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2/17/72 <br />213 <br />(b) The Board of Public Works and Safety permit and <br />allow within a reasonable time prior to hearing, <br />Maurice Van Woods to subpeona witnesses to tes- <br />tify on his behalf by using the spbpeona power <br />of the Board of Public Works and Safety. <br />(c) Maurice Van Woods, by his attorney, have the <br />right to cross-examine each and every witness <br />testifying against him and an opportunity to <br />rebut their allegations by receiving within a <br />a reasonable time prior to the hearing a list of <br />the witnesses.to be used by the Chief of Police <br />in substantiating his charges. <br />(d) The Chief of Police, within a reasonable time, <br />prior to the hearing, produce to the attorney <br />for Maurice Van Woods a copy of any and all <br />documents which will be used against him. <br />(e) Maurice Van Woods be allowed any and all other <br />eft <br />procedural rights afforded to him by either the <br />T-I <br />Constitution of the State of Indiana or the <br />Constitution of the United States of America, or <br />by any laws, rules, or regulations; and <br />(f) The Board of Public Works and Safety, after <br />hearing, give to Maurice Van Woods a written <br />copy of findings of fact and conclusions of <br />law, including any and all action proposed to <br />be taken by the Board of Public Works and <br />Safety, if any <br />It is not the intention of this letter to threaten the Board of <br />Public Works and Safety in carrying out its assigned duties. We <br />are trying to clear up some of the ground rules prior to the <br />hearing. <br />Thank you, <br />Sincerely, <br />JJR:bak <br />enclosure <br />s/ John J. Roper <br />The Answer, Special Answer and Motions in Response to the charges <br />against Patrolman Maurice Van Woods were then read by the Chairman <br />as follows: <br />CITY OF SOUTH BEND ) TO THE BOARD OF PUBLIC WORKS <br />,) SS: AND SAFETY OF THE CITY OF <br />STATE OF INDIANA ) SOUTH BEND, INDIANA <br />ANSWER, SPECIAL ANSWER AND <br />MOTIONS IN RESPONSE TO THE <br />CHARGES AGAINST PATROLMAN <br />MAURICE VAN WOODS. <br />1. <br />ANSWER <br />Comes now, John J. Roper, the attorney for Maurice Van Woods, and <br />for answer to charges against Maurice Van Woods, alleges and says: <br />1. Maurice Van Woods hereby denies each and every material <br />allegation contained in Count 1, County 11, County III, -and <br />Count 1V. <br />Wherefore, Maurice Van Woods prays that the Chief of the <br />South Bend Police Department take nothing by way of his charges, <br />and for any and all other proper relief. <br />s/ John J. Roper <br />