Case 1:19-cv-00500-ECM-JTA Document 4-3 Filed 07/15/19 Page 1 of 8

EXHIBIT 3
Excerpts from Plaintiff's Personnel File

Ex. 3 at 001
 Case 1:19-cv-00500-ECM-JTA Document 4-3 Filed 07/15/19 Page 2 of 8

CITY CLERK'S CERTIFICATE

I, Tina Barnes. as City Clerk/Treasurer of the City of Abbeville, Alabarna,

herby certify that the attached pages constitute a true and correct copy of Noel
Vanlandingham's personnel file.

Witness my signature as said City Clerk/Treasurer, under the seal of the City
of Abbeville, Alabama, this the lOth day ofiuly. 2019.

Tina Barnes, As City Clerk/Treasurer of the

CITY OF ABBEVILLE, ALABAMA

Ex. 3 at 002
 Case 1:19-cv-00500-ECM-JTA Document 4-3 Filed 07/15/19 Page 3 of 8
101 East Washington Street
P O Box 427,Abbeville AL 36310-0427
City of:Abbeville Phone:334-585-6444 Fax 334-585-8982
Web: www.citvoiabbevale.orn

Mayor
Billy Helms May 15, 2019
bhelmsecilvofatbeville.ord

CITY COUNCIL
Terry Mums
District 1
Noel Vanlandingham
Brendt Murphy
Mayor Pro Tempore 1961 County Road 29
District 2 Abbeville, AL 36310
Dorothy L. Baker
District 3

Rena'Cosby Mr. Vanlandingham,

District 4

Harold Robison, Jr. This letter is regarding the meeting we had on May 13, 2019 wherein
District 5
l allowed you an opportunity to be heard regarding an audio recording of you
Clty Attorney
Spence Danzey being published on the intemet. After due consideration of your explanation
and version of the facts, l have decided to place this matter on the May 20,
Poke Chlef
Noel Vanlandingham 2019 city council meeting agenda and defer any punishment to the council.
You are welcome to attend that meeting along with your attomey and if any
City Clorkffreasurer
Tina B. Bames action is taken, you wiH be afforded full due process pursuant to the City of
Abbevilles Personnel Manual.

Sincerely,

Billy Helms
Mayor

66eviffe, Afa6anta — Tirs t in the Tration....)1(phaõeticatly1

- Ex. 3 at 003
 Case 1:19-cv-00500-ECM-JTA Document 4-3 Filed 07/15/19 Page 4 of 8
101 East Washington Street
P0Box 42/,Abbeville AL 363101427
City of:Abbeville Phomx 334-5851444 Fay 334-585-6982
Web: www.citvolabbealle.am

Mayor
Billy Helms May 21,2019
bhelmsecitvotabbeville.org

cny COUNCIL
Teny Albin
District 1
Noel Vanlandingham
Brandt Murphy
Mayor Pro Tempore
1961 County Road 29
District 2 Abbeville, AL 36310
Dorothy L Baker
District 3

Renal Cosby
Chief Vanlandingham,
District4

Harold Robison,Jr. Please take notice that a disciplinary hearing has been scheduled at
District5 City Hall in Abbeville on May 23, 2019 at 12:30 p.m. The basis of the hearing
CityAttorney is:
Spence Danny 1) You have shown conduct that is unbecoming as an employee,which
Police Olaf tends to bring discredit upon the City and affects the public respect
Noel VanlandIngham with your department that could otherwise threaten order and safety.
City Clark/Demurer 2) Violation of the Citys vehicle and driving policy by allowing a city
Tina B.Barnes employee to possess a city vehicle while on leave of absence.

At the hearing, you or your representative will be allowed to present an oral

or written statement in your defense.

Sincerely,

Billy Helms
Mayor

1166evirre, ACa6ama — Tirst in tfie Aration....lapfiafieticaayi

Ex. 3 at 004
 Case 1:19-cv-00500-ECM-JTA Document 4-3 Filed 07/15/19 Page 5 of 8

101 East Washington Street

P0Box 427,Abbeville AL 363104427
City offq6bevitTh Phone:334-585-6444 Fax 334-585-6982
Web: www.clivoiabbeville.org

Mayor
Billy Helms May 23, 2019
Pheirngitilvolabbevile.orn
CITY CouNcp.,
Teny
District 1
Noel Vanlanding ham
Brandt Murphy 1961 County Road 29
Mayor Pro Ternpore
District2 Abbeville, AL 36310
Dorothy L Baker
District3
Chief Vanlandingham,
Rena'Cosby
District4 This notice is regarding the disciplinary hearing that was held at
Harold Robison,Jr. City Hall in Abbeville on May 23,2019 at 12:30 p.rn. Present at the
District5 hearing were Mayor Billy Helms, City Clerk Tina Bames,Councilman
Brendt Murphy, City Attomey Spence Danzey, your attomey Dustin
CityAttorney
Spence Danzey Fowler and yourself. The basis of the hearing was to address the
following: 1)that you have shown conduct that is unbecorning as an
Police Chlef employee, which tends to bring discredit upon the City and affects the
Noel Vanlandinghani
public respect with your department that could otherwise threaten order
City Clerlareaswer and safety; 2)violation of the Citys vehicle and driving policy by allowing
Tina B.Barnes a city employee to possess a city vehicle while on teave of absence.
During the hearing, you were in the process of stating your position
regarding item one when the hearing came to a conclusion with you and
your attomey leaving the room. item two was never addressed due to the
abandonment of the meeting.

Therefore, it is my conclusion that a ten (10)day suspension is an

appropriate punishment based on the facts and circumstances
surrounding these matters. The said suspension shall take effect
beginning Monday,June 3,2019 and continuing for ten consecutive work
days. You have five calèndar days to request an appeal of this decision to
the City Council.

Sincerely,

Billy Helms
Mayor

A66evirte, fitahanta — first in the Nation....MphabetieaftytEX. 3 at 005

 Case 1:19-cv-00500-ECM-JTA Document 4-3 Filed 07/15/19 Page 6 of 8

LAW OFFICES OF
BUNTIN,ETHEREDGE & FOWLER,L.L.C.
185 NORTH OATES STREET
DOTHAN.ALABAMA 36383
4•Mil•MMIN

TELEPHONE:(334)793-3377
FAX:(334)793-7756
STEPHEN T.ETHEREDGE (AL sad FL) REPLY TO:
DUSTIN J. FOWLER P.O.BOX 1193
DOTHAN,AL36302-U93

May 28,2019

Abbeville City Council

101 East Washington Street
Abbeville, Al 36310

Re: Chief Vanlandingham

City Council or To Whom It May Concern:

Pursuant to the letter issued by Mayor Helms ofthe City of Abbeville, Alabama on May
23,2019,this letter serves as Notice that Chief Vanlandingham is appealing the decision that
was made at the disciplinary hearing on May 23,2019,to the Abbeville City Council.

Please notify both our law firm and ChiefVanlandingham, as soon as the hearing is set
before the City Council.

Sincerely,

/s Dustin J. Fowler

Dustin J. Fowler
For the Firm

Enclosures: None
Cc: Spence Danzey,Esq.

Ex. 3 at 006
 Case 1:19-cv-00500-ECM-JTA Document 4-3 Filed 07/15/19 Page 7 of 8

101 East Washington Street

P0 Box 427,Abbeville AL 36310-042T
City ofigibbevif Phone:334-5854444Fac 334485.6982
Weix www.citvotabbevile.orq

Mayor
Baty Helms May 29,2019
bheims(kityotabbeviDe.org

CITY puma
Teffy Mums
District 1
Noel Vanlandingham
Brandt Murphy 1961 County Road 29
Mayor Pro Ternpctre
District2 Abbeville, AL 38310
Dorothy L Baker
District3
Chief Vanlandingham,
Rena'Cosby
District 4 Please be advised your appeal has been scheduled for a hearing
Harobt Robison,Jr. at City Hall on Monday, June 3,2019 at 5:00 P.M.The format of the
District5 hearing will allow you to proceed first to privately present your position to
the council. Second, Mayor Helms will be atlowed to privately present his
City Attorney
Spence Danzey position. Thereafter the council will have thirty(30)days to make a
determination to either impose or override the suspension. In the
Poke Chief meantime your job duties shall continue and the June 3,2019 beginning
Noel Vaniandingham
date of the suspension is stayed until further notice.
City Ciedirreasurer
Tina B.Bames Sincerely,

Billy Helms
Mayor

cc: Dustin J. Fowler

Buntin, Etheredge & Fowler, LLC

)166evitte, Al-ahead — Tirst in the Natio -rt....J(4 fi a6e tica ttyiEX. 3 at 007
 Case 1:19-cv-00500-ECM-JTA Document 4-3 Filed 07/15/19 Page 8 of 8
101 East Washington Street
P0Box 427,AbbevilleAL 36310-0427
City of:Abbey& Phone: 334.565-6444 Fax 334-585-6952
web; MJIthi&-.MiSi

Mayor
Billy Helms June 5,2019
bhelmsecitvofabbevilimont

CITY COUNCII,
Terry Alums
District 1
Noel Vanlandingham
Brandt Murphy 1961 County Road 29
Mayor Pro Tampons
District 2 Abbeville, AL 36310
Dorothy L Baker
District 3
Chief Vanlandingharn,
Rea COsby
District4 This letter is regarding your appeal hearing that was held on June
Harold Robison,Jr. 3, 2019 at City Hall in Abbeville, Alabama. After hearing argumentsfrom
District5 you and Mayor Helms and taking the same into consideratlon, the board
unanimously decided to uphold Mayor Helms ten (10)day suspension.
MyAttorney
Spence Daney However, the board did agree to impose the suspension in consecutive
days that includes weekends. The suspension shall begin on Monday
Poke Cidel June 10,2019 and continue for a period of ten(10)days. Thereafter your
Noel VantandIngham
normal duties as Police Chief shall contimte.
aiy ClerWTreasurer
Tina B. Berms Sincerely,

...UAre) 42-vkaA,
Tina B. Bames
City Clerk-Treasurer

cc: Dustin J. Fowler

Buntin, Etheredge & Fowler, LLC

Abbeville, firabama Tirst in tfie Xation....Afpfiabetically

3 at 008