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Howard Releases Exhibits for County Commission Termination Hearing of Health Officer Hambley

Sarah Riley Howard, workplace law attorney and shareholder of Pinsky Smith PC law firm, today released exhibits supporting Ottawa County Health Officer Adeline Hambley’s case in Hambley’s scheduled termination hearing before the Ottawa County Commission.

The termination hearing, called by commission chair Joe Moss, is scheduled for Tuesday, October 24, at 8 a.m. (and October 25 at 8 a.m., if necessary, at the Ottawa County Fillmore Complex and will move forward unless the circuit court in Muskegon grants Hambley’s motion to enforce the preliminary injunction against the Ottawa County Commissioners seeking to fire her. Hambley’s motion asks the circuit court to delay the scheduled removal hearing until the judge can set ground rules that ensure due process. Hambley’s motion also asks the circuit court to confirm the required legal standard of removing Hambley only upon a finding of “just cause” supported by evidence.

The circuit court hearing is scheduled for Oct 23 at 3:30 before Muskegon County’s 14th Circuit Court Judge Jenny L. McNeill.

Included are 32 exhibits, viewable below, which will be presented at the October 24 removal hearing, providing documentary support for Hambley’s position that Moss’s charges are not true and are only a pretext for wanting to install their chosen political appointee, Nate Kelly. Six members of the commission voted to demote Hambley to “interim” Health Officer in their first meeting on January 3 and to appoint Kelly, an effort that the courts rejected.

The discovery process has not yet started in Hambley’s legal case in the circuit court. That process allows Hambley access to all written communications of commissioners, county employees, and other witnesses relevant to Hambley’s claims of retaliation and wrongful demotion, as well as deposition testimony under subpoena of witnesses with information.

Howard was required to turn over her client’s exhibits for the October 24 removal hearing to corporate counsel David Kallman Friday morning at 8 am. Kallman has not disclosed any further exhibits supporting the commissioners’ case, other than those attached to Moss’ original charges seeking to remove Health Officer Hambley.

Kallman also will not permit Hambley to call commissioners as witnesses. Howard, Hambley’s attorney, has protested this decision and is asking the circuit court to clarify that due process requires that Hambley have that opportunity.

Motions and Briefs

Motion Hambley Motion To Enforce PI And Stay Oct 24 Hrg 10 13 2023

Brief Hambley Motion To Enforce PI And Stay Oct 24 Hrg 10 13 2023

Hambley Reply To Motion For TRO And PI FINAL 10 22 2023

Answer To Plaintiff's Motion To Enforce PI And Stay, Hambley Final


Ex 1 Communications On Public Health Budget PS000001 PS000557

Ex 1A Guide To Emails Re Budget Process

Ex 2 2021.11.16 Joe Moss Campaign Video Quote

Ex 3 2021.12.06 Ottawa Impact Blog Post

Ex 4 2022.03.19 Ottawa Impact Fundraising Goal

Ex 5 2022.05.21 Unofficial Partial Transcript Of Campaign Video

Ex 6 2022.08.17 Rachel Atwood And Kristen Meghan Kelly Facebook Comments

Ex 7 2022.09.19 Moss Email To Hambley

Ex 8 2023 Comms By Commissioners Against Health Officer

Ex 9 2023.01 Ottawa Impact January 2023 Review

Ex 10 2023.01.19 The Epoch Times Conservative GOP Reformers Have 'Wokeness' On Run In A Michigan County

Ex 11 2023.03.31 Transcript Hearing Muskegon Cir Court Hambley V Ottawa Co Et Al

Ex 12 2023.05.23 Press Contact Policy Emails

Ex 13 2023.06.07 Unofficial Transcript Of Joe Moss On J Barclay Show

Ex 14 2023.09.15 Fox 17 Story Facing Budget Cuts, Ottawa Health Officials & Planned Parenthood Explore Options

Ex 15 2023.09.15 The Detroit News Article

Ex 16 2023.09.26 FOIA Request 2023 008804816

Ex 17 2023.09.26 FOIA Response 2023 008804816

Ex 18 2023.09.28 J Moss On Justin Barclay Unofficial Transcript

Ex 19 2023.10.09 Hambley To Commissioner Curran Budget Email

Ex 20 Around 2023.09.15 Right To Life Comms Re Potential Budget Cuts To Family Planning

Ex 21 Commissioner Zylstra Social Media Posts

Ex 22 Description Of 8 2 2022 Primary Election Night Video Rachel Atwood And KM Kelly

Ex 23 Excerpt From Ottawa Impact January 2023 Review

Ex 24 Ottawa Impact Campaign 2022 Material Screenshot 2023 10 05 At 10.33.00 AM

Ex 25 Ottawa Impact Story 2022 (1)

Ex 26 Undated Statements Joe Moss Re Unaccountable Individual Administrator

Ex 27 06.20.23 Unofficial Transcript Of BOC HHS Mtg Commissioner Miedema Statement

Ex 28 08.18.2023 Fiscal Teams Chats

Ex. 29 Texts With Nina Baranowski 08.26.23 9.12.23

Ex. 30 Texts With Nina Baranowski And Marcia Mansaray 08.29.23

Ex. 31 Marcia Mansaray And Nina Baranowski Teams Chat Re Budget FY24

Ex. 32 Unofficial Transcript Of 08.02.22 Primary Election Night Videos Rachel Atwood

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