RESPONDENT RESPONSE TO MOTION FOR LIMITING THE ISSUES OF FACTS ON THE HEARING
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STATE OF FLORIDA
DIVISION OF ADMINISTRATIVE HEARINGS
CITY OF CLEARWATER,
Petitioner,
vs.
CASE NO. 89-3063
ROGER BRENNAN,
Respondent.
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CITY'S RESPONSE TO MOTION FOR RESCHEDULING
OF ADMINISTRATIVE HEARING AND REQUEST TO ISSUE SUBPORNAS
1. This case involves a five day suspension of Roger Brennan.
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The basic charge is that he wrote a highly inappropriate memorandum dated March
30, 1989, all of which has been specified in the notice of suspension.
2. The City of Clearwater has no objection to a reasonably
three or four witnesses should be necessary.
4. It is obvious that Mr. Brennan does not realize that the City
will object to any witness other than one concerning the direct issues contained
in the Notice of Suspension.
5. The City of Clearwater requests that the issue for the hearing
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be limited to whether there was just cause for discipline and whether the penalty
was appropriate.
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day of
I HEREBY CERTIFY that a true copy hereof has been furnished this 7~
~ ,1989, to the following: Donald D. Conn, Hearing Officer;
Rita Garvey, Mayor of the City of Clearwater; William Nunamaker, Richard
Fitzgerald, Donald Winner and Lee Regulski, Commissioners of the City of
Clearwater; City Clerk for City of Clearwater; Ron H. Rabin, City Manager of the
City of Clearwater and Roger C. Brennan, 12 Southwind Drive, Belleair Bluffs,
Florida 34640.
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Mi }es A. Lance . ~
Assistant City Attorney
P. O. Box 4748
Clearwater, Florida 34618
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