LAW OFFICES OF I<ELLY A.

AVILES
August 26, 2014
Carolina R. Padilla
City Clerk
City of Colton
650 N. La Cadena Drive
Colton, CA 92324
(via email and U.S.mailcpadilla@ci.colton.ca.us)
Re: California Public Records Request,
Pursuant to Government Code 6250 et seq.
Dear Ms. Padilla:
Pursuant to the California Public Records Act, our office is requesting copies of the following
documents on behalf of our client, Californians Aware. In that regard, please direct all further
communications regarding this matter to our office.
The purpose of this request is to learn the reasons for the abrupt departure of City Manager Stephen
Compton. In that regard, we request that you assist us in locating all public records which would
shed light on this issue. As I am sure you are aware, pursuant to Government Code 6253.1, the
City has a duty to assist us in locating records by identifying records and information that are
responsive to the "purpose of the request."
This should include, but is not limited, to the following records:
1. Any contract between the City and Mr. Compton from 2013 to present, including all
amendments, restatements, revisions, or the like;
2. Any claim or threat of litigation made by Mr. Compton;
3. Any communication from legal counsel for Mr. Compton;
4. Any communications regarding Mr. Compton's resignation, separation, or termination;
5. Any severance or separation agreement between the City and Mr. Compton;
6. Any "complaints and charges" against Mr. Compton from 2013 to the present;
7. Any personnel investigation done by the City, or at the direction of the City, relating to Mr.
Compton from May 2014 to the present;
8. All emails or correspondence between Mr. Compton and any City Council Member from
May 2014 to the present;
9. Any emails or correspondence to or from any City Council Member regarding the City
Manllger &om Mlly 2014 to the present; llnd,
1502 Foothill Boulevard, Suite 103-140. La Verne, California 91750
Phone: (909) 991-7560 Fax: (909) 991-7594 Email: kaviles@opengovlaw.com
Law Offices of Kelly A. Aviles
Carolina Padilla
August 26, 2014
Page 2
10. All weekly reports, sometimes referred to as Friday Reports, Weekly Reports, Weekly
Memos, or Weekly Updates, from the City Manager to the City Council from October 2013
to the present.
In addition, it has been reported by the Press Enterprise, that Mr. Compton had been conducting
investigations into the city's finances at the time he was placed on leave. Further, the Press
Enterprise reports that Mr. Compton claims to have been investigating members of the City
Council.
Therefore, we also requests copies of all documentation of any investigation done or initiated by Mr.
Compton into the City's finances or into members of the City Council.
If you claim that any of the responsive requested records are not disclosable, please provide us with
a written response providing the legal justification for your decision, as required by Government
Code section 62SS(a)-(b), which states:
The agency shall justify withholding any record by demonstrating that the record in
question is exempt under express provisions of this chapter or that on 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.
A response to a written request for inspection or copies of public records that
includes a determination that the request is denied, in whole or in part, shall be in
writing.
Thank you for your prompt attention to this matter.
Sincerely,

Kelly Aviles
"-
cc: Marco Martinez, Assistant City Attorney, Best, Best & Krieger (via email only to
marco.martinez@bbklaw.com)