1

BEFORE THE 'PERSONNEL APPEALS BOARD

2

"
STATE
OF WASHINGTON

3
4

SHARON KIESEL,
Appellant,

5
v.

6
7

DEPARTMENT OF CORRECTIONS,
Respondent.

8
9

)
)
)
)
)
)
)
)
)
)

Case No.

093-144

MOTION AND
ORDER OF DISMISSAL

The Appellant hereby notifies the Personnel Appeals Board that she

10

wishes~ithdraw the

11

DATED

oj

k-L

12

13

~, /77i

"

2

above-entitled appeal.

~~K

U'At?=t/7:r ...

A pellantjAttorneyjRepresentative

~

14

This matter came on regularly before the Personnel Appeals Board on

15

the consideration of the request of the Appellant to withdraw her

16

appeal.

The Board having reviewed the files and records herein,

being fully advised in the premises, and it appearing to the Board

17

that the Appellant has requested to withdraw her appeal, now enters

18

the following:

19
20
21

ORDER
NOW, THEREFORE, IT IS HEREBY ORDERED that the Appellant's request to
withdraw her appeal is granted and the appeal is dismissed.
. ':)~
(\
DATED this
}-;;)I day of
'=JU/\,\Q
, 1994.

22
23

24

25

26
27

28
29

30

WASHINGTON STATE PERSONNEL APPEALS BOARD

STATE OF WASHINGTON

2828 capitol 8lvd.
PO BOll 40911
Olympia. WA 98504·0911

(206) 586·1481
(SCAN) 321-1481
(FAX) 753·0139

PERSONNEL APPEALS BOARD

June 13. 1994

Robert F. Spaulding
Attorney At Law
P.O. Box 7846
Olympia, Washington 98507-7846
Re:

Sharon Kiesel v. Department Of Corrections. Dismissal
Appeal, Case No. 093-144

Dear Mr. Spaulding:
Enclosed is a copy of the order of the Personnel Appeals
Board in the above-referenced matter. The order was entered
by the Board on June 13. 1994.
Very truly yours,

QLut.a\(.

+ct-~

.Judy K. Larson
Confidential Secretary
gmh
Enclosure
cc:

t (

t

. 1£1!!id#

Sharon Kiesel, APP
Joe Olson, AAG
Jennie Adkins, PO
Sue Zukowski, WFSE

a.SiW.la.z,g,.J.3.J.b.i.5,.5. ... #.J Wi,

.

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STATE OF WASHINGTON

2828 Capitol Blvd.
PO Box 40911
Olympia, WA 98504-0911

(206) 586·1481
(SCAN) 321-1481

PERSONNEL APPEALS BOARD

June 1,

(FAX) 753-0139

1994

Robert F. Spaulding
P.O. Box 7846
Olympia, Washington 98507-7846
Re:

S. aron Kiesel v. Department of Corrections, Case Nos.
093-144 and 093-145

Dear Mr.

Spaulding:

The Personnel Appeals Board (PAB) has recently been
authorized by the Legislature and the Governor to become a
full-time board.
Therefore the Board requested that all
cases which have not yet been heard on the merits be
returned by hearings examiners.
As you know, the above-referenced cases were previously
assigned to be heard by Hearings Examiner Jennifer Woods.
In reviewing these cases, it appears that a settlement is
pending between the parties.
Please let us know by June 17,
1994, what the status of the cases are or whether we should
begin the sche~uling process.
If the cases have settled, please sign, date and return the
enclosed Motion and Order of Dismissal.
Very truly yours,

q~t'.~
Judy K. Larson
Confidential Secretary

..

njh
Enclosure
cc:

Sharon Kiesel, App
Joseph Olson, AAG
Jennie Adkins, PO
Sue Zukowski, WFSE
Jennifer Woods, HE

o
·· ..134liti.

. .. 6.

iiiP,Q,CNiM,iM,Mi,Cg,:;,Siv.6,d,h.3.SiQ'Qi

. .... .wA.:::zm;:z;;:qWPWM.J.J.l.41 .. h&.JJAP ..... AW& .£.;.I .. .t.tJ ' .h.M"

Ml

CERTIFICATE OF MAJUNG

I certify lhal I mailed It ~y or Ibis document by depositing willi Consolid:ucd
Services on 24-94 10 all panics or lllcir counselor rec:ord. I certify under penalty or perju
or lIIe laws or lIIe swe or Washington lhalllle foregoing is true and correa.
DaIed 24-94 at Lacey. WA.

R
\&

\Y)

8 '\S94

~kM 9'~

1

@

fEB
E~
PERSO"'~O~RO

2

p..PPE~S

3

BEFORE THE PERSONNEL APPEALS BOARD
STATE OF WASHINGTON

4

5

SHARON KIESEL,
6

Appellant,
7

v.
8

9

STATE OF WASHINGTON,
DEPARTMENT OF CORRECTIONS,

10

Respondent.

11

)
)
)
)
)
)
)
)
)
)

NO. D93-14.A
NO. D93-145
NOTICE OF SUBSTITUTION
OF COUNSEL

--------------)
TO:

13

VICTORIA W. SHELDON, Executive Secretary, Washington State
Personnel Appeals Board;
SHARON KIESEL, Appellant, and her attorney, ROBERT F.
SPAULDING.

14

NOTICE

12

IS

HEREBY

GIVEN

that

JOSEPH
for

OLSON,

MICHAEL

Assistant

15

Attorney General,

16

Assistant Attorney General, as the attorney for Respondent in the

17

above-entitled action.

18

pleadings herein be served upon the undersigned attorney at the

19

Office of the Attorney General at the address given below.

20

hereby substitutes

W.

P.

SELLARS,

It is requested that any and all further

DATED this 4th day of February, 1994.
CHRISTINE O. GREGOIRE
tt ney Ge r

21
22

/;~

23

J. SEPH W. OLSON

ssistant Attorney General
WSBA No. 20706
Attorney for Respondent

24
25
26

NOTICE OF SUBSTITUTION
OF COUNSEL

-1-

ATIORNEY GENERAL OF WASHINGTON
La1lor &. PenollllCl Division
670 Woodland Square Loop SE
PO BOX4014S
Olympia. WA 98S04-014S
(206) 407.0009

C. F. (RICK) CORDES, m
JOHN MCCUTCHEON PARR
DARREL L. PEEPLES
R. ALAN SWANSON
EDWARD EARL YOUNGLOVE,

SWANSON, PARR. CORDES,
YOUNGLOVE & PEEPLES, P.S.

WIWAM LEE PARR (1976)
CLIFFORD F. CORDES, JR. (1980)

ATIORNEYS AT LAW
EASTSIDE PROFESSIONAL PLAZA
924 EAST SEVEN'IH AVENUE
P.O. BOX 7846

m

1R?1E~IEOWIEIDJ

OLYMPIA, WASHINGTON 98507-7846
FACSIMILE (206) 754-9268

RALPH G. SWANSON
OF COUNSEL

(206) 357-7791

FEB 3

February 2, 1994

;994

PERSONNEL
APPEALS 80ARD
~.

Ms. Victoria Sheldon
Personnel Appeals Board
2828 Capitol Boulevard
KKK-11
Olympia, WA 98504-4911

°

0

Re: Kiesel vs. DOC
Case No. 093-144 & 093-145

-

Dear Ms. Sheldon:
Enclosed, for filing, is our Notice of Withdrawal and Consent to
Substitution of Counsel in this matter.
By copy of this letter we are hereby serving Mike Sellars,
Assistant Attorney General.
Very truly yours,
SWANSON, PARR, CORDES,
YOUNGLOVE & PE LES, P.S.

DLP/jel
Enclosure
cc:

': i

66163661616.61

Mike Sellars, AAG
Sue Zukowski, WFSE
Jennifer Woods, HE

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1

1994

2

PERSONNEL

3

BEFORE THE PERSONNEL APPEALS BOARD

4

STATE OF WASHINGTON

5

APPEALS BOARD

)

SHARON' KIESEL,

)

6

Appellant,

)
)

7

vs.

)

8

DEPARtMENT OF CORRECTIONS,

)
)
}

9

Respondent.

)

No.

,D93-144

D93 -145
NOTICE OF WITHDRAWAL AND
CONSENT TO SUBSTITUTION
OF COUNSEL
'.

10
11

TO:
TO:
TO:

JENNIFER WOODS, Hearing Examiner; and
PERSONNEL APPEALS BOARD; and
MICHAEL P. SELLARS, Assistant Attorney General.

12
YOU,

AND EACH OF YOU, WILL PLEASE TAKE NOTICE that DARREL L.

13
PEEPLES hereby withdraws as attorney for the Appellant, SHARON KIESEL,
14
and consents to the substitution of ROBERT F. SPAULDING of SWANSON,
15
PARR, CORDES, YOUNGLOVE & PEEPLES, P.S., 924 E. 7th Avenue, Suite A,
16
P.O. Box 7846, Olympia, Washington 98507-7846, as attorney for said
17
Appellant.
18
DATED this
19
20

2-J1 day of

SWANSON, PARR, CORDES,
YOUNGLOVE & PEEPLES, P.S.

February, 1994.
N, PARR, CORDES,
& PEEPLES, P.S.

~'T~~LOVE

21

22
23

ROBERT F. SPA
WSBA 17323

ING
WSBA

24
25
26
SWANSON. PAIII1, CDIIDES,

lOlJNCLO\IE, PEEPUS. WYaDFP. P.s.
ATIOlINE'i'S AT u..w

EASTSIDE PROFESSIONAL PLAZA. SUITE A
924 EAST S£VEN'IH AVENllE

II

Substitution of Counsel
Page 1

P.O. BOX 7846
OLYMPIA. WASHINGTON 98507·7846
PACSI1oII1E (206) 754-9268
(206) 357·7791

c. F. (RICK) CORDES, ill
JOHN MCCUTCHEON PARR
DARREL L. PEEPLES
R. ALAN SWANSON
EDWARD EARL YOUNGLOVE,

SWANSON, P~ CORDES,
YOUNGLOVE &: PEEPLES, P.S.
.

WILLIAM LEE PARR (1976)
CLIFFORD F. CORDES, JR. (1980)

ATIORNEYS AT LAW
EASTSIDE PROFESSIONAL PLAZA
924 EAST SEVENTIi AVENUE

P.O. BOX 7846

m

OLYMPIA, WASHINGTON 98507-7846
FACSIMILE (206) 754-9268

RALPH G. SWANSON
OF COUNSEL

(206) 357·7791

~1E©lEn/EIDJ
JAN 28 ;994

January 27, 1994

PERSONNEL.:
APPEALS BOARD

Ms. Victoria Sheldon
Personnel Appeals Board
2828 Capitol Boulevard
KKK-11
Olympia, WA 98504-4911
Re: Kiesel vs. DOC
Case No. D93-144 & 093-145

Dear Ms. Sheldon:
Enclosed, for filing, is our Notice of Withdrawal and Consent to
Substitution of Counsel in this matter.
By copy of this letter we are hereby serving Mike Sellars,
Assistant Attorney General.
Very truly yours

---

I

SWANSON, PARR, CORDES,
YOUNGLOVE & PEEPLES, P.S.

~

,..--:

(---/.,/

t~?~t~3:¥Z~~~

Judith E"': )Lut~er
Legal/l.~artt

Q!lB./jel
Enclosure
cc:

". Jt3!6

661.101

Mike Sellars, AAG
Sue Zuk~Nski, WFSE
Jennifer Woods, HE

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f&1E~IEOWlE

1

2

3

BEFORE THE PERSONNEL APPEALS BOARD

4

STATE OF WASHINGTON

5

SHARON. KIESEL,

6

JAN 28 1994
PERSONNEL'
APPEALS So

~RD

)
)

Appellant,

)
)

7

vs.

)

8

DEPARTMENT OF CORRECTIONS,

)
)
)

9

Respondent.

)

No.

093-144
093-145

NOTICE OF WITHDRAWAL AND
CONSENT TO SUBSTITUTION
OF COUNSEL

'.

10
11

TO:
TO:
TO:

JENNIFER WOODS, Hearing Examiner; and
PERSONNEL APPEALS BOARD; and
MICHAEL P. SELLARS, Assistant Attorney General.

12
YOU, AND EACH OF YOU,

WILL PLEASE TAKE NOTICE that EDWARD E.

13
YOUNGLOVE hereby withdraws as attorney for the Appellant,

SHARON

14
KIESEL,

and consents to the substitution of DARREL L.

PEEPLES of

15
SWANSON, PARR, CORDES, YOUNGLOVE & PEEPLES, P.S., 924 E. 7th Avenue,
16
Suite A, P.O. Box 7846, Olympia, Washington 98507-7846, as attorney
17
for said Appellant.
18
DATED this
19

2·~ day

of January, 1994.

SWANSON, PARR, CORDES,

: q~==\~~~~~"non'~t'-_--23

24

EDWARDY;/YOUNGmVE
WSB~~7.~

./ ~

D
EL PEE
WSBA

25
26
SWAHSDN, PABB., alBIlES,

lCU!iGtOVI. Pm!I'US • WYaDfP. p.s.

II

Substitution of Counsel
Page 1

ATI'ORNnS AT lAW
EASTSmE PROfESSIONAL PLUA, sum A
924 EAST SEVENTB AVENUE
P.O. BOX 7846
OL"I'MPIA, WASHINGTON 98!i07·7846
FACSIMILE (206) 754-9268
('2D6) 3$7-7791

m{~~fE~W~[ID
1

BEFORE THE PERSONNEL APPEALS BOARD

2

STATE OF WASHINGTON

3

SHARON KIESEL,
Appellant,

4

vs.

5
6

DEPARTMENT OF CORRECTIONS,

7

Respondent.

)
)
)
)
)
)
)
)
)
)

JAN 7 - 1994

PERSONNEL
APPEALS BOARD

Case Nos. D93-144 and 145
d

NOTICE OF HEARING

8

TO:

SHARON KIESEL, Appellant, and EDWARD EARL YOUNGLOVE, III,
her attorney;

AND TO:

MICHAEL P. SELLARS, Assistant Attorney General;

9

10
11

PLEASE TAKE NOTICE that the above-captioned matter will come

12

on for hearing before JENNIFER WOODS, Hearings Examiner, on Monday,

13

March 7,

14

Division of Community Corrections, 10109 South Tacoma Way, Building

15

C, Tacoma, Washington.

16

1994 at 10:00 a.m.

at the Department of Corrections,

DATED this 6th day of January, 1994.

17

PERSONNEL APPEALS BOARD
STATE OF WASHINGTON

18

\5\

19

,

By:

20

\

JENNIFER WOODS
Hearings Examiner

21
cc:
22
23

Jennie Adkins
Laura Saint
Linda Giles
Victoria Sheldon

24
25
26
27
28

NOTICE OF HEARING

-1-

JENNIFER WOODS
Attorney at Law
715 North 193rd Place
Seattle, WA 98133
(206) 546-9081

• I

CASE ASSIGNMENT
11/19/93

.

RE: Case No.:
Case Name:

D93-144
Sharon Kiesel v. DOC

The above-referenced case has been assigned to:
Hearings Examiner

Phone:

Jennifer Woods
715 N 193rd PI
Seattle, WA 98133
206-546-9081

You will be contacted by the hearings examiner to arrange a date and
location for the hearing.

cc: Sharon Kiesel
Edward Earl Younglove
Michael P. Sellars
Sue Zukowski

~eRTIFlCATE OF

1Rl~©~H/~ID)

MAILING

1 cenify that 1 mailed a copy of Ihis document by depositing wilh Consolidalcd Mail
Services on 11-08-93 10 all panics or Iheir counsel of record. 1 cenify under penalty of
perjury of Ihe laws of Ihe SIlIle of Washington that Ihe foregoing is true and correct.

1

D~3atLacey,W12

NOV 10 1993

h:

~V·~

2

PERSONNEL
APPEALS BOARD

BEFORE THE PERSONNEL APPEALS BOARD
STATE OF WASHINGTON

3

SHARON KIESEL,

}

)

4

Appellant,
5

v.
6

7

STATE OF WASHINGTON,
DEPARTMENT OF CORRECTIONS,

8

Respondent.

9

)
)
)
)

NO.

D93-1~

and D93-145

NOTICE OF APPEARANCE

}

)
)
)

--------------)
TO:

11

VICTORIA W. SHELDON, Wash. State Personnel Appeals Board;
SWANSON, PARR, CORDES, YOUNGLOVE & PEEPLES, Attorneys for
Appellant;
SUE ZUKOWSKI, Washington Federation of State Employees.

12

PLEASE TAKE NOTICE that the Respondent, State of Washington,

13

Department of Corrections, without waiving objection as to the

14

sufficiency of service of process or jurisdiction of this Board,

15

does hereby enter its appearance in the above-entitled action, by

16

and

17

General, and MICHAEL P. SELLARS, Assistant Attorney General, and

18

requests that all further pleadings herein be served upon said

19

Respondent at the Office of the Attorney General at the address

20

given below.

10

21

through

its

attorneys,

CHRISTINE

0.'

GREGOIRE,

Attorney

DATED this 8th day of November, 1993.
CHRISTINE O. GREGOIRE
Attorney General

22

23

~ELLARS
Assistant Attorney General

24

WSBA No. 21331
Attorney for Respondent

25
26

NOTICE OF APPEARANCE

-1-

ATTORNEY GENERAL OF WASHINGTON
Labor & PersoMd Division
670 Woodland Square Loop SE
PO BOXoW145
Olympia. WA 98504-0145
(206) 407-0009

\R{ IE ©lEn WIE tID

.TIFICATE OF MAILING
I certify dIat I mailed a copy of this l!oc:uIIIem by cIcposiUDg with Comolida&cd Mail
Sc:rvicc:s OD 11.08-93 co all panics or lhcir alWIScI of record. I certify WIder pemI1y of
perjury of lhc Jaws of lhc StIIC of WashingloD lbat Ihe fORgOiDg is IrUC lIIId correa.

1

NOV 101993

~.<-Y.wn ~

~ V

2

.

~

PERSONNEL
APPEALS BOARD

BEFORE THE PERSONNEL APPEALS BOARD
STATE OF WASHINGTON

3
SHARON KIESEL,

)

)

4
Appellant,
5
v.
6

)

NO. D93-144 and 093-145

)
)

NOTICE OF APPEARANCE

)

7

STATE OF WASHINGTON,
DEPARTMENT OF CORRECTIONS,

8

Respondent.

)
)
)
)
)

9

11

VICTORIA W. SHELDON, Wash. State Personnel Appeals Board;
SWANSON, PARR, CORDES, YOUNGLOVE & PEEPLES, Attorneys for
Appellant;
SUE ZUKOWSKI, Washington Federation of State Employees.

12

PLEASE TAKE NOTICE that the Respondent, State of Washington,

13

Department of Corrections, without waiving objection as to the

14

sufficiency of service of process or jurisdiction of this Board,

15

does hereby enter its appearance in the above-entitled action, by

16

and

17

General, and MICHAEL P. SELLARS, Assistant Attorney General, and

18

requests that all further pleadings herein be served upon said

19

Respondent at the Office of the Attorney General at the address

20

given below.

TO:
10

21

through

its

attorneys,

CHRISTINE

0.' GREGOIRE,

Attorney

DATED this 8th day of November, 1993.
CHRISTINE O. GREGOIRE
Attorney General

22

23

~ELLARS
Assistant Attorney General

24

WSBA No. 21331
Attorney for Respondent

25
26

NOTICE OF APPEARANCE

ATrORNEY GENERAL OF WASHINGTON
Labor .t Pcrsolllld Division
670 WoocI1aIId Square Loop SE
PO BOX4014S
Olympia. WA 98S()4.(l14S

-1-

(206) 407.()()09

1
2

BEFORE THE PERSONNEL APPEALS BollE

3

STATE OF WASHINGTON

4

5

SHARON KIESEL,
Appellant,

6
7

vs.

8

DEPARTMENT OF CORRECTION,
Respondent.

9

10

TO:

)
)
)
)
)
)
)
)
)

NO.

©IE n WI IE IDJ
NOV 04 1993

D93-144

PERSONNEL'
APPEALS BOARD

NOTICE OF APPEARANCE

Department of Corrections, by and through its Attorney,
KATHY NOLAN:

11
12
13

NOTICE IS HEREBY GIVEN that the firm of SWANSON, PARR, CORDES,
YOUNGLOVE & PEEPLES, P.S., hereby makes its appearance for and on
behalf of the appellant, above named, and a copy of all pleadings
should be served upon said firm ~ffice address below stated.
DATED this

14

2

day of

~

--;-1993.

15
16
17
18
19
20

Office and Post Office Address:

21

Eastside Professional Plaza, Suite A
924 E Seventh Avenue
PO Box 7846
Olympia, Washington
98507

22
23

(206) 357-7791

24

cc:

Sue Zukowski

25
26
SWANSON. PARR. CXllUlES,.
'YOUNGUNE • PEI!P1fS, P.5.
ATI'ORNEYS AT lAW
EASTIiIDI! PROFESSIONAL PlAZA, S11ITI! A

924 EAST SEVl!NlH AVENUE
P.O. BOX 1846
OLYMPIA, WASHINGTON 98501·1846

NOTICE OF APPEARANCE

FACSIMILE (206) 154-9268
(2ll6) 351·7791

L/

2828 Capitol Blvd.

STATE OF WASHINGTON

PO 80140911

PERSONNEL APPEALS BOARD

Olympia, WA 98504-0911

(206) 586-1481
(SCAN) 321-1481
(FAX) 753-0139

November 1, 1993

Sue Zukowski, Area Representative
Washington Federation of State Employees
10116 - 36th Avenue Court SW, #16
Tacoma, Washington 98499
RE:

Sharon Kiesel v. Department of Corrections, Suspension
Appeal Case No. 093-145 and Dismissal Appeal Case No.
...D2k,14!.

Dear Ms.

Zukowski:

Your letters of appeal to the Personnel Appeals Board were
received on October 27, 1993.
These matters are being assigned to Hearings Examiner
Jennifer Woods.
You will be contacted to arrange a date,
time and location for the hearing.
Sincerely,

Victoria W. Sheldon
Executive Secretary
VWS:

cc:

njh
Sharon Kiesel, App
Cordes, Younglove & Peeples, Atty
Kathy Nolan, AAG
Jennie Adkins, PO

o

CHASE RIVELAND
Secretary
STATE OF WASHINGTON

DEPARTMENT OF CORRECTIONS
McNEIL ISLAND CORRECTIONS CENTER
P. O. Sox 900.

Steilacoom. Washington 98388·0900

~~(Cl~n/~fID

October 15, 1993

OCT 29 1993
PERSONNEL
APPEALS BOARD

CONFIDENTIAL -PERSONAL SERVICE

Sharon Kiesel
8521 29th Ave. Ct. S. #6
Tacoma, WA 98409
Ms. Kiesel:

This is official notification that you are being dismissed from your position as a
Pharmacy Assistant-A at McNeil Island Corrections Center (MICC) effective November
3, 1993, at the end of your work shift.
This disciplinary action is taken pursuant to the Civil Service Laws of Washington
State, Chapter 41.06, Revised Code of Washington, and the Merit System Rules, Title
356, Washington Administrative Code (MSR), and Sections 356-34-010 (1 )(a) Neglect
of Duty, (b) Inefficiency, (c) Incompetence, (h) Gross misconduct and 356-34-040
Dismissal -- Notification.
Specifically, you committed an act of gross misconduct, neglected your duty, and
were inefficient and incompetent when on June 21, 1993 you admittedly incorrectly
filled a prescription for inmate Victor P. Inmate No. 216699. The label provided you
by your supervisor, Pharmacist Linda Paulson, indicated the refill was for Lanoxin 0.25
mg tablets. You filled the prescription with Synthroid 0.025 mg tablets. The Lanoxin
tablets are white in color and the medication is used to control atrial fibrillation. The
Synthroid is a synthetic thyroid medication, used to increase the level of thyroid.
hormones, with tablets that are peach in color. These actions are described in more
detail in the Employee Conduct Report, completed on August 13, 1993 (Attachment

1).
As a licensed Pharmacy Assistant A, you have a duty to dispense medication
appropriately and accurately. In .fact, the safety and well-being of inmates depends
on it. I find your actions in this instance particularly alarming, as the difference in the
type of medications (heart vs. thyroid) would have had severe repercussions if the
medication had not been corrected and had been ingested by the inmate. For
example, as stated in Ms. Callaghan's supervisory report; ". . . withholding the
Lanoxin in this case could cause a potentially lethal heart rhythm. Ingesting the

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Sharon Kiesel
October 15, 1993
Page 2 of 3

Synthroid would subject the inmate's already compromised cardiac system wrongly
to a thyroid preparation which would compound the effects and further contribute to
an adverse outcome (up to and including loss of life)."
Considering your nearly twelve years of relevant experience, I find the level of
mistakes you continue to make inexcusable and unacceptable. You have an obligation
to ensure that your work is done precisely. The error you made on June 21, 1993,
is another in a long line of errors, due to a work performance pattern of inattention to
detail, which you have exhibited since assuming your Pharmacy Assistant position at
this institution. You have been counseled relative to your carelessness and warned
about the consequences should these serious errors continue. Evidence of this
counseling and identification of possible consequences is included in two corrective
interview documents, dated May 14, 1993, and June 2, 1993, (Attachments 2 and
3 respectively) which specifically cite several instances of prescription dispensation
errors on your part. Additionally, on May 28, 1993, you received a letter of reprimand
for incorrectly filling one prescription and failing to fill two others (Attachment 4).
Most recently, you were suspended for five days (October 11, through October 15,
1993) as the result of a similar error (Attachment 5).
By your failure to properly fulfill your duties and responsibilities in support of the
Pharmacy program, you have committed gross misconduct. By not providing the level
of acceptable care each inmate has a right to expect, you placed the institution open
to allegations of inadequate inmate health care and even malpractice, possible
litigation, and other repercussions to inmates ranging from minimal medical reactions
to loss of physical well-being, up to and including the loss of life. I am distressed at
the overall level of unacceptable performance you have demonstrated since you
assumed your duties at MiCe. Although numerous efforts have been made by your
supervisor to correct your substandard performance, you have failed to respond and
continued to repeat these serious errors. This failure to respond and work with your
supervisor to improve your performance caused your supervisor to spend much of her
time (including overtime hours) reviewing your work, and correcting your errors. You
have seriously neglected your duty, and demonstrated inefficiency and incompetence
by the careless way in which you have carried out your duties.
A pretermination hearing was held on Monday, August 30, 1993. At that time you
and your representative, Sue Zukowski, stated that you have experienced personal
circumstances that interferred with your ability to perform well at work. Specifically,
you asked to be able to submit documentation from your physician and I stated that
would be acceptable. I gave you until the following Thursday (September 2, 1993)
to present documentation from your physician. I received a response from your
physician on September 22, 1993, that failed to provide adequate information and

Sharon Kiesel
October 15, 1993
Page 3 of 3

does not alter my decision to terminate you.
Attachments one through five are attached hereto and by this reference, made a part
hereof as though fully set forth herein.
Under the provisions of WAC 358-20-010 and WAC 358-20-040, you have a right
to appeal this action to the Personnel Appeals Board. Your appeal must be filed in
writing at the Office of the Executive Secretary, Personnel Appeals Board, thirty (30)
days after the first day of your dismissal as stated in paragraph one of this letter.
The Merit System Rules, Washington Administrative Code, and Department of
Corrections policies are available for your review in the personnel office.

Eldon Vail, Superintendent

Attachment(s)

cc:

Dennis Karras, Director, Department of Personnel
v.:rennie Adkins, Director, Division of Human Resources
James Blodgett, Assistant Director, Division of Prisons
Kathy Nolan, Sr. Assistant Attorney General
Donna Grazzini, Area Personnel Manager
Katherine Nagel, MICe Personnel Officer
Personnel file

093 -/4 L{
~~~~~W~ID1

4
APPEAL FORM

WASHIroroN STATE PERSONNEL APPEAlS BOARD
2828 capitol Boulevacl
PH:
P. O. Box 40911
Olympia, WA 98504-0911
FAX:

OCT 27 1993
SCAN 321-1481
(206) 586-1481
(206) 753-0139

PERSONNEL
APPEALS BOARD

'nUs fonn will help you provide necessaJ:y infonnation to the Pemonnel Appeals Board when
you file an appeal. You are .DQt. required to use this fOD1\; however, appeals ~ be filed
in accordance wi. th the requirements set forth in Chapter 358-20 WAC.
If the space on the fonn is insufficient or if you wish to provide additional infoDnation,
you may attach additional pages.
PART I.

PRIm' OR Tn'E - SIGN ON PAGE 2
APPELLANr IDEm'IFICATION

NAME:

KIESEL, SHARON
(Last name, first name, middle initial)
8521 29th Ave Ct. S #6
HeME ADDRESS:

-:(::-:::Numbe---=-r-and--:--s-:-t-re-e~t:-;):---------------------

Tacoma, WA 98409
(City, state and ZIP code)
PHONE NUMBERS:

WORK:

(SCAN):

HOME:

(Include area cede )

EMPIOYIOO AGEOCY OR INSTITUTION:

_

(Off-SCAN):

_

(_20_6_)_5_8_4-_9_3_2_5

_

Dept of Corrections (McNeil Island Correction Center)

Agency or institution that took action you are appealing: _ _D_OC_(_M_c_N_e_i_l_IS_la_n_d CC)
REPBES~VE' S NAME, ADDRESS AND TELEPHCNE NUMBER:
. Swanson, Parr, Cordes, Younglove
Sue Zukowski
Peeples and Wyckoff, P.S.
Area Representative
PO Box 7846
10116 36th Avenue Court, #16
01 m ia WA 98507 (PH:357-7791
Tacoma, WA 98499 (PH: 581-4402)
An
Y aUUlUL:.L.Ze a repJ:eS
ve 0 act on h:[sjher behalf.
'!he BoaJ::d must be notified of any change in representation

PART II.

PART III.

TYPE OF APPEAL

Check one of the following to indicate the type of appeal you are filing:
~

a.

Disciplinary:
(check applicable action(s»,
_X_DiSmissal,
_ _Suspension, _ _Demotion,

_ _Reduction in Pay.

h

Disability Separation

c.

Rule or Law Violation (complete PART IV. of this fOD1\)

d

Reduction in Force/Layoff (complete PART IV. of this fODll)

e.

Allocation (position classification) (complete PART V. of this fm:m)

f.

Declaratory Ruling (see WAC 358-20-050)

g.

Exemption of Position
1

Appeal form
Revised 7·1·93

PART IV.

roR ROLE VIOLATICN OR REDOOrICN-IN-FtIRCE APPEALS <ELY

What Rule (s) or Law(s) do you believe were violated?

Explain the particular circumstances of the alleged violation.

How were you adversely affected by the alleged violation? .

What remedy axe you requesting in this case?

PART V.

Has there been a review of your allocation?
If so, by whom?

_Yes or _ _No
_

What is your present classification?

_

'Ib which class do you think your position should be allocated?

.. ' ,

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I

.

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.'

_

l

;

_.'

.

_2

Appeal form
I.vl • .,t 7.1.0'

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