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

Exhibits

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