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Fontanari timely filed his Motion to Re-Open on September 19, 2019 prior to the <br /> finalization of the Board's minutes on September 26, 2019. Subsequent to <br /> September 26, Fontanari timely filed his Motion for Reconsideration,which <br /> incorporated the earlier Motion to Re-Open by reference,and by renewing his <br /> request for Relief. <br /> For reasons unknown to Fontanari,his Motion to Re-Open was not placed on <br /> the Board Agenda for September or October 2019. On November 4, 45 days after <br /> the filing of the Motion to Re-Open, DBMS filed its Motion to Strike. To avoid any <br /> implication that the Motion to Re-Open would be implicitly denied 60 days after <br /> filing (and just prior to the November Board meeting), Fontanari requests that his <br /> motions be administratively combined,effective this date, and set for hearing on the <br /> November Board agenda.As the Motion to Re-Open involves the assertion of <br /> statutory and constitutional rights,such rights being fundamental,the Board should <br /> observe due process in assuring that a full and fair hearing is held. <br /> WHEREFORE, Fontanari respectfully requests that DRMS's Motion to Strike be <br /> denied in its entirety,that Fontanari's Motions be heard by the Board,and re-stating and <br /> reiterating its Requests for relief contained in the Fontanari Motions: <br /> A. For a re-opening of the record of the August 21, 2019 Board hearing for <br /> the presentation of the defense case and all appropriate rebuttal; <br /> 13 <br />