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2. Neither counsel nor Fontanari were given notice due pursuant to Construction Materials <br /> Rules 2.5.4 (g) or, 2.2.1(a)(i), depriving Fontanari of his due process rights. Any notice <br /> given was inadequate under the circumstances. See, Sections 8-10 below. <br /> 3. Also pending on November 13, but unclear as to whether it was set for hearing, was a <br /> Motion to Strike all Motions filed by DRMS; this Motion was filed on November 4, <br /> forty-five(45) days after Fontanari's original Motion to Re-Open was filed on September <br /> 19, 2019. DRMS's Motion to Strike was extensive, as was the effort to respond to it; <br /> Fontanari's Response to the Motion to Strike was filed on the afternoon of November 12, <br /> 2019, after a major effort. <br /> 4. Thus, as of November 12 there were three Fontanari motions pending, as outlined in <br /> Fontanari's Response to Motion to Strike. There was one DRMS motion pending; further <br /> pending was Fontanari's Request to Consolidate all Motions and to place them on the <br /> Board agenda to avoid any implication that any of the motions were deemed denied by <br /> inaction (None of the Fontanari motions were placed on the September agenda (Motion <br /> to Re-Open),or,the October agenda(All 3 Motions), creating this risk). <br /> 5. Fontanari's Response to the Motion to Strike all Motions was filed on the afternoon of <br /> November 12. A copy of the Fontanari Response was e-mailed to the attorney for the <br /> Board, 2 attorneys for DRMS, two employees of DRMS and the Board Secretary (Six <br /> state representatives or employees) (See, Exhibit A attached) None responded to inform <br /> Fontanari or counsel that some or all or some of the outstanding Motions, including the <br /> DRMS motion and Fontanari Response,had been placed on the Agenda set for hearing in <br /> only 18 hours. <br /> 2 <br />