PasToRI|KRANS farTonners at Uk ‘Tetri L. Pastori Cooma Set tnastori@pasigrikvans.com sam 203 camo gti aso ws wanm QECVED) essen APR 18 2018 Office of the City Council By Electronic Mail Easthampton, MA Monica Kane, Personnel Director City of Easthampton Municipal Building 50 Payson Avenue Easthampton, MA 01027 ie: Investigation into Allegations Raised by Michael Tautznik Dear Monica: Please excuse the formality of this engagemen: letter. I am writing confirm that tke City of Easthampton (“Easthamptor”) has requested Past |Krans, PLLC ("the firm") to conduct an independent. attorney investigatio the allegations raised by Michael Tautznik concerning the existence of a “hi work environment” at City Hall, including allegations of “damage to moralk “disrespect,” as outlined in his letter to the Easthamr ton City Council recei March 12, 2018. During the course of the investigation, I will report to you 0 ni into stile "and ed directly. Aswe discussed, my plan is to commence the investigation by contacting Me. tions and ‘Tautznik to obtain a better sense of the nature and the basis of his allega proceed from there. I appreciate your confidence in my firm and I am pleased to accept tl engagement subject to the terms set forth below. As you kaow, I bill by the hour for my time, in venths of hours, at a fi is ced charge per hour. My hourly rate is $360.00. If the se:-vices of other attorneys or paraprofessional from my firm are required, you will be charged at their respective hourly rates for their time. Currently, Petar Leonard s rate is $230.00 and Krans’ rate is $365.00. HeatherMonica Kane, Personnel Director March 30, 2018 Page 2 Easthampton will be billed monthly for my professional time and effo} Monthly statements will also include any cut-of-pocket expenses and disburt t. ements made on its behalf such as photocopies, postage, delivery service, transportation, transcripts, computerized research charges and filing or recording fees. Mo invoices will be submitted to your attention, for payment by Easthampton. event that you have questions or comments about any bills or services, I re that you advise me of them promptly. It is my goal that you be fully satisfi my services as well as the cost thereof. The scope of this engagement may change if you ask me to provide dil or additional services, and if I agree to provide them. If the scope of the engagement changes, the terms set out in this letter will apply to the differ expanded engagement unless we enter into a further written agreement mo or superseding this one. My engagement may be terminated by you upon written notice to me me upon writtea notice to you. If the engagement is terminated for any re: Easthampton will, of course, remain obligated to pay for any fees and expe incurred before the termination date. Unless I agree to render additional s for you, this engagement will terminate upon my firm sending its final stat for services rendered in this matter. Any statement submitted to you under this engagement letter is upor receipt. You should be aware that I may stop work and terminate the enga in the event the fees and expenses invoiced to you are not paid. As you know, investigations can develop in une Sent: Wednesday, April 11, 2018 12:36 PM To: Terri L Pastori Subject: Re: Easthampton: Follow Up Hello Teri, IMy letter to the City Council was based solely on the Mayor not following the required procedures contained in the Easthampton Home Rule Charter. ‘To my recollection, the word hostile was not used by any errployee to describe their concern, The words disrespect and ‘morale did come up in conversation but my impression was [and is) that these words were not used in the context you refer to in your email ‘Since my concern is not based on actions taken against legal y protected categories, as you phrase it, | would suggest that you seek direct employee input about their interpretation of the workplace atmosphere as it relates to the state and federal laws limiting your review. Sincerely, Mike Tautznik On Wed, Apr 12, 2018 at 9:11 AM, Tere L, Pastor wrote: | Good morning Mike: ‘Thank you again for your time in sitting down with me on Monday. It was a pleasure to meet with you and learn more about Easthampton and your concerns. I appreciate your generosity | with the time you spent answering my questions concerning your letter to the City Council sent | in March 2017. As I review my notes from our discussion, I have one follow up for you. | Based upon our discussion, your concerns outlined in the letter concerning “hostile work environment,” “undue damage to morale,” and “disrespect” are based upon Mayor LaChappelle’s alleged failure to follow the process outlined in the City Charter in making staffing changes, and not based upon any legally protected category (e.g. race, color, religion, age, familial status, national origin, immigration, gender, gender identity or expression, sexual orientation, genetics, ancestry, disability, or veteran status). It is also my understanding that the letter expressed | Your interpretation of the nature of the current work environment based upon the employee concerns you have heard ~- in other words, no one has stated to you that they are being subjected to a “hostile work environment,” experiencing “undue damage to morale,” or “disrespect.” Those are conclusions you reached after hearing employee concerns about staffing 1changes. If my impressions are off base, please let me know. If you would prefer to call me, my contact information is below. Many thanks, Terri L, Pastori Attomey Pastori | Krans, PLLC Corporate Center at Horseshoe Pond 70 Commercial Street, Suite 203, | Concord, NH 03304 DD 603.369.4432 " ¥.608:369.4769 www. pastortkrans.com ' PasTori|KRAN