CITIZENS' CAMPAIGN TO FIX THE EXPO RAIL LINE

Led by Save Leimert, Expo Communities United & Baldwin Hills/Crenshaw Homeowners' Coalition
P. O. Box 781267 • Los Angeles, CA 90016 • Phone & Fax: (323) 761-6435 • www.FixExpo.org

July 24, 2008

Los Angeles County Metropolitan Transportation Authority

ATTN: Records Management Center
One Gateway Plaza
Los Angeles, CA 90012

Re: Public Records Act Request of July 24, 2008

Dear Los Angeles County Metropolitan Transportation Authority:

I represent the Citizens' Campaign to Fix the Expo Rail Line (“Fix Expo”). Fix Expo is a coalition of homeowners
associations, community-based organizations, block clubs and concerned parents, teachers, students and citizens
including Save Leimert Neighborhood Coalition, Expo Communities United and Baldwin Hills-Crenshaw Homeowners
Coalition. Fix Expo hereby makes the following requests under the California Public Records Act, Government Code §
6250 et seq. (the “CPRA”), with reference to the following definitions and statutes:

Definitions
“DOCUMENTS” is defined to have the same meaning as the term “Writing” is defined in Evidence Code § 250:
“handwriting, typewriting, printing, photostating, photographing, photocopying, transmitting by electronic mail or
facsimile, and every other means of recording upon any tangible thing, any form of communication or representation,
including letters, words, pictures, sounds, or symbols, or combinations thereof, and any record thereby created,
regardless of the manner in which the record has been stored.”

By “BLUE LINE” we mean the Los Angeles County Metropolitan Transportation Authority light rail Blue Line that travels
from Los Angeles to Long Beach.

By “GOLD LINE” we mean the Los Angeles County Metropolitan Transportation Authority light rail Gold Line that travels
from Los Angeles to Pasadena.

By “EXPO LINE” we mean the Los Angeles County Metropolitan Transportation Authority light rail project extending from
the Metro Rail Station at 7th Street and Flower Street in the City of Los Angeles to the downtown of the City of Culver
City.

By “INTERNAL” we mean any “DOCUMENT,” including e-mail, sent from one employee to another within a named agency
or organization.

By “REPRESENTATIVES” we mean anyone employed or contracted as a third party consultant or advisor, or

representative or agent.

By “YOU” we mean “the addressee on page one of this letter.”

Statutes
CRPA § 6253.1 requires you to assist the public in making a focused and effective request by: (1) identifying records and
information responsive to the request, (2) describing the information technology and physical location of the records, and
(3) providing suggestions for overcoming any practical basis for denying access to the records or information sought.

In the event YOU deny any request or part of any particular request, it is required to provide a written response
describing the legal authority on which YOU rely. CPRA § 625(c) states in part that YOU “shall properly notify the person
making the request of the determination and the reasons therefore.”1

1
Italics and/or boldface in quoted passages indicate that emphasis has been supplied.
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Section 6253(d) further provides that nothing in CPRA “shall be construed to permit an agency to delay or obstruct the
inspection or copying of public records. The notification of denial of any request for records required by Section 6255
shall set forth the names and titles or positions of each person responsible for the denial.”

In the event that YOU claim that one or more exemptions are applicable, CPRA § 6255(a) states that the “agency shall
justify withholding any record by demonstrating that the record in question is exempt under expressed provisions of this
chapter or that the facts of the particular case the public interest served by not disclosing the record clearly outweighs
the public interest served by disclosure of the record.” By virtue of this provision, YOU are required to justify withholding
any record with particularity as to “the record in question.”

Thus, when YOU respond to this request, please clearly indicate in writing, pursuant to Section 6255(b), as follows: (1) if
YOU is withholding any documents; (2) if YOU are redacting any documents; (3) what documents YOU are withholding
and/or redacting; and (4) the alleged legal grounds for either withholding and/or redacting any particular document.

Of course, if documents contain material covered by an exemption but also contain material that is not covered by an
exemption, YOU must redact the document, and produce the portion that is not claimed to be exempt.

Also, for each document being withheld, please specify whether exemptions are being claimed as to each record in
question, what exemptions are being claimed, and provide sufficient detail as to each such withheld document so that we
may test or challenge the alleged exemption by way of a petition for a writ of mandate. In this regard, please note that
categorical, boilerplate objections are insufficient.

Costs
If the copying costs do not exceed $25.00, please make the copies, charging only actual costs. If the copying costs
exceed $25.00, please contact the undersigned in advance so that we may arrange a time and place for inspection of the
documents.

Time for Compliance

As required by CPRA § 6253, please respond to the following requests within the next ten days.

Format
We request that NO DOCUMENTS BE STAPLED TOGETHER.
Do not staple any documents together.

If the documents are available in electronic format, please email them to dg@fixexpo.org.

Consequences for Non-Compliance

If YOU do not properly and promptly disclose all non-exempt documents responsive to the following CPRA requests, we
may file a petition for a writ of mandate. In that event, we will seek an award of attorney fees pursuant to CPRA §
6259(d).

Requests
1. All DOCUMENTS, memoranda or other documents of any kind whatsoever (including those printed, typed,
handwritten, or computer-generated) by and sent to YOU and YOUR REPRESENTATIVES related to EXPO LINE
accident potential, likelihood or predictability.

2. All YOUR INTERNAL DOCUMENTS, memoranda or other documents of any kind whatsoever (including those
printed, typed, handwritten, or computer-generated) related to the EXPO LINE accident potential, likelihood, or
predictability.

3. All DOCUMENTS, memoranda or other documents of any kind whatsoever (including those printed, typed,
handwritten, or computer-generated) by and sent to YOU and YOUR REPRESENTATIVES related to BLUE LINE
accident potential, likelihood or predictability.

4. All YOUR INTERNAL DOCUMENTS, memoranda or other documents of any kind whatsoever (including those
printed, typed, handwritten, or computer-generated) related to the BLUE LINE accident potential, likelihood, or
predictability.

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 5. All DOCUMENTS, memoranda or other documents of any kind whatsoever (including those printed, typed,
handwritten, or computer-generated) by and sent to YOU and YOUR REPRESENTATIVES related to the Farmdale
Avenue crossing of EXPO LINE.

6. All YOUR INTERNAL DOCUMENTS, memoranda or other documents of any kind whatsoever (including those
printed, typed, handwritten, or computer-generated) related to the Farmdale Avenue crossing of EXPO LINE.

7. All DOCUMENTS, memoranda or other documents of any kind whatsoever (including those printed, typed,
handwritten, or computer-generated) by and sent to YOU and YOUR REPRESENTATIVES related to the Western
Avenue crossing of EXPO LINE.

8. All YOUR INTERNAL DOCUMENTS, memoranda or other documents of any kind whatsoever (including those
printed, typed, handwritten, or computer-generated) related to the Western Avenue crossing of EXPO LINE.

9. All DOCUMENTS, memoranda or other documents of any kind whatsoever (including those printed, typed,
handwritten, or computer-generated) by and sent to YOU and YOUR REPRESENTATIVES related to the Harvard
Blvd crossing of EXPO LINE.

10. All YOUR INTERNAL DOCUMENTS, memoranda or other documents of any kind whatsoever (including those
printed, typed, handwritten, or computer-generated) related to the Harvard Blvd crossing of EXPO LINE.

11. All DOCUMENTS, memoranda or other documents of any kind whatsoever (including those printed, typed,
handwritten, or computer-generated) by and sent to YOU and YOUR REPRESENTATIVES related to BLUE LINE
accidents involving individuals under the age of 25.

12. All YOUR INTERNAL DOCUMENTS, memoranda or other documents of any kind whatsoever (including those
printed, typed, handwritten, or computer-generated) related to BLUE LINE accidents involving individuals under
the age of 25.

13. All Rail Incident Management System reports and logs related to BLUE LINE accidents and incidents.

14. All Rail Incident Management System reports and logs related to GOLD LINE accidents and incidents.

15. All TransitSafe reports and logs related to BLUE LINE accidents and incidents.

16. All TransitSafe reports and logs related to GOLD LINE accidents and incidents.

17. A list of all claims and lawsuits related to BLUE LINE accidents and incidents.

18. A list of all claims and lawsuits related to GOLD LINE accidents and incidents.

19. All legal status reports on all claims and lawsuits related to BLUE LINE accidents and incidents.

20. All legal status reports on all claims and lawsuits related to GOLD LINE accidents and incidents.

Contact Information
Please direct all requests for further information in a timely manner to:

Damien Goodmon EMAIL: xx@xxxxxxx.xxx PHONE: (xxx) xxx-xxxx

Sincerely,

____________________________________________
Damien Wesley Clark Goodmon
Coordinator

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