petition - exhibits

Dillard v. Alameda County Associated Community Action Program Governing Board

EXHIBIT AVERIFIED PETITION FOR WRIT OF MANDATE


EXHIBIT BVERIFIED PETITION FOR WRIT OF MANDATE

Bylawsof the

Governing Boardof the

Associated Community Action Program of Alameda County

CONTENTSSubject: Page Number

Article I: Article II: Article III: 3.1 3.2 3.3 Article IV: Article V: 5.1 Article VI: 6.1 6.2 6.3 6.4 Article VII: Article VIII: Article IX:

Name and Territory................................................................1 Purpose and Goal..................................................................1 Membership of the Governing Board.....................................1 Membership .....................................................................................1 Size of Board....................................................................................1 Term of Office .................................................................................2 Powers and Duties of the Governing Board ..........................2 Officers of the Governing Board and Duties..........................4 Officers ............................................................................................4 Meetings and Rules ..............................................................4 Regular Meetings .............................................................................4 Special Meetings..............................................................................4 Executive Sessions...........................................................................4 General Rules for All Meetings .......................................................5 Committees ...........................................................................5 Amendments to the Bylaws...................................................5 Severability ...........................................................................6

ARTICLE I Name and TerritoryThe Associated Community Action Program (ACAP) is the Community Action Agency for Alameda County, with the exception of those areas lying within the city limits of Oakland and Berkeley. The ACAP Governing Board (GB) is comprised of the parties signatory to the Joint Powers Agreement establishing a Community Action Agency in Alameda County, dated September 14, 1976 and those signatory to subsequent amendments thereto, and operates pursuant to it and the Economic Opportunity Act of 1964, as amended, and the Headstart, Economic Opportunity, and Community Partnership Act of 1974.

ARTICLE II Purpose and GoalThe purposes for which ACAP was created are those enumerated in the aforementioned ACAP Joint Powers Agreement (JPA).

ARTICLE III Membership of the Governing Board3.1 MEMBERSHIP

The agency shall be governed by a Governing Board composed of one elected official appointed by and from the legislative body of each of the parties signatory to the ACAP Joint Powers Agreement. Each signatory shall also appoint an alternate board member who shall be an elected member of the legislative body appointing him/her, who shall perform the duties of the member in the absence of said board members. Both such appointments shall be consistent with applicable federal nepotism regulations. Board members and/or their alternates will be seated after receiving an orientation by ACAP staff.

3.2

SIZE OF THE BOARD

The Governing Board shall have as many members as the number of participating parties signatory to the ACAP Joint Powers Agreement.

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3.3

TERM OF OFFICE

The members and officers of the Governing Board shall serve for terms of one year, beginning in January of each year, without limitation as to reappointment.

ARTICLE IV Powers and Duties of the Governing BoardA. Each member of the ACAP Governing Board of Directors (GB), together with other members of the board, is legally and ethically responsible for all activities of the Joint Powers Authority of ACAP. All members of the board share in a joint and collective authority, which exists and can only be exercised WHEN THE GROUP IS IN SESSION AND A QUORUM IS PRESENT. The ACAP GB is the principal policy making unit of Joint Powers Authority of ACAP. As such, the ACAP GBs responsibilities include creating and overseeing the overall structural organization of the JPA, overseeing and supporting ACAPs efforts to obtain private and public funds, and making overall ACAP policy decisions. Being FIRST, primarily, and fundamentally a POLICY MAKING BODY, as distinguished from that portion of the Joint Powers Authority charged with overseeing, administering, implementing and executing policy (i.e., the Community Action Board, the Executive Director and his/her staff). This means that while it may observe, question and recommend items regarding the operation of all functions of the organization, it should refrain, insofar as possible, from direct participation in those functions. C. The ACAP GB is autonomous, bound only by its legal responsibilities under its charter, bylaws and its contractual obligations to funding sources. Implied, however, is an obligation to the citizens of the community to accomplish the objectives as stated in the charter. THE AUTHORITY OF THE BOARD RESULTS FROM ITS GROUP ACTION. NO INDIVIDUAL BOARD MEMBER HAS ANY AUTHORITY OVER THE ORGANIZATION. D. The GB shall create and organize an Administering Board (Community Action Board CAB) in accordance with provisions set forth in the ACAP JPA. The CAB shall be a tripartite board with a minimum of 12 members representing low-income, public and private sectors as described in the CAB bylaws.

B.

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E.

The GB on behalf of the parties shall, in accordance with applicable federal regulations and taking into consideration the advanced review and recommendation of the CAB, do the following: 1. Approve the selection of an executive director, after public recruitment or by board appointment, who shall serve at the pleasure of the GB. The performance review of the Executive Director will be conducted on an annual basis to provide guidance, support, and (as necessary) disciplinary action to ensure that the executive leadership of ACAP is fulfilling its responsibilities to the lowincome community of Alameda County. The performance review, including disciplinary actions up to and including termination, may be approved by the CAB and subsequently approved by the GB before it can be acted upon. 2. 3. 4. 5. 6. Adopt, with or without amendment, the annual budget for the agency upon receipt thereof from the CAB. Adopt, with or without amendment the bi-annual Community Action Plan upon receipt thereof from the CAB. Require compliance with all applicable federal CSA statutes, regulations, and instructions by all agency personnel with respect to all agency activities. Adopt, with or without amendment submitted administrative policies and procedures upon receipt thereof from the CAB. Delegate administrative authority and responsibility in writing to the CAB as it deems workable and desirable, by any means not in conflict with the provisions of this agreement or applicable federal or California state regulations. Engage supportive services, as necessary, including but not limited to, personnel, purchasing, and legal services. Charges for any such services that are furnished by a signatory to the JPA will be determined by the legislative body of said signatory party.

7.

F.

For the achievement of the purposes stated in the ACAP JPA, the Board shall act on behalf of all the parties signatory to the ACAP JPA and shall have the power to bind the parties. However, the Board shall have no power or authority to incur obligations in excess of the amount of funds then appropriated to its use by a funding source.

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ARTICLE V Officers of the Governing Board and Duties5.1 Officers

The Board shall select from among its members a Chairperson who shall preside at all meetings. A Vice-Chairperson shall be selected in a similar manner and shall preside in the absence of the Chairperson. Elections shall be held at the GB meetings scheduled in December. The new GB Chair will begin his/her term as of January 1 of the year immediately following the election.

ARTICLE VI Meetings and Rules6.1 Regular Meetings

All meetings of the GB shall be public in accordance with the provisions of the Ralph M. Brown Act (California Government Code Sections 54950 et. seq). The Board shall meet not less frequently than every ninety (90) days. Written notice of meetings shall be sent to all members of the GB at least ten (10) days in advance of a meeting. Committee reports, reports from the Director, and other agenda material shall be included in the mailing when available. Advance publicity shall be provided to reasonably insure that the public will be notified of all GB meetings; such publicity may include notice in various newspapers in the ACAP service area and high traffic Internet sites. . The agenda of regular meetings shall include minutes of the previous regular meeting, any special meetings, and committee meetings held since the last general meeting. Opportunity for discussion of all material mailed in advance shall be included in the agenda. Each meeting shall provide opportunity for new business to be introduced from the floor and from the public whether or not it has been included in the written agenda provided in advance of the meeting.6.2 Special Meetings

Special meetings may be called by the Chairperson or at the request of a majority of the members of the GB, stating the purpose, time and place of the meeting. In case of special meetings, 72 hours advanced notice must be given to the public and the press.6.3 Executive Sessions

Closed sessions may be held only when the Ralph M. Brown Act (California Government Code, Section 54950 et. seq.) permits the holding of Executive Sessions.

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6.4

General Rules for all Meetings A. Rules of Procedure

Robert's Rules of Order, Revised shall govern all questions of procedure not provided for by these bylaws.B. Votes

Each board member shall have one (1) vote.C. Quorums

The presence of seven (7) members shall constitute a quorum for the transaction of business, except that less than a quorum may adjourn from time to time.D. Actions of the Board

Actions of the Board shall be by formal motion or resolution and no action may be taken except upon the affirmative vote of members representing a majority of the votes present at the meeting. Votes cast shall be cast only in person and not by proxy.

ARTICLE VII CommitteesThere shall be such special committees as the Board may establish from time to time. There shall be no permanent subcommittee to the Board.

ARTICLE VIII Amendments to the BylawsThese bylaws may be amended by a two-thirds vote of the members present at the meeting of the board, provided notice of the proposed amendment(s) has been given to each board member in writing at least 10 days prior to the meeting at which the proposed amendment(s) is to be considered.

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ARTICLE IX SeverabilityARTICLE IX SEVERABILITY If any Article, section, paragraph, sentence, clause or phrase of these bylaws is held for any reason to be illegal, unconstitutional, or null and void, such decision shall not affect the validity of the remaining portion of these bylaws.

Amended March 17, 2010 ___________

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EXHIBIT CVERIFIED PETITION FOR WRIT OF MANDATE


EXHIBIT DVERIFIED PETITION FOR WRIT OF MANDATE


EXHIBIT EVERIFIED PETITION FOR WRIT OF MANDATE


EXHIBIT FVERIFIED PETITION FOR WRIT OF MANDATE


EXHIBIT GVERIFIED PETITION FOR WRIT OF MANDATE

From: Date: February 18, 2011 10:03:19 PM PST To: Subject: Termination of Employment

By Hand Delivery February 18, 2011 Email ([email protected]) February 18, 2011 Nanette Dillard 1365 Brewster Drive El Cerrito, California 94530 Re: Termination of Employment Dear Ms. Dillard: As you are well aware, the Executive Director of the Associated Community Action Program (ACAP) shall serve at the pleasure of the (ACAP Governing Board), and said Board retains the exclusive jurisdiction to discipline the Executive Director, up to and including termination of employment. See Bylaws of the Governing Board of the Associated Community Action Program of Alameda County, Article IV, Section E. Further, Section 2.1 of Policies and Procedures of the Associated Community Action Program (Policy Manual), At-Will employment, provides in relevant part: Employment at ACAP is at-will. This means that ACAP has the right to terminate your employment, and you have the right to resign, at any time, with or without a reason and with or without prior notice. On or about February 3, 2011, you (and/or your husband with your knowledge) removed property from ACAPs premises without authorization and in direct violation of ACAP policies and the contract terms and guidelines associated with ACAP programs. Specifically, property access records and surveillance video taken at the premises indicate that, on or about 1:30 a.m., two vehicles consistent with vehicles owned by you and Paul Daniels arrived at 111 Review Way, and two persons fitting your descriptions began removing boxes from the building into those vehicles. All of the files, binders, and documents that previously existed in your office were removed that morning, along with files, binders, and documents maintained in the office of Deputy Director Lenita Ellis. On February 4, 2011, when confronted by Hayward Police Officer D. Rodriguez and Ms. Ellis, Mr. Daniels conceded that he knew the whereabouts of these materials and would facilitate their return. Later that day, Mr. Daniels returned some, but not all, of the stolen material. Although a complete list of missing documents has not been finalized, it is believed that list includes: grant binders, Board application files, bank account reconciliations, invoice records, audit files, monitor and reporting binders, related agency historical data, and the personnel file related to your employment maintained by Ms. Ellis. Section 5.3 of Policies and Procedures of the Associated Community Action Program (Policy Manual), Misconduct, provides in relevant part: Employees may be disciplined for misconduct, including but not limited to the following: (2) Dishonest; (3) theft Further, Section 9.0 of the Policy Manual, Personnel Records, states:

Personnel files are the property of ACAP and may not be removed from ACAPs premises without written authorization from the Personnel Manager. Your employment with ACAP is terminated effective immediately. Enclosed with original hand delivered letter is a final paycheck, which includes any accrued but unused vacation benefits. You must immediately return to the undersigned all ACAP property in your possession, custody and control, including, but not limited to: any ACAP documents or materials, access badges, keys, laptops, computer equipment, and related items. Sincerely, Diana Souza ACAP Board Chairperson


EXHIBIT HVERIFIED PETITION FOR WRIT OF MANDATE

Date: Wed, 23 Feb 2011 15:12:37 +0000 From: [email protected] To: [email protected] CC: [email protected] Subject: Board Packet List Request

Hello again, Meredith, As allowed by federal law, I would like to request to be placed on the list of individuals and organizations that receive all board meeting notifications and packets. Please forward the packets and notifications to: Nanette Dillard 1365 Brewster Drive El Cerrito, CA 94530 I am fine with receiving a scanned PDF copy by email to: [email protected]. Hope you are doing okay. Best regards, Nanette Dillard (415) 425-8785


EXHIBIT IVERIFIED PETITION FOR WRIT OF MANDATE


EXHIBIT JVERIFIED PETITION FOR WRIT OF MANDATE


EXHIBIT KVERIFIED PETITION FOR WRIT OF MANDATE


EXHIBIT LVERIFIED PETITION FOR WRIT OF MANDATE

FRANKELMICHELLE R. FERBER RICHARD A. FRANKEL STUART 1. GOLD WARE. ELLEN P. ROSENBLUTH INGRID VON KASCHNITZ

0 G O L D W A R E,av

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Of Counsel JAMES B. WICKERSHAM

STUART I. GOLDWARE [email protected] x234

March 11, 2011

VIA CERTIFIED MAIL Diana Souza, Chairperson, Governing Board Associated Community Action Program 24100 Amador Street, 3rd Floor Hayward, CA 94544 Re: Wrongful Termination of Nanette Dillard Demand to Cure or Correct Brown Act Violation

Dear Ms. Souza: This office represents Nanette Dillard in connection with the unlawful purported termination of her employment as the Executive Director of the Associated Community Action Program ("ACAP"). Please have all further communication concerning this matter directed to this office. Ms. Dillard had been employed with the ACAP since 2002, first as an administrative assistant, later becoming Executive Director in 2004. Under her leadership a $532,000 annual budget grew to over $3,300,000. This growth was attributable to Ms. Dillard's considerable talents and abilities. She created successful partnerships and collaborations, established multiple fundraising streams, and implemented effective programs, using evidenced-based practices. Ms. Dillard worked for two boards of directors, producing accurate, timely reports, meeting stringent federal and state guidelines. She carried out these functions within an extremely cumbersome, often erratic, and imperfect financial system administered by the Alameda County Auditor/Controller and the Alameda County Treasurer, and her written employee evaluations evidence that she performed well. ACAP underwent annual independent audits and was closely monitored by those who provided the program's funding. During Ms. Dillard's tenure, ACAP never missed a payroll, nor did it face a financial crisis. And it wouldn't have missed the February 18, 2011, payroll had the board not unlawfully placed Ms. Dillard on administrative leave on February 2, 2011. If there were a cash flow issue at the time of the February 2 meeting, it was not the fault of Ms. Dillard. It was the fault of governing board members who had not taken their responsibilities seriously enough to form a quorum at any meeting since March, 2010. The repeated failure to meet quorum requirements delayed formal action on numerous items, which

LOP RANCH

011 i BOLLINGER CANYON ROAD, SUITE 475 SAN RAMON, CA 94583 TEL (925) 355-9800 FAX (925) 355-9801 www.darivillelaw.torn

Diana Souza, Chairperson, Governing Board March 11, 2011 Page 2

would have enabled ACAP to receive grant money being held by the state or passed through the county. Indeed, I am advised that, despite Ms. Dillard's advice to the contrary, you led a drive to raise the quorum requirement to seven from the original five members. Even notwithstanding the late approval of the ACAP 2011 budget at the February 2, 2011, meeting, had Ms. Dillard not been placed on administrative leave, the February 18, 2011, payroll would have been met. Ms. Dillard would have ensured that the funds be made available on an expedited basis. I have reviewed the agenda for the February 2, 2011, board meeting. Nothing on that agenda even remotely references any proposed action involving Ms. Dillard's employment status. l Hence, the closed session action placing Ms. Dillard on administrative leave did not comport with the requirements of the Ralph M. Brown Act ("Brown Act") (California Government Code 54590 et seq.) The Brown Act does permit a closed session on specific complaints or charges brought against an employee; however, Ms. Dillard should have first been given written notice of her right to have the complaints or charges heard in an open session, such notice to be delivered to the employee personally or by mail at least 24 hours before the session. "If the notice is not given, any disciplinary or other action taken by the legislative body against the employee based on the specific complaints or charges in the closed session shall be null and void." (California Government Code 54957(b)(2) emphasis added.) Apparently, Ms. Dillard was informed verbally before that meeting that you were going to be elected Chair and that the votes had been lined up to take punitive action against Ms. Dillard. That fact alone, evidencing a serial meeting, constitutes still another Brown Act violation. I have been informed that one or more board members have asserted an emergency for the actions taken against Ms. Dillard. No such legal justification exists, as the Brown Act only permits the agency to hold emergency closed sessions "on matters posing a threat to the security of public buildings, a threat to the security of essential public services, including water, drinking water, wastewater treatment, natural gas service, and electric service, or a threat to the public's right of access to public services or public facilities. (California Government Code 54957(a)(1).) The board also ran afoul of the Brown Act, as well as ACAP's own bylaws, when it took the purported action to terminate Ms. Dillard's employment. Not only did it fail to deliver to Ms. Dillard its notice of action on charges or complaints brought against her, it also, to my understanding, voted to terminate her employment when a quorum of board members may not have been present. The board's authority to take action requires a quorum of seven members. (Bylaws of the Governing Board of the Associated Community Action Program of Alameda' The fact that the Agenda contains an entry permitting additions does not entitle a public agency to circumvent its requirement to provide advance notice "of each item of business to be transacted or discussed at the meeting, including items to be discussed in closed session." (California Government Code 54954.2(a)(1).)


County ("Bylaws"), Article IV, A; Article VI, 6.4C.) The Bylaws also make clear that any special meeting requires 72 hours' advanced notice and that executive sessions may only be held when the Brown Act permits. (Bylaws, Article VI, 6.2 and 6.3). Board member Nate Miley inferred that the action against Ms. Dillard had been "in the works since 2009." If that were the case, then further Brown Act violations would have been committed, as none of these communications took place as part of an item on a published board agenda. Compounding the unlawful conduct relating to the attempt to terminate Ms. Dillard's employment, it appears that certain board members went out of their way maliciously to damage the reputation of an exceptional woman, who devoted the past nine years of her life to working to help Alameda County's neediest residents. Mr. Miley is quoted in the press as expecting the 2009 audit to show a significant deficit. That audit report, which was to be presented as part of a staff report that was not permitted to be given at the February 2, 2011, meeting, found issues, not with Ms. Dillard, but with the cumbersome financial system in which she was forced to work. But by not-so-subtly inferring to the media that Ms. Dillard sought in the middle of the night to steal documents to cover up evidence of financial wrongdoing, certain board members have irretrievably defamed Ms. Dillard's reputation. Late in the evening on the day that she was unlawfully placed on administrative leave, Ms. Dillard was told to clear out her office. She removed her personal items, but when she arrived home, she realized that she had forgotten to retrieve some of her property. So she returned for the rest. Aside from items of a personal nature, the only documents removed were those available to the public and that would have been found in a board packet. Certainly ACAP cannot be taking the position that Ms. Dillard was not entitled to have in her possession publicly available documents, many of which she created. Ms. Dillard acknowledges the at-will nature of her employment as Executive Director of ACAP. That status does not, however, entitle her employer to violate the Brown Act, ignore its internal bylaws, defame her, discriminate against her because she is a member of a protected class, or retaliate against her because she complained about such discrimination. As mentioned above, the Brown Act violations alone render null and void the purported termination of Ms. Dillard's employment. Demand is hereby made that Ms. Dillard immediately be restored to her position of Executive Director of ACAP, with full pay and benefits from the date of her purported termination to the present. Demand is further made that ACAP's board publicly and unequivocally express its regret that its actions portrayed Ms. Dillard in a false light, acknowledging that there was and is no basis whatsoever to support the inference that Ms. Dillard committed any financial impropriety in her capacity as Executive Director of ACAP. Demand is further made that ACAP reimburse Ms. Dillard for all attorney fees and legal costs she has incurred to date in connection with the purported termination of her employment.


Enclosed with this letter you will find Ms. Dillard's formal demand to ACAP to cure and correct the actions taken in violation of the Brown Act. If the board fails to take the corrective action demanded with respect to the restoration of Ms. Dillard's employment and back pay and benefits within thirty (30) days of the receipt of that demand, then Ms. Dillard will bring legal action against ACAP and its board for the purpose of obtaining a judicial determination that the board's actions with respect to her employment are null and void. In such an action, the court is authorized to award attorney fees to the plaintiff where it is found that the legislative body of the local agency has violated the Brown Act. (California Government Code 54960.5.) If you wish to communicate further about this matter, please do not hesitate to contact me or have the board's legal counsel do so on its behalf. Ms. Dillard looks forward to resolving her differences with ACAP and its governing board without the necessity of judicial intervention. If such a resolution cannot be accomplished, then she will bring a legal action on account of the multiple wrongs committed by ACAP and its governing board. Very ly yours,

Stuart I. Goldware SIG/pc Enclosure cc: Marie Gilmore, Mayor (w/encl.) Nora Davis, Mayor (w/encl.) Bob Wasserman, Mayor (w/encl) Ana Apodaca, Vice Mayor (w/encl.) Jim Navarro, Vice Mayor (w/encl.) Kevin Hart, Vice Mayor (w/encl.) Jeff Williams, Councilmember (w/encl.) Cheryl Cook-Kallio, Councilmember (w/encl.) Nate Miley, Supervisor (w/encl.) Robert Lieber, Councilmember (w/encl.) Jeff Wieler, Councilmember (w/encl.) Francisco Zermeno, Councilmember (w/encl.) Client (w/encl.)

1: \Dillard, Nanette\LTR Souza re wrongful termination.doc

DEMAND FOR CURE OR CORRECTION

Op

TO: THE GOVERNING BOARD OF THE ASSOCIATED COMMUNITY ACTION PROGRAM OF ALAMEDA COUNTY ("ACAP"): DEMAND IS HEREBY MADE that you cure or correct the following actions taken in closed session on or about February 2, 2011, and on or about February 16, 2011: 1. The placing of Nanette Dillard on administrative leave from her position as Executive Director of ACAP on or about February 2, 2011; and The termination of Nanette Dillard's employment as Executive Director of ACAP on or about February 16, 2011.

2.

These demands are made pursuant to California Government Code 54960.1 and are based on the fact that the adverse employment decisions taken with respect to Nanette Dillard were made in violation of California Government Code 54954.2. Specifically, with respect to the February 2, 2011, board meeting, no description of any such proposed action was posted on an agenda for that meeting at least 72 hours before that meeting took place. Furthermore, on information and belief, subsequent adverse employment action taken against Nanette Dillard was not properly posted on meeting agendas.

Dated: March 11, 2011

FRANI L & GOLDWARE, LLP

A,By: Stuart I. Goldware, Attorneys for Nanette Dillard


EXHIBIT MVERIFIED PETITION FOR WRIT OF MANDATE


EXHIBIT NVERIFIED PETITION FOR WRIT OF MANDATE


EXHIBIT OVERIFIED PETITION FOR WRIT OF MANDATE

From: [email protected] [mailto:[email protected]] Sent: Friday, March 04, 2011 10:52 AM To: Meredith Walker Cc: [email protected] Subject: California Public Records Act Request Hello Meredith, I hope that you are well. I would like to submit the following request for information under the California Public Records Act.. I would like to request copies of the following documents: Item Request 1 - A copy of the complete ACAP Organizational Assessment as submitted to Governing Board members Supervisor Nate Miley and (then) ACAP Chair Robert Lieber. Item Request 2 - A copy of the 2010 Summer Youth Employment Program executed contract, including dated cover page signed by (then) Social Services Agency Director, Yolanda Baldovinos. Item Request 3 - A copy of the executed or non-executed Second Chance Act contract from the Alameda County Probation Department. Item Request 4 - A copy of the executed or non-executed Reentry Court contract from the Oakland Private Industry Council. Item Request 5 - A copy of the executed CSBG contract from the Community Services and Development Department. I am fine with receiving these documents as scanned PDFs sent by email to: [email protected]. If you prefer to send them as paper documents by post, please send them to: Nanette Dillard 1365 Brewster Drive El Cerrito, CA 94530 If you have any questions about this official California Public Records Act request, please feel free to call me at (415) 425-8785. Wishing you all the best blessings in the future,

Nanette Dillard


EXHIBIT PVERIFIED PETITION FOR WRIT OF MANDATE

----- Forwarded Message ----From: "Sam SSA Tuttelman" To: [email protected] Cc: "Diana Souza (E-mail" , [email protected] Sent: Tuesday, March 15, 2011 4:31:51 PM Subject: California Public Records Act Request Ms. Dillard Pursuant to the Californai Public Records Act we will make avaialble to you, assuming they can be located, items 2,3,4,and 5 below. However, upon advice of counsel you are not entitled to item #1, the ACAP Organizational Assessment as submitted to Governing Board members Supervisor Nate Miley and (then) ACAP Chair Robert Lieber. We hope to get you the requested items as staff are avaialble to locate and copy them. Sam Tuttelman Interim ACAP Executive Director


EXHIBIT QVERIFIED PETITION FOR WRIT OF MANDATE


EXHIBIT RVERIFIED PETITION FOR WRIT OF MANDATE

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