Case 1 :07—cv—00228-GI\/IS Document 66 Filed 07/29/2008 Page 1 of 3
Jejjiey D. Hill v. New Castle County, et al.
C. A. No. 07-228 (GMS)
Plaintiff s Answering Brief In Opposition Of Defendants’ Motion For Summary Judgment
Case 1 :07—cv—00228-GI\/IS Document 66 Filed 07/29/2008 Page 2 ot 3
W · l Case 1:07-cv-00228-GMS Document 4241 I Filed 07/15/2008 Page 2 of 3
. . I NEW CASTLE COUNTY
DEPARTMENT OF PUBLIC SAFETY
MEMORANDUM 9
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_ " TO: CAPTAHW MARK HITCH . zi Q NF
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FROM: crt. Jnrrnsr n. init;. #2390 its ile I, â€â€™ MJ
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SUBJECT: HARASSNIENI AND THREATENING DISCIPLINE [ie it
- . ‘ - DATE: DECEMBER 15, 2005
_ __ Sir, _
C Over approximately the past year writer has experienced some harassing and threatening
. behavior by his supo1vis0r`Sgt. Nicole Hyden.This situation became hostileon 10-04-05
. - when Sgt. Hyden threatened writers position as a Mounted Police Omcer. ·
· On date 10—04-05 Sgt.Hyden requested a meeting with writer in the mounted offices -
' .- This meeting was taking place one day after the unit had responded back trom the national
_ _polie.e mounted competition. During this meeting Sgt. Hyden immediately began telling
writer he had not done what she requested of him during the competition. This was in l g
· · — reference to the horse writer was using for the competition. (Tonl
- writer had not cleaned the horses sheath and that could have cost us the competition. Writer
` explained that this was an oversight and due -to the numerous things writer was preparing
- I for it had slipped his mind. Sgt. Hyden then stated that she was going to make writer clean
the sheath of every horse in the barn but changed her mind. Writer then reminded Sgt.
Hyden that he had taken Erst place in the competition.and‘ was not sure what she was so
angry about. Sgt. Hyden then began telling writer that his statistics in the unit were low and
that was also a problem. n . I
Writer then asked Sgt. Hyden why she was bringing theses issues up just a few hours alter
returning nom the competition. Writer felthe performed extremely well placing C
A . Hrst andesecond in two of three categories against riders nom all over the country -
and Canada. Writer further asked Sgt. Hyden was she considering discipline towards him. ° .
Sgt. Hydens response was that you saw what happened to Dave Devine he got transferred
out ofthe parks./mounted unit. Writer then told Sgt. Hyden he felt she was singling him out _
for some reason and was very disappointed that she would not only threaten his position but
. also that she had not congratulated him or stated one kind word about his perfonnance
at the competition. Sgt. Hyden became veryagitated by words from writer at which
time the meeting was ended.
_ Writer feels that for some reason Sgt. Hyden does not like him on a personal or professional
p L_ _ . level and has made it very clear on several occasions over the past year.
NCC2276 .
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Q ` Case 1:07·cv—-00228-GI\/1S Document 42-1 1 Fited 07/ 1 5/2008 Page 3 of 3
_ Z` ·Writer is requesting a meeting to further elaborate on some of the issues that have been t
· . _ " occurring over the past year. `
. Writer did tile a formal complaint with Capt. Setting on l0-26-05 who was the mounted
commander at the time.
Wiiter wants to state for the record that he is dedicated te the mounted patrol as can be
attested to in his personal accomplishments in this position.
g NCC2277