Huntington Park Insurance Policies
| Submitted | April 25, 2022 |
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Communications
From: Annette Morasch
To Whom It May Concern:
Pursuant to the California Public Records Act, I hereby request the following records:
Please provide:
1. any insurance policies that the City of Huntington Park maintains which may cover any claim or lawsuit for any of the following issues: a) wrongful termination; b) Fair Employment and Housing discrimination violations; c) retaliation in violation of any California Labor Code; d) the case Aragon et al. v. City of Huntington Park, case number 20STCV44933;
2. any reservation of rights letters provided to the City of Huntington Park in response to the case Aragon et al. v. City of Huntington Park, case number 20STCV44933;
3. any settlement agreement entered into between the City of Huntington Park on the one hand, and any current or former city employee between the years of 2018 and the present;
4. any communications between any City employee and any employee or agent of LanWan Enterprises (including text messages and emails) between the year 2018 and the present.
The requested documents will be made available to the general public, and this request is not being made for commercial purposes.
In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.
Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 10 calendar days, as the statute requires.
Sincerely,
Annette Morasch
From: Huntington Park
Dear Annette,
The City Clerk's Office is in receipt of your public records request received via email on April 25, 2022, regarding the below:
1. Any insurance policies that the City of Huntington Park maintains which may cover any claim or lawsuit for any of the following issues: a) wrongful termination; b) Fair Employment and Housing discrimination violations; c) retaliation in violation of any California Labor Code; d) the case Aragon et al. v. City of Huntington Park, case number 20STCV44933;
2. Any reservation of rights letters provided to the City of Huntington Park in response to the case Aragon et al. v. City of Huntington Park, case number 20STCV44933;
3. Any settlement agreement entered into between the City of Huntington Park on the one hand, and any current or former city employee between the years of 2018 and the present;
4. Any communications between any City employee and any employee or agent of LanWan Enterprises (including text messages and emails) between the year 2018 and the present and will be forwarded to the appropriate department.
In accordance with government code section 6253(c), please allow 10 days from receipt of your request to determine whether the request, in whole or in part, seeks copies of disclosable public records in the possession of the City, we will notify you of the determination within the allowable time.
From: Huntington Park
Dear Ms. Morasch:
Pursuant to Deputy City Attorney Ramirez's request, attached please find a response to your Public Records Request.
If you have any questions regarding this matter, please contact Deputy City Attorney Ramirez.
Best,
Maxine Caudillo
mcaudillo@agclawfirm.com<mailto:mcaudillo@agclawfirm.com>
Executive Assistant to Vincent C. Ewing
Legal Assistant to Gloria V. Ramirez
AGC - City of Industry, CA 91746
tel 562.699.5500 | fax 562.692.2244
Alvarez-Glasman & Colvin represents Cities, Counties, Special Districts - Airport, College, School, Transit, Water and other Public Agencies, Private Corporations and Business Entities
From: Huntington Park
Dear Ms. Morasch:
Pursuant to Deputy City Attorney Ramirez's request, attached please find a follow up response to your Public Records Request.
If you have any questions regarding this matter, please contact Deputy City Attorney Ramirez.
Best,
Maxine Caudillo
mcaudillo@agclawfirm.com<mailto:mcaudillo@agclawfirm.com>
Executive Assistant to Vincent C. Ewing
Legal Assistant to Gloria V. Ramirez
AGC - City of Industry, CA 91746
tel 562.699.5500 | fax 562.692.2244
Alvarez-Glasman & Colvin represents Cities, Counties, Special Districts - Airport, College, School, Transit, Water and other Public Agencies, Private Corporations and Business Entities
From: Huntington Park
Dear Ms. Morasch:
Attached please find the City of Huntington Park's follow-up response to your Public Records Request.
If you have any questions regarding this matter, please contact our office.
Best,
Gloria V. Ramirez, Senior Associate
GRamirez@agclawfirm.com<mailto:GRamirez@agclawfirm.com>
Southern California Office:
Alvarez-Glasman & Colvin
13181 Crossroads Pkwy. North
Suite 400 - West Tower
City of Industry, CA 91746
tel 562.699.5500 | fax 562.692.2244
Northern California Office Mailing Address:
Alvarez-Glasman & Colvin
PO Box 4016
Yountville, CA 94599
tel 707.944.0540 | fax 707.944.0580
Alvarez-Glasman & Colvin represents Cities, Counties, Special Districts - Airport, College, School, Transit, Water and other Public Agencies, Private Corporations and Business Entities
www.agclawfirm.com<http://www.agclawfirm.com/>
[agc]
Privileged And Confidential Communication.
This electronic transmission, and any documents attached hereto, (a) are protected by the Electronic Communications Privacy Act (18 USC §§ 2510-2521), (b) may contain confidential and/or legally privileged information, and (c) are for the sole use of the intended recipient named above. If you have received this electronic message in error, please notify the sender and delete the electronic message. Any disclosure, copying, distribution, or use of the contents of the information received in error is strictly prohibited.
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image001
From: Annette Morasch
The City is once again tardy as usual in producing relevant records in existence and within the direct possession of your firm, Alvarez Glasman.
The representation, that there are no insurance policies which cover wrongful termination/discrimination/retaliation, is demonstrably false. The representation that there are no settlement agreements concerning same, is demonstrably false. The city is covered by the Independent Cities Risk Management Authority, ("ICRMA") which is akin to an insurance policy. ICRMA just paid at least $1,200,000 to a settling plaintiff in a wrongful termination lawsuit which YOUR FIRM defended. YOUR ATTORNEY, Sharon Medellin, signed the settlement agreement as to form. The blatant unethical lies coming from YOUR FIRM is unbecoming and sanctionable.
An agency is required to make records promptly available to any person upon receipt of a request that “reasonably describes an identifiable record or records . . . .” Cal. Gov’t Code § 6253(b). An Agency is obligated to comply so long as the record can be located with reasonable effort." Cal. First Amendment Coal. v. Superior Court, 67 Cal. App. 4th 159, 166, 78 Cal. Rptr. 847 (1998).
Pursuant to Government Code section 6252(e), public records “includes any writing containing information relating to the conduct of the public’s business prepared, owned, used, or retained by any state or local agency regardless of physical form of characteristics.” YOUR FIRM has all of this information in YOUR FIRM's possession.
I will not hesitate to file yet another writ against the corrupt City of Huntington Park, which is using Alvarez Glasman's deceit to hide relevant documents. You should know YOUR FIRM is costing tax payers exorbitant fees, because Judge Chalfant instructed Christy Garcia (SBN 316570), of YOUR FIRM, to communicate with my attorney, Raul Sethi, about Mr. Sethi's attorneys' fees in the existing writ case I have against HP. Case No. 21STCP02084. YOUR FIRM was also ordered by Judge Chalfant, to re-produce a competent deponent or to do a completely new search for the records requested in 21STCP02084 because of YOUR FIRM's incompetence and obstruction.
There is a massive conflict of interest between the City and its taxpayers on the one hand, and Alvarez Glasman on the other. Alvarez Glasman needs to recuse itself from all public records searches. Alvarez Glasman needs to inform the ICRMA immediately about this demand to recuse, because Alvarez Glasman is inviting another expensive writ. Of course, this is in the interest of Alvarez Glasman, because Alvarez Glasman gets paid lots of money in defending the "City" from Alvaraez Glasman's obstruction.
You have one single week -until June 10, 2022- to produce the Christopher Lisner Settlement Agreement and all other settlement agreements. You have a single week -until June 10, 2022-to produce the ICRMA contract. You have a single week-until June 10, 2022- to produce LanWan communications. This is how you do it. You go into the email server and search @lanwan for all responsive documents.
If these documents are not forthcoming by end of business on June 10, 2022, we will be filing another writ of mandate and seeking attorneys' fees. We will also be seeking monetary sanctions against you and your firm personally for this blatant lying.
From: Muckrock Staff
To Whom It May Concern:
I'm following up on the following California Public Records Act request, copied below, and originally submitted on April 25, 2022. You had previously indicated that it would be completed on June 16, 2022. I wanted to check on the status of my request, and to see if there was a new estimated completion date.
Thanks for your help, and let me know if further clarification is needed.
From: Huntington Park
To Whom It May Concern:
Be advised that on June 10, 2022, the City of Huntington Park routed the attached letter providing additional records as requested and advising that clarification/narrowing of the scope requested would be needed to process Item 4. Search, review and release of the remaining documents depends on your complete attention to the attached.
Please do not hesitate to contact our office if you have further questions.
Gloria V. Ramirez, Senior Associate
GRamirez@agclawfirm.com<mailto:GRamirez@agclawfirm.com>
Southern California Office:
Alvarez-Glasman & Colvin
13181 Crossroads Pkwy. North
Suite 400 - West Tower
City of Industry, CA 91746
tel 562.699.5500 | fax 562.692.2244
Northern California Office Mailing Address:
Alvarez-Glasman & Colvin
PO Box 4016
Yountville, CA 94599
tel 707.944.0540 | fax 707.944.0580
Alvarez-Glasman & Colvin represents Cities, Counties, Special Districts – Airport, College, School, Transit, Water and other Public Agencies, Private Corporations and Business Entities
www.agclawfirm.com<http://www.agclawfirm.com/>
[agc]
Privileged And Confidential Communication.
This electronic transmission, and any documents attached hereto, (a) are protected by the Electronic Communications Privacy Act (18 USC §§ 2510-2521), (b) may contain confidential and/or legally privileged information, and (c) are for the sole use of the intended recipient named above. If you have received this electronic message in error, please notify the sender and delete the electronic message. Any disclosure, copying, distribution, or use of the contents of the information received in error is strictly prohibited.
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image001
From: Huntington Park
It looks like this agency uploaded responsive documents to a portal or link sharing site. Our team is working on moving them over, so please check back soon.
Dear Ms. Morasch:
Pursuant to Deputy City Attorney Ramirez's request, attached please find a further follow up response to your Public Records Request and link with the referenced documents (the initial zip drives were too large to attach to this email)
https://www.dropbox.com/sh/smhtiy2jak13xnn/AAAE00WUMyHUbIDwbj3YWYjEa?dl=0
If you have any questions regarding this matter, please contact Deputy City Attorney Ramirez.
Best,
Maxine Caudillo
mcaudillo@agclawfirm.com<mailto:mcaudillo@agclawfirm.com>
Executive Assistant to Vincent C. Ewing
Legal Assistant to Gloria V. Ramirez
AGC - City of Industry, CA 91746
tel 562.699.5500 | fax 562.692.2244
Alvarez-Glasman & Colvin represents Cities, Counties, Special Districts - Airport, College, School, Transit, Water and other Public Agencies, Private Corporations and Business Entities
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2022-07-21 _ A. MORASCH _ APRIL PRA REQUEST
From: Huntington Park
It looks like this agency uploaded responsive documents to a portal or link sharing site. Our team is working on moving them over, so please check back soon.
Dear Ms. Morasch:
Attached please find a further follow up response from the City of Huntington Park to your April 2022 Public Records Request and link with the referenced documents (the initial zip drives were too large to attach to this email):
https://www.dropbox.com/sh/dgv344mytr40sir/AAC2mYezzZUPcMA9wc1B-KGpa?dl=0
If you have any questions regarding this matter, please contact our office.
Best,
Gloria V. Ramirez, Senior Associate
GRamirez@agclawfirm.com<mailto:GRamirez@agclawfirm.com>
Southern California Office:
Alvarez-Glasman & Colvin
13181 Crossroads Pkwy. North
Suite 400 - West Tower
City of Industry, CA 91746
tel 562.699.5500 | fax 562.692.2244
Northern California Office Mailing Address:
Alvarez-Glasman & Colvin
PO Box 4016
Yountville, CA 94599
tel 707.944.0540 | fax 707.944.0580
Alvarez-Glasman & Colvin represents Cities, Counties, Special Districts - Airport, College, School, Transit, Water and other Public Agencies, Private Corporations and Business Entities
www.agclawfirm.com<http://www.agclawfirm.com/>
[agc]
Privileged And Confidential Communication.
This electronic transmission, and any documents attached hereto, (a) are protected by the Electronic Communications Privacy Act (18 USC §§ 2510-2521), (b) may contain confidential and/or legally privileged information, and (c) are for the sole use of the intended recipient named above. If you have received this electronic message in error, please notify the sender and delete the electronic message. Any disclosure, copying, distribution, or use of the contents of the information received in error is strictly prohibited.
From: Huntington Park
It looks like this agency uploaded responsive documents to a portal or link sharing site. Our team is working on moving them over, so please check back soon.
Dear Ms. Morasch:
Pursuant to Deputy City Attorney Ramirez's request, attached please find a ninth follow up response to your Public Records Request and link with the referenced documents https://www.dropbox.com/scl/fo/kjv3y5yga7wk1vzhp6jmv/h?dl=0&rlkey=4cazj2aypmnnfd646lfekyt3n
If you have any questions regarding this matter, please contact Deputy City Attorney Ramirez.
Best,
Maxine Caudillo
mcaudillo@agclawfirm.com<mailto:mcaudillo@agclawfirm.com>
Executive Assistant to Vincent C. Ewing
Legal Assistant to Gloria V. Ramirez
AGC - City of Industry, CA 91746
tel 562.699.5500 | fax 562.692.2244
Alvarez-Glasman & Colvin represents Cities, Counties, Special Districts - Airport, College, School, Transit, Water and other Public Agencies, Private Corporations and Business Entities
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2022-09-08 HP RESPONSE TO A. MORASCH (APRIL PRA)
From: Huntington Park
Dear Ms. Morasch:
Pursuant to Deputy City Attorney Ramirez's request, attached please find a final response to your Public Records Request.
If you have any questions regarding this matter, please contact Deputy City Attorney Ramirez.
Best,
Maxine Caudillo
mcaudillo@agclawfirm.com<mailto:mcaudillo@agclawfirm.com>
Executive Assistant to Vincent C. Ewing
Legal Assistant to Gloria V. Ramirez
AGC - City of Industry, CA 91746
tel 562.699.5500 | fax 562.692.2244
Alvarez-Glasman & Colvin represents Cities, Counties, Special Districts - Airport, College, School, Transit, Water and other Public Agencies, Private Corporations and Business Entities
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