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IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF OHIO

EASTERN DIVISION

MELISSA McFADDEN, : 

 : Civil Action No. 2:18 cv 544 

 : 

Plaintiff, : 

 : 

v. : JUDGE: SARGUS

 : MAGISTRATE JUDGE: JOLSON 

CITY OF COLUMBUS, : 

 : 

 Defendants. : 

PLAINTIFF MELISSA McFADDEN’S EXHIBIT LIST

Now comes Plaintiff by and through undersigned Counsel to provide her list of exhibits 

pursuant to this Court’s November 29, 2021, Order Setting Trial Date and Final Pretrial 

Conference. 

Plaintiff may introduce the following exhibits during the trial the below number does not 

indicate the order in which Plaintiff will introduce exhibits. 

• Expert Report of Lou Reiter previously produced to Defendants in discovery. 

• CV of Expert Lou Reiter previously produced to Defendants in discovery. 

• Decision of Safety Director Ned Pettus regarding recommendation for 

termination previously exchanged in discovery. 

• IAB investigation file of Plaintiff previously exchanged in discovery. 

• IAB findings in investigation of Plaintiff previously exchanged in discovery. 

• Narrative e-mails of Officers Johnson, Moorefield, and Sgt. Tate previously 

exchanged in discovery. 

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• Narrative e-mail of Officer Kaza to Cmdr. Grizzell regarding Plaintiff 

previously exchanged in discovery.

• Notice of reassignment of Plaintiff to Property previously exchanged in 

discovery.

• Notice of relief of assignment pending termination to Plaintiff previously 

exchanged in discovery.

• Text messages between Cmdr. Grizzell and Officers Johnson and Moorefield 

previously exchanged in discovery.

• Notebook pages showing serial numbers of ballistic vests processed by Plaintiff 

previously exchanged in discovery.

• Photographs of ballistic vests processed by Plaintiff previously exchanged in 

discovery.

• IAB complaint against Lt. Christine Nemchev previously exchanged in 

discovery.

• IAB complaint against Cmdr. Rhonda Grizzell previously exchanged in 

discovery.

• IAB complaint against Lt. Marby previously exchanged in discovery.

• Second IAB complaint against Lt. Marby previously exchanged in discovery.

• IAB complaint against Sgt. Fishburn previously exchanged in discovery.

• IAB complaint against Lt. Rector previously exchanged in discovery.

• IAB complaint against Sgt. Grunkemyer. previously exchanged in discovery.

• IAB Major Case worksheet previously exchanged in discovery.

• IAB Standard Operating Procedures previously exchanged in discovery.

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• Performance reviews of Sgt. Andre Tate conducted by Plaintiff previously 

exchanged in discovery.

• E-mails between Cmdr. Grizzell and Cmdr. Knight regarding their friendship 

previously exchanged in discovery.

• E-mails announcing reassignment of Plaintiff to property room previously 

exchanged in discovery.

• E-mails discussing Plaintiff remaining in property room during investigation 

previously exchanged in discovery.

• Notes of Dr. John Trapy previously exchanged in discovery.

• Zone 2 report authored by Cmdr. Mark Garner previously exchanged in 

discovery.

• Staffing information for Zone 2 previously exchanged in discovery.

• IAB interview transcripts of Cmdr. Grizzell, Sgt. Odom, Sgt. Tate, Ofc. 

Johnson, and Ofc. Moorefield previously exchanged in discovery.

• Transcript of Chief’s Hearing for Plaintiff previously exchanged in discovery.

• E-mails regarding non-reassignment of Sgt. Edly during Lt. Nemchev 

investigation previously exchanged in discovery.

• Cmdr. Grizzell’s notes regarding Saunders phone call previously exchanged in 

discovery.

• E-mail advising Cmdr. Grizzell of EEO investigation previously exchanged in 

discovery.

• Request for discipline of Plaintiff from Chief Jacobs regarding untruthfulness 

in Chief’s hearing previously exchanged in discovery.

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• Tuition reimbursement sheet previously exchanged in discovery. 

• Tuition reimbursement policy previously provided to Defendant 

• Property Room Sergeant Position Description copy provided to Defendant 

• Property Room Lieutenant Position Description copy provided to Defendant 

• Property Room Destruction of Property Procedure copy provided to Defendant

• Plaintiff’s Worker’s Compensation Records copy previously provided to 

Defendant

• EEO complaint filed by Sgt. Odom against Lt. Lowell Rector and Eric Moore

previously exchanged in discovery 

• E-mail from Deputy Chief Woods regarding tuition reimbursement previously 

exchanged between the parties.

• March 2017 Division Newsletter previously exchanged between the parties. 

• Paystubs issued by Defendant to Plaintiff previously exchanged between the 

parties.

• Certificate of Release or Discharge from United States Air Force provided to 

Defendant on May 2, 2022 

 Respectfully submitted,

By: /s/ Samuel M. Schlein___

Samuel M. Schlein (0092194) 

(sschlein@marshallforman.com) 

John S. Marshall (0015160) 

(jmarshall@marshallforman.com)

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OF COUNSEL:

Louis A. Jacobs (002101)

(LAJOhio@aol.com) 

177 19th St., Apt. 9C

Oakland, CA 94612

(614) 203-1255

Fax (510) 250-9007

Edward R. Forman (0076651)

(eforman@marshallforman.com) 

Samuel M. Schlein (0092194) 

(sschlein@marshallforman.com) 

Helen M. Robinson (0097070) 

(hrobinson@marshallforman.com) 

MARSHALL FORMAN AND SCHLEIN

LLC

250 Civic Center Dr., Suite 480 

Columbus, Ohio 43215-5296 

(614) 463-9790 

Fax (614) 463-9780 

 

CERTIFICATE OF SERVICE

This is to certify that a copy of the foregoing was filed with the Court on this 2 day of May, 

2022 using the CM/ECF system, which will send notification of such filing to all counsel of record. 

Parties may access this filing through the court’s filing system.

By:/s/ Samuel M. Schlein___

Samuel M. Schlein (0092194) 

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