As a public service, TLR is making available copies of selected documents filed in the court cases resulting from the question of whether District 2 Commissioner Thomasina Coates (D) is allowed to vote on the employment contract of County Administrator Mark Belton after having been administratively barred from doing so by the rest of the board.
The case is C-08-CV-23-000002, Amanda Stewart, et al. vs. The Charles County Board of County Commisioners, et al.
TLR‘s coverage of the cases, which are referred to collectively as “Stewart et al. v Commissioners,” can be found here.
Filings:
- “Verified Complaint for Temporary Restraining Order, Permanent Injunction, and Declaratory Judgment, Or, Alternatively, Writ of Mandamus and/or Prohibition,” Dec. 30, 2022
- Exhibit 1: Report of the Sargeant Investigation (UNDER SEAL)
- Exhibit 2: Minutes of the Closed Session of the County Commissioners, Tuesday, June 9, 2020 (UNDER SEAL)
- Exhibit 3: “Regular Meeting of County Commissioners, Tuesday June 9, 2020“
- “Motion to Intervene of Mark Belton,” Jan. 3, 2023
- “The Charles County Board of County Commissioners’ Motion to Dismiss,” Jan 13, 2023
- “Memorandum in Support of Defendant Commissioner Thomasina O. Coates’ Motion to Dismiss the Complaint,” Jan. 13, 2023 (REDACTED)
- “Defendant Commissioner Rueben B. Collin Ii’s Motion to Dismiss, Or, in the Alternative, Motion for Summary Judgment,” Jan. 13, 2023
- “Defendant Commissioner Ralph E. Patterson’s Motion to Dismiss Plaintiffs’ Complaint and Opposition to Temporary Restraining Order,” Jan. 13, 2023
- “Plaintiff Commissioners’ Consolidated Opposition to Defendants’ Motions to Dismiss,” Jan. 20, 2023
- “Intervening Plaintiff Mark Belton’s Consolidated Opposition to Defendants’ Motions to Dismiss,” Jan. 20, 2023
- “Reply Memorandum of Law in Support of Defendant Commissioner Ralph E. Patterson’s Motion to Dismiss and Opposition to Temporary Restraining Order,” Jan. 23, 2023
- “Defendant Commissioner Reuben B. Collins’ Reply Memorandum of Law in Support of Motion To Dismiss, or, in the Alternative, Motion for Summary Judgment,” Jan. 23, 2023
- “Defendant Commissioner Thomasina O. Coates’ Reply to Plaintiffs’ Opposition to Motion to Dismiss,” Jan. 23, 2023 (REDACTED)
- “Corrected Memorandum in Support of Defendant Commissioner Thomasina O. Coates’ Motion to Dismiss the Complaint,” Jan. 24, 2023
- “Order [arising from the Jan. 24, 2023, conference],” Feb. 15, 2023
- “Defendant Commissioner Thomasina O. Coates’ Answer to Plaintiffs’ Complaint,” Jan. 31, 2023
- “Notice of Service of Discovery Material,” Feb. 3, 2023
- “Notice of Appeal,” Feb. 3, 2023
- “Joint Motion to Stay the Circuit Court Proceedings Pending Outcome of the Appeal,” Feb. 8, 2023
- “Order [arising from the Feb. 14, 2023, conference],” Feb. 22, 2023
- “Commissioner Thomasina O. Coates’ Verified Counter-Claim and Cross-Claim,” Feb. 24, 2023
- “Defendant Commissioner Thomasina O. Coates’ Motion to Unseal and De-Designate the Fully Unredacted Minutes of the June 9, 2020, and December 13, 2022, Closed Sessions of the Board,” March 2, 2023
- Exhibit A: Redacted Minutes of the Closed Sessions of the County Commissioners, Tuesday, June 9, 2020, and Tuesday, Dec. 13, 2022 (UNDER SEAL)
- Exhibit B: Unredacted Minutes of the Closed Sessions of the County Commissioners, Tuesday, June 9, 2020, and Tuesday, Dec. 13, 2022 (UNDER SEAL)
- “Defendant Commissioner Thomasina O. Coates’ Motion to Suspend the Temporary Restraining Order and Stay Further Proceedings Pending Appeal,” and accompanying Memorandum in Support of Motion, March 9, 2023
- Exhibit A: Minutes of the Closed Session of the County Commissioners, Tuesday, June 9, 2020 (UNDER SEAL)
- Exhibit B: “Declaration of Thomasina O. Coates,” originally submitted to the Appellate Court of Maryland Feb. 9, 2023
- Exhibit C: Minutes of the Closed Session of the County Commissioners, Tuesday, Dec. 13, 2022 (UNDER SEAL)
- Exhibit D: Transcript, “Motions Hearing, Tuesday, January 24, 2023,” originally submitted to the Appellate Court of Maryland Feb. 9, 2023
- Exhibit E: “Order [in the Appellate Court of Maryland, No. 2133 September Term, 2022, MDEC: ACM-REG-2133-2022],” originally issued by the Appellate Court of Maryland March 6, 2023
- “Defendant Commissioner Thomasina O. Coates’ Motion to Shorten Briefing Schedule for Motion to Suspend Temporary Restraining Order and to Stay Further Proceedings Pending Appeal,” March 9, 2023
- “Defendant Charles County Board of County Commissioners’ Opposition to Defendant Commissioner Thomasina O. Coates’ Motion to Unseal and De-Designate the Fully Unredacted Minutes of the June 9, 2020 and December 13, 2022 Closed Sessions of the Board,” March 10, 2023
- “Defendant Commissioner Thomasina O. Coates’ Opposition to Joint Motion to Stay the Circuit Court Proceedings Pending Outcome of the Appeal,” March 13, 2023
- “Plaintiff Commissioners’ Opposition to Defendant Commissioner Coates’s Motion to Shorten Briefing Schedule for Motion to Suspend Temporary Restraining Order and to Stay Further Proceedings Pending Appeal,” March 13, 2023
- “Reply to Opposition to Defendant Commissioner Thomasina O. Coates’ Motion to Shorten Briefing Schedule for Motion to Suspend Temporary Restraining Order and to Stay Further Proceedings Pending Appeal,” March 14, 2023
- “Plaintiff Commissioners’ Motion for Leave to File Sur-Reply to Address Misrepresentations and New Evidence in Defendant Commissioner Thomasina O. Coates’s Reply in Support of Motion to Shorten Briefing Schedule for Motion to Suspend Temporary Restraining Order and to Stay Further Proceedings Pending Appeal,” March 15, 2023
- “Plaintiff Commissioners’ Sur-Reply in Support of Their Opposition to Defendant Commissioner Thomasina O. Coates’s Motion to Shorten Briefing Schedule for Motion to Suspend Temporary Restraining Order and to Stay Further Proceedings Pending Appeal,” March 15, 2023
- Exhibit A: “Plaintiffs-Appellee’ Opposition to Appellant’s Motion to Suspend Temporary Restraining Order and Stay Further Proceedings in the Circuit Court,” originally submitted to the Appellate Court of Maryland Feb. 16, 2023
- “Reply to Defendant Charles County Board of County Commissioners’ Opposition to Defendant Thomasina O. Coates’ Motion to Unseal and De-Designate the Fully Unredacted Minutes of the June 9, 2020 and December 13, 2022 Closed Sessions of the Board,” March 16, 2023
- “Praecipe Requesting a Status/Scheduling Conference,” March 22, 2023
- “Plaintiff Commissioners’ Opposition to Defendant Coates’s Motion to Suspend Temporary Restraining Order and Stay Further Proceedings in the Circuit Court,” March 24, 2023
- “Order [to Stay the Circuit Court Proceeding],” March 31, 2023
- “Order [to unseal Defendant Thomasina 0. Coates’ Memorandum in Support of her Motion to Dismiss and Exhibits 1 and 2 to Plaintiffs’ Complaint],” March 31, 2023
- Report of the Sargeant Investigation
- Minutes of the Closed Session of the County Commissioners, Tuesday, June 9, 2020 (REDACTED)
- “Memorandum in Support of Defendant Commissioner Thomasina O. Coates’ Motion to Dismiss the Complaint,” Jan. 13, 2023 (FULLY UNREDACTED)
- “Certification of Original Case File,” April 17, 2023
- Notice of Scheduling Conference, April 17, 2023
- “Order [Granting Permission for Commissioner Coates to Participate in Mediation],” May 9, 2023
- Notice of Evidentiary Hearing, May 10, 2023
- “Order [Lifting the Stay on Proceedings and Permitting Limited Discovery],” May 15, 2023
- “Plaintiff Commissioners’ Answer to Defendant Commissioner Thomasina O. Coates’s Verified Counter-Claim and Cross-Claim,” May 31, 2023
- “Plaintiff Mark Belton’s Answer to Defendant Coates’ Counter-Claim and Cross-Claim,” June 2, 2023
- “Defendant Charles County Board of County Commissioners’ Answer to Defendant Coates’ Counterclaim and Crossclaim,” June 7, 2023
- “Defendant Commissioner Thomasina O. Coates’ Amended Answer to Plaintiffs’ Complaint,” June 19, 2023
- Subpoena [for Bernadette Sargeant], Superior Court of the District of Columbia, Case No. 2023-CAB-003654, June 16, 2023
- Subpoena [for Stinson LLC], Superior Court of the District of Columbia, Case No. 2023-CAB-003657, June 16, 2023
- “Defendant Thomasina O. Coates’ Motion to Compel Deposition Testimony of Edward Wesley Adams III,” July 25, 2023
- Exhibit A, “Transcript of Edward Wesley Adams, III,” July 19, 2023
- “Defendant Charles County Board of County Commissioners’ Motion for Appropriate Relief,” August 14, 2023
- Letter from Alvin I. Frederick, Law Offices of Eccleston and Wolf, to Judge Leo E. Green, Circuit Court for Charles County, re: Amanda M. Stewart, et al v. Charles County Board of Commissioners, Case No.: C-08-CV-23-00002, August 14, 2023
- “Non-Party E. Wesley Adams, III’s Response to Defendant Thomasina O. Coates’ Motion to Compel Deposition Testimony of Edward Wesley Adams III,” August 14, 2023
- “Non-Party E. Wesley Adams, III’s Motion for a Continuance for September 1, 2023 Hearing,” August 14, 2023
- “Motion to Shorten Time to Respond to Non-Party E. Wesley Adams, III’s Motion for a Continuance for September 1, 2023 Hearing,” August 14, 2023
- “Plaintiff Commissioners’ Response to Board’s Motion for Protective Order and to Quash Foreign Subpoenas and Defendant Coates’s Motion to Compel Testimony of County Attorney Edward Wesley Adams, III,” August 15, 2023
- Exhibit 1, “Deposition of Mark Belton [excerpts],” July 20, 2023
- Exhibit 2, “Motion Hearing [transcript excerpts],” January 24, 2023
- Exhibit 3, “Deposition of Commissioner Thomasina O. Coates [excerpts],” July 19, 2023
- Exhibit 4, “Deposition of Reuben B. Collins II [excerpts],” July 24, 2023
- “Reply to Non-Party E Wesley Adams, III’s Response to Defendant Thomasina O. Coates’ Motion to Compel Deposition Testimony,” August 24, 2023
- Exhibit A, Email from E. Wesley Adams, III (UNDER SEAL)
- Exhibit B, Email from Kevin Karpinsky to Counsel, May 23, 2023
- Exhibit C, “[DRAFT] Separation of Employment Agreement,” undated
- “Defendant Thomasina O. Coates’ Opposition to Defendant Charles County Board of County Commissioners’ Motion for Appropriate Relief,” August 24, 2023
- Exhibit A, Deposition of Commissioner Gilbert O. Bowling (UNDER SEAL)
- “Reply to Plaintiff Commissioners Response to Board’s Motion for a Protective Order and to Quash Foreign Subpoenas and Defendant Coates’ Motion to Compel Testimony of County Attorney E. Wesley Adams,” August 25, 2023
- Exhibit 1 (UNDER SEAL)
- Exhibit 2 (UNDER SEAL)
- Exhibit 3 (UNDER SEAL)
- Exhibit 4, “Transcript of Edward Wesley Adams, III,” July 19, 2023
- Exhibit 5, Correspondence re: Draft Letter to the Editor regarding Paid Advertisement in the Maryland Independent, July 20-21, 2020
- Exhibit 6 (UNDER SEAL)
- Exhibit 7, Attorney Billing Records
- Exhibit 8, Correspondence re: Appellate Fees, February 3, 2023
- Exhibit 9, Correspondence re: Engagement of Mariam Tadros as Counsel for Commissioner Coates, January 5, 2023
- Exhibit 10, Response to Maryland Public Information Act Request re: Attorney Costs and Fees, May 5, 2023
- Exhibit 11, Correspondence re: Draft Separation of Employment Agreement (with unsigned and undated draft agreement), May 23, 2023
- Exhibit 12 (UNDER SEAL)
- Exhibit 13, Correspondence re: Mark Belton’s Hiring Authority (with accompanying extract of separate internal correspondence), July 15, 2019
- Exhibit 14, Correspondence re: Personnel Policy, July 12, 2019
- Exhibit 15, Correspondence re: Correspondence Relevant to Sargeant Investigation, April 22, 2020
- Exhibit 16, Correspondence re: Confidential Personnel Information, (no date) (REDACTED)
- Exhibit 17, Correspondence re: Request from Bernadette Sargeant for Call to Mark Belton, May 21, 2020
- Exhibit 18, Correspondence re: Negotiations with Bernadette Sargeant for Investigation, March 9, 2020
- Exhibit 19, Correspondence re: Proposed Meeting of E. Wesley Adams III, Eric Paltell, and Bernadette Sargeant, June 11, 2020
- Exhibit 20, Correspondence re: Property Inspection Related to Sargeant Investigation, May 23, 2020
- Exhibit 21, Correspondence re: Human Resources Response to Employee Actions, April 29, 2020
- Unnumbered Exhibit, Copy of Sargeant Investigation Report (plus Appendix A, “Materials Reviewed”), May 25, 2020
- “Line by Defendant Charles County Board of County Commissioners Joining Plaintiff Commissioners’ and Nonparty Wesley Adams, III’s Oppositions to Defendant Coates’ Motion to Compel the Testimony of Adams,” August 29, 2023
- “Reply to Defendant Thomasina O. Coates’ Opposition to Defendant Charles County Board of County Commissioners’ Motion for Appropriate Relief,” August 29, 2023
- “Memorandum of Court,” August 30, 2023
- “Memorandum and Order of the Court,” September 2, 2023
- “Defendant Commissioner Thomasina O. Coates’ Trial Brief for Hearing on Plaintiffs’ Request for a Preliminary Injunction,” September 7, 2023
- Exhibit A, Record Abstract (for the Appellate Court of Maryland), Vol. 1, pages E1 to E464
- Exhibit B, Record Abstract (for the Appellate Court of Maryland), Vol. 2, pages E465 to E488 (UNSEALED AND UNREDACTED)
- “Memorandum and Order of the Court” (denying defendant Coates’ motion to compel and finding that continuance is moot) (COMING SOON)
- Order (to unseal and de-designate the fully unredacted minutes of the June 9, 2020, and December 13, 2022, closed sessions of the board), September 14, 2023
- Order (to unseal the deposition transcripts of Plaintiff Commissioner Gilbert O. Bowing, Jr., Defendant Commissioner Thomasina O. Coates, Commissioner’s President Reuben B. Collins II, and Plaintiff Mark Belton), September 14, 2023
Closed Session Minutes:
- Minutes of the Closed Session of the County Commissioners, Tuesday, June 9, 2020 (UNREDACTED AND UNSEALED)
- Minutes of the Closed Session of the County Commissioners, Tuesday, Dec. 13, 2022 (UNREDACTED AND UNSEALED)
Depositions:
- Adams, E. Wesley III, July 19, 2023
- Belton, Mark, July 20, 2023
- Bowling, Gilbert O. III, July 20, 2023
- Coates, Thomasina O., July 19, 2023
- Collins, Reuben B. II, July 24, 2023