San Gabriel POA Vs City of San Gabriel

S UM -100

SUMMONS (CITACION JUDICIAL)

NOTICE TO DEFENDANT: (AVISO AL DEMANDADO):

CITY OF SAN GABRIEL, a municipality;CITY COUNCIL OF THE CITY OF SAN GABRIEL;DAVID R GUTIERREZ(please see attached)

YOU ARE BEING SUED BY PLAINTIFF: (LO ESTA DEMANDANDO EL DEMANDANTE):

SAN GABRIEL POLICE OFFICERS' ASSOCIATION; MARIAN ALVAREZ

FOR COURT USE ONLY (SOLO PARA ((WOE LA CORTE)

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NOTICE! You have been sued. The court may decide against you without your being heard unless you respond within 30 days. Read the information below.

You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at this court and have a copy served on the plaintiff. A letter or phone call will not protect you. Your written response must be in proper legal form if you want the court to hear your case. There may be a court form that you can use for your response. You can find these court forms and more information at the California Courts Online Self-Help Center (www.courtinfo.ca.goviselfhelp), your county law library, or the courthouse nearest you. If you cannot pay the filing fee, ask the court clerk for a fee waiver form. If you do not file your response on time, you may lose the case by default, and your wages, money, and property may be taken without further warning from the court.

There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may want to call an attorney referral service. If you cannot afford an attorney, you may be eligible for free legal services from a nonprofit legal services program. You can locate these nonprofit groups at the California Legal Services Web site (www.lawhelpcalifornia.org), the California Courts Online Self-Help Center (www.courtinfo.ca.goviselthelp), or by contacting your local court or county bar association. NOTE: The court has a statutory lien for waived fees and costs on any settlement or arbitration award of $10,000 or more in a civil case. The court's lien must be paid before the court will dismiss the case. jAVISO! Lo han demandado. Si no responde dentro de 30 dias, la corte puede decidir en su contra sin escuchar su version. Lea la informacion a continuaci6n.

Tiene 30 DIAS DE CALENDARIO despues de que le entreguen esta citaciOn y pape/es legales para presentar una respuesta por escrito en esta corte y hacer que se entregue una copia al demandante. Una carta o una Ilamada telefOnica no lo protegen. Su respuesta por escrito tiene que estar en formato legal correcto si desea que procesen su caso en la corte. Es posible que hays un formulario que usted pueda usar para su respuesta. Puede encontrar estos formularios de la corte y mas informaci6n en el Centro de Ayuda de las Cortes de California (www.sucorte.ca.gov), en la biblioteca de leyes de su condado o en la corte que le quede mas cerca. Si no puede pagar la cuota de presentaci6n, pida al secretario de la corte que le de un formulario de exenciOn de pago de cuotas. Si no presenta su respuesta a tiempo, puede perder el caso por incumplimiento y la corte le podra guitar su sue/do, dinero y bienes sin mas advertencia.

Hay otros requisitos legales. Es recomendable que !lame a un abogado inmediatamente. Si no conoce a un abogado, puede Ilamar a un servicio de remision a abogados. Si no puede pagar a un abogado, es posible que cumpla con los requisitos para obtener servicios legales gratuitos de un programa de servicios legales sin fines de lucro. Puede encontrar estos grupos sin fines de lucro en el sitio web de California Legal Services, (www.lawhelpcalifornia.org ), en el Centro de Ayuda de las Cortes de California, (www.sucorte.ca.gov) o poniendose en contacto con la corte o el colegio de abogados locales. AVISO: Por ley, la corte tiene derecho a reclamar las cuotas y los costos exentos por imponer un gravamen sobre cualquier recuperacion de $10,000 6 mas de valor recibida mediante un acuerdo o una concesiOn de arbitraje en un caso de derecho civil. Tiene que pagar el gravamen de la corte antes de que la code pueda desechar el caso.

The name and address of the court is: (El nombre y direcci6n de la corte es):

Los Angeles Superior Court - Northeast District Court 300 E. Walnut Street, Pasadena, CA 91101-1566

The name, address, and telephone number of plaintiffs attorney, or plaintiff without an attorney, is: (El nombre, la direcciOn y el flamer() de telefono del abogado del demandante, o del demandante que no tiene abogado, es):

Michael A. McGill, Esq. SBN 231613, 367 N. Second Ave., Upland, CA 91786

ri15.1A. CLARra AMAIN MOORE-R i LEY, , Deputy

(Secretario) (Adjunto)

[SEAL]

3. I I on behalf of (specify):

under: I I CCP 416.10 (corporation)

CCP 416.60 (minor)

CCP 416.20 (defunct corporation)

CCP 416.70 (conservatee)

CCP 416.40 (association or partnership)

CCP 416.90 (authorized person)

I 1 other (specify):

4. I I by personal delivery on (date): of 1

Form Adopted for Mandatory Use Judicial Council of California SUM-100 [Rev. July 1, 2009]

SUMMONS Code of Civil Procedure §§ 412.20, 465 www.courtinfo.ca.gov

American LegalNet, Inc. www.FormsWorkflow.com

CASE NUMBER: (NOmeno del Caso): 6 C 049042

MAR 0 8 2012 (For proof of service of this summons, use Proof of Service of Summons (form POS-010).) (Para prueba de entrega de esta citation use el formulario Proof of Service of Summons, (POS-010)).

NOTICE TO THE PERSON SERVED: You are served 1. I I as an individual defendant. 2. I I as the person sued under the fictitious name of (specify):

DATE: (Fecha)

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SHORT TITLE:

San Gabriel POA v. City of San Gabriel et al CASE NUMBER Ge04q042

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)

This form is required pursuant to LASC Local Rule 2.0 in all new civil case filings in the Los Angeles Superior Court.

Item I. Check the types of hearing and fill in the estimated length of hearing expected for this case:

JURY TRIAL? 3 YES CLASS ACTION? YES LIMITED CASE? YES TIME ESTIMATED FOR TRIAL 5 q HOURS/ Ca DAYS Item II. Select the correct district and courthouse location (4 steps — If you checked "Limited Case", skip to Item III, Pg. 4): Step 1: After first completing the Civil Case Cover Sheet Form, find the main civil case cover sheet heading for your case in

the left margin below, and, to the right in Column A, the Civil Case Cover Sheet case type you selected.

Step 2: Check one Superior Court type of action in Column B below which best describes the nature of this case.

Step 3: In Column C, circle the reason for the court location choice that applies to the type of action you have checked. For any exception to the court location, see Los Angeles Superior Court Local Rule 2.0.

Applicable Reasons for Choosing Courthouse Location (see Column C below) 1. Class Actions must be filed in the County Courthouse, Central District. 2. May be filed in Central (Other county, or no Bodily Injury/Property Damage). 3. Location where cause of action arose. 4. Location where bodily injury, death or damage occurred. 5. Location where performance required or defendant resides.

6. Location of property or permanently garaged vehicle. 7. Location where petitioner resides. 8. Location wherein defendant/respondent functions wholly. 9. Location where one or more of theparties reside. 10. Location of Labor Commissioner Office.

A Civil Case Cover Sheet

Category No.

B Type of Action

(Check only one)

C Applicable Reasons -

See Step 3 Above

Auto (22) q A7100 Motor Vehicle - Personal Injury/Property Damage/Wrongful Death 1., 2., 4.

Uninsured Motorist (46) q A7110 Personal Injury/Property Damage/Wrongful Death — Uninsured Motorist 1., 2., 4.

q A6070 Asbestos Property Damage 2. Asbestos (04)

q A7221 Asbestos - Personal Injury/Wrongful Death 2.

Product Liability (24) q A7260 Product Liability (not asbestos or toxic/environmental) 1., 2., 3., 4., 8.

Medical Malpractice (45) El A7210 Medical Malpractice - Physicians & Surgeons 1., 2., 4.

q A7240 Other Professional Health Care Malpractice 1. 2 4.

q A7250 Premises Liability (e.g., slip and fall) Other

Personal Injury Property Damage Wrongful Death

(23)

q

q

A7230 Intentional Bodily Injury/Property Damage/Wrongful Death (e.g., assault, vandalism, etc.)

A7270 Intentional Infliction of Emotional Distress

1.,

1.,

1.,

2.,

2.,

2.,

4.

4

3. q A7220 Other Personal Injury/Property Damage/Wrongful Death 1., 2., 4.

Business Tort (07) q A6029 Other Commercial/Business Tort (not fraud/breach of contract) 1., 2., 3.

Civil Rights (08) q A6005 Civil Rights/Discrimination 1. 2., 3.

Defamation (13) q A6010 Defamation (slander/libel) 1., 2., 3.

Fraud (16) q A6013 Fraud (no contract) 1., 2 3.

LACIV 109 (Rev. 01/07)

CIVIL CASE COVER SHEET ADDENDUM

LASC, rule 2.0

LASC Approved 03-04

AND STATEMENT OF LOCATION

Page 1 of 4

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SHORT TITLE

San Gabriel POA v. City of San Gabriel et al CASE NUMBER

Civil CaseA

Cover Sheet Category No.

B Type of Action

(Check only one)

C Applicable Reasons -See Step 3 Above

Professional Negligence

(25)

q

q

A6017 Legal Malpractice

A6050 Other Professional Malpractice (not medical or legal) 3.

1.,

1.,

2.,

2.,

3.

Other (35) q A6025 Other Non-Personal Injury/Property Damage tort 2.,3.

Wrongful Termination (36)

III A6037 Wrongful Termination 1., 2., 3.

Other Employment (15)

IZ

q

A6024 Other Employment Complaint Case

A6109 Labor Commissioner Appeals

1.,

10.

2., 3.

Breach of Contract/ Warranty

(06) (not insurance)

q

Eil

q

q

A6004 Breach of Rental/Lease Contract (not Unlawful Detainer or wrongful eviction)

A6008 Contract/Warranty Breach -Seller Plaintiff (no fraud/negligence)

A6019 Negligent Breach of Contract/Warranty (no fraud)

A6028 Other Breach of Contract/Warranty (not fraud or negligence)

2.,

2.,

1 ,

1.

5.

5.

2.,

2.,

5.

5.

Collections (09)

q

q

A6002 Collections Case-Seller Plaintiff

A6012 Other Promissory Note/Collections Case

2.,

2.,

5.,

5

6.

Insurance Coverage (18)

q A6015 Insurance Coverage (not complex) 1., 2., 5., 8.

Other Contract (37)

q

q

q

A6009 Contractual Fraud

A6031 Tortious Interference

A6027 Other Contract Dispute(not breach/insurance/fraud/negligence)

1.,

1.,

1.,

2.,

2.,

2.,

3.,

3.,

3.,

5.

5.

8.

Eminent Domain/Inverse

Condemnation (14)

q A7300 Eminent Domain/Condemnation Number of parcels 2.

Wrongful Eviction (33)

q A6023 Wrongful Eviction Case 2., 6.

Other Real Property (26)

q

q

q

A6018 Mortgage Foreclosure

A6032 Quiet Title

A6060 Other Real Property (not eminent domain, landlord/tenant, foreclosure)

2.,

2.

2.,

6.

6.

6.

Unlawful Detainer- Commercial (31)

0 A6021 Unlawful Detainer-Commercial (not drugs or wrongful eviction) 2., 6.

Unlawful Detainer- Residential (32)

Ell A6020 Unlawful Detainer-Residential (not drugs or wrongful eviction) 2., 6.

Unlawful Detainer- Drugs (38)

0 A6022 Unlawful Detainer-Drugs 2. 6.

Asset Forfeiture (05) q A6108 Asset Forfeiture Case 2., 6.

Petition re Arbitration (11)

q A6115 Petition to Compel/ConfirmNacate Arbitration 2 5

LACIV 109 (Rev. 01/07)


LASC, rule 2.0

LASC Approved 03-04


Page 2 of 4

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SHORT TITLE:


A Civil Case Cover Sheet

Category No.

B Type of Action

(Check only one)

C Applicable Reasons -

See Step 3 Above

Writ of Mandate

(02)

q A6151

q A6152

q A6153

Writ - Administrative Mandamus

Writ - Mandamus on Limited Court Case Matter

Writ - Other Limited Court Case Review

2.,

2

2.

8

Other Judicial Review (39)

q A6150 Other Writ /Judicial Review 2., 8.

Antitrust/Trade Regulation (03)

q A6003 Antitrust/Trade Regulation 1., 2 8.

Construction Defect (10) q A6007 Construction defect 1., 2., 3.

Claims Involving Mass Tort (40)

q A6006 Claims Involving Mass Tort 1., 2 8.

Securities Litigation (28) q A6035 Securities Litigation Case 1., 2 8.

Toxic Tort Environmental (30)

q A6036 Toxic Tort/Environmental 1., 2., 3., 8.

Insurance Coverage Claims from Complex

Case (41)

q A6014 Insurance Coverage/Subrogation (complex case only) 1., 2 5., 8.

Enforcement of Judgment

(20)

q A6141

q A6160

q A6107

q A6140

q A6114

q A6112

Sister State Judgment

Abstract of Judgment

Confession of Judgment (non-domestic relations)

Administrative Agency Award (not unpaid taxes)

Petition/Certificate for Entry of Judgment on Unpaid Tax

Other Enforcement of Judgment Case

2.,

2.,

2.,

2.,

2.,

2.,

9.

6.

9

8.

8.

8., 9.

RICO (27) q A6033 Racketeering (RICO) Case 1., 2 8.

Other Complaints (Not Specified Above)

(42)

q A6030

q A6040

q A6011

q A6000

Declaratory Relief Only

Injunctive Relief Only (not domestic/harassment)

Other Commercial Complaint Case (non-tort/non-complex)

Other Civil Complaint (non-tort/non-complex)

1

2.,

1.,

1

2.,

8.

2.,

2.,

8.

8.

8

Partnership Corporation Governance(21)

q A6113 Partnership and Corporate Governance Case 2., 8.

Other Petitions (Not Specified Above)

(43)

q A6121

q A6123

q A6124

L7 A6190

q A6110

El A6170

q A6100

Civil Harassment

Workplace Harassment

Elder/Dependent Adult Abuse Case

Election Contest

Petition for Change of Name

Petition for Relief from Late Claim Law

Other Civil Petition

9.

2.,

2

2 ,

2

2

2.,

2.,

3.,

3.,

3.,

7

3.,

9.

9

9

4., 8.

LACIV 109 (Rev. 01/07)


LASC, rule 2.0

LASC Approved 03-04


Page 3 of 4

SHORT TITLE:


Item III. Statement of Location: Enter the address of the accident, party's residence or place of business, performance, or other circumstance indicated in Item II., Step 3 on Page 1, as the proper reason for filing in the court location you selected.

REASON: CHECK THE NUMBER UNDER COLUMN C

WHICH APPLIES IN THIS CASE

Z 1. Z2. Z3. E14. 1115. E16. 117.118. D9. 1110.

ADDRESS:

425 S. Mission Drive

CITY:

San Gabriel

STATE:

CA

ZIP CODE:

91776

Item IV. Declaration of Assignment: I declare under penalty of perjury under the laws of the State of California that the foregoing is

true and correct and that the above-entitled matter is properly filed for assignment to the Pasadena courthouse in the Northeast District of the Los Angeles Superior Court (Code Civ. Proc., § 392 et seq., and LASC Local Rule 2.0,

subds. (b), (c) and (d)).

(SIGNATURE OF ATTORNEY/FILING PARTY)

PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY COMMENCE YOUR NEW COURT CASE:

1. Original Complaint or Petition.

2. If filing a Complaint, a completed Summons form for issuance by the Clerk.

3. Civil Case Cover Sheet form CM-010.

4. Complete Addendum to Civil Case Cover Sheet form LACIV 109 (Rev. 01/07), LASC Approved 03-04.

5. Payment in full of the filing fee, unless fees have been waived.

6. Signed order appointing the Guardian ad Litem, JC form FL-935, if the plaintiff or petitioner is a minor under 18 years of age, or if required by Court.

7. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendum must be served along with the summons and complaint, or other initiating pleading in the case.

LACIV 109 (Rev. 01/07)

CIVIL CASE COVER SHEET ADDENDUM LASC, rule 2.0 LASC Approved 03-04

AND STATEMENT OF LOCATION Page 4 of 4

Dated: March 8, 2012

SAN GABRIEL POLICE OFFICERS' ASSOCIATION; MARIAN ALVAREZ,

Plaintiffs, VS.

CITY OF SAN GABRIEL, a municipality; CITY COUNCIL OF THE CITY OF SAN GABRIEL; DAVID R GUTIERREZ, individually and in his official capacity as Mayor and Councilperson of the City of San Gabriel; KEVIN B. SAWKINS, individually and in his official capacity as Vice- Mayor and Councilperson of the City of San Gabriel; JULI COSTANZO, individually and in her official capacity as Councilperson of the City of San Gabriel; JOHN HARRINGTON, individually and in his official capacity as Councilperson of the City of San Gabriel; MARIO DE LA TORRE, individually and in his official capacity as Councilperson of the City of San Gabriel; STEVEN A. PRESTON, individually and in his official capacity as the City Manager of the City of San Gabriel; TOM MARSTON, individually and in his official capacity as the Finance Director for the City of San Gabriel; ROBERT KRESS, in his official capacity as City Attorney for the City of San

1

oR Gm" FILED

UR -8 2012

LOS LLES SUPERIOR COURT

Dieter C. Dammeier, SBN 188759 [email protected] Michael A. McGill, SBN 231613 [email protected] LACKIE, DAMMEIER & McGILL APC 367 North Second Avenue Upland, CA 91786 Telephone: (909) 985-4003 Facsimile: (909) 985-3299

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Attorneys for Plaintiffs SAN GABRIEL POLICE OFFICERS' ASSOCIATION; MARIAN ALVAREZ

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF LOS ANGELES — NORTHEAST DISTRICT

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Case No.:

COMPLAINT FOR DAMAGES AND DECLARATORY AND INJUNCTIVE RELIEF

DEMAND FOR JURY TRIAL

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COMPLAINT

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Gabriel; JOHN JANOSIK, individually and in his official capacity as the Treasurer of the City of San Gabriel; and DOES 1 through 50, Inclusive,

Defendants.

1. Plaintiff SAN GABRIEL POLICE OFFICERS' ASSOCIATION ("SGPOA") is

the recognized exclusive bargaining representative for those employees of the City of San

Gabriel ("the City") with the job classification of Police Officer. The SGPOA can sue and be

sued in its name and on behalf of its members.

2. Plaintiff MARIAN ALVAREZ brings this claim on behalf of herself and all other

similarly situated residents and taxpayers of the City of San Gabriel. She is a resident of the City

of San Gabriel who is liable or has been liable within one year of the filing of this complaint for

the payment of taxes, assessments and fees imposed and collected by the City.

3. Defendant CITY OF SAN GABRIEL ("the City") is a duly constituted municipal

corporation operating under the laws of the State of California, wholly situated in the County of

Los Angeles.

4. Defendant CITY COUNCIL OF THE CITY OF SAN GABRIEL ("City

Council"), the elected governing body of Defendant City, is responsible for establishing laws and

policies in the conduct of City business.

5. Defendant DAVID R GUTIERREZ is the Mayor and a Councilperson for the City

of San Gabriel. Defendant Gutierrez is named in both his official and individual capacities.

6. Defendant KEVIN B. SAWKINS is the Vice-Mayor and a Councilperson for the

City of San Gabriel. Defendant Sawkins is named in both his official and individual capacities.

7. Defendant JULI COSTANZO is a Councilperson for the City of San Gabriel.

Defendant Costanzo is named in both her official and individual capacities.

8. Defendant JOHN HARRINGTON is a Councilperson for the City of San Gabriel.

Defendant Harrington is named in both his official and individual capacities.

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COMPLAINT

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9. Defendant MARIO DE LA TORRE is a Councilperson for the City of San

Gabriel. Defendant De La Torre is named in both his official and individual capacities.

10. Defendant STEVEN A. PRESTON, the appointed City Manager of Defendant

City, is responsible for the administration of all City departments, and serves as the City's chief

executive to the City Council. Defendant Preston is named in both his official and individual

capacities.

11. Defendant TOM MARSTON is the Finance Director for the City of San Gabriel.

Defendant Marston is named in both his official and individual capacities.

12. Defendant ROBERT KRESS is the City Attorney for the City of San Gabriel. As

City Attorney, Kress owes a duty to residents and employees, including Plaintiff SGPOA's

members, of the City of San Gabriel to ensure that the City complies with the law. Defendant

Kress is named in his official and individual capacity.

13. Defendant JOHN JANOSIK, the elected City Treasurer of Defendant City, is

responsible for establishing and maintaining the procedures and controls over City revenues and

expenditures. Defendant Janosik is named in both his official and individual capacities.

14. The true names and capacities of the Defendants named herein as DOES 1

through 10, whether individual, government, corporate, associate, or otherwise, are unknown to

Plaintiffs who therefore bring this claim against Defendants by such fictitious names pursuant to

Code of Civil Procedure, § 474 et. seq.

15. Defendants DOES 1 through 50, were at all times alleged herein, officers,

employees or public bodies of defendant City and in some capacity were responsible for the

wrongful acts herein complained of. Plaintiffs are informed and believe that the DOE individual

Defendants herein are California residents and will amend this claim to show their true names

and capacities once they have been ascertained. Based on information and belief, DOES 1

through 50 personally benefitted from the unlawful actions complained of herein.

16. In 1948, the people of the City of San Gabriel voted upon and enacted Ordinance

No. 540, authorizing the City to enter its employees into the "State Employees' Retirement

System," and create a special tax to fund the obligations of this retirement system. (The "State

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Employees' Retirement System" is now known as the "Public Employees' Retirement System",

or "PERS".)

17. Regarding the special tax, Ordinance No. 540 of 1948 authorized the City to:

"...levy and collect annually...a special tax sufficient to raise the amount estimated...to be required to provide sufficient revenues to meet the obligations of said City to said retirement system..." (See "Exhibit A" attached hereto. Emphasis added.)

18. Based on information and belief, since the adoption of this special tax, the City

has updated the tax by enacting annual rate-setting Resolutions.

19. According to documents obtained by Plaintiffs, every rate-setting Resolution

enacted for the past eleven years, from fiscal year 2000-2001 through 2010-2011, specifically

references the purpose of the tax as the "City's indebtedness to Public Employees' Retirement

System as set forth in Ordinance No. 540..." (See "Exhibit B" attached hereto.)

20. Since at least fiscal year 2000-2001, and most likely beginning before that year,

the revenue from this special tax has been placed outside the City's general fund and into the

City's designated "Retirement Fund."

21. Despite the enumerated specified purpose for the revenues generated from this

special tax, documents obtained by Plaintiffs show that the funds instead are being, and have

been, diverted towards and used for purposes other than the City's indebtedness and contractual

obligations to PERS for the benefit of its employees, and attracting and retaining qualified

employees for the benefit of the City, and ultimately its residents, businesses and other

constituents.

22. Specifically, documents show that at least $5,714,280 from the City's Retirement

Fund has been diverted by Defendants to fund numerous benefits for City staff personnel,

including deferred compensation accounts and retiree medical accounts. (See Exhibit C attached

hereto.)

23. In addition, based on information and belief, interest received from the special tax

revenue was diverted to the City's General Fund by Defendants to assist in paying for City Staff

compensation increases.

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24. Based on information and belief, defendants MARSTON and PRESTON

personally received these benefits, and thus personally benefit from the diversions from the City

Retirement Fund.

25. Upon information and belief, Plaintiffs estimate that more than $5,714,280 has

been impermissibly diverted from the City's Retirement Fund; the documents obtained by

Plaintiffs only extend back to fiscal year 2000-2001.

26. As a result of these diversions, the Retirement Fund has been depleted to a point

where its continued solvency is in jeopardy, and as such the City's responsibility to fund its

PERS obligations is creating a fiscal crisis endangering the well-being of the City as a whole.

27. Based on information and belief, Defendant

28. In doing the things alleged herein, the individually-named Defendants acted under

color of state law, and within the course and scope of employment and official duties.

FIRST CAUSE OF ACTION

Failure to Comply with Mandatory Duty Under Gov't Code § 53724

Government Code § 815.6

29. Plaintiffs re-alleges each and every preceding paragraph as though set forth in full

here.

30. California Government Code § 815.6 states:

Where a public entity is under a mandatory duty imposed by an enactment that is designed to protect against the risk of a particular kind of injury, the public entity is liable for an injury of that kind proximately caused by its failure to discharge the duty unless the public entity establishes that it exercised reasonable diligence to discharge the duty.

(Emphasis added.)

31. California Gov't Code § 53724 imposes a mandatory duty on Defendants to

ensure that a special tax may be "used only for the purpose or service for which it was imposed,

and for no other purpose whatsoever." Gov't Code § 53724 (emphasis added).

32. The tax imposed pursuant to Ordinance No. 540 is a special tax, because it is a tax

"levied to fund a specific governmental project or program." Rider v. County of San Diego, 1

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.d 6 g

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Cal.4th 1, 15 (1991); see also Gov't Code § 53721 ("Special taxes are taxes imposed for specific

purposes.").

33. In doing the things alleged to have been done, Defendants unlawfully diverted

special tax revenue from the City's Retirement Fund towards purposes not specified in

enactment of the special tax, in violation of California Government Code § 53724.

34. Plaintiffs have been harmed by the depletion of the City's Retirement Fund in that

their pensions are now underfunded. Defendant's failure to comply with their mandatory duty to

fund the City's Retirement Fund as required by Ordinance No. 540 is the direct and proximate

cause of the depletion and underfunding of the City's Retirement Fund.

SECOND CAUSE OF ACTION

Illegal Expenditure of Taxpayer Funds

C.C.P. § 526a

35. Plaintiffs re-allege each and every preceding paragraph as though set forth in full

here.

36. C.C.P. § 526a provides in relevant part that a "taxpayer's suit", "...to obtain a

judgment, restraining and preventing any illegal expenditure of...(the) funds...of a county, town,

city...may be maintained against any officer thereof, or any agent, or other person, acting in its

behalf, either by a citizen resident therein, or by a corporation, who is assessed for and is liable

to pay, or, within one year before the commencement of the action, has paid, a tax therein."

37. Defendants diversion of funds from the specified purposes of the special tax is

unlawful, as it is made in violation of Gov. Code § 53724. Gov . Code § 53724 provides in

relevant part that revenues from a special tax may be "used only for the purpose or service for

which it was imposed, and for no other purpose whatsoever." (Emphasis added.) The tax

imposed pursuant to Ordinance No. 540 is a special tax, because it is a tax "levied to fund a

specific governmental project or program." Rider v. County of San Diego, 1 Ca1.4th 1, 15 (1991).

(Also see Gov. Code § 53721: "Special taxes are taxes imposed for specific purposes.")

6

COMPLAINT

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

38. Plaintiffs also claim damages from the individually-named Defendants, in the

form of reimbursement into the City's General Fund all unlawfully diverted money, as their

unlawful acts herein described were done in an absence of "due care."

THIRD CAUSE OF ACTION

Legal Malpractice — Wrongful Act or Omission

Against Defendant Robert Kress Only

39. Plaintiffs re-allege each and every preceding paragraph as though set forth in full

here.

40. As, City Attorney, Defendant Kress, owes a duty to Plaintiffs to use such skill,

prudence and diligence as City Attorneys commonly possess. Specifically, Defendant Kress

owes to Plaintiffs to ensure that City officials do not violate state statutes and that they are

informed of their obligations under the law regarding the acts and omissions complained of

herein.

41. Defendant Kress breached his duty to Plaintiffs. Based on information and belief

Kress was present and took part in the actions resulting in the illegal expenditure of taxpayer

funds.

42. As a proximate cause of Kress' breach, Plaintiffs were harmed in the depleted

funding of their retirement accounts.

FOURTH CAUSE OF ACTION

Violations of California Propositions 13 and 62

43. Plaintiffs reallege and incorporate by reference paragraphs 1 through 42 as though

fully set forth herein.

44. In 1978, Proposition 13 added Article 13a to the California Constitution, requiring

that all special taxes be approved by two-thirds vote of the local electorate.

45. In 1986, the California voters approved Proposition 62, requiring all proposals for

a new or higher general tax to be approved by two-thirds of the local agency's governing body,

and by a majority of the voters, and that proposals for special taxes contain specific information

7

COMPLAINT

1

2

3

4

5

6

7

8

9

10

11

12

1:3

14

15

16

17

18

19

20

2 1

24

-) 5

concerning the proposed use, and penalizes local agencies for failing to comply with these

requirements, as well as requiring local agencies to stop collecting any new or higher general

taxes adopted after July 31, 1985 unless approved by a majority of voters.

46. In doing things alleged hereinabove, the Defendants and each of them failed to

comply with either or both Proposition 13 and Proposition 62.

WHEREFORE, Plaintiffs pray that this Court:

1. Award general, compensatory, and special damages according to proof;

2. Award injunctive relief ordering Defendants to cease the unlawful diversion of

funds from the City's Retirement Fund and the interest accrued from the same;

3. Award injunctive relief ordering Defendants to take all necessary actions so as to

return all unlawfully diverted funds back into the City's Retirement Fund;

4. Render a judicial determination that the actions of the City as described above is

unlawful as it violates Gov't Code §§ 815.6, 53724 and C.C.P. § 526a;

5. Award reasonable attorney's fees and costs under C.C.P. §1021.5, and as

otherwise provided by law;

6. Award interest as provided by law; and

7. Award such other and further relief that the Court deems necessary and proper.

Dated: March 8, 2012 Respectfully Submitted,

LACKIE, DAM ER & McGILL APC

Dieter C. Dammeier Michael A. McGill Attorneys for Plaintiffs, SAN GABRIEL POLICE OFFICERS' ASSOCIATION; MARIAN ALVAREZ

26

77

28

8

COMPLAINT

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

24

25

"?6,

27

28

DEMAND FOR TRIAL BY JURY

Plaintiff hereby demands a trial by jury.

Dated: March 8, 2012 Respectfully Submitted,

LACKIE, DAMMEIER & McGILL APC

Dieter C. Dammeier Michael A. McGill Attorneys for Plaintiffs, SAN GABRIEL POLICE OFFICERS' ASSOCIATION; MARIAN ALVAREZ

9

COMPLAINT

SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES

Reserved for Clerk's File Stamp

l' . I FILED

EAR —8 2012

L. n S , LES

COURTHOUSE ADDRESS: 300 EAST WALNUT STREET, PASADENA, CALIFORNIA 91101

PLAINTIFF:

DEFENDANT:

NOTICE OF CASE MANAGEMENT CONFERENCE CASE NUMRER_Atefb i (4 1.611.12

TO THE PLAINTIFF(S)/ATTORNEY(S) FOR PLAINT! RECORD:

You are ordered to serve this notice of hearing on all parties/attorneys of record forthwith, and meet and confer with all parties/attorneys of record about the matters to be discussed no later than 30 days before the Case Management Conference.

Your Case Management Conference has been scheduled at the courthouse address shown above on:

Dale: JUL 1 2 2012me 8:3° a.m. NEP

Dept.: ra)

NOTICE TO DEFENDANT: THE SETTING OF THE CASE MANAGEMENT CONFERENCE DOES NOT EXEMPT THE DEFENDANT FROM FILING A RESPONSIVE PLEADING AS REQUIRED BY LAW.

Pursuant to California Rules of Court, rules 3.720-3.730, a completed Case Management Statement (Judicial Council form # CM-110) must be filed at least 15 calendar days prior to the Case Management Conference. The Case Management Statement may be filed jointly by all parties/attorneys of record or individually by each party/attorney of record. You must be familiar with the

case and be fully prepared to participate effectively in the Case Management Conference.

At the Case. Management Conference, the Court may make pretrial orders including the following, but not limited to, an order establishing a‘discovery schedule; an order referring the case to Alternative Dispute Resolution (ADR); an order reclassifying the case; an order setting subsequent conference and the trial date; or other orders to achieve the goals of the Trial Court Delay Reduction Act (Gov. Code, § 68600 et seq.)

Notice is hereby given that if you do not file the Case Management Statement or appear and effectively participate at the Case Management Conference, the Court may impose sanctions, pursuant to LASC Local Rule 7.13, Code of Civil Procedure

sections 177.5, 575.2, 583.150, 583.360 and 583.410, Government Code section 68608, subdivision (b), and California Rules of

Court, rule 2.2 et seq.

Dated: MARY THORNTON HOUSE

Judicial Officer

CERTIFICATE OF SERVICE

I, the below named Executive Officer/Clerk of the above-entitled court, do hereby certify that I am not a party to the cause herein, and that on this date I served the Notice of Case Management Conference upon each party or counsel named below:

q by depositing in the United States mail at the courthouse in , California, one copy of the original

filed herein in a separate sealed envelope to each address as shown below with the postage thereon fully prepaid.

[711 by personally giving the party notice upon filing of the complaint.

I41 11 40, JOHN A. CLARKE, Executive/Officer Clerk

Dated: By DAWN Ft400:1E-Fin. Deputy Clerk

LACIV 132 (Rev. 09/07) NOTICE OF

Cal. Rules of Court, rules 3.720-3.730

LASC Approved 10-03 CASE MANAGEMENT CONFERENCE

LASC Local Rules, Chapter Seven

NEP—JAN A. PLUIM --C . EDWARD SIMPSON

NES—JOSEPH F. DE VANON

SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES ALTERNATIVE DISPUTE RESOLUTION (ADR) INFORMATION PACKAGE

[CRC 3.221 Information about Alternative Dispute Resolution] For additional ADR information and forms visit the Court ADR web application at www.lasuperiorcourt.org (click on ADR).

The plaintiff shall serve a copy of this Information Package on each defendant along with the complaint (Civil only).

What Is ADR: Alternative Dispute Resolution (ADR) is the term used to describe all the other options available for settling a dispute which once had to be settled in court. ADR processes, such as arbitration, mediation, neutral evaluation (NE), and settlement conferences, are less formal

than a court process and provide opportunities for parties to reach an agreement using a problem-solving approach.

There are many different kinds of ADR. All of them utilize a "neutral", an impartial person, to decide the case or help the parties reach an

agreement.

Mediation: In mediation, a neutral person called a "mediator" helps the parties try to reach a mutually acceptable resolution of the dispute. The mediator does not decide the dispute but helps the parties communicate so they can try to settle the dispute themselves. Mediation

leaves control of the outcome with the parties.

Cases for Which Mediation May Be Appropriate Mediation may be particularly useful when parties have a dispute between or among family members, neighbors, or business partners. Mediation is also effective when emotions are getting in the way of resolution. An effective mediator can hear the parties out and help them communicate with each other in an effective and nondestructive manner.

Cases for Which Mediation May Not Be Appropriate Mediation may not be effective if one of the parties is unwilling to cooperate or compromise. Mediation also may not be effective if one of the parties has a significant advantage in power over the other. Therefore, it may not be a good choice if the parties have

a history of abuse or victimization.

Arbitration: In arbitration, a neutral person called an "arbitrator" hears arguments and evidence from each side and then decides the outcome of the

dispute. Arbitration is less formal than a trial, and the rules of evidence are often relaxed. Arbitration may be either "binding" or

"nonbinding." Binding arbitration means that the parties waive their right to a trial and agree to accept the arbitrator's decision as final.

Nonbinding arbitration means that the parties are free to request a trial if they do not accept the arbitrator's decision.

Cases for Which Arbitration May Be Appropriate Arbitration is best for cases where the parties want another person to decide the outcome of their dispute for them but would like to avoid the formality, time, and expense of a trial. It may also be appropriate for complex matters where the parties want a decision-maker who has training or experience in the subject matter of the dispute.

Cases for Which Arbitration May Not Be Appropriate If parties want to retain control over how their dispute is resolved, arbitration, particularly binding arbitration, is not appropriate. In

binding arbitration, the parties generally cannot appeal the arbitrator's award, even if it is not supported by the evidence or the law. Even in nonbinding arbitration, if a party requests a trial and does not receive a more favorable result at trial than in

arbitration, there may be penalties.

Neutral Evaluation: In neutral evaluation, each party gets a chance to present the case to a neutral person called an "evaluator." The evaluator then gives an opinion on the strengths and weaknesses of each party's evidence and arguments and about how the dispute could be resolved. The evaluator is often an expert in the subject matter of the dispute. Although the evaluator's opinion is not binding, the parties typically use it

as a basis for trying to negotiate a resolution of the dispute.

Cases for Which Neutral Evaluation May Be Appropriate Neutral evaluation may be most appropriate in cases in which there are technical issues that require special expertise to resolve or the only significant issue in the case is the amount of damages.

Cases for Which Neutral Evaluation May Not Be Appropriate Neutral evaluation may not be appropriate when there are significant personal or emotional barriers to resolving the dispute.

Settlement Conferences: Settlement conferences may be either mandatory or voluntary. In both types of settlement conferences, the parties and their attorneys meet with a judge or a neutral person called a "settlement officer" to discuss possible settlement of their dispute. The judge or settlement officer does not make a decision in the case but assists the parties in evaluating the strengths and weaknesses of the case and in

negotiating a settlement. Settlement conferences are appropriate in any case where settlement is an option. Mandatory settlement conferences are often held close to the date a case is set for trial .

LAADR 005 (05-09) LASC Approved Page 1 of 2

COURTHOUSE Antonovich Chatsworth Compton Glendale Long Beach Norwalk Pasadena Pomona San Pedro Santa Monica Stanley Mosk Torrance Van Nuys

ADDRESS 42011 4th St. West 9425 Penfield Ave. 200 W. Compton Blvd. 600 E. Broadway 415 W. Ocean Blvd. 12720 Norwalk Blvd. 300 E. Walnut St. 400 Civic Center Plaza 505 S. Centre 1725 Main St. 111 N. Hill St. 825 Maple Ave. 6230 Sylmar Ave.

ROOM None 1200 1002 273 316 308 109 106 209 203 113 100 418

CITY Lancaster, CA 93534 Chatsworth, CA 91311 Compton, CA 90220 Glendale, CA 91206 Long Beach, CA 90802 Norwalk, CA 90650 Pasadena, CA 91101 Pomona, CA 91766 San Pedro, CA 90731 Santa Monica, CA 90401 Los Angeles, CA 90012 Torrance, CA 90503 Van Nuys, CA 91401

PHONE (661)974-7275 (818)576-8565 (310)603-3072 (818)500-3160 (562)491-6272 (562)807-7243 (626)356-5685 (909)620-3183 (310)519-6151 (310)260-1829 (213)974-5425 (310)222-1701 (818)374-2337

FAX (661)974-7060 (818)576-8687 (310)223-0337 (818)548-5470 (562)437-3802 (562)462-9019 (626)666-1774 (909)629-6283 (310)514-0314 (310)319-6130 (213)633-5115 (310)782-7326 (818)902-2440

LOS ANGELES SUPERIOR COURT ADR PROGRAMS CIVIL:

• Civil Action Mediation (Governed by Code of Civil Procedure (CCP) sections 1775-1775.15, California Rules of Court, rules 3.850-3.868 and 3.870-3.878, Evidence Code sections 1115-1128, and Los Angeles Superior Court Rules, chapter 12.)

• Retired Judge Settlement Conference

• Neutral Evaluation (Governed by Los Angeles Superior Court Rules, chapter 12.) • Judicial Arbitration (Governed by Code of Civil Procedure sections 1141.10-1141.31, California Rules of Court, rules 3.810-3.830, and Los

Angeles Superior Court Rules, chapter 12.) • Eminent Domain Mediation (Governed by Code of Civil Procedure section 1250.420.) • Civil Harassment Mediation • Small Claims Mediation

FAMILY LAW (non-custody) - • Mediation

• Forensic Certified Public Accountant (CPA) Settlement Conference • Settlement Conference

• Nonbinding Arbitration (Governed by Family Code section 2554.) PROBATE:

• Mediation

• Settlement Conference

NEUTRAL SELECTION

Parties may select a mediator, neutral evaluator, or arbitrator from the Court Party Select Panel or may hire someone privately, at their discretion. If the parties utilize the Random SeleCt Mediation or Arbitration Panel, the parties will be assigned on a random basis the name of one neutral who meets the case criteria entered on the court's website.

COURT ADR PANELS

The Party Select Panel consists of mediators, neutral evaluators, and arbitrators who have achieved a specified level of experience in court-connected cases. The parties (collectively) may be charged $150.00 per hour for the first three hours of hearing time. Thereafter, the parties may be charged for additional hearing time on an hourly basis at rates established by the neutral if the parties consent in writing.

Random Select The Random Select Panel consists of trained mediators, neutral evaluators, and arbitrators who have not yet gained Panel the experience to qualify for the Party Select Panel, as well as experienced neutrals who make themselves available

pro bono as a way of supporting the judicial system. It is the policy of the Court that all Random Select panel volunteer mediators, neutral evaluators, and arbitrators provide three hours hearing time per case. Thereafter, the parties may be charged for additional hearing time on an hourly basis at rates established by the neutral if the parties consent in writing.

The market rate for private neutrals can range from $300-$1,000 per hour.

ADR ASSISTANCE For assistance regarding ADR, please contact the ADR clerk at the courthouse in which your case was filed.

Partially Funded by the Los Angeles County Dispute Resolution Program

A complete list of the County Dispute Resolution Programs is available online and upon request in the Clerk's Office.

LAADR 005 (05-09) LASC Approved

Party Select

Panel

Private Neutral

Page 2 of 2

NAME. ADDRESS, AND TELEPHONE NUMBER OF ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NUMBER Reserved le Pinks Fie Wear

ATTORNEY FOR (Name): SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES COURTHOUSE ADDRESS:

PLAINTIFF:

DEFENDANT:

CASE NUMBER: STIPULATION TO PARTICIPATE IN ALTERNATIVE DISPUTE RESOLUTION (ADR)

The undersigned parties stipulate to participate in an Alternative Dispute Resolution (ADR) process in the above-entitled

action, as follows:

q Mediation

q Non-Binding Arbitration

q Binding Arbitration

(=I Early Neutral Evaluation

q Settlement Conference

IEJ Other ADR Process (describe):

Dated:

Name of Stipulating Party Name of Party or Attorney Executing Stipulation

1:1 Plaintiff 1:1 Defendant 111 Cross-defendant

Signature of Party or Attorney

Name of Stipulating Party Name of Party or Attorney Executing Stipulation Signature of Party or Attorney

1:1 Plaintiff 1,:j Defendant q Cross-defendant


1:1 Plaintiff q Defendant q Cross-defendant Signature of Party or Attorney


q Plaintiff q Defendant q Cross-defendant Signature of Party or Attorney

DR 001 10-04 ASC Approved Rev. 01 -07)

q Additional signature(s) on reverse

STIPULATION TO PARTICIPATE IN ALTERNATIVE DISPUTE RESOLUTION (ADR)

Cal. Rules of Court, rule 3.221 Page 1 of 2

Signature of Party or Attorney lame of Stipulating Party

Name of Party or Attorney Executing Stipulation ] Plaintiff q Defendant q Cross-defendant

Signature of Party or Attorney ame of Stipulating Party


Signature of Party or Attorney ame of Stipulating Party


R 001 10-04 3C Approved At. 01-07)

Cal. Rules of Court, rule 3.221 Page 2 of 2

STIPULATION TO PARTICIPATE IN ALTERNATIVE DISPUTE RESOLUTION (ADR)

Jame of Stipulating Party • Name of Party or Attorney Executing Stipulation Signature of Party or Attorney 3 Plaintiff q Defendant q Cross-defendant

Jame of Stipulating Party Name of Party or Attorney Executing SlipulationSignature of Party or Attorney 3 Plaintiff q Defendant q Cross-defendant

lame of Stipulating Party Name of Party or Attorney Executing Stipulation Signature A Plaintiff 0 Defendant q Cross-defendant of Party or ttorney

Jame of Stipulating Party Name of Party or Attorney Executing Stipulation Si ] Plaintiff gnature of Party or Attorney tiff 0 Defendant q Cross-defendant

lame of Stipulating Party Name of Party or Attorney Executing Stipulation Signature of Party or Attorney ] Plaintiff q Defendant q Cross-defendant

ame of Stipulating Party Name of Party or Attorney Executing Stipulation Signature of Party or Attorney ] Plaintiff q Defendant q Cross-defendant

ame of Stipulating Party Name of Party or Attorney Executing Stipulation Signature of Party or Attorney ] Plaintiff q Defendant q Cross-defendant

Short Title Case Number

LOS ANGELES COUNTY DISPUTE RESOLUTION PROGRAMS ACT (DRPA) CONTRACTORS

. following organizations provide mediation services under contract with the Los Angeles County Department of Community & Senior Services. Services are provided to parties in any civil case filed in the Los Angeles County Superior Court. Services are not provided under this program to family, probate, traffic, criminal, appellate, mental health, unlawful detainer/eviction or juvenile court cases.

Asian-Pacific American Dispute Resolution Center (213) 250-8190

(Spanish & Asian languages capability)

California Academy of Mediation Professionals (818) 377-7250

Center for Conflict Resolution (818) 380-1840

Inland Valleys Justice Center (909) 397-5780

(Spanish language capability)

Office of the Los Angeles City Attorney Dispute Resolution Program (213) 485-8324


Los Angeles County Bar Association=Dispute Resolution Services toll free number 1-877-4Resolve (737-6583) or (213) 896-6533


Los Angeles County Department of Consumer Affairs (213) 974-0825


The Loyola Law School Center for Conflict Resolution (213) 736-1145


Martin Luther King Legacy Association Dispute Resolution Center (323) 290-4132


City of Norwalk (562) 929-5603

DRPA Contractors do not provide legal advice or assistance, including help with responding to summonses. Accessing these services does not negate any responsibility you have to respond to a summons or appear at any set court date. See the reverse side of this sheet for information on the mediation process and obtaining legal advice.

THIS IS A TWO-SIDED DOCUMENT. ADR 007 07-04 LASC Approved

Page 1 of 2

What is the goat of mediation?

The goal is to assist the parties in reaching a mutually acceptable agreement or understanding on some or all

of the issues. The parties jointly become the primary decision maker in how to resolve the issues as opposed to

the traditional judge and/or -jury system.

Do I need an attorney for this?

While it is recommended to have an attorney and/or receive legal advice before the mediation starts, you are not required to have representation. If you do have an attorney, they may participate in the mediation with you.

How long does it take?

Face-to-face mediations generally last one to three hours. Telephone conciliations, in which the parties do not meet face to face, vary from a few days to several weeks. Much depends on the number of parties involved and the complexities of the issues. When the mediation takes place depends on parties scheduling availability.

A Mediator helps parties...

+ Have productive discussions ♦Avoid or break impasses +Defuse controversy *Generate options that have potential for mutual gain

Better understand each other's concerns and goals *Focus on their interests rather than their positions

A Mediator does not...

+Provide advice or opinions ♦Offer legal information +Make decisions for parties +Represent or advocate for either side ♦Judge or evaluate anyone or anything *Conduct research ♦ "Take Sides"

What does it cost?

The first three hours of any mediation are free. Thereafter, charges are based on income or revenue. All fees are waived for low-income individuals.

Legal Advice/Information

If you want to retain an attorney, a list of state certified referral services is at courtinfo.ca.gov which also has an on-line self help legal center.

Self-Help Legal Access Centers are at the Inglewood, Palmdale, Pomona, and Van Nuys courthouses. nls-la.orq and lalla.orq What is the difference between the contractors

The services offered by the contractors listed may be accessed immediately. Those offered by the Superior Court ADR Office, also a DRPA contractor, may not

be accessed by parties until a court appearance, or at the directive of the judge assigned to the case.

listed and the Superior Court ADR Office? Court Personnel can answer non-legal questions (forms, fees, fee waivers). lasuperiorcourt.orq

Low-income individuals may qualify for help from non-profit legal organizations. Court Personnel and DRPA contractors have such listings.

Dispute Resolution Programs Act (DRPA) Grants Administration Office (213) 738-2621

(The ORP Office Is not a Superior Court Office. Consult your phone directory to locate the number of the Court Office on your summons.)

THIS IS A TWO-SIDED DOCUMENT.

ADR 007 07-04

Page 2 of2

IASC Approved

San Gabriel POA Vs City of San Gabriel

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Transcript of San Gabriel POA Vs City of San Gabriel