FACTS RELEVANT TO THE ETHICS CHARGES

6. During Wall’s election campaign in 2021, Wall ran on a platform of “keeping

NJEA politics out of Holmdel Schools.” This type of comments ultimately became the subject of
an ethics complaint by his opponents in that election, in which Surekha Collur, Kimberly Tuccillo
and Weiping Wang claimed that Wall wrongfully stated at a public meeting that they were backed
by the NJEA. They also accused Wall of making similar false claims in a “robocall” to residents
that the Collur/Tuccillo/Wang ticket was evidence that the “labor union is running a ticket to take

the schools over.” Ultimately, Collur and Tuccillo were elected to the Board of Education, along
with Wall, but the actions of Wall undermined the efficient operations of the School District.
7. Following the general election in 2021, Urbanski was approached by members of
the Board of Education to consider serving as President of the Board. Over the next few weeks,
she spoke to the members of the Board about their thoughts. She immediately had the support of
the newly elected members of the Board of Education.
8. On or about December 2, 2021, and December 3, 2021: When Urbanski spoke
to Wall to ask him for his support, Urbanski was shocked by Wall’s hostility towards her. In the
past, Urbanski and Wall always were able to speak about Board matters in a friendly and
productive manner. In fact, Urbanski was directly responsible for obtaining three of the signatures
necessary for Wall’s nominating petition to return to the School Board, including her own, and
displayed his campaign signage outside the entrance to hers and her mother’s residences in
Holmdel. However, once Urbanski discussed the idea of serving in Board leadership, Wall’s
attitude towards Urbanski shifted immediately.
9. Urbanski initially believed that Wall would not support her for Board leadership
because he, too, sought to serve in that capacity as President. However, many members of the
Board would not support Wall because they found him too political and divisive to serve in a
leadership capacity. Based upon his actions throughout the last year, however, it is now apparent
that Wall’s hostility towards Urbanski and other Board members is grounded in bias based upon
gender and national origin, as well as his political animus towards the NJEA.
3
 10. As soon it was clear that Urbanski would serve as Board President, Wall repeatedly
told her he would not support her and would, in fact, “do everything he could do to obstruct” and
not participate in Board related matters if Urbanski was selected as President. (From Urbanski’s
contemporaneous notes of phone calls placed with Wall to his number (908) 461-3400 on
12/02/2021 at 08:07 AM and 12/03/2021 at 08:26 AM.)
11. On or about January 5, 2022: At the reorganization meeting on January 5, 2022,
Wall exhibited extreme hostility towards the female members of the Board after they selected

Urbanski as Board President by a 5-4 vote and Linda Zhang as Vice President by a 5-4 vote. All
Board members also swore to follow the Code of Ethics at the reorganization meeting. All the
male Board members voted against the women for Board leadership, but Wall’s animosity was
evident in his agitated demeanor that evening and the email that he sent immediately thereafter.
12. Immediately following the reorganization meeting, Wall sent an email on January
5, 2022 to Urbanski and two male board members in which he clearly conveyed his unwillingness
to work with the new female members of the Board. (Emails from Wall to Urbanski, Joseph
Hammer (Board Member), Mike Petrizzo (Board Secretary), Mike Sockol (Board Member), and
Paul Green (Board Counsel), dated on January 5, 2022 8:35 PM titled “Committees” and sent
immediately after the Board’s reorganization meeting. Wall included Board Counsel Paul Green
in this email in an attempt to make it immune to OPRA as attorney client privileged, which it is
not.) He also continued to object to Urbanski and Zhang serving as leaders of the Board. Wall
refused to chair a committee or participate in committee meetings (unless the Board acted as a
Committee of the Whole) and he advised Urbanski he would not serve on any committee with the
new members of the Board, Collur and Tuccillo, both of whom are female and were perceived by
Wall as being supported by the NJEA. Wall’s refusal to serve on any committees with the two new
Board members -- Collur or Tuccillo -- demonstrated his gender bias. He also failed to copy Zhang
on this email, which demonstrated both his bias towards her based upon her gender and national
origin. Instead, Wall copied two of the male members of the Board of Education on these emails,
further underscoring the bias he exhibits towards the female members of the Board of Education.
4
 “Also, it’s prudent that I not serve with any members with bogus ethics complaints until
they are adjudicated, so kindly do not add Collur or Tuccillo to any committee that
includes me as I will not be seated with them at this time.
My recommendation to you as a newer person is committee of the whole which I have
argued for since I began.
I’ll serve all all committee work that requires all members to attend as a group of nine.”

13. In response to this email, Urbanski questioned Wall as to why he would copy only
the male Board members on his email. Wall rebuked Urbanski’s inquiry and claimed that it was
she who was sexist (email from Wall to Urbanski, Hammer, Sockol, Green and Petrizzo dated
January 6, 2022 at 9:08 am):
That was a sexist email Elizabeth and noted accordingly.
14. On or about January, 25, 2022: The Board had its next meeting on January 25,

2022. Following that meeting, Wall sent an email to the entire Board entitled “Zoom Questions”
that only underscored his bias towards Urbanski and the other female board members. (Email from
Wall to Board Members on Thursday, January 27, 2022 at 8:23 AM titled “Zoom Questions”.) In
that email, he was critical of Urbanski, claiming that he “was disappointed last night” by how the
meeting operated and indicated it was “not a good look for this board.”
15. In response to Wall’s email, Urbanski wrote “Thanks so much for sharing your

thoughts on how the meeting went,” to which Wall responded, “Sure! Reflects citizen feedback.”
Thus, it appears that Wall was actively engaged in seeking to undermine Urbanski’s role as Board
President with people he views as his supporters within the general public as part of his personal
campaign to undermine the newly reorganized Board.
16. On or about January 27, 2022: Wall also commenced his attacks towards
Urbanski by emailing the incoming Superintendent, Scott Cascone, on January 27, 2022, (prior to

the commencement of his employment in March, 2023) in which he tried to undermine Urbanski
and in furtherance of his threat to disrupt the female-led leadership team of the Board (email from
Wall to Scott Cascone (incoming Superintendent of Schools) on Thu, Jan 27, 2022 at 2:35 PM as
a reply to Cascone’s email on Thu, Jan 27, 2022 at 9:46 AM titled “Greetings Holmdel Professional

5
Community!” to Board Members (and other undisclosed recipients) communicated via Board
email systems). In this email he stated as follows:

“Last night was more an observation night for me of the new

leadership team who failed to engage the public, who have real
questions and demand real answers. So I was short on inputs and
made my exit. My base as you may have noticed is the citizenry not
the sclerotic behavior on the dais. I spoke with Paul and asked him
to give Elizabeth better advice on meeting management and public
engagement. It will smooth out I would imagine and unquestionably
when you start. I hope you liked my new mask. I intend to wear it
often.

Terence M. Wall
Board Member”

In response, Scott Cascone stated (email from Cascone to Wall on Thu, Jan 27, 2022 at 2:59),

“You can count on improvements when I join the board on the dais
good sir!”

17. On or about May 26, 2022: Wall sent another email to Urbanski to criticize how
she manages the Board meetings (email from Wall to Urbanski on Thursday, May 26, 2022 7:12

AM titled “Mike Sockol”), in which Wall responded as follows:

“My point is not whether or not you should bring a meeting back on
track my point is that you can be more graceful decent and respectful
in the manner within which you do it. On that count you do it very
poorly and next time I will call you out on it publicly as a decorum
issue which is my role in ensuring that the schools run well. If you
want to get Paul to carry your water on it feel free to ask him for a
memo.”
18. The animus that Wall exhibited towards the female members of the Board on the
day of the Reorganization Meeting, and in his email correspondence immediately following that
meeting and other meetings throughout the year, were intended to disrupt the operations of the
Board and the district due to his inherent and outward bias against women.

6
 19. Soon after being sworn in as President, Urbanski, in an effort to bring harmony to
the Board and due to the approaching start date of a new superintendent and the need for the
District to focus on its academic mission, spoke with the new members of the Board about their
ethics complaint (Kimberly Tuccillo, et al. v. Terence Wall, Holmdel Board of Education,
Monmouth County, School Ethics Commission Docket C53-21) to see if this could be brought to a
resolution that would promote better operations of the Board (Text messages between Urbanski,
Kimberly Tuccillo, and Surekha Collur dated Fri, Jan 7 at 4:07 PM, included here as Exhibit A).

The complainants decided to administratively dismiss their ethics complaint against Wall in early
February 2022, based upon a good faith belief that this would bring peace to the Board. Once the
ethics complaint was administratively dismissed pursuant to the request of the complainants,
Wall publicly denigrated the members of the Board (all of whom are female), in a public matter,
posting the dismissal of the ethics complaint on his website in which he indicated that they
“exhausted their professional reputations, abused state resources and cost Holmdel taxpayers
thousands with fake campaign claims, they run away before losing in court.” (Facebook Page post
by Wall in March, 2022.)
20. Thereafter, Wall continued to ignore the policies and practices of the Board, by
ignoring Board leadership and the chain of command, in his actions as a Board member. The
President of the Board serves as the main point of contact to the Superintendent, and members of
the Board shall copy the Board leadership on their communications to the Superintendent to ensure
the efficient operations of the Board. Wall has ignored that process in his communications with
the Superintendent throughout this year. (There are many examples which may be obtained under
subpoena as Wall often cc’s Paul Green (Board Counsel) in an attempt to make his emails subject
to attorney client privilege and immune to OPRA requests even though they do not solicit or
contain privileged legal advice.)
21. Wall’s conduct over the last year, by failing to copy Urbanski and Zhang on his
communications with the Superintendent, and, at times, by sending communications that only copy
male members of the Board of Education, fails to meet the letter and spirit of anti-discrimination
7
laws that are intended to ensure that there is an absence of bias or discrimination in decision
making by public entities.
22. Wall also has sent communication throughout the prior year, in violation of the
Open Public Meetings Act, despite multiple warnings to cease that practice. For instance, on
numerous occasions, usually to denigrate Urbanski and follow through with his threat to Urbanski
that he would not respect her as President of the Board, Wall would send email communications
to the entire Board. Those communications undermined the efficient operations of the Board of

Education.
23. In an effort to force Urbanski to resign from the Board, Wall utilized an incident
that occurred in her personal life. In November 2021, Urbanski was involved in a minor motor
vehicle incident while driving in dense traffic on school property as she was collecting her child
from school. A person later accused Urbanski of having struck her car, which Urbanski disputed.
This matter was ultimately settled among the parties and Urbanski pled guilty to two minor traffic
tickets. Soon after the accident occurred, Urbanski disclosed this matter to the Board’s legal
counsel and asked whether she should share it with the Board, and she was advised she did not
need to because it was a personal matter, not a board-related matter. (Emails between Urbanski
and Paul Green as Board Counsel to seek legal advice as to her responsibilities in her role as an
ordinary Board Member, November, 2021.)
24. On or about March 9, 2022, and March 23, 2022: In 2022, the accident was
referenced in a Facebook post, and, upon information and belief, Wall engaged in communications
to obtain information about this traffic incident from members of the public and disclosed this
information with other Board members as exhibited by the fact that, in March 2022, Board Member
Pete Reddy sent several emails in which he stated that the Board should discuss Urbanski’s
accident at a board meeting (email from Reddy to Wall dated March 23, 2022 at 2:47 PM and titled
“Hit and Run Question”; email from Reddy to Wall dated March 9, 2022 10:45 PM and titled
“Private not Private” obtained under OPRA request).

8
 25. On or about June 10, 2022: the Asbury Park Press ran an article about this minor
traffic incident involving Urbanski. It is unclear how the press learned about this incident because
the other party involved in the incident indicated that they did not approach the press and Urbanski,
on advice of her attorney, did not either. However, Wall engaged in communications with the
Asbury Park Press about this non-Board matter, in furtherance of his efforts to cast Urbanski in a
false light and undermine her leadership as Board President, by stating as following in the article
(“Video shows Holmdel School Board president's minor crash with student”, Joe Strupp, Asbury

Park Press, June 10th 2022).

“At least one school board member, Terence Wall, said an apology
is owed to Ledo, ‘The young lady and her family deserve an apology
and not a continued attack from my fellow board member, in my
opinion,’ Wall said, stressing that he does not speak for the entire
board.”
26. When Wall made this statement to the Asbury Park Press, he did not have personal
knowledge or information about what had occurred. In fact, he never spoke to Urbanski prior to
making those statements; thus, his communications were not informed or based upon fact, and
instead, Wall’s communication to members of the public and the press about a personal incident
involving Urbanski demonstrates the lengths he would go to harass, intimidate, and bully
Urbanski, in an effort to disrupt to the operations of the Holmdel School District.
27. Wall’s statement to the press -- “in my opinion” -- does not insulate his statements
of having violated the Code of Ethics because his statements to the press infers he is disclosing the
opinions of other members of the Board of Education. Wall is not the Board President, and thus,
is not permitted, under Board policy, to speak on behalf of the Board (New Jersey Commissioner
of Education, Final Decision in the Matter of Christopher Treston, Board of Education of
Randolph Township, Morris County, SEC Dkt. No. C71-18, OAL Dkt. No. EEC 09014-19, Agency
Dkt. No. 6-5/21A) regardless of any such disclaimers. At the time that this incident was made
public in the press, the journalist writing the article approached all Members of the Board for
comment and only Wall responded, showing that Green’s legal advice that this was a private matter

9
not relevant to the Board was clearly made and understood by the Board Members and that Wall
deliberately chose to violate the Code of Ethics he was fully aware of in responding in this manner.
Instead, Wall’s communications with the press are one of the many examples of his ongoing
campaign of harassment to undermine the leadership of the Board and disrupt the operations of
the Holmdel School District.
28. In a search engine optimization text for articles written by Wall’s wife, the text of
those articles on a TapInto page includes words that are deliberately intended to cast Urbanski in

a false light (see exhibit B, below). The TapInto publishing organization ultimately retracted those
false, misleading and defamatory comments made about Urbanski (see exhibit C, below), but the
publication of those articles demonstrates the lengths by which Wall has engaged in a malicious
attack towards Urbanski, in an effort to disrupt the operations of the Board.
29. On June 11, 2022: Despite being made aware that this car accident was not an
appropriate topic for discussion at a meeting of the Board because a car accident involving a
member of the Board does not transform that matter into a Board matter, on June 11,
2022, Wall emailed the entire Board, in violation of the OPMA, in which he included a screenshot
of an article in the Asbury Park Press regarding the car accident, in which he threatened the female
members of the Board as follows (email from Wall to Board Members on Sat, Jun 11, 2022 at
11:51 AM titled “Front Page: Attacking a Young Girl – RESIGN NOW” and following emails):

“COLLUR, BRIAMONTE, TUCILLO, ZHANG – your silence

speaks volumes on how the board majority has covered up and are
you treating this young lady – how dare you allow Elizabeth to
attack this young girl with falsehoods on the front page of the paper
with an attorney who obviously has no idea what he’s doing to the
reputation of the Board of Education on her behalf shame on all of
you. This is how you treat women?

Urbanski – RESIGN NOW! You have become a majority of bullies

to, of all people, the students in your care.

Paul Green should resign as well. What a joke.

Disgrace.

10
 Terence Wall.”

30. The aforementioned communications demonstrate that the animus and hostility that
was evident at the reorganization meeting in January 2022 carried forward through the year, and
Wall’s manufactured outrage over a private matter involving Urbanski was an attempt to force her
to resign. Wall’s actions were motivated by discriminatory bias towards female leadership of the
Board in an effort to remove female leadership from the Board.
31. Furthermore, this email illustrates Wall attempting to manage the professional staff
of the Board by instructing the Board’s Counsel to resign because he did not like the legal advice
given. This is done without regard to the proper chain of command that he is fully aware of having
attended multiple ethics training sessions during his various tenures on the School Board and is

outside his role as a Board Member.

32. During the past year, in her capacity as Board President, Urbanski has received
many complaints from members of the Board of Education of Wall’s inappropriate hostility he
exhibits towards the female members of the Board of Education. The hostility exhibited by Wall
at the reorganization meeting in January 2022 has not subsided and only has grown throughout the
year.
33. On or about February 22, 2022, March 24-26, 2022 and April 6, 2022: For
instance, in March 2022, Wall engaged in an attack towards the children of two female Board
members who had been hired by the District to fix broken computers, despite the fact that the
Board attorney indicated that students can be hired by the District to perform those services. Wall
made baseless accusations in texts, emails, and public meetings about how those students were
hired for those positions, without any personal knowledge or information to do so. Wall’s
statements only exemplified his discriminatory animus towards the female members of the Board
of Education in the manner in which he treated their children (emails from Wall that include Board
Counsel Paul Green and so are not available under OPRA request but would be deliverable under
subpoena).

11
 34. On or about June 11, 2022: Board Vice President Zhang advised Wall to
discontinue his campaign of gender bias as a board member (Email from Zhang to Wall and other
Board Members on Sat, Jun 11, 2022 at 1:44 PM):

“You need to stop threatening, bully and sex discriminate women

Board members”

Wall responded to this email in a hostile manner (email from Wall to Zhang and
other Board Members on Sat, Jun 11, 2022 at 1:53 PM):

“Linda – gaslighting and cancel culture does not work with me.
Topic will not be changed.”

35. On or about February 24, 2022: Wall also actively engages in comments
regarding the school’s curriculum that exhibit his bias. Some of those comments, however, have
caused strife based upon race and/or national origin. For instance, on or about February 24,
2022, Wall wrote to the school administration and the Board on a topic entitled “WAR” as follows
(Email from Wall to School Administrators on Thu, Feb 24, 2022 at 3:06 PM titled “WAR”):

“Putting out the question of what are we doing as a board and

districts on the communication of this new war and the education
imperative for our kids who are living through it. Also I anticipate
Taiwan belligerence to continue as well but that’s just
opinion. What and how, if anything are we communication. I think
we have a role to play in terms of education. Regards, TW”

36. Wall’s reference to “Taiwan belligerence” was a direct attack against Vice
President Zhang and her national origin; indeed, because of this email, Zhang spoke with the then-
Acting Superintendent to discuss this matter and how it could be wrongly interpreted.
37. On multiple occasions, Wall has failed to respect the role and responsibilities of
school personnel, causing the Superintendent to engage in regular communications with Urbanski
to remind her that Wall needs to confine his actions to policy making and to stop interfering with
the roles and responsibilities of school personnel.

12
 38. On or about October 14, 2022: For instance, on October 14, 2022, after reviewing
the agenda for a Curriculum and Instruction Committee, Wall engaged in his own research of the
books that were being presented to the Board for approval and emailed the members of the
Curriculum and Instruction Committee, the Superintendent, the Assistant Superintendent, Director
of Curriculum & Instruction, and secretaries of the district the following response to one of the
images in a book that was being presented for approval (email from Wall to Reddy (head of C&I
committee), Art Howard (Asst. Superintendent of Schools), Elizabeth Whitmore (Central Office

administrative assistant), Giovanna Buzzerio (Central Office administrative assistant), Jessica

Irwin (Director of Curriculum), Tuccillo (C&I committee member), and Cascone on October 14,
2022 at 11:27 PM):

“Here's another example – this of reverse racism – the bad actors are
a sneering white kid against a young POC and a fat white cop against
the same girl doing the same thing. Really? This too should be
yanked as anti white and anti police. Maybe you could add fat
shaming but I digress. If it were the other way around the double
standard would be in full bloom. Two wrongs still don’t make a
right. All of this needs ‘lenses’ on it.”
39. On or about October 19, 2022: After the Superintendent and Director of
Curriculum and Instruction engaged in multiple communications with the community about the
revisions to the health curriculum, Wall demanded that the Superintendent have school personnel
rewrite curriculum in those areas in which he found objectionable. In response, Urbanski was
warned by the Superintendent that he would like to speak with her because he was “very concerned
with the level of involvement by board members in making curricular decisions” because of its
interference with the instructional and administrative function in delivering the curriculum to
students. It has been stated on many occasions by school personnel that Wall interferes with the
role of curriculum writing, for his own personal and/or political benefit. This conduct of seeking
to influence the implementation of the curriculum is outside Wall’s role as a Board Member.

13
 40. The aforementioned incidents demonstrate that Wall has acted outside the scope of
his role as a member of the Holmdel Board of Education, which has only heightened during the
last year due to his gender bias towards Urbanski and other members of the Board of Education.
Wall is fully aware of the ethical rules imposed upon school board members by the School Ethics
Code because he affirmed his understanding of the School Ethics Code in each year of his tenure
as a member of the Board of Education, he has had to engage in training about the School Ethics
Code, he has received multiple warnings throughout his entire tenure as a member of the Board of

Education of what conduct is unacceptable under the School Ethics Code, but yet, he still
purposefully engages in an unlawful and unethical practice as a member of the Board of Education.

ETHICS CHARGES
41. For the last year, Wall has engaged in a pervasive pattern and practice, to undermine
the operations of the Holmdel School District, in violation of the School Ethics Code. Wall has
been involved in a campaign to disrupt a woman and minority led School Board by conducting
harassing actions involving unethical methods, by engaging in unauthorized communications with
the public and the press, by conducting his own investigation to intrude upon the private matters
of Board members, and by undermining the Board Leadership in their relationships with School
District administration. Wall engages in harassing, intimidating and bullying tactics to try to
silence people for his own political and/or personal agenda. Wall should be sanctioned for his
deliberate disregard of the Ethics Code so that the District can focus on its educational mission.
42. Prior to and during his Board Tenure throughout the entirety of 2022, and
specifically on or about the following dates: December 2, 2021; December 3, 2021; January 5,
2022; January 25, 2022; January 27, 2022; February 22, 2022; February 24, 2022; March 9, 2022;
March 23, 2022; March 24-26, 2022; April 6, 2022; May 26, 2022; June 10, 2022; June 11, 2022;
October 14, 2022; October 19, 2022; the actions of Wall, by failing to comply with State and
Federal anti-discrimination laws in his actions as a Board member, has created a hostile and

14
discriminatory environment, and therefore has violated the Code of Ethics in the following
manner:
a. Wall has failed to uphold and enforce all laws, rules and regulations of the State
Board of Education, in violation of N.J.S.A. 18A:12.24.1a;
b. Wall has failed to make decisions in furtherance of the educational welfare of
children, in violation of N.J.S.A. 18A:12-24.1b;
c. Wall has failed to confine his action to policy making, planning and appraisal, in

violation of N.J.S.A. 18A:12-24.1c;

d. Wall has failed to set aside is personal beliefs and bias, and instead, has proceeded
in a manner that compromises the Board based upon his only private benefit and
fails to respect that the authority of the Board of Education rests with the Board, in
violation of N.J.S.A. 18A:12-24.1e;
e. In his role as a Board member, Wall is motivated by his own political gain, in
violation of N.J.S.A. 18A:12-24.1f;
f. Wall has failed to adhere to laws, rules and practices that ensure the confidentiality
of matters related to the school, and instead, proceeded in a manner in his hostility
and/or attacks towards other Board members that needlessly injuries individuals
and the schools, in violation of N.J.S.A. 18A:12-24.1g;
g. Wall has failed to support and protect school personnel in the proper performance
of their duties, in violation of N.J.S.A. 18A:12-24.1i.
43. Prior to and during his Board Tenure throughout the entirety of 2022, and
specifically on or about the following dates: June 10, 2022; June 11, 2022; the actions of Wall, by
using his Board position to cast Urbanski in a false light by violating Board policy in his
communications with members of the public and the press, violates the Code of Ethics in the
following ways:
a. Wall has failed to uphold and enforce all laws, rules and regulations of the State
Board of Education, in violation of N.J.S.A. 18A:12.24.1a;
15
 b. Wall has failed to make decisions in furtherance of the educational welfare of
children, in violation of N.J.S.A. 18A:12-24.1b;
c. Wall has failed to confirm his action to policy making, planning and appraisal, in
violation of N.J.S.A. 18A:12-24.1c;
d. Wall has failed to set aside is personal beliefs and bias, and instead, has proceeded
in a manner that compromises the Board based upon his only private benefit and
fails to respect that the authority of the Board of Education rests with the Board, in

violation of N.J.S.A. 18A:12-24.1e;

e. In his role as a Board member, Wall is motivated by his own political gain, in
violation of N.J.S.A. 18A:12-24.1f;
f. Wall has failed to adhere to laws, rules and practices that ensure the confidentiality
of matters related to the school, and instead, proceeded in a manner in his hostility
and/or attacks towards other Board members that needlessly injuries individuals
and the schools, in violation of N.J.S.A. 18A:12-24.1g;
g. Wall has failed to support and protect school personnel in the proper performance
of their duties, in violation of N.J.S.A. 18A:12-24.1i.
44. Prior to and during his Board Tenure throughout the entirety of 2022, and
specifically on or about the following dates: March 9, 2022; March 24-26, 2022; June 10, 2022;
June 11, 2022; the actions of Wall, by violating the Open Public Meetings Act in his
communications with members of the Board, despite multiple warnings to discontinue that
practice, violates the Code of Ethics in the following way:
a. Wall has failed to uphold and enforce all laws, rules and regulations of the State
Board of Education, in violation of N.J.S.A. 18A:12.24.1a;
b. Wall has failed to set aside is personal beliefs and bias in his role as a Board
member, and instead, proceeded in a manner that compromises the Board based
upon his only private benefit, in violation of N.J.S.A. 18A:12-24.1e;

16
 c. Wall has failed to adhere to laws, rules and practices that ensure the confidentiality
of matters related to the school, and instead, proceeded in a manner in his hostility
and/or attacks towards other Board members that needlessly injuries individuals
and the schools, in violation of N.J.S.A. 18A:12-24.1g;
45. Prior to and during his Board Tenure throughout the entirety of 2022, and
specifically on or about the following dates: February 24, 2022; October 14, 2022; October 19,
2022; the actions of Wall, by interfering with the curriculum decisions of the District due to his

own political and illegal bias, violates the Code of Ethics in the following ways:
a. Wall has failed to uphold and enforce all laws, rules and regulations of the State
Board of Education, in violation of N.J.S.A. 18A:12.24.1a;
b. Wall has failed to make decisions in furtherance of the educational welfare of
children, in violation of N.J.S.A. 18A:12-24.1b;
c. Wall has failed to conform his actions to policy making, planning and appraisal, in
violation of N.J.S.A. 18A:12-24.1c;
d. Wall has failed to set aside is personal beliefs and bias in his role as a Board
member, and instead, proceeded in a manner that compromises the Board based
upon his only private benefit, in violation of N.J.S.A. 18A:12-24.1e;
e. In his role as a Board member, Wall is motivated by his own political gain, in
violation of N.J.S.A. 18A:12-24.1f;
f. Wall has failed to support and protect school personnel in the proper performance
of their duties, in violation of N.J.S.A. 18A:12-24.1i.
46. Prior to and during his Board Tenure throughout the entirety of 2022, and
specifically on or about the following dates: December 2, 2021; December 3, 2021; January 5,
2022; January 25, 2022; January 27, 2022; February 24, 2022; March 9, 2022; March 23, 2022;
March 26, 2022; May 26, 2022; June 10, 2022; June 11, 2022; October 14, 2022; October 19,
2022; the actions of Wall, by undermining the operations of the Board and creating exposure for
the District, violates the Code of Ethics in the following manner:
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Exhibit A
Communication from Urbanski to Collur and Tuccillo showing that Collur and Tuccillo
voluntarily withdrew their ethics charges against Wall to promote Board harmony.

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Exhibit B

Email to Adam Darsky, communities manager at TapInto, dated July 17, 2022 at 9:11 AM showing
Search Engine Optimization text (SEO) deliberately crafted to misrepresent the facts of the matter
and to be defamatory and inflammatory:

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Exhibit C

Excerpt from email from Adam Darsky, at TapInto, dated July 18, 2022 at 9:51 AM, stating that
the articles have been modified to remove defamatory content.

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