P.O. Box 432181 Los Angeles, CA 90043 Phone & Fax: (323) 761-6435 info@crenshawsubway.org www.CrenshawSubway.

org
June 6, 2013 Los Angeles County Metropolitan Transportation Authority ATTN: Records Management Center One Gateway Plaza Los Angeles, CA 90012 Re: Public Records Act Request Dear Los Angeles County Metropolitan Transportation Authority: I am a representative of the Crenshaw Subway Coalition (CSC). CSC is a California 501(c)3 nonprofit corporation led by stakeholders directly impacted by the Crenshaw/LAX Light Rail Transit Project. CSC 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 RELATE TO we mean consisting of, referring to, reflecting upon, supporting, describing, contradicting, concerning, containing, constituting, discussing, embodying, memorializing, evidencing, mentioning or commenting on the matter discussed. By YOU we mean the addressee on page one of this letter. By MTA we mean Los Angeles County Metropolitan Transportation Authority, its agents, employees, representatives and anyone else acting on YOUR behalf. By FTA we mean the United States Department of Transportation Federal Transit Administration, its agents, employees, representatives and anyone else acting in its behalf. By CRENSHAW LINE we mean the proposed Los Angeles County Metropolitan Transportation Authority light rail Crenshaw-to-LAX Transit Corridor project. By CRENSHAW TRANSIT PARTNERS we mean the joint venture led by Fluor, Balfour Beatty, and S.A. Healy that is a finalist for the CRENSHAW LINE design-build contract, its agents, employees, representatives and anyone else acting in its behalf. By SKANSKA-TRAYLOR-KIEWIT we mean the joint venture led by Skanska US Civil West California District, Traylor Bros., and Kiewit Infrastructure West Co. that is a finalist for the CRENSHAW LINE design-build contract, its agents, employees, representatives and anyone else acting in its behalf. By URS-DRAGADOS-FLATIRON we mean the joint venture led by URS Corporation, Dragados USA, and Flatiron Construction that is a finalist for the CRENSHAW LINE design-build contract, its agents, employees, representatives and anyone else acting in its behalf.

SENT VIA EMAIL TO: leahya@metro.net & rmc@metro.net

Crenshaw Subway Coalition is a California 501(c)3 nonprofit, led by a collaboration of South L.A. neighborhood associations, business owners & community leaders.

PRA TO LACMTA JUNE 6, 2013

By WALSH-SHEA we mean the joint venture led by Walsh Construction Company and J.F. Shea Construction that is a finalist for the CRENSHAW LINE design-build contract, its agents, employees, representatives and anyone else acting in its behalf. By ALTERNATIVE TECHNICAL CONCEPTS we mean proposed changes to the projects base design, project scope, design criteria or construction criteria. By PARK MESA HEIGHTS we mean the section of the CRENSHAW LINE from the intersection of 48th Street and Crenshaw Boulevard in the City of Los Angeles, California to the intersection of 59th Street and Crenshaw Boulevard in the City of Los Angeles, California. 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 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 are 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 exceeds $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
1

Italics and/or boldface in quoted passages indicate that emphasis has been supplied.

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We request that no DOCUMENTS be stapled together. We request DOCUMENTS in response to Requests be grouped together and labeled accordingly. If the DOCUMENTS are available in electronic format, please email them to dg@crenshawsubway.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 from December 31, 2011 to June 6, 2013 that RELATE TO ALTERNATIVE TECHNICAL CONCEPTS for the CRENSHAW LINE. 2. All DOCUMENTS from December 31, 2011 to June 6, 2013 that RELATE TO ALTERNATIVE TECHNICAL CONCEPTS for the CRENSHAW LINE submitted by CRENSHAW TRANSIT PARTNERS. 3. All DOCUMENTS from December 31, 2011 to June 6, 2013 from CRENSHAW TRANSIT PARTNERS to MTA that RELATE TO ALTERNATIVE TECHNICAL CONCEPTS for the CRENSHAW LINE. 4. All DOCUMENTS from December 31, 2011 to June 6, 2013 from MTA to CRENSHAW TRANSIT PARTNERS that RELATE TO ALTERNATIVE TECHNICAL CONCEPTS for the CRENSHAW LINE. 5. All DOCUMENTS from December 31, 2011 to June 6, 2013 that RELATE TO ALTERNATIVE TECHNICAL CONCEPTS for the CRENSHAW LINE submitted by SKANSKA-TRAYLOR-KIEWIT. 6. All DOCUMENTS from December 31, 2011 to June 6, 2013 from SKANSKA-TRAYLOR-KIEWIT to MTA that RELATE TO ALTERNATIVE TECHNICAL CONCEPTS for the CRENSHAW LINE. 7. All DOCUMENTS from December 31, 2011 to June 6, 2013 from MTA to SKANSKA-TRAYLOR-KIEWIT that RELATE TO ALTERNATIVE TECHNICAL CONCEPTS for the CRENSHAW LINE. 8. All DOCUMENTS from December 31, 2011 to June 6, 2013 that RELATE TO ALTERNATIVE TECHNICAL CONCEPTS for the CRENSHAW LINE submitted by URS-DRAGADOS-FLATIRON. 9. All DOCUMENTS from December 31, 2011 to June 6, 2013 from URS-DRAGADOS-FLATIRON to MTA that RELATE TO ALTERNATIVE TECHNICAL CONCEPTS for the CRENSHAW LINE. 10. All DOCUMENTS from December 31, 2011 to June 6, 2013 from MTA to URS-DRAGADOS-FLATIRON that RELATE TO ALTERNATIVE TECHNICAL CONCEPTS for the CRENSHAW LINE. 11. All DOCUMENTS from December 31, 2011 to June 6, 2013 that RELATE TO ALTERNATIVE TECHNICAL CONCEPTS for the CRENSHAW LINE submitted by WALSH-SHEA. 12. All DOCUMENTS from December 31, 2011 to June 6, 2013 from WALSH-SHEA to MTA that RELATE TO ALTERNATIVE TECHNICAL CONCEPTS for the CRENSHAW LINE. 13. All DOCUMENTS from December 31, 2011 to June 6, 2013 from MTA to WALSH-SHEA that RELATE TO ALTERNATIVE TECHNICAL CONCEPTS for the CRENSHAW LINE. 14. All DOCUMENTS from December 31, 2011 to June 6, 2013 from FTA to MTA that RELATE TO ALTERNATIVE TECHNICAL CONCEPTS for the CRENSHAW LINE.

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15. All DOCUMENTS from December 31, 2011 to June 6, 2013 from MTA to FTA that RELATE TO ALTERNATIVE TECHNICAL CONCEPTS for the CRENSHAW LINE. 16. All DOCUMENTS from December 31, 2011 to June 6, 2013 that RELATE TO CRENSHAW LINE delays for undergrounding PARK MESA HEIGHTS. 17. All DOCUMENTS from December 31, 2011 to June 6, 2013 that RELATE TO CRENSHAW LINE cost increases for undergrounding PARK MESA HEIGHTS. Contact Information Please direct all requests for further information in a timely manner to: Damien Goodmon EMAIL: dg@crenshawsubway.org PHONE: (323) 761-6435 Sincerely, /S/ DAMIEN GOODMON

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