Ousting Carl Paladino

Update: April 4, 2017
NYSED Appeal Number 20602
Samuel L. Radford, et al vs. Carl Paladino, et al
Regarding the Removal of Carl Paladino
from the Buffalo Board of Education and
the Replacement of the Board with a Receiver

Buffalo Parent 306 Petitioners
In NYS Education Application For Removal of Carl Paladino
F O R I M M E D I A T E R E L E A S E
Contact:
Samuel L. Radford, III
In the Matter of Samuel L. Radford, III vs. Carl Paladino
NYS Education, Appeal No. 20602
Buffalo, NY
716-578-3571
Franklin Redd, Jr.
In the Matter of Samuel L. Radford, III vs. Carl Paladino
NYS Education, Appeal No. 20602
Buffalo, NY
(716) 948-8113
BUFFALO ATTORNEY DENNIS VACCO CALLS FOR HALT IN ALBANY
LAWSUITS TO REMOVE CARL PALADINO AND GIVES NOTICE OF
INTENT TO FILE FEDERAL LAWSUIT. PARENTS CONTINUE TO CALL
FOR THE DISTRICT TO BE PUT UNDER THE CONTROL OF A RECEIVER.
April 4, 2017, Buffalo, New York---Buffalo attorney Dennis Vacco, representing
School Board Member Carl Paladino in a series of petitions calling for the removal of Mr.
Paladino from office by the NYS Education Commissioner, has called for a halt in the
continuation of the actions filed by the Board of Education, the Buffalo Parent Teacher
Organization and the NYS Teachers Union.
By letter and affidavit dated March 30, 2017, Mr. Vacco raises serious questions of
conspiracy, collusion and the violation of Mr. Paladino’s civil rights by members of the
Buffalo Board of Education and parties to three of the four petitions filed to remove Mr.
Paladino from office. Citing an unprecedented look at a billing statement of attorney Frank
Miller, who is representing the Buffalo School Board, Mr. Vacco gives notice of his intent
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-more
to immediately file a lawsuit in federal court and putting an end to the Albany actions
against Mr. Paladino.
By letter dated April 4, 2017, parents, headed by Samuel L. Radford, III, filed a fourth
petition seeking the removal of Mr. Paladino and the entire School Board. The petition
filed by the parents was not included in the allegations filed by Mr. Vacco. Parents
continue to call for the Commissioner to replace Mr. Paladino and the entire Buffalo
School Board with a receiver.
For access to complete inventory of relevant documents, click the following link:
https://www.yumpu.com/s/DXYqIFGdiNO3tKf9
-End-
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Parent Petitioners’ April 4, 2017
Response to Dennis Vacco, Esq.
March 30, 2017 Letter

District Parent Coordinating Council
April 4, 2017
VIA FAX (518) 474-4188 & FIRST CLASS MAIL
MaryEllen Elia, Commissioner
NYS Education Department
Office of Counsel
NYS Education Department, Room 112ED
State Education Building
89 Washington Avenue
Albany, NY 12234
Tina Urbiatis, Appeals Coordinator
NYS Education Department
Office of Counsel
NYS Education Department, Room 112ED
State Education Building
89 Washington Avenue
Albany, NY 12234
Re:
Samuel L. Radford, III, et al vs. Carl Paladino, et al
SED Appeal Number 20602
Commissioner Elia and Ms. Urbiatis:
For reasons that follow, and good cause shown, pursuant to 8 NYCRR Section 276.5, the
undersigned petitioners kindly request that:
(1) that the above referenced Appeal be STAYED, consistent with the request of Dennis
C. Vacco, attorney for Mr. Carl Paladino in SED Appeals Numbered 20601, 20604 and
20596. A copy of Mr. Vacco’s letter, dated March 30, 2017 is annexed as EXHIBIT A; and
(2) that the records of SED Appeals Numbered 20601, 20604 and 20596 be fully
incorporated, by reference, into the record of the above referenced Appeal, including the
two applications made by Mr. Vacco, on behalf of Mr. Paladino, dated March 17, 2017 and
March 30, 2017 to provide additional supporting evidence; and

MaryEllen Elia, Commissioner
Tina Urbiatis, Appeals Coordinator
Page 2
(Continued)
(3) that Mr. Vacco’s request that SED Appeals Numbered 20601, 20604 and 20596 be
STAYED is granted so that the serious allegations raised in his March 30, 2017 are fully
investigated.
The undersigned petitioners represent the interests of our children, along with the
interests of similarly situated parents and children within the Buffalo Public Schools
District. Ab initio, the interests of the other parties in the related petitions to remove Mr.
Paladino, along with questions of duty of loyalty raised by attorneys for the Buffalo Board
of Education and the individual Board Members have triggered numerous questions about
collusion and conflicts of interests. For this very reason, cause is shown that the request of
the undersigned petitioners should be granted.
Moreover, and in addition, the undersigned petitioners’ request herein should be
granted because if the March 30, 2017 allegations of Mr. Vacco are true, then the ultimate
determination by the Commissioner, in all four of the pending petitions to remove Mr.
Paladino from the Buffalo Board of Education, will be tainted and subject to years of
litigation with the resulting enormous legal costs. See, EXHIBIT B, invoices of attorney
Frank Miller representing the Buffalo School Board, except Carl Paladino.
It is also the position of the undersigned petitioners that Mr. Vacco’s March 30, 2017
allegations, if true, would further support the petitioners’ request in SED Appeal 20602,
that the entire Board is dysfunctional and should be immediately replaced by a receiver. It
is also the petitioners’ position that the allegations raised by Mr. Vacco in his March 30,
2017 letter supports the position of the undersigned that the 306 Appeal process is

MaryEllen Elia, Commissioner
Tina Urbiatis, Appeals Coordinator
Page 3
(Continued)
fruitless and violates the Due Process and Equal Protection clauses of the 14 th Amendment
to the U.S. Constitution. Should Mr. Paladino initiate a federal court action based on the
“Illegal Cases” Mr. Vacco alleges have been filed with SED to remove Mr. Paladino, the
undersigned will seriously consider intervening in such action pursuant to Rule 24(a)(2) of
the Federal Rules of Civil Procedure.
For reasons set forth above, the undersigned kindly request the relief requested.
Thank you,
/s/ Samuel L. Radford, III
_________________________________________________________
Samuel L. Radford, III, Petitioner
1423 Fillmore Avenue
Buffalo, NY 14211
(716) 578-3571
(716) 332-1015(fax)
/s/ Patricia A. Elliott Patton
_______________________________________________________
Patricia A. Elliott Patton
1423 Fillmore Avenue
Buffalo, NY 14211
(716) 578-3571
(716) 332-1015(Fax)
/s/ Kevin Lafferty
_______________________________________________________
Kevin Lafferty
1423 Fillmore Avenue
Buffalo, NY 14211
(716) 578-3571
(716) 332-1015 (Fax)
/s/Franklin Redd, Jr.
_________________________________________________________
Franklin Redd, Jr.
1423 Fillmore Avenue
Buffalo, NY 14211
(716) 578-3571
(716) 332-1015 (Fax)

Certification of Service
The undersigned, _____________________________________, hereby certify that a true copy of
the annexed letter, with attachments have been forwarded by first class mail, postage prepaid
to the following and deposited on April 4, 2017 at a post office of the U.S. Postal
Service in Buffalo, New York.
By: ______________________________________________
Name:
_______________________________________
Address: _______________________________________
_______________________________________
Mailed to:
Dennis C. Vacco, Esq. (via U.S. Mail)
Frank W. Miller, Esq. (via U.S. Mail)
Richard T. Ross, Esq. (via U.S. Mail)
Raymond Audain, Esq. (via U.S. Mail)
Jalina J. Hudson, Esq. (via U.S. Mail)
Richard E. Casagrande, Esq. (via U.S. Mail)
Bethany A. Centrone, Esq. via U.S. Mail)

EXHIBIT A

EXHIBIT B

Dennis Vacco, Esq.
March 30, 2017 Letter To NYS Education
Commissioner Seeking Halt To Three
Petitions Filed Against Carl Paladino

Dennis Vacco, Esq.
March 30, 2017 Affidavit To NYS
Education Commissioner Seeking Halt
To Three Petitions Filed Against Carl
Paladino

Original 306 Petition Filed By Parent
Advocates Seeking Removal of Carl
Paladino and Appointment of Receiver To
Replace Entire Buffalo School Board

23. The toxic tone and tenor of the atmosphere within the Buffalo Public
Schools District-antithetical to the best interests of our children-is illustrated by this flyer-
--which circulated within the City of Buffalo two years ago:
You are Cordially Invited to a Board of Education Circus Performance
Featuring
“The KRAZY KARL KLAN”
Wednesday January 28, 2015
Performing Arts High School – Buffalo, New York
Pre-Show Rally at 4:00 pm - Performance begins at 5:00 pm
____________________________________________________
Buffalo: America the Beautiful
Starring
(In Order of Self Importance)
Carl “Bull
Connors” Paladino
Witness “Sam
The Rafter”
swing from his
monkey bars!
CRITICS ARE RAVING!
“An exciting performance---a fiasco that can only be seen in Buffalo,
New York. A true artistic work of political theater.”
--- The Buffalo Daily Snooze
Larry “George the
Wallace” Quinn
James “David the
Duke” Sampson
Jay “Mason-Dixie”
McCarthy
Insparaciallional music and dance by the
4 SISTAS OF SOUL
Singing there smash Gospels hit
“WE AIN’T NEVA GONNA BEES
FREE LORD”
“A major showcase of social themes like ‘the disassembly of Buffalo
Public Schools’ and ‘how to violate black people’s rights.’ A must see
event for all self-respecting white people.”
--- W BEE E IN Radio
“This is just what Buffalo needs…more plans plays like this. I would
score this performance a 0 out of 10 and rate it highly effective!
Mandatory for the whole world. Let’s test!”
--- Dr. John Charter King
“Even kids in poverty will appreciate this performance. Don’t blame
the teachers if the kids miss this educational opportunity of a lifetime!
I really loved the scene where the teacher gets a facelift, tummy tuck
and boob job and the school district was forced to pay for it.”
--- Fill Ruin Moore
ADMISSION
Free (Parents with EBT card)
$10,000 (Supporters of Charter Schools with Ben Done Bennett Vouchers)
$15,000 (Supporters of Charter Schools with Kuomo Tax Credits)
If you BELIEVE…make a donation!
Donations may be tax deductible – Ask Mike Dealee or Larry Scottch
Photo: The sistahood, circa 1968, Buffalo East-Side
A Special Guest Appearance by
Patty “Rubberstamp” Pierce in the Recurring
Role of Peppermint Patty
Underwritten by The Piss-On-Your-Broken-Promise Neighborhood Group
Bob Wiltsomemore (M&Tea Party Bank), The OSHIT Foundation & The Buffalo Daily Snooze
A Buffalo School Board Production where our motto is: “we produce drama instead of education”
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25. Petitioners bring this action in the context of a district described as failing
by the Governor, in violation of fundamental rights of students as guaranteed by the
Civil Rights Act of 1964, where noted educational experts are ignored and ridiculed, and
public racialize politics is the norm.
Facts Related To Relief Requested
26. On or about December 23, 2016, Buffalo School Board Member Carl P.
Paladino caused the followed article to be published nationally in ARTVOICE
newspaper:
Carl Paladino
DEVELOPER, SCHOOL BOARD MEMBER, POLITICAL ACTIVIST
1. Obama catches mad cow disease after being caught having relations with a Herford. He dies
before his trial and is buried in a cow pasture next to Valerie Jarret, who died weeks prior, after
being convicted of sedition and treason, when a Jihady cell mate mistook her for being a nice
person and decapitated her.
2. Michelle Obama. I’d like her to return to being a male and let loose in the outback of
Zimbabwe where she lives comfortably in a cave with Maxie, the gorilla.
3. Someone with a brain, a set of balls and a lack of fear who has enough money so as not to
owe anyone anything once elected and who believes in a market economy.
4. We need a $50 million dollar train station as much as we need parasitic people like Lou
Ciminelli, 80% of the school board and the dizziness of socialistic progressive politicians who
never signed the front of a paycheck. At best 400 people a day take a train. They are not
complaining about exchange or Depew. We are already the laughingstock of America for
having the dumbest elected leaders ever. Why add to it.
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