Loading...
HomeMy WebLinkAbout34-Council Office 'cn · OF SAN BERNARDI~.O - REQUF~T FOR COUNCIL AC....'ON " From: Councilman Jack Reilly Subject: Legislative Review Committee Report Dept: Council Office f'""~ Date: November 25, 1987 Synopsis of Previous Council action: o c:; I :">' CJ Recommen<:led motion: ., That minutes of Legislative Review Committee meeting held November 19, 1987 be received and filed. \ t__",_. -"I-. ." . ~~ '~ ,~nature Contact person: Phil l'.rvizo Phone: 384-5208 N/A Supporting data attached: Yes Ward: FUNDING REQUIREMENTS: Amount: Nil'. Source: Finance: Council Notes: 75-0262 Agenda Item N~ ~I , LEGISLATIVE REVIEW COMMITTEE November 19, 1987 ATTENDEES: Councilman Jack Reilly - Chairman; Councilman Michael Maudsley; Councilman Torn Minor; City Attorney - Jim Penman; City Clerk - Shauna Clark; City Administrator - Ray Schweitzer; Police Chief - Donald Burnett; Planning Director - Ann Siracusa; Deputy City Administrator/Development - Jim Richardson; Public Services Director - Manuel Moreno; Police Captain Mike Lewis; Senior Planner - Ed Gundy; Council Execu- tive Assistant - Phil Arvizo, Council Administrative Assis- tant - John Cole; Mayor's Administrative Assistant - Patti Gonzales; ABC - Torn Keasling and Vicky Welch. \} 1. LARGE CITIES' INSURANCE POOL PRESENTATION - BICEP Referred to noon luncheon on December 2l. \ ~ 2. LEWIS - policy. POLICY ON ISSUANCE OF ABC LICENSES - CAPTAIN MIKE The Committee recommended approval of the suggested A legal opinion is to be ready for the next meeting. 3. VENDING ORDINANCE - The Committee referred this to the City Attorney for a full review. The discussion centered around Title 5, the type of limitations that could be placed on this type of operation so that it would remain an upgraded service rather than becoming an unenforceable array of hot dog vendors. 4. GREENBELT STUDY - Item referred to the Fire Commis- sion for their review and recommendation within sixty days. , 5. RISK MANAGEMENT DIVISION FUNCTIONS/ALTERNATIVES- The Committee reviewed the Memorandum of Understanding and recommended several changes. The City Attorney and City Administrator concurred with the changes and will present the MOU to the full Council. 6. ORDINANCE AMENDING MUNICIPAL CODE BY DELETING AND ADOPTING BY REFERENCE CERTAIN PORTIONS PERTAINING TO ENVIRON- MENTAL HEALTH CODE - The Committee referred this item to Mr. Jim Richardson for a full review. He will coordinate with the Water Department and Public Services and provide all necessary information to the Committee. 7. DISCUSSION OF CONFLICT OF INTEREST AS REQUESTED AT COUNCIL MEETING OF NOVEMBER 2, 1987 - The City Attorney presented a memo to the Committee and enough copies for the remaining Council members pertaining to Nature of City Council/City Attorney relationship; Hire of Outside Counsel (attached) . 8. SURVEY OF NO SMOKING ORDINANCE The Committee received a survey from Mr. Fred Wilson (survey attached). Meeting adjourned. ~e tfully s itted, ,~/e~~ /' ouncilman Jac illy " Cha i rman Legislative Re iew Committee JR:ej I CITY OF SAN BE~NARDINO - MEMORANDIJ'M ,~r " To Legislation Review Committee Mayor and Common Council NATURE OF CITY COUNCIL/CITY ATTORNEY RELATIONSHIP; HIRE OF OUTSIDE COUNSEL From JAMES F. PENMAN" City Attorney' - November 17, 1987- Su bject Date Approved Date " ... the attorney does not represent you, he represents the City of San Bernardino, therefore the information you gave him was not confidential. It is for this reason that'your complaint file is being closed." May 18, 1987 letter from The State Bar of California to then - Councilman Jack Strickler, (copy attached marked Exhibit A) . In early 1987, Councilman Jack Strickler filed a complaint with the State Bar against Senior Assistant City Attorney Alan Briggs. Attorney Briggs had prepared a legal opinion citing a conflict of interest on the part of Strickler. Brigg's opinion was released to the press. The reply from the State Bar to Strickler's complaint correctly states the role of the City Attorney and the unique situation with respect to the relationship between City Council members and the City Attorney and his deputies. In addition, the California State Govern~e~t Code provides that: "In any case in which a district attorney could act as the civil or criminal prosecutor under the pro- visions of this title, the ELECTED CITY ATTORNEY OF ANY CHARTER CITY may act as the civil or criminal pro- secutor with respect to any violations of this title occurring within the city" (emphasis added). Government Code Section 91001.5. This section makes it obvious that the traditional attorney- client relationship is not present between individual Council members and the City Attorney's office on conflict of interest matters. Nor is there any authority for the City to provide attorneys for Council members or the Council in such matters. As stated in the attached opinions, however, there is ample authority to the contrary. The law on the matter of the Council's ability to retain outside counsel was determined in the 1890's and has continued without change to the present day. HOUSE vs. LOS ANGELES COUNTY (1894) 104 C 73, 78; MERRIA!oI vs. BARNUM (1897) 116 C 6l9; ~.. ., .......... -, LEGISLATION REVIEW CO~~ITTEE MAYOR AND COMMON COUNCIL Page 2 November 17, 1987 MERCED COUNTY vs. COOK, (1898) 120 C 275; DENMAN vs. WEBSTER (1903) 139 C 452; DADMORE vs. CITY OF SAN DIEGO; (1908) 9 Cal. Rptr. 549; RAFAEL vs. BOYLE (1916), 31C.A. 623; JOYNER vs. STOCKTON (1961) 14 Cal. Rptr. 49, 54; MONTGOMERY vs. SUPERIOR COURT (1975) 46 C.A. 3d 657. In the case of RAFAEL vs. BOYLE (1916) 31 C.A. 623, the City Attorney of the City of San Francisco gave certain legal advice to the City's Civil Service Commission. The Commission ignored the advice. The Commission was then sued because of their actions. The Commission refused to accept representation in the case from the City Attorney and HIRED OUTSIDE COUNSEL. THE COURT HELD THAT THE COMMISSION DID NOT HAVE THE AUTHORITY TO HIRE OUTSIDE COUNSEL AND ACTED ILLEGALLY IN DOING SO. The basis for the long standing rule is found in HOUSE vs. LOS ANGELES COUNTY (1894) 104 C 73, 78: "whatever duties are imposed on officers by law must be personally discharged by them and the City cannot relieve its officers from discharging their regular duties by con- tracting with other persons to perform them", and in JOYNER vs. STOCKTON (1961) 14 Cal. Rptr. 49, 54: "The law will not indulge an implication that a public agency has authority to spend public funds which it does not need to spend; that it has authority to pay for services which it may obtain without payment; OR THAT IT MAY DUPLICATE AN EXPENDITURE FOR SERVICES WHICH THE TAXPAYERS HAVE ALREADY PROVIDED" (emphasis added). The taxpayers have provided two sources of legal advice to Council members for conflict of interest opinions, the City Attorney's Office (San Bernardino City Charter Section 55(d)), and the Fair Political Practices Commission (California Government Code Section 84ll4(a) and (b)). The fact that these opinions may be made public and the desire of a fe' Council members to receive secret advice is irrelevant. An exhaustive search of statutes and cases fails to reveal a s~ngle statute or case that entitles elected officials to obtain at publ~c expense, secret or confidential advice on conflict of interest issues in a charter city with an elected city attorney. San Bernardino Municipal Code Section 2.20.070 while prohibiting the tire of outside counsel without the City Attorney first making "'. "'- ,.J -- LEGISLATION REVIEW COMMITTEE MAYOR AND CO~~ON COUNCIL Page 3 ,-,,' Nove~ber 17, 1987 a determination that it is necessary, recognizes that city officers may encounter situations wherein thpj need legal advice that the taxpayers are not required to provide. To allow for this contin- gency the code states: " ... nothing herein shall preclude any city officer from obtaining outside legal services AT HIS OR HER OWN EXPENSE concerning the personal or public rights, duties, privileges or benefits of such officer as an individual or as an office holder or from obtaining AT HIS OR HER OWN EXPENSE legal services of a private nature" (emphasis added). Section 2.20.070 San Bernardino Municipal Code Attached are legal opinions 87-59 and 87-36, marked Exhibit B and Exhibit C, respectively, on this subject. These opinions pro- vide greater detail on the cases cited herein as well as additional authority. City officers, including elected officials, are advised that it is unlawful to hire outside attorneys unless the City Attorney is unable or unwilling to perform a duty or cuties required of him by the Charter. Individual city officers are subject to court orders to personally reimburse the City fer public funds paid to attorneys unlaWfully hired by, or whose hl=ing is unlawfully approved by, said officers. Respectfully submitted, ...-. , ~. ;.#, .., ... -,....~-,.:................. JAMES F. PENMAN City Attorney JFP:dd :~~ .,. -~~~ .,! ,,~ , ~ . , ' ....~ I THE STATE BAR OF CALIFO&.HA OFFICE OF I:-iVESTIG))J~S '.>' ,'>~"7" ~!-,IR~:lTREf.T ;.J5 ,,'CELF:, ('4.LlFUR'I'~lt' _i! ~ay 18. 1987 Jack Strickler City Hall 300 ~. "D" Street Sa~ E~rnardino. CA 92418 Re: SR 86-0206 Dear ~r. Strickler: During our recent telephone conversation, I advised you that the attorney does not represent you, he represents the City of San Bernardino, therefore the information you gave him was not confidential. It is for this reason that your complaint file is being closed. If you are not satisfied with t~~ State Bar's decision to close your complaint, yc_ ~ay request a review of our decision. Your req~';~, which must be submitted in writing, will be cO~c_1ered by the Complainant's Grievance Panel. Your written request should be d~rected to the Administrative Compliance Vnit, Office of Investiga- ti~~s, State Bar of California 1230 K~3t Third Street, ~os A~geles, California 90017. ~ery tr~ly ~ours, ---- - ~ ....,a^J2_()rfo) Q.~ Karen Ortolani Special Investigator KO:dr ,/ -.J I::XHIBrT B /....... .....) , ".~"" CITY OF SAN BERNARDINO JOO NORTH "0" STReeT, SAN SERNARDINO, CAliFORNIA 92.,S ~ ':'\1ES F. PENMAN :iTV ATTORNEY ."" JU.5J55 ~ovember 17, 1987 Opinion ~o. 87-59 10.37 JAMES F. PENMAN City Attorney Re: Power of Council to Employ Outside Attorneys ISSUE The issue has been raised as to whether the Mayor.and Common, Coincil may employ outside attorneys at public expense to perform duties which the City Attorney would normally perform and which he stands ready, willing and ab~= to discharge. A~ALYSIS The duties of the City Attorney are set f::th in Section 55(d) of the Charter of the City of San Bernard~~o. As last amended on April l3, 1971, this subsection reads as follows: "(d) The City Attorney shall be the chief legal officer of the City; he shall :epresent and ~dvise the Mayor and Common Cou~:il and all City officers in all matters of law ?ertaining to their offices; he shall represen: and appear for the City in all legal ac::ons brought by or against the City, and 'rosecute violations of City ordinances, he s 111 also act and appear as attorney for any ~"ty officer or employee who is a party to any l~~al action in his official capacity; he shall ;~tend ~eetings of the City Council, draft ?roposed ordinances and resolutions, give hi= advice or opinion in writing when requestej to do so in writing by the Mayor or Common Councilor other City official upon any matter pertaining to ~unicipal affairs; and otherwise to do and perform ail services incident to hi3 position and required by statute, this Charter or general law." /~.., /"" J ) ",-,,' James F. Penrr.an November 17, 1987 page Two It is important to note that throughout this section the mandatory "shall" is used. In addition, Section 241 of the Charter provides: "The Mayor and Common Council shall have power and authority to employ and engage such legal counsel and services and other assistants, as may be necessary and proper for the interest and benefit of the City and the inhabitants thereof." The question then becomes, what Charter sections to each other? as follows: is the relation of these two The general rule can be stated "Whatever duties are imposed on officers by law must be personally discharged by them and the City cannot relieve its officers from discharging their regular duties by contracting by ordinance or otherwise with other persons to perform part or all of them." (2 ~1cQuillin, Municipal Corporations, 3d Ed. Rev., Section 10.38, pg. 840; see also 52 Cal.Jur.III "Public Officers, etc." Section 57 :~d House v. Los Angeles Countv (1894) 104 C '3. 78.) Nationally, with reference to legal officers the cases are mixed. However, it seems very clear that :he decisions turn on the individual charter or statute involved. "It has in numerous cases been deci~!d that where the corporation has regular c:~nsel, charged with the duty of conducting 111 the law business in which the corporati,~ is interested, contracts for additiona, or extra legal services are unauthorized. T.:is role has frequently been applied to the ~~gagements of attorneys by municipal boards, co~missions, departments, or officials, for the ~erformance of services within the proper sphere of activity of the city attorney, or c:ty law department." (10 McQuillin, Munici~al Corporat!9D?, 3d Ed. Rev., Section 29.12, pgs. 244-245.) ~/ -, J j James F. Penman November 17, 1987 Page Three In the case of Denman v. Webster(1903) 139 C 452, the California Supreme Court considered the claim for compensation for legal services provided by Attorney Denman allegedly on behalf of the San Francisco Board of Education. The underlying question involved which individual had a right to a seat on the Board. The Court concluded that the question as to who had a right to the seat was not a public question but a private one and, as a result, the Board did not have the authority to use public funds to employ counsel for this purpose.' Since the Charter of the City and County of San Francisco imposed on the City Attorney the obligation to represent the Board of Education, Justice Shaw, in a concurring opinion, stated: "If the law provides an attorney upon whom the board may call when a defense to any suit is necessary, it cannot ignore this provision and put the district to the expense of paying some other attorney for services which it is the duty of the attorney thus provided to perform." (at page 456) In Dadmore v._~~Y-Qf San Dieoo (1908) 9'11.App. 549, the City, by ordinance, created the office of o~ecial Prosecutor and appointed Attorney Dadmore to that pc ~tion. After performing the specified duties, he sougt: payment and was refused. The court reviewed the charter ~:ovision in question which authorized the city council to "employ other attorneys to take charge of any such litigation, or to assist, the city attorney therein." The court stated: " . . . under the charter of the Ci:~ of San Siego the City Council cannot r~lieve a Charter officer of the city from :~e duties devolving upon him by the cr .ter and designate another to perform su duties." (at page 551) The court concluded that the authority in :he charter provlslon did not authorize the employment of outsi~? counsel to perform prosecutorial cuties. In ~~~?~D_~OYn~Y_Y~ Shinn (1891) 88 C 510, the Supreme Court in considering an old statutory provision re:1ting to the power of boards of supervisors in general law counties concluded that such boards have the authority to hire outside counsel. But even here the court noted that such authority rested upon the ground: /'~.."." "--' , '-" ...I James F. Penman November 17, 1987 Page Four " . . . that the district attorney may be incompetent, or sick, or absent from the county, or engaged in other business, so that he cannot attend to it, or the business to be transacted may be outside of the county." (at page 512) Following action by the legislature in amending the subject provision relied upon in Lassen, the Supreme Court once again considered the issue in Merced COYD~Y_Y~_~QQ~ (1898) 120 C 275: "There is no doubt that the enactment of this amendment [limiting the power of boards of supervisors to hire outside counsell was occasioned by the somewhat common and indiscriminate action indulged in by boards of supervisors of hiring outside attorneys to conduct county litigation. There can be no question but that the district attorney of the county is the officer authorized by law to take charge of and conduc: such litigation. He is an officer of t~~ county elected by the people for that pur~:se and no board of supervisors had (sic) the 'rbitrary power to displace him in the conduc: of its litigation and substitute other attorneys. . . . If the board of superivsors could portion out the legal business of the county as appertaining to license matters to cuts ide attorneys, it could likewise apport:~n to such attorneys all other branches or legal business in which the county was directly in:arested, and thus relieve and deprive the di~trict attorney of the very labors which a:~ devolved upon him by the law, and which he w 3 elected by the people to perform, and which un_=r his oath of office he is bound to perfo,~" (at page 277-278) In the case of ~~IIi~m_Y. Barnum (1897) l15 C 6l9, the Supre~e Court rejected an agreement to employ outside counsel to give legal advice to the Fresno County Board of Supervisors since the court concluded that such responsibil"ties were included within the duties of the District Attorney. " In the case of Rafael v~_~QY1~ (l9l6) 3l C.A. 623, the City Attorney of the City of San Francisco gave certain legal advice to the City's Civil Service Commission, w~ich advice was ~ ~ ,/ ~. ~ j James F. Penman November 17, 1987 Page Five ignored. Thereupon, the Commission was sued on the basis of those actions. The City Attorney offered to defend the suit but the offer was rejected and the Commission hired outside counsel. The court concluded that such employment was outside the authority of the Charter and therefore illegal. In MontgomerY-Y~~Y~rior_~9Y~ (l975) 46 Cal.App~3d 657 a general law city took action to relieve its contract city attorney of the responsibility of prosecuting certain other violations, with the attorney's concurrence. The court, in considering this question, concluded: "Several authorities hold that a public body may not validly . . . [employ outside personnel for special services] where a regular officer or employee thereof is obligated by law to perform such services (citations ommitted) and is willing and able to do so as part of the ordinary professional functions of his position (citations omitted). "Although this proscription applie: to a chartered city whose charter impose~ upon one of its regular city officers tt, duty to perform the services in questio~ (citation omitted), it does not ap~~j to preclude a general law city from employing special counsel to perform prosecutorial duties where it has di~ested its regular city attorney of such d~~ies." (at page 668-669) When read in light of the foregoing law, t~! Charter provisions of the City of San Bernardino first quotec ~Iean that the City Attorney of the City of San Bernardino has the responsibility and must provide all the legal responsibil ties of the City. However, upon his request, the Mayor and C_~mon Council may employ attorneys to assist him in that dut_ both in-house and outside. This may occur when there is mor: work than he can do, when the work is beyond his expertise (such as bond coun3el~, or when he is legally disqualifi2d. But the Mayor and Council may not employ independent leg31 assistance when the City Attorney is ready, willing and ab.e to provide the service. This rule has been codified in San Bernaroino Municipal Code Chapter 2.20 although it is clearly the 13~ even in the absence of this provision. Section 2.20.020 requl~es the City Attorney , ,",.,,/ "-'" James F. Penman November 17, 1987 Page Six to coordinate all legal services for the City. Section 2.20.030 requires all requests for legal servies to be directed to the City Attorney. Of special significance are the provisions of Sections 2.02.040 and 2.20.070. These sections set forth the procedures and conditions for the employment of special or outside counsel. Section 2.20.040 provides as follows: "Special counsel shall be retained by the Council pursuant to Charter Section 241 subject to the recommendation of the City Attorney that such counsel is necessary in instances when legal specialization not possessed by the City Attorney is required or when the City Attorney is unable or disqualified from performing such legal services. Special counsel shall not be retained when the City Attorney is willing and able to perform the legal services as a part of the, ordinary professional functions of his or her office. The City Attorney shall advise the Mayor and Common Council as to the experience and qualifications of attorneys con:idered for retention as special counsel." Section 2.20.070 states: "Any City officer desiring legal services concerning City business from legal counsel other than the City Attorney shall first i~form the City Attorney of such intended reqwest for outside legal services to determine whether ~he City Attorney is willing and able to pro~ide such services. No City officer shall be ,uthorized to obligate the City for payment of ~ervices of outside counsel without the express )pproval of the Council. No City officer shall Jtilize outside legal services concerning City busi,~ss without the approval of the City Attorney 0, Council; provided, however, that nothing herein shall preclude any City officer from obta:~ing outside legal services at his or her own ex~ense concerning the personal or public rights, duties, privileges or benefits of such officer as an i~jividual or as an office holder, or from obtaining at his or her own expense legal services of a private nature." r",",,- , v . " , ......./ James F. Penman November 17, 1987 Page Seven CONCLUSION The Mayor and Common Council may not employ outside attorneys at public expense over the objection of the City Attorney to provide the services that he is ready, willing and able to provide and which is his duty as the elected City Attorney under the Charter of the City of San Bernardino. Respectfully submitted, ARLOW City Attorney DAB:cm cc: Mayor City Administrator City Clerk .... - ~'\~'J ~, ......~, " .. '.'., . , .... ,. . - .. . CITY OF SAN BERNARDINO VEXHIBIT C '_..'. "- .'"-...) .I 300 NORTH "0" STREET, SAN BERNARDINO. CALIFORNIA 92418 , - . JAVes F, PENMAN C;"T'V ATTORNEY 'i'", 38".5J55 June 30, 1987 Oon No. 87-36 10.37 700.1 Honorable Mayor and Common Council Re: City Council, Power to Retain Counsel QUESTION Can the Mayor and Common Council retain outside counsel? If the answer is in the affirmative, must the Mayor and Common Council first obtain the approval of the City Attorney before retaining outside counsel? ANALYSIS The question centers on the interpretation f two Charter sections which seem to conflict. Charter 5:ction 55(d) provides: "The City Attorney shall be the chief legal officer of the City; he shall ,~?resent and advise the Mayor and Common Counc~l and all Citv officers in all matters of ~:w pertaining to their offices; he shal~ represent and appear for the City in all legal,ctions 6rought by or against the City . . . (Emphasis added) Charter Section 241 authorizes the Mayor ar.. ComJ;\on Council to employ legal counsel: "Employment of legal counsel. The Mayor and Common Council shall have the pOh~r and authority to employ and engage such :~gal counsel and services and other assistants, as may be necessary and proper for the interes~ and benefit of the City and the inhabitants thereof." ('f' , ) . " ~'" ....... Mayor and Common June 30, 1987 page Two "-' Council ---/ " ) The courts characterize the seeming conflict between Sections 55(d) and 241 as a question of a public agency's authority to contract for special services where a regular officer or employee of the agency is obligated by law to perform such special services. The rule is: "Two sections of the Government Code . . expressly authorize a general law city, and other public agencies, to employ and compensate personnel for the performance of 'special services. I . . . a public body may not validlY do this where a reqular officer or employee thereof is obliqated bv law to perform such services (citations) and is willinq and able to do so as part of the ordinary professional functions of his position. "[TJhis proscription applies to a chartered city whose charter imposes upon one of its regular officers, the duty to perform the services in question . . . " Montqomery v. Supreme Court, County of Solano (1975) 46 Cal.App.3d 657, 668, 121 Cal.Rptr. 44) (Emphasis added) When this rule and the general rules for t. ! interpretation of Charter provisions are applied, Charter Se :ions 55(d) and 241 are not in conflict. The applicable rules of Charter interpretation are: "All provisions relating to th2 same subject must be construed together s: as to harmonize with each other. If two ar)arently conflicting sections can fairly be g_len an operative effect through a different construction, that construction will be given to a ,id the conflict. . . R (45 Ca1.Jur.3d, Mu. _cipalities Sec. 59) The two sections harmonize where the Mayor nd Common Council's authority Rto employ such legal counsel. . . may be necessary . . . R is read to make the Mayor and Commc:1 Council's authority to hire contingent on a finding o:~. The ~ test is the one stated in the Montqomery ca,e. The Mayor and Common Council must find that there is no :2gular officer of the City required by law to perform the service or that the officer is disqualified or not willing or able to provide the legal service as part of the ordinary professional function of his position. When construed in this way, :he apparent conflict between Charter Sections 241 and co(d) is resolved. ,: . . , ' Mayor and Common Coun~ June 30, 1987 Page Three ~.. ,/ " San Bernardino Municipal Code Chapter 2.20 is a specific expression of the Montaomery rule as it applies to the City Attorney. San Bernardino Municipal Code Section 2.20.070 provides: "Any City officer desiring legal services concerning City business from legal counsel other than the City Attorney shall first . . . det:rmine whether the City Attorney is willinQ and abl_ to provide such services . . . No City office~ shall utilize outside legal services concerning the City business without the approval of the City Attorney or Council . . . " (Emphasis added) In the absence of San Bernardino Municipal Code Chapter 2.20, the Charter mandates the basic relationship expressed in that section. Addressing the issue in another context, the courts have given an insight into the policy reasons behind the rule let out in Montcomerv: "The law will not indulge an implication that a public agency has authority to spend public funds which it does not need to spend~ that it has authority to pay for services which. . may obtain without payment; or that it may dupl. 3te an expenditure for services which the taxpayers have 31ready provided." Joyner v. Stockton (1961) 14 Cal.Rpt. 49, 54. CONCLUSION The Mayor and Common Council may retain outz je counsel, but they must first obtain a determination from he City Attorney that he or she is either unwilling or unabl€ to perform the desired service. Respectfull submitted, 1;, -~ I(./,{ ,( - I -10HN F. WIL. lN Deputy City ~ttorney JFW:ca cc: City Administrator City Cleck Concur: -,' .-a '...... / ~ 1"1r--~ ,',/ City Attorney