They work closely with numerous subdivisions of that agency, including the Department of Conservation and Recreation. They are assigned to oversee the numerous parks, waterways, greenways, landscapes, seashores, lakes, ponds, reservoirs and other location of the Commonwealth.

oneself and others by minimizing personal contact with environments where this potentially deadly virus may be transmitted; WHEREAS, on April 2, 2020, in order to limit all non-essential person-to-person contact and non-essential movement outside the home as a means of combatting the spread of COVID19 within the Commonwealth, I issued COVID-19 Order No. 22, which closed public parking spaces and facilities at State beaches, prohibited parking on Department

The purpose of the detail was to provide traffic control in connection with a beach nourishment project funded by the Massachusetts Department of Conservation and Recreation (DCR). The project involved the movement of sand and rocks to Winthrop beach. The detail ran from 7 A.M. until 3 P.M., and the detail officer was to receive a one-hour lunch break and bathroom breaks as needed.

On or about November 24, 2014, Romeo was assigned to work a detail with the Department of Conservation and Recreation (DCR) from 7:00 AM until 3:00 PM. Romeo had completed this same detail on other occasions. The Union argues that DCR representatives told Romeo that he only needed to be on call and available in case he was needed during his detail.

On or about November 24, 2014, Romeo was assigned to work a detail with the Department of Conservation and Recreation (DCR) from 7:00 AM until 3:00 PM. Romeo had completed this same detail on other occasions. The Union argues that DCR representatives told Romeo that he only needed to be on call and available in case he was needed during his detail.

Provide notice to the following of any alterations or relocation of a watercourse and ensure that such activity does not diminish the flood carrying capacity of such watercourse: Adjacent Communities 28 Section 15.09 NFIP State Coordinator Massachusetts Department of Conservation and Recreation 251 Causeway Street, Suite 600-700 Boston, MA 02114-2104 NFIP Program Specialist Federal Emergency Management Agency, Region I 99 High Street, 6th Floor Boston

Department of Conservation & Recreation, 21 MCSR 23 (2008); Rainville v. Massachusetts Rehab. Commn, 19 MCSR 386 (2006), citing. OBrien v. Massachusetts Rehab. Commn, CSC Case No. G-1883 (1991).

The Union is the exclusive bargaining representative for all rangers employed by the Commonwealth in the Department of Conservation and Recreation (DCR). Prior to February 2017, ranger vehicles were equipped with sirens and red and blue lights. In or about January 2017, the Employer began removing the sirens and red and blue lights from 22 ranger vehicles.

Department Chilmark Police Department Clark University Clarksburg Police Department Clinton Police Department Cohasset Police Department College of the Holy Cross Colrain Police Department Concord Police Department Conway Police Department Cummington Police Department Curry College Dalton Police Department Danvers Police Department Dartmouth Police Department Dean College Dedham Police Department Deerfield Police Department Dennis Police Department Department

Department Chilmark Police Department Clark University Clarksburg Police Department Clinton Police Department Cohasset Police Department College of the Holy Cross Colrain Police Department Concord Police Department Conway Police Department Cummington Police Department Curry College Dalton Police Department Danvers Police Department Dartmouth Police Department Dean College Dedham Police Department Deerfield Police Department Dennis Police Department Department

Based on the above, the Respondent respectfully requests that a finding of no probable cause be entered and that the charge be dismissed in its entirety Respectfully submitted: Department of Conservation and Recreation its7Attorney: /s/Patrick Butler Labor Counsel Human Resources Division One Ashburton Place, Rm. 211 Boston, MA 02108 ph: (617) 878-9785 fx: (617) 727-1477 Patrick.Butler2@state.ma.us al Dated: June 14, 2018 Page 14 of 15 CERTIFICATE

Simmons v Department of Conservation and Recreation, 25 MCSR 249, 252 (2012) (citing Stone v. Univ. of MD. Med. Sys. Corp., 855 F.2d 167, 175 (4th Cir.1988)(establishing the legal standard to determine resignation voluntariness)(cited by the First Circuit of the US Court of Appeals in Monahan v. Romney, 625 F.3d 42, 47 (1st Cir. 2010)).

He has been employed seasonally at the MA Department of Conservation and Recreation in the past, as well having been employed in construction. He volunteers as a hunter education teacher at a local fish and game club, where he teaches children the basics of hunting. The Appellant provided the MEP with positive personal references to include former employers, Air Force supervisors, friends, and two police officers.