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Home My WebLink About1993-08-03; City Council; 12340; RETENTION OF SPECIAL COUNSELCQ OF CARLSBAB - AQENa BILL 2 -2.2. .. AB#-D MTG.~~~?L. TITLE CITY DEPT.&L RECOMMENDED ACTION: RETENTION m OF SPECIAL COUNSEL Approve Resolution No. q 3 - 2x3, authorizing the retention special counsel for eminent domain proceedings, and defense liability and workers' compensation claims. I ITEM EXPLANATION The Council has previously authorized the City Attorney retain certain law firms as special counsel. From time time, these authorizations should be reaffirmed and amended include new law firms and current proposal letters. The Ci Attorney recommends that the City Council authorize t retention of the following special counsel and accept thc letters of proposal: GENERAL LIABILITY Daley and Heft Neil, Dymott, Perkins, Brown and Frank Butz, Lucas, Dunn and Enright WORKERS' COMPENSATION England, Hodik & Troviltlion Gillette, Loof, Langtorl & Hagner EMINENT DOMAIN AND CONIIEMNATION Asaro and Keagy Daley and Heft I F1SCAL IMPACT 9 2 2 0 2 0 4 E d 8 Z 5) Funds for retention of special counsel for liability E workers' compensation are already included in the City's sel insurance budget. Legal fees for assessment districts will funded and recovered from the district. The costs of le5 counsel for eminent domain proceedings must .be evaluated 01 case-by-case basis. EXHIBITS I. Resolution NO. 93-923 2. Letters of proposa:l from: Daley and He:Et Neil, Dymott, Perkins, Brown and Frank Butz, Lucas, Dunn and Enright England, Hodik & Trovillion Gillette, Loof, Langton & Hagner Asaro and Keagy r I- ': . om 3UJz !33m a08 Ow% iU, 304s E&: rr->o 6gw LYE%,. 0 E% cv :;32 OOLL aoA GO 1 2 3 4 5 6 7 0 9 10 11 12 13 14 15 16' 17 18 19 20 21 22 23 24 25 26 27 28 1, .m 0 RESOLUTION NO. 93-223 A RESOLUTION OF THE CITY COUNCIL OF THE CI'I CARLSBAD, CALIFORNIA, AUTHORIZING THE --- RETENTION OF SPECIAL COUNSEL WHEREAS, Section 2.14.130 of the Carlsbad Munic Code provides that the City Council may employ special col under terms it considers proper; and WHEREAS, the City Council has determined, recommendation of the City Attorney, that it is necessal retain special counsel for eminent domain proceedings, defense of liability and workers' compensation claims; anc WHEREAS, the City has received proposals from ce: law firms which are attached to this resolution as Exhibit and are hereby incorporated by reference. NOW, THEREFORE, BE IT RESOLVED by the City Counc the City of Carlsbad, California, as follows: 1. That the above recitations are true and cor 2. That the City Attorney is hereby authorizl employ the following firms as he considers appropriat accordance with the terms and conditions of the above-refer proposals: Daley and Heft Neil, Dymott, Perkins, Brown and Frank Butz, Lucas, Dunn and Enright England, Hodik & Trovillion Gillette, Loof, Langton & Hagner Heggeness & Sweet Asaro and Keagy 3, That the City Council authorizes the expenc of funds as may be necessary to pay the fees of special COI for liability and workers' compensation claims, respecti1 1 1 9- ,% 1 2 3 4 5 6 7 a 9 10 11 9m ~wZ Ow% an8 iUCJ 2035 ktsa 0002 S&$< OZJ? !?$m >-I= J I 4- “UzQ E:? 40-1 >cz 50 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 a 0 PASSED, APPROVED, AND ADOPTED at a Regular Meatii the City Council of the City of Carlsbad, California, on 1 3rd day- of AUGUST , 1993, by the following vote, to AYES: Council Members Lewis, Stanton, Kulchin, Nygaard, NOES: None ABSENT : None ATTEST: ALETHA L. RAUTENKRANZ, City Clekk ~ 1 2 ., (L/ .J .. O~NNB W, DU ' RO~T R. Hem BAN Gnoaucnvo~a NEAL 9. MMRP RICHARD J. Sc~rrctc~t~~ ROIBERT W. BRODICMAN, JR., MITCHEU. 0. DUN GIN0 P. PleTF40 RON J. BEVEFUWE DAVID P. BERMAN ROB~RT M. MIUSR JosepH M. HNYU<A ' Scorr NOVA JANET A. ALEXANDER WAUJEMI 0. HaKA M~~OARET A. HENDR~CK WILLIAM Gi; WHEATLEV JFI. Jmes 0. MATHISON TIM J. VANDENHRWeL %A 1. EOWARDB STePlieN G). BAPTl8T4 DALEY & HEFT momm AT LAW 482 STEVENS AVE SUITE 201 SOMA BEACH, CALiFORNlA 0207s PATRIC~A P TELEPHONE (619) 755 - 5666 FAX (619) 754 - 7870 OF CO p-. -. ;- !; ~ ___ Jiji\j *. 9 <.-:-.rj t l" G L c&k+&-& AOMINm January 7, 1992 Is;.L &*-. 2 r .,,;. .. a c ,.;: > CnJ'J:.. 2,: . . .: .> -e."" 2 Mr. Ronald R, Ball Acting City Attorney CITY OF CARLSBAD 3200 Carlsbad Village Drive Carlsbad, CA 92008-1989 RE: Daley & Heft Legal Fees Dear Ron: As you know, we have been billing our legal services at the rat4 of $90 per hour without an increase since September 1, 1989, almost two and one-half years. Due to continuing' increases in all costs of doing business, it has become necessary for us to raise our hourly billing rates to all our City clients. The new rates will be $95 per hour for general liability work a1 $110 per hour for eminent domain work. This will go into effecl for time billed after January 1, 1992, The new rates are still very competitive and will allow us to maintain a high level of quality in our legal services. We appreciate the opportunity to be of service to the City of Carlsbad. As always, if there is ever anything that we can do ' provide more effective and efficient service, please let US kno -" Veq truly .pdurs, De &* is W. Daley DWD:pc .. 0 e -. NEIL. DYMOTT. PERKINS. BROWN 8 FRANK A PROFESSIONAL CORPORATION ATTORNEYS AT LAW 1010 SECOND AVENUE, SUITE 2500 SAN DIEGO, CALIFORNIA 92101-4959 TELEPHONE (619) 238-1712 FAX (61 9) 238-1 562 William P. Ferrel Director of Administration July 19, 1993 Michael I. Neil mornas M. Dymott Roger 0. Perkins David G. Brown Robert W. Frank Gina L. Lacagnina Robert W. Harrison James Alan McFall Michael A. San Fillppo Sheila S. Trexler Constantine D. Buzunis Morgan M. LeBeau Hugh A. McCabe - DonaM F. Mlchael S Jaye E. 0 Marc D. I Sandra L. Tlm S. MI Clark R. t William C Julle K. P Loren N. KTIS P. TP Carolyn T Daniel R. James D. RECElVTD JUL 2 1 1993 Karen J. Hirata, Esq. Deputy City Attorney City of Carlsbad CITY OF CARLSBAD CITY ATTORNEY 1200 Carlsbad Village Drive Carlsbad, California 92008-1989 Dear Ms. Hirata: This is to inform the City of Carlsbad of our firm’s fec $95 per hour for attorneys, and $45 per hour for paralegals. I apologize for the delay in getting this proposal to office. Very truly yours, NEIL, DYMOTT, PERKINS, BROWN & F Roge &7&- G. Perkins RGP/ gd w 0 e 'I .- STEPHEN 0. LUCAS DOUGLAS M. BUT2 KEVIN A. ENRIGHT RICHARD L. BOYER BART J. MIESFELD KEVIN V. DcSANTlS K. ELIZABETH DUNN KEVIN A. PARK LINDA HUNT MULLANY ALBERT E. HAVERKAMP BUTZ, LUCAS, DUNN Q ENRIGHT A PROFESSIONAL CORPORATION ATTORNEYS AT LAW 101 WEST BROADWAY, SUITE 1700 SAN DIEGO, CALIFORNIA 92101-3881 TELEPHONE (619) 233-4777 FAX (619)' 231-0341 J. LAWRENCE OF COUN UNITED STATES 015 11982 - 19 SANDRA W. DIRECTOR OF ADN June 16, 1993 Ronald R. Ball, Esq. City Attorney City of Carlsbad 1200 Carlsbad Village .Drive Carlsbad, CA 92008 RECEWED J'N 1 8 1993 %2:g!$y;o Dear Mr. Ball: I thank you and Karen Hirata for your recent request for letter of proposal to serve as special counsel for the City Carlsbad as necessary. Our firm heartily welcomes opportunity to serve as special counsel for the City of Carlsk We are an AV-rated civil litigation law firm of el€ lawyers. In order to provide you and interested others P detailed information about our firm, I have taken the libertj . enclosing our firm brochure with this letter. The brocl provides detailed information about the philosophy and experit of our law firm. Within the brochure are contained biograph: sketches of the partners and associates. Hopefully, our brocl will provide sufficient detail to adequately reflect the qua: of the lawyers in our firm. Public entity and municipality law is one of our fi~ specialities. Our largest client within the specialty is the Diego Unified Port District, which we have represented for 1 years. We have always enjoyed a high degree of success in results we: have obtained not only for the Port District, but all of ow clients. In obtaining those su6cessful results'in litigation, we 1 always diligently striven to control the costs and expenses litigation. Although litigation is expensive, we pride ourse in our ability to minimize such costs as best we.can. Our attorneys' fees are $95 per hour. Work by paralegal's is performed at $60 per hour. I 4 ., c e 0 -. b ._ 1 Ronald R. Ball, Esq. June 16, 1993 Page - 2 - Invoices for services rendered are submitted on a mont basis. Those invoices include. costs incurred in defending clients. Examples of such costs include court filing fees, ca reporter fees, deposition transcript fees, jury fe photocopying charges, postage and other miscellaneous third pa and out-of-pocket expenses. In compliance with California Business and Professions C Section 6148 (a) (4), our firm maintains Errors and Omissi insurance coverage for its attorneys applicable to the semi performed by them. clients, not the reverse. We feel that it is of critj importance to listen to our clients in order to understand tt goals. We then strive to meet those goals through professic excellence and responsibility. The attorneys and staff of our firm are here to serve If you have any questions or comments, I will of course happy to answer them. We view our service to the' City Carlsbad as special counsel to be both an opportunity an privilege. Very truly yours, X@ w KEVIN A. ENRIGHT KAE: sp Enclosure r. r:. . - I. _ SUSAN I_. ENGLAND JOHN J. HUOfK, JR. DANlEL P. TROVILLION w. w. TROVlLLlON ANDRlS E ,N”ElSS MARK J. HOLL/xND BARRY W. PONTICELLO June 10, 1993 ENGLAND. HODIK 8 TROVILLION A PROFE*S,ON*L CORPORATlON ,551 FOURTH Ja”ENUE SUITE 210 SAN DIEGO. CALIFORNIA 92101-3150 CITY OF CARLSBAD 1200 Carlsbad Village Drive Carlsbad, CA 92008-1989 Attention Karen J. Hirata Re: Representation of the City of Carlsbad Dear Ms. Hirata: *RCA CODE 619 TELEPHONE 232-71 FAX 232-8423 Thank you for your correspondence of June 3, 1993. Enclosed herewith please find a copy of this firm’s Fee Schedule and Curriculum Vitae, You will note in reviewing the attorney information that three of our attorneys are certified specialists in workers’ compensation matters. Three have had extensive experience in handling cases involving public safety officers, including advising on and defending retirement applications. Two of our attorneys are also heavily involved in handling subrogation matters whereby it is sought to obtain back from negligent third parties monies spent on industrial injuries caused by them. We feel our attorneys are well versed in both common and unusual issues confronted by employers through the workers’ compensation system and ancillary laws. We would appreciate being considered for continued placement on the City’s list of approved counsel. Should you require any further information about our firm or any individual attorneys, please feel free to contact Angela Landeros, our office administrator, or one of the attorneys. Very truly yours, IrLE; && SUSAN L. ENGLAND SLE/ace Enclosures t 0 0 L. ’* . ENGLAND. HODIK 8 TROVILLION A PROFESSIONAL CORPORATION SUSAN L. ENGLAND JOHN, J. HODIK. JR. DANIEL P. TROVlLLlON W. W. TROVILLION ANDRIS E. INVEISS MARK J. HOLLAND BARRY W. PONTICELLO 1551 FOURTH AVENUE SUITE 210 SAN DIECO. CALIFORNIA 92101-3150 FEE SCHEDULE AREA CODE TELEPHONE 2 FAX 232-8 Services are billed at the rate of $105.00 per hour. Sam! charges for various types of services are as follows: Initial review of file, including filing and service of Answer to Application, review and filing and service of medical issues. ........... $105.00 - $210.00 (Depending on the extent to which the file contains extensive factual materials, records or medical file or other materials for review). Preparation and arrangements for service of Subpoena Duces Tecum for records ....... $21.00 - $42.00 Preparation and arrangements for service of Personal Subpoena .................... $31.50 Arrangements for deposition, including the obtaining of a convenient date, arrangements for court reporter and medical reports and correspondence analyzing legal and notification of all interested parties ..... $42.00 Preparation and forwarding of report on hearing, deposition or other proceedings ... $42.00 - $84.00 Review, filing and service of medical. $42.00 - $84.00 Arrangements for medical evaluation, including securing of appointment date from physician, initiation of appointment correspondence ........... $42.00 The above represents standard procedures. Charges for 01 services are billed on the basis of time spent. EHT/ace 4/92 I,' ~ 0 0 '*. , Law ofFces GILLETTE, LOOF, LANGTON 6r HAGNER NURMRN L, QILLETTE' A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 1905 BUSINESS CHARLES J. LOOF' KEITH D. LANGTON' SAN BERNARDINO, CA FAYE E. HAGNER' 7851 Mission Center Court, Suite 210 ROBERT C. MER' MARK A. BLOCK SAN DIEGO, CALIFORNIA 92108 1851 E. FIRSTSTF - MARK S. SILVER RAYMOND J. BORDELON STEPHEN C. PERETZ DAVID 6. NUS2 'Professional Law Corporation MAILING ADDRESS: P.O. 13~~ 880587 SAN DIEGO, CALIFORNIA 92168-0012 (619) 296-5684 FAX (619) 296-3854 SANTA ANA, CA %9pp, June 8, 1993 City of Carlsbad 1200 Carlsbad Village Drive. Carlsbad, CA 92008-1989 JuN 10 c Obc '$83 ki % '*4*4e1$e %f&L"" ATTN: KAREN J. HIRATA DEPUTY CITY ATTORNEY Dear Ms. Hirata: I am in receipt of your letter of June 3, 1993 requesting a lett of proposal describing our fees and related charges. Attached please find the fee schedule for workers' compensation a for workers' compensation subrogation, as well. As we have done in the past, we will continue to make it a practj to work closely with you and your workers' compensatj administrators and to make ourselves available for'consultation your convenience. If you have any questions or wish to discuss any matter,.please not hesitate to call at your convenience. Very truly yours, GIUETTE, LOOF, LANGTON 61 HAG1 By: czit&&igq CJL:pb Enclosures ,1 0 0 -*. . rroRyIEl L WmE' -1 J LOOF' KElTn 0 UNCITON' FA- E MACWiR' UAnA~woUC ncemc (03~~- - luRKs ShVFR RAyyo)(o J. #WIDELON pAVD8 MISZ STEP" C. PERER pmcuacul~caDorrwn b- GILLETTE, LOOF, LANGTON 6r HAGNER APART"HCLUO(m3PAOFESSKmUDTKWIS le03 BUSmESS ( W BERNARMNO. CM 7851 Mission Gnter Court, Suite 210 SAN DIEGO, CALIFORNIA 92 108 18Sl E. FIRST STRl I WLffiUX)(IESS SAHIA ANA. CM P.O. Box 880587 SAN DIEGO, CALIFORNIA 92168-6012 . (619) 296-5684 FAX (619) 296-3854 8CHEDULS O? PROFESSIONAL PEES WORIERS' COMPENSATION April 5, 1993 gervica Pee Review of Medical Reports or Medical Records; Review of Investigative Reports and Material; Including Views of Motion Picture Film; Deposition Analysis; Review Client'r Correspondence; Letter to Client; Telephone Conferences with Client; hdjustment of Hearing Time for TriaL of One-Half Day or Full-Day Carer; Xedieal Exam8/Conferencm with Appropriatr Correspondence to Doctor; Preparation of Cmptomise and Release Agreements; Baitd Formula Computations or Stipulations; Review of Rating Instructions and Recommended Permanent Disability Ratings; Review of Findings and Awards; Orders Approving Compromise and Release Agreements and Other Orders of theworkera' Compen8ation Appeal8 Board; Review of Petition8 to Reopen and Preparation of Answers thereto; and Correspondence to Client regarding my of the above. Appellate work; Including Review of or Preparation of Petitions for Reconsideration; Answers to Petitions; Research and Preparation of Petition8 for Writ of Review or Pet it ions for Hearing and Answers to much Petit ions. $1.05 e OO/b $lOS.OO/b Attorney Appearance at Deposition of Applicant; Witnesses or beetate. (MXNIMUM) $ZSOmOO Attorney Appearance at Workers' Compensation Appeals Board hearing. (MINIMUX) S25OmOO Review of New Incoming File, Letter of Analysis and Recommendations to Client. (MINIMUX) $180 00 Preparation; Issuance and Service by Mail of Subpoena Duces Tecum (Exclusive of Service or Copying Costs, if incurred) and Peraonal Subpoena.. $ 31.50 d. 'i ~ . * NOAUAN L OnLEm' CHARLES J LO" KEITH D WUiToN' FAYE E. WGNER' ROBERTC WER' MARK A. MOCK - MARK S. SILVER RAYMOND J. WRDELON STEPHEN C. PERETZ DAVIO 6. NUS 'PfOhUhd m cofPW8lwnr e. ( ,c ho/fL= GILLETTE, LOOF, LANGTON 6r HAGNER A PARTNERSHIP INCLUDING PROFESSlONAL ~f'ORATm lw5 BUSINESS SAN BERNARDINO. 0 785 1 Mission Center Gun. Suite 2 10 SAN DIEGO, CALIFORNIA 92108 1351 E FIRST ST1 y*KING ADDRESS: SANTA ANA. C4 P.O. Box 880587 SAN DIEGO, CALIFORNIA 92168-0012 (619) 296-5684 FAX (619) 2%-3854 SCHEDULE OF PROPESSXONAL FEES SUBROGATION April 5, 1993 Service Fee Review of New Incoming File; Letter of Analyeis and ' Recommendations to Client; Review of File for Periodic Diary; Review of Pom/Supplemental Interrogatories and Answer Interrogatories; Deposition Analyeis; Review of Client's correspondence; Letters to Client; Telephone Conferences with Client; Review of File for Preparation of Court Appearance and Deposition; Review of File for Recommendations of Claims Handling to Client; Review and/or prepare Demand and Responses of Inspection of Documents, Demand and Responses of Request for Copies of all Documents, Pleadings and Discovery, Request and Response6 for Special Notice, Notice of Deposition, Memo of Points and Authorities, Declarations/Supplemental notion, Review of Notice to Transfer and Oppositions to Transfer; Review of Stipulation for Consolidation of Cases, Review of Case Management Questionnaire; R,evfew of Offer to Compromise; Review of Plaintiff 'a Statement of Damages. Declaration#, Notice of Motion and of Opposition to $105.00j Review Summons and Complaint; Review of Answers to Complaint; Preparation of Complaint in Intervention, Points and Authorities and Declaration; Preparation of Notice of Motion; Preparation of Acknowledgement and Receipt; 'Preparation of Case Management Questionnaire; Preparation of Expert Witness Statement. $105*00, Attorney Appearances at Depositions for Plaintiff, Defendants and Expert Witness(es). Attorney Appearance at Status Conference; Case Management Conference; Trial Settlement Conferences; Disposition Conference; Motions; $105 00 I’ 4. 0 0 - :- ’. RECEIVED ASARO & KEA@! ATTORNEYS AT iAW JUN - 9 19 @ FRANK L. ASARO ROSCOE 0. KEAGY RICHARD R. FREELAND ARNOLD NEVES. JR STEVEN A McKlNLEY GARY L SIROTA FOURTH FLOOR 3170 FOURTH AVENUE CITY Of CARLSEAO SAN OIEGO. CALIFORNIA 92103 CITY AlTORNEY TELEPHONE 1619) 297-3170 IN REPLY TELECOPIER (61s) 299-426.~ June 8, 1993 REFER TO: Ms. Karen J. Hirata Deputy City Attorney City of Carlsbad 1290 Carlsbad Village Drive Carlsbad, CA 92008-1 989 Dear Ms. Hirata: The following is in response to your request that we provide you with a propos? provide legal services as necessary to assist the City in eminent domain and other real esi related matters. Asaro & Keagy would be pleased to provide legal services as outlined above, Our bi rates are: $1 50 per hour for partners $1 15 per hour for associates $ 55 per hour for paralegals. These rates are substantially less than those charged to private clients; however, the! consistent with our firm’s charges to other governmental or quasi-governmental entities. would also bill for photocopies, fax transmissions, long-distance telephone charges, and t costs. All billings are made monthly for work performed the preceding month. Our firm has extensive experience in condemnation and real estate matters and represented or currently represent numerous condemnors, including the Cities of Chula \ Coronado, Del Mar, Escondido, La Mesa, and San Marcos. Our firm has also representec Calexico Redevelopment Agency, Cajon Valley Union School District, the County of San D Escondido Union School District, Fallbrook Sanitary District, Jamul-Dulzura Union School Di! San Diego Gas & Electric Company, the San Diego Unified Port District, the Walnut L Municipal Water District; and the San Diego County Water Authority, In addition to representation of public agencies and other condemnors, we have exte experience in representation of property owners in condemnation proceedings. In conjur with the prosecution and defense of condemnation matters, we have worked with numl experts, including real estate appraisers, engineers, architects, biologists, environment geologists, land planners, accountants, and goodwill appraisers. " * b e** . 0 e Ms. Karen J. Hirata Office of City Attorney Page 2 June 8,1999 Asaro & Keagy also has had extensive experience in providing legal service! institutional, public agency, and developer clients in connection with real estate matters. A: & Keagy is prepared to render legal services for general real estate matters at your reql including real estate transactional matters and those which might result from condemn; activity. Resumes of Frank L. Asaro, Roscoe D. Keagy, and Richard R. Freeland, the partners would be primarily involved in providing the services requested, are all attached for 1 information. We welcome the opportunity to provide services to the City of Carlsbad. Please feel to call should you require further information. .Very truly yours, ASARO at KEAGY &a& Roscoe D. Keagy d RDWmad En-. q k e a RONALD R. BALL CITY AlTORNEY CITY OF CARLSBAD 1200 CARLSBAD VILLAGE DRIVE CARLSBAD, CALIFORNIA 92008-1989 (61 9) 434-2891 FAX: (61 9) 434-8367 4 KAREN J. HIRATA DEPUTY CITY AlTORNEY March 11, 1993 Cathy L. Jensen, Esq. 14252 Culver Drive Suite A570 Imine, California 92714-I918 RE: TURNER V. CITY OF CARLSBAD, ET AL. Dear Ms. Jensen: Thank you for your letter of March 11, 1993 regarding this case Please subpena the requested documents so that we may assert tf appropriate defense, if any, to their production in court. Ar disputes between us as to the production of documents may k resolved by the court in this case rather than a separate lawsuj involving the Public Records Act. This will save us both time j the long run and not burden the judicial system with anotht lawsuit. Should you have any questions regarding the above, please do nc hesitate to contact me. rmh c: Chief Vales City Clerk J' v&R* k. truly yours, RONALD R. BALL City Attorney k * I )t e -. "_ .-.- e W&%y 9 2 Attorney at Law March 11, 1993 ~SM~WED VIA FACSIMLLE AND MAILED ON ABOVE DATX RON BAIL City Attorney ROBERT C. VALES chief of Police LEE RAUTENKRANZ city Cbrk City of Carlsbad 1200 Carlabad Village Drive Carlsbad, CA 92008 .. . .. . . .. . . ._ ,. .. . .. . - .II RE: CALIFORNIA PUBLIC RECOmS Am REQUEST Dear Sir8 and Madame: Pursuant to the California Public Records Act, (Governmr code 6eckion 6250 et seq.) T request khat you provide he with t . documents, photos, tape and/or video recordings described he101 1. With respect to the Carlsbad and . Oceanside pol: activity on July 25, 1991, 1.:30 a.m., involving.Anthony Ray Turn4 Case No. 91015634, subsequently referred to as the INCIRENT, plei provide me with all documents, photos, tape and/or vi{ recordings: a. Any and all WRITINGS, PHOTOS and RECORD11 concerning the INCIDENT, specifically including, but not lirni- -bo all police reports, whether primary or supplemental, K9 b reports, daily lags of participating officers, transmission tap b. Any and all WRITINGS, PHOTOS and RECORD1 rsoeived from outside agencies concerning the INCIDENT. d. Any and all WRTTINGS Yeflecking the polid training and police practices regardihg the use of canines (Kg) the detecrtion, location or apprehension of any persons, or the of canine8 (Kg) as a law enforcement tools by the Carlsbad Po1 Department. d, Par the preceding five years, all statisti compilatians, analysis, evaluations, studies or surveys of search/use by the Carlsbad Police Department. 1 14252 Culver Drive, Suite A570, Irvine, Calfomfa 92714-1918 (714) 843-6363 f .I z * s e 0 e, my and all reports, analysis, inquiries, or studies relied on by the Carlabad Police Deparhnent reflecting or analyzing 02 C6nSidWing the medical, psychological, physiological, legal or social risks pomd by %he use ofi CaIliris?S to apprehend or detain persone f. Any and all WRITINGS reflecting the policies, traintng and palice praotioes of the Carlsbad Police Depaement regardin the use of force in the apprehension of suspecks in either m 9 ademeanors or felonies. 4. Any and all WRITINGS reflecting the policies, training and police practices of the Carlsbad Police Department rqard-ing the use of high speed chases in the apprehension of criminal auspacts. DATEDt March ii, i993 .. .. '. , , , . - . . . . . . -. . : , . . .. - .. , , .. 2 A I. -. v 3 I- 14252 Culver a, suite M70, twine, Catibrnia Sne.(9@(m) 843-6363 DATED: March li, 1993 - .. , .. 2 I) 0 CITY OF CARLSBAD 1200 CARLSBAD VILLAGE DRIVE CARLSBAD, CALIFORNIA 92008-1 989 (619) 434-2891 RONALD R. BALL FAX: (61 9) 434-8367 CITY ATORNEY KAREN J. HIRATA DEPUTY CITY AlTORNEY August 13, 1992 4 Philip Paul Bowe Davis, Cowell & Bowe 20th Floor 100 Van Ness Avenue San Francisco, CA 94102 RE: FLOYD C. ODEN ET AL. V. BOARD OF ADMINISTRATION OF THE PUB1 EMPLOYEES' RETIREMENT SYSTEM, COUNTY OF RIVERSIDE, ET AL. Dear Mr. Bowe: The City of Carlsbad received your Notice and Acknowledgement Receipt of the trial court's writ of mandate in this act: addressed to me. I am not the agent for serivce of process. you wish to serve the City, please serve Aletha L. Rautenkrai City Clerk, 1200 Carlsbad Village. Drive, Carlsbad, Califor] 92008. I appreciate your prompt attention to this matter. vLQ*k ruly yours, RO D R. BALL City Attorney rmh c: City Clerk / " -