ASTUNO LAW PC A PROFESSIONAL CORPORATION

October 2, 2019

Sent Via Electronic Portal

Public Records Management City Clerk

202 C St.,

San Diego, CA 92101

To Whom It May Concern:

Pursuant to the California Public Records Act (Gov. Code, §§ 6250 to 6270.5), we request the following documents described below:

1. “DOCUMENTS” means any and all writings as defined in California Evidence Code § 250. This includes without limitation all communications and writings of every kind, letters, telegrams, telexes, memoranda, reports, studies, calendar or diary entries, telephone logs, maps, pamphlets, drafts, notes, graphs, charts, tabulations, analyses, statistical or informational accumulations, accounting records of any kind, audio recordings, photographs, film impressions, videotapes, microfilm, microfiche, vu-graphs, computer disks, computer programs, software, magnetic tapes, or any medium containing computer programs, software, or data, and sounds or mechanical reproductions, and all compilations of the foregoing.

2. “ELECTRONIC” means relating to technology having electrical, digital, magnetic, wireless, optical, electromagnetic, or similar capabilities. 

3. “ELECTRONICALLY STORED INFORMATION” means information that is stored in an ELECTRONIC medium, including without limitation disks, including hard disks and floppy disks, CD-ROMs, DVDs, network servers, shared servers, computers, magnetic tape, back-up tape, voicemail, and PDAs, whether currently on your premises or otherwise (e.g., at an employee’s home or remote office).

4. “COMMUNICATIONS” means all e-mails, phone conversations, text messages, and voicemails.

5. “CITY” the City of San Diego and any of its agents, representatives, contractors, or employees. 

Documents and Communications: Please provide the following documents and communications, along with any and all other evidence relevant to the basis for this request.

6. ALL DOCUMENTS relating to Kearny Industrial Park redevelopment plans.

7. ALL DOCUMENTS relating to 7640 Clairemont Mesa Boulevard San Diego, CA 92111 and redevelopment plans or proposals.

8. All COMMUNICATIONS relating to Kearny Industrial Park and site re-development from January 2013 to Present.

9. All COMMUNICATIONS relating to Kearny Industrial Park and zoning from January 2013 to Present.

10. All COMMUNICATIONS between John Hancock Real Estate and the City of San Diego including any agents, contractors, acting on behalf of the city relating to redevelopment of 7640 Clairemont Mesa Boulevard San Diego, CA 92111 from January 2011 to Present.

In furtherance of your obligations under Gov. Code, § 6253 and to resolve this matter as expeditiously as possible, we request that you provide a written response to this request within ten (10) days of receipt. In your written response, please identify any fees or costs that will be incurred in complying with this request and how you would like to provide the requested records. In particular, please notify us immediately if the total charges for responding to this request will exceed $250.00.

If you have any questions regarding the foregoing, please do not hesitate to call me. Thank you for your assistance in this matter.

Very Truly Yours,

James J. Astuno Jr. Attorney at Law Astuno Law PC

JJA