To: GMSB
From: Dr. William Rayburn
May 14, 2018
Dear Board Members:
I was notified of this “investigation” on or about April 11, 2018 and was
immediately placed on unpaid suspension. During this time in which I
have been suspended, the investigation has evolved to include other
unsupportable charges, with no process or provision for me to respond,
with either my own testimony or by presenting contrary proof or other
evidence. Although I was only made aware of the investigation of
certain charges, at the inception of the meeting on May 7, 2018, Mr.
Haddow initiated that meeting and set the stage for what was to follow
by playing a recording of me which had nothing to do with the actions
being investigated but was instead simply a recorded conversation
between myself and a colleague during which I angrily criticized the
process and the charges against me. Of course, you also used that
opportunity to present new “charges” of which I had no prior notice or
opportunity to respond.
Nonetheless, at that meeting and shortly thereafter, I provided you
with you with completely credibly explanations and corroborating
witnesses or evidence for each of those charges.
Nonetheless, by
Friday, May 11, 2018, your findings were emailed to me finding me
guilty of virtually every charge. Additionally, our investigation reveals
that you have not contacted a single one of the witnesses I gave you
nor have you even come close to completing a thorough, balanced and
unbiased investigation to which I am entitled. For these reasons, I
formally request that you consider this rebuttal and
investigate the charges and defenses contained herein before
submission to the Board. If you do not, the Board will receive an
incomplete and heavily distorted “investigation report.”
I will follow these five areas of required investigation by further
explanation:
First, Mr. Haddow did not report these allegations to the DCS
immediately as required by Tennessee Law which is actionable by the
District Attorney.
This can only be attributed to oversight or a
complete lack of concern for the accuracy of the allegations.
Second, I have reported Mr. Haddow to the police for stealing my
phone and, in violation of my federal and state right to privacy,
scrolling through its contents. Additionally, he has intimidated teachers
from other schools to show him their cell phones and discuss my
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 unfounded culpability for allegations yet to be proven.
intimidation has been prevalent through the entire investigation.

This

Third, there have been violations of federal law by Mr. Haddow and the
District in the areas of separation of church and state and civil rights.
Those must be investigated in order to establish the true intention
behind these allegations and the motive, particulars, and facts behind
the misrepresentations and allegations against me.
Fourth, there are numerous instances of defamation and slander for
which the District must stand responsible. You have recklessly and
intentionally tried these matters in the press from the outset, heavily
prejudicing my rights to a fair hearing. You must also be held
accountable for these actions.
Fifth, I would like to file an official grievance against Mr. Haddow for
alleged unethical behavior, intentional factual omissions and
misrepresentations, violations of federal and state laws, and the
blatant intimidation of educators for his own self-gain and purpose.
Please advise the proper procedure for such a grievance since I am to
present this pursuant to a chain of command process.
During the course of the school year, Mr. Haddow has compared me to
a teacher who had sex with one of his students at a former school; he
has said that I promoted the sex slave trade business in Africa; he has
illegally taken my phone; he has intimidated a friend who teachers at
Riverdale; and he has said that I took the joy out of his Friday emails.
These and other comments, as well as the rebuttal of the accusations
below have NOT been investigated by Mr. Haddow or GMSD.
I know for a fact that the following family has been contacting students
as
far
back
as
2016
asking
them
for
any
kind
of
mistake/misstep/misspoken word they could pin on me. One of the
accusations goes back as far as 2011. ___________ has been calling
people and then encouraging those people to call the school district.
In many of these cases, the family has an axe to grind with me.
Shockingly, an overwhelming majority of these have to do with not
getting an auditioned solo. I am aware Mr. Haddow did not interview all
of the students. It has come to my attention that Mrs. Abel and Mrs.
Fischer interviewed some as well. Any teacher or student who spoke
positively of me was not included in his investigation. It was as if they
never existed.
The list below seems to be the main people the district has consulted
regarding my teaching abilities:


_________ Family – parents of ________. Calling families to
encourage them to call school district
2

 







___________– parent of ___________, the young man who recorded
the audiotape. Both Mrs. Speakman and Mr. Haddow mentioned
at the end of the meeting that parents are worried about
retaliation. There was no mention of children safety. This is my
best case against retaliation. ___________was not accepted to the
music program at MTSU. He and his mother were distraught. I
encouraged her not to call MTSU to complain. Instead, I called
MTSU (first time I have ever done this, as a teacher in 20 years).
I communicated with those who auditioned with ___________, and
they were kind enough to tell me why they did not accept him. I
then arranged with Dr. Kevin Ford, Director of Choirs at UTChattanooga to come to Houston High School to audition three
students, one being ___________. Mr. ___________ will be attending
UT-Chatt in the fall on scholarship. I also selected ___________ as
the soloist for one of the three songs for the National High School
A cappella Championship before I was suspended. At that time, I
already knew that ___________ had turned over the audio to the
school district. In addition, ___________ has a special needs
brother who attends Houston High School and I allow him to eat
his lunch during choir rehearsal every day.
Many times,
___________and I have had words both face to face and on the
phone. Over the ten years I have been at Houston High School, I
have taught two of her three children. That means that she has
had a student in choir for eight of the past nine years. With the
information I have given above, does this look like the works of a
teacher who has or would ever retaliate against a student for
their behavior or their parents?
___________– parent of ___________. She is one of the parents that
confronted my wife that our daughter, ___________, was in a boy’s
room. She is also the parent who says that I discussed the
brassiere or cup size of her daughter with the Dicken’s outfit.
Again, they were not happy with the solos she received.
___________– parent of ___________. She was a Booster Board
Member who rarely came to meetings. She complains that I
bullied her daughter, but her daughter and her friends created a
toxic environment in the choir room. Was at the School Board
Meeting on Monday in Support of Mrs. ___________
___________– Teaching assistant at Houston Middle School, drank
an entire fifth of Vodka at the Kettering National A Cappella
Festival at the Hotel; ___________was her roommate ____________.
___________ could not get out of bed the next morning and came
to the event late. Never took off of her sunglasses. She is one of
the mothers that confronted ___________ in NYC about
___________as well as asked for the meeting about her daughter’s

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 





behavior. Again, she was upset because her daughter did not
receive any solo.
___________– President of the current Houston Choirs Booster
Club. Seems to be the parent who is driving everything. Her
daughter has never been mistreated. I have only had one
meeting with her and that dealt with her texting me during a
performance telling me that one of the students on stage had a
shirt on that was too short. That student had to borrow that
shirt. She considers herself to be a reporter. Likes to ask a lot of
questions. Questioned me about everything during the year and
did not like when I did not take or follow her directions.
Ms___________claimed to have a dossier about my conduct
prepared for Mr. Cherry. However, according to Mr. Cherry, he
received an email in early April that her daughter, at the time,
had nothing bad to say about me.
___________– Mother of ___________. Chosen by parents to speak
against me at the GMSD School Board Meeting on Monday Night
– Transcript: Representing concerned group of students, send
children to school to prepare for lifelong learning and socially be
responsible, the mission statement needs to be fulfilled,
frustration re: teacher allegations, deeply disappointed, evidence
to support that there was a pattern of behavior, citizens have
rights, need transparency, need to know that our children are
safe physically and emotionally, I am teacher, teachers have
sacred and solemn role.
___________- Mother of ___________. Did meet with Mr. Cherry
about ___________’s experience in choir. The most I remember
was dealing with solos. Was at the GMSD school board on
Monday night.

RETALIATION – see ___________bullet above.
Other charges:
1. Dr. Rayburn kissed students on the head and forehead:
a. To the extent this occurred, it was always in a public setting
and never alone. It was usually in the context of a celebratory
or consolatory action. Students who will speak to this include;
___________.
2. On multiple occasions, Dr. Rayburn disrespected Houston High
School parents, students, and employees by yelling at them:
a. This charge is addressed via a Student Recording of Speech
on the bus in Chicago, March 26, 2018. The speech recorded
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 on the bus was concerned with student decorum during the
concert as well as during the entire trip. No curse words were
used, no one was singled out, and I did not threaten or
intimidate the students. I do not feel that I was out of line
with the speech. The group was seated in the center section
of Chicago Symphony Hall (see attachment for where we were
seated. Students were seated 13 rows back from the stage).
This can all be confirmed via witnesses ___________, who will
speak on my behalf as to the speech on the bus as well as the
behavior of the students on the trip.
b. In November of 2011 or 2012, the Dickens singers were
invited by WKNO to film a 30-minute Christmas special. We
were there a very long time because WKNO wanted it perfect.
One of the students who was an alternate cheerleader said
that she needed to go to cheerleader practice. I stated that
she needed to be at the performance recording at WKNO. She
left and went to cheerleading practice to sit and watch
because she was an alternate. She never participated in the
finals at Disneyland.
c. These rebuttals deal with complaints from members of the
Houston Choirs Booster Club, who have complained where
their student’s solo was placed in a concert; why a different
student won best solo at a competition; why their child did not
get enough solos; why someone else’s child on the board got
a solo and their child did not; who texted complaints during
the concert about performances that were approved by the
administration; and who texted complaints about why
students were wearing the clothes that they were wearing
while I was not backstage and was running sound.
i. May 16, 2014 – ___________approached me less than
thirty minutes before the concert was to begin on the
night complaining to me that she did not appreciate
where her child’s senior solo was placed in the program.
I did become upset and later apologized to her and her
husband. Her daughter asked me to write her Hall of
Fame Yearbook remarks her senior year.
ii. In February of 2017, fifth measure won first place at the
ICHSA Quarterfinals in Georgia. ___________won best
soloist for the competition. Before returning to the
hotel, Booster President ___________called me to
complain about why her daughter had not won the best
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 vi.

soloist award. First Mrs. -- was not present.
Secondly, I did not make any decision on who won best
soloist, the judges did. Any of our soloists could have
won best soloist that night.

-- (May 2017) and -- (April 2016)
always complained to me that their children never
received enough solos for fifth measure and Dolce Bella.
These parents inferred that since they were members of
the booster club that their children should have more
solos. -- and her husband asked for a meeting
with assistant principal LeGault, Senior Guidance
Counselor Intervention Counselor Denise
Fisher, and WThe meeting was announced to
me about -- being bullied, but the meeting was
truly about the lack of solos her child received. The only
reason I got onto her daughter in the first place was
because she was eating pizza during class on the grand
piano. Then the parents really only complained about
her lack of solos. --called me on my personal
phone after school hours complaining that her daughter
did not receive a long enough solo for the dessert show.
After a long discussion where I finally hung up on her
complaining, I gave her daughter a longer solo.

April 2014, parent --texted me during the
concert complaining about a performance by the choir
that was approved by principal Dr. Lisa Justice. It was a
performance that had been a tradition for at least six
years.

December 2017, Booster Club President, --,
texted during the middle of the performance about a
shirt a student was wearing and a skirt that another
student was wearing. I was in the back of the
auditorium and was not aware of the issues until the
students came on stage. The young lady with the short
skirt had to change, the young lady whose shirt
displayed her navel was not asked to change. She was
poor and was wearing a borrowed shirt.

I believe in November 2013, String Teacher
--had a student drop my class and enroll in his
class. He was originally, in strings in middle school, but
wanted to do choir in high school. Without asking me.
Mr. -- had the student drop my class and enroll

6

in his class. This did anger me and I confronted Mr.
___________ before school telling him that this is not how
we handle issues in the Fine Arts Department. Next
time, all he needed to do was come talk to me about the
switch. My disappointment was that he did it without
talking with me first.
3. Dr. Rayburn engaged in inappropriate touching of students:
a. Yes I have hugged students on numerous occasions, but what
teacher has not? Other than the one occasion below, I have
not touched a student inappropriately that I am aware of and
that one occasion was the result of a complete
misunderstanding, which I fully explained to Mr. Haddow
during the May 1meeting and which I again explain below:
i. ___________– This happened at Harrell Theatre sometime
during the first two weeks of September. Due to the
lack of males to present ‘Joseph’s Coat,’ there were
several female students who played the parts of
Joseph’s brothers. They wore the male clothing as well
as fake beards to complete the costume. I mistook
___________for one of my male performers and gave a
congratulatory slap on the rear end. When I realized it
was ___________, I was mortified and apologized
profusely, which she accepted and the incident was
never again mentioned until these charges. Witnesses
to this incident were ___________ remembers this as a
non-incident.
___________remembers the incident
happening exactly as told to Mr. Cherry, Mrs. Abel and
Mr. Haddow.
This is the exact same description
provided on May 7, 2018 at the meeting at the GMSD
Board. I also think I recall ___________ (current HHS
Senior) being there. It was a total accident, and I
apologized immediately. Everyone laughed including
___________.
4. On multiple occasions, Dr. Rayburn bullied, threatened and
intimidated Houston High School parents, students and employees:
a. I am having a difficult time differentiating between question 2
and 4. Please see my response to #2 above. The only time
that I can recall anything even remotely like this happening is
dealing with purchasing choir shirts for the tour to Hawaii in
2015. The treasurer was ___________. She did not approve the
purchase of the shirts. She called me and began to argue
7

 with me why I went behind her back and purchased the
Hawaiian shirts. This was on a Saturday. This was an
extended argument about who was in charge of the choral
program at HHS. Was it the Booster Board or the Coir
Director? In another case where ___________called and began
yelling at me on my personal phone while I was at home, I
was forced to change my number in order to have her stop
calling and harassing me.
b. As for the accusations from the ___________families, I ask, no
beg of you, to call witnesses to the event. You asked for a list
of witnesses, I provided them, but apparently you have not
seen fit to contact any of them. By talking to the witnesses
provided, they can tell you what was actually happening in
the classroom. As to the Cell Phone Incident in Dolce Bella –
This was a common practice for my choirs. I would often take
up phones and have them place on the table in front of the
piano. I would also like to point out that ___________did try out
for choir the following year. She did not get in the choir she
wanted and dropped the class. Class member and witness for
this event is ___________. The toxic nature can be best
explained as how they behaved in the class, inappropriate
posture, continuously texting on their phones, not singing,
showing no respect to the teacher or their peers which ruined
the classroom experience for all of the other students. This
was due to jealousy caused by not receiving solos.)
___________ (Current HHS Senior will also testify to the toxic
nature of the students listed above.)
c. If you are including having students crying during their
auditions, I hope you listened to the MP3 I provided of
___________audition. You would hear that I was encouraging
throughout the entire audition. This afternoon, May 12, 2018,
I have contacted a number of local high school and one
middle school choir teachers and asked, “Have you ever had a
student cry during an audition?” The following names and
phone numbers are the choir directors I contacted. Each
answered yes. ___________.
5. Dr. Rayburn made inappropriate comments to students:
a. Osaka: I spoke of this at the meeting. I did not consider it an
official HHS event. It was just a way for me to reward the
students for missing an entire day of classes to perform in a
hallway by the library. Students who I recall present were
8

 ___________, and one other I can’t remember. There is a
statement from ___________ “We had spent the whole day
singing for the Showcase at school so you decided to buy us
dinner as a reward. There were like ten of us total including
you. Most of the students were talking about stuff your
previous students were doing currently. You left because you
had to be at rehearsal for your play, and because some of the
stuff the kids were saying was making you uncomfortable. It
wasn’t a hhs “event”. It was just a fun dinner we all had
together because we worked hard and deserved it.
b. Religion – This is why we talk about religion in class as it
relates to the music. But for secular music in the Renaissance
(English Madrigal, French Chanson, and Italian Madrigals) the
overwhelmingly majority of choral music that survives is
Sacred Music (much of the secular music was destroyed by
the Roman Catholic Church). This was from the beginning of
monophonic chant until the Classical Period. During the
Classical Period, composers began to compose more secular
music, but still Sacred Choral music was the music that was
written and mostly survives to this day. It was only during the
Romantic Period until now that composers began to compose
more secular choral music. Even today there is as much
sacred choral music written as secular. As an educator, I try
to explain what the music is about the students are
performing no matter if the language is Latin, Yiddish, Italian,
German, or English. We explore the text to understand the
emotional content of the music. Sadly, the Islamic faith does
not allow for choral music. It is only monophonic. I can
provide the National Association for Music Educators
Statement on Religious Music. In addition, the two a cappella
pop choirs perform over 95% secular music throughout the
school year.
c. Boyfriends or Girlfriends – Many types of relationships are
found in choir. You can’t ignore the relationships because
they affect the dynamics of the rehearsal as well as the
performance. This includes where students stand during
rehearsals and performance. The relationships can even
affect the performance of an ensemble, especially a small
ensemble.
The following people can speak about
relationships and their dynamics in the HHS Choirs:
___________ – I can provide audio from Mr. ___________.
d. Breast Reduction – ___________; I have shared my version of
this story with Mr. Cherry, Mrs. Abel, and Mr. Haddow. Either
9

  mother or --told me that --was
planning to have breast reduction surgery during the summer
afier Governor's School and before Joseph and the Amazing
Technicolor Dreamcoat. Durin one of the early rehearsals for
the musical, I asked how she was feeling afier her
surgery. I did not say anything about boobs or breasts. Adult
witnesses to the question are -- (Cordova, TN
resident who doesn't remember the specific question, but
knows that I never used the term boob or breast because that
would have caught her attention because of her work position
as a nurse). In addition -- shared with how freely the
- family discussed the breast reduction surgery.

6. On multiple occasions. Dr. Rayburn engaged in inappropriate
conversations with students:

a.

This question is so similar to question five above. I am not
sure what you are talking about. Please refer to the rebuttals
provided on question five.

7. Dr. Rayburn caused embarrassment to Germantown Municipal
School District, Houston High School. its studenE. parents.
employees and himself:

a.

I am not sure how I have caused embarrassment to GMSD.
HHS, its students, parents, employees and myself. If you
consider the incident with the National Anthem brought GMSD
embarrassment, I am sorry. I may have made some mistakes,
but I did my best to stand up for my students that night. I
wish that you could be more specific, but I feel that if having
the highest number of students make All-Southwest
Tennessee Honor Choir and the most students to make the
Tennessee All-State Honor Choir is an embarrassment, I don't
know what else I can do. The HHS choirs consistently make
Superiors at every competition. The HHS a cappella choirs
are both ranked in the top ten in the nation. If any of my
behavior was an embarrassment, I don't see it. I have worked
very hard to bring nothing but respect and pride to this
program. No matter where we have travelled, the HHS
students have always represented their, school, their parents,
and their city proudhave brought
embarrassment to GMSD. In conclusion, In conclusion, I have
brought honor to GMSD and Houston High School be being
selected as Mississippi College Department of Music
Distinguished Alumni of the Year, being chosen as a clinician
at the 2018 National A Cappella Convention, sewing as

10

President of the West Tennessee Vocal Music Educators
Association, serving as Choral Chair for the Tennessee Music
Educators Association, as well as running the sound for almost
every event at HHS.
8. Dr. Rayburn exhibited poor decision making:
a. Trying to defend myself against the accusations brought by
you and the few parents from the parents from the past few
years with these vague charges which seem to change each
time I receive information from you leaves me guessing as to
what you are talking about.
b. I believe that this is an example of proper decision making
from our tour to Florence, Italy – On the first morning in
Florence, most the girls were wearing towels back to their
rooms. I asked the girls to dress before leaving the shower
and returning to their rooms. I was not even expecting that in
the first place. I also stayed in a small sitting area/nook with a
couch near the bathroom not directly across from the door of
the bathroom in order to make sure the girls and guys were
separated going to the bathroom. In addition, I sat there to
keep other hostel guests from using the restroom. The hostel
had one restroom on the hall, but there were individual
showers with attached dressing rooms. In addition, there
were individual restroom stalls. All were locked. Witness from
the 2011 Italy Tour: ___________
c. If we are discussing poor decisions, just this past school year, I
refused to allow my girl’s group perform a song that was
given to us to perform at the National A Cappella
Championship because of it’s subject matter and the way the
lyrics and words were put together. A witness to this is
___________.
d. One of the poorest decisions I have made as an educator was
not to report Mr. Manuel and Mrs. Crowder’s comments about
the type of students we were looking for when starting the
HHS Fine Arts Academy. Both said that HHS wanted students
who are currently residents of Germantown who attend
private schools. We do not want students who are from
Raleigh Egypt High School, Treazvant High School, Craigmont
High School and Memphis East. This is in direct violation of
US Law as it deals with civil rights violations and open
enrollment.

11

 e. Another poor decision I made was to not file charges against
Mr. Haddow for taking my phone and reading text messages
from Mr. ___________ and then asking for that to be struck from
the records. When he took the phone he said that it was not
against the law. In hindsight, I should have called the police
immediately because this was not the first time Mr. Haddow
had intentionally bullied and harassed me.
9. Dr. Rayburn exhibited poor classroom management:
a. I think all of my teacher evaluations will invalidate this
statement. I have been a Level 5 teacher every year since
the new evaluation system began. I am consulted by
numerous choir directors throughout the area for input about
teaching anything from sight-reading to selecting choral
literature.
b. If this were actually true, the choirs would be unable to
perform at such a high standard.
c. The only time Mr. Haddow has ever visited my classroom was
to show a video of a mission trip to Kenya and ask for the
choir to assist his church in a fundraiser. During your time in
my classroom the students were well behaved and watched
your video respectfully. They then respectfully declined to
participate. In October, Mr. Haddow then accused me of
assisting the African Sex Slave Trade because my group did
not assist his church.
10. Dr. Rayburn violated the Tennessee Teacher Code of Ethics (T.C.A
49-5-1001, et seq.):
a. The causes for which a teacher may be dismissed are as
follows: incompetence, inefficiency, neglect of duty,
unprofessional conduct and insubordination as defined in 495-501.
b. I ask that you provide specific instances, date, witness and
code(s) that you believe I have broken. Please be specific.
Your generalities have placed my legal team and myself in a
position of having to literally guess what you are referring to.
I see nothing that I have done in 49-5-1003, (I can name at
least one HHS faculty who has broken no. 7 yearly.) I see
nothing that I have done in 49-5-1004. Tenn. Code Ann 49-51002: I have met with parents. I have conducted myself
12

 ethically.
If defending my decisions, or defending the
decisions made by judges that I don’t know is a violation
worthy of dismissal, this is a very thin standard.
11. Dr. Rayburn violated GMSD policies: Staff Rights and
Responsibilities, Policy #5.600, Ethics Policy 5.611, Student
Discrimination,
Harassment,
Bullying,
Cyber-bullying,
and
Intimidation, Policy #6.304, Promoting Student Welfare, Policy
#6.400, Child Abuse and Neglect, Policy #6.409:
a. 5.611 – I have been forced to change my phone number due
to actions against me HHS parents. I have had to almost
yearly defend my selections of soloists against parents with
the highest percentage of them being from the Booster Board
who desired a return for their investment as a Booster Board
Member. By selecting the best student, I had to constantly
defend my selections. If you hold every teacher to the same
standard in which you hold me, then all of the teachers who
have filled parent teacher conferences should be terminated
as well. Since GMSD and Mr. Haddow decided to use my
daughter against me on our meeting on Monday, May 7, 2018,
I will use my wife to discuss this GMSD policy. As a teacher, I
always allowed my wife to deal with my daughter’s
instructors. A teacher at Houston told my wife that not all
children should pass her class. She was referring to our
daughter. I have never told a parent that. I also assume that
the language used by ___________on the soccer field nor the
vulgarities and intimidation coming from the wrestling
gymnasium does not fall under the code of ethics for GMSD.
They way in which ___________coach can only be described as
intimidation and bullying, but since they are your friends, they
receive a pass. The language they use with HHS students is
repugnant. In fact Coach ___________ used the N word to refer
to one of my former students. We reported it, but nothing
was done. The student received three days ISS.
b. 6.304 – If not giving a student or a parent their way is
harassment or bullying, then I am guilty. As a teacher that
teaches both individually and collectively, I have to always
place the best students in a solo or leadership position. If
conversation via email with the Houston Choir Booster Board,
who this year provided the least support possible, is seen as
bullying, I object. Due to Tennessee law, I cannot touch the
money from the students. Therefore, I am reliant on the
board to do their work. When expenses have not been
13

 notated for three months, it is very difficult to operate as a
teacher and an organization.
c. 6.400 – In my opinion, I have not used unreasonable force and
fear as an appropriate procedure in student discipline. You
must look at one’s total work of ten years and not draw a
conclusion on one recording that resulted in a natural and
logical consequence.
d. 6.409 – In my opinion, I have not caused any child abuse or
neglect in my teaching career at HHS. If you are referring to
the incident at Mass in Blue, I have already discussed this with
you, but you can also talk to the parent, ___________
The “findings” also make the completely unsupported and factually
inaccurate as well as intentionally false conclusion that “Based upon
the examples set forth in support of the charge unbecoming to a
member of the teaching profession/unprofessional conduct Dr. Rayburn
has refused or continued to obey the school laws of this state, to
comply with GMSD policies, and follow the instruction of the Director of
Schools. On October 26, 2017, Dr. Rayburn received a written warning
and suspension. In that written warning Dr. Rayburn was told that any
further incidents of unprofessional conduct may result in further
disciplinary action taken against you including but not limited to
suspension and/or termination of your employment. However, Dr.
Rayburn continued to engage in acts of unprofessional conduct as set
forth above, after he received that warning.”

As with the other allegations, the above conclusions are completely
unsupported and are at best based upon an incomplete, intentionally
biased and inherently unfair investigative process in which none of my
witnesses or evidence was considered. With all due respect, these
findings are no more than the recitation of a predetermined outcome
on the part of Mr. Haddow and his supporters.
As such, as I stated at the outset of this rebuttal, I formally request
that you consider this rebuttal and investigate the charges and
defenses contained herein before submission to the Board.
Sincerely,

Dr. William Rayburn
(signed in his absence to avoid delay in mailing)
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