NYSED redacts decisions, and its source files vary in quality. Gaps and text errors are original to the NYSED documents.
FINDINGS OF FACT AND DECISION
RE L"""E'-.\/
_l \I f)
-
Student:
SEP O3 2019~
OFFICE OF SPECli''. '::DU,Af1.0P
DUE PROCESS lJoJfl Date of Birth:
District: CSD
Requested By: District
Dates of Hearing: June 25, 2019
June 26, 2019
Hearing Officer: Aaron Turetsky
I
Central School District
By an impartial hearing request filed on April 12, 2019, the District has requested an order permitting the District to speak directly to the medical and providers, granting the District access to the medical/therapeutic/treatment records for the ' past two years, and authorizing an "independent" evaluation of a then year old, now year old, student with a disability. (Exhibit D-1) The parent's 1 memorandum of law, in addition to requesting denial of the District's requests, sets forth the parent's own requested relief: the removal of the director of secondary special education from the student's case, compensation for lack of PAPE provided to the student during the last school year, in which the student's family is said to have paid $3,600 in connection with the student's attendance in an school, consideration by the District of all New York State approved placement options, said to include, as the option preferred by the student and her family, supplementation of classes in the District with classes to be funded by the District, and payment by the District of the cost of treatment, in-patient stay, and family accommodations at a (Exhibit IHO-VII)
The parent's request for the removal of the director of special education from the case is based to a significant extent upon the latter's testimony at this impartial hearing.
(Exh. IHO-VII, pp. 6-7) The record discloses that prior to this impartial hearing, the District may have had at least some inkling of at least some of these issues of the parent.
Central School District
For example, a non-attorney advocate for the parent who participated in a CSE meeting on May 2, 2018 told the CSE that the IEP being developed by the CSE did not allow the student access to FAPE. (Exh. D-21, p.l; Tr. 411-412) And by a letter dated April 10, 2018, the student's. recommended to school authorities that the District pay for the student's tuition at the school. (Exh. D-19) The parent's wanting the District to pay for an school was known to the District since at least February 7, 2018. (Exh.
D-17, p. 2) Furthermore, the parent's request for payment by the District of expenses pertaining to the out of state clinic might seem a logical response to the District's wish for greater collaboration among the various medical specialists who are involved in the student's care.[2] (Tr. 43, 178-179, 241-242, 377) However, as far as the undersigned is aware, the parent has not filed a due process complaint notice seeking relief with regard to any of these issues, nor has the parent sought such relief by way of a counterclaim in a pleading responsive to the due process complaint notice filed by the District. Thus, other than the parent's request for the denial of the District's requests, the parent's requests are not before me, not even for me to deny them without prejudice to the parent requesting them in a due process complaint notice, and not even for me to express an opinion as to whether or not they would be within the jurisdiction of an impartial hearing officer to grant.
It would violate due process for me to address these requests in any way when the District was not on notice of them and did not have an opportunity to respond to them. As an important corollary, it should be noted that because the District's requests have not been
Central School District
made in the context of the District responding to such requests by the parent, no inference should be drawn from anything in this decision concerning the extent to which the District might be entitled to the same requested relief if requested by the District in another context. 3 Cf, e.g., Stancourt v. Worthington City Sch. Dist. Bd. of Educ., 164 Ohio App. 3d
184 (Ohio Ct. App. 2005).
The student, who will henceforth be referred to by the fictitious initial R , for
E
D purposes of confidentiality and readability, was referred by a physician
A to a
C
T specialist in (Exh. P-C, p. 1) for consultation regarding a possible
E
D
disorder several after dislocating her in May 2015 (Exh. P-C, p.
1) while going down a hill at the District's school (Tr. 14) and having had therapy two to three times per week (Exh. P-C, p. 1). In October 2015, the specialist in assessed R as meeting the criteria for
E
D (Exh. C, p. 3 ), which sinceA has received new nomenclatures of
C
T
E (Exh. D-
D
41, p. 11). (It appears from the entirety of the exhibits that a hyphen is sometimes used between and sometimes not.) The specialist m referred R for a evaluation to assess for possible . , said to be
E
D appropriate
A for all persons diagnosed with and for an evaluation for
C
T
E and because of her (Exh. P-C, p. 3)
D
An August 2018 letter from a . stated that R was being followed for a
E
D
A 3 C The IDEA does not require a responsive due process complaint notice,T nor does the IDEA provide for a counterclaim. It is immaterial that the parent might have requested suchE relief in a due process complaint notice and that the hearing on such a hypothetical due process complaint notice
D might have been consolidated with this one.
Central School District case No. s2426s
(Exh. P-F) and was being referred to the for
evaluation for (Exh P-F) stands for
The parent's understanding that R has , which she has
E
D shared with the District (Tr. 406, P-QQ) and, it appears, withAR s (Exhs. D-6,
CE
TD D-8, D-19, D-25, D-31, P-R), might be based on R 's symptoms EA (Tr. 256, Exh. D-41, p. 8).
E DC
D T The that R had E
's letter also stated A symptoms of
C E D
T D
E A
D C
T
E
D
A March 2018 letter from a
stated that R was being evaluated for (Exh. P-H)
E
D
occurs at increasedjfrequency
A in (Exh. D-41, p. 9)
C II -
--- ---- -
T
Meanwhile, a FebruaryE 20) 8 letter from a , who was in
D
the same physicians' network as the specialist in the , and the , stated that she was treating R for
E
D
(Exh. P-I, p. 1) _________ may overlap with or complicate · A . (Exh. D-
C
T 41, p. 15) Also in February 2018, a letter from the physician Estated that R
D E
D was under her care for (Exh. P-K), which can be manifestations of A
C
T
E
D
Central School District
(Exh. D-41, p.17). Another letter from the physician in February 2018 stated that R was under her care for that R had chronic
E E
D D
A issues and chronic related to A
C C
T T (Exh. D-10) AnE October 2018 letter from the physician stated
E that R was
D D E
D under her care for with underlying · '- A (Exh
C
T P-L) A March 2018 letter from a pediatric neurologist in the same physician's networkE as
D
the , the specialist in , the
and the seems to have accurately summed UJJ the situation in stating that RE was working with multiple specialists to manage her disorders. (Exh. D-14)
D
A Some of theCTdisorders listed in the letter have yet to be mentioned in this decision.
ED
During the 2016-2017 school year, when RE attended the District's school
DA
CT with §504 program accommodations, modifications,
ED and supports to address R 's having
E
D
(Exh. D-2), P (Exh. D-3, p. 2). ForA the 2017-
C
T 2018 school year, RE was provided with an IEP with her disability classified as E
D D
A
(Exh. CT
D-3, p. 1) and in addition to program accommodations, modifications,
ED
and supports that were further developed from those on her previous year's §504
Accommodation Plan (Exh. D-3, pp. 10-11; Tr. 67), P was provided with a special class with a student teacher ratio, in which she was to receive curriculum support in all of her content area subjects to support her IBP in the areas of ("[R ] will complete
E
D homework assignments and classroom assignments for all her classes") A and
C
T ("When given a writing assignment, [R ] will use the writing processes Eof planning and
E D
D revising in assessing if intended audience
A and specific purpose have been adequately
C
T
E
D
Central School District
addressed utilizing a writing rubric to evaluate and quantify the planning and revision processes"). (Exh. D-3, pp. 9-10; Tr. 67) It was anticipated by all involved that R would
E
D be attending school with a full schedule. (Tr. 66-67) However, within a week intoA school,
C
T the District started making changes to R 's schedule because she · E
E D
D
A . (Tr. 66-68) On January 3, 2018, P's
C
T
advised school authorities Ethat R was having
D E
D because of and suggested that R be Areferred to the
E C
D T [Tr. 72]) program. (Exh. D-6) The A DistrictE referred R to the · program, but the ·
C D E
T D program declined the referral because E the ProgramA believed that R 's
D C E
T D
E A
D C
T (Tr. 73-74) On January 31, 2018, apparently on the assumption that ER would be accepted
DE
D into the . program, R 's suggested to school authoritiesA that while R was
E C E
D T D
waiting for a slot at theA program to open up, R receive E HeA also
C E D C
T D T
stated that the reason Efor R A was that R was E
D E C E D
D T D
A . E (Exh. D-8) The DistrictA promptly
C D C
T T provided R with E , but cancellations by the parent and late arrivals
E by R
E D D E
D D were frequent.
A (Exh. D-17, pp. 1-2) On March 23, 2018, the parent withdrew R from A
C E C
T D T
school in Ethe District, giving as the reason for withdrawing that R would be A E
D E C D
D T (Exh. D-18) The parent enrolled R in the school. (Exh. A P-NN) For a semester's
E
E C D
D T attendance, the school awarded
A R E
C E D
T D
E A (Exh. NN)
D C
T
E
D
Central School District
as of March 14, 2018. (Exh. D-39)
R did not like the school because she was isolated at home and unable to
E
D socialize
A with her peer group (Tr. 221) and the parent infonned the CSE that she would be
C
T re-registering
E R back into the District for the 2018-2019 school year and that R was ready to
D E E
D D come back into A the District. (Tr. 102-103) On August 22, 2018, the CSE developed
A an IBP
C C
T T for R for th~ E2018-2019 school year, which provided for special classes withEa student
E D D
D teacher
A ratiq once daily in . and twice daily in , as
C
T wellE as th} once daily special class. (Exh. D-26, p. 17-18)
D
I Additionally, R was to receive ' on Monday contingent upon her absences:
E
D If R were a, A
sent one day during the previous week, she would receive one hour of home E C D T
If R were absent more than one day during the previous week, she would instruction. E A
C D E
T D
A of home instruction. (Exh. D-26, p. 18) It was agreed that R would not receive two hours E
D C E
T D take (Exh. D-26, p. 2) P
E A (Tr. 109)
D C
T
E
D
(Tr. 115-116, Exh. D-
35) On October 15, 2018, the CSE reconvened and recommended an additional special class two and a half times per week (Exh. D-28, p. 19), the idea being that on alternate days, R could have lunch before coming to school and attend the additional
E
D
instead Aoflunch. (Tr. 115) However, R did not attend the additional
C E
T D
E A
D C
T
E
D
Central School District
class after R 's . wrote to school authorities "at the request of her mother to
E
D support [R J's
A wish to spend lunchtime with her friends in the cafeteria rather than in an
E C
D T extra A Eclass." (Exh. 31, p. 1) The special education teacher of the special education
C D
T
E class R continued to attend testified that when R was in attendance, 90%
D E E
D D of what she did with R was A make up work for R 's academic classesA rather than what the
E C E C
D T D T
class
A Ewas intended for. (Tr. A 158) No one seems E to have questioned the
C D C D
T T special education teacher's
E professional judgmentE in that regard. R 's participation in home
D D E
D instruction was similar to that of the previous school year. (Exh. D-36)
A
C
T
The District's nurse coordinator (Tr. 4), who has extensive E nursing expenence,
D
education, and credentials (Tr. 5-9), testified that the District has at least four other student~ in R 's school, and perhaps seven or either students in other schools in the District, who E D have A the same diagnosis as R and who attend school on a regular basis. (Tr. 15) C E T D However, given the wide range of Apossible conditions and possible symptoms associated E D C T with , it's a safe bet that no Etwo cases are identical. It is also of concern for the
D
District that photographs of herself that P has posted on social media4, in the District's view, portrayR as being physically active to a degree that suggests R is physically able to
E E
D D
A A
C C
T T
E E
D D
4 The director of secondary special education testified that she obtained these photographs by going into R 's
E social media site. (Tr. 135) She testified that the District looks at students' social media sites when "we start
D to have concerns regarding students, whether it's students who may not be coming to school or students using A substances or students who have residency issues." (Tr. 135) She testified that the District has "student C informants that share information and give us information so we can secure social media sites." (Tr. 136) T It is unclear whether student informants were involved in the District accessing P's social media site, since Ethe director of secondary special education testified that E's social media site "was an open page," (Tr. 135) D However, with regard to the District's use of informants, the undersigned takes judicial notice that students elsewhere have engaged in acts of violence on school premises after previewing their intentions on social media ard that none of their peers reported these posts to authorities in advance, either because of disbelief or because of not w ting to be snitches.
Central School District
- - - - - - - - ~ "-·---------.,-·--------- - - - - - ----------- - - - - - - - - - - - -
Central School District
As the specialist in wrote, "The treatment for involves a symptomatic approach, directed toward the individual patient's concerns. Such treatment might include gastroenterology evaluation for persons with diarrhea, abdominal pain or other GI concerns; neurology evaluation for chronic headache; and/or rheumatologic evaluation for persons with joint pain." (Exh. C, p. 3) In her opening statement, the parent elaborated as follows upon what the specialist in wrote: "There is not a doctor for , and there is no cure. A specialist in a specific area, for example, a cardiologist, an orthopedist, et cetera, treats each symptom. These doctors can discuss their specific area only as they do not treat the whole patient nor can they provide generalizations." Athough the following requests are not set forth in the due process complaint notice, the Petitioner's Post-Hearing Memorandum of Law states that the District would like "a group meeting at which [R ]' s providers can be informed of all of
E
D the educational and medical concerns in order to A develop an appropriate educational plan"
C
T (Exh. IHO-VIII, pp. 14-15), "a collaborative relationship
E in which the District, the Parents
D
Central School District
and the private providers can all work together to support [R ]" (Exh. IHO-VIII , p. 15), or
E
D "the collaborative effort of all of [R J's private providers"A (Exh. IHO-VIII, p. 19).
E C
D T Although it indeed is challenging for Athe District to determine
E an appropriate educational
C D
T plan when different medical specialists
E have made different recommendations that are at
D
variance with one another, I agree with the parent, based on the information in the record about hEDS, that it would be beyond the competence of any of the medical specialists to weigh in on the recommendations of the others and that they could not reasonably be expected to get together and iron out their differences, either with or without the District's participation. (Exh. IHO-VII, pp. 3-4)
As concerns what the District has requested in the due process complaint notice, it is important to note that, contrary to the understanding of the parent (Exh. IHO-VII, p. 1), the District has not requested "an independent evaluation." According to §200.5(g) of the Regulations of the Commissioner of Education, an independent educational evaluation is either (1) an evaluation requested by a parent if the parent disagrees with an evaluation obtained by a school district or (2) an evaluation requested by an impartial hearing officer as part of a hearing. Neither (1) nor (2) is the case here.
There is no evaluation of R in the record. There are three
E
D diagnoses of R in various letters to school authorities
A by R 's
E C E
D T D
A E A
C D C
T T
E E
D D
None of these brief letters can reasonably be characterized as a report of a
Central School District
evaluation. Some of them, most notably the last discussed above (Exh. D-31 ), lend credence to the District's "concern that RE 's ] will write a letter stating anything
D
A the Parent asks" (Exh. IHO-VIII, p. 14
CT). The 's careful phrasing in all his
ED
letters that he is writing in his capacity as R 's at the request of her mother to
E
D suggest, indicate, recommend, or support something
A seems a tacit acknowledgement that
C
T was the case, although surely the E would not have importuned the District for
D
anything that was contraindicated. And the parent may have followed advice in A Parent's
Guide: Helping Your Child Succeed at School: "Ask your doctor to provide a letter of diagnosis and suggestions for the school." (Exh. P-Y, p. 12) The part of eaeh of the conditions in R 's and how they impact upon one another is
E
D not clear. A A that the parent consented to at the same time
C
T she declined Econsent to the evaluation sought by the District (Exh. D-9, p. 1)
D
identified the following reinforcement for R 's : "RE
D
] is encouraged to
E
D A
." (Exh. D-16, p. 4)A I doubt that either the CT parent or the District
C ED
T found that new or helpful. E
D
It is unnecessary for me to have recourse to the broad equitable powers of an impartial hearing officer to craft remedies in order to permit the District to conduct a evaluation of R over the parent's objection, as the District suggests. (Exh. IHO
E
D VTII, pp. 16-17) An abundance of case law supports that position of the District. See G.J.
A
C
T by L.J. and E.J. v. Muscogee
E County Sch. Dist., 668 F.3d 1258 (U.S. Court of Appeals,
D
Eleventh Circuit 2012); Renton Sch. Dist., 111 LRP 39470 (Washington State Educational Agency 2011 ); Shoreline Sch. Dist., 110 LRP 12540 (Washington State Educational
Central School District Case No, 524265
Agency 2010); Prince George's County Pub, Schs., 105 LRP 57861 (Maryland State Educational Agency 2005); Selma City Sch. Bd., 39 IDELR 115 (Alabama State Educational Agency 2003); Westport Bd, of Educ,, 4 ECLPR 412 (Connecticut State Educational Agency 2002); Madison Metropolitan Sch. Dist,, 34 IDELR 109 (Wisconsin
State Educational Agency 200 I); Seattle Sch. Dist,, I 02 LRP 2694 (Washington State Educational Agency 2000); As the State Review Officer wrote in Appeal No, 09-098,
"Subject to certain exceptions, a school district must obtain informed parental consent prior to conducting an evaluation (34 C.F.R § 300,300[c]; 8 NYCRR 200,S[b][l][i]; see Letter to Sarzynski, 51 IDELR 193 [OSEP 2008]) and provide adequate notice to the parent of the proposed evaluation (8 NYCRR 200,5[a][5]). However, if the parent refuses to consent to the evaluation, the school district 'may, but is not required to,' pursue the reevaluation using consent override procedures, including mediation and the filing of a due process complaint notice (34 C.F,R § 300.300[c][l][ii]; 8 NYCRR 200,5[b][3])," However, I do not believe that the District has shown that it is necessary, useful, or practicable for the District to speak directly to R 's medical and providers or to have as
E
D extensive access to R 's medical/therapeutic/treatment records as the District has requested,
A
E C
D T and I shall limit such
A relief E to what I believe is reasonable for the District to conduct a
C D
T
evaluation
E of R , With regard to the parent's position that R 's medical
D E E
D D information is protected by AHIP AA, "While there are limited circumstances A where a school
C C
T T district might qualify as a Ecovered entity, generally educational records that E
are protected
D D
by the Family Educational Rights and Privacy Act of 1974 ("FERPA") are not subject to
Central School District
HIPAA." In re: Student with a Disability, 103 LRP 57778 (New Mexico State Educational Agency 2003)
Based upon the foregoing, it is hereby
(1) ORDERED that the District may conduct a evaluation of the student by a of the District's choosing, and that the parent shall make the student available for the evaluation; and it is further
(2) ORDERED that the District shall provide transportation for purposes of the evaluation if the parent requests such transportation; and it is further
(3) ORDERED that the parent shall execute consent for the student's current
(or last former , if the student has no current · ) to communicate with the chosen by the District to conduct the evaluation and to release to the chosen by the District information concerning the student that the student's current (or last former · , if the student has no current ), in his or her independent professional judgment, believes it appropriate to release for purposes of the evaluation, including the report thereof; and it is further
(4) ORDERED that the parent shall execute consent for the student's current
(or last fonner , if the student has no current ) to communicate with the chosen by the District to conduct the evaluation and to release to the chosen by the District information concerning the student that the student's current (or last former , if the student has no current · ), in his or her independent professional judgment, believes it
Central School District
appropriate to release for purposes of the evaluation, including the report thereof; and it is further
(5) ORDERED that if the parent disagrees with the evaluation of the student thus obtained by the District, the parent may have recourse to the procedures for requesting an independent evaluation of the student set forth in the Regulations of the Commissioner of Education.
Dated: August 25. 2019
/s::
Aaron Turetsky
Impartial Hearing Officer
PLEASE TAKE NOTICE
The parents and the board of education are hereby advised of the right of any party involved in the hearing to obtain a review of this decision by the State review officer in accordance with subdivision k of section 200.5 of the Regulations of the Commissioner of Education.
Central School District
EXHIBITS ENTERED INTO RECORD JUNE 25, 2019 5
I Due Process Complaint Notice 4/12/19 6pp,
2 §504 Plan ]0/11/16 4pp.
3 IBP 6/12/17 13 pp.
4 Assessment 5/11/17 11 pp.
5 Letter from 9/28/17 Ip.
6 Letter from 1/3/18 Ip.
7 E-mails between parent and 1/29/18 2 pp.
/
8 Letter from · 1/31/18 Ip.
9 Consent for ~ __ ___ 2/15/18 4 pp.
Assessment and Prior Written Notice
of proposed reevaluation
10 Letter from physician 2/26/18 Ip.
11 Patient Health Summary 3/1/18 2pp.
12 Treatment Summary by 3/8/18 2 pp.
14 Letters from 3/12/18 2 pp.
15 E-mails between parent and director 3/17-18/18 3 pp.
of secondary special education
16 assessment 3/15/18 4 pp.
17 instruction attendance log and vanous 3 pp.
related e-mails
18 Student Withdrawal Check Sheet 3/23/18 Ip.
5
District exhibits are labeled by number, parents' exhibits by letter. Impartial Hearing Officer exhibits are prefaced !HO.
Central School District
Case No, 524265
19 Letter from 4/10/18 1 p.
20 E-mail from· 5/12/18 1 p,
21 IEP 5/2/18 19 pp.
22 E-mails between parent and director 6/16-18/18 2pp, i of secondary special education
23 E-mail from District's attorney 7/30/18 I p.
24 Health Services Form 7/31/18 l p.
25 Letter from 8/20/18 l p,
26 IBP 8/22/18 22 pp,
27 E-mails between parent and health various 4pp.
services coordinator with Emergency
Care Plan
28 IEP 10/15/18 24 pp,
29 E-mails between director of secondary 10/15/18 3 pp, special education and parent
| 30 | Lctterfrom physician 11/4/18 l p. |
| 31 | Letter from and e-mails vanous 3 pp. |
| 32 | Letter from 3/8/19 1 p, |
| 33 | Letter from physician 3/12/19 l p, |
| 34 | Quarter 3 Report Card undated Ip. |
| 35 | Attendance Log various 2pp, |
| 36 | Instruction Attendance Log various 2pp. |
| 37 | Class Assignment Log various 60pp, |
| 38 | Quick Lookup 3/21/19 2pp. 18 Central School District Case No. 524265 |
39 Official Transcript 3/18/19 1 p.
40 Photos posted on social media undated 3 pp.
~
41 Article 6121/18 31 pp. ~
r
l,"
A "America's Top Doctors" undated 1 p. I
B "Best Hospital, Best Results" undated 9pp.
C Consultation Report 10/20/15 4 pp.
F Letter from 8/9/18 1 p.
H Letter from 3/5/18 1 p.
I Letter from 2/20/18 3 pp.
J Letter from physician 12/20/15 2pp.
K Letter from physician 2/20/18 1 p.
L Letter from physician 10/16/18 1 p.
R Letter from 3/8/18 1 p.
X "A Child's Life" 2014 1 p.
y "An Educator's Guide/A Parent's Guide" 2003 20 pp6 .
z Body Diagram undated Ip.
AA "A Teacher's Guide" and excerpt from undated 3 pp.
"Tips for Teachers"
BB Excerpt from "Tips for Teachers" undated 1 p.
cc "Diseases and Conditions" undated 5pp.
DD "Emergency Care Plan" undated 2 p.
6
Due to a copying error, only odd numbered pages of this exhibit were provided to the undersigned on June 25, 2019. The entirety of the exhibit was e-mailed to the undersigned on August 14, 2019. (Exhibit IHO-IX)
August 14, 2019 is the actual record close date.
]9
Central School District
Case No, 524265 ·
EE Advocate's Resume 1/30/18 9pp,
FF Letter from advocate 2/8/19 1 p,
~
GG E-mails between parent and director of 2/12-14/19 1 p, [
~
secondary special education
J
HH E-mail from parent 2/13/l 9 l p,
II E-mails from parent and director of 2/11-12/19 2pp, secondary special education
KK E-mails between parent and school 3/1/18 2pp, psychologist
LL Letters from Department of Social Services 5/24/18 2pp,
3/1/18
MM Letter from Department of Soeial Services 1/23/19 1 p,
NN Private school transcript 8/28/18 1 p,
| 00 | Official Transcript 3/14/18 2pp, |
| pp | E-mails from parent 3/5/18 1 p, |
| E-mails among director of secondary special various 3 pp, education, school counselor, and parent | |
| RR | E-mails among parent, school counselor, and various 5pp, director of secondary special education |
| ss | Confidential Information Release 2/15/18 1 p, |
| vv | Confidential Evaluation 8/2/18 2pp, |
EXHIBIT ENTERED INTO RECORD JUNE 26, 2019
WW Video undated
yy E-mails and correspondence re, midterms various 7pp,
Central School District
Case No~ 524265
EXHIBITS ENTERED INTO RECORD POST HEARING
IHO-I Letter from IHO 4/25/19 l p.
~-
IHO-II Letter from IHO 4/26/19 l p. fr
f
IHO-III Letter from IHO 5/11/19 2pp. i
IHO-IV Letter from IHO 5/14/19 Ip.
IHO-V Letter from IHO 6/28/19 1 p,
IHO-VI Letter from IHO 7/24119 Ip.
IHO-VII Parent's Closing Memoranda undated 7pp.
IHO-VIII Petitioners' Post Hearing Memorandwn of Law 8/7/19 20pp,
IHO-IX E-mails from IHO, Parent, and District's attorney 8/14/19 2pp.
Footnotes
[2] The District does not contend that there has been a complete absence of collaboration among the student's medical specialists, and does not contend that the circumstances of the student being treated by different doctors would be comparable to, say, an addict going to various doctors to obtain prescriptions, with each doctor unaware of the other doctors also having written prescriptions.