HomeMy WebLinkAboutPRR21296 Ernst Law - Highland/Hwy1DON A. ERNST
NIGEL A. WHITEHEAD
TERRY KILPATRICK
December 06, 2021
CITY CLERK'S OFFICE
990 Palm St.
San Luis Obispo, CA 93401
Dear Sir or Madam:
ERNST LAW GROUP
A Law Corporation
1020 Palm St.
San Luis Obispo, CA 93401
Tel:(805) 541-0300
Fax:(805) 541-5168
PUBLIC RECORDS ACT REQUEST
TAYLOR ERNST
CHRISTOPHER D. EDGINGTON
JOHN C. CARLSON
Pursuant to the California Public Records Act (Government Code § 6250, et seq), I am
writing to request copies of the following, which we understand to be held by your agency:
All records of complaints or concerns made by any individual or organization
regarding the safety of the intersection of Highland Drive and State Route 1 in San
Luis Obispo. Among other things we would appreciate obtaining copies of any
document (letter, email, social media post, etc.) that contains complaints or safety
concerns regarding the configuration of the intersection, the speed limits on State
Route 1, sight distance concerns, conflicts between cars and pedestrians, or the
increase of motor vehicle, pedestrian, and bicycle use in the area.
2. All records containing potential modifications of the intersection of Highland Drive
and State Route 1. In particular, it is our understanding that the City of San Luis
Obispo has provided CalTrans with one or more documents discussing the dangerous
condition of the intersection and that it proposed various modifications.
Our office represents the family of Finn Hartford, the young man who was killed in a
three -car collision at the intersection of Highland Drive and State Route 1 on Saturday,
September 11, 2021. It is important that we identify all public records regarding the safety of the
intersection and the surrounding area.
Pursuant to Government Code Section 6253.1, subdivisions (a)(I)-(3), your agency is
required to assist us if there are any ambiguities or difficulties fulfilling our request. To the
extent reasonable under the circumstances, we ask that your agency:
• Assist our office in identifying records that are responsive to
the request and/or its purpose;
DEC 0 9 2021
SLO CITY CLERK
December 6, 2021
Page two
• Describe the information technology and physical location in
which the records exist: and
Provide suggestions for overcoming any practical basis for
denying access to the records.
If you require any further information to process and/or comply with the above requests,
or if we can provide any clarification that will expedite your attention to the requests, please
contact:
Terry Kilpatrick, Ernst Law Group, (805) 541-0300, tk@ernstlawgroup.com.
We ask that you notify Mr. Kilpatrick of any duplication costs exceeding $300 before
you duplicate the records so that we may decide which records we want copied. You are
otherwise authorized to prepare the copies and we will reimburse you for the costs.
Thank you for your time and attention to this matter.
Since 0y,
Terry ilpat c
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Subject:REVISE: Records Request RESPONSE: PRR21296 Ernst Law - Highland/Hwy1
BELOW LIST A REVISE FOR ITEM 1
From: Scott Juretic <sjuretic@sbcglobal.net>
Sent: Tuesday, April 5, 2022 8:16 AM
To: Christian, Kevin <kchristi@slocity.org>
Cc: CityClerk <CityClerk@slocity.org>; City_Attorney <City_Attorney@slocity.org>; tk@ernstlawgroup.com
Subject: Re: Records Request RESPONSE: PRR21296 Ernst Law - Highland/Hwy1
This message is from an External Source. Use caution when deciding to open attachments, click links, or respond.
Dear Mr. Christian,
Thank you for your help in this matter. Based upon the City's supplemental responses (entitled
"Responsive 21296 Priority), we have identified some specific requests for additional documents. I
wish to know whether the City will provide them in the Ernst Law Group's present PRA request or
whether we will need to submit a new one. I am available almost any time to discuss this with you in
order to expedite the process.
1. The City has provided an email dated September 30, 2021 from Diane Dostalek of Caltrans to
Luke Schwartz, City Transportation Director. The email is found on pages 45-46, 48-49, 50-51, 54-55
and 57-58 of the City's supplemental responses. The email indicates that the City has a permit to
plant and maintain vegetation in the Highway 1 median north of Highland Drive. Ms. Dostalek
identified the precise location in a Google Maps satellite image, and attached a photo of the specific
median and vegetation. We request all permits issued to the City of SLO that allowed it to plant and
maintain vegetation in that median.
2. We further request all City work orders regarding the planting and maintaining of vegetation in the
median identified in Ms. Dostalek's email of September 30, 2021.
3. On November 18, 2021, City Director of Public Works Matt Horn emailed Michael Britton at
Caltrans, "I'm getting lots of correspondence on SR 1 at Highland not being safe." The email is
located on page 12 of your supplemental responses. We request all correspondence and complaints
received by the City regarding safety of the SR 1 - Highland intersection.
4. We further request all public comments regarding the SR 1- Highland intersection made at the SLO
City Council meeting of October 5, 2021, as referenced in a City email to resident Genevieve Czech
on September 27, 2021, located on page 32 of the City's supplemental responses.
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