Beaudry Avenue, 20th FloOT, Los Angeles, CA 90017 TELEPHONE (2l3) 241 "7600; FACSIMILE (213) 241-3308

RAMON C. CORT1NES Superintendent of Schools

DA V1D HOLMQUIST General Counsel

KATHLEEN COLLINS Associate Genera! Counsel II

January 14,2011

Via Facsimile and U.S. Mail (510) 622-1027

Anita I. Martinez, Regional Director Public Employment Relations Board San Francisco Regional Office

1330 Broadway, Suite 1532 Oakland, California 94612-2514

Re: Philip A. Kok v. Los Angeles Unified School District Unfair Practice Charge Nos. LA-CE~5520~E

Dear Ms. Martinez:

Thank you for granting Los Angeles Unified School District ("LAUSD") additional time to respond to the above-referenced unfair practice charge.

FACTUAL SUMMARY

On or around December 2, 2010, Charging Party called the LAUSD substitute office and spoke with Ms. Diana Lemus between the hours of 5:30 a.m. and 8:00 a.m. He indicated his concern that he had not received additional calls for substitute assignment opportunities, beyond his first call on that date. He called numerous times on that date and was informed that the administrator with whom he needed to speak, Ms .. Nichols, would not be in the office until 8:00am. After 8:00 am, he called every 5~ 1 a minutes until she met with hi.m around 11 :00 am.

Staff reported to Ms. Nichols that Charging Party appeared extremely agitated, sarcastic, and edgy. He contended that the automated "sub finder" system was biased, and that the staff was blocking him from speaking to Ms. Nichols. Ms. Nichols was similarly concerned about his manner when she met with him, and so she rightfully alerted security.

When the two met at 11 a.m., Charging Party asserted that his seniority date was incorrect. Wben asked for evidence to support his claim, Charging Party began commenting on how few

Doc# 200058

Grievance Form For Certificated Employees (See Article V of the DISTRICT/UTLA Agreement)

1. Full Name of Grievant 2. Grievant's Employee Number
Phi lip KOK - #2011-100037 704195
3. Grievant's Assigned Work Location 4. Grievant's Home Phone
Audubon MS 323-316-0244
5. Grievant's Home Address, Including City & ZIP
P. O. Box 152, Malibu, CA 90265
6. Specific Article(s) and Section(s) of the Agreement Allegedly Violated
Article X, Section 7.0 - (Inadequate Service Report)
7. Statement of Complaint (state the facts relating to the Grievance, including names,
dates, and circumstances)
On or about January 20, 2011, the Grievant received notification from the District
(during a telephone call with Dr. Ira Berman) that he had been issued an Inadequate
Service Report (ISR) by assistant principal Cynthia Durousseau of Audubon MS. Such
ISR had been issued without cause in violation of the above-cited Article. Moreover,
the ISR was never properly issued nor timely issued in that the District failed to provide
the Grievant with a copy within ten days as required by the Collective Bargaining
Agreement despite the fact that the District had his correct address and was using this
address for correspondence including his paycheck.
8. Remedy Sought under the Agreement
1. Declaratory relief.
2. Removal of Inadequate Service Report from all District files.
3. Such further relief as may be granted under the Collective Bargaining
Agreement.
9. UTLA is representing the Grievant on this matter
Authorized UTLA Officer or Staff
Roger Scott
10. Date filed with Immediate Administrator 11. Grievant's Signature
'M
January 25, 2011 '~A, kok-.,
-- Copies of this form shall be distributed as follows:

Staff Relations Field Director Madeline Latham-Wilson

Site Administrator Dewayne Davis

United Teacher/Los Angeles (UTLA) Roger Scott

Employee , Philip Kok

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FROM

FIRST-CLASS MAIL

704195

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LOS ANGELES' UNIFIED SCHOOL DISTRICT ACCOUNTING & DISBURSEMENTS DIVISI.QN.

PAYROLL SERVICES BRANCH RETURN SERVICE

P.O. BOX 513307, TERMINAL ANNEX REQUESTED

LOS ANGELES, CA 90051-1307

1 9950

Philip Kok

P. O. Box 152 Malibu CA 90265

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·JCZ-At·11

90265

v.Iobiles~

FIRST,CLASS MAIL U.S. POSTAGE

1025 Pi EI Dorado Hills CA 95762-9025

PAID

OST OUTPUT

AV 02 002135 13362B 13 B"5DGT

111'1.1,1111111"1.11"11111111,111111,,,111111,,1 '11'11111111111

PHILLIP A. KOK

16828 CHICAGO AVE BELLFLOWER CA 90706·5028

OFFICERS

A.J. DUFFY President

ANA VALENCIA

UTLA/NEA Vice President UTlA/NEA Affiliate President

JOSH PECHTHALT UTLA/AFT Vice President AFT Local 1021 President

JULIE WASHINGTON Elementary Vice President

GREGG SOLKOVITS Secondary Vice President

DAVID GOLDBERG Treasurer

BETIY FORRESTER Secretary

January 25, 2011

Mr. Philip Kok

P. O. Box 052 Malibu, CA 90265

RE:

KOK, Philip vs. LAUSO • OF: 01/25/11 #2011·100037

United Teachers los Angeles • 3303 Wlishire Blvd, 10th Floor, los Angeles, CA 90010· (213) 487-5560 • www.ulla.net

1.-____ Serving Los Angeles tecchers wilh Ihe California Teochers Assoc!allon/Natlonal Education Association ----~

and the Calilornio Federation of TeacherS/American Federallon of Teachers, AFL-CIO

~

Dear Mr. Kok:

Enclosed is a copy of the formal grievance filed by UTLA on your behalf. It is imperative that you be aware of the confidentially clause contained in the Collective Bargaining Agreement. This clause, in part, provides for complete confidentiality once a grievance has been formally filed.

Accordingly, you are advised not to communicate the subject of your grievance with anyone without prior approval of the undersigned or other UTLA Staff Representative.

You will be contacted within the near future concerning the scheduled date of a Step One Meeting, which is a preliminary meeting between the school administrator(s) and yourself accompanied by me, to discuss your grievance.

Finally, please take note of our office procedure regarding the maintenance and handling of your file. In the event that you desire to submit letter(s), memorandum(s), note(s) or any type of document it is advisable that you only submit j::oQie§ to our office since we cannot assure the meintenance or return of ycor originals. Additionally, we will only maintain your file for a period of five years from the date that your grievance is filed.

a e any questions or concerns, please call me.

dyr QPEIU #.537 AFl-CIO, CLC

January 25, 2011

OFFICERS

A.J. DUFFY President

Mr. Dewayne Davis, Principal Audubon MS

4120 11th Ave

Los Angeles, CA 90008

ANA VAlENCIA

UTLA/NEA Vice P,residenf UTLA/NEA Affiliate President

JOSH PECHTHALT UTLA/AFT Vice President AA Local 1021 President

JULIE WASHINGTON Elementary Vice President

RE: KOK, Philip VS. LAUSD - DF: 01/25/11

#2011-100037

GREGG SOLKOVfTS Secondary Vice Presidenf

Dear Mr. Davis:

DAVID GOLDBERG Treasurer

The above-referenced matter is hereby referred to your office under the provisions of Article V., Section 8.0 of the Collective Bargaining Agreement.

BEm FORRESTER Secretary

I await your reply within the deslqnated time limits.

"

RS:dyr OPEIU #537 AFL-CIO, CLC

cc: Madeline Latham-Wilson Philip Kok

United Teachers Las Angeles • 3303 Wilshire Blvd, lOth Floor, los Angeles, CA 90010' (213)487-5560 • www.utla.net

'------ Serving Los Angeles teachers with the California Teachers Association/National Education ASSOCiation ------'

and the California Federation of Teachel5/American Federation of Teachers, AfL-CIO

~