STATE OF INDIANA	)		IN THE KOSCIUSKO CIRCUIT 
				) SS:		COURT
KOSCIUSKO COUNTY	)		2004 TERM


CONCERNED CITIZENS FOR	CAUSE NO: 43C01-0310-PL-000731
QUALITY EDUCATION, INC.	
(an Indiana not-for-profit corporation)
		Plaintiff

		VS

WARSAW COMMUNITY
SCHOOL CORPORATION
		Defendant
		

	

AFFIDAVIT OF RONALD L. YEITER



Comes now, your affiant, Ronald L. Yeiter, and makes the following statements

 based upon his own personal knowledge and belief:
	
1.	I am over the age of eighteen (18) and a member of the Board of School 

Trustees ("Board") at Warsaw Community School Corporation.
	
2.	I was elected by the registered voters of School District 1 of Warsaw 

Community Schools in November of 2002 and sworn into office on January 13, 2003.  

My elected term as a School Board Trustee will continue for a period of four (4) years 

and will finish at the end of December, 2007.
	
3.	The Warsaw Community School Corporation ("School") is a public 

school corporation located in Kosciusko County and has an approximate enrollment of 

6,464 students.  These students currently attend ten (10) elementary schools, two (2) 

middle schools, one (1) high school and one (1) alternative school.
	
4.	I personally attended the Motion To Dismiss hearing at the Warsaw 

Justice Building on May 7, 2004 involving the Concerned Citizens for Quality Education, 

Inc. ("CCQE") versus the Warsaw Community School Corporation ("WCS").  In 

listening to the discussion of the attorneys for both parties, I was surprised to learn of 

certain statements made by Dr. David McGuire, Superintendent of Warsaw Community 

Schools, in an affidavit addressed to the court.  I was totally unaware of particular 

statements being made and proceeded to obtain a copy of Dr. McGuireÕs affidavit from 

the courtÕs file approximately 4 to 5 days after the hearing.  In reading the affidavit in its 

entirety and then reading the text of Judge Douglas MortonÕs Order of Dismissal, I feel 

that I have a legal and moral obligation to clarify to the best of my ability several blatant 

discrepancies that appeared in Dr. McGuireÕs affidavit commentary.
	
5.	In reference to Item 10, Page 6, Dr. McGuire has emphasized how the 

public has provided input into proposal after proposal.  He is indeed correct that the 

public has offered a great amount of input.  However, the current board membership has 

essentially ignored what public input and professional recommendations that have been 

tendered.  As noted in the Warsaw School Board Policy 103, item D, "The Board 

represents the public of Warsaw Community Schools."  The majority vote of the current 

board membership literally approves most of the recommendations of Dr. McGuire with 

little or no discussion and questions from this majority are certainly a rarity.  For 

example, input from the public who attended the August and September Board meetings 

of 2003 (involving closing of Atwood, Claypool, and Silver Lake Elementary Schools) 

was large in number, yet replies to the public and discussion between board members was 

to the most degree non-existent.  The comments made by Larry Chamberlain, Cathy Folk, 

and Jim Folk at the August 18, 2003 board meeting (Exhibit A) were general in nature 

and addressed no specifics of the proposal.  Mark Minatel mentioned that he would 

determine his decision by the Jefferson Elementary constituency.  Mr. Minatel clearly 

indicated his vote hinged on the desires of a minor portion (in number) of the entire 

school corporation population.  Gene England and I both addressed the problem of 

specific concerns regarding Dr. McGuireÕs proposal (as noted on pages 6 through 8).  I 

emphasized the fact (on page 7) that "there had been no presentation as to dollar savings 

or the mechanics of the plan to the Board.  (I) stressed that there was a need for hard 

dollar figures to clarify what was being proposed.  (I) stated that he had a proposal of 

$300,000 savings with no supporting documentation, which was not enough to vote on 

the recommendation."  I also stated that had the board continued the original building 

plan and recommendation as described from a resolution (Exhibit B) in March 2002 

(which included an elementary in  Prairie Township), a remonstrance would have been

avoided and the closings would not have been an issue as Dr. McGuire had made it.  

Craig Allebach, Jim Folk, Cathy Folk, and Larry Chamberlain were the same members 

who had voted, as a majority, in favor of the building resolution of March 2002.  Now 

these same members were making general statements of approval to close three 

elementary schools without one public statement of factual evidence to support their 

opinions nor any discussion of the consequences of such closings.  At the board meeting 

of September 15, 2003 (Exhibit C), a Silver Lake parent, Angela Fulton, had handed out 

folders to Mr. Rande Thorpe (Chief Financial Officer), Ms. Sandra Hess (Asst. 

Superintendent), Dr. McGuire, and six of the seven board members (Mark Minatel was 

on vacation) which provided budget computations to determine actual cost savings and 

expenses (Exhibit D) in closing the three elementary schools.  Dr. McGuire stated that he 

disagreed with the enclosed figures even though he had not reviewed the data and Mr. 

Allebach, Mr. Chamberlain, Ms Folk, and Mr. Folk flipped through the information for 

approximately a minute and a half. Public comment ended at a certain point and the 

meeting opened for board member discussion.  I made a motion to the board to table 

closing recommendation for a minimum of 30 days with the explanation that we did not 

have all of the details needed to make an educated decision and also the importance of 

having full member attendance for this decision.  This motion was seconded by Gene 

England.  The motion to table was voted  against by Mr. Chamberlain, Mr. Allebach, Ms. 

Folk, and Mr. Folk.  Gene and I continued to ask questions of Dr. McGuire and Rande 

Thorpe.  Larry Chamberlain read a prepared statement that pretty much voiced the items 

that Dr. McGuire had stated at the beginning of this session.  Gene England stated that 

Mr. ChamberlainÕs comments were a carbon copy of Dr. McGuireÕs comments.  Mr. 

Allebach, Ms. Folk, and Mr. Folk made no public comment.  Cathy Folk made the 

motion to close the three schools and Larry Chamberlain seconded the motion.  The vote 

was 4 in favor and two against.  To this day, I have not understood how five of these 

board members have voted on so many recommendations of Dr. McGuire without some 

if any questions or comments that clearly indicate any knowledge, concern, perception of 

results involving our students and community.  I clearly would perceive from the actions 

and lack of public discussions of these five board members that one of eight things are 

occurring:  1) discussions with school administration are being conducted ahead and 

aside from the public meetings and details of discussions are not being relayed to all 

board members, or 2) the board members consider these board decisions secondary in 

importance, or 3) the board members are embarrassed to reflect their lack of knowledge 

involving the subjects at hand, or 4) the board members have an uncanny knack of voting 

the same as the others, or 5) the board members want to appear purely as "team players" 

and really donÕt care for independent thinking, or 6) these members have an extraordinary 

sense of knowing what the public needs regardless of what the public is telling them, or 

7) these members strictly donÕt care and want to end the meeting as quickly as possible, 

or 8) the decisions are pre-decided prior to the meetings in order to fulfill a master plan 

yet to be revealed to the public.  As ridiculous as these possible perceptions might sound, 

I canÕt firmly believe that these board members know all of the answers to so many 

questions that should be asked or are not asked.  I have stated in at least two of our 

meetings in the past 18 months, "we have more questions than we have answers."


6.	In Item 5, page 4 of Dr. McGuireÕs affidavit, it is stated "Should there be 

overcrowding at the elementary schools in 2004-2005 or thereafter, the School board 

could simply move the 6th grade classesÉÉÉ..to the middle schools freeing up 500 

spaces at the elementary schools."  Thomas Wheeler presented this alternative plan to the 

court on May 7, 2004.  I personally had not heard of this plan until the day of the hearing 

nor had any of the board members publicly discussed this alternative at any point since 

the decision had been reached to close the schools.  We had an executive session and 

public board meeting on the evening of May 17, 2004 and not one comment was uttered 

from any of the board members about this "backup" plan.  To this very day, no discussion 

has taken place publicly about this plan.  Dr. McGuire had emphasized prior to the 

closing decision in September 2003 that moving the 6th graders to the middle schools was 

a widely unacceptable alternative and the board members concurred by voting for the 

closing of the three elementary schools with a 4 to 2 vote.  However, the majority of our 

board never raised one single question as to the acceptability of this new alternative.
	
7.	In brief review, page by page, of Dr. McGuireÕs affidavit, only two board 

membersÕ names are stated in the text: Gene England and Ron Yeiter.  Why would Dr. 

McGuire not mention the other five board members?  Dr. McGuire has mentioned on 

more than one occasion that he understands the "positions" that Gene and I must maintain 

during this critical elementary school discussion.  Dr. McGuire clearly indicates that 

Gene and I are displaying obligations to our elected districts that are comprised of 

Atwood, Claypool, and Silver Lake.  We indeed have obligations to the students, parents, 

teachers and staff of Warsaw Community Schools.  But our obligations and concerns are 

not concentrated on one small community or electoral district.  We represent the entire 

school corporation no matter whether the student lives east, north, south, west or centrally 

located in the corporationÕs boundaries.  Our questions and concerns are not attached to 

regional preferences.  An equitable education opportunity for every student in Warsaw 

Community Schools has and will continue to be paramount in importance for myself and 

I believe for Gene England as well.  Yet Dr. McGuireÕs mention of our names 

exclusively in his affidavit infers that Mr. England and I are unreasonable in working 

with the remaining board members and that we project a negative attitude toward a fairly 

"positive" school board as a whole.  If a total review were conducted on the voting 

records of Mr. Chamberlain, Mr. Allebach, Ms. Folk, and Mr. Folk, it would be 

extremely safe to say that each of these memberÕs votes on various proposals would align 

perfectly with each other for the past 3 _ years.  This is not an improbability.  It could 

happen.  But with so little board discussion in public, the chance of consistent vote 

alignment becomes less probable.  If discussions were conducted in private or among 

individuals, Gene England and I were not personally involved in those discussions.  In a 

review of the past four years of school board minutes, I would tend to say that Dr. 

McGuire has not quoted the remaining board members in his affidavit due to the fact that 

their comments and questions are far and few between.
	
8.	Regarding Item 3, page 2 of Dr. McGuireÕs affidavit, he states "I 

personally attended board meetings and public meetings at Atwood, Claypool, Jefferson 

and Silver Lake and communicated to the public that closing schools and building 

schools were two separate issues."  I, too, personally attended the same meetings as Dr. 

McGuire.  When the elementary building plans were first discussed, I individually met 

with Dr. McGuire on May 5, 2003 in Dr. McGuireÕs office.  According to Dr. McGuire, 

he was making his plans on elementary buildings and closings by the recommendations 

of James McKibben of Gann-McKibben Demographics.  On May 5th, the plan included 

closing four elementary schools (Jefferson, Atwood, Claypool, and Silver Lake) and 

building two new buildings (one in Prairie Township or NW corner of Warsaw and one 

northeast of Claypool that would accommodate Jefferson, Claypool and Silver Lake 

students).  Dr. McGuire had spoken with all of the board members individually by May 

15, 2003 and had changed his plan on location of the two new schools to one at Prairie 

Township (northwest of Warsaw) and one in Winona Lake.  I was not notified of any 

change in plans, locations, etc. when I picked up my school board book (with agenda plus 

documents for our Board meeting on May 19, 2003) on May 15, 2003.  Plans were made 

to bus the Claypool and Silver Lake students to Winona Lake.  James McKibben had  

made absolutely no recommendation to build a new building in Winona Lake (Exhibit    

E).      

9.	Between the school board meetings of May 19, 2003 and June 16, 2003,

Dr. McGuire conducted public meetings at Jefferson School (Winona Lake) on May 22, 

Silver Lake School on May 27, Atwood School on May 29, and Claypool School on June 

3 to discuss his plans with the public.  These were public meetings but no minutes were 

formally recorded and three of four of the meetings had a Times-Union reporter noting 

newsworthy information for print (there was no reporter present at the Claypool 

meeting).  Gene England missed the Jefferson meeting but attended the last three 

sessions.  Mark Minatel attended only the Jefferson meeting and Larry Chamberlain, 

Craig Allebach, Cathy Folk, and Jim Folk did not attend any of the four meetings.  Dr. 

McGuire did not emphasize board member attendance to these particular meetings and in 

one weekly memo dated May 30, 2003, he stated "Although the T-U (Times-Union 

newspaper) reports that people felt that these (meetings) should have been board 

meetings, I feel very strongly that it would have been a waste of your time." (Exhibit  F)

The emotional tone and atmosphere of the Jefferson Elementary meeting on May 22 was 

completely different from the meetings at Silver Lake, Atwood and Claypool.  Dr. 

McGuire heavily promoted the positive aspects of a new school building in Winona Lake.  

The Jefferson parents were literally promised a new building, all current Jefferson 

teachers, administration and staff would move to the new facility and the trade 

arrangement between Grace College and Warsaw Community Schools of land in 

exchange for the Jefferson Elementary building was a "win-win situation" for both 

involved parties.  In turn, Dr. McGuire emphasized the negative of a sixth grade 

reconfiguration alternative and the importance of Winona Lake support in order to keep 

an elementary school in that particular community.  He took considerable time in 

explaining how the Winona Lake community could work collectively to challenge and 

defeat remonstrance efforts that might arise against this plan.  The problems of added 

expenses, long bus rides for Claypool and Silver Lake students and the alienation of the 

Silver Lake and Claypool communities from the Warsaw Schools system were mentioned 

but not really discussed.  Mark MinatelÕs input at the meeting was merely that he would 

base his board vote on the decision of the Jefferson Elementary parents.  As I sat in on 

this session, I had no intention of speaking.  However, as the discussion turned more 

toward the concept of a "new" Jefferson School being threatened by the needs of the 

Silver Lake and Claypool students, I felt compelled to remark that we as parents and 

employees of Warsaw Community Schools should keep our plans concentrated on the 

benefits of all of the children in our school system and encouraged the group not to 

develop any type of "we versus they" mentality. (Exhibit G).

The atmosphere of the three remaining public meetings was anything but relaxed in 

nature.  Dr. McGuire was adamant in his contentions that: 1)our school system is in a 

major financial crisis and closing these 3 elementary schools was our one of only a few 

cost-cutting measures remaining that WCS had not already done, 2) the small schools had 

cost our school system 12.2 teaching positions and was a "luxury that we can no longer 

afford", 3) the aging buildings were costing substantial dollars and this would be a step 

toward building replacement at no additional increase in real estate taxes and 4) a 

successful remonstrance against the building plans would result only in a closing of these 

small schools.  The first 2 items mentioned are totally false, the third item is debatable 

and the fourth item was merely a statement of fact.  The only positive statements that Dr. 

McGuire made was that a school was being planned for the northwest side of Warsaw 

near Prairie Township (which was later changed) and that if a remonstrance did occur, 

the students from the schools to be closed would not be split up between different host 

schools (this was also changed later). (Exhibit  H and I)   I cannot recall that our board 

members ever publicly discussed the issues and questions that were raised from these 

four meetings.
	
10.	In Item 4, page 2, Dr. McGuire implies that Warsaw Community Schools 

will be realizing a total projected savings of $688,053.00 after the second year of the 

schools closing.  Of this amount, $300,000.00 will supposedly be the savings captured 

because three administrative positions will be eliminated.  However, the principals from 

Claypool School and Silver Lake School will be taking new positions within the school 

system which will replace positions that were not paid at the high level of pay in which 

they are accustomed.  In order to justify their pay levels in these new positions, their new 

jobs will be padded with additional compensated duties that are questionable as to being 

necessary and/or required within our school system.  The principal at Atwood has been 

paid as part-time administrator and part-time LD (learning disability) teacher and total 

elimination of her position (including benefits) will not come close to equaling the 

$100,000 mark that Dr. McGuire contends will be saved.  The Atwood principal has not 

submitted a retirement or resignation letter to our superintendent.  Therefore, the school 

may be required to place this principal in another position which will also lower the 

"savings."  The wording of "Projected Potential Maximum Cost Savings for Closing 

Atwood, Claypool, and Silver Lake" has three indicative words that Dr. McGuire and 

Rande Thorpe (CFO) are "grasping for straws."  The words "projected," "potential," and 

"maximum" hint to the fact that the administration is working with speculative, hopefully 

guessed, top dollar figures that reflect not one bit of thought as to the expense side of 

transporting, housing, feeding, accommodating (restroom and medical needs) and 

educating approximately 450 displaced students.  It is quite clear to see that the expenses 

incurred in moving (and maintaining) these students in to another facility have been 

ignored.  
	
11.	The inferences in cost savings leads us to Item 9, page 6.  The new 

computers and peripheral supplies that are estimated at $100,000.00 is an item that our 

board members have not publicly discussed (like so many other expenditures).  I have 

only heard about these "satellite station" type computer systems through a principal at 

one of the host schools (school accepting students from one of the closed schools).  Due 

to the fact that most accessory rooms (such as resource, reading, and computer) are being 

converted to regular classroom space in the host schools, the transition has caused the 

need to order these satellite computer systems (these are wireless and rolled from room to 

room).  We would not have the need for such computer system if Atwood, Claypool, and 

Silver Lake Schools remained open.  The board members have not discussed anything 

regarding these computers.  I have no specific information as to exact cost, how many 

units are needed, who we are supposedly purchasing these items from and how we can 

afford this purchase.  Dr. McGuireÕs only contention in Item 9, page 6 is that these 

computers will be compatible with computers presently owned by the school corporation.
	
12.	Item 5, page 3 of Dr. McGuireÕs affidavit addresses the elementary school 

capacities.  Dr. McGuire explains quite well how every possible room will be converted 

to a regular classroom.  At Madison, Washington and Eisenhower Elementary Schools, 

resource, reading, music, storage, and some computer rooms will now be classrooms.  

Using all of these rooms as classrooms is an assumption by our corporation 

administration that all children learn at a comparable level equal to all other children and 

at a comprehension level acceptable to the standards set by the Indiana Department of 

Education.  Students termed as "marginal" are likely to increase their chances of not 

showing improvement.  Useable space for individualized instruction will be little if 

perhaps non-existent in some instances.  The adverse effects on teachers and students 

may reflect likewise on state and federal testing.  The degree of distraction will increase, 

accommodations for lunch (shifts will change from 3 to 4) and restroom use will be 

strained and current storage areas for equipment and supplies will be severely limited or 

eliminated.  The majority of the board members have not physically reviewed the 

facilities nor have discussed concerns with the school administrators since the transition 

plan has been announced.  

At Washington Elementary, there is a classroom of twelve Special Education (special 

needs) students who are scheduled to be moved to Jefferson Elementary.  In a discussion 

with the parents of one of these students, I have learned that change in facilities will be a 

tremendous detriment on the maintenance and improvement of those studentsÕ emotional 

and physical health.  Change in physical environment for these students is anything but 

positive.  Consideration of these studentsÕ needs has been ignored by our corporation 

administration through this classroom move.  The board members were informed of the 

special education student move at the board meeting of November 12, 2003 but did not 

publicly discuss any of these concerns.

The "historic high" capacity figures that Dr. McGuire provided the court (on page 3 and 4 

of his affidavit) show the numbers in the years of 1988 to 1990.  Admittedly, numbers 

were excessively high at that period.  I believe all portable classrooms were used and 

teaching conditions were far from ideal.  However, those numbers dropped drastically 

with the opening of Eisenhower and Harrison Elementary Schools in 1991.  A major 

redistricting of students occurred at that same time.  I have no knowledge or information 

that indicates Eisenhower and Harrison Elementary Schools ever had a historic high of 

630 students in either of these schools.  Even though our school corporation can display 

these historic high numbers, we can not boast that we were providing the best learning 

conditions for our students during these years.  I presented a chart at the March 15, 2004 

board meeting as to the capacities of the host schools (as based on the community-based 

study of 1999-2000) and how numbers would end up at each of the schools after the 

transition was complete. (Exhibit  J) Dr. McGuire commented that he disagreed with the 

capacities due to a reconfiguration by usage.  No comments or questions came from the 

other board members.

On page 4 of Dr. McGuireÕs affidavit, he states "the capacity figures used by the 

Concerned Citizens ignore excess unused capacity at the middle schools."  At the May 

19, 2003 board meeting, I questioned Dr. McGuire as to the present utilization of the 

middle schools.  Dr. McGuire indicated that the capacity numbers for the middle schools 

were not as reliable as statistics would indicate. (Exhibit  K)  I have toured the middle 

schools and contend that our corporation is not using this building space efficiently for 

what enrollments are noted.  Now Dr. McGuire boasts of capacities of 945 students at 

Edgewood and 1,293 students at Lakeview and infers that there is plenty of space for a 

reconfiguration of grade 6 to the middle schools.  We as board members have not been 

presented the expense numbers for the individual middle schools, but the cost per student 

will certainly exceed the numbers given for the elementary schools that are to be closed.

At the top of page 5 of Dr. McGuireÕs affidavit, he states "should overcrowding manifest 

itself, the School could begin using the eight (8) unused modular classrooms at no 

additional expenseÉÉ"  Dr. McGuire neglects to inform the court that the four (4) of the 

remaining eight (8) portables are located at Lincoln and Jefferson Elementary Schools.  

Besides needing some refurbishing, the school corporation would also need to redistrict 

one hundred (100) children to utilize the portables as noted.  In addition, there is 

documentation that the portables are very expensive to operate.  Clearly, substantial costs 

would be incurred.
	
13.	In Item 6, page 5, Dr. McGuire states "With respect to the distances these 

children will be bused next year, this distance is equal to or less than the distance that 

many of these students are already being bused for swimming which is centrally located 

at Warsaw Community High School."  Obviously, Dr. McGuire has not ridden on a 

school bus route in the past.  The children do not all load on to a school bus at the school 

building and travel to Warsaw.  The mileage that accumulates on bus odometers is from 

the route driving.  Buses are currently used to handle two routes (secondary school first 

and elementary last) each morning and two return routes in the afternoon.  This next 

school year, there is a chance that more secondary students may be riding the buses due 

to the fact that sophomores may not be granted parking permits for the high school.  

Therefore, more riders may be on the secondary routes.  Then add to the fact that the 
buses must come back to Warsaw (rather than Atwood, Claypool, and Silver Lake 

Elementary Schools) for the elementary routes, the return trips to Warsaw for those 

routes would be longer and times would be extended to getting the elementary students 

home in the afternoon.  If you add more children to a bus, it will also increase the time 

that the children at the end of the route will have to endure the ride.
	
14.	In Item 7, page 5, Dr. McGuire states "Moreover, teacher-student ratios 

should not appreciably change as the School is not eliminating any teaching positions as a 

consequence of the closuresÉ.." and in absolute contrast two sentences later states 

"When those teachers are moved to other schools the class sizes at the other schools and 

corporate wide (currently 23:1) will decrease."  These two statements are completely 

opposite of each other.  And consider Dr. McGuireÕs use of logic: if the elementary 

enrollment (3,638 as of May 2004) and the number of teachers (159.5 as of May 2004) 

remains constant, the average corporate wide ratio will remain the same at 23:1 no matter 

where the teachers and students are located.  If student enrollment drops and teacher 

numbers are the same, the ratio will increase greater than 23:1.  If student enrollment 

remains constant and teachers numbers drop, the ratio will increase greater than 23:1.  If 

student enrollment remains the same or drops and teacher numbers increase, then the 

ratio will decrease lower than 23:1.  An increase in teacher numbers during the financial 

crisis our corporation is experiencing in the general fund would seem highly unlikely.  

Dr. McGuire also states in the same paragraph "In reality the teacher-student ratios will 

actually reduce corporation-wide since the three elementary schools to be closed had very 

low teacher-student ratios (Atwood 14:1 and Silver Lake 16:1)."  If the mathematics 

classes in our Warsaw schools were given the assignment of determining average 

teacher-student ratio of a given school, the student would divide the total number of 

students by the number of regular classroom teachers in that particular school building.  

Dr. McGuire would have used the April figures for determining these numbers, although 

the May numbers for enrollment and teachers are the same.  Atwood has 144 students and 

6.5 teachers: that figures to 22:1 ratio.  Silver Lake has 143 students and 8 teachers: that 

figures to 18:1 ratio.  Incidentally, Claypool has 137 students and 6.5 teachers for a 21:1 

ratio. (Exhibit   L)  Representation of these numbers to the court in Dr. McGuireÕs 

affidavit indicates that the misquote of facts and figures are not merely an oversight.
	
15.	The second paragraph of Item 10, page 7 of Dr. McGuireÕs affidavit 

explains the process in which the previous Superintendent Dr. Harman and the school 

board arrived at a decision of the building resolution of March 2002.  This resolution was 

not possibly the most popular plan that was presented to the public, but it became 

acceptable from the standpoint that a portion of the elementary enrollment problem was 

being addressed by the corporation. (Refer to Exhibit B)  When Dr. Harman retired rather 

suddenly and Dr. McGuire was named as his replacement, the entire administrative 

complexion of Warsaw Community Schools changed.  The entrance of Dr. McGuire as 

Superintendent in July 2002 converted the emphasis of equitable education for all 

elementary children over to extracurricular and administrative wants at the high school 

and the CIMC building.  Brad Brail, whose board position expired in December 2002, 

firmly questioned Dr. McGuire during the board meetings of October and November 

2002 about dropping the elementary school proposal out of the building plan.  Mr. Brail 

in fact was the only vote against the 1028 proposal in November 2002.  He clearly stated 

at that meeting that he felt the board had neglected to address the key reason for the 

original building proposal: the elementary school issue.  The primary reason the building 

plan of November 2002 continued without public resistance was that very little public 

attention was drawn to the fact that the original plan had drastically been altered.  A large 

number of the taxpayers and parents in the Warsaw community were not aware that Dr. 

HarmanÕs proposal had been altered.  Dr. McGuireÕs mention of "the revised project went 

through with full public input" was not quite a demonstration of community support as it 

was a well planned display of special interest groups representing the high school 

development speaking at the 1028 hearing.
	
16.	In Item 11, Page 8, Dr. McGuire mentions Chief Financial Officer Rande 

ThorpeÕs  report regarding a projected "$1.3 million deficit unless cuts were made."  I 

have enclosed a copy of Mr. ThorpeÕs printed report of March 2003 (Exhibit M).  I 

suggest that review be made of the Section 5 Ð Conclusions of this report.  Mr. Thorpe 

noted Potential Cuts by priority or tiers of importance.  Dr. McGuire had all intention of 

changing the Block 4 Scheduling to a Block 5 trimester schedule and eliminating 

elementary counseling in his first shift of cuts.  In actuality, when the Block 4 plan was 

originally introduced to Warsaw Community Schools approximately 4 _ years before, 

the High School Principal (Paul Crousore) at that time had assured the Board of Trustees 

that going from a 7 period schedule to Block 4 would not increase any teachers to the 

staff.  Shortly after the program was adopted, eight teachers were added to handle the 

additional time slots needed in the 90 minute class periods.  If the teachersÕ average 

salary and benefits would be figured at $30,000.00 per year (which would be very 

conservative), the Block 4 scheduling cost the corporation annually a minimum of 

$240,000.00 more than the corporation had originally intended.  By switching to the 

Block 5 trimester schedule, those eight positions were no longer needed.  The switch to 

Block 5 trimester was just a correction of a mistake from years back.  The elementary 

counseling program was also eliminated in March of 2003 in hopes that a federally 

funded nurse/mental health therapist plan could be initiated in the place of the counseling.  

The effects to the school corporation are still in question regarding this decision.

Dr. McGuire has thrown the blame of these positions lost due to the small school 

expense.  Also, Mr. Thorpe had recommended other cuts prior to the one-section schools 

but Dr. McGuire ignored those recommendations and at one point referred to those 

possible cuts as "cannibalizing" the system.

	17.	The remonstrance process that began after the June 16, 2003 board 

meeting regarding the proposed elementary building program was a very evident 

example of public input that the board members and the Superintendent ignored. 

Response to the boardÕs loosely based building plan was swift and impressively 

indicative of the publicÕs reaction with over one thousand (1,000) signatures being 

secured on petitions for remonstrance.  The cover sheet that was attached to each set

of signature petitions is being entered here as Exhibit  "N."  The remonstrance process 

was informly titled as the "LetÕs Start Over" remonstrance.  It was organized by the 

taxpaying public who reside in the Warsaw School district as a response to the school 

corporation that the elementary building plan was not a product of community input and 

that the Board of School Trustees should not endorse such an ill-conceived 

recommendation from the Superintendent.  I believe the current action by the Concerned 

Citizens group (CCQE) is a request to the court to stop the present plan of closing these 

three schools until a viable and community-generated building proposal can be agreed 

upon and a smooth redistricting plan to new or renovated facilities can be put in place.  

As it stands presently, the current plan to close these schools may hamper any upcoming 

building plan procedures for a longer time than the administration might anticipate.  

Public trust in our school administration and board membership has declined in the past 

twenty-four (24) months and recovery may even be a hindered due to the closings.
	
18.	In an overall evaluation of what has occurred between the 

SuperintendentÕs role as an employee of the corporation and the Board of Trustees as 

policymakers, these terms noted by Judge Morton in his Order of Dismissal, there has 

been a major disregard as to the duties of both the employee and the policymakers.  Dr. 

McGuireÕs capacity as an employee should not have any effect of the end decisions of the 

Board of School Trustees of Warsaw Community Schools.  Not only has Dr. McGuire 

elected to limit plan options before the Board on so many occasions but he also tightens 

the opportunity for review and channels selected bits of information to the board that will 

reinforce his proposals.  I have been discouraged on several occasions by Dr. McGuire to 

ask questions of school personnel and encouraged to give the inquiries to him in order 

that he might filter to me what he wants me to know.  IÕve found his process not only to 

be restrictive but insulting.  My obligation and duty as a Board Trustee is to work with 

fellow board members in making sound collective decisions regarding the finance, 

operation, and maintenance of our school system and be accountable to our taxpaying 

public for making those sound decisions.  Up to this point, the administrative employees 

at the corporate level, have not provided each of the board members sufficient detailed 

information to make those sound decisions.  The mere fact that the board members were 

not provided copies of Dr. McGuireÕs affidavit used in the May 7, 2004 hearing is a clear 

indication that pertinent information is being withheld by the SuperintendentÕs office.  In 

evaluating the current board members as policymakers, I refer my analysis to discussion 

in Item 5 of my affidavit.  I clearly donÕt know what the motives are for many of majority 

votes made by this board.   All I know is that our decisions as a board will have a long-

lasting and perhaps permanent effect on the degree of educational success and future of 

our students for many years to come.  It is absolutely mandatory that we as board 

members are provided with the tools necessary to make those decisions that will be the 

best for our children.

	I affirm under the penalties for perjury that the foregoing representations are true 

and accurate to the best of my knowledge and belief.


								
________________________
								Ronald L. Yeiter      
   
                      


20