Others wrote the Court of my integrity, and that I take obligations seriously, describing me as a caring
<br />person within the community. They said I act based on rules, integrity and ability to put others before
<br />myself, and am not afraid to speak up when an injustice or persons rights are being infringed upon.
<br />No testimony was given connecting my conduct or presence to a delay of Commission business, or
<br />hampering its ability to fulfill its function as measured by statute standards. Testimony of Jonathon
<br />Thomas, Jerry Peterson, and Brandon Clawson — all Commission members, with whom I serve, all
<br />testified that I treat them with respect. No testimony was given that I abuse or disrupt the meeting
<br />process and procedures.
<br />The online video recording of the May 21, 2019, Charter Commission meeting shows that I conduct
<br />myself professionally, keeping comments to the topic of discussion, asking for clarity, properly making
<br />motions, following the decisions of the Commission, while not scandalizing other members or
<br />resorting to personal attacks. The added agenda items on May 21, 2019 caused contention because, as
<br />I argued to the Court in my Answer, the City Staff were directing the Chair to expand the chair
<br />authority and change Commission Bylaw specified duties and procedures without regard to the
<br />Commission previous decisions on agenda format and minutes recording. I had attempted for over 30
<br />days to resolve this with the Chair and Mr. Zikmund with only deadlocked differing opinion, thus the
<br />Commission was needed to finally decide. The audio recording of the City Council meeting of June 18,
<br />2019 (Answer Amendment, Attachment 3), depicts my professional conduct, willingness to discuss a
<br />difference of opinion, willingness to listen openly to other's opinions and not use strong language when
<br />confronted by the other party, and my ability to focus on the topic. During that June 18 meeting,
<br />Council Members scolded me, stating that I did not show courtesy to the chair by bringing a printed
<br />proposed agenda. In my opinion, this would have been quite presumptuous of me. The online video
<br />recording of the Charter Commission meeting of January 29, 2019, (last meeting I chaired) — depicts
<br />my professional manner in conducting meetings, willingness and desire to move from chair position,
<br />and promote newer members to leadership positions. This meeting was more typical of Commission
<br />meetings.
<br />Lastly, while elected officials may be removed from office for malfeasance or nonfeasance, clearly
<br />these are not the Plaintiff's accusation and therefore do not apply in this case as reason for removal.
<br />Conclusion
<br />Your Honor. This case is about a City trying to exercise its control over a separate autonomous body,
<br />in this case the Mounds View Charter Commission, by attempting to remove a member (me) from his
<br />appointment without just cause. The case brought against me was frankly shocking, slanderous, biased
<br />and completely without merit. In fact, I contend that I have done nothing wrong. The Plaintiff failed to
<br />present any valid or reasonable grounds, as per your instructions, to support their claim that the
<br />Commission is not able to effectively function with me on the Commission. Actually, the Commission
<br />functions just fine, and is fulfilling its statutory required function. They further attempted to muddy the
<br />waters, by bringing in many tangential issues, such as quorum, turnover and full complement of the
<br />Commission, which are arguably irrelevant to the original charge made against me. As stated in
<br />evidence, the City acknowledges that they would like to "change" the Commission, and simply sees me
<br />as a barrier.
<br />The Plaintiff failed to present evidence that linked my behavior or conduct to any purported
<br />Commission ineffectiveness or inactivity. Many accusations were tossed about throughout this case,
<br />Case File: 62-CV 19-4965 Page 10 of 11
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