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Kelly A. Aviles (SBN 257168) LAW OFFICES OF KELLY AVILES
1502 þ-oothill Blvd., #103-140 La Verne, Califbrnia 91750 I'elephone: (909) 991 -7560 Facsimile: (909) 991-7594

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Attonrey for Petitioner GIL AGUIRRE

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SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES

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GIL AGUIRRE,
Petiti oner/P

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Case

No.: 8S132514
Assignedfor All Purposes la Hon. Luis Levin - Dept 82

laintiff,

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SAN GABRIEL VALLEY COUNCIL OF GOVERNMENTS,
Respondent/Defendant

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) ) ) ) ) ) ) ) ) ) ) )

STIPULATION AND [Proposed] ORDER AND FTNAL JT]T}GMENT
Action Filed
Hearing Date Time: Dept:
0611512011

08t09t20t2
1:30 p.m.
82

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.

Petitioner/Plaintiff

GIL AGUIRRE and

Respondent/Defbndant
as follows:

SAN GABRIEL

VALLEY COUNCIL OF GOVERNMENTS hereby stipulate

This Stipulated Order and Final Judgment is made and entered into by and between

GIl, AGUIRRE ("Petitioner"), and the SAN GABRIEL VALLEY COUNCIL OF'
GOVERNMENTS (the "SGVCOG"), in the above-captioned litigation (the "Action"). The
Parties have also"waived their right to appeal ¿rnd have agreed to settle this Action without

further litigation, as set forth in the Settlement Agreement attached hereto as Exhibit 1 and
incorporated herein by reference. The Parties agree that this Court has jurisdiction to

STIPULATION AND PROPOSED ORDER

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interpret and enflorce this Stipulation and Order and Judgment and the Settlement Agreement
attached hereto as Exhibit 1, on which this Stipulated Order and Judgment are based.

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WHEREAS, Petitioner filed the above-captioned Action against the SGVCOG in the
Superior Court of the State of California, County of Los Angeles (the "Action"), alleging that Defendant has violated and is likely to continue to violate the Ralph M. Brown Open Meeting
Ãct (Government Code

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$

54950, eÍ se(4., the "Brown

Act") and the California Public Records

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Ãct(Government Code $ 6250, et seq.,the "CPRA");

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WHEREAS, the parties agree that the parties had a genuine dispute as to whether
some òf the documents sought in this lawsuit were disclosable public records at the time they

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were requested;

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WHEREAS, the parties âgree that unintentional violations of the Brown Act have
previously occurred;

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NOW THEREFORE, the Parties hereby stipulate to the proposed order and entry of
judgment in favor of Gil Aguirre and against San Gabriel Valley Council of Governments, as
set forth below:

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1. On January 23,2012, after the filing of this action, Respondent

released the Caltrans

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Audit requested by Petitioner, which is the subject of this action. Should a request for
subsequent draft audits

from Caltrans be made in the future, Respondent shall give notice to

Caltrans of such request and release any such drafts within the time specified in the Public
Records Act unless Caltrans has obtained a court order or an agreement from the requesting party that such drafts are not subject to release;

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2. It is stipulated
54957.5

that Respondent shall comply with Government Code section

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by making all documents which are distributed to a majority of governing board

members in connection with a public meeting and which are not attorney-client privileged or

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STIPULATION AND PROPOSED ORDER

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a

otherwise protected from disclosure by law, available to the public, upon request and without delay;

3. It is stipulated

that Respondent shall comply with Government Code section 54956.9

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bV (1) only holding closed sessions where litigation is pending, "anticipated" as defined in this

section or the possibility of initiating litigation is being discussed, (2) releasing the facts and oircumstances of such litigæion, when required by that section,
session discussion to items directly related to the litigation;

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and (3) limiting the closed

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4. It is stipulated that Respondent shall comply with Government Code $ 54954.2 by
posting agendas f'or every regular and special meeting

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of the Governing Board and all

committees which are subject to the Brown Act, on Respondent's website and in one consistent

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location, which is accessible to all.members of the public twenty-fout QÐ hours a day except
during any periods of reasonable interruptions for maintenance, upgrades, or not due to the fault

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of the Respondent. Nothing herein shall preclude Respondent from giving additional public
notice by posting agendas at the offices of member cities;

5. It is stipulated that Respondent shall comply with Government Code section 54954.2
by only discussing items at meetings which were either (a) listed on a posted agenda complying

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with this section or (b) have come to the attention of the Board or Committee after the posting
of the agenda and which require immediate action;

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6.

It is stipulated

that Respondent shall discuss and approve all contracts and

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agreements, except for settlement agreements as authorized under Government Code section
54956.9, in open session, unless discussions are otherwise permitted in closed session by law;

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7. It is stipulated that Respondent

shall comply with Government Code 54957.1 by

announcing all actions taken in closed session, as required by this section, in open session at the meeting in which the closed session was held, unless otherwise requirecl by this section;

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8. It is stipulated that Respondent shall comply with Government Code section
54953.3 by clearly noting on any sign sign-in sheet available at any public meeting, that

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signing, registering, er completion

of said document is completely voluntary and that all

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STIPULATION AND PROPOSED ORDER

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persons may attend the rneeting regardless of whether a person signs, registers, or completes
said document;

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9. It is stipulated that Respondent shall comply with Government

Code section

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54954,3 by allowing members of the public the opportunity to address the board or committee

on any item of interest to the public and within the jurisdiction of the Respondent, bef.ore or during the consideration of that item, , except as provided in this section.
Board requests that persons addressing the Board

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If

the Goveming

fill

out a speaker card. such cards shall make

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clear that such cards are not required, are voluntary, ancl a person has a right to speak without

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filling out

a speaker card;

10. It is stipulated
attendance on axy agenda; I

that Respondent shall not include any ref'erence to a cost of

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1. It is stipulated that Respondent sliall comply with Government

Code section

54954,2(a)(1) bV including the ADA information required by this section on every agenda;

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12. lt is stipulated

that Respondent shall comply with Government Code section

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54952(b) by ensuring that any advisory committees, which currently exist or that are created in

the future, which are not required to comply with the Brown Act, are comprised solely of less than a quorum of members of legislative body and do not have a continuing subject matter

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juristliction.

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The Court shall retain jurisdiction to resolve any disputes between the parties with
regard to this Stipulation and Order and judgment and the settlement agreement on which
based.

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it

is

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Except as set forth in the stipulation and the agreement attached hereto as Exhibit A, each

party shall bear its own costs, attorneys' fees and other

in this action.

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DATED:

"/*/*a/L-

GIL AGUIRRE Petitioner/Plaintiff
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STIPULATION AND PROPOSED ORDER

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DATED:

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SAN GABRIEL VALLEY COLINCIL OF GOVERNMENTS

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By Angel Carrillo, President of Governing Board
Respondents/Def.endants

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APPROVED AS TO FORM

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DATED:

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LAW OFFICES OF KELLY

AVILES

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A Attorney for

GIL AGUIRRE

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DATED

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JON

& MAYER

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Barlow mberly Attorney for Respondent SAN GABRIEL VALLEY COTINCIL OF GOVERNMENTS

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Ilased on the fbregoing Stipulation, the Settlement Agreement attached hereto as Exhibit 1, and
f'or good cause appearing,

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IT IS SO ORDERED:

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DATED
Honorable Luis Levin .ludge of the Superior Court

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STIPULATION AND PROPOSED ORDER

EXHIBIT $I))

SETTLEMENT AGREEMENT AND RELEASE

THIS SETTLEMENT AGREEMENT ("Agreement") is made and entered into as of this 21st day of June, 2012 (fhe "Effective Date") by and between the San Gabriel Valley Council of Governments (the "SGVCOG") and Gil Aguirre ("Aguine")
(collectively referred to herein as the "Settling Parties").

RECITALS
In May 2011, Aguirre made a request under the CPRA for an audit done by Caltrans relating to a grant funds received by the SGVCOG. The SGVCOG denied Aguirre's request, stating that the document done by Caltrans was a draft and its release was prohibited by Caltrans.
Dissatisfied with the SGVCOG Attorney's response to his request, Aguirre filed a lawsuit entitled Gil Aguirre v. San Gabriel Valley Council of Governments, Los Angeles County Superior Court Case No. 85132514 (the "Action"), seeking a writ of mandate and injunctive and declaratory relief, claiming that withholding the document constituted a violation of the California Public Records Act. Subsequently, Mr. Aguine sent a cure and correct demand SGVCOG alleging multiple violations of the Ralph M. Brown Act.

A.

B.

C.

to the

The SGVCOG, by and through its attomeys Jones & Mayey denied the majority of the allegations in the cure and correct demand. The SGVOG alleges that some items referenced in the letter were cured and others were not susceptible of a cure
because no action had been taken.

D.

Dissatisfied with the SGVCOG Attomey's response, Aguirre amended his lawsuit to include allegations relating to the alleged violations of the Ralph M. existing Brown Act, seeking a writ of mandate and injunctive and declaratory relief for alleged violations of the Brown Act and the Califomia Public Records Act.

E.

F. In the interest of avoiding the time, expense and risk of litigation, the Settling Parties wish to resolve and settle the Action and all causes of action set forth therein on the terms set forth herein.
The Settling Parties intend for this Agreement to resolve and extinguish all claims arising from the Action.

G.

NOW, THEREFORE, in consideration of the mutual covenants and agreements described below, and for good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the Settling Parties hereby agree as follows:
Obligations of the Settline Parties. The Parties shall execute the stipulation attached to this Agreement as Exhibit B within thirty (30) days of the execution of this Agreement. The parties agree, pursuant to Code of Civil Procedure section 664.6, that the court will retain jurisdiction over the parties to enforce this settlement until full performance of the terms of the settlement. By the atthorization and

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execution of this settlement agreement, the SGVCOG hereby authorizes the President the Goveming Board to execute the attached stipulation.
a.

of

Oblieations of SGVCOG.

Within thirty (30) days of execution of this Agreement, SGVCOG shall deliver a check made payable to Law Offices of Kelly Aviles in the amount of $50,000 in reimbursement of and to resolve all claims for Aguir:re's attomeys
fees and costs associated with this matter.

(iÐ Concurrently with execution of this Agreement, SGVCOG shall issue a public statement in the form attached hereto as Exhibit A. By its release, the SGVCOG acknowledges that multiple unintentional violations the Ralph M. Brown Act and the failure to release disclosable public records pursuant to the California Public Records Act have previously occurred.
The SGVCOG shall develop and formally adopt policies and procedures to ensure future compliance with the Brown Act and Public Records Act. Said policies and procedures shall be submitted to the Law Offices of Kelly Aviles, legal counsel for Aguirre for review and comment prior their adoption.

(iiÐ

(iv) Within 90 days, the SGVCOG shall conduct a training for its Executive Director and staff, and members of SGVCOG boards and committees on the requirements of the California Public Records Act and the Ralph M. Brown Act, and on the implementation of the new policies and procedures described in the preceding paragraph. The training program and materials shall be submitted prior to the training to Kelly Aviles, legal counsel for Aguirre for review and comment. If there is any delay in reviewing the training program materials, the time for conducting such training shall be extended as necessary so as not to require the calling of a special meeting. The training shall take place at a noticed and public meeting, complying with the requirements of the Ralph M. Brown Act. The training shall be at least t hour long. b.
Obligations of Aguirre

(i)
paragraph (a)

Within 5 days of receipt of the payment described in

(i) above, Aguirre shall file the executed stipulated order and judgment set forth in Exhibit B. The Settling Parties both agree to any further acts and to execute and
deliver any further documents that may be required by the Court to conclude this action.

2.

Release

Aguirre hereby fully and forever releases and discharges the SGVCOG, its officers, employees, agents, attomeys and consultants from any and all
past, present or future claims, actions, losses, liabilities, causes of action, liens, demands, rights, damages, costs, attomeys' fees, interest, expenses, reimbursement and

a.

compensation of any nature whatsoever, whether known or unknown, disclosed or undisclosed, and whether or not anticipated, in any way related to the Action and claimed violations of the Brown Act or Public Records Act.
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'Waiver

of Civil Code Section 1542. This Agreement expressly extends only to all Brown Act and Public Records Act claims, whether known or unknown, and Aguirre expressly waives the provisions of Section 1542 of the California Civil Code which provides as follows:
A general release does not extend to claims which the creditor does not know or suspect to exist in his or her favor at the time of executing the release, which if løtown by him or her must have materially øffected his or her settlement with the debtor.

Except as otherwise provided in this Agreement, Aguine walves for the recovery of any costs, expenses or fees, including attomeys' any and all claims fees, against the SGVCOG related to or associated with the matters and claims released
herein.

b.

c. This Agreement shall constitute an absolute bar to any future action or proceeding of any kind in any venue by Settling Parties or any person or entity acting in cooperation or conjunction with them or on their behalf against SGVCOG relating to the matters raised in the Action or any other alleged violations of the Ralph M. Brown Act or the California Public Records Act, which occurred prior to the date of this Agreement, even if such alleged violations were not identified in the Action or known to Aguirre. d.
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The provisions of this Section 2

will survive the execution

and

delivery of this Agreement
Representations and Warranties.

a.
as

Aguirre hereby represents and warrants, as of the Effective Date,

follows:

He has not heretofore assigned or transferred, or purported to assign or transfer, to any party not named herein any released matter or claim, or any part or portion thereof.

(i)

Aguirre is fully authorized to commit and bind himself to each and all of the commitments, terms and conditions hereof, and to release the claims described herein, and that all documents and instruments relating thereto are, or, upon execution and delivery willbe, valid and binding obligations, enforceable against him in accordance with their respective terms.

(ii)

(iv) Aguirre has freely entered into this Agreement and is not entering into this Agreement because of any duress, fiiar, or undue influence and this Agreement is being entered into in good faith. (v)
Aguirre has made such investigation of the facts pertaining to this Agreement as he deems necessary.

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Aguirre has, prior to the execution of this Agreement, obtained the advice of independent legal counsel of his own selection regarding the substance of this Agreement, and the claims released herein.

(vi)

In executing this Agreement, each of the Settling Parties represents, and warrants to each other that he/it has not relied upon any acknowledges, statement or representation of any other party nor of any officer, agent, employee, representative, or attomey for any other party regarding any facts not expressly set forth within this Agreement. In entering into this Agreement, helit assumes the risk of any misrepresentations, concealment or mistake, whether or not it should subsequently discover or assert for any reason that any fact relied upon by him/it in entering into this Agreement was untrue, or that any fact was concealed from himlit, or that his/its understanding of the facts or of the law was incorrect or incomplete. b.
The representations and warranties of each of the Settling Parties set forth in this Section 3 and elsewhere in this Agreement will survive the execution and delivery of this Agreement and are a material part of the consideration to each of the other Settling Parties in entering into this Agreement.

c.

4.

Interpretation.

a.

All Settling Parties have cooperated in the drafting

and preparation

of this Agreement and in any construction or interpretation to be made of this Agreement, the same shall not be construed against any such Settling Party. This Agreement is the product of bargained for and arms length negotiations between the Settling Parlies and their counsel. This Agreement is the joint product of the Settling Parties.

This Agreement is an integrated contract and sets forth the entire agreement between the parties hereto with respect to the subject matter contained herein. All agreements, covenants, representations and warranties, express or implied, oral or written, of the parties hereto with regard to such subject matter are contained in this Agreement. No other agreements, covenants, representations or warranties, express or implied, oral or written, have been made or relied on by any party hereto.
This Agreement may not be changed, modified or amended except by written instrument specifying that it amends such agreement and signed by the party against whom the enforcement of any waiver, change, modification, extension or discharge is sought. No waiver of any provision of this Agreement shall be deemed or shall constitute a waiver of any other provision whether or not similar, nor shall any waiver be deemed a continuing waiver; and no waiver shall be implied from delay or be binding unless executed in writing by the party making the waiver.
herein contained in favor of the persons and entities released are made for the express benefit of each and all of the said persons and entities, each of which has the right to enforce such provisions.

b.

c.

d.

All of the covenants, releases and other provisions

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This Agreement shall be binding upon and inure to the benefit of each of the Settling Parties, and their respective representatives, officers, employees,
agents, heirs, devisees, successors and assigns..

e.

Further Cooperation. Each party shall perform any further acts and to execute and deliver any fuither documents that may be reasonably necessary or appropriate to carry out the provisions and intent of this Agreement.

5.

Except as provided elsewhere in this Agreement, each party to this Agreement shall bear its own costs, attomeys' fees and other expenses incumed in association with negotiation and execution of this Agreement and the Action.

6. l.

Attornevs'Fees.

This agreement shall be governed by, and Goveming Law; Venue. construed in accordance with, the laws of the State of California, without regard to any otherwise applicable principles of conflicts of laws. Any action arising out of this agreement must be coÍtmenced in the state courts of the State of Califomia, County of Los Angeles, and each party hereby consents to the jurisdiction of the above couft in any such action and to the laying of venue in the State of California, County of Los Angeles, and agrees that such courts have personal jurisdiction over each of them.

8. Counterparts. This Agreement may be executed in any number of counterparts, each of which when so executed shall be deemed to be an original, but such counterparts together shall constitute one and the same instrument. IN
WITNESS \ilHEREOF, the Settling Parties hereto have caused this
Agreement to be duly executed as of the Effective Date.

SAN GABRIEL VALLEY COUNCIL OF GOVERNMENTS

Angel

Gil Aguirre

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APPROVED AS TO FORM:

JONES'& MAY.ER

Attorneys for San Gabriel ValleJ Council of Governrnents

LAW OFFICES OF KELLY AVILES

Kelly
Attotney for

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Erhibit,\

Pronosed Statement Resardins Brown Act and Public Reco rds Lawsuit Settlement In May 20II, Gil Aguine filed a lawsuit against the San Gabriel Valley Council of Govemments ("SGVCOG") in Los Angeles Superior Coutl, Case No. 8S132514. The lawsuit alleged that the SGVCOG (1) violated the Public Records Act by failing to release a Caltrans Audit of the SGVCOG anci (2) violated numerous provisions of the Brown Act. Furlher, after the suit was filed, Mr. Aguirre has brought a number of additional issues to our attention relating to Brown Act compliance.
Over the past few months, attomeys for both the SGVCOG and for Mr. Aguirre have worked together to resolve this matter. After further analysis of these issues and the Brown Act's requirements, SGVCOG acknowledges that there have been some inadvertent Brown Act violations and some disputes over compliance with the Public Records Act.

While unintentional, the SGVCOG regrets these violations and believes that the public deserve nothing shorl of full compliance with both the spirit and the letter of the open meeting and public records laws. To ensure future compliance with these important open government laws, we have aheady released the Caltrans Audit. In addition, we will be developing and implementing a number of policies and procedures specifically addressing the areas of concem set forth in the litigation. Finally, we will be conducting training on the requirements of the Brown Act and Public Records Act for all of our staff and board members.
The San Gabriel Valley Council of Govemments is committed to having its public business addressed in the most transparent and open way, consistent with the law.

Exhibit B

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Kelly A. Aviles (SBN 257168) LAW OFFICES OF KELLY AVILES 1502 Foothill Blvd., #103-140 La Verne, California 91750 Telephone: (909) 991-7560 Facsimile: (909) 991-7594
Attorney for Petitioner GIL AGUIRRE

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SUPERIOR COURT OF THE STATE OF CALIFORIUA
F'OR

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THE COUNTY OF LOS ANGELES

GIL AGUIRRE,
P

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V.

) Case )
etitioner/P I ainti

No.: 85132514
Assignedfor All Purposes to Hon. Luis Levin - Dept 82

ff,

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SAN GABzuEL VALLEY COUNCIL OF GOVERNMENTS,
Resp ondent/Defendant.

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STIPULATION AND [Proposed] ORDER AND FINAL JUDGMENT
Action Filed:
Hearing Date:

06lt5l20ll
0810912012 1:30 p.m. 82

Time: Dept:

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PetitionerÆlaintiff

GIL AGUIRRE and

Respondent/Defendant
as

SAN GABRIEL

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VALLEY COTINCIL OF GOVERNMENTS hereby stipulate

follows:

This Stipulated Order and Final Judgment is made and'entered into by and between

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GIL AGUIRRE ("Petitioner"), and the SAN GABRIEL VALLEY
Parties have also waived their right to appeal and have agreed

COLTNCIL OF

GOVERNMENTS (the "SGVCOG"), in the above-captioned litigation (the "Action"). The

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to settle this Action without

further litigation, as set forth in the Settlement Agreement attached hereto as Exhibit 1 and
incorporated herein by reference. The Parties agree that this Court has jurisdiction to

-1STIPULATION AND PROPOSED ORDER

1

interpret and enforce this Stipulation and Order and Judgment and the Settlement Agreement
attached hereto as Exhibit 1, on which this Stipulated Order and Judgment are based.

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WHEREAS, Petitioner filed the above-captioned Action against the SGVCOG in the
Superior Court of the State of Califomia, County of Los Angeles (the "Action"), allegingThat Defendant has violated and is likely to continue to violate the Ralph M. Brown Open Meeting Act (Government Code $ 54950, et seq., the "Brown Act") and the California Public Records Act (Government Code $ 6250, et seq.,the "CPRA");

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WHEREAS, the parties agree that the parties had a genuine dispute as to whether
some of the documents sought in this lawsuit were disclosable public records at the time they

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were requested;

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WHEREAS, the parties agree that unintentional violations of the Brown Act have
previously occurred;

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NOW THEREFORE, the Parties hereby stipulate to the proposed order and entry of
judgment in favor of Gil Aguirre and against San Gabriel Valley Council of Governments, as
set forth below:

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1. On January 23,2012,

after the

filing of this action, Respondent

released the Caltrans

Audit requested by Petitioner, which is the subject of this action. Should a request for
subsequent draft audits from Caltrans be made in the future, Respondent shall give notice to

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Caltrans of such request and release any such drafts within the time specified in the Public
Records

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Act unless Caltrans has obtained a court order or an agreement from the requesting

party that such drafts are not subject to release;

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2. It is stipulated that Respondent shall comply with Government
54957.5 by making all documents which are distributed to a majority

Code section
board

of governing

members in connection with a public meeting and which are not attorney-client privileged or

.,

STIPULATION AND PROPOSED ORDER

1

otherwise protected from disclosure by law, available to the public, upon request and without
delay;

2
3

3. It is stipulated

that Respondent shall comply with Government Code section 54956.9

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5

bV (1) only holding closed sessions where litigation is pending, "anticipated" as defined in this

section or the possibility of initiating litigation is being discussed, (2) releasing the facts and
circumstances

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of such litigation, when required by that section, and (3) limiting the closed

session discussion to items directly related to the litigation;

4. It is stipulated that Respondent shall comply with Government Code $ 54954.2 by

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posting agendas for every regular and special meeting

of the Governing Board and all

committees which are subject to the Brown Act, on Respondent's website and in one consistent

location, which is accessible to all members of the public twenty-four (24) hours a day except during any periods of reasonable interruptions for maintenance, upgrades, or not due to the fault

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of the Respondent. Nothing herein shall preclude Respondent from giving additional public
notice by posting agendas at the offices of member cities;

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5. It is stipulated

that Respondent shall comply with Government Code section 54954.2

by only discussing items at meetings which were either (a) listed on a posted agenda complying

with this section or (b) have come to the attention of the Board or Committee after the posting
of the agenda and which require immediate action;

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6.

It is stipulated that Respondent shall discuss and approve all contracts

and

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agreements, except

for settlement agreements as authorized under Government Code section

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54956.9, in open session, unless discussions are otherwise permitted in closed session by law;

7. It is stipulated that Respondent

shall comply with Government Code 54957.1 by

announcing all actions taken in closed session, as required by this section, in open session at the meeting in which the closed session was held, unless otherwise required by this section;

8. It is stipulated that Respondent shall comply with Government Code section
54953.3 by clearly noting on any sign sign-in sheet available at any public meeting, that

signing, registering, or completion

of said document is completely voluntary and that

all

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a

STIPULATION AND PROPOSED ORDER

I
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persons may attend the meeting regardless of whether a person signs, registers, or completes
said document;

9. It is stipulated that Respondent shall comply with Government Code section
54954.3 by

4
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allowing members of the public the opportunity to address the board or committee

on any item of interest to the public and within the jurisdiction of the Respondent, before or during the consideration of that item, , except as provided in this section.

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If

the Governing

Board requests that persons addressing the Board filI out a speaker card, such cards shall make
clear that such cards are not required, are voluntary, and a person has a right to speak without

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11

filling out a speaker

card;

10. It is stipulated that Respondent shall not include
attendance on any agenda;

any reference to a cost of

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11. It is stipulated that Respondent shall comply with Government
5a95a.2@)(1) by including the

Code section
agenda;

ADA information required by this section on every

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12. It is stipulated

that Respondent shall comply with Government Code section

54952(b) by ensuring that any advisory committees,

which currently exist or that

are created in

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the future, which are not required to comply with the Brown Act, are comprised solely of less

than a quorum of members of legislative body and do not have a continuing subject matter jurisdiction.

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The Court shall retain jurisdiction to resolve any disputes between the parties with
regard to this Stipulation and Order and judgment and the settlement agreement on which
based.

it

is

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Except as set forth in the stipulation and the agreement attached hereto as Exhibit A, each party shall bear its own costs, attorneys' fees and other expenses incuned in this action.

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DATED

GIL AGUIRRE Petitioner/Plaintiff
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STIPULATION AND PROPOSED ORDER

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a

DATED:

SAN GABRIEL VALLEY COUNCIT OF GOVERNMENTS

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By Angel Carrillo, President
Respondents/Defendants

o,f Governìng

Board

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APPROYED AS TO FORM:

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DATED:

LA\II OFFICES OF KETLY A. AVILES

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Kelly A. Aviles
Attorney for Petitionor GIL AGUIRRE

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DATED:

JONES &

MAYtrR

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Kimberly Hall Barlow Attorney for Respondent SAN GABRIEL VALLEY C.OIINCIL OF GOVERNMENTS

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Based on the foregoing Stipulation, the Settlement Agreemsnt attached hereto as Exhibit 1, and

for good cause appearing,

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28

IT IS

SO ORDERED:

DATED:
Honorable Luis Levin Judge of the Superior Court

-5STIPULATION AND PROPOSED ORDER

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