On March 28, 2013 a
TRIAL MATERIALS FILED EXCHANGE OF DEFENDANTS JOHN BECKNER AND MONTGOMERY COUNTY BOARD OF COMMISSIONERS FILED BY TODD AHEARN
was filed
involving a dispute between
Harley Shepherd,
and
John Beckner,
Montgomery County Board Of Commissioners,
Montgomery County Dept Environmental Services,
for JOHN BECKNER
in the District Court of Montgomery County.
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ELECTRONICALLY FILED
COURT OF COMMON PLEAS
Thursday, July 24, 2014 3:23:18 PM
CASE NUMBER: 2013 CV 01972 Docket ID: 19296128
GREGORY A BRUSH
CLERK OF COURTS MONTGOMERY COUNTY OHIO
IN THE COMMON PLEAS COURT OF MONTGOMERY COUNTY, OHIO
CIVIL DIVISION
HARLEY SHEPHERD : CASE NO. 2013 CV 01972
Plaintiff, : JUDGE DENNIS J. ADKINS
vs. :
TRIAL MATERIALS EXCHANGE
MONTGOMERY COUNTY BOARD OF : OF DEFENDANTS, JOHN
COUNTY COMMISSIONERS, et al., BECKNER AND MONTGOMERY
: COUNTY BOARD OF
Defendants. COMMISSIONERS
______________________________________________________________
Pursuant to the Final Pretrial Order filed herein on February 6, 2014 and Mont.
Co. C. P. R. 2.01 IV(A)(b)(5), the Defendants herein, the Montgomery County Board of
Commissioners and John Beckner, hereby submit their Trial Materials Exchange.
1. Montgomery County Public Works Department “Work Rules” [selected
pages] effective December 14, 1998;
2. Memorandum from Jack Gearing dated June 17, 2005, with receipt;
3. Memorandum from Dave Ricks dated October 5, 2006;
4. Memorandum from Steven Schulze dated January 4, 2011;
5. Montgomery County Environmental Services “Work Rules” [selected
pages] revised January 1, 2011;
6. Memorandum from Pat Turnbull dated December 8, 2011;
7. Letter received by Montgomery County Board of Commissioners dated
August 1, 2011;
8. Meeting Agenda for meeting held September 28, 2011;
9. Video narrative for several dates between December 23, 2011 and
January 4, 2012;
10. Letter received by Montgomery County Board of Commissioners dated
April 10, 2012;
11. Letter from Stephanie Echols dated April 11, 2012;
12. Collective Bargaining Agreement between Montgomery County and
American Federation of State, County and Municipal Employees 2010-
2012;
13. Video from 12/24/2011 titled
DVR-20111223_205528-20111223_210622.re4;
14. Video from 01/03/2012 titled
DVR-20120102_171838-20120102_172254.re4;
15. Video from 01/05/2014 titled
DVR-20120104_152902-20120104_153218.re4.
Respectfully submitted,
MATHIAS H. HECK, JR.
PROSECUTING ATTORNEY
By:s/Todd M. Ahearn
Todd M. Ahearn, #0069674
Assistant Prosecuting Attorney
301 West Third Street
P.O. Box 972
Dayton, Ohio 45422
Phone: (937) 496-6870
Fax: (937) 225-4822
Email: ahearnt@mcohio.org
Attorney for Montgomery County Board
of Commissioners and John Beckner
and
2
MATHIAS H. HECK, JR.
PROSECUTING ATTORNEY
By: s/Jonathan A. Ketter
Jonathan A. Ketter, #0084064
Assistant Prosecuting Attorney
301 West Third Street
P.O. Box 972
Dayton, Ohio 45422
Phone: (937) 225-3499
Fax: (937) 225-4822
Email: ketterj@mcohio.org
Attorney for Montgomery County Board
of Commissioners and John Beckner
CERTIFICATE OF SERVICE
I hereby certify that on July 24, 2014, the foregoing document was served on all
parties or their counsel of record through the Montgomery County Electronic Filing
System, if they are registered users or, if they are not, by placing a true and correct
copy in the United States mail, postage prepaid, to their address of record.
s/Todd M. Ahearn
Todd M. Ahearn, #0069674
Assistant Prosecuting Attorney
3
Document Filed Date
July 24, 2014
Case Filing Date
March 28, 2013
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ELECTRONICALLY FILED COURT OF COMMON PLEAS Thursday, July 24, 2014 3:23:18 PM CASE NUMBER: 2013 CV 01972 Docket ID: 19296128 GREGORY A BRUSH CLERK OF COURTS MONTGOMERY COUNTY OHIO IN THE COMMON PLEAS COURT OF MONTGOMERY COUNTY, OHIO CIVIL DIVISION HARLEY SHEPHERD : CASE NO. 2013 CV 01972 Plaintiff, : JUDGE DENNIS J. ADKINS vs. : TRIAL MATERIALS EXCHANGE MONTGOMERY COUNTY BOARD OF : OF DEFENDANTS, JOHN COUNTY COMMISSIONERS, et al., BECKNER AND MONTGOMERY : COUNTY BOARD OF Defendants. COMMISSIONERS ______________________________________________________________ Pursuant to the Final Pretrial Order filed herein on February 6, 2014 and Mont. Co. C. P. R. 2.01 IV(A)(b)(5), the Defendants herein, the Montgomery County Board of Commissioners and John Beckner, hereby submit their Trial Materials Exchange. 1. Montgomery County Public Works Department “Work Rules” [selected pages] effective December 14, 1998; 2. Memorandum from Jack Gearing dated June 17, 2005, with receipt; 3. Memorandum from Dave Ricks dated October 5, 2006; 4. Memorandum from Steven Schulze dated January 4, 2011; 5. Montgomery County Environmental Services “Work Rules” [selected pages] revised January 1, 2011; 6. Memorandum from Pat Turnbull dated December 8, 2011; 7. Letter received by Montgomery County Board of Commissioners dated August 1, 2011; 8. Meeting Agenda for meeting held September 28, 2011; 9. Video narrative for several dates between December 23, 2011 and January 4, 2012; 10. Letter received by Montgomery County Board of Commissioners dated April 10, 2012; 11. Letter from Stephanie Echols dated April 11, 2012; 12. Collective Bargaining Agreement between Montgomery County and American Federation of State, County and Municipal Employees 2010- 2012; 13. Video from 12/24/2011 titled DVR-20111223_205528-20111223_210622.re4; 14. Video from 01/03/2012 titled DVR-20120102_171838-20120102_172254.re4; 15. Video from 01/05/2014 titled DVR-20120104_152902-20120104_153218.re4. Respectfully submitted, MATHIAS H. HECK, JR. PROSECUTING ATTORNEY By:s/Todd M. Ahearn Todd M. Ahearn, #0069674 Assistant Prosecuting Attorney 301 West Third Street P.O. Box 972 Dayton, Ohio 45422 Phone: (937) 496-6870 Fax: (937) 225-4822 Email: ahearnt@mcohio.org Attorney for Montgomery County Board of Commissioners and John Beckner and 2 MATHIAS H. HECK, JR. PROSECUTING ATTORNEY By: s/Jonathan A. Ketter Jonathan A. Ketter, #0084064 Assistant Prosecuting Attorney 301 West Third Street P.O. Box 972 Dayton, Ohio 45422 Phone: (937) 225-3499 Fax: (937) 225-4822 Email: ketterj@mcohio.org Attorney for Montgomery County Board of Commissioners and John Beckner CERTIFICATE OF SERVICE I hereby certify that on July 24, 2014, the foregoing document was served on all parties or their counsel of record through the Montgomery County Electronic Filing System, if they are registered users or, if they are not, by placing a true and correct copy in the United States mail, postage prepaid, to their address of record. s/Todd M. Ahearn Todd M. Ahearn, #0069674 Assistant Prosecuting Attorney 3