Dear Madam or Sir:
This is a formal request for public documents pursuant to California’s Public Records Act, Cal. Gov’t. Code § 6250, et seq. This request concerns the following properties: 3551 – 3561 S. Motor Ave., Los Angeles, 90034 (APN: 4314013010) and 3563 S. Motor Ave., Los Angeles, 90034 (herein after “the Properties”).
Based on this request, please provide access to and copies of the following records:
- Any and all records reflecting communications concerning the Properties from January 1, 2018 through the present.
- Any and all records reflecting communications between Michael Cohanzad, or any of his agents, and the City from January 1, 2018 through the present.
- Any and all records reflecting communications between Willowstream Exchange Company LLC, or any of its agents, and the City from January 1, 2018 through the present.
- Any and all records reflecting any proposed construction, demolition, or other work requiring a permit of any kind at the Properties that was submitted, initiated, requested or proposed at any time between January 1, 2018 at the present
- Any and all records reflecting any report, review, or analysis by City staff concerning the Properties that was requested, initiated, or completed at any time between January 1, 2018 at the present.
- Any and all records reflecting any report concerning actual or proposed conditions during any proposed demolition, construction, or rehabilitation at the Properties submitted to the City at any time between January 1, 2018 and the present.
- Any and all records reflecting any report, complaint, review, or analysis by City staff concerning Michael Cohanzad and/or Willowstream Exchange Company, LLC that was requested, initiated, or completed at any time between January 1, 2018 at the present.
- Any and all records that address any proposed or planned policies at the Properties during any planned construction at the Properties for accommodations for persons with disabilities under the Americans with Disabilities Act (42 U.S.C. §12101, et seq.); Section 504 of the Rehabilitation Act (28 U.S.C. §794a, et seq.); and/or Fair Housing Act (42 U.S.C. 3601, et seq.).
Each paragraph and sub-paragraph above should be considered a separate request. For each public document produced in response to these requests, please identify the specific request to which it is responsive. If the City does not possess any documents responsive to a particular request, please indicate that in your response.
Documents produced in response to one request need not be produced again in response to another. However, where a document is responsive to more than one request, please state each request to which it is responsive.
If any records are claimed to be exempt from disclosure, we request that you redact the exempt content and disclose the rest, consistent with Cal. Gov’t Code § 6253(a). Additionally, please provide a written response that describes with specificity each record that is being withheld and the claimed reason for exemption.
As you are likely aware, the appropriate time for a response to a request to receive copies of public records is ten (10) days. Cal. Gov’t Code § 6253(c). However, if a full production within ten days is not feasible, we request a rolling production of documents as they become available.
We have attempted to be as specific as we can in designating public records without having access to the records themselves, but if you find any of these requests insufficiently detailed, we request that you provide the assistance required by Cal. Gov’t Code § 6253.1, including but not limited to “assisting the member of the public to identify records and information that are responsive to the request or to the purpose of the request.”
Please note that Disability Rights Advocates is a non-profit organization requesting these documents in order to further the public interest. Accordingly, we ask that you consider waiving any copying fees for production of the documents pursuant to North Country Parents v. Dept. of Education, 23 Cal. App. 4th 144 (1994). If you choose not to waive such costs, we will reimburse you for the direct costs of copying. Please contact us in advance should the costs be expected to exceed $150.
We would prefer to receive documents by e-mail, which should reduce any copying costs. Please send all responsive documents via email to firstname.lastname@example.org Cal. Gov’t Code § 6253.9 (providing for production of documents in electronic format). If the documents are only available in hard copy please mail them to:
Disability Rights Advocates
2001 Center St, Fourth Floor
Berkeley, California 94704
If you have any questions, please contact me via email at email@example.com or via telephone at (510) 665-8644.