Friday, November 17, 2017

Chilone Payton vs. City of Carmel by the Sea, CA. FIRST AMENDED COMPLAINT FOR DAMAGES FOR: (1) RACE DISCRIMINATION IN VIOLATION OF FEHA; (2) HARASSMENT ON THE BASIS OF RACE IN VIOLATION OF FEHA; (3) SEX DISCRIMINATION IN VIOLATION OF FEHA; (4) HARASSMENT ON THE BASIS OF SEX IN VIOLATION OF FEHA; (5) RETALIATION FOR COMPLAINING ABOUT DISCRIMINATION AND HARASSMENT ON THE BASIS OF RACE IN VIOLATION OF FEHA; (6) RETALIATION FOR COMPLAINING ABOUT DISCRIMINATION AND HARASSMENT ON THE BASIS OF SEX IN VIOLATION OF FEHA; and (7) FAILURE TO TAKE ALL REASONABLE STEPS NECESSARY TO PREVENT DISCRIMINATION AND HARASSMENT FROM OCCURRING IN VIOLATION OF FEHA.

ABSTRACT: RE: IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF MONTEREY CHILONE PAYTON, Plaintiff, VS. CITY OF CARMEL-BY -THE-SEA, CA, and DOES 1 through 21, inclusive, Defendants. Case No.: 16CV003820 FIRST AMENDED COMPLAINT FOR DAMAGES FOR:
(1) RACE DISCRIMINATION IN VIOLATION OF FEHA;
(2) HARASSMENT ON THE BASIS OF RACE IN VIOLATION OF FEHA;
(3) SEX DISCRIMINATION IN VIOLATION OF FEHA;
(4) HARASSMENT ON THE BASIS OF SEX IN VIOLATION OF FEHA;
(5) RETALIATION FOR COMPLAINING ABOUT DISCRIMINATION AND HARASSMENT ON THE BASIS OF RACE IN VIOLATION OF FEHA;
(6) RETALIATION FOR COMPLAINING ABOUT DISCRIMINATION AND HARASSMENT ON THE BASIS OF SEX IN VIOLATION OF FEHA; and
(7) FAILURE TO TAKE ALL REASONABLE STEPS NECESSARY TO PREVENT DISCRIMINATION AND HARASSMENT FROM OCCURRING IN VIOLATION OF FEHA.

On February 13, 2017, Jose A. Gonzalez, Attorney for Chilone Payton, submitted to the Superior Court of California, County of Monterey, FIRST AMENDED COMPLAINT FOR DAMAGES FOR: (1) RACE DISCRIMINATION IN VIOLATION OF FEHA; (2) HARASSMENT ON THE BASIS OF RACE IN VIOLATION OF FEHA; (3) SEX DISCRIMINATION IN VIOLATION OF FEHA; (4) HARASSMENT ON THE BASIS OF SEX IN VIOLATION OF FEHA; (5) RETALIATION FOR COMPLAINING ABOUT DISCRIMINATION AND HARASSMENT ON THE BASIS OF RACE IN VIOLATION OF FEHA; (6) RETALIATION FOR COMPLAINING ABOUT DISCRIMINATION AND HARASSMENT ON THE BASIS OF SEX IN VIOLATION OF FEHA; and (7) FAILURE TO TAKE ALL REASONABLE STEPS NECESSARY TO PREVENT DISCRIMINATION AND HARASSMENT FROM OCCURRING IN VIOLATION OF FEHA. On April 4, 2017, a Conference Case Management was held. A Conference Settlement is scheduled for February 16, 2018, Department 14 and a Jury Trial: Long Cause is scheduled for March 19, 2018, Department 14, according to the SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY website. The FIRST AMENDED COMPLAINT FOR DAMAGES document copy is embedded; named and referenced in the amended complaint, including but not limited to, Mike Calhoun (Chief of Police), Janet Bombard (Director of Library Services and Director of Community Activities), Leticia Livian (Senior Human Resources Analyst), Lori Frontella (City Clerk), Al Fasulo (Code Enforcement Officer), Cleve Waters (Public Works Department), Stu Ross (Public Works employee), Paul Tomasi (Police Officer), Joe Boucher (Police Officer), Ashlee Wright (Library Assistant), Tim Woods (Public Works employee), Tim Meroney (Police Officer), Deanna Allen (Finance Department) and Mayor Jason Burnett.
 WHEREFORE, Ms. Payton prays for judgment against the defendants as follows:
1. For compensatory damages. including lost wages and other lost employment benefits according to proof. on each cause of action;
2. For mental and emotional distress damages on each cause of action;
3. For prejudgment and post-judgment interest. at the legal rate;
4. For an award of attorney fees pursuant to California Government Code Section 12965(b) on each cause of action;
5. For costs of suit incurred;
6. For such other and further relief as the court deems proper and appropriate.
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF MONTEREY
CHILONE PAYTON, Plaintiff, VS. CITY OF CARMEL-BY -THE-SEA, CA, and DOES 1 through 21, inclusive, Defendants.
Case No.: 16CV003820
FIRST AMENDED COMPLAINT FOR DAMAGES FOR:
(1) RACE DISCRIMINATION IN VIOLATION OF FEHA;
(2) HARASSMENT ON THE BASIS OF RACE IN VIOLATION OF FEHA;
(3) SEX DISCRIMINATION IN VIOLATION OF FEHA;
(4) HARASSMENT ON THE BASIS OF SEX IN VIOLATION OF FEHA;
(5) RETALIATION FOR COMPLAINING ABOUT DISCRIMINATION AND HARASSMENT ON THE BASIS OF RACE IN VIOLATION OF FEHA;
(6) RETALIATION FOR COMPLAINING ABOUT DISCRIMINATION AND HARASSMENT ON THE BASIS OF SEX IN VIOLATION OF FEHA; and
(7) FAILURE TO TAKE ALL REASONABLE STEPS NECESSARY TO PREVENT DISCRIMINATION AND HARASSMENT FROM OCCURRING IN VIOLATION OF FEHA.

State Farm General Insurance Company vs City of Carmel-By-The-Sea THIRD AMENDED COMPLAINT FOR DAMAGES 1) Negligence 2) Dangerous Condition of Public Property 3) Inverse Condemnation

ABSTRACT: RE; SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY UNLIMITED CIVIL CASE STATE FARM GENERAL INSURANCE COMPANY, Plaintiff, vs. CITY OF CARMEL-BY-THE-SEA; and DOES 1 through 10, inclusive, Defendants. Case No.:16CV002381 THIRD AMENDED COMPLAINT FOR DAMAGES 1) Negligence 2) Dangerous Condition of Public Property 3) Inverse Condemnation On January 4, 2017, Ashley Stander, Law Offices of Geordan Goebel, Attorneys for Plaintiff, submitted to the Superior Court of California, County of Monterey, THIRD AMENDED COMPLAINT FOR DAMAGES 1) Negligence 2) Dangerous Condition of Public Property 3) Inverse Condemnation. A fourth Conference Case Management and Conference: Trail Setting are scheduled for December 12, 2017, Department 15, according to the SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY website. The THIRD AMENDED COMPLAINT FOR DAMAGES 1) Negligence 2) Dangerous Condition of Public Property 3) Inverse Condemnation document copy is embedded; named, including "City Forester." FIRST CAUSE OF ACTION, NEGLIGENCE [Cal. Gov. Code§§ 815.2, 815.6, 818.6. Municipal Code §17.481 SECOND CAUSE OF ACTION, DANGEROUS CONDITION OF PUBLIC PROPERTY [Cal. Gov. Code§ 835} THIRD CAUSE OF ACTION, INVERSE CONDEMNATION [Cal. Const, art. I,§ 19)
WHEREFORE, plaintiff prays for judgment against the defendants, and each of them as follows:
  1. For the sum of $64,792.40 and for interest thereon at the maximum legal rate from and after November, 2015;
  2. For costs of suit, expert fees and attorneys’ fees incurred therein;
  3. For such other and further relief as this Court may deem just and proper.
16cv002381 Third Amended Complaint for Damages 1-4-2017 by L. A. Paterson on Scribd
SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY
UNLIMITED CIVIL CASE
STATE FARM GENERAL INSURANCE COMPANY, Plaintiff, vs. CITY OF CARMEL-BY-THE-SEA; and DOES 1 through 10, inclusive, Defendants.
Case No.:16CV002381
THIRD AMENDED COMPLAINT FOR DAMAGES
1) Negligence
2) Dangerous Condition of Public Property
3) Inverse Condemnation

State Farm General Insurance Company vs City of Carmel-By-The-Sea: OPPOSITION TO DEMURRER TO THIRD AMENDED COMPLAINT

ABSTRACT: RE: SUPERIOR COURT OF CALIFORNIA COUNTY OF MONTEREY STATE FARM GENERAL INSURANCE COMPANY, Plaintiff, vs. CITY OF CARMEL-BY-THE-SEA; and DOES 1 through 10, inclusive, Defendants. Case No.: 16CV002381 OPPOSITION TO DEMURRER TO THIRD AMENDED COMPLAINT On March 7, 2017, Ashley Stander, Law Offices of Geordan Goebel, Attorneys for Plaintiff, submitted to the Superior Court of California, County of Monterey, OPPOSITION TO DEMURRER TO THIRD AMENDED COMPLAINT. 1. ANY VALIDLY PLED CLAIM DEFEATS A DEMURRER. 2. PLAINTIFFS' THIRD AMENDED COMPLAINT SETS FORTH SUFFICIENT FACTS TO STATE ALL THREE CAUSES OF ACTION. A. The City's Violation of its Own Code Section Proximately Caused the Damages as Allege Herein. B. The City's Exercise of Dominion and Control over Trees within its Limits Prevented Property Owners from Rectifying Dangerous Condition of Property. C. Inverse Condemnation
3. CONCLUSION. The TAC sets forth sufficient facts to establish causes of action against the City. The demurrer should be overrruled.
The OPPOSITION TO DEMURRER TO THIRD AMENDED COMPLAINT document copy is embedded.
SUPERIOR COURT OF CALIFORNIA COUNTY OF MONTEREY
STATE FARM GENERAL INSURANCE COMPANY, Plaintiff, vs. CITY OF CARMEL-BY-THE-SEA; and DOES 1 through 10, inclusive, Defendants.
Case No.: 16CV002381
OPPOSITION TO DEMURRER TO THIRD AMENDED COMPLAINT

State Farm General Insurance Company vs City of Carmel-By-The-Sea: OPPOSITION TO MOTION FOR SANCTIONS

ABSTRACT: RE: SUPERIOR COURT OF CALIFORNIA COUNTY OF MONTEREY

STATE FARM GENERAL INSURANCE COMPANY, Plaintiff, vs. CITY OF CARMEL-BY-THE-SEA; and DOES 1 through I 0, inclusive, Defendants. Case No.: 16CV002381 OPPOSITION TO MOTION FOR SANCTIONS On March 7, 2017, Ashley Stander, Law Offices of Geordan Goebel, Attorneys for Plaintiff, submitted to the Superior Court of California, County of Monterey, OPPOSITION TO MOTION FOR SANCTIONS. 1. STATE FARM'S COMPLAINT IS BASED UPON THE CITY'S VIOLATION OF ITS OWN ORDINANCE. 2. THE CITY'S MOTION FOR SANCTIONS IS FRIVOLOUS AND IN BAD FAITH. 3. CONCLUSION. The City's frivolous sanctions motion should be denied. Plaintiff's complaint is brought in good faith, and is supported by the facts and the law. The OPPOSITION TO MOTION FOR SANCTIONS document copy is embedded.
SUPERIOR COURT OF CALIFORNIA
COUNTY OF MONTEREY
STATE FARM GENERAL INSURANCE COMPANY, Plaintiff, vs. CITY OF CARMEL-BY-THE-SEA; and DOES I through I 0, inclusive, Defendants.
Case No.: 16CV002381
OPPOSITION TO MOTION FOR SANCTIONS

City Administrator Chip Rerig: FRIDAY LETTER, November 17, 2017

FRIDAY LETTER November 17, 2017
TIME TO START HOLIDAY SHOPPING!
FOOD DRIVE
TEEN PHOTO CONTEST
FROM LIGHT BLUE TO DARK BLUE
HOLIDAY MEAL DELIVERY
CITY HALL KITTENS
PUBLIC WORKS NEWS & UPDATES First Flush
Forest Theater Sign
Please Drive Carefully!
What a Mess
Cross Training in Public Works
It's Beginning to Look a Lot Like Christmas
HAPPENING AT SUNSET CENTER & FOREST THEATER
TURKEY DAY SAFETY TIPS
HAPPY THANKSGIVING!!

Thursday, November 16, 2017

Proceeding Number A.12-04-019 ADMINISTRATIVE LAW JUDGES’ RULING MODIFYING OCTOBER 27, 2017 RULING REGARDING CALIFORNIA-AMERICAN WATER COMPANY’S MOTION TO STRIKE TESTIMONY

ABSTRACT: Re: Application of California-American Water Company (U210W) for Approval of the Monterey Peninsula Water Supply Project and Authorization to Recover All Present and Future Costs in Rates, the ADMINISTRATIVE LAW JUDGES’ RULING MODIFYING OCTOBER 27, 2017 RULING REGARDING CALIFORNIA-AMERICAN WATER COMPANY’S MOTION TO STRIKE TESTIMONY document copy is embedded.
FILED 11-13-17
ADMINISTRATIVE LAW JUDGES’ RULING MODIFYING OCTOBER 27, 2017 RULING REGARDING CALIFORNIA-AMERICAN WATER COMPANY’S MOTION TO STRIKE TESTIMONY

GOVERNANCE COMMITTEE FOR THE MONTEREY PENINSULA WATER SUPPLY PROJECT, REGULAR MEETING, AGENDA & MINUTES, November 15, 2017

GOVERNANCE COMMITTEE FOR THE MONTEREY PENINSULA WATER SUPPLY PROJECT
REGULAR MEETING AGENDA PACKET
November 15, 2017