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Home My WebLink About1995-04-04; City Council; 13093; RETENTION OF SPECIAL COUNSEL,I v a LBB i5 E 6b 4 z O 0 U r g 3 8 CI@ OF CARLSBAD - AGEW BILL 3x AB # '3. (3 9 3' RECOMMENDED ACTION: CITY DEPT. CITY RETENTION OF SPECIAL COUNSEL MTG. 4/4/95 DEPT TITLE: CA Approve Resolution NO. q5-83 , authorizing retention additional special counsel for defense of general liabilj 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 Cj Attorney recommends that the City Council authorize t retention of additional special counsel for general liabilj and workers' compensation claims by retaining the Law Offic of Charles A. Viviano; Heggeness & Sweet and Graves, Robers & Bourassa and accept their letters of proposal, GENERAL LIABILITY Daley and Heft Butz, Lucas, Dunn and Enright Law Offices of Charles A. Viviano I WORKERS' COMPENSATION England, Hodik Q Trovillion Gilllette, Loof, Langton & Hagner Heggeness & Sweet Graves, Roberson & Bourassa EMINENT DOMAIN AND CONDEMNATION Asaaro and Keagy Daley and Heft I FISCAL IMPACT Funds for retention of special counsel for workex compensation are already included in the City's self-insurar budget o I EXHIBITS 1 o Resolution No. 9 5-8 2 2. Exhibit "Att, Letter of proposal from the Law Offices c 3. Exhibit OlBll, Letter of proposal from Heggeness & Sweet 4. Exhibit 'lC1l, Letter of proposal from Graves, Robearson Charles A. Viviano, dated March 24, 1995. dated March 28, 1935. Bourassa, dated January 14, 1994. !# I 1 2 3 4 5 6 7 8 9 10 11 D sug I?? cr“A an8 Ow$ iLCl a>~i uogu ““8 DODL 2,s. zwrJY4 oz-ro ““90 zz2 0 iA aoA 50 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 a 0 RESOLUTION NO. 95-87 A RESOLUTION OF THE CITY COUNCIL OF THE C: CARLSBAD, CALIFORNIA, AUTHORIZING THE RETENTION OF ADDITIONAL SPECIAL COUNSEL WHEREAS, Section 2.14.130 of the Carlsbad Mun: code provides that the City Council may employ special C( under terms it considers proper; and WHEREAS, the City Council has determined, recommendation of the City Attorney, that it is necesse retain additional special counsel for defense of g( liability and workers‘ compensation claims, and WHEREAS, the City has received a proposal from tl Offices of Charles A. Vivian0 which is attached to resolution as Exhibit llA1l and is hereby incorporatc reference; and WHEREAS, the City has received proposals Heggeness & Sweet and Graves, Roberson & Bourassa whic ~ attached to this resolution as Exhibits I1BVr and I1C1’ an hereby incorporated by reference. NOW, THEREFORE, BE IT RESOLVED by the City COUm the City of Carlsbad, California, as follows: 1. That the above recitations are true and cox 2. That the city Attorney is hereby authoriz emplay the Law Off ices Of Charles A. Viviano; Heggeness & z and Graves, Roberson & Bourassa as he considers appropriz accordance with the terms .and conditions of the att proposals. i ~ 3. That the City Council authorizes the expend ~ of funds as may be necessary to pay the fees of special cC ~ I i’ +. + n m>- &Em ao0, zuz d;;% s:2$ dk5U 0009 zwma $Gsi 02-10 “US0 E:; 40-1 gzz 0 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 0 0 for liability and workers‘ compensation claims, respectiv PASSED, APPROVED, AND ADOPTED at a Regular Meeti the City Council of the City of Carlsbad, California, on 4th day of APRIL , 1995, by the following vote, tc AYES: Council Members Lewis, Nygaard, Kulchin, Finnila NOES: None ABSENT: None ATTEST : ALETHA L. RAUTENKRANZ, City Cferk 2 .. <* 0 0 ALSO PRACTICING IN: IMPERIAL COUNTY RIVERSIDE COUNTY LAW OFFICES OF CHARLES A. VIVIANO CHARLES A. VIV 8880 RIO SAN DIEGO DRIVE, SUITE 800 *ALSO ADMITTEC SAN DIEGO, CALIFORNIA 9~108 HAWAII TELEPHONE: (619) 688-0080 FACSIMILE: (619) 688-0081 RECEIVI MAR 2 7 ; March 24, 1995 CI'I'Y OF CAR1 CITY AlTOR Ronald R. Ball, Esq. City Attorney City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92008 Dear Mr. Ball: I wish to take this opportunity to thank you and Mr. Rudol for meeting with me on Tuesday, March 21, 1995, and requesting subsequent to that meeting, that I submit a letter of proposal serve as special counsel for the City of Carlsbad on an as neec basis. As I informed you, my firm is of counsel to my former 1 firm Franco Bradley & Martorella, formerly Vivian0 & Bradley, i I welcome the opportunity to serve as special counsel for the City of Carlsbad, I am an av rated civil litigator, and my former firm is al av rated. In order to provide you and interested others with detailed information about myself as well as the firm of Francc Bradley & Martorella, to whom I serve of counsel, I have taken the liberty of enclosing their firm resume, which includes my resume as well. Also included, you will find a letter from the County of Imperial, as well as the certificate granted me for outstanding service by the County Board of Supervisors. The brochure provides detailed information about the philosophy and experience of both Franco Bradley and Martorella, as well as my own experience. Within the procedures are contained not only m: biographical sketch, but that of the partners and associates of the firm of Franco Bradley 6: Martorella as well. These individuals would serve as "back up" attorneys in the event assistance was needed on any case I was working on for the City I. I. 0 0 Ronald R. Ball, Esq. March 24, 1995 Page No. 2 Public entity and municipal law has been my primary specialty for over fifteen years. As we discussed, prior to entering private practice I handled the most serious injury ca for the County of San Diego in the area of personal injury wor with emphasis on road design and dangerous condition cases. Prior to that, I served in the same functions for the City and County of Honolulu. Since leaving the employ of the County of San Diego, I formed my own firm, Viviano b Bradley, now Franco Bradley & Martorella, which emphasized public entity defense. Additionally, as my resume reflects, I have taught courses on: handling of dangerous condition cases for the County Counsel's Association, as well as the Office of the Attorney General., St: of Hawaii, Besides obtaining successful results in litigation for governmental entities, I have always striven to control the cob and expenses of litigation activities. In this regard, I have always made sure that the services provided were not only extremely competent in nature, but cost effective. My current rates for legal services are $100 per hour for attorney time, and $60 per hour for paralegal time, Invoices for services rendered are submitted on a monthly basis. Invoices include, in addition to professional services rendered, costs incurred in defending a client. Such costs include court filing fees, court reporter fees, deposition transcript fees, jury fees, expert witness fees, photocopying charges at $.lo per page, postage, and fax charges at $.25 per page, in addition to other miscellaneous third party and out of pocket expenses. Mileage is not charged. Other than the costs outlined above for photocopying and fax charges, all costs are billed to the client at actual costs incurred by me. There is 1 mark-up on any such services, In compliance with the California Business and Professions Code Section 6148 (A)(4), my offices as well as those of Franc0 Bradley & Martorella, maintain errors and omissions insurance coverage applicable to the services performed. I. a 0 Ronald R. Ball, Esq. March 24, 1995 Page No. 3 I believe that in checking with the County of Imperial, f whom 1 have served as primary litigation counsel for the past seven years, you will find that the professional services rendered have been extremely satisfactory, and the costs extremely reasonable. If you have any questions or comments I would, of course, be happy to answer them. I would view the opportunity to serve the City of Carlsbad as special counsel a: an opportunity and a privilege. Sincerely, THE LAW OFFIC S OF i Cz?@/F i '6% - ClTar es. A. Vlviano CAV: emb Enclosures atty/cav/ltr-rb.0323 1IlIIL LY uu 1UL LU.-IU flCUUGIYG33 (Y 3WGGI rnA NU, ItiIYZdIUtidZ r, uz .. 0 FLIFFORD D. SWEET 111 * TERRV HEQaENE99 * ROBERT V. LaBERGEr JOHN P. MULLER HARRY E. TEAR 111 JULIE E. SHAW SHARON E. MolAUGHLlN A.J. DAtTCH * ALICIA C. EASKETTE KAREN KROM BOYLE RANDALL W. MOORE HERNAN 0. CETINA BRIAN T. HACKLEY LYNN PIERCE WHITLOCK Jill Ft. HGGWEIN HEGGENESS & SWEET hW OFFICES OF OWECWNlY (716 550-il33 A PRQFfisslPNAL CORPORATION -ASH PUW4 SAN DIE=, CALIFORNIA 82101-3404 (8 1 91 237- I 200 FAX (6 1 0) 237-0632 BAN RERNAFIPOVOlRiVER 0" PHILLIP L. HACW 350 WEST ASH STREET. SUIT€ 803 of Coumsel March 28, 1995 * GEFlllFIEO SPECWST WRK€R.$GOMPENsATI~ LAW BolAFlD OF LE% BPECIALIzAfloN WAYE BAR OF CALIFORNIA City Attorney's Office City of CarLsbad 1200 Catlabad Village Drive Carlsbad, dA 92008 VIA FAC~IWILE~U.~. MAI~,~ Genklepersone; "his is in 'follow up to my telephone conversation with Ms. &din DOemer of your office an March 28, 1995, mi6 is in reference to Mr. Sweet's Scgtember 20, 1993 letter to Mr. Lctsch concerning the expression of interest on the part of the City of Carlsbad eo consider engaging the services of this firm with respect to the defeme of its workers' compensation meters. We previously had forwarded to you a copy of our Resume and Billing and Litigation mnagement Guidelines. I understand that you still have those and there is no need for re- sanding them. We are interested in exploring your workers' compensation defense needs and how OUT office could service those needs. As before, if you have any puestionrr or if you need any additional i!lfOI'lDatdOll, please do not hesitate to contact the underdgned- We thank you very much for your expression of interest in our firm. 9x:mlcl Very truly yours, m \\ Em Si3 & SmKT, A P,C. g"-%&U.~ erry He99 w ~~ 1. *. 0 e HEGGENESS & SWEET Firm Resume I? pv. RATES The firm’s philosophy is to have general rate increases as infrequently as pot However, like everyone else, Heggeness & Sweet has experienced a progressive in1 in our own cost of doing business, in large part due to escalating salary structures 7 the San Diego legal community for knowledgeable and experienced attorneys as P for clerical support. Effective January 1, 1990, the California workers’ compensation law was drama amended placing increased demands upon defendants and their defense attornc quickly and aggressively investigate and resolve claims. Since it is the objective of the firm to maintain a stable staff of knowledgeab experienced attorneys, the’ firm does not desire to lose valuable employees beca salary pressures. Accordingly, the firm’s general rate increases were: m November 1, 1985 November 1, 1989 December 1, 1991 $ $5 per hour $ 95 per hour $105 per hour Civil Litigation $130/$110 per hour Paralegal (workers’ comp) $45 per hour Paralegal (civil) $60 per hour Exnenses Photocopies Facsimile Local travel Long distance travel Cash advance fee Telephone Postage Storage Parking 16C per page 50C per page Waived 21C per mile waived waived waived 30C or lower waived Waived (all hard copy fies are purged 5 years from date our file is closed) A special hourly rate of $155 an hour will be charged for designated Special Invest Unit (SIU) files involving suspected criminal misconduct or organized unfair b1 practices. These cases present eomplex issues calling for special howled! ," e" f .e 0 HEGGENESS & SWEET Firm Resume Pagc expertise on the part of defense counsel. These cases frequently involve highly unus investigation and extensive discovery battles with well financed and highly organi business entities suspected of having engaged in unlawful activities, This rate qQ only to specially designated SIU cases. V* COST CONTROL The firm does not charge for attorney travel time or travel expense with resgect to ! Diego, Santa Ana, or San Bemardino Workers' Compensation Appeals Bo; appearances. AU billing statements are hlly itemized to the nearest l/lOth of an hour. Transportatj charges are made only for necessary appearances outside of the San Diego, Santa A and Riverside metropolitan areas. Heggeness & Sweet has always avoided abusive billing practices. We do not "task bil We have no arbitrary pre-determined flat charges, minimum time billings, or physic file set-up or storage fees. What clients pay is straight time at the fm's hourly rai Support work is performed by legal assistants at a much lower hourly rate. The res1 is a comparably lower fd total bill per litigated case. VI. LITIGATION MANAGEMENT AND BILLING GUIDELINES Subject to the desires and objectives of a particular client, the case handling philosopl of Heggeness & Sweet has been and continues to be to achieve case closure ~ expeditiously and as inexpensively as possible. This is achieved by prompt prepanti( of each case for early settlement, or if unsuccessfbl, prompt adjudication. Heggeness & Sweet takes great pride in the fact that some years ago we established a published to each of our clients our own comprehensive Litigation Management m Billing Guidelines. These were last revised effective January 1, 1990. If you want copy, please give us a call. I., - e a STEPHEN D. ROBERSON' MARSHALL W. GRAVES' M. GARY BOURASSA' H€VIN PATRICK MCVEROV OTTO P. CIPOLLA, JR. JOSEPH W. RIPPINGER. m STEVEN L. RICE ROSS M. BARTON FRANK C. WYMOND. m EDWARD R. CALABA COLLEEN MARMOR GARY E. SKAWIN SUSAN NOVELL ERICK B. JAVAfuEAU *A PROFESSIONAL CORPORATION GRAVES, ROBERSON 6 BOURASSA ATTORNEYS AT LAW SUITE 220 THOUSAND OAKS C 17821 EAST SEVENTEENTH STREET SUITE 100 TUSTIN. CALIFORNIA 92680 1200 WEST HILLCRES (714) 573-8488 THOUSAND OAKS, CALlFORh (818) 707-1333 a (8051 .. . .. ;>; ;; A 7, , . . /* j .. January 14, 1994 Attn: Ms. Erin Letsch CITY OF CARLSBAD 1200 Carlsbad Village Dr. Carlsbad, CA 92808 Dear Erin: Thank you for taking time from your busy schedule to meet w: me yesterday. As we discussed, our office has specialized in 1 defense of workers' compensation cases for the last 14 years. represent a wide variety of clients including self-insurec carriers and public entities. We bill at $110.00 per hour i provide itemized billings on a monthly basis. Pursuant to your request I have attached a copy of both resume and business card. We take pride in our aggressive and responsive representat: and would look forward to the opportunity to be of service to J and your staff. should YOU have any questions please feel free to contact office. GB : dap Enc . Very truly yours, GR&YES, ROBERSON & BOURASSA - &Y+ GM~ BOURASSA .<er 0 e RESUME OF GARY BOURASSA EDUCATION Juris Doctorate - Western State University College of La1 Fullerton, California Honors : Law Review Staff Bachelor of Arts - California State University Long Beach, California Honors : Dean's List EXPERIENCE ATTORNEY - Workers' Compensation Litigation Extensive experience includes successful litigation at the trial level. Specialization in workers' com- pensation'defense representing insurance carriers an( insurance administrators for both private and public self insured employers. Additional experience cover2 the preparation and handling of Longshoremen and Harbor Workers' cases. Association includes: Graves, Roberson & Bourassa Agoura Hills, California (January 1982 through present) Whiting, Falk, Graves & Robers Thousand Oaks, California (March 1981 through December 19E WORKERS COMP JUDGE PRO TEl4i)C)EZE - Swern ir? April 17, 1985 TEACHER - California Lutheran College Taught upper division business law (1984) HOUSE COUNSEL - Workers' Compensation Litigation State Compensation Insurance Fund Long Beach, California (1979-1981) .< . I. , .% e 9 RESUME OF GARY BOURASSA PAGE TWO , HOUSE COUNSEL - Corporate Law Experience includes drafting and negotiation of oil and gas leases, operating agreements, land purchase advisement to management staff. and sale agreements, Responsible for all legal Union Oil Company of Californj Los Angeles, California (1977-1979) PROFESSIONAL AFFILIATIONS: Admitted to State Bar of California, 1976 Member, American Bar Association Member, Ventura County Bar Association I e 0 RONALD R. BALL CITY ATTORNEY KAREN J. HIRATA DEPUTY CITY ATTORNEY CITY OF CARLSBAD 1200 CARLSBAD VILLAGE DRIVE CARLSBAD, CALIFORNIA 92008-1989 (619) 434-2891 FAX: (61 9) 434-8367 January 5, 1994 Daniel Callaway, Esq. 1020 S. Santa Fe Avenue, Suite F Vista, California 92084-7003 RE: SHARON MARIE CARNO V. CITY OF OCEANSIDE, CITY OF CARLSBAD, ET AL. Dear Mr. Callaway; . I received your letter of January 1, 1994. As I have indicated prior correspondence, I would advise against pursuing this mat. . against the City of Carlsbad or its police chief, as your clien. complaint states no cause of action against either party. In considering this matter, I would draw your attention to Ci. Code section 43.55 which states: "There shall be no liability on the part of, and no cause of action shall arise against, any peace officer who makes an arrest pursuant to a warrant of arrest regular upon its face if the peace officer in making. the arrest acts without malice and in the reasonable belief that the person arrested is the one referred to in the warrant. I' As I have indicated and the arrest report demonstrated, the pro: procedures were followed by Carlsbad in executing this warrant I would also like to clarify a possible misunderstanding, regard dismissal of this suit. My letter of December 30, 1993 reques' that you dismiss Carlsbad and the police chief from this litigat without prejudice, not with prejudice. If you still wish to pursue this matter, you must serve complaint by serving the City Clerk at 1200 Carlsbad Village Dri Carlsbad, California, during normal business hours from 8 a.m. 5 p.m. Monday through Friday. e 0 I would like to reiterate, that if your client does proceed 1 this lawsuit we will hold her responsible for all costs attorneys' fees, and we will seek all available sanctions. I appreciate your prompt attention to this matter. V*ruly yours, af d LL-4. (2. Lae RONALD R. BALL City Attorney - c: Lee Rautenkranz, City Clerk Robert Vales, Police Chief Erin Letsch, Risk Manager t 0 0 i CITY OF CARLSBAD 1200 CARLSBAD VILLAGE DRIVE CARLSBAD, CALIFORNIA 92008-1 989 RONALD R. BALL CITY ATTORNEY KAREN J. HIRATA DEPUTY CITY ATTORNEY (6 1 9) 434-289 1 FAX: (61 9) 434-8367 4 December 30, 1993 Daniel Callaway, Esq. 1020 S. Santa Fe Avenue, Suite F Vista, California 92084-7003 RE: SHARON MARIE CARNO V. CITY OF OCEANSIDE, CITY OF CARLSBAD, ET AL Dear Mr. Callaway: I received your letter of December 28, 1993 enclosing the summon: complaint in this case. If you want to serve it, you must do E serving the city clerk at 1200 Carlsbad Village Drive, Carls California, during normal business hours from 8 a.m. to 5 p.m. Mc through Friday. However, I would advise against doing so at time since your client's complaint does not form the basis of action against the City of Carlsbad or its police chief. I have reviewed your complaint and the underlying arrest which place on April 9, 1993 pursuant to a felony warrant issued Aprj 1993. There was nothing unusual in the procedure followec Carlsbad to execute the warrant and it is standard procedure fo~ criminal justice system function. There is nothing in your cornpl indicating that Carlsbad or its police chief did anything wror the execution of the arrest warrant. I am enclosing a copy of your client's two-page arrest repor order to substantiate the above. After you have reviewed it satisfied yourself that Carlsbad did nothing wrong in the exes of this warrant, I respectfully request that you dismiss it anc police chief from this litigation without prejudice. If you insist on serving the City and proceeding with this law: we intend to hold you responsible for costs and attorneys fees tc fullest extent allowable under law. I appreciate your prompt attention to this matter. agency to honor warrants issued by another agency to make V ry ruly yours, &kk ONALD R. BALL afd enclosure c: City Clerk Police Chief Risk Manager City Attorney .. 0. SAN DlEW REGIONAL L G NOTIFY WARRANT W z a 0 I w w I- I a a 4 - 2 + E! P, a u v) w 0 w * YI SUSJLCT A SUSCCCTKO - - 1 LENGTH PE/ "*'b ' HAiRSTYLE WE SPEECH COMPLEXION FAClALHAiR ORIVCR'S LlCCN - j l 8ALO I ' 1 AFROINAT. , 1 CLLAN SHAVS I ACCZNT 1 ACNC 1 DISOUISCO rn 1 p- ICOLLAR , 1DRAlOCD j ZPULLBLARO 2DARX 3 ausnv j 3 tU MANCHU 3 LOUD lMUWSL=S 3 FR=CXUD 2 LISPS s%~?u<l- i t n,On C,TCW .4 NECK 4 GREASY ' 4 GOATIC I 4 Lsnr 55 - ?o = 4 LOW PITCH OCCLNSIVC I 5 SUORT s MtLltARY i s Lowrw"P I-~DIUM ! ~~C(OU~OC~ ~ 6CONYTAIL $'Cml N? eSDlUM &utrT 7 moccnco i&~~?~~~z 7 COCKED 6 CALX 6 RAPID 1 COARSE 7 SLOW 6 WOMOTONC 7 NASAL 8 8 SIDCBURNS I RUDDY : I CLeASANT ' I STUTTIRS &::x ;&J!;?:&LY: 9 UNSHAVCN 9 SALLOW TALXATIVC 9 RA8.Y 4 THINNING '1ow1o I WIRY 6 OTUCR: jll OTHER: ~ 11 OTHCR: 10 VAN DYKC 10 son 10 TANNCD '10 OTHmR: 11 OTHCR: !i =It No- 11 OTHCR: u1 2 OTHCR 1.D. F LL ! i 131 .ai /mnnimnC?tnn :::...C mn' FU,RTULR SUSPCCT OLSCRIPTION (1.1.. GLASSLS. TATTOOS, TCETH, SIRTHMARKS. JCWCLRY, SCARS, MANNCRISMS, CTC 1 " ARJIS-a 1Rw *-a?) . 0 0 * P%GC s 2 01. z, lAW FATHCR/¶TLPfATHCR'S NAME (L.F,Ml HOMC ?MONS ' 'AOORCSS CITY \ I MOTUlR/STLPMOTULR'S NAYC 1L.F.M) HOME CUONL ADDRESS CITY * 1 ~ GCHOOL GRAOL j PARENTS NOTIFIED 8Y: WHOM AN0 UOW DATE it 2 ii j 0, Ill Id 'LIVES w>. RLLLASL DA izz w a- JUVLNILL z -OTHER "_ . I 5 FILL0 DISC.: HALL POLlCL AGENCY: *QrnC'I 5, - OTHCR: - 'ATTITUOC OF JUVENILE AN0 PARENTS/GUAROIAN wu.lrnrnclr.wlr 'I I, 11 oCT. OISPO.: E- RCFLR COURTIPROB 5-OEPT. DIVERSION El-COUflLLIINVORMAL 3 -0TUtR j I AOOITIONALCHARGES: 11 !NARRATIVE: . . I yze I Hi7 HP?l&X ///- r daw5 HH/W "4"' ufi I; 12 YR? Fes7AQ 7p G%;z - a I sbp A -<"4/7# /Y AUdv z #B//#d z t@dTrnW G€ &e!iFSzFa Dv Y9 adAHmm &.mJv ~ s //)5m 75~L k - 'I i I have arresrsd / /, v 1 1 0 For a public offense. committed or attempted in my presence. j 1 0 When the penon arrested has committed a felony, although not in my preSOnca. ! L 0 hen a fehv hm been in fact committed. and I ham rcasaneble cauM far helidvinp rhr Mnon anemd to have committed it. !ai ia ICE 4 the prisoner, which ant c to Section 849 of the Pend Code of the State of California, it is neeassaw for me to sign a complaint Statin made before a magistrsts, and I agw to sign said complaint and wemar in said matter wit) ;z iw ik !V I I iN I .""% Date: Signed: 1 RES. ADORCSS ARRESTING CITIZIN (L.F.My PRINT CITY BUS. ADORLSI CITY I .US. PHONS SEX RACE I I I I 1 0 2. The penon arrested required medical examination or medical care or was otherwia unable to care for his own safew. 1 Check each mason for not relwing the subject with a written noticr, to appear. 0 1. The pawn arrurted was sa intoxicared that he could have been a danger to himself or to othen. li R 3. The penon was apsted for one or more of the offenses listed in section 40302 of me vehicle code. 0 .a 4. There were 008 or more ouotandlmbr.the penon. I g i ;f 0 5. The person cwld not provide satisfactory evidence of Penonat idsrwificafim. ' 1 0 8. The penon arrested demanded to be taken before a magistrate or refused to sian the nodm to spperr. 0 7. There WBS a reasonable likelihood that the offense(s) would continue or resume. or that the =fen/ of penons or property i 1 2 $A 0 6, The prosecution of the offenre(s) for which the penon vw1 arrested or the prsuh of my other offenos(sI would be ieo Il- ate rete- of perJon arrested. !2 endangered by ~IMs~ of the person arrested. 1 rc] 9. Any other rearon: