HomeMy WebLinkAbout23- Adminstrator's Office CITY OF SAN BERNARDINO - REQUEST FOR COUNCIL ACTION
From: Fred Wilson, City Administrator Subject: Authorization to execute subpoenas
for production of business records
Dept: Administrator's Offi-- relative to an audit of utility
[P LI users taxes.
O
Date: January 5, 1999 O
Synopsis of Previous Council
3/20/95 Mayor and Common Council authorized execution of subpoenas for the utility company
business records of Southern California Gas, Southern California Edison,Pacific Bell and
General Telephone for the purpose of conducting an audit of Service Users Taxes (utility
users taxes).
Recommended Motion:
That the Mayor be authorized to execute the attached subpoenas for the production of business
records at Southern California Edison Company and AT&T for the purpose of conducting an audit
of utility users taxes.
Cy_
Signature
Contact person: Fred Wilson Phone 5122
Supporting data attached: Yes Ward:
FUNDING REQUIREMENTS: Amount:
Source:(Acct. No.)
(Acct Description)
Finance:
Council Notes:
Agenda Item No.
CITY OF SAN BERNARDINO REQUEST FOR COUNCIL ACTION
STAFF REPORT
SUBJECT:
Authorization to execute a subpoena for production of business
records by the Southern California Edison Company and AT&T in order
for the City of San Bernardino to perform an audit of the City' s
utility user tax revenue received from Southern California Edison
Company and. AT&T.
BACKGROUND:
Over the last several months, the City of San Bernardino has
experienced a significant decline in its electric utility user tax
revenues . The main factors identified as the cause of this decline
are the 10% mandated reduction in electric bills, the City' s . 5%s
rate reduction of the utility user tax, the introduction of new
electric marketers known as ESP' s (Energy Service Providers) , and
milder temperatures .
Based on the factors above, an approximate $940, 000 decline in the
utility user tax revenue was included in the FY 1998-99 adopted
budget . However, the actual utility user tax revenue collected
during the months of July - November has been less than what was
anticipated in the budget .
Due to the complexity of collecting the utility user tax and the
factors discussed above that have significantly impacted the City' s
utility user tax revenue, staff has determined that the best course
of action is to begin to audit the electric ESP' s. Since Edison is
still the largest ESP, the City is going to begin the audit process
with them and then move on to all the other ESP' s.
In order to gain access to the needed records at Edison, Edison
requires the City to issue a subpoena. This arrangement has
already been agreed to by Edison and this is the same process that
was followed approximately 4 years ago when the City first audited
Edison.
In addition, a subpoena is also being requested for AT&T so the
City can perform an audit of their utility user tax process.
Although the City has not experienced any utility user tax revenue
short fall from AT&T, we have never audited AT&T. Staff recommends
auditing AT&T as part of the City' s on-going monitoring of the
utility user tax revenue. AT&T has agreed to the audit and like
Edison, they also require a subpoena before releasing any records
to the City.
ANALYSIS:
The City of San Bernardino has an on going agreement with Municipal
Resource Consultants (MRC) to help monitor and audit the City' s
major revenue sources (sales tax and utility user tax) . The
agreement between the City and MRC was originally authorized in
1987 and has been amended and updated several times since the
inception. Under the terms of the current agreement, MRC will
perform the audits on Edison and AT&T. MRC will be compensated 259S
for 12 quarters for errors detected on Edison' s and AT&T' s part
that are corrected and result in additional revenue to the City.
Due to the complexity of the utility user tax audits, the amount of
staff time .needed to perform the audits, and the location of the
vendor' s records, it is not feasible to perform these audits with
in-house staff . It is for this reason that we contract this work
out to MRC.
Staff has negotiated a reduced rate range with MRC of 15%-25t for
12 quarters to audit other ESP' s when the Edison audit is
completed. The reduced rate would be applied and paid to MRC on
the ESP' s that the City has made compliance and audit efforts with.
Only if MRC has to perform an on-site audit of those ESP' s, will
MRC be paid the full 25 96 for 12 quarters .
Starting in February 1998, (prior to when the electric deregulation
1 began) , staff sent out approximately 260 letters to all new ESP' s
registered with the PUC (Public Utilities Commission) . This letter
introduced the City of San Bernardino to the new ESP' s and informed
them of the City' s utility user tax rate (a copy of the City' s
utility user tax ordinance was included with the letter) .
Staff also obtained a list from Edison of all customers that had
moved to other ESP' s . Based on this list, staff sent out letters
to some of the larger businesses requesting their assistance in
confirming that their new ESP was charging the City' s utility user
tax correctly (see Attachment I) . Very helpful information was
obtained from businesses that cooperated.
Staff also sent out additional letters to ESP' s when their utility
user tax revenues sent to the City did not appear to be correct
based on known customers that had moved to their company (see
Attachment II) . In addition to the above letters, staff also made
some follow up phone calls. Again very helpful information was
obtained from some of the ESP' s that cooperated.
Because the staff work discussed above and the information that was
obtained will be helpful to MRC, a reduced audit rate was able to
be negotiated with MRC for the ESP audits . As MRC continues with
the audits of the various ESP' s, the City may have to issue
additional subpoenas .
FINANCIAL IMPACT•
The FY 1998-99 adopted budget includes funds to pay MRC their
contract fees and anticipated revenues they will find. As the
above audits progress, if there are any amendments to the budget
that are required under the City' s budget amendment policy, staff
will bring them back to the Mayor and Council for approval .
RECOMMENDATION:
That the Mayor be authorized to execute the subpoenas to Southern
California Edison Company and AT&T.
C I T Y O F
5an Bernardino
rDED t� �
O F F I C R OF T H R C I T Y A D M I N I S T R A T O R
F R E D A W I L S O N
C I T Y A 0 Y I N 1 ! r R A T O R
October 20, 1998
San Bernardino, CA 92408
Attn: Manager
Dear Sir or Madam:
As you are aware, the electrical industry has begun the process of deregulation. With deregulation comes the
ability for businesses like yours to make a choice as to who will provide your energy needs. Southern
California Edison has provided the City of San Bernardino with a listing of all accounts that have moved
from Edison to other energy service providers(ESP). According to Edison, your business is one that has
transferred to another ESP.
I am writing to ask your assistance in confirming that your ESP is charging the City's Utility User Tax
(Uli 1-) on your monthly electric bill. In February 1998, the City's Finance Director sent out a letter to all
energy service providers advising them of the City of San Bernardino's local requirements relative to
collecting a Utility User Tax. With your assistance, the City can verify that ESP's are complying with the
City's policies and verify that all businesses are being treated equally.
The UUT is a critical revenue to our City and is used to cover the costs of many basic services including
Police, Fire, Parks, and Street Maintenance.
I would appreciate your business providing the City with a copy of your latest electric bill so we can verify
that the ESP is charging UUT in accordance with City codes. Please be assured this information will be kept
confidential and the City's only interest in the electric bill is the City's UUT. If you have any questions, you
can call Barbara Pachon at (909) 384-5242 or me at(909) 3845122. Your invoice can also be sent directly
to Barbara Pachon at City Hall, 300 N. "D" Street, San Bernardino, CA 92418.
i would like to sincerely thank you for all your time and effort in helping us. Together we can make the city
of San Bernardino a better place!
Sincerely,
`Fred Wilson
City Administrator
] 0 0 N O R T N 0 T N R I 1 T A N R 1 R N A R 0 1 N O -
C A L I F 9 ] • 1 R - 0 0 0 1 ( 0 0 * 1 ] 0 4. f 1 2 ] • F A I ( 9 0 9 1 11 R 4- 5 0 9 1
FRSARI),
- C I T Y O F
5an Pernardino
E�DfD i`rA
O F F I C E O F T N S C I T Y A 0 N I N I O T R A T O R
F R E D A . W I L S O N
C I T Y A 0 Y 1 N 1 ! T R A T O R
October 13, :998
Dear
In February 1998, the City of San Bernardino sent you a letter to advise you of the City's local
requirements regarding our Utility Users Tax(UUT)in the event that you conduct business within the
city.
Southern California Edison has provided the City of San Bernardino with a listing of all accounts
(residential and commercial)that have moved to other energy service providers(ESP). According to
Edison, there arc a number of accounts that have transferred to your company.
In reviewing our Utility Users Tax revenue,it appears to us that the City of San Bernardino is not
receiving the proper amount of revenue from your company. Please review all accounts you have in
the city of San Bernardino and verify that your company is charging,collecting and remitting the
proper UUT amount to the City of San Bernardino.
I would like to reques±that you send a listing of all accounts your company currently has in the city of
San Bernardino and the effective date of their service with you so it can be verified with our records.
If this information is not provided to us,the City will consider performing an audit of your records to
determine compliance with the UUT ordinance which is authorized under Section 3.44.120 of the
City's Municipal Code.
This information should be submitted to my office no later than November 2, 1998.
For easy reference, I have attached another copy of the City's UUT ordinance and an administrative
interpretation of the term"electricity." If you have any questions regarding the City's UUT,please
contact Ms. Barbara Pachon, Finance Director,at(909)384-5242.
S' y
N
O
City Administrator
FAW/md
Cc: Barbara Pachon.Finance Director
0 0 0 N O R T H . 0 S T R E E T S A N a E R N A R 0 1 N 0 .
C A L I F 9 2 4 1 • . 0 0 0 1 It 0 0) 1 A 1 . S 1 1 0 • PA a ( 0 0 9) S O A• 0 0 0 T
I '
MUNICIPAL RESOURCE CONSULTANTS
DATA ELEMENT SPECIFICATIONS
DISKETTE RECORDS:
Diskettes can be either 5 1/4" or 3 1/2" in size
DBF files are preferred,however any DOS compatible file format is acceptable
MAGNETIC TAPE RECORDS:
RECORDING MODE: 1/2' 9 track(6262 BPI or 1600 BPI)tape or IBM 3480/3490 cartridge,
recorded in EBCDIC or ASCII(ASCII is preferred)
DENSITY:Either 6250 BPI or 1600 BPI is acceptable(6250 BPI is preferred)
INTERNAL LABELS: Labels are optional;however,unlabeled tapes are preferred. If labels are provided,we don
not require any specific information placed in the label records
TAPE MARKS: There must always be at least one tape mark following the last data block.If internal labels are
provided,a tape mark must be placed between the last header block and the first data block. If internal label records
are not provided,a tape mark must not precede the first data block
RECORD LENGTH: Written fixed length,NOT variable length
FIELD SPECIFICATIONS: All fields should be fixed length;unpacked,and unsigned(when possible)
BLOCKING FACTOR: No more than 9000 characters per block is preferred. Block size must be an even
increment of the record size utilized.Example(Record size 300)x(10 records)=Block size of 3000
SUPPORTIVE DOCUMENTATION
A list of any codes and their associated description is requested for all files supplied.If these codes are maintained
electronically,please supply them as part of entire package(i.e.,send them as separate files using the same media
A file layout is requested for all file format types other than DBF. Layout to include the field name,field length,
and field type(i.e.,character,numeric,date,etc.)
Include file name,record count,block size and record length on an external tape label
MUNICIPAL RESOURCE CONSULTANTS
DATA ELEMENT SPECIFICATIONS
DISKETTE RECORDS:
Diskettes-cart be either 5 1/4" or 3 1/2" in size
DBF files are preferred,however any DOS compatible file format is acceptable
MAGNETIC TAPE RECORDS:
RECORDING MODE: 1/2'9 track(6262 BPI or 1600 BPI)tape or IBM 3480/3490 cartridge,
recorded in EBCDIC or ASCII(ASCII is preferred)
DENSITY:Either 6250 BPI or 1600 BPI is acceptable(6250 BPI is preferred)
INTERNAL LABELS: Labels are optional;however,unlabeled tapes are preferred. If labels are provided,we don
not require any specific information placed in the label records
TAPE MARKS: There must always be at least one tape mark following the last data block.If internal labels are
provided,a tape mark must be placed between the last header block and the first data block. If internal label records
are not provided,a tape mark must not precede the first data block
RECORD LENGTH: Written fixed length,NOT variable length
FIELD SPECIFICATIONS: All fields should be fixed length;unpacked,and unsigned(when possible)
BLOCKING FACTOR: No more than 9000 characters per block is preferred. Block size must be an even
increment of the record size utilized.Example(Record size 300)x(10 records)=Block size of 3000
SUPPORTIVE DOCUMENTATION
A list of any codes and their associated description is requested for all files supplied.If these codes are maintained
electronically,please supply them as part of entire package(i.e.,send them as separate files using the same media
A file layout is requested for all file format types other than DBF. Layout to include the field name, field length,
and field type(i.e.,character,numeric,date,etc.)
Include file name,record count,block size and record length on an external tape label
Meeting Date: 01/11/1999 - -
Item #23 LAW OFFICE
No Resolution Number DONALD H. MAYNOR
P PROF2951OCA ORWE�T�ON
ATHERTON,CA 94027
(650)327-2894
FACSIMILE
771 ' r A (650)327-264
4
E-MAIL:tlhmaynor�wrCnet
.at.net O P
February 9, 1999
Mr. Fr @d Wilson'
Asst. City Administrator
CITY OF SAN BERNARDINO
300 North D Street
San Bernardino CA 92418
RE: Nondisclosure and Protective Agreement
s
Dear Mr. Wilson:
Enclosed is a copy of the fully executed above-referenced document for your records.
Sincerely, _
G Z/,`
Lisa M. Montelius
Assistant to Donald H. Maynor
enclosure
tbm:LMM
Q O 1 LJ NoeResoluution Number/1999
NONDISCLOSURE AND PROTECTIVE AGREEMENT
THIS NONDISCLOSURE AND PROTECTIVE AGREEMENT ("Agreement"), effective
when executed by the parties, is made by and among AT&T ("AT&T"), with an address for
purposes of this Agreement of 412 Mt. Kemble Avenue, Morristown, NJ 07960, the City of San
Bernardino ("City"), with an address for the purposes of this Agreement of 300 North "D" Street,
San Bernardino, CA 92418, and Municipal Resource Consultants ("MRC"), a partnership, with
an address for the purposes of this Agreement of 32107 West Lindero Canyon Road, Suite 233,
Westlake Village, CA 91361, and its technical advisers, Donald H. Maynor of 235 Catalpa Drive,
Atherton, CA 94027, and Lome Bernstein of Moss Adams, LLP, 1899 March Lane, Suite F,
Stockton CA, 95207-6422 (collectively, 'Recipients") to protect the confidential or proprietary
nature of information to be disclosed by AT&T to Recipients, or either of them, pursuant to that
certain SUBPENA For Production of Business Records (Govt. Code § 37104 et seq.) issued by
the City to AT&T on , 1998 ("Subpena"), and any supplemental subpoenas issued
thereafter but within twenty-four(24) months of said date.
ACCORDINGLY, the parties hereto and their counsel agree that the following terms and
conditions shall govern the use of Confidential Information provided to Recipients, or either of
them, in accordance with any Request:
1. "Confidential Information" as used herein means any information described in Revenue
and Tax Code § 7284.6 and 7284.7, including any information that is in written, oral or
other tangible or intangible form. Such information may include but is not limited to,
ideas, concepts, know-how, models, diagrams, Flowcharts, data, computer programs,
marketing plans, business plans, customer names, customer account numbers,
customer billing information, customer demographic information and other technical,
financial, customer or business information, which is designated as "confidential' or
"proprietary" by Company in the belief that it contains a trade secret or other confidential
research, development, customer, commercial or financial information. Documents
containing Confidential Information and all copies thereof shall remain the property of
Company, and all copies thereof shall be returned to counsel for Company as set forth
hereinbelow.
2. This Agreement governs all Confidential Information whether produced, revealed or
disclosed to Recipients by Company.
3. Recipients, and each of them, acknowledge, covenant and agree:
a. All Confidential Information shall be and shall remain the exclusive property of
the source;
b. Confidential Information shall not be revealed or disclosed without the express
advance consent of Company and except as provided for in this Agreement;
C. To receive in confidence any Confidential Information; to limit access to such
Confidential Information to authorized agents and/or employees who have a
need to know the Confidential Information; and not to disclose such Confidential
Information to others or authorize anyone else to disclose such Confidential
Information to others without the prior written approval of Company;
0 uINAL
NONDISCLOSURE AND PROTECTIVE AGREEMENT
PAGE
d. To inform the receiving party, in advance of any disclosure of Confidential
Information, in non-confidential and non-proprietary terms, of the nature of the
proposed disclosure, and to afford the receiving party the option of declining to
receive the Confidential Information.
e. To identify in writing as confidential or proprietary, or to mark as confidential or
proprietary, all Confidential Information;
f. Alf persons receiving access to Confidential Information shall treat it as
confidential and shall not disclose it nor afford access to it to any other person
not authorized by Company and this Agreement to obtain said Confidential
Information;
g. No copies shall be made of any Confidential Information, whether by photostatic,
electronic, mechanical, database or other means, without the prior consent of
Company;
h. To return promptly to Company, or, at Company's option, to destroy any and all
copies of Confidential Information in written, graphic or other tangible form;
i. The obligations with respect to Confidential Information shall extend for a period
of not less than five (5) years following the date of initial disclosure of specific
portion of Confidential Information, and such obligations shall extend beyond
completion of the term of this Agreement;
j. Neither disclosure of Confidential Information nor this Agreement shall be
construed as a license to make, use or sell the Confidential Information or any
products derived therefrom; and
k. Neither the Confidential Information nor the act of disclosure shall constitute a
grant of any license under any trademark, patent or copyright for the same, nor
shall they constitute any representation, warranty, assurance or guarantee by
Company with respect to the infringement of any trademark, patent, copyright or
any right of privacy, or of any third persons.
4. Except as provided in this paragraph 4, persons receiving Confidential Information shall
not disclose or divulge such information to any other person. With the prior approval of
Company, Recipient(s) may disclose Confidential Information to an expert, agent,
consultant or employee of Recipient(s) as necessary to assist Recipient(s) with regard to
the existing MRC compliance review. Prior to the disclosure of such Confidential
Information to any such expert, agent, consultant or employee, Recipient(s) shall:
(a)give Company's counsel prior notice of the identity and affiliation of any such person;
(b) require any such person to read and sign an agreement in the form of Appendix A
which is attached hereto agreeing to abide by the terms of this Agreement; and
(c) cause to be delivered to Company's counsel a copy of such agreement. All persons
NONDISCLOSURE AND PROTECTIVE AGREEMENT
PAGE
receiving access to Confidential Information shall treat it as confidential and shall not
disclose it nor afford access to it to any other person not authorized by this Agreement to
obtain said information nor shall such information be used in any other manner as for
any other purpose than provided in this Agreement. No copies shall be made of any
Confidential Information or any part thereof without the prior written consent of
Company.
5. These obligations do not apply to Confidential Information which is, as shown by clear
and conviricing tangible proof:
a. Was in Recipient's possession prior to receipt thereof from Company; or
b. Was received by Recipient in good faith from a third party not subject to a
confidential obligation to Company; or
C. Now is or later becomes publicly known through no breach of confidential
obligation by Recipients, or either of them, or their agents or employees, or any
third party; or
d. Was developed by Recipient(s) without the developing person(s) having access
to Confidential Information received from Company or is developed
independently by Recipient(s)without any portion of the development having
been based on the Confidential Information.
6. If Recipients, or either of them, wish to divulge or disclose any such Confidential
Information in testimony, examination, exhibits or briefs in any legal or administrative
proceeding, Recipients shall contact counsel for Company at least three (3) business
days prior to such use to determine the appropriate protections to be imposed in order to
ensure the confidential and proprietary nature of the information against disclosure to
any persons not bound by this Agreement. For the purposes of this Agreement,
"Counsel for Company" shall be:
C. Stephen Rosander, Esq.
Room 5247
412 Mt. Kemble Avenue
Morristown, NJ 07960
Phone: (973)644-8465
Fax: (973) 644-8548
7. This Agreement does not preclude Company from opposing the production of any
Confidential Information or documents for lack of relevance or from objecting on any
grounds to the use of such Confidential Information in any legal or administrative
proceeding.
8. It is agreed that a violation of any of the provisions of this Agreement by Recipients, or
NONDISCLOSURE AND PROTECTIVE AGREEMENT
PAGE
either of them, will cause irreparable harm and injury to Company and that Company
shall be entitled, in addition to any other rights it may have at law or in equity, to an
injunction enjoining and restraining the violating party from doing or continuing to do any
such act and any other violations or threatened violation of this Agreement.
9. Recipients, and each of them, agree to indemnify and hold harmless Company from and
against any and all claims, losses, actions, damages, fines, expenses, attorneys'fee and
all other liabilities and costs arising out of or resulting from the negligent performance,
failure to perform, or willful misconduct of Recipients, or either of them, of any provision
of this Agreement and for the negligent acts or omissions or wrongful or willful
misconduct of their agents, servants, officers or employees.
10. Neither this Agreement nor provision of Confidential Information pursuant to it shall be
construed as an agreement, commitment, promise or representation by Company to do
business with Recipients, or either of them, or to do anything except as set out
specifically in this Agreement.
11. This Agreement shall be construed in accordance with the laws of the State of California.
12. This Agreement is the entire agreement between the parties with respect to
nondisclosure of Confidential Information and supersedes all prior agreements and
understandings with respect to this subject. This Agreement may be amended only by
written agreement executed by the parties. This Agreement shall not be assigned or
transferred by Recipients, or either of them, without the prior written consent of
Company. This Agreement shall be binding on agents, successors and permitted
assigns of the parties.
13. This Agreement may be executed in one or more counterparts, each of which shall be
deemed an original, but all of which together shall constitute one and the same
instrument.
FOR "Company"
By 0-5 k1p . �Ixwdv7
Name •g
Title ` u uo2 Accoiur ,4
Date 7-1-31.gg
NONDISCLOSURE AND PROTECTIVE AGREEMENT
PAGE 5
Title
Date
FOR R ip T "City of San Bernardino"
B `f'✓ �C
Name Fred Wilson
Title City Administrator
Date / — /2 - 99
FOR RECIPIENT "Municipal Resource Consultants"
By
Name John Austin
Title
Date
FOR RECIPIENT "Donald H. Maynor"
By
Name Donald H. Maynor
Title Donald H. Maynor. A Professional Law Corporation
Date
NONDISCLOSURE AND PROTECTIVE AGREEMENT
PAGE
FOR RECIPIENT "City of San Bernardino"
By
Name Fred Wilson
Title City Administrator
Date
FOR R C1 IE, NT "Mun' p�Resource Consultants"
B
Y
N me
Title
Date
FOR RECIPIENT "Donald H. Maynor"
By
Name Donald H Maynor
Title Donald H Maynor. A Professional Law Corporation
Date
NONDISCLOSURE AND PROTECTIVE AGREEMENT
PAGE
FOR RECIPIENT "City of San Bernardino"
BY
Name Fred Wilson
Title .City Administrator
Date
FOR RECIPIENT"Municipal Resource Consultants"
By
Name John Austin
Title
Date
FOR RECIPIENT "Donald H. Maynor"
By
Name Donald H. Maynor
Title Donald H. Maynor. A Professional Law Corporation
Date
NONDISCLOSURE AND PROTECTIVE AGREEMENT
PAGE
FOR RECIPIENT "Lorne Bemstein, Moss Adams, LLP"
By eftU„&lIA&k
Name Lorrie Bemstein Moss Adams LLP
Title Accountant for Moss Adams LLP
Date
APPENDIX A
AGREEMENT FOR ACCESS TO Company'S
PROPRIETARY AND CONFIDENTIAL INFORMATION
I, , (Name) (Title)
hereby acknowledge that I have received and read a copy of the Nondisclosure and Protective
Agreement ("Agreement") by and among ("Company"), the City of San Bernardino, Donald H.
Maynor, Lorne Bernstein, and Municipal Resource Consultants ('Recipients") regarding the
production of Confidential Information as defined therein. I understand and agree to be bound
by all the terms of said Agreement. I further state that neither I nor any firm with which I am
affiliated will use any Confidential Information to which I obtain access pursuant to said Agree-
ment in connection with the development of any marketing strategies or plans of any firm,
person or entity and that I will use said Confidential Information exclusively for the purpose of
the MRC Audit.
DATED: , 199_
Signature
Public Agency or Company
Business Address
Business Telephone
In re: Compliance Review of ) SUBPOENA
Telecommunications Utility User ) For Production of
Taxes. ) Business Records
[Govt. Code §37104 et. seq,
18 U.S.C.A. § 2703 (c)(1)(C)l
TO: CUSTODIAN OF RECORDS OF AT&T
FROM: CITY OF SAN BERNARDINO
1. YOU ARE ORDERED TO PRODUCE BUSINESS RECORDS
described in Item 3 as follows:
a. By delivery of a true, legible, and durable copy of the business
records described in item 3 to: Steve Gibson, Municipal Resource
Consultants, 32107 West Lindero Canyon Road, #233, Westlake
Village, CA CA 91361.
�.. 2. The records identified in Section 3a are to be produced by no later than
30 days after the issuance of the subpoena, or 25 days after service, whichever is
later. The records identified in Section 3b and 3c are to be produced by no later than
120 days after the issuance of the subpoena, or 115 days after service, whichever is
later. The records identified in Section 3d through 3h are to be produced following
a court order directing AT&T to disclose such information to City, subject to any
protective conditions imposed by the court. Reasonable costs of copying and
postage are recoverable from the City. The records shall be accompanied by an
affidavit of the custodian or other qualified witness stating in substance each of the
following:
a. the affiant is the duly authorized custodian of records or other
qualified witness and has authority to certify the records;
b. the copy is a true copy of all the records described in the
subpoena; and,
C. if AT&T has none of the records described, or only part thereof,
�... 1
the custodian or other qualified witness shall so state in the affidavit,
and deliver the affidavit and such records as are available.
3. The records to be produced are as follows:-
a. The account numbers, both billing and service addresses (if
different), and jurisdictional geocode designator for all current
nonresidential AT&T customers with Postal ZIP Codes of 92346,
92376, 92324, 92354, 92374, 92401, 92404, 92405, 92407, 92408,
92410, and 92411. [See attached memorandum dated October 28,
1997 from Scott Eckman to Karen Nations further describing such
records].
b. AT&T's tax matrix (for end users) used to apply the federal
excise tax and WT to the various telecommunication services
provided to retail customers within the City, including any changes
made to the tax matrix after January 1, 1997.
C. The names and addresses of all AT&T resale customers (e.g.,
CLECs, competitive access providers, telemanagement customers)
that provide retail telecommunication services within the City using
AT&T's facilities, including a copy of any declarations or
statements executed by such customers promising to apply and
collect local taxes on their retail telecommunications services.
d. The account numbers and addresses of all nonresidential
customers within the City,which, according to AT&T's records, are
designated as exempt from the City's utility users tax, and a copy of
their FET exemption application.
e. The names, service addresses, and billing addresses of AT&T
customers, within the City, that take Special Access Services
(including "private line services or channels") with Voice Grade
Channels or Voice Grade Services, whether or not the customer
actually uses such voice services [e.g., Switched Digital Services,
Switched Voice and Data Services (ACCUNET and DATAPHONE),
2
Packet Switched Service, Switched Digital Integrated Service,
Dedicated Transmission Service, ACCUNET Local Channel and
ACCUNET Spectrum of Digital Services, Digital Channel Service;
High Capacity Service (TI or DS1); Frame Relay Service (FRS),
ISDN (business and residential); Packet Network Services; Switched
Data Services; and any other Digital Data Service with Voice Grade
(VG) or High Capacity Channels with Voice Grade (VG)], which are
capable of connection to the public switched network (whether or
not used for that purpose).
f. Copies of contracts with customers within the City covering
AT&T services at rates or under terms and conditions differing
from filed AT&T tariff schedules. [Names and addresses of
customers can be redacted].
g. A copy of the surcharge exemption certificates or reporting
statements of AT&T customers, within the City, taking special
access service from AT&T (see enclosed sample), including any
additional information that the customer provides to AT&T in
support of its claim of exemption.
h. For each customer within the City that is billed on a master or
aggregate billing, a copy of the master billing verifying that AT&T's
telecommunication services to such customer are properly taxed
under the City's UUT.
Date:
MAYOR
3
NONDISCLOSURE AND PROTECTIVE AGREEMENT
THIS NONDISCLOSURE AND PROTECTIVE AGREEMENT ("Agreement"), effective
when executed by the parties, is made by and among AT&T ("AT&T"), with an address for
purposes of this Agreement of 412 Mt. Kemble Avenue, Morristown, NJ 07960, the City of San
Bernardino ("City"), with an address for the purposes of this Agreement of 300 North "D" Street,
San Bernardino, CA 92418, and Municipal Resource Consultants ("MRC"), a partnership, with
an address for the purposes of this Agreement of 32107 West Lindero Canyon Road, Suite 233,
Westlake Village, CA 91361, and its technical advisers, Donald H. Maynor of 235 Catalpa Drive,
Atherton, CA 94027, and Lome Bemstein of Moss Adams, LLP, 1899 March Lane, Suite F,
Stockton CA, 95207-6422 (collectively, "Recipients")to protect the confidential or proprietary
nature of information to be disclosed by AT&T to Recipients, or either of them, pursuant to that
certain SUBPENA For Production of Business Records (Govt. Code § 37104 at seq.) issued by
the City to AT&T on , 1998 ("Subpena"), and any supplemental subpoenas issued
thereafter but within twenty-four (24) months of said date.
ACCORDINGLY, the parties hereto and their counsel agree that the following terms and
conditions shall govern the use of Confidential Information provided to Recipients, or either of
them, in accordance with any Request:
1. "Confidential Information" as used herein means any information described in Revenue
and Tax Code § 7284.6 and 7284.7, including any information that is in written, oral or
other tangible or intangible form. Such information may include but is not limited to,
ideas, concepts, know-how, models, diagrams, flowcharts, data, computer programs,
marketing plans, business plans, customer names, customer account numbers,
customer billing information, customer demographic information and other technical,
financial, customer or business information, which is designated as "confidential" or
"proprietary" by Company in the belief that it contains a trade secret or other confidential
research, development, customer, commercial or financial information. Documents
containing Confidential Information and all copies thereof shall remain the property of
Company, and all copies thereof shall be returned to counsel for Company as set forth
hereinbelow.
2. This Agreement governs all Confidential Information whether produced, revealed or
disclosed to Recipients by Company.
3. Recipients, and each of them, acknowledge, covenant and agree:
a. All Confidential Information shall be and shall remain the exclusive property of
the source;
b. Confidential Information shall not be revealed or disclosed without the express
advance consent of Company and except as provided for in this Agreement;
C. To receive in confidence any Confidential Information; to limit access to such
Confidential Information to authorized agents and/or employees who have a
need to know the Confidential Information; and not to disclose such Confidential
Information to others or authorize anyone else to disclose such Confidential
Information to others without the prior written approval of Company;
NONDISCLOSURE AND PROTECTIVE AGREEMENT
PAGE
d. To inform the receiving party, in advance of any disclosure of Confidential
Information, in non-confidential and non-proprietary terms, of the nature of the
proposed disclosure, and to afford the receiving party the option of declining to
receive the Confidential Information.
e. To identify in writing as confidential or proprietary, or to mark as confidential or
proprietary, all Confidential Information;
f. All persons receiving access to Confidential Information shall treat it as
confidential and shall not disclose it nor afford access to it to any other person
not authorized by Company and this Agreement to obtain said Confidential
Information;
g. No copies shall be made of any Confidential Information, whether by photostatic,
electronic, mechanical, database or other means, without the prior consent of
Company;
h. To return promptly to Company, or, at Company's option, to destroy any and all
copies of Confidential Information in written, graphic or other tangible form;
i. The obligations with respect to Confidential Information shall extend for a period
of not less than five (5) years following the date of initial disclosure of specific
portion of Confidential Information, and such obligations shall extend beyond
completion of the term of this Agreement;
j. Neither disclosure of Confidential Information nor this Agreement shall be
construed as a license to make, use or sell the Confidential Information or any
products derived therefrom; and
k. Neither the Confidential Information nor the act of disclosure shall constitute a
grant of any license under any trademark, patent or copyright for the same, nor
shall they constitute any representation, warranty, assurance or guarantee by
Company with respect to the infringement of any trademark, patent, copyright or
any right of privacy, or of any third persons.
4. Except as provided in this paragraph 4, persons receiving Confidential Information shall
not disclose or divulge such information to any other person. With the prior approval of
Company, Recipient(s) may disclose Confidential Information to an expert, agent,
consultant or employee of Recipient(s) as necessary to assist Recipient(s)with regard to
the existing MRC compliance review. Prior to the disclosure of such Confidential
Information to any such expert, agent, consultant or employee, Recipient(s)shall:
(a) give Company's counsel prior notice of the identity and affiliation of any such person;
(b) require any such person to read and sign an agreement in the form of Appendix A
which is attached hereto agreeing to abide by the terms of this Agreement; and
(c) cause to be delivered to Company's counsel a copy of such agreement. All persons
NONDISCLOSURE AND PROTECTIVE AGREEMENT
PAGE
receiving access to Confidential Information shall treat it as confidential and shall not
disclose it nor afford access to it to any other person not authorized by this Agreement to
obtain said information nor shall such information be used in any other manner as for
any other purpose than provided in this Agreement. No copies shall be made of any
Confidential Information or any part thereof without the prior written consent of
Company.
5. These obligations do not apply to Confidential Information which is, as shown by clear
and convincing tangible proof:
a. Was in Recipient's possession prior to receipt thereof from Company; or
b. Was received by Recipient in good faith from a third party not subject to a
confidential obligation to Company; or
C. Now is or later becomes publicly known through no breach of confidential
obligation by Recipients, or either of them, or their agents or employees, or any
third party; or
d. Was developed by Recipient(s)without the developing person(s) having access
to Confidential Information received from Company or is developed
" independently by Recipient(s)without any portion of the development having
been based on the Confidential Information.
6. If Recipients, or either of them, wish to divulge or disclose any such Confidential
Information in testimony, examination, exhibits or briefs in any legal or administrative
proceeding, Recipients shall contact counsel for Company at least three (3) business
days prior to such use to determine the appropriate protections to be imposed in order to
ensure the confidential and proprietary nature of the information against disclosure to
any persons not bound by this Agreement. For the purposes of this Agreement,
"Counsel for Company" shall be:
C. Stephen Rosander, Esq.
Room S247
412 Mt. Kemble Avenue
Morristown, NJ 07960
Phone: (973) 644-8465
Fax: (973) 644-8548
7. This Agreement does not preclude Company from opposing the production of any
Confidential Information or documents for lack of relevance or from objecting on any
grounds to the use of such Confidential Information in any legal or administrative
proceeding.
8. It is agreed that a violation of any of the provisions of this Agreement by Recipients, or
NONDISCLOSURE AND PROTECTIVE AGREEMENT
PAGE
either of them, will cause irreparable harm and injury to Company and that Company
shall be entitled, in addition to any other rights it may have at law or in equity, to an
injunction enjoining and restraining the violating party from doing or continuing to do any
such act and any other violations or threatened violation of this Agreement.
9. Recipients, and each of them, agree to indemnify and hold harmless Company from and
against any and all claims, losses, actions, damages, fines, expenses, attorneys'fee and
all other liabilities and costs arising out of or resulting from the negligent performance,
failure to perform, or willful misconduct of Recipients, or either of them, of any provision
of this Agreement and for the negligent acts or omissions or wrongful or willful
misconduct of their agents, servants, officers or employees.
10. Neither this Agreement nor provision of Confidential Information pursuant to it shall be
construed as an agreement, commitment, promise or representation by Company to do
business with Recipients, or either of them, or to do anything except as set out
specifically in this Agreement.
11. This Agreement shall be construed in accordance with the laws of the State of California.
12. This Agreement is the entire agreement between the parties with respect to
nondisclosure of Confidential Information and supersedes all prior agreements and
understandings with respect to this subject. This Agreement may be amended only by
written agreement executed by the parties. This Agreement shall not be assigned or
transferred by Recipients, or either of them, without the prior written consent of
Company. This Agreement shall be binding on agents, successors and permitted
assigns of the parties.
13. This Agreement may be executed in one or more counterparts, each of which shall be
deemed an original, but all of which together shall constitute one and the same
instrument.
FOR "Company"
By
Name
Title
Date
NONDISCLOSURE AND PROTECTIVE AGREEMENT
PAGE
FOR RECIPIENT "City of San Bernardino"
By
Name Fred Wilson
Title City Administrator
Date
FOR RECIPIENT "Municipal Resource Consultants"
By
Name John Austin
Title
Date
FOR RECIPIENT "Donald H. Maynor"
By
Name Donald H Maynor
Title Donald H Maynor A Professional Law Corporation
Date
NONDISCLOSURE AND PROTECTIVE AGREEMENT
PAGE 6
FOR RECIPIENT "Lome Bemstein, Moss Adams, LLP"
By
Name Lorrie Bemstein Moss Adams. LLP
Title Accountant for Moss Adams LLP
Date
APPENDIX A
AGREEMENT FOR ACCESS TO Company'S
PROPRIETARY AND CONFIDENTIAL INFORMATION
I, (Name) (Title)
hereby acknowledge that I have received and read a copy of the Nondisclosure and Protective
Agreement ("Agreement") by and among ("Company"), the City of San Bernardino, Donald H.
Maynor, Lomie Bernstein, and Municipal Resource Consultants ("Recipients") regarding the
production of Confidential Information as defined therein. I understand and agree to be bound
by all the terms of said Agreement. I further state that neither I nor any firm with which I am
affiliated will use any Confidential Information to which I obtain access pursuant to said Agree-
ment in connection with the development of any marketing strategies or plans of any firm,
person or entity and that I will use said Confidential Information exclusively for the purpose of
the MRC Audit.
DATED: ' 199
Signature
Public Agency or Company
Business Address
Business Telephone
In re: Audit of Electric Utility ) SUBPOENA
Users Taxes ) For Production of
and Franchise Fees. ) Business Records
(Govt Code §37104 et seq.)
et. seq, 18 U.S.C.A. § 2703 (c)(1)(C)]
TO: CUSTODIAN OF RECORDS OF SOUTHERN CALIFORNIA
EDISON COMPANY
FROM: CITY OF SAN BERNARDINO
C 1. YOU ARE ORDERED TO PRODUCE BUSINESS
RECORDS described in Item 3 as follows:
a. By delivery of a true, legible, and durable electronic
copy of the business records described in Item 3 to: MUNICIPAL
RESOURCE CONSULTANTS, c/o Mr. Stephen L. Gibson, 32107
W. Lindero Canyon Road, Suite 233, Westlake Village, CA 91361.
2. The records are to be produced by no later than 20 days
after the issuance of the subpoena, or 15 days after service, whichever
is later. Reasonable costs of copying and postage are recoverable
from the City. The records shall be accompanied by an affidavit of
the custodian or other qualified witness stating in substance each of
the following:
a. the affiant is the duly authorized custodian of records or
other qualified witness and has authority to certify the records;
b. the copy is a true copy of all the records described in the
subpoena; and,
-1-
C. if Edison has none of the records described, or only part
thereof, the custodian or other qualified witness shall so state in the
affidavit, and deliver the affidavit and such records as are available.
d. The records required by the subpoena will be for the months of
June, July, August, September, October, and November, 1997 (separate data
for each month) and June, July, August, September, October, and
November, 1998 (separate data for each month). The electronic format,
specified by the subpoena, shall be the same as the format agreed and
applied to the City of San Bernardino reports previously completed in years
past by Southern California Edison (data format attached). This will allow
Southern California Edison Company's compliance with providing the
necessary information to be as efficient as possible.
3. The records to be produced are as follows:
a. The names and addresses of all
nonresidential customers within the City that
are deemed exempt from the City's utility users
tax.
b. The names, addresses and account
numbers of all current Edison customers, by
revenue class, within the City. The gross
revenue amount billed to each of those accounts
and the amount of City utility users tax
collected for each account during the audit
period.
C. The addresses and account numbers of all
accounts in adjacent or shared postal zip codes
contiguous to the City's boundaries.
d. A complete list of all customers who have chosen to
utilize an ESP for their electric service including their
names, service address, billing address, monthly usage in
kwh and their ESP provider.
The City and its contractor (Municipal Resource Consultants) will maintain
all such requested records and documents as confidential pursuant to
Revenue and Tax Code Section 7284.7
Dated Issued:
Mayor
CITY OF SAN BERNARDINO
-2-
MUNICIPAL RESOURCE CONSULTANTS
DATA ELEMENT SPECIFICATIONS -
DISKETTE RECORDS:
Diskettes can be either 5 1/4" or 3 1/2" in size
DBF files are preferred,however any DOS compatible file format is acceptable
MAGNETIC TAPE RECORDS:
RECORDING MODE: 1/2' 9 track(6262 BPI or 1600 BPI)tape or IBM 3480/3490 cartridge,
recorded in EBCDIC or ASCII(ASCII is preferred)
DENSITY: Either 6250 BPI or 1600 BPI is acceptable(6250 BPI is preferred)
INTERNAL LABELS: Labels are optional;however,unlabeled tapes are preferred. If labels are provided,we don
not require any specific information placed in the label records
TAPE MARKS: There must always be at least one tape mark following the last data block.If internal labels are
provided,a tape mark must be placed between the last header block and the first data block. If internal label records
are not provided a tape mark must not precede the first data block
RECORD LENGTH: Written fixed length,NOT variable length
FIELD SPECIFICATIONS: All fields should be fixed length;unpacked,and unsigned(when possible)
BLOCKING FACTOR: No more than 9000 characters per block is preferred. Block size must be an even
increment of the record size utilized.Example(Record size 300)x(10 records)=Block size of 3000
SUPPORTIVE DOCUMENTATION
A list of any codes and their associated description is requested for all files supplied.If these codes are maintained
electronically,please supply them as part of entire package(i.e.,send them as separate files using the same media
A file layout is requested for all file format types other than DBF. Layout to include the field name,field length,
and field type(i.e.,character,numeric,date,etc.)
Include file name,record count,block size and record length on an external tape label
9F'RNARD�
Sp
C I T Y O F
0 RAN D U M
G'YDED 1N
Date : PST
From:
R A C H E L C L A R K Dept ;
C I T Y C L E R K Tel No:
Subject :
Miss Rachel, Fred asked me to mention that once the subpoenas for
SCE and AT&T records have been signed and dated by the Mayor (and
Fred has signed off on the non-disclosure agreement) , the
documents are to be returned to Don Maynor, A Professional Law
Corporation, 3220 Alpine Road, Suite A, Portola Valley, CA
94028 .
Thanks,
Jan
P . O. B 0 2 1 0 1 8 , B A N B B R N A R D I N O , CA 9 2 4 0 2
3 0 0 N O R T H 0 S T R E E T S A N B E R N A R 0 1 N O .
C A L I F O R N I A 9 2 4 1 5 . 0 0 0 1 ( 0 0 2 ( 2 2 4 - 5 0 0 2
( 9 0 0 ( 2 0 4 - 5 1 0 2 FA Y -(0 0 0 ) 0 0 4 .0 1 O B
T D D I T T Y -(0 0 0 ) 0 5 4 .5 5 4 0
I N T E R O F F I C E M E M O R A N D U M
Date: 12-Jan-1999 12 :26pm PST
From: Jan Wages
WAGES JA
Dept : Administration
Tel No:
TO: Melanie Miller ( MILLER ME )
CC: Sandra Medina ( MEDINA_SA )
Subject : Subpoenas - Item 23
The subpoenas were delivered to Sandy at approximately 12 : 10 this
afternoon. Forwarding e-mail sent to Rachel yesterday relative
to processing of same.
i
Any questions, please call .
Thanks,
i
Jan
i
I N T E R O F F I C E M E M O R A N D U M
Date: 12-Jan-1999 11 :44am PST
From: Sandra Medina
MEDINA SA
Dept : CITY CLERK
Tel No:
TO: Melanie Miller ( MILLER_ME )
CC: Jan Wages ( WAGES JA )
CC: Rachel Clark ( CLARK RA )
Subject : RE : Item #23 - 01/11/1999
Yes, there is a disclosure agreement that needs to be executed.
As far as the subpoenas, I would check with City Attorney to see
if they are going to execute those documents.
Also, you need to call Jan Wages before executing as there was
something being changed in some of the documents .
Sandra
_ r
I N T E R O F F I C E M E M O R A N D U M
Date: 12-Jan-1999 11 :16am PST
From: Melanie Miller
MILLER ME
Dept : CITY CLERK
Tel No:
TO: Rachel Clark ( CLARK RA )
TO: Sandra Medina ( MEDINA_SA )
CC: Jan Wages ( WAGES—JA )
Subject : Item #23 - 01/11/1999
As item #23 subpoena of utility billing records - AT&T and
Edison.
Is there something I have to execute?
I would assume a subpoena would be executed by the City
Attorney' s Office.
I N T E R O F F I C E M E M O R A N D U M
Date: 11-Jan-1999 04 :36pm PST
From: Rachel Clark
CLARK RA Y
Dept : CITY CLERK
Tel No:
TO: Sandra Medina ( MEDINA SA )
TO: Melanie Miller ( MILLER_ME )
CC: Jan Wages ( WAGES—JA )
Subject : AT&T audit - item 23 on today' s agenda
Please hold up execution of any documents related to item #23 on
today' s agenda.
Jan Wages has advised me that there will be a change in Section
1A of the subpoena and Mr. Maynor' s office will be sending
revised documents for execution.
Jan checked with Mr. Penman' s office to see if docs would have to
be brought back before Council on 1/25 (due to technical
changes) ; however, Mr. Penman advises that it won' t be necessary.
Docs can be executed once they are returned.
If my message is not clear to you, please let me know.