Mr. Braden -- Burdensome is not an answer. I will be more than happy to review claims as I have done in the past. These are public documents.
Barry Allen
Direct Line - 818 243 1502
-----Original Message-----
From: Braden, Ronald [mailto:RBraden@ci.glendale.ca.us]
Sent:
To: ba@fieldworks.net
Cc: Kassakhian, Ardashes; Buchanan, Rita; Varpetian, Lucy
Subject: RE: CPRAR 100307 GFD Claims
Sensitivity: Confidential
This request is far too burdensome. First, in order to comply with the request, we would have to read every claim that was ever filed with the City in order to determine if it involved the units which you have identified. The burden would be increased by the fact that the City would then have to go through every such claim, assuming that there was existence of such claims, and redact every piece of information which contained personal, medical or similar information which is subject to the right of privacy pursuant to Gov’t Code § 6254(c).
Therefore, as required by Gov’t. Code § 6253, the request fails to reasonably describe an identifiable record or records. Pursuant to Gov’t. Code § 6253.1, you may contact me so that I may make an effort to assist you in making a focused and effective request which identifies a record or records, assuming that such exist, which are responsive to your request. However, it is very difficult for me to ascertain how you are going to be able to reasonably describe an identifiable record unless you know of a specific claim which has been filed.
My telephone number is (818) 548-2080.
Ron R. Braden
613 E. Broadway,
Office: (818) 548-2080
Fax: (818) 547-3402
CONFIDENTIAL
THIS MATERIAL IS SUBJECT TO THE ATTORNEY-CLIENT AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGES. DO NOT DISCLOSE THE CONTENTS HEREOF. DO NOT FILE WITH PUBLICLY ACCESSIBLE RECORDS.
-----Original
Message-----
From: Barry [mailto:ba@fieldworks.net]
Sent:
To: Braden, Ronald
Subject: RE: CPRAR 100307 GFD Claims
Sensitivity: Confidential
Modify request for claims against city involving the fire department or paramedics or fire inspection
Barry Allen
818 243 1502
-----Original Message-----
From: Braden, Ronald [mailto:RBraden@ci.glendale.ca.us]
Sent:
To: ba@fieldworks.net
Subject: CPRAR 100307 GFD Claims
Sensitivity: Confidential
This is a correction of the previous response
regarding this record request. There are no documents which comply with
your request because all claims are filed against the City of
Ron R. Braden
613 E.
Broadway,
Office: (818) 548-2080
Fax: (818) 547-3402
-----Original Message-----
From: Barry [mailto:ba@fieldworks.net]
Sent:
To: Braden, Ronald; Kassakhian, Ardashes; Varpetian, Lucy; Buchanan,
Rita
Subject: CPRAR 100307 GFD Claims
|
VANGUARD
POB 11202,
818 243 1502 – vanguard1@charter.net
Contributions are tax deductible – Rev. Proc. 92-85, 1992-42 I.R.B. 32
VIGILANCE leads to ACCOUNTABILITY
Ardy Kassakhian, City Clerk
613 E. Broadway
RE: Public Records Act Request Reference: 100307 GFD Claims
Dear Mr. Kassakhian:
Pursuant to my rights under the California
Public Records Act (Government Code Section 6250 et seq.) and the California
Constitution, as amended by passage of Prop 59 on
Claims filed against
Definitions:
1. The term "Person" and/or "Persons" as used herein means a "member of the public", "State Agency", and "Public agency" as those terms are defined in State of California Statutes and Administrative Codes, Government Code §6250, et. seq., and related sections respectively, and of its respective predecessors, successors, shareholders, officers, directors employees, agents, representatives, assigns or person action or purporting to on his/her behalf and attorneys.
2 The term "documents" and/or "document" as used herein means all "writings", "originals", and "duplicates" as those terms are defined in Government Code Section §6252, respectively. Every kind, source, authorship, both originals and/or non-identical copies thereof, in City of Glendale possession, custody or control, or known by the City of Glendale to exist, irrespective of whether the document is one intended for or transmitted internally by the City of Glendale, or intended for or transmitted to any other person or entity, including, without limiting any government agency, department, administrative entity, personnel, or employee. The foregoing, these terms include any and all typed, duplicated, handwritten or combination thereof, authored or used, handwritings, typewritten, printed, photo stated, photographed, or any means of recording upon any form, printed, pictorial, magnetic or paper tapes, photographic films or prints, magnetic or punched cards, discs, drums, or graphic matter, however, produced or reproduced, of every kind or description or communication, preserved and communicated in some manner-verbal or nonverbal, qualitative or quantitative information, mediated by any technology, including but not limited to: records, letters, correspondence, telegrams, telexes, accounting, notes of any type, minutes of any meeting memoranda, intra-office and inter-office communications, reports, written analyses, contracts, modifications, of such contracts, licenses, agreements, schedules, work papers, summaries, interviews, telephone conversations, affidavits, printed matter (including published books, articles, speeches, and newspaper clippings, press releases, charts, drawings, specifications, parts lists, evaluations, advice, recommendations, commentaries, conclusions, studies, testing, data, reports and results, ledgers, books of account, vouchers, bank checks, invoices, charge slips, receipts, digest, analysis, communications, broadcasts, working papers, statistical records, cost sheets, stenographer's notebooks, transcriptions, desk calendars, appointment books, diaries, time sheets or logs telephone logs, maps, illustrations, diagrams, photographs, tape recordings, movies, films, transcriptions, videotapes, electronic or magnetic recordings, computer data, including but not limited to punch cards, magnetic tapes and printouts, job and transaction files, books, notes or recordings of any conversations, or anything similar to any of the foregoing, however denominated, as well as all copies, duplicates, and drafts of the foregoing and including any electronic communication(s).
I ask for a determination on this request within 10 days of your receipt of it, and an even earlier reply if you can make that determination without having to review the record(s) in question.
If you determine that any or all or the information is exempt from disclosure, I ask that you reconsider that determination in view of Prop 59, which has amended the state Constitution to require that all exemptions be "narrowly construed." Prop 59 may modify or overturn authorities on which you have relied in the past.
If you nonetheless determine that the requested records are subject to a still-valid exemption, I would further request that: (1) you exercise your discretion to disclose some or all of the records notwithstanding the exemption; and (2) that, with respect to records containing both exempt and non-exempt content, you redact the exempt content and disclose the rest.
You must provide assistance by helping to identify records and information relevant to the request and suggesting ways to overcome any practical basis for denying access.
Finally, should you deny part or this entire request, you are required to provide a written response describing the legal authority or authorities on which you rely. Please also address the question whether Prop 59 requires disclosure even though authorities predating Prop 59 may appear to support your exemption claim.
Records concerning litigation are exempt only until the claim is resolved or settled. Upon disposition all records including court records and those pre-dating the suit are public.
If I can provide any clarification that will help expedite your attention to this request, please contact me at the number above. I ask that you notify me of any duplication costs so that I may decide which records I want copied.
I am sending a copy of this letter to your legal advisor to help encourage a speedy determination, and I would likewise be happy to discuss my request with him or his designee at any time.
Thank you for your time and attention to this matter.
Sincerely,
Barry Allen