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Bylaws and/or for any other good and sufficient cause
including but not limited to the following:
(a) The NCUA's [National Credit Union
Association] expressed concerns over
management practices including underwriting
policies and collection policies;
(b) Mismanagement associated with Dale Armstrong
and Cemetery Services, Inc.;
(c) Mismanagement associated with the purchase of
automobile conditional sales contracts;
(d) Mismanagement associated with the failure to
follow applicable FHA regulations in
connection with its home improvement loan
program;
(e) Mismanagement associated with employee
problems and concerns; and
(f) Failure to follow Board policies and Bylaws
in connection with the foregoing.
(2) Set forth in writing the reasons for the proposed
removal;
(3) Establish a time and location at which Mr. Goeden
may appear before the Board to rebut allegations
made against him which such time to be not less
than five (5) business days subsequent to mailing
to Mr. Goeden the Written notice described herein.
Various matters pertaining to petitioner's employment were
discussed at nine board meetings held between April 8, 1988, and
September 15, 1988. Although some of the allegations of
petitioner's mismanagement were challenged by some board members
as being false, neither petitioner nor his attorney, as reflected
in the board's minutes, specifically indicated at board meetings
that a suit based entirely on libel, injury to professional
reputation, or defamation would be brought by petitioner against
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