AFFIDAVIT OF EUGENE ENGLAND

Comes now, your affiant, Eugene England and makes the following statements base upon 
his own personal knowledge and belief:
1. I am over the age of eighteen and a member of the Board of Trustees for the 
Warsaw Community School Corporation.
2. I was elected by the voters of School District 7 of Warsaw Community Schools in 
November of 2002 for a four (4) year term.  December 2007 will be the end of my 
position.
3. I ran against an incumbent in District 7 and won by receiving 78% of the votes.
4. I grew up in the Claypool area and graduated from Claypool High School in 1952.  
I taught school at Silver Lake for five (5) years, was elementary principal for 
Silver Lake and Claypool combined for ten (10) years and then elementary 
principal at Silver Lake for twenty (20) years.  Thus I have thirty-five (35) years 
as teacher and elementary principal in the Warsaw Community School system.
5. My four (4) children attended Claypool and Silver Lake elementary schools and 
all graduated from Warsaw Community High School.  
6. My wife grew up in the Silver Lake area and graduated from Silver Lake High 
School.
7. My background and experience show that I am very aware of the opinions, 
beliefs, etc. of the people I represent in District 7. 
8. The Warsaw Community School Corporation is a public school corporation 
located in Kosciusko County and has an approximate enrollment of 6500 students.  
At the present time these students attend ten (10) elementary schools, two middle 
schools, one high school and one alternative school.  In addition, several parochial 
elementary schools feed into the Warsaw Community SchoolsÕ secondary 
schools.  
9. During my seventeen months as a member of this school board I have voted 
against the closing of the three schools, Atwood, Claypool, and Silver Lake.  All 
votes regarding this matter have been 5-2 in favor of closing.  Ron Yeiter and I 
were the opposing voices.
10. During one school board meeting I made the following statement.  "During my 
thirty-five (35) years with WCS I have seen our past school boards make 
decisions that were good, some bad, some I approved of, some I disapproved of, 
but this decision to close these small schools is the worst decision ever made."  
11. Prior to my election to the board, a thirty million dollar building program which 
included some remodeling at Lakeview Middle School, adding an addition to the 
central office, improving and building at the high school, and building an athletic 
complex was approved.  The biggest issue was the construction of the football 
field and stadium.  The vote was 6-1 in favor, with the negative vote cast by a 
member who was opposed because there was nothing for elementary children.
12. The building program originally included building an elementary school in the 
Northwest, which would take the place of Atwood Elementary and alleviate 
overcrowding at Madison, Leesburg and Harrison elementaries.  Why the 
elementary school was excluded, I do not know unless it was concern over 
potential public outcry regarding tax increases.
13. When I came on the school board I believed they would make the decisions since 
they have the power.  I have been greatly disappointed with our board because:
A. Five members seem to vote for whatever Dr. McGuire endorses. 
B. There is very little discussion or questions asked on important 
issues.  
C. It appears to me that these five board members make decisions 
outside of our regular meetings.
D. The make-up of our board does not represent our communities in a 
fair and unbiased manner.  
a. We have a father and daughter among our seven (7) 
members.
b. Three (3) of our members have a strong interest in Winona 
Lake and Grace College.
14. The first year that I came on the board there were various proposals about the 
building of elementary schools and their locations.  It is very difficult to explain 
the many different building plans and the flip-flops that Dr. McGuire proposed.  
Many of these ran together or were changed before a vote was taken.
A. Build a school in the Northwest along with the thirty (30) million-dollar 
project, which I described earlier.
B. Close four (4) schools (Atwood, Claypool, Jefferson, and Silver Lake) and 
build two (2).
C. Build a three (3) or four (4) section school at Jefferson, close Claypool and 
Silver Lake and transport elementary children from those two schools all 
the way to Winona Lake (Jefferson).  In my opinion, this is the worst 
proposal of all.
D. Build a three (3) or four (4) section school at Winona Lake and take 
students from Harrison and Eisenhower elementaries.
E. The big plan that Dr. McGuire finally came up with was to close Atwood, 
Claypool, and Sliver Lake.  The Atwood students would then be bused to 
Madison with a few going to Leesburg.  Then Claypool students would go 
to Eisenhower and the Silver Lake students would be transported to 
Washington.
F. The original plan was to have portable classrooms at Eisenhower and 
Washington, but later that was determined to be unnecessary.
15. During this time a population consultant was hired to do a survey of our school 
system.  He presented his findings to the board.  He found we have growth areas 
and also districts that will not grow due to older citizens.  One such area was the 
Jefferson Elementary area, located in Winona Lake.  The expertÕs 
recommendations, as I recall, were to build an elementary school in the 
Northwest, and combine Claypool and Silver Lake by either (1) building a new 
school at 700 South and County Farm Road, (2) remodeling and adding on to 
Claypool Elementary, or building a new school between Silver Lake and Claypool 
elementaries.  None of these were acted on by the board.
16. Dr. McGuire reported that Grace College was willing to trade a practice soccer 
field for the Jefferson property, which is land-locked by Grace College.  Many 
people in the community reported that the soccer field area was contaminated 
from dumping of Gatke Corporation hazardous waste.  The board was never 
informed on the money involved or details of the proposed deal.
17. Public meetings were held at Atwood, Claypool and Silver Lake about the 
proposed closing of these schools.  Many patrons attended these meetings with 
feelings running rather high.  Board members who attended were Ron Yeiter and 
myself.  Dr. McGuire sent a communications letter to all board members telling 
them that it would be a waste of time to attend.  As important as this issue was I 
would think all board members should have been present.
18. At the Claypool meeting, Dr. McGuire, while strolling back and forth in front of 
the large crowd in the Claypool gym made this statement, "If a remonstrance is 
filed then I will close these three (3) schools."  At this point I interrupted him and 
explained to the people why Dr. McGuire was so sure of himself.  I said, "He can 
do this because the five (5) board members who are not here will vote for 
whatever he recommends.  He has their votes in his back pocket."
19. The remonstrance was filed and easily gathered over one thousand signatures, the 
majority of which were from Warsaw, not Atwood, Claypool and Silver Lake.
20. Dr. McGuire then decided not to contest the remonstrance because it would divide 
the community.  How could the community be more divided?  I believe the real 
reason was that Dr. McGuire recognized that the majority of the patrons opposed 
his proposal and he would lose.  
21. Opposition to Dr. McGuire and his plan to close the three schools has been very 
strong.
A. Letters to the Editor in local newspapers have, in my estimation, been 20 
to 1 against Dr. McGuireÕs plan.
B. Patrons at our board meetings have asked time and again to put the issue 
to a vote.  Refusal and no comment usually occur.  One board member 
made the comment that you canÕt let people vote on every unimportant 
issue or they may want to vote on teachers or the basketball coach.  In my 
opinion, this attitude trivializes real issues.
22. Try telling the people in these three communities that this is not important.  They 
know losing the elementary schools will have negative effects on their towns and 
communities for years to come.  Some immediate problems are:
A. Miles to drive for parents whose children desire to participate in after 
school activities. 	
B. Kindergarten parents will need to drive to pick up students or deliver them 
for afternoon sessions.
C. Walking to the neighborhood school will no longer be possible.
D. It is about sixteen (16) miles from the southwest corner of Lake Township 
to Washington Elementary.  How long will the bus ride be?
23. Kent Adams, our state senator, and Dave Wolkins and William Ruppel, our state 
representatives, have opposed the closing of the three schools.  They have 
attended board meetings and have spoken against Dr. McGuireÕs plan.  Kent 
Adams, who has extensive fiscal experience, suggested alternatives but got 
nowhere with his offered help.
24. Last year, on two occasions, I met with Dr. McGuire in his office and discussed 
the following:	
A. We need a plan and schedule.  I suggested that we keep the three schools 
open while we implement the following:		
1.	2005, start construction of the Northwest school.  When finished, 
close Atwood and move students into the new school.  This school 
would also solve the overcrowding at Leesburg, Madison, and 
Harrison.  
2. Keep Claypool and Silver Lake open, but have a plan for 2006 to 
combine these two schools.  We would either remodel or add on to 
the existing Claypool School or build a new three-section school 
on State Road 15 near the overhead or somewhere between the two 
towns.  Let the people in these two communities decide.
3. Months later when portables were discussed I had another meeting 
with Dr. McGuire and suggested that since the long range plans 
were to put Claypool and Silver Lake together, wouldnÕt it be more 
sensible and practical to move the portables to Claypool and bring 
the Silver Lake students there until sound decisions could be made 
about these two schools.
25.	Rande Thorpe, our business manager, and Dr. McGuire have stated time and 
again that three hundred thousand dollars ($300,000) will be saved during the first 
year these schools are closed.  However, no documentation of the potential 
savings has been provided.  General terms are quoted but line by line items where 
savings will take place have not been issued.  Unanswered questions are:
A. Will more buses be needed to transport the four hundred fifty (450) 
children affected?
B. Has the extra mileage and the cost of gas been figured into the plan?
C. What will the total COST be to transport these children to the four 
receiving schools?
26.	Another question people ask me is about the closed buildings.  Who is responsible 
for maintaining them until they are sold?  Does Warsaw Community Schools have 
obligations to provide security, mowing, heating, cooling, etc. to prevent damage?  
Has this expense been figured in? 
27.	One reason for closing the three schools is to save money so that it will not be 
necessary to release teachers due to a shortage of money.  To my knowledge, the 
board has not been asked for suggestions except when we cut the elementary 
school counselors.  Adjoining school corporations are having problems with 
finance from the state but are coming up with different ways to save money and 
cut costs.  Some are:
A. cut athletic programs
B. eliminate coaching positions
C. cut gifted and talented programs
D. no field trips or teacher and administration conventions		
E. Larger class sizes especially in upper grades
These are all hard to do but necessary until our state gets on better financial terms.  
28.	With the Warsaw Community School system, athletics are a sacred cow.  Notice 
that no cuts have been recommended for sports and for another untouchable, the 
gifted and talented program.
Also, new positions have been created in our central office.  The question comes 
up often, how much more is our payroll in the central office compared to four 
years ago?  If we are trying to save money in our school system then why are 
administrators taking trips to conventions and other meetings and why are we 
increasing overhead?
29. I worked many years under our former superintendent, Dr. Lee Harman.  Dr. 
Harman was always concerned about the public and their perceptions of Warsaw 
Community Schools.  He tried to maintain a positive approach.  With Dr. 
McGuire and the present board we have:
A.	Discussed limiting public comments at our board meetings.	
B. After years of taping each school board meeting, we are no longer taping.  
Now there is no tape to compare to the minutes, which have been 
inaccurate on key points during Dr. McGuireÕs tenure.
C. Many questions asked by the public are received with "no comment", 
"weÕve discussed this before", or "weÕll look into it".
30. It concerns and bothers me that when I meet people from Tippecanoe Valley, 
North Manchester, and Whitko school districts they make reference to our thirty 
million dollar football field and question why we would close schools and bus 
children to Warsaw.
31. I was present at the Motion to Dismiss hearing on May 7, 2004 at the Warsaw 
Justice Building.  The hearing before Judge Douglas Morton was between the 
CCQE (Concerned Citizens for Quality Education) and the Warsaw Community 
School Corporation.  Some of the information presented by the schools attorney 
Tom Wheeler as fact and in Dr. McGuireÕs affidavit was, in my opinion, untrue or 
misleading.  
32. Page 2 Paragraph 1
I was present at the Claypool public meeting when Dr. McGuire made the 
statement, "If a remonstrance is filed then I will close the three schools." Notice 
he used the word I and not the Warsaw School Board.
	Page 2 Paragraph 1
Once again we have the figure of $300,000 used to show the savings for the first 
year.  Where are the numbers for the complete cost of transportation?  Showing 
savings on water and electricity are not practical when the 450 children will still 
need water, restroom facilities, heat, and lights.
When pressed on this issue at the board meeting, Rande Thorpe did a quick 
accounting on what looked like scratch paper and then made a presentation on the 
overhead to the audience.  It appeared to be done without much thought and on 
the spur of the moment.  I have yet to see a complete breakdown of how the 
$300,000 will be saved.

33. Page 3 Paragraph 2
It is difficult to see how the receiving schools, Madison, Leesburg, Eisenhower, 
and Washington, can take into their buildings 450 students when a few years ago 
we were operating at or near capacity.  I know that by using storage rooms, multi-
purpose rooms, conference rooms, special reading rooms, art and music rooms, a 
claim can be made for no problems with more students.  Are all these rooms 
suitable for regular classrooms? I donÕt believe so.
34. Page 3 Paragraph 3
Historical highs are not accurate.  Example: When I was elementary principal at 
Silver Lake in the 70Õs and 80Õs there were enrollments of 200 plus.  The highest 
was 222.  This is 25 more than Dr. McGuire has listed.
35. Page 4 paragraph 1
Where and when did Dr. McGuire decide we might move sixth graders to the 
middle school?  There was some discussion from a couple of parents at the public 
meeting held at Washington School on June 16, 2003.  All board members were 
opposed, with the exception of Ron Yeiter, who thought this was an idea to 
consider.  This proposal might lead one to believe that Dr. McGuire is not sure 
about the future capacity of our schools in the fall of 2004.

36. Page 5 Paragraph 1
Dr. McGuire made this statement in his affidavit.  "The distance that children will 
be bused next year is equal to or less than the distance that many of these students 
are already being bused for swimming."  I would point out that the fifth and sixth 
grade students at Silver Lake are transported each year for five (5) days of swim 
lessons to the Warsaw Community Pool which would be about 11 miles on State 
Road 15.  Next year, students at this school who live in the southeast corner of our 
school district will travel about fifteen or sixteen miles twice a day, each school 
day, in all kinds of weather on country roads.
37. Page 6 Paragraph 1
I have made visitations to all three of the involved schools and the only way the 
figures of teacher/student ratio at Atwood, 14 to 1 and Silver Lake at 16 to 1 can 
be valid is to include the teachers, special needs teacher and the teaching 
principal.
38. Page 6 Paragraph 3
Dr. McGuire keeps referring to all the public discussion and input regarding his 
decision.  Yes, there was much public input with the vast majority being opposed.  
This is why Dr. McGuire and the five members of the board will not consider 
putting the school closing proposal up for a vote by the public.  Members of the 
public, plus Ron Yeiter and myself have tried and made motions but to no avail.  I 
sincerely believe a public vote would be about 3 to 1 against the superintendent 
and the board.
39. Page 7 Paragraph 1
There was a Community-Based Planning Project in 2000.  Both representatives 
from Silver Lake reported the committee was stacked (their words) with teachers, 
relatives, and others involved in education for the WCS system.  They felt so 
strongly about this that they chose not to attend the afternoon session.
40. Page 7 Last Paragraph
Dr. McGuire reported that the $30 million project went through with no 
opposition.  Brad Braile, a member of the board at that time voted against it.  His 
rationale was that with all the money being spent there was still nothing for our 
elementary schools.
41. Page 8 Paragraph 2
Reference is made to Demographic Consulting updating done by Dr. Jerry 
McKibben. Why was his recommendation ignored?
42.	Page 9 Paragraph 1	
The affidavit reads: Because the School Board feared that a petition/remonstrance 
process would split the community, the School Board decided not to pursue the 
project.  The community was already split and upset.  Fear of defeat led to the 
decision.
After the School Board election in November of 2002 I looked forward to being a 
good member and being able to provide input and information.  This has not been 
the case and I have been greatly disappointed with the present school board.  
Maybe things would have been different if we had not been faced with the 
building and closing projects.  When my four-year term is over I am uncertain if I 
shall seek to be re-elected.  My biggest disappointment will be that I was a 
member of the School Board when the three schools in Atwood, Claypool, and 
Silver Lake were closed and the damage this will do for years to come to these 
three communities.  It is difficult to believe that three schools can be shut down 
forever, leaving only many great memories.
I affirm under the penalties for perjury that the foregoing representations and facts 
are true and accurate to the best of my knowledge, history, and belief.
Eugene England