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To: City Administrator Russ Hawes From: Former Police Chief Keith Grounsell KPG Date: January 7, 2013

Re: Official Grievance for the wrongful termination of Chief Keith P. Grounsell Personnel Employment Action Pursuant to the grievance procedure, I am requesting a hearing. This document is to serve as my official grievance for the wrongful termination as the Chief of the Simpsonville Police Department on December 28, 2012. Since the City of Simpsonville has changed their reasons for my termination at least 3 different times and one additional time based upon what I have learned was discussed in the executive session; I will try and address all of the allegations one at a time. It should be known that I have met and spoke to a council member(s) and learned that some of the items in the document that I received on January 3, 2013, (via the U.S. Mail) are different from what was discussed during the executive session as a reason for my termination. In addition, the document I received was signed by City Administrator Russ Hawes and HR Director Lavada Galloway on December 31, 2012. This is three days after my termination date of December 28, 2012. Since you failed to mention almost all of these reasons during the executive session on December 28, 2012, and wrote/signed this document after my termination, they are irrelevant. With that said, I will still go ahead and disprove each item on face value because I have done nothing wrong. You should be aware that under Section 30-4-70 of the Public Officials Guide to Compliance with South Carolinas Freedom of Information Act (SEE THE BELOW LAW), it is a violation of the law to fail to give me the option of a public hearing before you opted to conduct the executive session to determine my employment. In addition, you failed to notify me that this executive session had anything to do with me. I was told to be at the special city council session just like all the other department heads, so I should not have had any reason for concern when I noticed there was an executive session to deal with a personnel matter at the police department on the agenda. I even called HR Director Lavada Galloway and she would not tell me who or what the personnel & legal matter pertaining to the Police Department was about that evening. I should have been advised it was about me and given the option of a public hearing, which I would have chosen. SECTION 30-4-70. Meetings which may be closed; procedure; circumvention of chapter; disruption of meeting; executive sessions of General Assembly. (a) A public body may hold a meeting closed to the public for one or more of the following reasons: This exemption deals with individual employment matters. However, employees have the right to demand an open hearing. (1) Discussion of employment, appointment, compensation, promotion, demotion, discipline, or release of an employee, a student, or a person regulated by a public body or the appointment of a person to a public body; however, if an adversary hearing involving the employee or client is held, the employee or client has the

right to demand that the hearing be conducted publicly. Nothing contained in this item shall prevent the public body, in its discretion, from deleting the names of the other employees or clients whose records are submitted for use at the hearing. Under Section 30-4-70 of the Public Officials Guide to Compliance with South Carolinas Freedom of Information Act (SEE THE BELOW LAW) it is illegal to use electronic communications to circumvent the system. According to a council member(s) this was violated by Councilmen Matthew Gooch during the executive session when he shared an email, which is an electronic communication, with the rest of the council to persuade others to vote for my termination. It is evident that this email occurred before the executive session because Matthew Gooch brought a hard copy of this email with him to the council meeting. In addition, the actions of City Administrator Russ Hawes less than 24 hours before the date of my termination indicated that he must have had a meeting or discussion about my termination with someone on city council before the executive session on December 28, 2012. I know this because City Administrator Russ Hawes all of a sudden started approving items (via email) that I have been trying to get him to approve for approximately two months. This is not a coincidence; it is an attempt at a cover up on behalf of the City Administrator to give the appearance that he has been trying to work with me. In actuality, he has ignored my urgent request on numerous occasions and felt it necessary to all of a sudden approve these things less than 24 hours before my termination. (b) Before going into executive session the public agency shall vote in public on the question and when the vote is favorable, the presiding officer shall announce the specific purpose of the executive session. As used in this subsection, specific purpose means a description of the matter to be discussed as identified in items (1) through (5) of subsection (a) of this section. However, when the executive session is held pursuant to Sections 30-4-70(a)(1) or 30-4-70(a)(5), the identity of the individual or entity being discussed is not required to be disclosed to satisfy the requirement that the specific purpose of the executive session be stated. No action may be taken in executive session except to (a) adjourn or (b) return to public session. The members of a public body may not commit the public body to a course of action by a polling of members in executive session. Some public bodies have abused the FOIA through chance meetings at parties, over meals or through telephone or internet conferences. This kind of activity is illegal and the following language spells it out. (c) No chance meeting, social meeting, or electronic communication may be used in circumvention of the spirit of requirements of this chapter to act upon a matter over which the public body has supervision, control, jurisdiction, or advisory power.

In press releases immediately after my termination, Mayor Perry Eichor has said that I failed to pass probationary requirements and that after a "performance review" it was decided to terminate me because he said I was not a good fit for the City. It should be known that I only officially worked approximately 40 business days on the job as the Chief of Police; the rest of my time was in training out of town. Due to the short time period on the job, I dont recall ever being given a performance review that the Mayor refers to in his statement. I have never been told or given a copy of any probationary requirements specific to the job as the Chief of Police. In addition, I have never physically been given a copy of my performance evaluation (a/k/a performance review) by my direct supervisor, City Administrator Russ Hawes. If I were given a performance evaluation, I would have had to of signed it after it was explained to me. Mayor Perry Eichors statements were factually inaccurate and this document does not exist. In furtherance of my argument, Councilwoman Geneva Lawrence has requested a copy of my performance review and probationary requirements, which the Mayor claimed to be the reasons for which I was terminated. As of the date of this document, City Administrator Russ Hawes has never provided these documents to Councilwomen Lawrence, which leads Geneva Lawrence and any reasonable person to believe that they do not exist. If they did exist I would have signed them myself and so would every member of City Council. Both Councilwomen Geneva Lawrence and Sylvia Lockaby have repeatedly stated that they never saw or signed any performance review for me. In addition, City Administrator Russ Hawes has indicated in an electronic communication to Councilwomen Sylvia Lockaby the following about my work performance: he is clearly trying to do what he can while away at the police academy. This proves I am doing the best I can under the constraints that have been presented to me. I was trying my best under difficult circumstances, but the City Administrator intentionally avoided responding to my phone calls and emails, which caused additional problems for me. This was on top of them forcing me to allow the Assistant Chief to continue her employment at the Police Department as my second in command, despite the numerous policies, ethical and insubordination violations she has committed. I have been advised that in a discussion between Councilwoman Sylvia Lockaby and City Administrator Russ Hawes, Russ Hawes admitted that he did not answer all my emails. His complaint was that I sent him too many emails, which is not an excuse to ignore them. I was doing my best trying to manage things from 100 miles away at the police academy, but it is difficult when your direct supervisor (City Administrator Russ Hawes) ignores your phone calls and emails. I was forced into a position to question my trust and the integrity of the City Administrator, so I created a paper trail by sending emails. It is unfortunate that I was forced into a position where I had to create a paper trail, but my perception of the City Administrators constant refusal to answer my emails and phone calls forced me into this position. I was hired to emulate and uphold the trust of the public and unfortunately I do not feel those around me had the same goals in mind. Individuals like the City Administrator do not need to be in a position of public trust.

It is obvious that the City Administrator was more than partially to blame for the snowballing effects of my dealings with the Assistant Chief. In an email to Councilwoman Sylvia Lockaby the City Administrator said I am sure that in hindsight some decisions made during this issue could have been better. This was received on December 20, 2012, eight days before my termination. The City Administrator admits to being partially responsible for all of the problems at the police department. It is unfortunate that I am the apparent scape goat for the City Administrators inability to perform his duties. It was stated in the letter that my officers sent to City Council in October 22, 2012, that I was part of the positive solution to the police departments problems that go back over a decade. You cannot expect me to fix these issues with around 40 working days (not including weekends) actually in the office. At the time that the letter was written these officers had more of a working knowledge of the department than city council members looking in from afar. The letter should have been given more consideration and not brushed aside and perceived as a threat. If allowed to perform the job I was hired for, and given a fair chance, I would have been able to resolve the perceived issues brought to my attention. Feedback that I was receiving from the officers, which was evident in the aforementioned letter, further substantiates my pervious statement. It is my understanding from the officers that the predominate issue prior to my arrival at the police department was the former Chief of Police, the Assistant Chief and the current City Administrator. On top of the above issues, I would like to address a letter that I received on January 3, 2013, via US Mail. (SEE BELOW) This is where additional items, which were not discussed in the executive session on December 28, 2012, were brought out as reasons for my termination. As you know, if these issues were not discussed in the executive session then they cannot officially be used as reasons for my termination. If they were used against me then it is proof that the city council violated rules within the Public Officials Guide to Compliance with South Carolinas Freedom of Information Act. The italicized items below are direct quotes taken from the letter that I received from City Hall on a City of Simpsonville Termination Action Form: Reason employees actions are not acceptable: 1. Failed to inform City Council that he was not a certified officer either during his interview or when offered the position. Nevertheless, the City overlooked this and allowed him to begin work and attend the academy. (MY RESPONSE: If you were willing to overlook this, then why is it listed as the first reason for my termination on the employee Termination Action Form? This was also not one of the job requirements listed in the job description for this position. In addition, the job application never asked if I was a certified Class I Law Enforcement Officer. I also had two separate 2-hour long interviews during this selection process and I was never asked this question. Every council member was allowed to ask me multiple questions, but they failed to delve into the topic of law enforcement certification.

This is only the fault of city council because I was prepared to truthfully answer any question I was asked. I was certified as a Class III Law Enforcement Officer when I applied for this position. As a Class III officer I can run the police department administratively, but opted to go back to the SC Criminal Justice Academy for a 6-week special basic program to get back my Class I certification. This was discussed with the City Administrator and he understood this before I left for training. Not one person, to include the City Administrator, Mayor or any member of City Council, ever verbalized specifically to me an issue with me going back to the police academy. In addition, I was not the only applicant selected to be in the top-5 to become the next Police Chief that was not a certified Class I Law Enforcement Officer in the state of South Carolina. The FBI agent was also not a certified Class I LE Officer in SC.) 2. There are serious morale problems in the PD directly related to Chief Grounsells ongoing conflicts with Assistant Chief ONeil. Chief Grounsell was made aware of Assistant Chief ONeils EEOC complaint and the legal restrictions placed on the city in light of that complaint. Under federal law a person who files an EEOC complaint is entitled to certain protections. Chief Grounsell was well aware of those protections. (MY RESPONSE: It is my understanding that the current low morale issues at the police department are directly related to Assistant Chief Colleen ONeil. This was evident in the letter written by the officers and submitted to city council. Furthermore, a subsequent personnel investigation revealed further underlying issues and specific complaints from the officers involving improper treatment, misconduct and a hostile work environment created by the Assistant Chief. It is evidently clear based on the above, that morale was substantially lower prior to my arrival. This was proven after approximately one month on the job when the police department employees sent a letter to city council. In this letter the police department employees stated Since Chief Grounsell's first day on the job (9-18-2012) morale at the Police Department has completely turned around. It is definitely better than it has been in the last 12 years and we are excited about the direction Chief Grounsell is attempting. The number of quality applicants wanting to work for the Simpsonville Police Department has drastically increased. We feel that City Council made the right decision in their selection, and stand behind him and his efforts for future growth and development 100%. Based upon the above statement, which was signed by 32 police department employees and supported by others that told me they did not sign out of fear of reprisal, the morale increased significantly with my presence. This was done in a very short period, when I was only on the job for approximately 1 month. When I left to go the police academy for training morale drastically declined, due to the fact that I was forced by City Council and the City Administrator to leave the Assistant Chief in charge during my absence. In a very short period of time she destroyed all of the forward progress I was able to accomplish prior to leaving for the academy.

You are correct in stating that there are legal restrictions placed on the city when an employee has filed an EEOC complaint. You are referring to the no-retaliation clause. Under the no-retaliation clause it does not give the Assistant Chief free reign to do whatever she wants without any fear of being disciplined. Unfortunately, the City of Simpsonville has allowed the Assistant Chief the ability to violate policies, procedures, and ethical standards without consequence. The city cannot lean on the no retaliation clause of the EEOC complainant anymore, because the EEOC complaint is still ongoing and the Assistant Chief is currently suspended. Why is it that after my termination she is all of a sudden allow to be disciplined? This gives the appearance that council hired me to be a lame duck Chief. The City Administrator admitted that he has allowed the Assistant Chief to commit many different types of violations in an email that he sent to Councilwomen Sylvia Lockaby on December 20, 2012. In this email City Administrator Russ Hawes says the following in reference to a question as to why he appears to be letting the Assistant Chief have a free pass and get away with everything: I mean she appears to be getting away with a lot of things. Violating protocol, disobeying orders or not following orders, disrespecting city policy, and more. The response by the City Administrator clearly shows he has lost control as a manager. Unfortunately for me, I was the one that had to deal with his mismanagement issues that spiraled out of control. The very second that the City Administrator undermined my internal policy against anyone retiring and coming back above the rank of corporal, I knew he was intentionally intervening in my day to day operations [which is also known as micromanaging]. The negative results of the City Administrators poor management skills were blamed on me, which is not fair. If I was allowed to run my department like I wanted to, these issues would not have compounded and pulled down others!) 3. The conflict between Chief Grounsell and Assistant Chief ONeil grew to the point that investigations had to be conducted by the HR Director who was required to spend many hours interviewing employees. (MY RESPONSE: I am unaware of any personal conflict the Assistant Chief and I may have. This is a professional issue, in which the Assistant Chief failed to adhere to the policies and basic rules, regulations and standards of the agency. It is the Assistant Chiefs responsibility to set a standard for the officers under her command. By failing to do so, she has placed me in a position where I had to discipline her accordingly. I was told that I am not allowed to discipline the Assistant Chief while she continued to commit additional violation. This was confirmed in the above answer to #2, where I quoted Russ Hawes in an email to Councilwomen Sylvia Lockaby. There was an apparent complaint filed against me to the HR Director approximately three weeks after I had left for the police academy. The HR Director advised that the formal title for the complaint was harassment. I asked for specifics and a copy of the complaint and I

was given general answers with no specifics. It appeared to me that the only obvious answer is that the Assistant Chief was attempting to strengthen her EEOC complaint by filing false claims. After an approximately 1 month investigation the HR Director submitted her findings to the city council in executive session. I found out that the complaint was unfounded, however I was never officially informed that the investigation was complete or the findings. I asked the HR Director for a copy of the harassment complaint filed against me by the Assistant Chief. She refused and I was told that I was not entitled to that information. The standard protocol would dictate that an employee has the right to review the accusations and the findings made against them, however I was not afforded this same opportunity. For the city to continue to blame me for an investigation based upon the Assistant Chiefs harassment complaint is absurd. If I would have been allowed to properly run the department the blatant acts of insubordination by Assistant Chief ONeil would potentially of been the cause of her termination and not mine. 4. In an effort to resolve the conflict, council authorized the HR Director to meet with Chief Grounsell and Assistant Chief ONeil. The meeting lasted over 4 hours. At the end of the meeting, Chief Grounsell said that he was willing to start over and put any previous concerns behind him. He also agreed to maintain as confidential the discussion that took place during the meeting. (MY RESPONSE: This conflict was created by the City Administrator not allowing me to run my department and/or discipline the Assistant Chief. At this point it had already been announced to city council that the findings of the HR Directors investigation cleared me of any wrongdoing. I was informed by certain members of council that this meeting was designed to strengthen the cities EEOC defense, by getting the Assistant Chief to admit that we could work together. In other words, I was unwittingly being used as a pawn to help the city out in the EEOC complaint. I only agreed to come to this meeting because I was trying everything in my power to help the police department move forward in a positive direction. If I would have known that this meeting was going to be used against me at a later date, I would have been much more reluctant to cooperate. For the city to use this against me, and as a reason for my termination, is suspect. I did agree not to discuss the details of this meeting, but I was never told I could not to tell anyone we had the meeting. As a matter of fact, the HR Director suggested for me to tell everyone at the police department that the Assistant Chief and I had talked things out, we are now on the same page and I am optimistic about moving forward. 5. City Council believes that Chief Grounsell lacked candor in dealing with the HR Director and by extension, City Council. Chief Grounsell had a discussion with an individual after the settlement meeting during which Chief Grounsell repeated the details of the meeting. Chief Grounsell also made statements after the meeting that are contrary to his commitment to the HR Director that the prior conflict had been resolved and his commitment to start

over. (MY RESPONSE: To suggest that I lacked candor in dealing with the HR Director and city council is to directly question my integrity. At no point did I ever lack any candor in dealing with any person, employee, or administrator in Simpsonville City. The HR Director herself had attempted to unknowingly violate proper hiring practices established by the police department, which had already been approved by our state accreditation process and the SC Municipal Association. Specifically, the HR Director advised me that I was not allowed to ask a police officer applicant for any type of identification before I gave them a conditional offer of employment. This was ridiculous since it is a prerequisite of every police officer to have a valid drivers license and we also needed to confirm the identification of the person applying for the job. In addition, the HR Director told me that I was not allowed to run a criminal history of any police department applicant until I gave them a conditional offer of employment. I knew this was a violation of the proper hiring practices according to the SC Municipal Association, but the HR Director stood her ground and basically called me a liar. I informed her that we would be the laughing stock of the law enforcement community if we were consistently giving conditional offers of employment to persons with criminal histories. I also informed her that it was a job requirement that each police officer applicant not have a criminal history because certain criminal offenses are automatic disqualifiers. The HR Director started with the City of Simpsonville shortly before I did and she admitted to me on multiple occasions that she does not understand the dynamics of working for a government agency, especially not dealing with Police Officers in HR matters. HR Director Lavada Galloway came to the city from Renewable Water Source [ReWa], which is part of the private sector. In addition, I was advised by councilwomen Geneva Lawrence that she had a discussion with the HR Director about some of the above matters. She specifically stated that she showed the HR Director where the SC Municipal Association allows some of these things to be done by law enforcement agencies during the hiring process. At the time when the HR Director tried to argue these things with me I had no knowledge that Councilwomen Geneva Lawrence had already explained the above to her. The HR Director tried to change the entire hiring practice of the police department two days before I was terminated. Now, because I did not agree with the HR Director, and with good reasons, they are saying I lacked candor in dealing with the HR Director. No, the real statement should have been that I proved that she did not know her job and was wrong, so she is upset. Not only did I do my research and find this information on the SC Municipal Association website, I also reached out to a neighboring police department that is Internationally Accredited. I asked them if they ran criminal histories and/or asked for a copy of their drivers license before they give a conditional offer of employment to a police officer applicant. Without hesitation I was informed that they did. I told this individual what I was going through with the HR Director trying to change the police department hiring process and he/she laughed at her ignorance to the process.

Now, let me address the second half of this false reason for my termination. The city claims that Chief Grounsell had a discussion with an individual after the settlement meeting during which Chief Grounsell repeated the details of the meeting. I was contacted by this third party immediately after my meeting with the Assistant Chief and the HR Director while I was driving back to the police academy for training. The purpose of the conversation had nothing to do with the Assistant Chief, it was about an emergency management topic. During the conversation the other party advised me that he/she was friends with the Assistant Chief and asked how things were going between us. It was no secret that the Assistant Chief hated me and she proved that in her actions and statements to others. I advised this individual that I just left a meeting with the Assistant Chief and HR Director where we put all our issues out on the table. I informed him/her without going into details about any of the issues, that we hashed our differences out and decided to move forward. I ended by saying that I was optimistic about moving forward and working together with the Assistant Chief. That was the extent of the conversation about the Assistant Chief. What I am stating is supported by an email that this third party provided to Councilwomen Geneva Lawrence about the details of the above conversation. It should be known that during the executive session Councilman Matthew Gooch used the information provided by the Assistant Chief against me and as the primary reason for my termination. Councilman Matthew Gooch admitted that the Assistant Chief claimed that I bad-mouthed her to this third party. Councilman Gooch failed to investigate these allegations himself and took what the Assistant Chief said on face value. This third party confirmed that Matthew Gooch failed to call him/her to hear his/her side of the story. In addition, Councilman Matthew Gooch failed to ask me my side of this story. Therefore, it is evident that Councilman Matthew Gooch used false and uncorroborated information as a primary reason for terminating my employment as the Chief of Police. Based upon this alone, I should be reinstated immediately! With that said, I did not divulge anything about the details of the meeting, so therefore I did nothing wrong unless it is bad to speak positively about what took place that day. At no point did the HR Director ever tell me not to tell anyone that the meeting took place, but she did ask that we not discuss the details of the meeting. I followed the orders of the HR Director and did nothing wrong. The statement to Councilwoman Geneva Lawrence by this third party proves that the Assistant Chief lied about this situation. I know that the Assistant Chief and the Fire Chief are currently suspended for lying, so there is a pattern here with the Assistant Chief. This is supporting evidence that should be used to terminate the employment of Assistant Police Chief Colleen ONeil during the next executive session at the next city council meeting on January 8, 2013. I cannot help it that everyone knew we were meeting that day based upon our vehicles being the only ones parked outside of City Hall for more than 4 hours on the weekend. Police Officers can put two and two together and reasonably infer that we had a meeting. For this reason, the meeting was no secret to anyone.

The city also claims that I made statements after the meeting that are contrary to my commitment to the HR Director. I left that meeting optimistic that the Assistant Chief and I were going to be able to try and work together and move forward. From day one I walked into this position trying to work with the Assistant Chief, despite her rudeness and blatant disrespect for me as her boss. The Assistant Chief has been allowed to repeatedly violate policies, procedures, rules and orders without any consequences. I documented this in the approximately 50 page document that I provided to the City Administrator, HR Director and Mayor. I agreed to do this meeting because it was in the best interest of the city, the citizens and the police department employees. During the meeting the HR Director clearly stated that I was the Chief of Police and she was the Assistant Chief. She further stated that the Assistant Chief had to follow my direct orders, whether she liked them or not. I left the 4 hour meeting that Sunday willing to give the Assistant Chief another chance, but within 48 hours she was violating policies and procedures and started being insubordinate again. When she started doing these things again I reported them up the chain of command and to the HR Director, since she obviously did not have a clue what was going on at the police department. You have to remember, I was still under investigation for harassment claims made by the Assistant Chief, even though the investigation was official over and showed I did nothing wrong. So, when I reported these violations I am somehow said to be making statements contrary to my commitment to the HR Director. I am sorry that the Assistant Chief almost immediately started doing what she did after we had our 4 hour meeting. But, it was my duty to report this information up the chain of command. I also felt it necessary to notify the HR Director since City Administrator Russ Hawes wanted me to overlook everything that the Assistant Chief was doing wrong. I thought that HR was there to assist in employee/personnel issues, but I a guess I was mistaken. To say I lacked candor, is false.) 6. Chief Grounsell is either unwilling or unable to fully cooperate with the City in light of the position the City faced with Assistant Chief ONeils EEOC claim. On several occasions, Council had expressed its full support of him as the Chief of Police. However, Chief Grounsell took great exception to the Citys direction that limitations had to be in place limiting his ability to realign the PD, at least temporarily, due to the EEOC Charge filed by Assistant Chief ONeil. (MY RESPONSE: The only thing that I was unwilling to do was continue to overlook clear violations committed by the Assistant Chief. In addition, I was not willing to violate SC Municipal Codes in the improper hiring practices that the HR Director wanted me to follow. If they call me uncooperative because I reported ethical, moral, policy and legal violations, then I am guilty of this. At first, I only reported them to the City Administrator verbally. It was not until after my officers submitted the letter to city council that I put together the approximately 50 page packet to give to city council. I only did this after the City Administrator tried to embarrass me in front of the Mayor by saying that I have never given him anything in writing. He tried to use this as his excuse as to why he never allowed me to discipline the Assistant Chief. This was a blatant lie, because the

City Administrator told me not to give him anything in writing since we could not discipline her. The reason the City Administrator said that I could not discipline the Assistant Chief was because she had an active EEOC complaint. Once he called me out in front of the Mayor, I gave him, the HR Director and the Mayor the approximately 50 page packet of violations and corroborating evidence on behalf of the Assistant Chief. It was evident that after I submitted this packet requesting the immediate termination of the Assistant Chief that I was unfairly targeted by the City Administrator, Mayor and a majority of the City Council members. The City Administrator started to ignore my email request to get things done in order to make things very difficult on me. It was not until 24 hours before I was terminated that the City Administrator miraculously started answering my emails for help. Some of these emails were things I had request verbally months prior to him finally responding. It was obviously no coincidence that the City Administrator all of a sudden answered my emails 24 hours prior to my termination; he was doing this to cover his own butt and to give the appearance that he was working with me all along. This also proves that he had acquired knowledge from someone on City Council or the mayor that I was going to be terminated. As I have explained before these types of communications before going into an executive session are clear violations of the Section 30-4-70 of the Public Officials Guide to Compliance with South Carolinas Freedom of Information Act. These actions prove that one or more persons conspired outside of the normal avenues to get rid of me as the Police Chief. Further adding to my suspicion was the fact that City Administrator Russ Hawes approved numerous other things (i.e. allowing the Interim Chief to immediately restructure the agency by moving the Assistant Chief to a new position as the Uniform Patrol Commander), via the Interim Chief, that I had been asking for approval on during my time as the Chief. To make matters worse these things were approved almost immediately and upon the first request of the interim Police Chief. If I was such a bad fit for the city, why are they still doing the things that I had put into motion before being terminated? Throughout my employment with the city, my pleas for help to the City Administrator were ignored. He told me almost the exact same thing that the City Attorney told me, which is that I am a white, male, under the age of 40, so I really dont have a leg to stand on up against the Assistant Chief who is a female over the age of 40. This statement was exactly how I was treated, like a second class citizen without any rights. This was in addition to the city bending over backwards to allow the Assistant Chief to get away with anything and everything, which the City Administrator admitted he did in the email explained earlier in this document. In addition, I never once saw City Council show me their full support, which they indicated in my reasons for termination. I was discriminated against by certain City Council members from the onset of putting in my application in for the position. I know that

Councilman Brown Garrett has told others that he did not like the goatee that I had when I applied for the position, which was evident when he gave me a very low score for appearance and the Assistant Chief received a perfect score. I am one of those types of people who take great pride in my appearance and personal hygiene. I am known as one of the best dressers and I a very meticulous person, so to be given a very low score for my appearance was a personal vendetta against and unfair. In addition, Mayor Perry Eichor has commented to Bob Gecy, the owner of the Simpsonville Sentinel Newspaper, and other persons about my involvement with the newspaper. I write articles to educate the public about the dangers of drugs and drug use. Drugs have negatively affected about every household in some way shape or form and are an epidemic that is plaguing America. For these and many other reasons, I spend countless hours researching different drugs of abuse to be able to educate the general public. I know that Perry Eichor does not have an issue with the drug articles, but more with my relationship with the owner of the Simpsonville Sentinel Newspaper. Mayor Eichor also told me on the night I was terminated that another reason for my termination was that I hitched my wagon to the wrong horse. This clearly tells me that because I was not part of their good ole boy system that was willing to overlook certain things, I was being unfairly targeted and eventually wrongfully terminated.) 7. The position of Chief of Police placed squarely on Chief Grounsell responsibility for the management of the department. However, Chief Grounsell, by his own words and actions, has demonstrated his belief that he should have absolute management authority without being subject to the overall direction of the City Council or the City Administrator. (MY RESPONSE: How could this position rest squarely on me, when I was told by the City Administrator that I could not discipline one of my employees that was breaking every rule under the sun. On top of this, once the Assistant Chief filed the false Harassment Complaint against me, I was not allowed to communicate directly with her or even be in the same room as her. Yes, I was told I could not contact her, but she was to still remain as the number two person in the police department. If she was the number two person in the police department under the command structure that I was not allowed to change, it meant that everyone in the chain of command had to go through her to get to me. Since approximately 90% of the police department has made it clear to me, via a letter to city council and/or verbally, that they do not trust the Assistant Chief, this is a recipe for disaster. Have you ever tried to coordinate anything or accomplish something with someone that you were not allowed to initiate any contact with? It is almost impossible! This was an absurd situation that set me up for failure and allowed the Assistant Chief to run wildly violating any rules she wanted. When I brought these violations to the attention of the City Administrator he blew me off. Since she was allowed to undermine anything I was doing without consequences; how can I be held responsible for the entire police department? I could understand if I was allowed to run my department and things went wrong, but that was never the case. Like the others, this reason for my termination is ridiculous when you take into consideration the above facts.

In furtherance of my argument, I was forced to leave the Assistant Chief as the commanding officer of the police department while I was away at the SC Criminal Justice Academy for training. I was told that I had to leave her in charge upon my absence. I did not want to do this and I wanted to leave one of my Lieutenants in charge. This was because both Lieutenants demonstrated more leadership abilities and higher ethical standards than the Assistant Chief. Leaving an untrustworthy person in charge while I am gone was not fair to me, since I am ultimately responsible for the entire police department under normal circumstances. Since I was forced to leave the Assistant Chief in charge against my better judgment, I should not be held responsible for the damage she did in my absence. I came back from training and worked only three days before I was terminated. It proves allegations in my previous investigation were true, since the Assistant Chief was subsequently suspended for lying to the City Administrator. Whenever a police officer lies they are no longer able to be trusted, nor can they do their job as a police officer. In a command staff position, just like any other police position on the force, a person must be completely trustworthy. The Assistant Chief is not honest or trustworthy, which I have tried to tell everyone all along. Now, I am proven to be right and the city needs to correct my wrongful termination immediately by reinstating me. I have never asked for absolute management authority of the police department without interference from the City Administrator or City Council. This claim is completely false! I have asked that the City Administrator stop micromanaging me. I did this because the City Administrator has questioned every single decision I have made during my time as the Chief of Police. On top of this the Assistant Chief went running to the City Administrator, without notifying me, every time something took place that she did not like. Jumping above me in the chain of command is insubordination. An example of this occurred during the termination of a police officer with the Simpsonville Police Department. He/she had been the focus of multiple prior lawsuits and had been terminated in at least one circumstance. For example, one of the many examples of this is in the termination process of a Police Officer with the Simpsonville Police Department. The City Administrator did not question the hiring of this police officer, but he questioned the hiring practices of every single certified police officer applicant that has put in an application with the SPD since I have been the Chief of Police. How fair is this compared to the way the City Administrator has treated the previous Chief of Police? It was not fair at all. The underlying reason that the City Administrator did not question the hiring of this officer is because the Assistant Chief recommended him as well as the Fire Chief. We now know because of the recent suspension of the Assistant Chief and the Fire Chief for a violation of the romantic relationship policy and for lying about it, that the Fire Chief and Assistant Chief are together as a couple. Since they were caught lying to the City Administrator, this would lead a reasonable person to

believe that they would be willing to lie for one another or someone else. This is another reason not to believe anything that they say. In furtherance of my argument, I have one more example I would like to share. When I decided that I wanted to restructure my police departments command staff while the Assistant Chief was out on her 15 day retirement break; I met opposition from the City Administrator. I knew that the City Administrator was being difficult to work with, so I went and met with some of the council members before I told him what I was going to be doing to my command staff. I got the blessing from the majority of council members for my department restructuring. I was told that if the City Administrator tries to deny me the ability to restructure my department to stand my ground. I brought the City Administrator a copy of the new organization chart with a brief explanation of the changes. He looked over it and acted as if he approved it. I was surprised, but happy that he did not attempt to change anything. A couple of days before I initiated this plan I notified my two Lieutenants, who were going to be promoted to Captains, how things would be done. The day before I implement this plan the City Administrator calls me into his office. He then proceeds to tell me that he has denied my proposal. I tell him that I did not give him any proposal, and that I was only keeping him advised of what I was doing with the police department. He tried to bully me into not making any changes and I stood my ground, but was respectful when I did this. I left his office and then he immediately reached out to the Mayor and started saying how I was disrespectful towards him. This was a complete fabrication of the truth, but he obviously thinks that if we disagree I am doing something wrong. At this point I had no knowledge of the EEOC complaint filed by the Assistant Chief, so I did not understand why he was in opposition to my changes. I had compromised and was even going to allow, against my better judgment, the Assist Chief to remain on my command staff. The City Administrator never told me about the EEOC complaint being a reason that he denied the changes I was going to be making. Since he could not tell me a good reason as to why he fought me on these changes, and I thought I had city councils approval, I stood my ground. If I would have known about the EEOC complaint I would have taken a different approach. As a matter of fact, once I found out about it I immediately called the City Administrator and apologized. For some odd reason I am now being accused of demanding that I wanted absolute management authority without being subject to overall direct of City Council or the City Administrator. I have never said this, nor will I ever say this. I understand how the city works and that I have to work closely with the City Administrator and City Council. For this reason, the claim here is absurd. On top of this, after I stood my ground to make the command staff changes, the Mayor completely abandon what he told me in private. In private the Mayor said that he supported this decision, but after I stood my ground he flipped the script and blamed me for not being willing to work with the City Administrator. This really caught me off guard, but showed the untrustworthy nature of the Mayor.)

a. When asked for reasons why he refused to interview applicants for the police department who were already certified, his response was that he was being micromanaged and harassed. (MY RESPONSE: I admit I have indicated that the City Administrator is micromanaging and harassing me. I have said these things separately at different points to the HR Director. The HR Director blew off these complaints and did not act as if she cared at all. I feel my words were taken out of context, but a section of this statement is actually partially true. Let me explain my answer. The City Administrator has micromanaged me on more than one occasion. One example is when he intervened himself in the grievance process of the police officer that I terminated for repeatedly violating innocent peoples 4th Amendment rights. After arguing to me that he had the right to do the grievance himself at City Hall and telling me I was wrong for 2 days, he eventually changed his mind. After I showed him policies and proved to him that he had no right to intervene in our police department grievance process, he backed off and told me I was correct. This was not until he had caused me lots of issues and stress thinking he and the Assistant Chief were teaming up against me to allow an employee I terminated to come back to work. This really scared me because we were blessed that none of the people that this officer had violated their rights has filed a civil suit against the city. The City Administrator acts like he is always looking out for the tax payers money, but that is only if it promotes his personal agenda. I know that the Assistant Chief and City Administrator conspired behind my back to fight me on this officers grievance because the Assistant Chief fought against me with his/her termination. She also advised me that she spoke to the City Administrator about this process, without asking for my permission and before jumping over me in the chain of command. In addition, the City Administrator advised me that this was brought to his attention by the Assistant Chief. NOTE: The Assistant Chief was good friends with this police officer and with his/her background check alone he/she should not have been hired. He/she was hired because the Assistant Chief and former Police Chief were willing to overlook all of his/her baggage. He/she is the same officer mentioned earlier in this document who was named as a party in two prior law suits for his/her conduct as a police officer. In late December of 2012, while I was at the police academy for training, I was contacted by two separate persons at the police department who each explained something that the Assistant Chief was doing that they found weird. These two separate people advised me that the Assistant Chief was all of a sudden going through all of the police department applicant files. This was unusual and she had no reason to be doing this since we had already interviewed and selected the persons that we were going to hire for the two vacant positions. Not knowing why she did this I made a mental note of this, but could not do anything because looking at the files is not a

violation. I did not understand why she was doing this until late that same evening when I received a phone call from City Administrator Russ Hawes. He kept me on the phone for about an hour interrogating me about every police department applicant and why I made every decision that I made. He tried to say that I should have offered the vacant position to one of the certified applicants that put in for the position. He tried to say his primary reason for this is to make sure it does not cost the city any extra money to send these new police officers through the police academy. I informed the City Administrator that it did not cost the city any extra money to send someone through the police academy, other than the cost to pay their regular salary while they are away at training. I learned later on that the City Administrator intentionally took what I told him and lied to every city council member and the city attorney. He lied by telling them that it cost an extra $6,000 to send each new police officer through the police academy, which was on top of paying their salary during training. This is absolutely false! I know that the City Administrator knew better than this because I specifically told him about this process. I did not know that he was conspiring against me by spreading this lie until I was told by one of the city council members. This was just one of many attempts by the City Administrator to discredit me and allow himself a reason to come after my job. He eventually succeeded by convincing council member of other lies and I was wrongfully terminated without cause. It should be known for my grievance that the City Administrator questioned every step of the hiring process I conducted for new police officers but he never did this to the old Chief of Police. The City Administrator admitted this in an email correspondence with Councilwoman Sylvia Lockaby around December 20, 2012. The reason I say this is because I was brand new to the police department and was in a rush to hire at least one police officer for a vacancy that had been there since before I got started at the PD. Since I was about to leave out of town for 6 weeks of training, I did not have time to change the hiring process. I know that the police department is state accredited and the hiring practices have been approved through the CALEO standards. With that said I used the existing practices and allowed the Assistant Chief to be involved in the entire process just like she had been under the previous Chief of Police. This is why I found it weird that the City Administrator tried to make me change the process and hire someone other than the candidates that scored number 1 and number 2 overall in our selection process. The even more significant part about this is that the Assistant Chief was the one that entered all the scores into the computer program that she had for this process. The program then spits out the police officer candidates in descending order according to overall scores. I did not deviate from the scores and wanted to hire the number one and number two persons on the list. I felt this was the most unbiased and fair way of conducting the hiring process.)

b. He accused the City Administrator of being in a conspiracy. (MY RESPONSE: Based upon what I have documented here and for many other instances for which I have not included, it would lead a reasonable person to believe that I am being plotted against by the City Administrator and Assistant Chief. The City Administrator admitting that he allows the Assistant Chief to get away with many different types of violations. On top of this, the City Administrator micromanages and scrutinizes my every move only further solidifying why I thought this way. My definition of a conspiracy is two or more persons coming together for a common purpose, which is usually illegal, unethical or just wrong. Knowing my definition of conspiracy, it is clear that the Assistant Chief and City Administrator did conspire against me to terminate my employment. I was correct about this on December 28, 2012, when I was fired based upon things that the City Administrator and Assistant Chief had said about me. It is evident now, that I was correct since I was wrongfully terminated without cause or without a thorough investigation being conducted. With that said, why is it that I was never given a warning in writing about things I was allegedly doing wrong? Fair is fair, but I was not treated like every other employee. Again, I need to mention how ironic it was that the City Administrator started approving everything I wanted approval on for approximately 2 months within less than 24 hours of my termination. This proved to me that the City Administrator knew something was going to happen and he wanted to make himself look good and as if he was working with me before I was terminated. This was hardly a coincidence and is proof that the city violated Section 30-4-70 of the Public Officials Guide to Compliance with South Carolinas Freedom of Information Act by circumventing the system and conspiring with someone else, city council or the mayor, to get me terminated. How else would the City Administrator have known to all of a sudden approve things he had been blowing off for up to two months? Before I started my first day as the Chief of Police, but after I was selected by City Council as the next Chief, the City Administrator and Assistant Chief tried to stop me from getting hired. They forced me to go through every step of the hiring process as if I was a regular rookie police officer being hired in off of the street. It is my understanding that it is not normal protocol to have a Police Chief take a polygraph or psychological examination after being appointed. My hiring process was initially being handled by the Assistant Chief until I complained to the HR Director. I felt it was improper to have the person that I beat out for the job doing things in furtherance of the selection process. Eventually everything was handled at City Hall and away from the Assistant Chief. The reason I did not want the Assistant Chief involved in this process is because she was one of the top two finalists for the position of Chief of

Police and she was very upset that I was hired instead of her. She demonstrated this the night I was announced as the selection by city council for the Chief of Police. On this evening, her and the previous Chief of Police stormed out of the City Hall without congratulating me. It was not that they were in a hurry or wanted to avoid the media, which is what the Assistant Chief said during our 4 hour meeting, because about 30 minutes after the meeting she was standing out in front of her car talking to someone. I walked very close to her and she looked at me with an evil glare, but never said congratulations. She made this clear in her actions here and subsequently that she was not a fan of mine. In addition, I have been told by a council member(s) that the Fire Chief, who is now confirmed as in a relationship with the Assistant Police Chief, intentionally spread rumors about me to people at city hall and in the general public. I was advised by one of these employees at city hall, who wished to remain anonymous due to the high potential for retaliation after speaking out, that they told him/her I beat my wife and was bankrupt. These are two things that are outlandish allegations, very slanderous and completely false. For some reason the city of Simpsonville said they investigated this, but did not discipline anyone for making these false and hurtful allegations against me. It seems as if the city has a double standard and only comes after the people that are doing the right things, but allows those who repeatedly violate the policies and/or laws to be able to get away with things. The only reason that the City Administrator recently suspended the Assistant Police Chief and the Fire Chief for lying about their relationship was because proof came from a source outside of the city. This put them in a predicament and forced them to have to act. I provided the City Administrator with statements from police officers who witnessed them acting inappropriately on duty and gave a photograph supporting this inappropriate relationship, but nothing was ever done with my complaint. As a matter of fact, my last day on the job I emailed the City Administrator and HR Director to inquire if the Assistant Chief had any disciplinary actions that were put in her personnel file over the last year. I did this because I was working on the Assistant Chiefs annual performance evaluation and had a need to know this information. They both advised me that nothing was in her file. I then asked if there was anything pending. I specifically asked about the 26 or 27 page document with supporting statements, making it approximately 50 pages, and they all of a sudden stopped answering my emails. This was a time where their silence spoke volumes. It was evident to me that they had taken the approximately 50 page document that I spent many hours putting together and made it disappear. This only further leads to my claims of a conspiracy that was against me. To further prove that I was being plotted against and micromanaged I need to discuss the following: The HR director and Assistant Chief were conducting an investigation about allegations of a violation of the romantic relationship policy with two young police department employees. They started this investigation without my knowledge.

I found out about it after the HR Director had questioned one of my officers. This is not the normal protocol for these types of investigations because the Chief should be notified of any investigation involving his employees. After a discussion with the HR Director she apologized to me for violating the normal protocol. I can say without a doubt, that the Assistant Chief should not have been involved in this process because she was actively violating this policy herself. The Assistant Chief was also vocal about going after these employees, which makes her a hypocrite. I voiced my opinion about this problem to the HR Director and was chastised and later ignored. I originally reported the Assistant Police Chief and Fire Chiefs violation of the Romantic Relationship Policy to the City Administrator, HR Director and Mayor in writing, but nothing was done. After my termination it was confirmed that the Assistant Chief has been in violation of the romantic relationship policy of the city with the Fire Chief. In addition, they lied about this relationship. It is bad enough to be in violation of the romantic relationship policy, but to lie about it is grounds for immediate termination with any employer. I was terminated because I was not a good fit, so lying should be an easy and quick decision to terminate at the January 8, 2013, City Council meeting. If these employees are lying about the above relationship, what else are they lying about? With that said, any reasons for my termination based upon any information provided by the Assist Police Chief or the Fire Chief should automatically be suspect and corroborated by a separate and independent source. This is the right and logical thing to do because just about everything listed as a reason for my termination has something to do with the Assistant Chief. Taking that into consideration, the reasons for my termination are now invalid because of an untrustworthy source. In addition to the above, I have repeatedly been blamed by the City Administrator for releasing certain things to the media. For example, I was blamed for releasing a letter to the media that my officers wrote and gave to city council. Even though I was chastised for it by the City Administrator, I know for a fact that I did not do it and the city has no evidence to prove otherwise. This was just one small part of the harassment that I received. It is unfortunate that the Mayor is not man enough to speak out and admit that he said the things he was quoted on by the media. Only a coward hides behind his own silence. Since the Mayor lied about what he said, I was blamed for every media story that made the city shine in a negative light. At first the Mayor led the media to believe that the officers support the Assistant Chief and not me. Once someone produced the letter to the media and it was printed, the truth was the opposite of the way the Mayor wanted the story to read. In turn, this made the city look bad because they were doing me and my officers wrong. Sometimes the truth hurts!)

c. The Chief did not limit his criticism to communication with the City Administrator. In correspondence with the HR Director, after the conference where he claimed to have set aside the past, he contended that he was being harassed and bullied by people with bad intentions. (MY RESPONSE: The HR Director was the one handling the investigation of the harassment allegations that the Assistant Chief made against me. For this reason, I also included her in any complaints I had about the Assistant Chief after we had our 4 hour meeting. As I had discussed earlier in this document, the City Administrator admitted that he has allowed the Assistant Chief to be insubordinate and violate policies and procedures on numerous occasions. This is not only unfair, but I felt I was being treated inappropriately and allowed to be bullied and harassed. I was told that when I have a complaint of harassment or something else going wrong in the workplace that I that I needed to report it to the HR Departmentwhich is what I did. By the looks of this being used against me, I can reasonable conclude that this is only corroborating evidence of how the HR Director brushed off my complaints. If they are using it against me to report violations that occurred after the 4 hour meeting, this only solidifies my claim that I was treated unfairly. I find it unfair and wrong that I was blown off by the HR Director when I complained to her that both the City Administrator and the Assistant Chief were harassing me. The HR Department is supposed to be a place where employees feel comfortable going to with sensitive issues, but that is not the case in Simpsonville. It also has not been the case for many years leading up to the new HR Director taking her job just before I was hired. The previous Police Chief and the former HR Director allegedly had a long term affair, which was later corroborated when they decided to get married. For this reason, the police department has never had an outlet to go to for grievances involving the Assistant Chief of former Chief. If they complained to the HR Director, she would eventually tell her lover, the former Police Chief. So, the city has always had issues under the watch of the City Administrator and my story is nothing new.) 8. The Chief of Police, as with every Department Head, must demonstrate an ability to work with the City Council, the City Administrator, and the HR Director. Chief Grounsell has made it clear that he will not or cannot work with any of them. (MY RESPONSE: I understand that I need to work with all of the above stated persons. I have demonstrated that I can work with all of them, but consistently the Assistant Chief has not been willing to work with me. You quickly forget that the Assistant Chief told me early on that her and I were not on the same page and we never will be. I truly believe she meant this when she said it and her actions have proven I was correct. I have morals, values and ethics, which are things she does not hold near and close to her. She proved this recently by lying to the City Administrator, which resulted in her being suspended indefinitely. Forcing this person to be my second in command is uncalled for and proves the City Council and City Administrator

are not willing to work with me. Cooperation is a two way street. The City Council and City Administrator have never demonstrated that they would give me an opportunity to run my department. This is evident by the way I have not been allowed to make any changes since I started as the Chief of Police. What you are asking me to do is like saying if I am the new President of America, I have to keep the previous Vice President in place from the previous administration. Of course, this makes absolutely no sense and sounds ridiculous, because it is. In this instance you can no longer use the EEOC as your excuse for not doing anything. It is evident now with the recent suspension of the Assistant Chief that I was being lied to when told I could not discipline her. Because of this you have allowed the Assistant Chief to have free reign to destroy everything about the department that I was working so hard to change. The mismanagement on behalf of the City Administrator and his constant lies have not allowed me to have a positive relationship with him. As for the City Council, those who chose to speak to me quickly learned that I am a good and honest guy. Even one of those who voted against me on December 28, 2012, later admitted that I would have made a great Chief, if I were given the chance. As for the HR Director, things went well in the beginning, but when I disagreed with things she was doing she turned against me. It was evident that she was unprofessional because I have been told by another city employee that the HR Director has called me arrogant behind my back. She sadly mistakes my confidence for arrogance because I called her out on doing her job in violation of SC Municipal Code rules and regulations. I never reported this to anyone else because I was fired immediately after this occurred. Since the document for which I am commenting about was drafted and signed on December 31, 2012, the HR director is holding a grudge and coming after me personally.) Pursuant to the Citys Probation Policy, the probationary phase of an employees employment is to determine whether the employee is suited to the job. The Police Departments SOP Manual also states: All new employees will be considered to be on probation for at least the first six (6) months of their employment. This trial period is actually an extension of the selection process and is designed to provide the new employee with the opportunity to demonstrate that he/she is well suited for the job and that the job is well suited for him or her. (MY RESPONSE: I thought that this is what the extensive Police Chiefs vetting process did. I have no problem with going through a probation period, but I do have one with not being given an opportunity to do my job and that being used against me. I was only officially on the job for about 40 work days. All of the other days I was out of town for training. About one week before I was terminated, the City Administrators comments to Councilwomen Sylvia Lockaby in an email, leads a reasonable person to believe I was never given a fair chance with such a short amount of time on the job. Please see the below quotes which were taken out of an email communication on December 20, 2012 between Councilwomen Sylvia Lockaby and City Administrator Russ Hawes.

Councilwoman Sylvia Lockaby asked the following question: What issues do you have with Chief Grounsell? Russ Hawes responded with the following answer: I have seen very little of the Chief because he is away at the academy. I look forward to his return. (MY RESPONSE: I agree that I have not had sufficient enough time on the job to prove myself, so it is unfair to prematurely cast judgment and say I am not a good fit for the department. This is especially true knowing how the vast majority of the police department supports me and the direction I was trying to take the department. They proved this in the letter that they sent to city council in October of 2012. My overwhelming support by the citizens of Simpsonville was proven in my meet the chief night and recently by the public out crying of support for me on social media networks.) Councilwoman Sylvia Lockaby asked the following question: Is he doing his job? Russ Hawes responded with the following answer: He is clearly trying to do what he can while away. (MY RESPONSE: No further comments needed, because I was trying my best even though I was dealt a bad hand.) Councilwoman Sylvia Lockaby asked the following question: If not, in what area is he lacking? Russ Hawes responded with the following answer: It would be difficult for me to say at this point. (MY RESPONSE: If the City Administrator, who is my direct supervisor and at work every day, cannot tell if I am doing a good job or not because I havent been on the job long enough; how can 4 city council members and a mayor have made this call on December 28, 2012. Again, I was wrongfully terminated and should be reinstated immediately.) (MY RESPONSE: In addition to the above, Councilman Dr. Welborn stated, This is a very upsetting situation." "I'm not happy with how this has turned out. I think he would have been a good police chief. I'm not very happy with my position on counsel. Maybe things could have resolved themselves in time."---quotation taken from Fox 21 interview off camera Councilwomen Sylvia Lockaby and Geneva Lawrence both claim that I would have been an exceptional Police Chief if I was allowed to do my job. Due to the EEOC complaint and the favoritism showed toward the Assistant Chief by the City Administrator out of fear of a lawsuit, I was not given a fair shot to do my job. I was not even given enough

time to be fairly evaluated, which was exactly what City Administrator Russ Hawes said in the above quotes.) For sworn employees who are not currently certified, the probationary period shall end not sooner than six (6) months after the completion of the law enforcement training at the Academy. As a result of the above as well as other issues, it is unfortunate that Chief Grounsell is not a good fit for the position of Chief of Police. Therefore, his position with the City is being terminated immediately. (MY RESPONSE: Based upon the above quote, I was only 3 days into my probationary period. Is that enough time to determine if I am a good fit for the department or not? What are the other issues that are so important that you make reference to them, but failed to let me know what they are? Saying I am not a good fit after approx. 40 days that I officially was in the office is stretching things. If I was given 90 days of officially being on the job and away from training, that would allow you to make a better judgment call. To say I am not a good fit is saying I havent done anything wrong and I was fired just because. Since becoming the Police Chief I have been responsible for the following positive changes: (1) getting SC Criminal Justice Academy approval to become a Reserve Police Officer agency. This will allow us to have extra manpower without the extra cost to the tax payers. This year I had one person that was already a certified reserve police officer for another agency apply with Simpsonville PD. This individual brings a lot to the table and speaks 7 different languages; (2) after the recent school shooting in CT, we have developed a program where one of our officer goes around to private daycares and churches to discuss with them the options available when a gunman enters their building; (3) I had the police officers draft and design the new police car decals and new police patches. These patches are very symbolic and the decals are a much more modern scheme than before. This was one way that I had the officers buy into the program and put a new face on the new and improved Simpsonville Police Department; (4) we started having monthly meetings for the victims of criminal domestic violence cases, to walk them through the entire process; (5) I opened back up the relationship with the surrounding jurisdictions, who did very little work with the Simpsonville Police Department because of the former Chief; (6) I have started conducting a cross-training program within the police department. This allows officers to explore different career path options available to them at the police department; (7) I have opened up a great working relationship with the Sheriffs Office and it has allowed us to start working together to form a Narcotics task force, which was recently able to bust one meth lab in our area; (8) we were in the developmental stages of starting a police mentoring program, an inhouse accident review board, a Community Action Teametc. As you can see I have been able to do many different things in such a very short period of time, so to say that I was not a good fit is confusing. What must they be looking for if I was not a good fit? In conclusion, it is evident by the document that was signed 3 days after my termination, the laws that were violated in this process, and the overwhelming outcry for my reinstatement as the Chief, that you only have one choice. Your choice is to admit you made a mistake and correct

the wrong that was done. I was fired on the same week as Christmas, my insurance was canceled a few days later and now my wife, 8 year old, 5 year old and 3 year old are at home without insurance coverage and I have no income. I was never warned of anything I was doing wrong in writing. On top of this the basis for the majority of this termination is a result of actions committed by the Assistant Chief, who is currently suspended for being caught in a lie. This lie needs to be taken into consideration when making your decision because you took what she told you on face value without investigating and corroborating evidence. You are given one opportunity to fix things before they go too far, the city is in too deep and they have to take the hit civilly for their intentional wrongdoing. With the suspension of the Assistant Chief and Fire Chief, all I have to say is you were warned. Now it is your turn to do the right thing.) Respectfully, DDDDDDDDDDDDDDD KKKKKKKKKKKKKKK Keith P. Grounsell