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1 || DENNIS J. HERRERA, sate Bar #139669 ELECTRONICALLY City Attorney 2|| BLIZABETH SALVESON, sue sur ds3788 FILED Chief Labor Attorney Supa Co of Caton, 3 || RAFAL OFIERSKL, state Bar #194798 er aes JENICA MALDONADO, state Bar #266982 MAR 18 2015 4 || Deputy City Attorneys Clerk of the Court 1390 Market Street, Fifth Floor BY. MAURA RAMIREZ 5 |] San Francisco, California 94102-5408 ‘Deputy Clerk Telephone: (415) 554-3915 6 || Eacsimile: (413) 554.4248 E-Mail: jenicamaldonado@sfgov.org 1 8 Attorneys for Respondent 9 || CITY AND COUNTY OF SAN FRANCISCO 10 ‘SUPERIOR COURT OF THE STATE OF CALIFORNIA u COUNTY OF SAN FRANCISCO 12 UNLIMITED JURISDICTION 13 SAN FRANCISCO DEPUTY SHERIFFS’ —_| Case No. CPF 14-514030 14] ASSOCIATION, 1s Petitioner, ANSWER TO VERIFIED PETITION FOR ‘WRIT OF MANDATE [CCP § 1085] 16 vs. 17] CITY & COUNTY OF SAN FRANCISCO, AND DOES 1 THROUGH 10, INCLUSIVE, Respondents. ‘ANSWER TO VERIFIED PET. FOR WRIT OF MANDATE ‘abo 201 8 SOTORVORDIID doe CASE NO. 14514030 wie en 10 u 2 13 14 15 16 7 18 19 20 21 2 2B 4 25 2 28 DEFENDANT CITY AND COUNTY OF SAN FRANCISCO (“Respondent” or “City”) hereby answers the Verified Petition for Writ of Mandate [CCP § 1085] filed by Petitioner San Francisco Deputy Sheriffs’ Asso ion (“Petitiones” or “Association”). (PARTIES 1. Answering paragraph 1, Respondent admits the allegations of this paragraph, 2. Answering paragraph 2, Respondent admits the allegations of this paragraph, 3. Answering paragraph 3, Respondent admits the allegations of this paragraph. 4, Answering paragraph 4, Respondent admits the allegations of this paragraph. 5. Answering paragraph 5, Respondent admits the allegations of this paragraph to the extent that it is the employer of each of Petitioner's members and is subject to the MMBA and its own City Charter and Civil Service Rules, Respondent otherwise currently lacks sufficient information to form a belief as to the truth of the remaining allegations and, and on this basis, denies each and every remaining allegation in paragraph 5. 6. Answering paragraph 6, Respondent admits the allegations of this paragraph. 7. Answering paragraph 7, Respondent currently lacks sufficient information to form a belief as to the truth of the allegations and, and on this basis, denies each and every allegation in paragraph 7. COLLECTIVE BARGAINING RELATIONSHIP BETWEEN THE PARTIES} 8. Answering paragraph 8, Respondent admits that the City and SFDSA are, as a general ‘matter, governed by the MMBA. Respondent otherwise denies each and every remaining allegation in Paragraph 8 9. Answering paragraph 9, the MMBA speaks for itself. Respondent denies each and every remaining allegation in paragraph 9, 10. Answering paragraph 10, the Government Code section cited speaks for itself, Respondent denies each and every remaining allegation in paragraph 10. 11. Answering paragraph 11, the Government Code section cited speaks for itself, Respondent denies each and every remaining allegation in paragraph 11. 1 "ANSWER TO VERIFIED PET. FOR WRIT OF MANDATE ‘bor IDOTSSITONOOD doe CASE NO. 14-514030 aaueron 10 ul 1B 14 15 16 7 18 19 20 2 22 23 25 26 a 28 12, Answering paragraph 12, the Government Code section cited speaks for itself Respondent denies each and every remaining allegation in paragraph 12. 13, Answering paragraph 13, the cases cited speak for themselves. Respondent denies each and every remaining allegation in paragraph 13. 14, Answering paragraph 14, the Government Code section cited speaks for itself, Respondent denies each and every remaining allegation in paragraph 14, 15. Answering paragraph 15, the California Code of Regulations section cited speaks for itself. Respondent denies each and every remaining allegation in paragraph 15. 16. Answering paragraph 16, the San Francisco Sheriff's Department Work Rule 03-49— which Petitioner fails to submit with its Petition—speaks for itself, Respondent denies each and every remaining allegation in paragraph 16. 17. Answering paragraph 17, the Government Code section cited speaks for itself. Respondent denies each and every remaining allegation in paragraph 17. 18 Answering paragraph 18, the Government Code section cited speaks for itself Respondent denies each and every remaining allegation in paragraph 18, 19. Answering paragraph 19, the Government Code section cited speaks for itself. Respondent denies each and every remaining allegation in paragraph 19. 20. Answering paragraph 20, the California Code of Regulations section cited speaks for itself. Respondent denies each and every remai allegation in paragraph 20. 21. Answering paragraph 21, the California Code of Regulations section cited speaks for itself, Respondent denies each and every remaining allegation in paragraph 21 22. Answering paragraph 22, the section of the San Francisco Administrative Code cited speaks for itself. Respondent denies each and every remaining allegation in paragraph 22. 23. Answering paragraph 23, the California Code of Regulations section cited speaks for itself. Respondent denies each and every remaining allegation in paragraph 23. 2 "ANSWER TO VERIFIED PET, FOR WRIT OF MANDATE ‘bor a015 SOTO TDdoe CASENO. 14-514030