Request #20-184
  Closed

 *“SUBJECT LOCATION” which is defined as Bay Ho neighborhood of San Diego County (directly across/west of 4645 Morena Blvd).  More specifically a bike/walking trail on the west side of side of Morena Blvd as depicted in "Attachment A" hereto, incorporated herein by reference (on and around the 4600 block of Morena Blvd and including but not limited Assessor Parcel Numbers 3590100500 & 3598201300) in the City/County of San Diego. *"LOCATION", generally, is also defined as public property at or near 4696/4652 Morena Blvd, San Diego, CA 92117 (approximate longitude and latitude mapping coordinates 32.823034 - 117.228035).

The information should be for a period of five (5) years prior to the date of this letter unless otherwise stated. All the below requests seek writings as defined in the California Evidence Code section 240, et seq. and DOCUMENTS as defined herein.  The extent allowed by law, Holmes Law Group (HLG) will reimburse for the reasonable cost of producing the following requested DOCUMENTS:

 

  1. Any and all copies of PUBLIC ENTITY’S internal accident records system printouts of injuries and deaths at and within a five-mile radius from the SUBJECT LOCATION;

 

  1. Any and all copies of PUBLIC ENTITY’S policies, guidelines and standards for defining and reviewing injuries and or deaths on and/or relating in any way to PUBLIC ENTITY’S property (including all property in which PUBLIC ENTITY has any interest(s), including but not limited to easements and the like);
    1. Any and all copies of PUBLIC ENTITY’S policies, guidelines and standards for defining and reviewing injuries and deaths to or relating to trees on and/or relating in any way to PUBLIC ENTITY’S property (including all property in which PUBLIC ENTITY has any interest(s), including but not limited to easements and the like);

     

    1. Any and all copies of PUBLIC ENTITY’S policies, guidelines and standards for defining and reviewing injuries and deaths to or relating specifically to eucalyptus trees on and/or relating in any way to PUBLIC ENTITY’S property (including all property in which PUBLIC ENTITY has any interest(s), including but not limited to easements and the like);

     

    1. Any and all copies of PUBLIC ENTITY’S policies and procedures relating to the care and maintenance of trees located on and/or relating in any way to PUBLIC ENTITY’S property (including all property in which PUBLIC ENTITY has any interest(s), including but not limited to easements and the like);

     

    1. Any and all copies of PUBLIC ENTITY’S policies and procedures relating to the care and maintenance of eucalyptus trees located on and/or relating in any way to PUBLIC ENTITY’S property (including all property in which PUBLIC ENTITY has any interest(s), including but not limited to easements and the like);

     

    1. Any and all copies of DOCUMENTS relating to the care and maintenance of the trees, shrubs, plants, trail, fencing, irrigation, signage located on, around, and within a 100-yard radius of the SUBJECT LOCATION;

     

    1. Any and all copies of DOCUMENTS relating in any way to the trees, shrubs, plants, trail, fencing, irrigation, signage located on, around, and within a 100-yard radius of the SUBJECT LOCATION;

     

    1. Any and all copies of complaints filed with the PUBLIC ENTITY relating to bodily injury caused by and alleged to have been caused by trees located on and/or relating in any way to PUBLIC ENTITY’S property (including all property in which PUBLIC ENTITY has any interest(s), including but not limited to easements and the like);

     

    1. Any and all copies of complaints filed with the PUBLIC ENTITY relating to bodily injury caused by and alleged to have been caused by eucalyptus trees located on and/or relating in any way to PUBLIC ENTITY’S property (including all property in which PUBLIC ENTITY has any interest(s), including but not limited to easements and the like);

     

    1. Any and all copies of complaints or requests from private parties relative to any occurrence on or within the SUBJECT LOCATION;
      1. Any and all copies of complaints or requests from private parties relative to any occurrence on or within PUBLIC ENTITY’S property (including all property in which PUBLIC ENTITY has any interest(s), including but not limited to easements and the like) within a five-mile radius of the SUBJECT LOCATION;

       

      1. Any and all internal and external PUBLIC ENTITY E-mails or correspondence relative to the SUBJECT LOCATION;

       

      1. Any and all internal and external PUBLIC ENTITY E-mails or correspondence relative to PUBLIC ENTITY’S property (including all property in which PUBLIC ENTITY has any interest(s), including but not limited to easements and the like); within a five-mile radius of the SUBJECT LOCATION;

       

      1. Any and all copies of PUBLIC ENTITY studies and investigations relative to the SUBJECT LOCATION;

       

      1. Any and all copies of studies and investigations relative to trees located on and/or relating in any way to PUBLIC ENTITY’S property (including all property in which PUBLIC ENTITY has any interest(s), including but not limited to easements and the like);

       

      1. Any and all copies of studies and investigations relative to eucalyptus trees located on and/or relating in any way to PUBLIC ENTITY’S property (including all property in which PUBLIC ENTITY has any interest(s), including but not limited to easements and the like);

       

      1. Any and all DOCUMENTS referring or relating to Scott Howard Osmon;

       

      1. Any and all DOCUMENTS referring or relating to Leslie Osmon;

       

      1. Any and all DOCUMENTS evidencing title to, ownership of, and property interests in (including but not limited to leasehold interest(s), easement(s), and the like) the property identified as the SUBJECT LOCATION;

       

      1. Any and all agreements, ordinances, resolutions with respect to the SUBJECT LOCATION;

       

      Any and all agreements, ordinances, resolutions with respect to trees located on and/or relating in any way to PUBLIC ENTITY’S property (including all property in which PUBLIC ENTITY has any interest(s), including but not limited to easements and the like);   
      1. Any and all agreements, ordinances, resolutions with respect to eucalyptus trees located on and/or relating in any way to PUBLIC ENTITY’S property (including all property in which PUBLIC ENTITY has any interest(s), including but not limited to easements and the like);

       

      1. Any and all DOCUMENTS relating or referring to the SUBJECT INCIDENT; and

       

      1. Any and all DOCUMENTS relating or referring to the SUBJECT LOCATION.

       

       

       

      Please contact the undersigned to confirm receipt of this request and to inform of the costs associated with producing the documents requested herein.

       

       

       

      Sincerely,

       

       

       

       

      Rhonda J. Holmes, Esq.

                      of

      HOLMES LAW GROUP

         -Civil Trial Lawyers-

      1030 La Bonita Drive

      Suite 314

      San Marcos, CA  92078

      Tel: 760-539-7315

      Fax: 833-747-9654

      RHolmes@HLGTrialLawyers.com


Received

April 29, 2020 via web


Departments

Legal -- Public Records Act

Documents

Public

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Staff

Point of Contact

Public Records

Request Closed Public

No Responsive Documents Released

The Commission does not possess responsive documents or cannot release the responsive records.

May 7, 2020, 1:06pm
Department Assignment Public
Added: Legal -- Public Records Act.
April 30, 2020, 9:43am
Request Published Public
April 30, 2020, 9:37am
Request Opened Public
Request received via web
April 29, 2020, 3:40pm