Direct Dial: 912-644-5736

Facsimile: 912-233-0811
Email: mtbutler@bouhan.com
Please reply to:
Post Office Box 2139
One West Park Avenue Savannah, Georgia 31402-2139
Savannah, Georgia 31401

February 4, 2021

Dear Mr. Buckley:

We have received forwarded copies of your letters dated February 2 and 4, 2021, to the
Chairman of the Chatham Area Transit Authority regarding Ms. Mauldin. While your February
2 letter raises a number of issues to which CAT will respond in due time, I write today to address
your February 4 letter, because it contains a number of misstatements that your client may rely
upon to attempt improperly to return to the CAT offices "immediately". Let me be clear: Under
no circumstances will Ms. Mauldin be afforded admission or access to any CAT facility.
Should she attempt to do so, she will be barred and, if necessary, removed by security personnel.
If Ms. Mauldin needs to obtain access to CAT property, she should make an appointment with
Interim CEO Valerie Ragland first.
Your letter is based on the false premise that Ms. Mauldin’s termination by CAT’s Board
was somehow invalid because Ms. Odell was not a member of the CAT Board when the vote
was taken to terminate Ms. Mauldin. However, the vote was valid even without Ms. Odell’s
participation. First, it was approved by a 5-3 majority, not counting Ms. Odell’s vote. Second,
under Robert's Rules, which are expressly incorporated into the Board’s procedures by the CAT
Act, see Chatham Area Transit Act, §13-206(6), a second to the motion was not necessary and
the lack thereof does not invalidate the vote. The motion to terminate Ms. Mauldin, brought by
Commissioner Stone, was valid even though Ms. Odell may have purported to second the
motion. Robert’s Rules of Order (12th ed.), § 4:13 (“If a motion is considered and adopted
without having been seconded—even in a case where there was no reason for the chair to
overlook this requirement—the absence of a second does not affect the validity of the motion’s
adoption.”). This is because the only purpose of a second is “to prevent time from being
consumed by the assembly’s having to dispose of a motion that only one person wants to see
introduced.” Id., § 4:12. With a 5-3 vote in favor of the motion to terminate, there was
obviously enough Board support to consider the motion.
Your client’s unilateral belief that she remains an employee of CAT is unfounded. The
CAT Board terminated Ms. Mauldin’s contract, as it was expressly and specifically entitled to do
under the terms of that contract.
 Letter to Mr. Buckley
February 4, 2021
Page 2

For the present, CAT remains willing to perform its post-termination duties to Ms.
Mauldin under her contract, including paying her severance salary and benefits. Ms. Mauldin, in
turn, is obligated to abide by that same contract. She is no longer a CAT employee, and she
should not attempt to return to CAT premises without prior approval.

Sincerely,

M. Tyus Butler, Jr.

Legal Counsel
Chatham Area Transit Authority

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