Requa vs the Regents of the University of California

1 Stember Feinstein Doyle Payne & Cordes, LLC John Stember (Pro Hac Vice Pending)

2 William T. Pay-ne (SB No. 90988) Allegheny BuIlding, 17th Floor

3 429 Forbes Avenue Pittsburgh, PA 15219

4 Tel:(412)281-8400 Fax: (412) 281-1007

5 [email protected] [email protected]

6 Sinclair Law Office

7 Andrew Thomas Sinclair (SB No. 72681) 300 Frank H. Ogawa Plaza

8 Rotunda Building, Suite 160 Oakland, CA 94612

9 Tel: (510) 465-5300 Fax: (510) 465-5356

10 ats@sinc\airlawoffice.com

11 Carter Carter Fries & Grunschlag Dov M. Grunschlag (SB No. 42040)

12 44 Montgomery St., Suite 2405 San Francisco, CA 94104

13 Tel: (415) 989-7694 Fax (415) 989-4864

14 [email protected]

15 Attorneys for Petitioners

ENDORSED Fr LED

ALAMEDA COUNTY

AUG 11 20lD CLERK OF THE COURT By Barbara LaMotte

Deputy

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF ALAMEDA

JOE REQUA, WENDELL G. MOEN, JAY DAVIS AND DONNA VENTURA,

Petitioners,

v.

REGENTS OF UNIVERSITY OF CALIFORNIA, and DOES, 1 through 99, inclusive,

Respondents. _________________________________ 1

lOS 0 4 9 2

PETITION FOR WRIT OF MANDATE

Requa, et aI, v. Regents a/University a/California, et al. PETITION FOR WRIT OF MANDATE PAGE 1

1 INTRODUCTION

2 1. This case is brought by former employees of the Regents of the University of

3 California ("Regents" or "University") who worked at the Lawrence Livermore National

4 Laboratory ("Livermore Lab"). For many years, the University managed the Livermore Lab,

5 which is widely considered one of the nation's premier defense research laboratories. While

6 Petitioners worked there, they were University employees, and the Regents treated them as

7 University employees for all purposes.

8 2. In the 1960s, the Regents first authorized University-provided medical benefits for

9 University employees and retirees, and the Regents have provided these benefits since then.

lOIn 2008, however, the Regents singled out retirees from the Livermore Lab and shifted

11 responsibility for providing their retiree medical benefits to a newly created private

12 consortium (that includes the Regents), known as Lawrence Livermore National Security

13 ("LLNS"). In so doing, the Regents impaired Petitioners' vested right to receive the same

14 University-provided retiree medical benefits as other University retirees in violation of the

15 Contract Clause of the California Constitution.

16 3. Since the Regents stopped providing retirees who worked at the Livermore Lab

17 with the same medical benefits as other University retirees and shifted responsibility for

18 providing their benefits to Petitioners have been significantly disadvantaged. The

19 benefits LLNS has provided have been inferior to those provided by the University.

20 Petitioners ask the Court to restore their vested right to University-provided health benefits

21 and to make them whole for losses suffered.

22 PARTIES

23 JOE REQUA

24 4. After Petitioner Joe Requa graduated from the University of California, Berkeley in

25 1961 with a degree in Engineering, he was hired by the University to work at the Lawrence

26 Berkeley Lab.

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Requa, et ai, v. Regents 0/ University a/California, et al. PETITION FOR WRIT OF MANDATE PAGE 2

1 5. When Requa began work in 1961, the University did not have its own retirement

2 system. Instead, University employees were members of the Public Employees' Retirement

3 System (PERS). Like other University employees, Requa was a member ofPERS.

4 6. During the 1961-62 and 1962-63 academic years, Requa continued to work at the

5 Lawrence Berkeley Laboratory and attended graduate school at UC Berkeley. In 1963, he

6 withdrew his retirement funds from PERS and moved to Illinois to continue his education. In

7 mid-1965, Requa returned to California and began working at the Lawrence Livermore Lab.

8 By that time, the University had established its own retirement system, known as the

9 University of California Retirement System (UCRS), and Requa became a member. UCRS

10 later became known as the University of California Retirement Plan (UCRP). Throughout his

11 career at the Livermore Lab, Requa was a University employee and was always treated like

12 one. Among other things, paycheck came from the University, and he was covered by the

13 University's Staff Personnel Policies and Procedures.

14 7. On or about October 30, 1999, Requa retired from the Livermore Lab as a

15 University employee. Since then, Requa's retirement checks have been (and still are) issued

16 by UCRP. In fact, neither Requa nor other retirees who worked at the Livermore Lab were

17 treated any differently than other University retirees until on or about January 1,2008, when

18 the Regents stopped providing their medical benefits and transferred responsibility for

19 providing these benefits to LLNS. In so doing, the Regents terminated the vested right of

20 Requa and other retirees who had worked at Livermore Lab to receive the same University-

21 provided health coverage as other University retirees.

22 8. After Requa retired, the University provided medical benefits to him through

23 Kaiser, which LLNS uses his current provider. Requa is informed and believes that,

24 although LLNS assumed responsibility for managing the Livermore Lab on or about October

25 1, 2007, the Regents continued to provide him and other retirees who had worked at the

26 Livermore Lab with medical benefits through the University until on or about January 1,

27 2008. Requa is further informed and believes that, throughout 2008, the coverage LLNS

28 provided was the same or similar to the coverage that the Regents provided to other


1 University retirees. However, on or about January 1,2009, LLNS increased Requa's monthly

2 premium and his co-payments for medical visits and prescriptions. During the same period,

3 the Regents did not increase the monthly premium and co-payments for University retirees

4 from facilities other than the Livermore Lab. Requa estimates that for 2009, he paid about

5 $1,000 more for retiree medical benefits than he would have paid under the University-

6 provided plan. He estimates that, in 2010, he will pay $2,000 more.

7 WENDELL G. MOEN

8 9. Wendell G. Moen began working at the Livermore Lab in 1963. He retired in June

9 2000 with no breaks in University service. Throughout his career at the Livermore Lab,

10 Moen was a University employee, was always treated like a University employee, and was

11 told by his superiors that he was a University employee. Among other things, the University

12 issued his paycheck, and he was covered by the University's Staff Personnel Policies and

13 Procedures.

14 10. When Moen began working at the Livermore Lab, he became a member of the

15 University of Cali fomi a Retirement System (UCRS), later known as UCRP.

16 11. After he retired, Moen's retirement checks came from UCRP, and the Regents

17 treated him like any other Up,iversjty retiree. In fact, Moen was not treated differently than

18 other University retirees until on or about January 1,2008, when the Regents shifted

19 responsibility for providing his medical benefits to LLNS, a private consortium. Moen is

20 informed and believes that, although LLNS assumed responsibility for managing the Lab on

21 or about October 1,2007, the Regents did not shift the responsibility for providing Moen's

22 retiree medical benefits to LLNS until on or about January 1,2008. When the Regents shifted

23 responsibility for Moen's medical benefits to LLNS, they breached his vested right to receive

24 the same University-provided health benefits as other University retirees.

25 12. After LLNS assumed responsibility for managing the Livermore Lab, University

26 retirees from the Lab (including Moen himself) were asked to select a health care provider.

27 Moen selected Anthem Blue Cross, and LLNS still uses Anthem Blue Cross to provide

28 Moen's retiree medical benefits.

Requa, etal, v. Regents a/University a/California, et al. PETITION FOR WRIT OF MANDATE PAGE 4

1 JAY DAVIS

2 13. Jay Davis began working at the Livermore Lab in June 1971 and retired on June

3 29,2002, with no breaks in University service. Throughout his career at the Livermore Lab,

4 he was a University employee. He was told by his superiors that he was a University

5 employee and was always treated like one. Among other things, the University issued his

6 paycheck, and he was covered by the University Staff Personnel Policies and Procedures.

7 14. When Davis began working at the Livermore Lab, he became a member of the


9 15. Since Davis retired in June 2002, his retirement checks have been issued by

10 UCRP. The Regents treated him like any other University retiree until on or about January 1,

11 2008, when the Regents stopped providing him with medical benefits through the University.

12 16. Davis is informed and believes that, although LLNS assumed responsibility for

13 managing the Livermore Lab on or about October 1,2007, the Regents continued to provide

14 the same medical benefits to him (and other retirees who had worked at the Livermore Lab) as

15 to other University retirees until on or about January 1,2008. He is further informed and

16 believes that, during 2008, the coverage LLNS provided was the same or similar to the

17 coverage the Regents provided to other University retirees. However, on or about January 1,

18 2009, LLNS increased Davis' monthly premium and his co-payments for medical visits and

19 prescriptions. The Regents did not impose this increase on retirees from other University

20 facilities. Davis estimates that for 2009, he paid about $1,000 more for retiree medical

21 benefits than he would have paid under the University-provided plan. He estimates that, in

22 2010, he will pay about $2,000 more.

23 17. By shifting responsibility for providing Davis' retiree medical benefits to a private

24 consortium, LLNS, the Regents terminated Davis' vested right to receive the same

25 University-provided health coverage as other University retirees.

26 18. LLNS currently uses Kaiser to provide Davis' retiree medical benefits.

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Requa, et aI, v. Regents 0/ University a/California, et al. PETITION FOR WRIT OF MANDATE PAGE 5

1 DONNA VENTURA

2 19. Donna Ventura began working at the Livermore Lab in January 1974 and retired

3 on June 30, 2006, with no breaks in University service. Throughout her time at the Livermore

4 Lab, Ventura was a University employee. She was told by her superiors that she was a

5 University employee, and they always treated her like one. Among other things, the

6 University issued her paycheck, and she was covered by its Staff Personnel Policies and

7 Procedures.

8 20. When Ventura began work at the Livermore Lab, she became a member of the


10 21. Since Ventura retired in June 2006, her retirement checks have always been issued

11 by UCRP. In fact, she was never treated differently than any other University retiree until on

12 or about January 1,2008, when the Regents stopped providing her with retiree medical

13 benefits through the University.

14 22. Ventura is informed and believes that, although LLNS assumed responsibility for

15 managing the Livermore Lab on or about October 1, 2007, the Regents continued to provide

16 medical benefits to her and: other retirees who had worked at the Livermore Lab until on or

17 about January 1,2008. She is further informed and believes that during 2008, the coverage

18 provided by LLNS was the same or similar to the coverage the Regents provided to other

19 University retirees. However, on or about January 1, 2009, LLNS increased Ventura's

20 monthly premium and her co-payments for medical visits and prescriptions, an increase that

21 the Regents did not impose on retirees from other University facilities. Ventura estimates that

22 for 2009, she paid about $1,000 more for retiree medical benefits than she would have paid

23 under the University-provided plan. She estimates that, in 2010, she will pay about $2,000

24 more.

25 23. By shifting responsibility for providing retiree medical benefits to a private

26 consortium, LLNS, the Regents abrogated Ventura's vested right to receive the same

27 University-provided health c(:werage as other University retirees.

28 24. LLNS now uses Kaiser to provide Ventura's retiree medical benefits.

Requa, et ai, v. Regents a/University a/California, et al. PETITION FOR WRIT OF MANDATE PAGE 6

1 THE REGENTS

2 25. The Regents of the University of California is a public corporation organized and

3 operating under the laws of the State of California, pursuant to Article IX, section 9, of the

4 California Constitution.

5 DOE RESPONDENTS

6 26. Petitioners do not know the names and capacities of Doe Respondents 1-99, but

7 will amend their petition and add this information when they do. Petitioners are informed

8 and believe that each Doe Respondent was responsible in some manner for the acts

9 complained of.

10 FACTS

11 27. The Livermore Lab opened in 1952 as a branch of the University of California

12 Radiation Laboratory. From 1952 until 2007, the Regents operated the Livermore Lab under

13 a contract with the U.S. Department of Energy ("DOE") or predecessor agencies of the

14 federal government.

15 28. During this time, Petitioners and most employees who worked at the Livermore

16 Lab were regular employees of the University, working under the same terms and conditions,

17 and entitled to the same benefits as other University employees.

18 29. While the Regents managed the Livermore Lab, they treated University employees

19 who worked there in the same manner as they treated other University employees. Like other

20 University employees, the Livermore Lab employees received their paychecks from the

21 University; were subject to the same terms and conditions of work and covered by the same

22 personnel policies as other University employees; and they participated in the same retirement

23 system as other University employees.

24 30. Until 2007 or early 2008, the Regents also treated retirees who had worked at the

25 Livermore Lab in the same manner as other University retirees.

26 31. During the 1960s, the Regents first authorized medical benefits for University

27 employees, including those working at the Livermore Lab. At the same time or shortly

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1 thereafter, the Regents also authorized medical benefits for University retirees, including the

2 retirees who had worked at the Livermore Lab.

3 32. Between the 1960s and 2007, the Regents provided the same medical benefits to

4 active and retired employees who had worked at the Livermore Lab as they provided to other

5 active and retired University employees.

6 33. Petitioners who began work at the Livermore Lab before the Regents offered

7 retiree medical benefits acquired a vested right to these benefits when the Regents first

8 authorized them. Petitioners who began work at the Livermore Lab after the Regents

9 authorized retiree medical benefits acquired a vested right to these benefits upon being hired

10 by the University.

11 34. From the 1960s through 2007, the Regents, by and through statements made by

12 them and other University representatives and staff, acting within the scope of their authority,

13 and through publications, representations and communications from the Regents themselves

14 or from other University staff acting within the scope of their authority, led Petitioners and

15 other retirees who had worked at the Livermore Lab to reasonably believe they were entitled

16 to and would receive the same medical benefits as other University retirees.

17 35. After learning that LLNS planned to make changes to medical benefits for

18 University retirees who had worked at the Livermore Lab, Requa contacted the University's

19 Office of the General Counsel. On or about August 11,2008, Requa advised Acting General

20 Counsel Jeffrey Blair that he believed the Regents had acted unlawfully by terminating

21 University-provided medical benefits for retirees who had worked at the Livermore Lab and

22 shifting responsibility for providing these benefits to LLNS. Blair assured Requa that he

23 would respond within a week but called on August 25 and told Requa he needed another

24 week. After Requa waited,&p0ther week, he telephoned Blair on September 4. Blair

25 promised a response in five days, but he never did respond.

26 36. Although Requa never heard from Blair, he did receive a letter from counsel for

27 LLNS on September 16,2008. In her letter, LLNS's attorney represented that "medical costs

28 for Laboratory retirees have always been paid for by operating costs of the Laboratory" and

Requa, et aI, v. Regents of University of California, et al. PETITION FOR WRIT OF MANDATE PAGE 8

1 asserted that "coverage could change or be terminated at any time." She went on to say it had

2 been "determined by the Department of Energy that Laboratory employees who retired from

3 UC would no longer be included in the UC retiree pool for coverage purposes," and that

4 going forward, benefits for retirees who had worked at Livermore Lab "may not be equivalent

5 to those offered by the University." These assertions were inconsistent with earlier

6 assurances and representations from the Regents.

7 37. In 2007, DOE did not renew its contract with the Regents to manage the

8 Livermore Lab. Instead, it contracted with Lawrence Livermore National Security ("LLNS"),

9 a newly-created private consortium that included the University, Bechtel National, Babcock

1 0 and Wilcox and other entities.

11 38. As noted, on or about January 1,2008, the Regents stopped providing medical

12 benefits through the University to the retirees who had worked at the Livermore Lab and

13 shifted the responsibility for doing so to LLNS. At or about this time, the Regents assured

14 retirees who had worked at the Livermore Lab that they would continue to receive

15 "substantially equivalent" medical benefits from LLNS.

16 39. Since the Regents stopped providing Petitioners with University-provided retiree

17 medical benefits, Petitioners and other retirees who had worked at the Livermore Lab have

18 not received the same medical benefits as other University retirees.

19 40. Nor have who worked at the Livermore Lab received "substantially

20 equivalent" retiree medical benefits, despite the Regents' assurances that they would.

21 41. Even if LLNS had provided Petitioners with "equivalent" benefits, this would not

22 have given the Regents authority to abrogate Petitioners' vested right to receive the same

23 University-provided medical benefits as other University retirees.

24 42. As University retirees who have suffered and will continue to suffer harm as a

25 result of the actions described above, Petitioners are beneficially interested in this proceeding.

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Requa, et al. v. Regents 0/ University o/California, et al. PETITION FOR WRIT OF MANDATE PAGE 9

1 FIRST CAUSE OF ACTION

2 (Impairment of Contract)

3 43. Petitioners incorporate the above allegations as if set forth in full.

4 44. Petitioners and other retirees who worked at the Livermore Lab have a vested right

5 to the retiree medical benefits described above as each of them was (a) a University employee

6 when the Regents first authorized retiree medical benefits or (b) became a University

7 employee after retiree medical benefits were authorized.

8 45. Retiree medical benefits were (and continue to be) an integral part of Petitioners'

9 compensation. Once these benefits vested, the Regents could not terminate the benefits

10 without impairing contractual obligations they owed to Petitioners under the Contract Clause

11 of the California Constitution, Article I, § 9.

12 46. Though vested, Petitioners' benefits are not rigidly fixed, and may be modified in

13 accord with changing conditions - but only if the modification is reasonable. To be

14 sustained as reasonable, a modification must be materially related to the theory of a pension

15 plan and its successful operation, and changes in a pension plan which disadvantage

16 employees should be accompanied by comparable new advantages.

17 47. The termination of Petitioners' vested right to receive the same University-

18 provided retiree medical benefits as other University retirees was not a reasonable

19 modification. The Regents did not modify Petitioners' right to these benefits; they eliminated

20 the right.

21 48. By terminating Petitioners' vested right to receive the same University-provided

22 medical benefits as other University retirees, the Regents impaired their contractual

23 obligations to Petitioners aqd other retirees who worked at the Livermore Lab in violation of

24 Article I, § 9 of the California Constitution.

25 49. Alternatively, by shifting the responsibility for providing medical benefits for

26 retirees who worked at the Livermore Lab to LLNS, the Regents abrogated or impaired their

27 contractual obligation to Petitioners (to continue to provide them with the same medical

28 benefits as other University retirees) under the California Constitution, Article I, § 9.


1 50. Even if shifting responsibility from the University to LLNS could be regarded as a

2 "modification," it was not a "reasonable modification." The change eliminated Petitioners'

3 right to coverage under the University-provided retiree medical benefit plan and put them into

4 a plan that has significant disadvantages while providing no comparable new advantages.

5 Retirees from the have been removed from the University's risk pool and put

6 into a much smaller pool that is aging and becoming more infirm. Since retirees who worked

7 at Livermore Lab will no longer enjoy the benefits of spreading risk over the University's

8 much larger pool (of retirees and employees), the cost of their coverage will increase more

9 rapidly than it will for other University retirees; and as members of a smaller pool, their

10 bargaining power with health care providers has and will continue to diminish. None of these

11 changes bears a material relation to the theory of a pension system and its successful

12 operation.

13 51. University-provided retiree medical benefits are a form of deferred compensation

14 that Petitioners earned during years of service to the University and which vested before

15 retirement.

16 52. The Regents offered University-provided retiree medical benefits in order to

17 induce Petitioners to remain at the Livermore Lab. Once their right to these benefits vested,

18 Petitioners reasonably expected that the Regents would continue to provide them with these

19 benefits throughout retirement.

20 53. This Court may issue a writ "to any ... corporation, board or person to compel the

21 performance of an act which the law specially enjoins ... or to compel the admission of a party

22 to the use and enjoyment of a right ... to which the party is entitled, and from which the party

23 is unlawfully precluded by such inferior ... corporation, board, or person." Cal. Code ofCiv.

24 Proc. § 1085(a). Here, the Regents have deprived Petitioners of the use and enjoyment of

25 vested right to the same University-provided medical benefits as other University retirees.

26 Petitioners are entitled to a writ to restore them to the use and enjoyment of these rights.

27 54. Petitioners have no plain, speedy and adequate remedy in the ordinary course of

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1 SECOND CAUSE OF ACTION

2 (Promissory Estoppel)


4 56. As noted above, between the 1960s and the 2007 "modification," the Regents

5 clearly and unambiguously promised, through publications, representations, communications

6 and conduct, that Petitioners would receive the same University-provided medical benefits as

7 other University retirees.

8 57. For more than 40 years, the Regents treated University employees and retirees

9 who worked at the Livermore Lab like other University employees and retirees. During this

10 time, the Regents knew that University employees who worked at the Livermore Lab would

11 and did rely on the fact that the Regents had authorized and were providing retirees who had

12 worked at the Livermore Lab with the same medical benefits as other University retirees. The

13 Regents knew or should have known that Petitioners would reasonably believe that when they

14 retired they would continue to receive the same University-provided medical benefits as other

15 University retirees.

16 58. Petitioners relied on the Regents' promises, representations, statements,

17 publications, communications, and course of conduct by remaining at the Livermore Lab and

18 foregoing other employment opportunities.

19 59. Petitioners had no reason to believe prior to 2007 that the Regents would treat

20 them any differently than other University retirees.

21 60. Petitioners' reliance on the Regents' promises, statements, publications,

22 comments, communications and conduct was reasonable.

23 61. Petitioners were injured by their reliance on the Regents' promises, statements,

24 publications, comments, communications and conduct in that, among other things, they

25 continued to work at the Livermore Lab while foregoing other employment opportunities, and

26 they made retirement plans based on the reasonable assumption that the Regents would

27 continue to provide them with the same medical coverage as other University retirees.

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1 THIRD CAUSE OF ACTION

2 (Declaratory Relief)


4 63. As alleged, Petitioners' right to receive the same University-provided retiree

5 medical benefits as other University retirees vested before retirement. Once vested, the

6 Regents could not abrogate these benefits without impairing Petitioners' rights under the

7 Contract Clause of the California Constitution.

8 64. The Regents were without authority to shift responsibility for providing

9 Petitioners' retiree medical benefits to LLNS (a private entity).

10 65. By shifting this responsibility, the Regents impaired Petitioners' contractual

11 rights.

12 66. As a public agency, the Regents had a duty to honor their contractual obligations

13 as required by the Contract Clause of the California Constitution and to ensure that the

14 University continued to the retirees who had worked at the Livermore Lab with same

15 medical benefits as other University retirees.

16 67. The Regents are estopped from denying their obligation for the medical benefits

17 promised to Petitioners as alleged above.

18 68. A dispute has arisen and presently exists regarding: the Regents' authority (a) to

19 lawfully terminate Petitioners' vested right to receive University-provided medical benefits on

20 the same basis as other University retirees and (b) to shift responsibility for providing

21 Petitioners' retiree medical benefits to LLNS; and (c) whether the Regents are estopped from

22 denying responsibility for providing the promised medical benefits.

23 69. Petitioners are entitled to a declaration of their rights and to appropriate injunctive

24 relief.

25 PRA YER FOR RELIEF

26 Petitioners pray that,after an appropriate hearing, this Court issue the following relief:

27 1. A Peremptory Writ of Mandate, directing the Regents to restore Petitioners' use and

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enjoyment of their right to receive University-provided medical benefits on the same basis as

2 other University retirees;

3 2. Direct the Regents to pay restitution and/or damages to Petitioners, with interest at

4 the legal rate, and make Petitioners whole for losses suffered as a result of the termination of

5 their vested rights;

6 3. Declare that the Regents were without authority to terminate Petitioners' vested

7 right to receive University-provided medical coverage on the same basis as other University

8 retirees or to transfer responsibility for providing retiree medical benefits to LLNS;

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4. Award reasonable attorney's fees;

5. Direct Respondents to reimburse Petitioners for the costs of this action;

6. Issue such other and further relief as is deemed appropriate by the Court.

Date: q -/ /-;2-0 I 0

Date: ,....-/(,.. fi)

STEMBER, FEINSTEIN, DOYLE, PA YNE, & CORDES LLC

WILLIAM T. PAYNE JOHN STEMBER

SINCLAIR LA W OFFICE

ANDREW THOMAS SINCLAIR

Requa, et aI, v. Regents of University of California, et al. PETITION FOR WRIT OF MANDATE PAGE 14

· Aug 09 10 07: 51a Kurt Alexander 925-449-5229 p.2

1 VERIFICATION OF JOE REQUA

2 I say and declare:

3 1. My name is Joe Requa. I am one of the Petitioners in this action. I am a resident of

4 the County of Alameda, State ofCalifomia.

5 2. I have read the above Petition for Writ of Mandate. The facts alleged in the petition

6 are true and correct to the best of my knowledge and belief, except the facts relating to the

7 employment ofthe other petitioners.

8 I declare under penalty of perjury under the laws of the State of Cali fomi a that the

9 foregoing is true and correct and that this verification was signed by me on August -1-, 2010,

10 at t. -; UlI2Jtlo.JZ.tCalifornia.

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Requa, et aI, v. Regents of University of California, et ale PETITION FOR WRIT OF MANDATE PAGE 15

08/06/2010 15:35 9254522297 PAK MAIL PAGE 01

I VERIFICATION OF WElIDELL G. MOEN


3 1. My name is Wendell G. Moen. I am of the Petitioners in this action. I am a

4 resident of the County of State of California.


6 are ttue and correct to the best of my knowledge 811ld beliet except the facts relating to the

7 employment of the other petitioners.

8 I declare under penalty of perjuxy under the laws of the State of California that the

9 fore,&oing is true and correct and that this verification was signed by me on August 2010.

10 at l:ka.s6lttbt, California.

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Requa. et or, v. Regents oj University of California. et al.

14:15 FROM:DAVIS 9254550862 TO: 15104655356 P.U1

1 VERIFICA TlON OF JAY DAVIS


3 L My name is Jay Davis. I am one of the Petitioners in this action. I am a resident of

4 the County of Alameda. State of California.


6 are true and correct to the best of my knowledge and belief. except the facts relating to the

7 employment of the other petitioners.

8 I declare under penalty of perjury under the Jaws of the State of California that the

9 foregoing is true and correct and that this verification was signed by me on August 2,2010,

10 at L {() ex""" 0).,( , California

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1 VERmCATION OF DoNNA V"£:NTURA


3 1. My name is Donna Vent\n'a. I am one of the Petitioners in d:ris action. I am a

4 resident of Contra Costa County, State of California. 5 2. I have read the above Petition for Writ of Mandate. The faclts alleged .in the petition

6 are true and coaect to the best of my .knowledge and beliet: except the facts relating to 1he 7 employment of the other petitioners.

8 I declare under penalty of perjury under the laws of the State of California that the 9 foregoing is 1rue and correct and that this verification was signed by me on August L 2010,

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Requa, et al. v. Regents of University of California. et al. PETITION FOR Wm OF MANDATE PAGE 18

Requa vs the Regents of the University of California

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