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;, <br />City of North Olmsted <br />Citv Council Meetine <br /> <br />Michael Ubaldi <br />March 22, 2011 <br /> Page 145 Page 147 <br />i follow the advice of the law department, i So what's important is that the notice <br />z it's that coupled with what he tried to do 2 comes from the safety director, the <br />3 on March 2nd because he knew he was under 3 appointing authority, as to is there <br />4 the gun to get that posting done. And that 4 actually a vacancy to fill. <br />s he then attempted to post it himself even s So if you follow that logic, <br />s though he had never done it before, and he s that's why it's important to get that <br />~ knew that Ms. Eccleston wouldn't do it. It 7 notice from the appointing authority based <br />a was that combination of where he's acting s on reasonable legislation you just passed. <br />s outside the scope of what he's empowered to s And so while the chiefs would be a little <br />io do that's important in this case, and I io bit different, because you would always <br />ii would just remind you of that. ari have to have a chief, okay. But for the <br />iz At some point Mr. Carson made the iz other positions, if you look at that <br />is statement that as he went through the, you >.s ordinance, that's not necessarily true <br />is know, whether it was required to have 1r4 because of that "up to" language that's <br />ars notice before they set that test date, is contained in that ordinance. So that's an <br />i6 again, I would refer you to the legal i6 important distinction to make. And it's <br />i7 opinion of your law director. I think it's i~ mentioned in Mr. Gareau's opinion as to why , <br />ie well written and concise and carries the ie it's important and why that's in the Civil <br />i9 right conclusion. i9 Service rules. ~ <br />20 And I would point this out to you, zo Mr. Carson had you believe that if ~ <br />zi and it's related in his memo even though 21 you follow these Latin terms and everything <br />zz this doesn't really relate to the position 22 else, if you look at that section of rules, <br />2s of police chief, and Mr. Carson kept saying z3 it's pretty plain to me that the triggering <br />z4 it doesn't make sense, why can't we just z4 event is, it says whenever a vacancy <br />zs create the list and, you know, if there's zs occurs. It's pretty plain, straightforward <br /> Page 146 Page 148 <br />' <br />i an opening, then we've got the list ready a, to me. There's no ambiguity to that. And <br />z to go. It doesn't make sense to allow us z it's not reading other sentences together <br />s to do it. I think he said that like five s with that that allows them to create lists. <br />4 times. And so here's why it does make 4 The triggering event as it was related by <br />s sense that you do follow the procedure 5 Mr. Gareau and Mr. O'Malley on the night in <br />6 that's spelled out in the Civil Service 6 question back on February 28th, it's when <br />7 rules, which I would point out to you is 7 the vacancy occurs. <br />a rule number eight, Roman numeral eight on a But what's important in this case <br />s page 15 of Exhibit 1. s is that not only did Mr. Ubaldi be advised <br />io This council enacted a new io and he went forward anyway, it's then his <br />ii ordinance last year, ordinance number ii attempts to try and follow up on that to <br />iz 2010.66. That was relating to the lz post it himself. And I would assert, as I <br />is reorganization of the safety department, ars related earlier, that it was in his mind <br />i4 and it included "up to" language for i4 from the beginning that he was going down a <br />>.5 various positions in the police department. i5 certain road and that there was no one who <br />i6 And the reason that's important is that, i6 was going to change his mind on how he <br />i7 let's take the position of sergeant as an i~ thought the Commission should proceed. And <br />is example. >.a that he went down that road and wasn't i <br /> <br />i9 <br />Based on the new ordinance, <br />i9 t <br />going to let anybody change that. <br />20 there's no requirement at this point that zo And so I would assert, and again, <br />21 you're then going to have a set amount of zi I believe Mr. Gareau is going to give you <br />22 sergeants. The safety director can z2 definitions and I do have them this time, I <br />23 recommend to the Civil Service, you know z3 found them, misfeasance again is the <br />z4 what, we're going to maybe keep the same za improper doing of an act which a person <br />z5 number of sergeants and not replace that. 25 might lawfully do. Malfeasance is the <br />Mehler & Hagestrom (37) Page 145 -Page 148 <br />800.822.0650 <br />,.,.~..._.R_, _ ,..~,~, <br />