Dear Special Agent Ghent:

I have reviewed your extensive investigation into the alleged grade-changing that took
place at Beaufort High School. It appears there is substantial evidence that Dr. Dan Durbin,

While acting as principal of Beaufort High School, changed the grades of 33 students who were
enrolled at the school.

The Beaufort County High School Counselor Handbook appears to give a principal the
discretion to change grades, but only alter meetings With the student's teacher and guidance
counselor. This internal procedure requires substantial documentation of the process and an
explanation of Why each change was made. In many cases, there is some evidence that Dr.
Durbin changed the grades in question añer consulting with Various faculty members, but in
other cases he made unilateral decisions. There was insufficient record-keeping as to Who was
consulted for each instance and Why the changes were necessary. Thus, it appears Dr. Durbin did
not follow the schoo1district's policy and procedures.

There is no evidence, however, to suggest that Dr. Durbin received any financial benefit
for these changes or that he engaged in this behavior with malicious intent. He was not paid for
his grade changes nor was his contract contingent on student grades. Further, he made no effort
to hide the fact that he was changing students' grades. He not only involved other faculty

members in his actions, but logged into the computer network using his own username and
password.

In order for Durbin’s actions to be criminal, I must prove more than a violation of School
Board policy. I must prove criminal intent. Based on the results of this comprehensive
investigation, I can find no evidence of this.

Dr. Durbin has clearly created many problems, but these are administrative matters that
are best handled by the State Board of Education and the Beaufort County School District, not
our Criminal courts. His actions have called into question the credibility of the entire high
schoo1’s grading system, an unfortunate consequence that must be confronted in order to restore
academic integrity.

There is insufficient evidence to support any criminal charges against Dr. Durbin at this
time. If you later receive evidence of criminal intent please provide that to me immediately and I
will revisit my decision.

Thank you again for your thorough investigation.

Duffie Stone