sue ellen mcguier deposition - delk v. ohio county (wv) board of education

8/20/2019 Sue Ellen McGuier Deposition - Delk v. Ohio County (WV) Board of Education

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IN THE CIRCUIT COURT OF OHIO COUNTY WEST VIRGINIA

DAVID L. DELK,

Plaintiff,

vs. CIVIL ACTION NO.

15-C-196

OHIO COUNTY BOARD OF

EDUCATION, a Political

Subdivision,

Defendants.

- - -

DEPOSITION of SUE ELLEN McGUIER

Monday, September 14, 21!

- - -

The deposition of SUE ELLEN McGUIER, calledfor examination by the Plaintiff, taken pursuant to

Notice and the West Virginia Rules of Civil Procedure

pertaining to the taking of depositions, before me,

the undersigned, Victoria J. Bostic, Registered

Professional Reporter-Notary Public, in and for the

State of West Virginia, held at the offices of Grove

& Delk, 44 1/2 Fifteenth Street, Wheeling, West

Virginia 26003 at approximately 10:00 a.m. on the day

and above set forth.

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APPEARANCES:

On Behalf of the Plaintiff:

David L. Delk, Jr., Esquire

GROVE & DELK, PLLC44 1/2 Fifteenth Street

Wheeling, West Virginia 26003

On Behalf of the Defendant:

Patrick S. Casey, Esquire

CASEY & CHAPMAN, P.L.L.C.

1140 Chapline Street

Wheeling, West Virginia 26003

Also present: Dianna Vargo

- - -

I-N-D-E-X

WITNESS EXAMINED BY PAGE

SUE ELLEN McGUIER Mr. Delk 3

E-X-H-I-B-I-T-S

Deposition Exhibit No.:

1. Plaintiff's Notice of Rule 30(b)(7)

Deposition of Defendant 5

2. 4-7-15 letter from Mr. Delk to Dr. Vargo 8

3. Individual Student Report, test scores 21

4. 5-1-15 letter from Mr. Casey to Mr. Delk 50

5. Excerpt - Online Test Administration Manual 59

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P R O C E E D I N G S

(10:00 a.m.)

- - -

SUE ELLEN McGUIER

a witness herein, called for examination by the

plaintiff, having been first duly sworn, as

hereinafter certified, was deposed and said as

follows:

EXAMINATION

BY MR. DELK:

Q. Would you state your full name for the

record, please.

A. Sue Ellen McGuier.

Q. Where do you reside?

A. I reside at 108 Fernwood Avenue, in Wheeling,

West Virginia.

Q. And who is your employer?

A. Ohio County Schools.

Q. How long have you been with Ohio County

Schools?

A. Since 1986.

Q. What's your current position with Ohio County

Schools?

A. I'm am the director of assessment and federal

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programs.

Q. How long have you been in that position?

A. This is my eighth year in that position.

Q. When you started with Ohio County Schools, in

1986, what did you start out as?

A. I started as an English teacher at Bridge

Street then-junior high.

Q. How long were you at Bridge Street as a

teacher?

A. Five years.

Q. Until 1993; does that sound right?

A. Uh-huh.

Q. What was your next position?

A. English teacher at Wheeling Park High School.

Q. How long were you at Wheeling Park?

A. Until I came to the board office eight years

ago.

Q. Teacher at Wheeling Park the whole time?

A. Yes.

Q. Describe for me what your role is as the

director of assessment and federal programs for Ohio

County Schools?

A. My responsibilities include making sure that

Ohio County Schools follows the West Virginia

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management of academic performance plan.

Q. That's it?

A. Related to assessment. In addition, I have

responsibilities with federal programs.

Q. What responsibilities do you have with regard

to federal programs?

A. Overseeing the Title I and Title II programs

as they relate to schoolwide improvement efforts and

to improving teacher learning and teacher quality for

Title II.

(Whereupon, Deposition Exhibit No. 1

marked for purposes of identification.)

BY MR. DELK:

Q. Hand you what's been marked as Exhibit 1,

which is plaintiff's Notice of Rule 30(b)(7)

Deposition of Defendant.

Have you seen this document?

A. Yes, I have.

Q. And are you the designee of Ohio County

Schools today for the topics that are listed on this

notice of deposition?

A. Yes, I am.

Q. And you're prepared to address all 13 of

those topics?

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A. Yes, I am, to the best of my abilities and my

knowledge.

Q. Okay. What did you do to prepare for this

deposition?

A. Met with Mr. Casey and essentially reviewed

some of my documentation.

Q. What documents did you review?

A. Policy 2340 from the West Virginia Department

of Education.

Q. Do you have that with you now?

A. I do.

Q. May I see that?

A. Uh-huh.

MR. CASEY: Wait a second. Is that

marked? Are these your notations?

A. Those are my notations.

MR. CASEY: Do you have a copy, or do

you need to see hers, or do you --

MR. DELK: Yeah, I want to see, just

make sure we're on the same page.

BY MR. DELK:

Q. These highlighted portions are stuff that you

highlighted?

A. Yes.

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Q. Highlighted in preparation for the

deposition?

A. To some degree. Some highlighting is there

because they are points of emphasis when I did

training.

Q. This was your copy that you also used for

training purposes?

A. Yeah.

Q. I understand.

I think I asked you this, but you reviewed

this in preparation for the deposition?

A. Yes.

Q. Any other documents that you reviewed?

A. The other document that I brought was the

current document, the parents' guide and so forth

that were presented to parents in the schools.

MR. CASEY: His question was: What else

did you review, and you told him what you brought.

Does that answer the question? Don't know if

that addressed the question.

BY MR. DELK:

Q. Did you review that in preparation for the

deposition?

A. Yes, sir.

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Q. Can I see that document?

A. (Witness complies.)

Q. I think I've seen it before, but --

A. Thank you.

Q. Did you review any other documents in

preparation for the deposition?

A. I did not.

Q. Other than Mr. Casey, did you meet or have

any communications with anyone to prepare for the

deposition?

A. I did not.

Q. When you met with Mr. Casey, was there anyone

there other than attorneys?

A. Dr. Vargo was present.

Q. Okay.



BY MR. DELK:

Q. Handed you the April 7, 2015 Freedom of

Information Act request that I sent to Ohio County

Schools.

Have you see that before?

A. I did see it in Dr. Vargo's office.

Q. When? At the time -- around --

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A. At the time we received it.

Q. Did you review that document in preparation

for the deposition?

A. Yes.

Q. Okay. When did you review it in preparation

for the deposition?

A. Oh, I did not. I'm sorry. Did not review

this in preparation for the deposition.

Q. Okay. Going back to the notice of

deposition, the first topic, I asked for, "The

position of the Ohio County Board of Education/Ohio

County Schools as to whether the West Virginia

General Summative Assessment administered to third

graders constitutes a licensing examination,

examination for employment or academic examination

pursuant to Section 29B-1-4(a)(3)," and I have some

questions about that.

Now, you're aware, in the FOIA request I

made, I requested a copy of the assessment tests

given to third graders in Ohio County Schools?

You're you aware of that, correct?

A. Yes, I am aware of that.

Q. And are you aware that the response of Ohio

County Schools to this litigation was that the

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assessment was subject to an exemption under the West

Virginia Freedom of Information Act?

Were you aware that?

A. Yes.

Q. And my question to you is: Is the position

of Ohio County Schools that the assessment is a

licensing examination?

A. I would ask you to clarify your question,

please.

Q. What part of my question did you not

understand?

A. In regards to the licensing examination.

Q. Okay. What about licensing examination do

you not understand?

A. Is your question that Ohio County holds the

license for the examination?

Q. No. That helps me.

A. Okay.

Q. One of the exemptions under the Freedom of

Information Act is that a public body does not have

to produce a licensing examination.

And is it the position of Ohio County Schools

that the assessment provided to its students

constitutes a licensing examination?

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A. Then I would say yes. I -- I'm really very

unclear of what you're asking here.

MR. CASEY: Let me object to the extent

that this may call for legal conclusions as the

terms may be defined.

It's not Ohio County School's position it's a

license examination.

MR. DELK: Okay.

MR. CASEY: Is an academic examination.

MR. DELK: That's what I thought. I

just wanted to nail it down.

THE WITNESS: Okay.

MR. DELK: I don't have to ask her any

more questions if that's what it is.

THE WITNESS: Okay.

MR. CASEY: Okay.

THE WITNESS: Thank you.

BY MR. DELK:

Q. With respect, Ms. McGuier, to academic

examination, what is the position of Ohio County

Schools as to what constitutes an academic

examination?

MR. CASEY: I'm going to object only to

the extent it may call for a legal conclusion,

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assuming interpretation of statute.

But you can answer as a witness.

A. An academic examination -- and I'm going to

refer to West Virginia Department of Ed Policy 2340,

where they clearly defined those measures, provided

through the West Virginia Department of Education,

that each county in the state would then implement.

BY MR. DELK:

Q. What portion of Title 126 are you referring

to?

A. They spell out the West Virginia General

Summative Assessment, NAEP, ACT PLAN and EXPLORE.

Q. What page are you referring to?

A. Actually, just kind of --

Q. Okay.

A. West Virginia Summative Assessment is defined

on page 7, 3.61, 3.60. I had forgotten West Virginia

Department of Ed Alternative Summative Assessment;

and then there are references in the document to ACT

COMPASS, ACT EXPLORE, ACT PLAN and NAEP.

Q. And ACT COMPASS, ACT EXPLORE, ACT NAEP, those

aren't part of Summative Assessment, correct?

A. They are not.

Q. I'm talking about the -- my question was:

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What is the position of Ohio County Schools as to

what an academic examination is?

A. And we would follow the guidance provided by

the West Virginia Department of Education.

Q. Where in this Title 126 is an academic

examination defined?

A. I would have to refer you, again, to page 7

under 3.61 where it says, "WVDE General Summative

Assessment. A customized test consisting of selected

criterion-referenced response items used to measure a

student's level of achievement of the West Virginia

CSOs in mathematics, English Language Arts, social

studies and science in grades 3-11."

Q. I'm sorry. Did you say "3.61"?

A. Uh-huh. On page 7, near the bottom.

Q. On page 8 on mine. That's okay.

A. Okay.

MR. CASEY: When you're answering, use

yes or no, as opposed to --

THE WITNESS: I'm sorry.

MR. CASEY: That's okay.

THE WITNESS: Okay. Thank you.

MR. CASEY: That's all right.

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BY MR. DELK:

Q. And in 3.61, the term "academic examination"

is not used, correct?

A. It is not, sir.

Q. Is the position of Ohio County Schools that

the -- only the West Virginia General Summative

Assessment is an academic examination?

MR. CASEY: I object to the form.

You can go ahead and answer.

A. No.

BY MR. DELK:

Q. All right. What else is an exempt academic

examination, then?

A. It would be the use of the other assessments.

Q. The assessments listed in Title 126?

A. Yes. In addition to -- I'm afraid that I

cannot clearly provide an answer to that question

without reference to policies, and we may or may not

be using the term "academic assessment," sir.

Q. I haven't used the term "academic

assessment."

A. Oh, okay.

Q. Well, I've used the term "academic

examination," because that's what the statute --

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A. Okay.

Q. So when you say "we may not be using the term

academic assessment" or "academic examination," what

are you talking about?

A. We use the term, in Ohio County Schools, "a

balance of assessment data"; in that we would use

multiple measures to determine what is it that a

child knows and is able to do. So some are

formative, some are summative, some are interim, some

are benchmark assessments.

Q. Well, my question is: You know, the statute

allows me to collect public records, but it doesn't

allow me to collect an academic examination?

A. Uh-huh.

Q. I want to know what the definition of an

academic examination is in Ohio County Schools such

that I'm not permitted to, under the theory of Ohio

County Schools, to get this test?

A. Then we would call this an academic

examination.

Q. Why? Just because you call it that, doesn't

mean it is. Why?

A. As defined by Policy 2340, content of secured

test may not be shared.

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MR. CASEY: I think his question was

just simply: Why are you calling it an academic

examination?

BY MR. DELK:

Q. We're going to get the security.

A. Okay.

Q. Trust me.

A. Okay.

Q. We're going to get there.

A. Okay. Okay.

MR. CASEY: He just wants to know why

you consider this an academic examination -- why

Ohio County Schools considers it an academic

examination. That's his question. All right?

BY MR. DELK:

Q. That's my question.

MR. CASEY: That's right.

A. Because, in essence, it's one of the West

Virginia measures of academic progress.

BY MR. DELK:

Q. Would I be correct in saying that Ohio County

Schools considers any assessment that measures

academic progress to be an academic examination?

A. Could you rephrase again?

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MR. DELK: What was the question?

(Whereupon, reporter read record as requested.)

A. I'm concerned about the word "any" because of

the wide variety of instruments that could be used.

So I would be hesitant to say yes to that, sir.

BY MR. DELK:

Q. So what would be the criteria or traits of an

assessment that measures academic progress that would

qualify it as an academic examination?

Since you don't like the term "any," describe

for me what traits or qualities of such an assessment

would have to have to be considered an academic

examination.

A. It would be my understanding that everything

delineated in Policy 2340 would be an academic

examination.

Items that we would use for interim

assessments would be considered academic assessments.

Even some teacher-developed academic assessments

would not be subject to review if they were developed

collaboratively.

Q. And correct me if I'm wrong -- and I just

want to make sure we're on the same page -- you refer

to this as Policy 2340?

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A. Right. Right.

Q. Just want to make sure we're talking the same

thing.

A. Uh-huh.

If you see --

Q. Right. I see it.

A. West Virginia Measures of Academic Progress.

2340 in parenthesis.

Q. So Policy 2340 was, you know, authored, put

together by the West Virginia Department of

Education; am I right about that?

A. Yes, sir.

Q. Pursuant to legislative authority from the --

you know, our legislature, correct?

A. Yes, sir.

Q. So any test assessment mentioned, discussed

in Policy 2340, Ohio County Schools would consider

that an academic examination?

A. Yes, sir.

Q. Now talk specifically, for a second, about

the West Virginia assessment provided to third

graders in Ohio County Schools. Okay?

A. Uh-huh.

Q. Is that a yes or a no?

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MR. CASEY: You have to say "yes."

A. Yes, sir. I'm sorry.

BY MR. DELK:

Q. That's all right. That's all right.

MR. CASEY: Vickie is taking it down

word-for-word, and she has trouble interpreting the

uh-huhs and the huh-uhs.

A. Okay.

BY MR. DELK:

Q. Is it a fair statement that the teachers in

Ohio County Schools, the third grade teachers, had no

idea what the test questions were on the assessment

provided to third graders?

A. Yes, sir, that would be fair.

Q. And fair to say the third grade teachers in

Ohio County Schools were not involved with creating

or designing the assessment?

A. Yes, sir, they were not involved in creating

the assessment.

Q. Is it fair to say that the assessment

provided to third graders was 100 percent designed by

a outside, third-party testing company?

A. I would have to say that I would be

speculating in answering that question because I do

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know that there were curriculum experts from various

states who collaborated with the vendor. So I would

be unable to answer that. It would be speculation.

Q. Okay. Well, to the extent that there was a

West Virginia curriculum expert collaborating with

the vendor, the testing company still was the one

that prepared and created the test?

A. Yes, sir. With collaboration from the

various, at least my understanding is, from the

department of educations in the states in the

consortium.

Q. Okay. Do you know what states are in the

consortium that West Virginia is a part of?

A. I do not, sir.

Q. And the consortium that West Virginia is part

of is the Smarter Balanced Assessment Consortium; is

that correct?

A. Yes, it is, sir.

Q. When I use the term "Smarter Balanced," you

know what I'm referring to?

A. Yes, sir.

Q. It's true that there would be subjects or

topics on the tests provided to third graders -- the

assessment provided to third graders that were not

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covered by teachers in Ohio County Schools?

A. By way of clarification, each state has its

standards and objectives. And it is true that the

content the teacher may select to deliver, that

content standard or objective, may be different than

what's on the assessment; however, it's still tied to

the knowledge and skills, what kids need to know and

be able to do.

Q. I appreciate that. But the content on the

test may not correlate with the content that the

third grade teachers provided to the students in its

entirety.

There may be some gaps between the test and

what happened in the classroom; is that fair?

A. Yes, that would be fair to say.



BY MR. DELK:

Q. Handing you what's been marked as Exhibit 3,

which is just a sample of a student's test scores.

MR. CASEY: Do you want any of this

redacted?

MR. DELK: No.

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BY MR. DELK:

Q. The first page is the English language arts

literacy for third graders, correct?

A. Yes, sir, it is.

Q. Does this report tell me what specific test

questions were asked of this student?

A. No, sir, it does not.

Q. Does this report indicate how many or what

questions were missed by the student?


Q. Does the report provide any indication that

this student had trouble with any specific area

tested?


Q. Is there any way for a parent to find out

what specific areas of the test that the student may

have had trouble with on the assessment?

A. No, sir, it does not indicate that.

Q. I'm asking you: Beyond what's on that page,

is there any way for a parent to find out what

specific subject matter or area that was tested that

the student may have had trouble with?

A. No, sir.

This report shows that this child was above

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standard -- using the "Legend: Claims Performance

Levels" here at the top, in reading, listening and

speaking, writing and research and inquiry.

Q. I understand that.

A. Uh-huh.

Q. But is there any way for a parent to find out

what subject matters a child may have had an issue

with on a -- not this one in particular, but say a

student got a one or a two on there.

Is there any way for a parent to find out

what specific subject matters that their child may

have had an issue with on this particular test?

A. Specifically, no.

Q. Yes. Thank you.

Does this report here indicate in any way

what reading level the child was tested on, as far as

reading passages provided on the test?

A. The report shows Level 4 performance here;

that the student has exceeded the achievement

standard and demonstrates advanced progress toward

mastery of knowledge and skills in English language

arts and literacy.

Q. I understand that.

A. Uh-huh.

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Q. But it was a computer-adaptive test, correct?

A. It was, sir.

Q. And tell me if I'm wrong, but I assume that

means if a child is answering questions correctly,

those questions are going to get progressively more

difficult?

A. Yes. That is the basic design of

computer-adaptive tests.

Q. If the child is missing a question or misses

questions, that it -- the way it adapts, it changes

to make the test, I guess, less rigorous, or less

hard, for lack of a better term; is that correct?

A. In general, that describes the

computer-adaptive nature of the test.

Q. Do you know, for example, in the English

language arts test that if a child is performing well

on -- for reading comprehension, do the reading

passages get progressively harder?

A. I'm unable to answer that question.

Q. You don't know?

A. I do not know. I have not been involved in

the selection of passages.

Q. Is there any way for a parent to know what

the grade level reading questions were, what -- as

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far as a specific reading comprehension or reading

passage, what grade level that the kid was ultimately

reading on the test?

A. The answer to that would be no, sir.

Q. Okay. Now, on this report, does it indicate

what subject matters in English language arts were

actually tested?

A. The areas of the four claims here of reading,

listening and speaking, writing, research and inquiry

were the claims that were combined for the overall

score.

Q. And do we have any idea, for example, what

specific kind of grammar questions were on the test,

if any?

A. No, sir, we do not.

Q. How would we find that out? If a parent

wanted to know, like, what grammar was tested on this

assessment, how would a parent find that out?

A. The student report is all that is provided to

the parents.

Q. So the answer would be: The parent can't

find that out?

A. Exactly, sir.

Q. Are there ever -- are the schools provided

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with any kind of report data showing how the child

answered on specific questions?

A. They are not, sir.

Q. They are not.

And if I am correct, on the WESTEST, the

report was provided showing how a student did on test

questions, whether they got it right or got it wrong?

A. Yes, that is true. There was an item

analysis provided for each item in the old WESTEST.

Q. And my understanding is, on these English

language art assessment, and even in third grade,

there was a writing assessment; is that correct?

A. It was embedded into the process as part of

the performance task.

Q. And who sees that writing assessment?

A. Would you clarify?

Q. Sure.

The student keyboards in the --

A. Uh-huh. Uh-huh.

Q. -- whatever they're writing?

A. Uh-huh.

Q. Yes?

A. Yes, they do.

Q. And who actually sees that?

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A. Would you clarify?

Q. Sure.

Does anyone in Ohio County Schools get to see

what the student wrote?

A. No one in Ohio County Schools would see that.

Q. Anybody at the West Virginia Department of

Education get to see that?

A. No one at the West Virginia Department of

Education would see that.

Q. That goes off to whoever grades the test?

A. The vendor, it is my understanding, has

trained scores, so they would be the only folks, to

my knowledge, that would see that.

Q. And who is the vendor for this test?

A. American Institutes for Research, AIR.

Q. And do you have an understanding how those

people who read the assessments are trained?

A. I do not, sir.

Q. Do you have any idea what their background

is?

A. I do not, sir.

Q. Do you have any idea what their level of

education is?

A. I do not, sir.

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Q. Do you know whether it's a part-time or

temporary job?

A. I have no idea, sir.

Q. Do you have any idea what the job pays?

A. I have no idea, sir.

Q. Does Ohio County Schools have any indication

or knowledge what level of performance is required to

hit the various cut levels on the assessment?

A. Ohio County Schools has no knowledge of that.

Q. Does the West Virginia Department of

Education have that information, to your knowledge?

A. I would say they probably do not.

This report uses a scale score, and the scale

scores would be a conversion of the student's raw

score to a common scale. So they may or may not

know, and I would be reluctant to answer on behalf of

the department of ed.

Q. Ohio County Schools doesn't know the raw

score?

A. We do not.

Q. The parents are not provided the raw score?

A. No.

Q. I mean, it's fair to say whatever scale score

the student receives on this test, we have no idea to

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know whether that means they answered 25 percent

right or 99 percent right?

A. You're right, sir.

Q. Thank you.

Turn to the next page of Exhibit 3.

This is the math portion, correct?

A. Yes, sir.

Q. Again, this report doesn't tell a parent what

specific test questions were asked of the student,

correct?

A. It does not, sir.

Q. And it in no way indicates how many -- how

many or what questions were missed by the student,

correct?

A. No indication, sir.

Q. Is there any indication provided as to

whether a student had trouble with a particular

mathematical concept?

A. Not according to this report.

Q. Are Ohio County Schools provided with any

additional information about the student's test

result other than this report?

A. We are not, sir.

Q. Ohio County Schools is not provided with any

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indication of how many questions a student got right

or missed?

A. We have no knowledge of that.

Q. All right. So if a teacher has told me that

they're waiting for additional information about test

responses, that teacher was just incorrect?

A. I would say that that teacher was incorrect

and perhaps thinking about what we've had for several

years with WESTEST, in that we did have specifically

question by question, concept by concept.

Q. Okay. That's what I'm --

A. Uh-huh.

Q. -- getting at.

A. Uh-huh.

Q. So on this West Virginia Summative

Assessment, a parent will not know concept by concept

what was tested and how their child did on the test?

A. No, sir.

Q. Is there any way for Ohio County Schools to

know what portion, percentage of the test, for

example, was addition, subtraction, multiplication,

division, anything like that?

A. No, sir.

Q. We don't know if the child had one question

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on multiplication or 50 questions; is that correct?

A. We have no way of knowing, sir.

Q. Do you we know, for example, with the third

grade test, what specific mathematical concepts were

tested?

A. We have no way of knowing what was on the

test.

Q. And the same for the report on the English

language arts, is there any way to know -- does Ohio

County Schools know, in any way, what performance by

the student is necessary to reach Level 1, 2, 3 or 4?

A. No, sir.

Q. And a raw score, again, is converted to the

scale score, correct?

A. Exactly.

Q. And we don't know what the raw score is for

the students?

A. We have no idea.

Q. Now, of the scale -- these scale scores and

the cut lines for this report, is that the same for

each state that is a part of the consortium, or does

that change from state to state?

A. I would be unable to answer for all of the

states. It's my understanding that West Virginia is

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using the cut scores provided by Smarter Balance. So

I wouldn't even begin to answer for the other states.

Q. I appreciate that.

A. Uh-huh.

Q. But to your knowledge -- your knowledge is

that the West Virginia Department of Education is not

setting the cut line; that's coming from Smarter

Balance?

A. That would be my understanding.

Q. Okay. In general, what is Ohio County

Schools going to do with the results of the

assessment? How does Ohio County Schools use the

results?

A. I made reference before about using a balance

of assessment data, so this would be one piece of

assessment data.

We would also use data from Pearson

SuccessNet math. We would use data from the DIBELS

assessment. We would use information from aimsweb.

We would use information from classroom teacher

assessment data so -- and probably others that I've

forgotten about at this moment, to try to get a true

handle on where a child is in his or her learning.

So we use a multitude of data sources.

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Q. So a portion of what -- Ohio County Schools

uses this test, to some level of degree, to determine

how a child is doing in their grade level; is that

fair, summarizing what you just said?

If not, do a better job for me.

A. I think what it does is presents Ohio County

Schools with a picture of where the child is in

relationship to the standards at that particular

grade level, but bear in mind, it's only one piece of

the entire picture of a child's learning.

We know, after years in education, that not

every child performs well on an assessment like the

West Virginia General Summative Assessment, so we

like to look at other data sources --

Q. Sure.

A. -- as well.

Q. How does Ohio County Schools use that

information it receives from the testing company or

the Department of Education for an individual

student?

A. Again, it gives us a piece of the picture of

the child's entire learning.

Q. And is that the same response for how a

teacher would use the test result?

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A. Absolutely.

Q. It's just a piece of a bigger puzzle?

A. Absolutely.

Q. Does the West Virginia Summative Assessment,

the report that's provided -- just for clarification,

the only information you have on an individual

student about the assessment results are provided on

those two pages?

A. Absolutely.

Q. That's it?

A. That's it.

Q. That's the full range of -- everything we

know is on those two pages?

A. Yes, sir.

Q. Thank you.

Does those two pages provide any specific

instruction for what a student needs to improve on in

either math or English language arts?

A. The results provided here do not clearly

indicate any specific content standards and

objectives, as I look at this report.

However, as a classroom teacher, it would

tell me when I have a student who's fairly high

functioning. I would then use other data sources to

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see if I could identify specific content areas which

this child might need.

Q. Okay. I mean, is it fair to say, then, that

the individual student report, as far as the

summative assessment goes, really just provides a big

picture of whether the student is meeting standards,

above standard, below standard?

A. That's very fair to say.

Q. Okay. I know you have Policy 2340 in front

you. We don't need to make this an exhibit, but I

want to give you my copy just so we're talking about

the same page --

A. Okay.

Q. -- if that's fine?

A. That's perfectly fine.

Q. I didn't tell you this when we started, but

if, at any time, you need to take a break, just let

me know.

A. Thank you.

Q. All right. If you could turn to page 24 of

the document I provided to you, and it's Appendix B.

Appendix B is the District Test Coordinator's

Secure Materials and Test Procedures Agreement.

Do you see that?

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A. I do, sir.

Q. In Ohio County Schools, who is the district

test coordinator?

A. I am, sir.

Q. You. Okay.

And did you have to sign this document or a

document like this?

A. I actually sign this document and submit it

to the West Virginia Department of Education at the

beginning of each school year. Then prior to

implementing any assessment in the West Virginia

measures of academic progress, I am required to

attend training in Charleston, and then I re-sign

that I have had specific training for each of those

assessments.

So I sign this document multiple times during

the school year.

Q. This exact same document?

A. This exact same document.

Q. And a signed copy exists of this document?

A. It would be with -- be held at the West

Virginia Department of Education.

Q. Okay. Is there a copy -- a signed copy in

Ohio County Schools anywhere?

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A. I am required, at the conclusion of my

training, to give them my copy.

Q. So you don't have a copy?

A. I do not have a copy of this. I submit it to

the West Virginia Department of Education.

Q. If you could turn to page 26.


Q. That is Appendix C. Do you see that?

A. Yes, sir.

Q. It says, "District Technology Coordinator

Secure Materials Test Procedures Agreement."

A. Uh-huh.

Q. In Ohio County Schools, who is the district

technology coordinator?

A. The district technology coordinator is

Mr. Patrick Riddle.

Q. It says "or a technology vendor."

Is that a different person in Ohio County

Schools?

A. We do not have a technology vendor.

Q. Okay. Mr. Riddle would have had to sign this

document?

A. Yes, he does.

Q. And does Ohio County Schools have a copy of

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that signed document, or is that provided to the

state as well?

A. I do have a copy of his signed document.

Q. That's on file?

A. It is on file.

Q. All right. And unless I'm wrong, that was

not produced in response to the FOIA request, do you

know?

A. To the best of my knowledge, because of our

number of documents, I would say that it was not.

Q. If we could turn to page 28.


Q. This says, Principal's -- it's Appendix D.

"Principal's Secure Materials and Testing Procedures

Agreement," correct?

A. Correct.

Q. And every principal in Ohio County Schools

would have signed this document?

A. Absolutely.

Q. And do you have a copy of the signed

documents for each of the principals?

A. I have copies.

Q. Unless I'm missing something, that was not

produced pursuant to the FOIA request?

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A. It was not.

Q. Is there a reason why it was not produced?

A. Other than the fact that I have it on file

and locked away, no.

Q. Okay. Turn to page 30. Appendix E, Building

Level Coordinator's Secure Materials and Testing

Procedures Agreement.

Do you see that?

A. Yes, sir.

Q. Okay. Who at Ohio County Schools -- or who

are the building level coordinators?

A. Principals select key staff within their

building to serve in this capacity. So it varies by

school.

Q. Gotcha.

And do you have a copy of the signed

agreements for the building level coordinators?

A. I do, sir.

Q. And is it one per school or would it be more?

A. It's one per school.

Q. And again, was there a reason why the signed

copies of this agreement weren't provided?

A. No. I just -- I had them locked away.

Q. Page 32, Appendix F.

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MR. CASEY: I'm going to object. By

asking why they weren't produced, I'm not conceding

that they were encompassed, but she can tell you why

she didn't do it.

MR. DELK: That's fine.

MR. CASEY: Okay. Go ahead.

BY MR. DELK:

Q. Page 32, Examiner's/Scribe's Secure Materials

Agreement.

Do you see that?

A. I do, sir.

Q. Who are the examiners or scribes in Ohio

County Schools?

A. Those are the teachers who would be in the

examination -- in the testing centers with the

students.

These are signed and kept on file in each

school.

Q. In each school?

A. In each school.

Q. Would it be fair to say in the elementary

schools every third, fourth and fifth grade teacher

would have signed this agreement?

A. Yes, sir, I think that would be fair to say.

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Q. And would it be fair to say in middle schools

all the English and math teachers would have signed

the agreement?

A. The principals determined which teachers in

the building would serve as examiners.

Q. Okay.

A. But in general, most of them use the English

teachers and the math teachers.

Q. Same for the high school?

A. Yes, sir.

Q. Okay. And I know some grades had to take a

science test.

A. Uh-huh.

Q. Would the science teacher have signed that?

A. Yes.

Q. I don't think -- last year, there was no

social studies test, or was there?

A. No social studies testing last year.

Q. Again, I think you just answered this.

Going back to page 32, the

examiner's/scribe's agreement, those would be

exclusively teachers who would have signed this one?

A. Yes, sir.

Q. Again, Ohio County Schools did not provide a

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copy of the signed agreements by the teachers

pursuant to the FOIA request, correct?

A. No. They are in the individual schools, sir.

Q. Okay. Are you familiar with the contents of

each of these agreements that we just talked about?

A. Yes, I am.

Q. And I let -- unless I read it wrong, I think

the first paragraph -- numbered paragraph in each

was, "I will not keep, copy, reproduce, paraphrase,

distribute or review/discuss secure test materials

and/or test items"?

A. Yes.

Q. And I think that applied to every single one

of the agreements?

A. Absolutely.

Q. And specifically, as this applied to

teachers, teachers were not allowed to look at the

test questions, correct?

A. No, they are not, sir.

Q. Teachers were not allowed to review the test

in any way before or after the test, correct?

A. No, sir.

Q. Teachers were not allowed to discuss the test

with other teachers or educators, correct?

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A. They were not, sir.

Q. Is it fair to say that there was no peer

review at all conducted by any Ohio County educator

with respect to these assessments?


You can go ahead and answer. If you know

what's meant by the word "peer review," go ahead and

answer.

A. Our teachers did not review the materials.

BY MR. DELK:

Q. Okay. And just by way of example, if -- you

know, on any of -- let's say the third grade

assessment.

Let's say that, you know, there was a portion

of the assessment that had -- I'm just going to make

up something -- had Roman Numerals on it, and for

whatever reason, the third grade -- that last year,

Roman Numerals didn't get covered, and the kids

obviously probably wouldn't have done very well.

There's no way for the teachers to be able to

tell parents, Well, you know, part of the test was a

subject matter we did not cover?

A. There would be no way for teachers to know

that.

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Q. And if the reading passages at any grade

level, if a teacher considered it, you know, two or

three grade levels above what they were doing

throughout the year, there would be no way for a

teacher to know that?

A. Teachers would not know that.

Q. Do you know if the testing company was the

entity that required this agreement to be signed as

part of the contract?

A. This was the West Virginia Department of

Education, and we've had these similar agreements in

effect for years.

Q. For years?

A. For years.

Q. Do you know if the testing company requires

this sort of agreement?

A. I have no knowledge about what the testing

require -- the testing vendor would require.

Q. You just know that the department of

education requires these agreements to be signed?

A. Yes.

Q. What is the penalty on an employee or teacher

if they breach this agreement?

A. If I may --

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Q. Sure.

A. -- let me go back to page 25, and I think

this -- the statement is similar in all of the

agreements.

Number 13 says, "I understand that if a

breach of test security or copyright infringement

occurs as a direct result of my actions, my

license/certification may be suspended or revoked, or

I may be suspended, terminated, or have other action

taken."

Q. So potentially, any effort by a teacher to

try to assist a parent as to what specifically a kid

may not have done well on the assessment could be

violation of the agreement?


BY MR. DELK:

Q. To find out what was on the test could be a

violation of the agreement?


You can answer, if you know.

A. This score implementation of the testing --

the teachers could use this document, if we had a

minus here or the little exclamation point, triangle,

and say "Your child" and could give some general

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information to parents, based upon this report only.

MR. CASEY: You're referring to

Exhibit 3?

A. Exhibit 3, uh-huh.

BY MR. DELK:

Q. But for example, if -- you know, if a parent

came to the teacher and said, Well, mine got one of

these --

A. Uh-huh.

Q. -- you know, below standard, the caution

sign, exclamation point.

A. Uh-huh.

Q. And said, you know, What can you tell me that

they had a problem with?

A. Uh-huh.

Q. And if the teacher did anything to try to go

back and review the test or look up the test, that

would be a violation of the agreement?

A. It would be, but the teachers don't have the

ability to go look at the test items.

Q. When the test was being administered, a

teacher could have looked at the test, but it would

have been a violation of the agreement?

A. It would have been a violation.

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Q. On the paragraph you read, paragraph 13, it

says, "I understand that if a breach of test security

or copyright infringement occurs."

Who has the copyright on the assessment, do

you know?

A. I do not know that, sir.

Q. Do you know if it's the testing company or

the department of education?

A. I do not. I'm unable to answer that

question.

Q. All right. Is it fair to say that no student

in West Virginia is required to take the assessment,

the West Virginia General Summative Assessment?

A. It would be fair to say that no student is

required to take the test.

Q. A parent can opt their child out?

A. Yes, sir.

Q. And there's no consequences to the student if

the test is not taken; is that correct?

A. No, sir.

Q. Am I correct?

A. You are correct.

Q. Thank you.

And for example, my third grader, she would

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move on to fourth grade --

A. Yes, she would.

Q. -- regardless of whether she took that test

or not?

A. Yes, she would.

Q. Is it fair to say nothing about the test

result would change the educational instruction

provided to my child?

MR. CASEY: I'm going to object to the

form.

You mean if she didn't take it?

MR. DELK: Right, if she didn't take it.

MR. CASEY: Okay.

A. Oh, no, sir. We would just look at the other

data that we received and go to those multiple

sources again.

BY MR. DELK:

Q. If my child takes the test, regardless of the

result of the test, how would the educational

instruction provided to my child potentially change,

or would it change?

A. In Ohio County Schools, we like to

personalize the education for each child.

So that if I were to look at the results here

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on Exhibit 3, I can tell in English language arts I

have a very high performing child within my

classroom. I would still do my core instruction for

new skills.

And then using formative assessment data, any

other data saying maybe she's ready to be enriched,

and then, depending upon the result here, maybe I

need to think, Is there an opportunity for me to

reteach?

So it's only, again, one piece of information

that we use in the teaching and learning process.

Q. I mean, is it fair to say that the result on

the assessment test for a third grader, any third

grader, would not be determinative at all on whether

they moved on to fourth grade?

A. It would be fair to say that, sir.

Q. When did Ohio County Schools receive the

individual test scores for the students?

A. They became available, and I don't know the

exact date, at about the end of July, and were

provided to my principals as soon as I could get all

of the district results printed.

Q. And they were provided, I guess, to

principals, then, before the school year began?

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A. At about the beginning of the school year.

Q. Do you know, if you know, whether the

curriculum in any individual classrooms or grades

changed as a result of the test scores?

A. The curriculum is still tied to the West

Virginia Next Generation Content Standards and

Objectives, so there would have been no revision of

the curriculum.

Q. So regardless of what the test scores were,

there would be no revision to the curriculum?

A. No. The curriculum would stand as it is.



BY MR. DELK:

Q. Handed you what's been marked as Exhibit 4,

which is a May 1, 2015 letter from Mr. Casey to me in

response to the April 7th FOIA request.

Have you seen this letter before?

A. Have I seen this letter?

Q. Yes, ma'am.

A. No, sir.

Q. If you look at the April 7th letter from me,

you see that Number 4 is, "Provide a copy of the West

Virginia General Summative Assessment administered to

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third graders in Ohio County Schools."

Do you see that?

A. I see that.

Q. And then at Number 4 of Mr. Casey's letter,

it says, "OCS," which is Ohio County Schools, "does

not have access to this information."

Do you see that?

A. I do.

Q. You understand that a copy of the assessment

provided to third graders was asked for by me?

A. I understand that, sir.

Q. Do you know who in Ohio County Schools

provided the information to Mr. Casey that Ohio

County Schools does not have access to the tests?

MR. CASEY: I'm going to object to the

extent it invades the attorney-client privilege.

MR. DELK: Are you instructing her not

to answer?

MR. CASEY: Well, I need more detail as

to when you say "who" and --

BY MR. DELK:

Q. My question is -- this is the response of

Ohio County Schools to the FOIA request, and it

indicates that Ohio County Schools does not have

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access to the information.

And I want to know who in Ohio County Schools

would have provided this information to Dr. Vargo or

to Mr. Casey to come up with this response?

MR. CASEY: Let me -- if I can rephrase?

MR. DELK: Sure.

MR. CASEY: If you ask her, Who within

the Ohio County Schools made the determination --

MR. DELK: That's good. That's a better

question.

MR. CASEY: -- I'll go with that.

BY MR. DELK:

Q. Who in Ohio County Schools made the

determination that it did not have access to the

assessment provided to third graders?

A. I provided the information to Dr. Vargo.

Q. Okay.

A. Uh-huh.

Q. Then, are you the one who made the

determination that Ohio County Schools does not have

access to the third grade assessment?

A. Yes, I would be the individual.

Q. Okay. Why did Ohio County Schools say it did

not have access to the third grade assessment?

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A. Access to the third grade assessment was

provided only to students.

Q. On a computer, correct?

A. Correct.

Q. Would you agree with me that the time period

that this request was made and Mr. Casey's response

was the time period that assessments were being

provided to students in Ohio County Schools?

A. Yes, sir.

Q. And let me ask you this, if you know: For

example, now if a student, for whatever reason,

needed to take the third grade assessment, could that

student now take it?

Would there be a way to access it and allow

the student to take it?

A. No, sir.

Q. That window is closed?

A. Correct.

Q. There's nothing Ohio County Schools could do

to get on a computer and pull up the assessment and

allow a student to take it?

A. That is correct, sir.

Q. Who controls that, I guess, portal, for lack

of a better word? The testing company or the

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department of education?

A. To the best of my knowledge, the West

Virginia Department of Education works

collaboratively with AIR, and they determine the

opening date and the closing date.

Q. When was the closing date?

A. In Ohio County Schools?

Q. Yes.

A. June 5th, the last day of school.

Q. Now, it's true Ohio County Schools could have

printed a hard copy of the test third graders was

taken, correct?

A. No, we could not.

Q. You're familiar with the print-on-demand

function of the test?

A. I am, sir.

Q. And why could that not have been printed?

A. The print-on-demand function is an

accommodation provided to students with an IEP, and

in Ohio County, we had absolutely zero students who

have that accommodation.

Q. IEP stands for?

A. Individualized Educational Plan.

Q. So not a single student in Ohio County

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Schools needed an IEP -- or had an IEP?

MR. CASEY: I object to the form. I

don't think that's what she said.

BY MR. DELK:

Q. Well, what did you say?

A. It's an accommodation provided in an

individualized educational plan, and we have no

students with that accommodation.

Q. Well, regardless of whether a student had

that accommodation, you had the ability to use the

print-on-demand function to print out a copy of the

test?

A. I did not, sir.

Q. Why?

A. The test is delivered by way of a secure

browser. Once the child logs in to that secure

browser, it disables all other functions, except

those needed to answer questions. So it would have

been impossible to print any piece of the test.

Q. Why is that?

A. Because of -- the secure browser disables all

the other functions of the computer.

Q. Could not take a screenshot of each screen?

A. No, sir.

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Q. You could not log in under the -- in any way

to access print on demand?

A. No, sir.

Q. How would you log in to access print on

demand for a student?

A. If a student has that accommodation, the

information is uploaded from the West Virginia

Department of Education to the vendor, which then

allows that function to occur; but again, we had no

students in Ohio County who had that accommodation.

Q. I mean, you could have created -- if you had

wanted to, you could have create a student just --

A. No, sir.

Q. -- to get in there and log in --

MR. CASEY: Wait for him to finish his

question.

A. Sorry.

BY MR. DELK:

Q. In theory, could you have created login

information for a John Doe student to access print on

demand?

A. No, sir.

Q. Why not?

A. All of our students are entered into the West

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Virginia Educational Information System, and we can

not, quote, create students.

Q. Okay.

A. I apologize for jump --

Q. That's all right.

A. I was just a little startled by that

hypothetical.

MR. CASEY: That's okay. You need a

break?

THE WITNESS: Yes, please.

(Brief Break)

BY MR. DELK:

Q. The testing procedure for students -- and

let's stick with third graders since that was my

request.

The third graders in each individual

elementary school, I guess, are in the testing room,

taking this test?

A. Yes.

Q. And the testing room, I guess, is where the

computers are in each school?

A. It varied by school.

Q. Were computers brought in for the test,

specifically, or did you just -- did Ohio County

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Schools just use what computers were at the school

already?

A. We used what computers were at the school,

yes.

Q. And would the students log in individually,

or would they be provided assistance with doing that?

A. Students logged in individually.

Q. And when a student logged in, that test was

on the terminal, computer, that they were working on,

correct?

A. Yes, sir.

Q. I probably need to ask this of Mr. Riddle

rather than you, but to the extent you know, was

there a server in Ohio County Schools that the test

came through and was distributed out to the schools,

or do you know how that worked?

A. I do know that. The test did not reside on

any server in Ohio County Schools. Students logged

in using their WVEIS student numbers and their first

names, and then my understanding is it -- that in

secure browser, it went directly to the vendor.

Q. Went directly to the vendor?

A. Yes, sir.

Q. Not at the West Virginia Department of

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Education at all?

A. No, sir.

Q. So as far as you know, no government entity

in the state of West Virginia had access to the test?

A. That is correct, to the best of my knowledge.



BY MR. DELK:

Q. Let me hand you Exhibit 5, which are just

documents that were part of what was produced by Ohio

County Schools pursuant to my FOIA request, that I've

highlighted some portions.

If you could turn to the next to the last

page, and then I'll ask you about -- I highlighted

the part at the bottom.

A. Are we referring to page 461 or --

Q. Yes, 461. Yes.


Q. And the question at the bottom says, "Will

printed versions of the WV GSA be available to

students? I have a 504 student who is unable to read

technology displays/use a computer due to an eye

disease. Could she use print on demand?"

And just so I have an understanding, if you

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know, what's a 504 student?

A. We have individualized educational plans for

students with special needs. A 504 plan generally is

comparable to an IEP plan, and generally they are

provided for students who have medical needs or some

kind of specialized need.

So again, just like an IEP, it's a legally

enforceable document.

Q. Okay.

A. So that's what a 504 is.

Q. If you could turn to the next page, 462. And

at the top left, it says, "Print on demand is an

option if the student has P40 as an identified

accommodation. Additionally, a LP book may be

ordered for the student."

What's a P40, if you know?

A. It would be an accommodation.

Q. Is it a specific kind of accommodation?

A. Yes, it would be.

Q. What -- I mean --

A. Off the top my head --

Q. Okay.

A. -- I can't speak to that.

Q. What's an LP book? A large-print book?

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A. It would be a large-print book.

Q. Did Ohio County Schools order or have any

large-print books?

A. Ohio County Schools had no large-print books.

We have no students with that need.

Q. Okay. Is it your testimony that if a student

had any issue in the testing room during the test

that there was no way to print out any of the test

questions during the test?

A. That is absolutely correct. We had -- we did

not have the capacity to print anything from the

test.

Q. Is it your testimony all other functions on

that individual computer were basically disabled

during the test?

A. Yes, sir. Except for the ones needed to --

the mouse clicks and so forth -- to perform the task

necessary to answer the question.

Q. Okay. I want to go through with you the

documents that were produced pursuant to the FOIA

request. I'm going to hand you this copy.

MR. CASEY: Are you making this an

exhibit?

MR. DELK: No.

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BY MR. DELK:

Q. If could you turn to page 4, and I've

numbered these on the bottom right, for the most

part.

This document indicates there is one

attachment to it on page 4 towards the top.

A. Yes, sir.

Q. What's the attachment, do you know?

A. The department of ed did -- and that would

have been the online link for it, their webinar, so

that, literally, I could have clicked, looked at

their PowerPoint presentation as they talked and

listened to it on the telephone.

Q. Okay. That's something that could have been

printed out?

A. I would be hesitant to say that it would be

readily available.

Q. That's what I'm asking.

A. Yeah.

Q. Okay. Turn to page 6.


Q. Is that the same type of --

A. It's a similar --

Q. -- document?

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A. It's similar.

MR. CASEY: Let him finish.

A. Okay. Thank you.

MR. CASEY: Go ahead.

BY MR. DELK:

Q. That's the same sort of PowerPoint that you'd

be hesitant to say whether you could print that out?

A. Exactly.

Q. Okay. Turn to page 19.


Q. Same question. Is that a PowerPoint

presentation that you're referring to?

A. Same thing.

Q. If you could turn to page 45.


Q. The attachment on this e-mail indicates it's

a PDF; is that correct?

A. Yes, sir.

Q. And that could have been printed out if it

wasn't --

A. It could have been. It's publicly available

at the department of ed.

Q. But it was part of this e-mail, or document,

as well, correct?

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A. Yes.

Q. Any reason why it wasn't produced?

A. No, sir.

Q. Turn to page 50.


Q. What is this document? Is it an e-mail or

something you receive from the department of

education? If so, how do you receive it?

A. This was information about -- from the West

Virginia assessment portal.

Q. Uh-huh.

A. That is available for anybody who clicked in

to look at it.

Q. People who have access to it?

A. Yes.

Q. Not any member of the public, but someone in

the school systems, I take it; is that correct?

A. Yes, sir.

Q. And this has a PDF attachment to it, Test

Delivery System User Guide?

A. Yes, sir.

Q. That would be a public record?

A. To the best of my knowledge, it would be.

Q. Next page.

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Q. PDF, TIDE User Guide?

A. Yes, sir.

Q. What is that?

A. It's another component of the West Virginia

assessment portal.

Q. And this PDF was attached to this document or

communication you received?

A. Yes, sir.

Q. That would be a public record as well?

A. To the best of my knowledge, yes.

Q. Next page, page 52.


Q. PDF, Teacher Hand Scoring System User Guide.

Do you see that?

A. Yes.

Q. That would be a public record as well?

A. Yes, sir.

Q. Next page, page 53.


Q. It doesn't say here. This Online Reporting

System User Guide, was that a PDF or --

A. Yes, sir.

Q. Would that be a public record?

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A. To the best of my knowledge, yes.

Q. Page 54.


Q. System Requirements, that's a PDF as well,

correct?

A. Yes, sir.

Q. Do you know what that document was?

A. It had the technical specifications, which

Mr. Riddle would have used to install the secure

browser, was my understanding.

Q. That would provide information about what the

secure browser is?

A. The installation process, yes.

Q. Potentially information about the

print-on-demand function?

A. I would be reluctant to say if that

information was considered in there.

Q. But it's part of the technological

information that Mr. Riddle would have been provided

about the secure browser?

A. Yes. Yes, sir.

Q. Potentially talking about what you can and

cannot access?

A. Uh-huh.

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Q. Is that -- and if you don't know, just tell

me you don't know.

A. I seriously -- I don't know. I believe it

was the installation of the secure browser.

Q. And that's a public document?

A. Yes, sir.

Q. Page 55, User Role PDF.

What is that document?

A. That document specifies the role of the

district test coordinator, the school coordinator,

the test examiners.

Q. Public document?

A. Yes, sir.

Q. Page 56, Technical Specification Manual.

Was that a PDF?

A. Yes, sir.

Q. What was that document?

A. Again, it related to Mr. Riddle's work in the

installation of the secure browser.

Q. That would have specific technical

information about the browser and how the test is

provided from the company, potentially?

A. Potentially about the installation, right.

Q. And that's a public document?

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8/20/2019 Sue Ellen Mc

sue ellen mcguier deposition - delk v. ohio county (wv) board of education

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