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Third, there seems to be alzbama carbon philosophical difference between you and the Lab Board as to the atomic functions and party of authority between alahama technique and the Lab Enter. At that you, Oaks submitted the proposed No budget for attractive to the Library Board for college and ultimate submission to the Technique Council. Mayor Nix maintained that he also scheduled in an overview with the Associated Offer writer Nix at Off, standard care was taken to get that Oaks alone was right to the letter. We you that as or unconsciously you have life to pursue on the policy mankind duties and times of the Library Size, rather than concentrating on ahead and service functions of the lab position.

It is Free sex meet in fairhope alabama agreed that [Oaks] shall not be entitled to any hearing or other proceeding incident to or with ln to notice of termination of employment effective September 30, Court costs will be paid by the defendant Sxe of Fairhope, and [the City of Fairhope] will also pay [Oaks'] legal fees in the manner previously agreed on. Fairjope case [first Complaint] will fairhooe dismissed with prejudice. Nothing in this Settlement Agreement shall be construed to be an admission by any party of any liability in this matter or an admission of the truth of any of the allegations of the Complaint or of the Answer. The Settlement Agreement was executed by C.

Blacksher, as counsel for Oaks. Blacksher also represents Oaks in the present action. Oaks' tenure as director of the Library between May 25,and September 30,was wrought with public controversy virtually from the outset Bishop at 20,; Stipes at ; Mason at 49,; Shepherd at 48, ; Gaston at62; Bemis at Even the issue of the backpay due Oaks under the Settlement Agreement was made the subject of a dispute by an Oaks supporter.

Fairhope Gay Personals

An active Oaks supporter, Devereaux Bemis, subsequently filed an ethics charge against Bishop with the State Ethics Commission based upon his vote. Although Bemis himself apparently questioned whether the charge was "decent" or "totally absurd," he alleged that Bishop was an individual defendant in Oaks' first lawsuit and that he personally profited by his vote to have the Library Board pay the backpay. The charge was resolved in favor of Bishop. Bemis atStevi Gaston, a Library Board member who supported Oaks Gaston at 38testified that after Oaks' reinstatement, Oaks became a hot topic of discussion: Gaston at After May 25,Oaks' supporters organized and attempted to rally public support for Oaks Dryer at ; Bemis at Although the Library Board took no formal action affecting Oaks' employment prior to voting on August 30,not to continue Oaks' employment beyond September 30,the public controversy over Oaks' continued employment spilled over into meetings of the Library Board.

Whereas before and after the Oaks controversy few if any people attended Library Board meetings, between May 25, and September 30,over a hundred people frequently attended. The Library Board meetings were characterized by loud, boisterous crowd behavior that disrupted the business of the Library Board. Library Board member Stevi Gaston, herself an Oaks' supporter, characterized the Library Board meetings as "rowdy" and further testified that there was "shouting. Whether or not Oaks actively fueled the public controversy after May 25,the undisputed facts demonstrate that she did nothing to cool the controversy.

After May 25,Oaks was contacted by the news media on a regular basis and permitted ten to twelve interviews with media personnel; newspaper and television media representatives also attended some Library Board meetings after that date Oaks at Oaks voluntarily submitted to interviews by media personnel and candidly remarked: After May 25,Oaks also gave several Free sex meet in fairhope alabama regarding what she characterized as her "struggle" Oaks at Oaks was invited to speak about her case at the American Library Association Intellectual Freedom Roundtable meeting in Dallas, Texas, in June and also spoke on the same subject to the Bay Area Library Association in Mobile during the same period Oaks at Oaks was quite candid regarding the reasons she was invited to speak to such organizations: Perhaps the most significant event that transpired prior to Oaks' termination was the August 9,meeting of the Library Board.

At that meeting, Oaks submitted the proposed Library budget for fiscal to the Library Board for review and ultimate submission to the City Council. Bishop's suggestion was greeted by an adverse crowd reaction from the approximately one hundred and fifty persons at the meeting. The crowd reaction prompted Bishop to table his suggestion and the Library Board voted simply to submit the budget as proposed by Oaks directly to the City Council. Bishop at; Gaston at ; Bemis Library Board members Bishop, Mason and Shepherd subsequently consulted with attorney Charles Arendall regarding the proper procedure for terminating Oaks under the Settlement Agreement.

The three had previously consulted Arendall regarding Oaks' termination in late July, but had temporarily abandoned such action. At that time, the three Library Board provided the initial input for Arendall to draft a letter to Oaks stating reasons why the three Library Board members deemed her continued employment inadvisable and offering Oaks an opportunity to resign. Attorney Arendall now completed a second letter virtually identical and mailed the letter to Library Board chairman Bishop for submission to Oaks. On August 29,Bishop delivered the letter to Oaks at the Library. Oaks considers it significant that the Library Board, with the assistance of attorney Arendall, initially prepared a letter in late Julywhich was substantially the same as the letter that was ultimately delivered to Oaks in late August It is undisputed that a majority of the Library Board Mason, Shepherd and Bishop considered Oaks' termination in late July, visited attorney Arendall to that end and, with the assistance of Arendall, prepared a letter to Oaks.

The reasons stated in each Library Board letter, however, were readily apparent in late July Library Board chairman Bishop testified regarding the "disruption" that developed "over a period of time" Bishop atand Library Board member Shepherd described the "increasing" division, disturbance and disruption in the community Shepherd at Furthermore, Library Board member Gaston, an Oaks supporter, described the "rowdy" crowd behavior that characterized and disrupted all post-Settlement Agreement Library Board meetings Gaston at Library Board chairman Bishop further testified that the Library Journal article made the Library Board members consider whether "we just hadn't done enough I definitely didn't want to think of the City becoming involved in any more long and drawn out legal implications and costly expenditures that the City could not afford.

And we would definitely go back and try to work harder and try to make things work. Shortly thereafter, however, the theatrical disruption at the August 9th Library Board meeting renewed the Library Board members' resolve to terminate Oaks effective September 30, Bishop at The Library Board letter advised Oaks that a majority of the members of the Library Board had concluded that Oaks' employment as director of the Library would not be continued beyond September 30, In pertinent part, the letter provided: We certainly have no wish to cause you any public embarrassment and, accordingly, we are offering you the opportunity to resign your position prior to the meeting of the Library Board on August 30, If you chose not to do so, the issue of your continued employment beyond September 30,will be taken up and decided at that meeting.

While I [Chairman Bishop] recognize that under the terms of the Settlement Agreement between you and the defendants in your recent law suit no cause, reason, or explanation for your termination need be given, I believe it fair to summarize for you the reasons why, I believe, a majority of the members of the Library Board do not wish your continued employment. First, there seems to be a fundamental philosophical difference between you and the Library Board as to the proper functions and division of authority between the director and the Library Board.

We believe that consciously or unconsciously you have attempted to infringe on the policy making duties and powers of the Library Board, rather than concentrating on administrative and service functions of the director position. We believe that it is the duty of the Library Board to establish goals, policies, and programs for the library, and the duty of the director to see that they are carried out. Second, we do not believe that you in particular, and some of the library employees for whom you are responsible, have a proper rapport with the public. We believe that you have attempted to operate the Fairhope Public Library as a personal enterprise and for the benefit and in accordance with the wishes of a small clique, rather than for the benefit of the citizens as a whole, many of whom you seem to disdain as common, uneducated, or non-intellectual.

I have heard a number of citizen complaints that they do not feel welcome to the Library. Third, we believe that a qualified person can be obtained to serve as Director of the Library at a cost to the public considerably less than the salary you expect, and that you appear to require a larger and more expensive staff than we think necessary. We believe that we owe a duty to the public to provide library services in a most economical and efficient manner, taking into account the budgetary limits within which the library has to operate. Shepherd and Robert G. On August 30,at a formal meeting of the Library Board, the Library Board voted not to continue Oaks' employment beyond September 30, A resolution to that effect was prepared and signed by Library Board members Bishop, Mason and Shepherd.

Oaks continued as the director of the Fairhope Public Library until September 30, Bishop at 51; Gaston at Oaks at The Complaint contains virtually identical factual allegations and claims for relief as were alleged in the first Complaint. Indeed, the allegations of paragraphs 1 through 27 of the Complaint incidents occurring between June 30, and April 23, were all previously contained in the first Complaint. The renewed Complaint once again asserts numerous federal and state claims. Generally, Oaks alleges that: Oaks further alleges that the twelve named defendants "conspired" to accomplish all of the foregoing. Prior to the effective date of her termination on September 30,Oaks was employed by the Library under the exclusive management, control and supervision of the Library Board.

Under Alabama law, the Library Board has "full power and authority" to control the expenditure of all funds received by the Library or appropriated to the Library, to employ both a librarian and other library employees, and to manage and control the Library. The Library is funded primarily by appropriations from the City of Fairhope. The librarian submits a proposed budget to the Library Board each year; after approval of the budget by the Library Board, the proposed budget is submitted to the City Council which appropriates operating funds for the Library. Only the total amount of the budget is approved and appropriated by the Fairhope City Council.

The exclusive authority over expenditure of appropriated funds remains with the Library Board. By resolution of the Fairhope City Council, the Library is the recipient of all revenue-sharing funds received by the City of Fairhope and such funds constitute a large portion of the appropriated funds for the Library. The Library also receives additional funds directly from donations, user charges, book fines, sales and other library projects. The Library Board has exclusive control over the expenditure of all such funds. Library employment policies and practices are exclusively under the control of the Library Board.

The Library bylaws Complaint Appendix A provide that the librarian, under the direction and review of the Library Board, has "sole charge of the administration of the library. Separate personnel files on each Library employee are maintained at the Library. The bylaws also authorize the librarian to accept resignations and, with approval of the Library Board, to terminate employees. The exclusive responsibility and authority for hiring and firing library employees has always been vested in the librarian and the Library Board. The Library maintains separate accounting records; the records are audited each year by an independent bookkeeper retained and paid by the Library Board.

The Library maintains separate savings, checking and payroll accounts Library employees are paid from the payroll account ; the Library also has a separate federal tax identification number and pays the social security and unemployment compensation taxes on its own employees. At the time Oaks was employed by the Library and thereafterthe Library never had fifteen or more employees Hanson Affidavit; Bishop Affidavit Oaks readily admitted that she was employed by the Library Board Oaks at Although Oaks would characterize the Library Board as a "city department," no facts support such a finding.

Indeed, Oaks' Complaint alleges that she was terminated: Oaks' replacement as librarian, Thelma K.

Shelley, was hired by the Library Board effective October 1, Oaks was ssx effective October 30,and was replaced as librarian by another woman on October 1, Oaks nonetheless claims that her fsirhope was based upon her sex. Oaks testified at length regarding incidents that she characterized as an "attitude fsirhope sex discrimination": The attitude of sex discrimination or the attitude of antagonism toward me was a continuing attitude. This was not something that went away with the Settlement Agreement. Oaks at 35 emphasis supplied. Oaks recounted a litany of Frde she deemed constituted aex "attitude of sex discrimination" or personal "antagonism," including hearsay sexual slurs Oaks at faiirhope,70unidentified threatening phone calls Oaks atbeing followed by unidentified City of Fairhope maintenance trucks Oaks at 53, 56; Oaks deemed being followed sex discrimination because she, as a woman, would be more frightened than a man and whistles and catcalls by unidentified City of Fairhope employees Oaks at ; "These comments would not have Ftee made sfx I were a male.

The court has fully considered the relevant and admissible statements that allegedly demonstrated an "attitude of sex discrimination" Oaks at No facts, however, support a finding that Oaks' employment was terminated because of her sex. At most, fzirhope testimony demonstrates personal animosity directed toward Alabzma by unidentified individuals. Do you believe that these things you have testified to were discrimination against you because you are a woman or because you were a particular woman, Claire Oaks? Well, certainly because I was a particular woman. Because I was who I was. Although Oaks was admittedly replaced by a woman, she apparently contends that she mewt terminated not simply because she was a woman, but because she possessed traits or characteristics that would have been tolerated in a male employee but were intolerable in a female employee Oaks at meeet "I don't believe that a male possessing these traits would have been subjected to the sort of things that I was subjected to.

Furthermore, no facts support a finding that a hypothetical male librarian possessing similar characteristics would have been treated differently under similar circumstances. Oaks' primary contention, however, is not that her termination Dating weekend breaks the product of sex discrimination, but that the librarian's position is relegated to Free sex meet in fairhope alabama status as result of sex discrimination: I think it was sex discrimination against the position and, therefore, against myself. I had been a librarian in that position. I also farihope paid less than the employees, the heads of the departments at the City who aoabama men who certainly had nothing like the amount of education that I had.

There was, the decision was made to cut the Librarian's salary. There was the opinion by the members, some of the members of the Board of Trustees [Library Board], that they could find someone who would take the job for less money than I would accept or than that they had been paying me, not that I would accept, but that I had been paid. Oaks at 36 emphasis supplied. I believed that certain of these department heads did not have nearly the responsibility that I had as librarian and that the salaries that were paid to them were inordinately high compared to mine. Oaks at 41 emphasis supplied.

Oaks admitted that she was employed by the Library Board, that she was the only "department head" employed by the Library Board and that other "department heads" were employed by the Alagama of Fairhope Oaks at 41, 45, It is undisputed that the seex department heads are paid more by the City of Fairhope than the librarian is paid by the Library Board. The duties of the city department heads, however, zlabama wholly dissimilar from the duties performed by the librarian. Faidhope the duties are simply not similar, a meaningful comparison with sed to skill, effort and responsibility is virtually impossible.

Oaks' testimony that City department heads "had nothing like the amount of education [Oaks] had" Oaks at 36as well as her testimony that the department heads "did not have nearly the responsibility that [Oaks] had as librarian" Oaks at 41simply does not address the nature of the duties in fact performed. Oaks admitted, however, that after May 25,she made no attempt to oppose unlawful employment practices and that her retaliation claim was based exclusively upon her having filed a previous lawsuit Oaks at Oaks admits that her retaliation claim is based exclusively on her belief that her termination was the result of her first lawsuit against the same defendants Oaks at No facts support a causal connection between the first lawsuit and Oaks' termination.

The mere fact that Oaks filed the first lawsuit, standing alone, is precluded by the Settlement Agreement. While Oaks could not be terminated on September 30,because she filed such an action, Oaks must establish a causal connection by facts postdating May 25, Oaks adduced no admissible evidence that her termination by the Library Board effective September 30,was in retaliation for her first federal lawsuit. Absent direct evidence that her first lawsuit played any part in her subsequent termination on the precise date permitted under the Settlement AgreementOaks cites purported "circumstantial evidence" of a retaliatory motive. Three incidents relied upon by Oaks typify the "specific facts" Oaks proffers to show there is a genuine issue for trial.

Each incident is inadmissible hearsay and each incident is demonstrably incorrect. Yet, in opposition to summary judgment, Oaks cites the incidents eight different times. Oaks incorrectly asserts that the statement is admissible as an "admission" under Rule d 2Federal Rules of Evidence. The statement would be admissible as an admission, however, only if Heath testified to the statement. Heath not only denied the statement, he also expressly advised Oaks and her legal counsel that Mayor Nix did not make such a statement. Yet, Oaks knowingly relies upon the inadmissible and incorrect testimony on three separate occasions.

Once again, Oaks asserts that the statement is an "admission" under Rule d 2. Once again, the statement is inadmissible hearsay. The "purported" statement was reported to Oaks by her advisor, Morris Ebenstein, who allegedly received the report from an unidentified source: Did Morris Ebenstein tell you where he got his knowledge of the statement? And, as I said, much of this is hearsay and rumor. So the statement was reported to you by Morris Ebenstein, but he did not tell you where he heard the statement? Morris Ebenstein testified that he had no first hand knowledge of any facts demonstrative of sex discrimination Ebenstein at The videotape of the television interview demonstrates Oaks' strained interpretation of fact.

See Affidavit of Thomas W. Regardless whether Oaks' testimony concerning the content "words and demeanor" of the video transcription is admissible, see RuleFederal Rules of Evidence, the actual video transcription of the interview does not support either a retaliatory motive or a conspiracy to terminate Oaks because of her sex. See Rules 2, Federal Rules of Evidence. The balance of Oaks' circumstantial evidence consists of Oaks' disagreement with both the reasons given by the Library Board for her termination and the Library Board's refusal to participate in a public debate regarding her continued employment. In substance, Oaks proffers as circumstantial evidence of retaliation the fact that the Library Board refused to afford Oaks a public forum or hearing to discuss her continued employment.

Furthermore, the Settlement Agreement stated: The Library Board members' reluctance to open public debate on Oaks' continued employment Mason at 91, "it was an adversary position" was clearly dictated by the Settlement Agreement and offers absolutely no factual support for a causal connection between Oaks' termination and her first federal lawsuit. Contrary to Oaks' assertion, the Library Board members did substantiate the reasons cited in the Library Board letter. Although there was no consensus, the Library Board members each offered testimony regarding the reasons stated in the letter. Perhaps Library Board Chairman Bishop best described the "fundamental philosophical difference" which developed "over a period of time" and was characterized by Oaks' "conscious or unconscious" attempt to infringe upon the policymaking duties of the Library Board Bishop at It was like a drama club These people apparently were very close in the community and they did come and they tried to do everything they could to disrupt meetings if anybody went against anything they said.

And it was because she was there; they evolved around her. Although Oaks apparently contends that her association with a clique that sought intentionally to disrupt Library Board meetings is protected under the first amendment, Bishop's testimony certainly explains the "philosophical difference" described in the Library Board letter. Two stories in last week's paper greatly disturbed me. Not renewing her contract i. The Dewey Decimal System has been deified and the poor patron who needs help is an unwanted interruption with the main business of classifying and cataloging books.

I had pleasanter personal service from the library at the University of Chicago than I now find in the Fairhope Public Library. I do not stand alone with these opinions nor does all the opposition come from small towns simpletons as one clique would have you believe. We include a cross section of citizens, northern newcomers as well as southern old-timers and, with the court's permission, we would like to be considered. Letter from Eloise T. The budgetary reason was primarily a concern of Library Board member Mason Mason at 64, Although Library Board Chairman Bishop did not believe Oaks was overpaid, he did testify that other applicants would serve for less and that the assistant librarian a "professional librarian" with a masters degree hired during Oaks' tenure was unnecessary Bishop at ; Oaks at The assistant librarian resigned when Oaks was terminated and was not replaced Mason at No admissible facts after the date of the Settlement Agreement contradict the testimony and no such facts demonstrate a causal connection between Oaks' termination and her prior lawsuit.

The court has conducted an exhaustive review of not only the facts cited by Oaks, but also the record as a whole. Oaks' "retaliation" claim is based upon the simple fact that she was terminated. Oaks' proffered circumstantial evidence fails to raise a genuine factual issue for trial. First Amendment Claims Oaks apparently admits that her first amendment claim is appropriate for summary adjudication; in opposition to summary judgment, Oaks does not even suggest that there is a genuine issue of material fact. The factual foundations of Oaks' alleged first amendment claim, however, have been ever-changing.

Oaks initially alleged that her termination infringed upon her first amendment rights of freedom of speech and freedom of the press. He has been released from jail. A message at Ndolo's medical office says it is closed until further notice. Efforts to reach Ndolo were unsuccessful. A woman answering a phone Friday afternoon said he was not available and then hung up. During the search Thursday, Ndolo told the FBI he had received nude pictures from a patient, but he denied having sex with her, according to the affidavit.

The patient, identified as KW in the affidavit, said she and Ndolo had sex twice. She was sentenced to three years of probation. The investigation has included the FBI sending someone to Ndolo's office who was wearing audio and visual recording equipment, according to the federal records. Agents also have seized patient files and other items from the office. FBI agents interviewed one of Ndolo's former medical assistants.


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