[brief] The Commission incorrectly dismissed complaints where all Board members were involved (Raised at: Pa16)**  In considering the Alleged Violations of N.J.S.A. 18A:12-24.1(g), the Commission first considered the allegations against all of the Board members.  In its decision to dismiss, they state:  In Counts 1-8, Count 12, Counts 14-15, and Count 18, Complainant submits that “Respondents” violated *N.J.S.A.* 18A:12-24.1(g).  At its core, these Counts contend that “the Board” acted unethically because it did not provide accurate information, and/or presented biased or incomplete information to the public regarding the referendum.  In its review, the Commission finds that Complainant has not articulated exactly how any of the named Respondents may have specifically violated the confidentiality provision and/or the inaccurate information provision of *N.J.S.A.* 18A:12-24.1(g).  Instead, Complainant offers nothing more than general and vague conclusory statements about what the “Board” may have done, but does not offer any detailed facts evidencing how the named Respondents may have engaged in unethical conduct.  Because such generalized accusations are wholly insufficient to satisfy Complainant’s burden of proof, the Commission finds that the alleged violations of *N.J.S.A.* 18A:12-24.1(g) in Counts 1-8, Count 12, Counts 14-15, and Count 18 should be dismissed.  (Decision on Motion to Dismiss, Pa16).  As with other sections of its order to dismiss, the Commission chooses to lump several disparate charges into one convenient bucket to dismiss en masse, without any analysis of the individual charges or detailed reasoning for their decision.  It appears (but is not entirely clear here), that the Commission rejects ethics complaint that charge the entire Board with unethical behavior.  What the Commission fails to consider here is its responsibility when, in fact, an entire board conspires to act unethically, in this case all Board members acting in concert to influence voters in the District.  Counts 1-8, 12, 14, 15, and 18 all involve actions the Board members, collectively, embarked on to deceive taxpayers about the nature of the facilities referendum; to hide material information about the state of the [...]; to falsely indicate that the [...] could not be renovated; and to spend vast sums of money on the “yes” side of the referendum and disenfranchising those who were against the referendum in the district.  As can be seen in its decision, the Commission entirely ignored the rich judicial history in New Jersey regarding Board conduct during referendums.  As mentioned in earlier in this brief, the New Jersey Supreme Court set forth the standard of conduct for school board members who publicize a referendum that they sponsored in *Citizens*.  What the Commission fails to consider is a situation where all Board members decide to act in concert in an unethical matter on a vital issue for a school district.  In this case, all nine members knowingly entered actions to promote the Referendum, to deceive the public on certain facts, and to sow discord in the community among those who did not favor the Referendum.  By dismissing these counts en masse, the Commission gives Board members an “out” from ethic rules by merely conspiring to act together unethically.  This oversight is arbitrary and capricious, and should be overturned.