IN THE

Court Of Appeals Of Virginia

AT RICHMOND
____________________________________________

Record No. 1585-23-4

KAREN A. WILLIAMS, ET AL.

Appellants,

versus
RAPPAHANNOCK CO. BOARD OF SUPERVISORS, ET AL.
Appellees
________________________________
MOTION OF APPELLANTS
FOR EXPEDITED HEARING AND DECISION
________________________________
TO: THE HONORABLE JUDGES OF THE COURT OF APPEALS OF VIRGINIA:

COME NOW the Appellants, Karen A. Williams, et al., pursuant to Rule 5A:2

of the Rules of the Supreme Court of Virginia and respectfully requests the

Court to expedite the scheduling of oral argument and decision in this case,

and in support thereof, state as follows:

(1) The primary issue raised by Appellants in this case is whether

volunteer fire companies that were organized as independent not-for-profit

corporations are, in fact, independent legal entities under Title 13.1 of the

-1-
Code of Virginia (“Code”), or whether they are Title 27 “fire companies” that

are subordinate to local governing bodies and subject to interference in their

internal corporate governance under Code § 27-13 (and/or dissolution under

Code § 27-10).

(2) Acting under purported color of authority of Code § 27-13, on January

26, 2023 the Board of Supervisors of Rappahannock County (“Board of

Supervisors”) adopted a Resolution [Record at 51-54 (Exhibit C to the

Petition); Record at 851-854 (Exhibit P-2)] (hereafter “the January 26th

Resolution”) which, inter alia, removed all of the duly elected officers and

directors of the Corporation, including Petitioners, and appointed five

replacement directors, including a new Fire Chief who was not even a

member of the Company.

(3) Appellants challenged the lawfulness of the Board’s January 26th

Resolution, and also sought removal of the new Directors pursuant to

Virginia Code 13.1-861. (See, Appellants’ Opening Brief at 34-36). The

Circuit Court granted Appellees’ Plea(s) in Bar and this Appeal followed.

(4) In January 2024, with the 2023 January 26th Resolution set to expire,

on January 4, 2024 the Board of Supervisors enacted a new Resolution

APPELLANTS’ MOTION FOR EXPEDITED ORAL ARGUMENT AND DECISION

WILLIAMS ET AL. VS. BOARD OF SUPERVISORS, ET AL. RECORD № 1585-23-4 PAGE 2
extending the original January 26th Resolution for another year, which

resolution is the subject of Appellants’ February 7, 2024 Motion to Take

Judicial Notice. (See, Exhibit C to Appellants’ February 7th Motion.)1

(5) In anticipation of this Court reversing the Trial Court’s erroneous

decision in the pending case, and in order to preserve their rights going

forward, Appellants also filed a new case in the Circuit Court of

Rappahannock County, styled “Foreback et al. vs. Board of Supervisors, et

al., Case № 24-000020, in which they challenge the lawfulness of the

January 4th 2024 Resolution, the lawfulness of various actions of the

Individual Appellees in this case since January 2023 involving violations of

the Freedom of Information Act and the Corporation’s Bylaws, and again

seek a judicial determination of whether or not the Appellees were lawfully

“re-appointed” under Title 27 and should be removed from office pursuant to

Virginia Code §13.1-861.

(6) On March 13, 2024, acting under color of the January 4, 2024

Resolution, without prior notice, any opportunity to be heard or defend

1
“RESOLUTION OF THE BOARD OF SUPERVISORS OF RAPPAHANNOCK COUNTY,
VIRGINIA UPDATING THE FLINT HILL VOLUNTEER FIRE COMPANY, INC. CHIEF/BOARD OF
DIRECTOR APPOINTMENTS INITIALLY MADE ON JANUARY 26, 2023 AND UPDATED ON
SEPTEMBER 11, 2023 PURSUANT TO VIRGINIA CODE § 27-13.”

APPELLANTS’ MOTION FOR EXPEDITED ORAL ARGUMENT AND DECISION

WILLIAMS ET AL. VS. BOARD OF SUPERVISORS, ET AL. RECORD № 1585-23-4 PAGE 3
themselves, and in violation of provisions of the Bylaws that require a two-

thirds vote of the Members,2 the Individual Appellees apparently voted to

summarily terminate the membership of all Appellants, including six (6) “Life

Members.” [See “Exhibit A”]. On information and belief, this was done in

direct retaliation for Appellants pursuing this Appeal, and for filing the Petition

in CL24-000020, challenging the lawfulness of the Board of Supervisors’

hijacking of the Flint Hill Volunteer Fire Department, Inc., and the legitimacy

of the appointment of the Individual Appellees as its new officers and

directors.

(7) As if summary termination of their respective memberships was not

enough of an insult to these community servants, on March 19, 2024

Individual Appellees Bailey and Hill unlawfully issued and caused to be

served on Appellants by the Rappahannock County Sheriff’s Department

“NO TRESPASS NOTICES” warning each of Appellants that if they came upon

the Fire Company property in Flint Hill, Virginia, they would be subject to

arrest and prosecution pursuant to Code § 18.2-119. [See, “Exhibit A”]

2
See, Record at 872, Exhibit 3 (FHVFC Bylaws) at p. 18, Section 9.2
“Expulsion.”

APPELLANTS’ MOTION FOR EXPEDITED ORAL ARGUMENT AND DECISION

WILLIAMS ET AL. VS. BOARD OF SUPERVISORS, ET AL. RECORD № 1585-23-4 PAGE 4
(8) The Chairman of Respondent, Board of Supervisors, Debbie A.

Donehey, purportedly became a member of the Corporation subsequent to

the January 26th Resolution, and on information and belief, she knew of and

approved the actions of the Individual Appellees and their decision to

terminate the membership of Appellants and to issue the NO TRESPASS

NOTICES.

(9) On March 20, 2024 − the day after the NO TRESPASS NOTICES were

issued − Rappahannock County was hit by high winds and a number of

wildfires that caused the County Administrator to declare a County-wide

State of Emergency (Exhibit C). Rappahannock County was so short-

handed during the emergency that it had to enlist assistance from Fairfax

County and Gloucester County, some three hours away. Thanks to the

aforementioned actions of Appellees, Appellants − including two former Fire

Chiefs (Bruce D. Williams, Michael D. Williams) and one former “Firefighter

of the Year” elected by the Rappahannock County Fire & Rescue Association

(Sam Foreback) − were precluded from assisting with fire-fighting efforts. As

a direct and proximate cause of the unlawful actions of Appellees and their

APPELLANTS’ MOTION FOR EXPEDITED ORAL ARGUMENT AND DECISION

WILLIAMS ET AL. VS. BOARD OF SUPERVISORS, ET AL. RECORD № 1585-23-4 PAGE 5
abuse of power, Rappahannock County residents’ lives and property were

put in harm’s way and exposed to grave danger on March 20-21, 2024.

(10) The hereinabove facts and circumstances demonstrate that the

Individual Appellees, with the knowledge and tacit approval of the Board of

Supervisors and its Chairman, are willfully and wantonly violating the

Corporation’s Bylaws in total disregard for public safety and Appellants’

rights in a deliberate and vindictive campaign to humiliate and intimidate

Appellants into dropping this appeal as well as CL24-000020 pending in the

Circuit Court of Rappahannock County.

(11) Appellants understand that this appeal is not scheduled for oral

argument until the week of June 25, 2024. The hereinabove recited facts

and circumstances warrant expediting the case schedule and advancing the

date for oral arguments so that a decision can be rendered promptly.

(12) Appellants are willing to participate in oral argument via ZOOM or other

electronic means, or to appear at any time and place that the Court may

establish.

(13) As required by S.Ct. Rule 5A:2(a)(1), the undersigned contacted

Counsel for Appellees on March 25, 2024 and sent each of them a draft of

APPELLANTS’ MOTION FOR EXPEDITED ORAL ARGUMENT AND DECISION

WILLIAMS ET AL. VS. BOARD OF SUPERVISORS, ET AL. RECORD № 1585-23-4 PAGE 6
the instant motion, but neither have responded, except to acknowledge

receipt of the draft Motion. Appellants presume that Appellees do not consent

to the Motion and intend to file responses in opposition.

WHEREFORE, for all the foregoing reasons, Appellants respectfully

request the Court to expedite the schedule for oral argument and decision in

this case.

Respectfully submitted,

Dated: March 27, 2024 Karen A. Williams, et al.

By counsel

David L. Konick .

David L. Konick VSB No. 17495

P.O. Box 57
Washington, Virginia 22747-0057
Phone 540-937-5067
Counsel for Petitioners

Attachments:

Exhibit A: Termination of Membership letters and NO TRESPASS NOTICES

Exhibit B: March 20, 2024 Declaration of Emergency
Exhibit C: 22 March 2024 Rappahannock News article on wildfires

APPELLANTS’ MOTION FOR EXPEDITED ORAL ARGUMENT AND DECISION

WILLIAMS ET AL. VS. BOARD OF SUPERVISORS, ET AL. RECORD № 1585-23-4 PAGE 7
 CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing
Motion and attached Exhibits was served electronically to the offices of each
counsel of record for Appellees this 27th day of March 2024 via electronic
mail as shown below:

JEREMY D. CAPPS (VSB No. 43909) E-MAIL: JCAPPS@HCCW.COM

SARAH M. CARROLL (VSB No. 93442) E-MAIL: SCARROLL@HCCW.COM
Harman, Claytor, Corrigan & Wellman TELEPHONE: 804-747-5200
P.O. Box 70280 FACSIMILE: 804-747-6085
Richmond, Virginia 23255
COUNSEL FOR RESPONDENT, RAPPAHANNOCK COUNTY BOARD OF SUPERVISORS

WHITSON R. ROBINSON VSB № 47344 E-MAIL: WROBINSON@ROBINSONSTOVER.COM

Robinson & Stover TELEPHONE: (443) 371-7248
403 Holiday Court FACSIMILE: (443) 371-7275
Warrenton, Virginia 20186
COUNSEL FOR DAVID E. JARRELL, DAVID E. BAILEY, TIMOTHY F. BILLS, PATRICK F.
O'MALLEY, HUGH F. HILL, AND FLINT HILL VOLUNTEER FIRE COMPANY, A VIRGINIA
NON-STOCK CORPORATION

David L. Konick /s/

David L. Konick VSB № 17495
P.O. Box 57
Washington, Virginia 22747-0057
[dlkonick@earthlink.net]
Telephone: (540) 937-5067
Counsel for Appellants

APPELLANTS’ MOTION FOR EXPEDITED ORAL ARGUMENT AND DECISION

WILLIAMS ET AL. VS. BOARD OF SUPERVISORS, ET AL. RECORD № 1585-23-4 PAGE 8
 IEXHIBIT AI

APPELLANTS' MOTION FOR EXPEDITED ORAL ARGUMENT AND DECISION

WILLIAMS ET AL. VS. BOARD OF SUPERVISORS, ET AL. RECORD N!! 1585-23-4

Exhibit A:
Notices of Termination of Membership and No Trespass Notices
 Flint Hill Volunteer Fire and Rescue Company
P.O. Box 150, Plin1 Hill. Virginia 22627

Sharon Hamill-Huff
PO Box 116
Flint Hill VA

SENT BY CERTIFIED MAIL, RETURN RECEIPT REQUESTED

Dear Ms. Hamill-Huff:

Please be advised: The Fire Chief has found your actions over the past year to be
particularly egregious and warrant the termination of your membership.
Members are expected to contribute to the mission and good of the Company.
Your actions have been deleterious to the Company and the membership.

The Board of Directors concurs with this determination.

Please return any Company property you may have.

Sincerely,

Hugh Hill, Secretary

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Rappahannock County Sheriff's Office

.C9~nie S. Compton 383 Porter Street Roger L. jenkins
Sheriff Washington, VA 22747 Chief Deputy
Office: 540-675-5300 Fax: 540-675-5301

Trespass Notice

To: g~MoN !JQAJw.- {~JfF

Name

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City/State/Zip

You are hereby notified that your presence on or in the property located at:

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Street Address

City/State/Zip

Is no longer desired and will not be tolerated and that you are to refrain from entering therein or
thereon for any reason whatsoever.

· You are further notified that upon violation of this notice, you may be subject to immediate arrest or a
trespass warrant will be sworn for your arrest and prosecution (VA Code Section 18.2-119).

Signed on this the ,.........:-i~_.__-

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,ignattir of roperty Owner easee ........... - · ·

bAut.O S~ BA {tAS'-(
PrintName (Co{ Aces)
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Personal Service by: _ _ ,/_ 1 (_z._'-__
c_._D--l,J~e_A_~_in_ r__________.J.. :.~_ 1
Deputy Sheriff Date

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RECE\VED
 Flint Hill Volunteer Ftrc and Rescue Company
P.O. Box 150. Fliui II ill. Virginia 22627

Karen A. Williams
1786 Zachary Taylor
Chester Gap VA 22623

SENT BY CERTIFIED MAIL, RETURN RECEIPT REQUESTED

Dear Ms. Williams:

Please be advised: The Fire Chief has found your actions over the past year to be
particularly egregious and warrant the termination of your membership.
Members are expected to contribute to the mission and good of the Company.
Your actions have been deleterious to the Company and the membership.

The Board of Directors concurs with this determination.

Please return any Company property you may have.

Sincerely,

Hugh Hill, Secretary

 \
Retail U.S. POSTAGE PAID
Flint Hiii.Volunteer Fire & Rescue CoruBfil.,P¥2 ., FCM LETTER
FLINT HILL, VA 22627
P.O. Box 150 13 f~;! El I I Ill Ill
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Flint Hill VA 22627 22623

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Connie S. Compton 383 Porter Street Roger L. Jenkins
Sheriff Washington, VA 22747 Chief Deputy
Office: 540-675-5300 Fax: 540-675-5301

Trespass Notice

To: \"'f\ '~tN f\ W:I:0~'slf\'JV\~

Name

Street Address

City/State/Zip

You are hereby notified that your presence on or in the property located at:

Street Address

City/State/Zip

Is no longer desired and will not be tolerated and that you are to refrain from entering therein or
thereon for any reason whatsoever.

You are further notified that upon violation of this notice, you may be subject to immediate arrest or a
trespass warrant will be sworn for your arrest and prosecution (VA Code Section 18.2-119).

roperty Owner/Leasee - -··--:-- ,

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SHERIFF'S DEPT
 Flint Hill Volunteer Fire and Rescue Company
P.O. Box 150. flint Hill. Virgin•a .22627

Bruce D. Williams
1786 Zachary Taylor Hwy
Chester Gap VA 22623

SENT BY CERTIFIED MAIL, RETURN RECEIPT REQUESTED

Dear Mr. Williams:

Please be advised: The Fire Chief has found your actions over the past year to be
particularly egregious and warrant the termination of your membership.
Members are expected to contribute to the mission and good of the Company.
Your actions have been deleterious to the Company and the membership.

The Board of Directors concurs with this determination.

Please return any Company property you may have.

Sincerely,

I
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Hugh Hill, Secretary
 Retail ........u.s. POSTAGE> PAIQ I

Flint Hill Volunteer Fire & Rescue Company .. ·~~~~_i.~~C,·~~··22si;:~_ ·

' MAR 13 2024' , ,..__,,
P.O . Box 150 i~ 1111111 . ,, •... · l. , ~ ......,

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 Rappahannock County Sheriff's Office
--c~nnie
S. Compton 383 Porter Street Roger L. Jenkins
Sheriff Washington, VA 22747 · Chief Deputy
Office: 540-675-5300 Fax: 540-675-5301

Trespass Notice

To: \) R\Jt t \J. \N ':t L-L -:t ~ ~S

Name

Street Address

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c: \\£ s ·" 0-- Gl\ft
City/State/Zip
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You.are hereby notified that your presence on or in the property located at:

Street Address

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City/State/Zip

Is no longer desired and will not be tolerated and that you are to refrain from entering therein or
thereon for any reason whatsoever.

You are furthernotified that upon violation of this notice, you may be subject to immediate arrest or a
trespass warrant will be sworn for your arrest and prosecution (VA Code Section 18.2-119).

Signed on this the \C\.. ~ day of tv\ ~AL\-\ , 20l l.

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Date

RECEIVED
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HAP~AHAI'Ji'JUlJi\ \JUUI~TY
SHERIFF'S DEPT
 ·-- - ··- - - - - --- - - - -- -

Flint Hill Volunteer Fire and Rescue Company

P.O. Box 150. rlin! J..lill. Vtrginia 22627

Michael R. Williams
1786 Zachary Taylor Hwy
Chester Gap VA 22623

SENT BY CERTIFIED MAIL, RETURN RECEIPT REQUESTED

Dear Mr. Williams:

Please be advised: The Fire Chief has found your actions over the past year to be
particularly egregious and warrant the termination of your membership.
Members are expected to contribute to the mission and good of the Company.
Your actions have been deleterious to the Company and the membership.

The Board of Directors concurs with this determination.

Please return any Company property you may have.

Sincerely,
Flint Hill Volurife.er Fire & Rescue Company' Retail u~ s . POSTAG E:PAID ...._,,
FCM LETTER . ~"' ,.. • ·
FU NT HI LL, VA 22627 """"~' '
P.O. Box 150 ! ill
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MAR 13, 2024 • ,.,..,
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Rappahannock County Sheriff's Office
·connie S. Compton 383 Porter Street Roger L. Jenkins
Sheriff Washington, VA 22747 Chief Deputy
Office: 540-675-5300 Fax: 540-675-5301

Trespass Notice

To: '(V\~C\\ {\ t L.. Q.<

Name

\ ,_~ <0
Street Address

City/State/Zip

You are hereby notified that your presence on or in the property located at:

Street Address

I. City/State/Zip

Is no longer desired and will not be tolerated and that you are to refrain from entering therein or
thereon for any reason whatsoever.

You are further notified that upon violation ofthis notice, you may be subject to immediate arrest or a
trespass warrant will be sworn for your arrest and prosecution (VA Code Section 18.2-119).

Signed on this the \ (\ ~ day of \'\ ~'&: \ r 20_ll.

roperty Owner/C asee_ ~

Dt!VLO '-. /lltlLP( \~~~-\-\~~~tl1q)
Print Name {[ 1 }iu--s)
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Personal Service by: {!.J) 1-Ut/{/I!.J

Deputy Sh iff
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RECEIVED
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SHERIFF'S DEPT
 Flint Hill Voluntee1 -; :rt.. aha Rescue Company
P.O. Bo. I :>0. f-lint Hill. V1r 'llllfl 2262-

Samuel G. Foreback
PO Box 269
Flint Hill VA

SENT BY CERTIFIED MAIL, RETURN RECEIPT REQUESTED

Dear Mr. Foreback:

Please be advised: The Fire Chief has found your actions over the past year to be
particularly egregious and warrant the termination of your membership.
Members are expected to contribute to the mission and good of the Company.
Your actions have been deleterious to the Company and the membership.

The Board of Directors concurs with this determination.

Please return any Company property you may have.

Sincerely,

-~
c...____ . .
Hugh Hill, Secretary
==
' . ·· -·· - - - -
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Flint Hill Volunteer Fire & Rescue Company

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Retail . ~.S. POSTAGE PAI!;>·;..,..~· -

P.O. Box 150 1 iiiii!l!l~- .· .111111 :: ·MAR

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13,-2024
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· :connie S. Compton 383 Porter Street Roger L. J enkins
· Sheriff Washington, VA 22747 Chief Deputy
Office: 540-675-5300 Fax: 540-675-5301

Trespass Notice

To: ~BMu~L.
Name
q. fb~«:;]Mcf(
?.ro. '3ox Z& 9
Street Address

City/State/Zip t

You are hereby notified that your presence on or in the property located at:

q15- FoD.lf.;;gs 17T( k ·Ko

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Is no longer desired and wOl not.be tolerated and that you are to refrain from entering therein or
thereon for any reason whatsoever.

You are further notified that upon violation of this notice, you may be subject to immediate arrest or a
trespass warrant will be sworn for your arrest and prosecution (VA Code Section 18.2-119).

_Icr,__ day of /v(Af?Q{I '20.?f/_.

\

Personal Service by: --=L--~·j1_,_.fJA_~j_(\.:~-------~3.__,J-CI'l-+-(

. ,_ _,_jl~Y...__
Deput)rt§heriff fDate

RECE\VED
 Flint Hill \1 olunteer Fm:: and Resc 1e Company
P.O. Bo.\ ISO. Flint IIi II. Virginw 1.21>27

Charles T. Baker
PO Box 123
Washington VA 22747

SENT BY CERTIFIED MAIL, RETURN RECEIPT REQUESTED

Dear Mr. Baker:

Please be advised: The Fire Chief has found your actions over the past year to be
particularly egregious and warrant the termination of your membership.
Members are expected to contribute to the mission and good of the Company.
Your actions have been deleterious to the Company and the membership.

The Board of Directors concurs with this determination.

Please return any Company property you may have.

Sincerely,

Hugh Hill, Secretary

 Retail U.S. POSTAGE PAID
Flint Hill Volunteer Fire & Rescue Company FCM LETTER ..
P.O. Box 150
VA 22627
~
~~c II II Il
22747
FLINT HILL, VA 22627
MAR 13, 2024

$8.73
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 Rappahannock County Sheriff's Office
·connie S. Compton 383 Porter Street Roger L. Jenkins
Sheriff Washington, VA 22747 Chief Deputy
Office: 540-675-5300 Fax: 540-675-5301

Trespass Notice

To: _Name
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Street ·Address

City/State/Zip

You are hereby notified that your presence on or in the property located -at:

Street Address
..
..
City/State/Zip

Is no longer desired and will not be tolerated and that you are to refrain from entering therein or
thereon for any reason whatsoever.

You are further notified that upon violation of this riotice, you may be subject to immediate arrest or a
.trespass warrant will be sworn for your arrest and prosecution·(VA Code Section 18.2-119).

Signed on this the {q day of ;./(4{?0?/ , 20Jd._.

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Personal Service by: .;¥! . '\3 e/J'"' :.e.f!- 1J 3/:).:S/J.t.{
Deputy Sheriff Date

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RAPfAriAi~~~(JI,jr\ CGUN1Y
SHERIFF'S DEPT
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Flint Hill Volunteer l• m.' and {escue Company

P.O. Hox 150. Flinl Hill. Vit·gmia 22627

Patsy L Baker
PO Box 123
Washington VA 22747

SENT BY CERTIFIED MAIL, RETURN RECEIPT REQUESTED

Dear Ms. Baker:

Please be advised: The Fire Chief has found your actions over the past year to be
particularly egregious and warrant the termination of your membership.
Members are expected to contribute to the mission and good of the Company.
Your actions have been deleterious to the Company and the membership.

The Board of Directors concurs with this determination.

Please return any Company property you may have.

Sincerely,

Hugh Hill, Secretary

Flint Hill Volunteer Fire & Rescue Co ~BSifl}';. Retail
U.S. POSTAGE PAID
FCM LETTER

II IIIII
FLINT HILL, VA 22627
.0 . Box 150 1.2- MAr' :i-:.~ MAl
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MAR 13,2024

VA 22627 i0i•44w....CC.a
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- 'Connie S. Compton
Rappahannock County Sheriff's Office
383 Porter Street Roger L. Jenkins
Sheriff Washington, VA 22747 Chief Deputy · · ·
Office: 540-675-5300 Fax: 540-675-5301

Trespass Notice

Street Address

ZZtfl
You are hereby notified that your presence on or in the property located at:

Street Address . .·.' ~

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Is no longer desired and will not be tolerated and that you are to refrain from entering therein or
thereon for any reason whatsoever.

You are further notified that upon violation of this notice, you may be subject to immediate arrest or a
· trespass warrant will be sworn for your arrest and prosecution (VA Code Section 18.2-119).

Sigq.ed on this the {3 day of HA~CH , 20.li_.

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ignatur operty Owner/(easee _--·- -·· -··---·-··-~·-

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Personal Service by: ; L1 . B C!r1 ll e. ·+/- 3/.)5"/.7l(
Deputy Sheriff Date

RECEIVED
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RAPPAH/-\1\Ji~Ulil\
liVUNTY
SHERIFFS DEPT
 ·------------- ----------

Flint Hill Voluntee.r 'ire a110 J.escue Company

P.O. Box ISO. flint II ill. Virginia 22627

Norma J. Settle
143 Chester Gap Road
Chester Gap VA 22623

SENT BY CERTIFIED MAIL, RETURN RECEIPT REQUESTED

Dear Ms. Settle:

Please be advised: The Fire Chief has found your actions over the past year to be
particularly egregious and warrant the termination of your membership.
Members are expected to contribute to the mission and good of the Company.
Your actions have been deleterious to the Company and the membership.

The Board of Directors concurs with this determination.

Please return any Company property you may have.

Sincerely,

Hugh Hill, Secretary

 (
Retail
Flint Hill Volunteer Fire & Rescue Company U.S. POSTAGE PAID
FCM LETTER

P.O. Box 150 jl;l FLINT HILL, VA 22627

MAR 13, 2024
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Flint Hill. VA 22627 . . . 22623
$8.73
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 Rappahannock County Sheriff's Office
·connie S. Compton 383 Porter Street Roger L. Jenkins
Sheriff Washington, VA 22747 Chief Deputy
Office: 540-675-5300 Fax: 540-675-5301

Trespass Notice

To: NOR ~'\ i\ "3 . S" \:_\\ L E:

Name

Street Address

\x \\ ~c5'T G{\ G f\ ~
City/State/Zip

You are hereby notified that your presence on or in the propertY lo·cated at:

Street Address

- -- :.
City/State/Zip
~ . .

Is no longer desired and will not be tolerated and that you are to refrain from entering therein or
thereon for any reason whatsoever.

You are further notified that upon violation of this notice, you may be subject to immediate arrest or a
trespass warrant will be sworn for your arrest and prosecution (VA Code Section 18.2-119).

Signed on this the \ q~ day of \"'\ i\~c..\\

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I AutO D. 8A-lUj .
PrintName ~if Jic~)

Personal Service by : ~
De~Silt(iff
e.'\) ~in u(\ I
:

REC EIVED
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RAPt"'AMfii'Ji'JUlit\ \..UU I~TY

SHERIFF'SDEPT
 IEXHIBIT sl
Board of Supervisors
Debbie P. Donehey, Chair
RAPPAHANNOCK COUNTY Keir A. Whitson, Vice Chair
Van C. Carney
COUNTY ADMINISTRATOR'S OFFICE Donna D. Comer
3 Lilmuy Road- P.O. Box 519 Christine Smith
Washington, Virginia 22747-0519 Countv Administrator
t>honc: (540) 675-5330 Fax: (540) 675-5331 Gan·ey W. Cmty,Jr., P.E.
www.rappahannockcc>unlyva.ge>v
Asst. CountY Administrator
Bom1ie L.Jewell

DECLARATION OF A LOCAL STATE OF EMERGENCY

WHEREAS, at the advice of qualified individuals, I hereby find that a declaration of a local state
of emergency is necessary:

1. due to adverse weather conditions including a Red Flag Warning, wind gusts exceeding
50 mph, and multiple uncontrolled brush fires that Rappahannock County is facing
dangerous conditions; and
2. due to the uncontrolled brush fires, a condition of extreme peril of life and property
necessitates the proclamation of existence of local emergency.

NOW, THEREFORE, IT IS HEREBY PROCLAIMED on this 201h day of March, 2024,

effective 2:00 p.m. that that an emergency does now exist throughout Rappahannock County,
Virginia, and acting as Director of Emergency Management, I, Garrey W. Curry. Jr., exercise the
authority given to me under Code of Virginia § 44-146.21 to declare a local state of emergency
that shall remain in effect until rescinded by a subsequent order; and

BE IT FURTHER PROCLAIMED that during the existence of said emergency, the powers,
functions, and duties of the Director of Emergency Management and the organization of
Rappahannock County shall be those prescribed by State law and the ordinances, resolutions, and
approved plans of Rappahannock County in order to mitigate the effects of said emergency; and

BE IT YET FURTHER PROCLAIMED that I shall present a resolution ratifying said

declaration of local emergency at the next regular meeting of the Rappahannock County Board of
Supervisors or at a special meeting held within 45 days of the declaration pursuant to Code of
Virginia§ 44-146.21.

March 20, 2024

Date
Director or Emergency Management
County Administrator

APPELLANTS' MOTION FOR EXPEDITED ORAL ARGUMENT AND DECISION

WILLIAMS ET AL. VS. BOARD OF SUPERVISORS, ET AL. RECORD N!! 1585-23-4
 lEXHIBITC I
https://www.rammews.com/news/fireandrescue/rannahannock-hrush-fires-now-contained-atl:er-
incredible-effort-by-volunteers-citizens/article 466I242o-e7fo-nee-86Jc-zb6b8f740905.html

Rappahannock brush fires now contained

after 'incredible effort' by volunteers, citizens
By Julia Shanaban Mar 21, 2024 Updated Mar 22, 2024

• Continued smoldering, flare-ups expected; rain on the way

• Hundreds of acres bm·ning in Shenandoah National Park

Brush fires burning in seemingly every corner of the county have been mostly
contained as of Thursday evening - all thanks to the first responders at all seven fire
and rescue companies, along with some citizens who helped fill in the gaps.
Seven fires across the county ignited Wednesday afternoon amid dry and
extraordinarily windy conditions. The cause of the fires have not been confirmed, but
many residents have reported seeing fallen electrical wires and Rappahannock Electric
Cooperative trucks.
"All of the outside fire locations that were problematic yesterday are contained (and
there are no new concerns at this time)," County Administrator Garrey Curry wrote in
an email to the Rappahannock News and members of the Board of Supervisors.
"There will be flare ups that our fire and rescue resources will manage as they come
up. Continued smoke and smoldering is to be expected," Curry wrote. "Fortunately,
the National Weather Service forecasts more than an inch of rain Friday night into
Saturday."
Since Wednesday afternoon, fire and rescue volunteers from all seven companies have
been fighting fires at the following locations, according to the Rappahannock County
Sheriff's Office:
• Boston/Sperryville Pike
• Red Oak Mountain
• Battle Run Lane
-1-
• Sundale Farm Lane/Battle Mountain Road
• F.T. Valley/Ashby Road
• Zachary Taylor Highway in Huntly
• Lee Highway near Washington
Curry said that in the coming weeks, there will be a more comprehensive report that
outlines the total amount of damage done.
The sheriffs dispatch center answered u8 calls on Wednesday, each call within three
seconds, according to a Facebook post by the Rappahannock County Fire & Rescue
Department.
"While this response required hundreds of man-hours by our public safety teams, it
also included several citizens and businesses that donated their time and resources to
support us through the day," the department wrote on Facebook.
The Rappahannock News attempted to reach EMS coordinator Darren Stevens for
more information and was directed to the social media post.
Curry declared a local state of emergency on Wednesday in order to leverage
potential funding from the state. Stevens requested mutual aid from communities
across the state via the Statewide Mutual Aid process.
~In the end, while some communities from as far away as 3-hours (volunteer
companies in Gloucester County, Gloucester VFR and Abingdon VFR) offered
assistance, we were able to allow them to redirect to more pressing issues because of
the incredible effort made by our local volunteer fire and rescue companies as
supported by many citizens," Curry wrote to the Rapp News. "We will be working to
properly document all who provided assistance."

APPELLANTS' MOTION FOR EXPEDITED ORAL ARGUMENT AND DECISION

WILLIAMS ETAL. VS. BOARD OF SUPERVISORS, ETAL. RECORD N!l 1585-23-4