ON SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Feb-20-2018 2:50 pm Case Number: CGC-18-564457 Filing Date: Feb-20-2018 2:48 Filed by: KALENE APOLONIO Image: 06224079 COMPLAINT SCOTT NELSON VS. DEPARTMENT OF HOMELESSNESS AND SUPPORTIVE HOUSING ET AL 001006224079 Instructions: Please place this sheet on top of the document to be scanned.o SUMMONS (CITACION JUDICIAL) NOTICE TO DEFENDANT: (AVISO AL DEMANDADO) DEPARTMENT OF HOMELESSNESS AND SUPPORTIVE HOUSING; RANDOLPH QUEZADA; DOES 1 to 10, Inclusive YOU ARE BEING SUED BY PLAINTIFF: (LO ESTA DEMANDANDO EL DEMANDANTE): SCOTT NELSON 'NOTICET You have been sued, The Courl may decide again you without your being heard unless you respond wii 30 days. Read the formation below. ‘You have 30 CALENDAR DAYS after this summons and legal papers are served on yout flea writen response at this court and have a copy served on the plaintif. eter or phone cal wil not protect you, Your writen response must bein proper legal form you want the court to ear your tase, There may be a court form that you can use for your response. You can find these court forms and more information atthe Calfornia Courts nine SetHelp Genter (www courtnfo.ca.gow/sefelp), your county tw library, othe courthouse nearest you. f you cannt pay the fling fee, ask ‘he court clerk fora fee waiver form. you do not fle your response on time, you may lose the case by default, and your wages, money, and property may be taken without further warning ffom the cour. "There are other legal requrements. You may want to cal an attorney right away. Ifyou do not know an attorney, you may want to call an attomey referral service. f you cannat afford an aflorney, you may be elie fo ree legal services from a nonproftlegal services program. You can locate ‘these nonproft groups atthe California Legal Services Web ste (www Jewhelpcalfeyna.or), the Calfornia Courts Online Self-Help Center (Gnew-courtinfo.ca.gow/sehetp), oF by contacting your local court or county bar association. NOTE: The court has a statutory len for waive fees and ‘costs on any setiement or arbitration award of $10,000 or mare ina ovll case, The courts len must be pai befoe the cout wil dismiss the case. TAVISO! Lo nan demancado. Si no responde dentro de 30 las, la cote puede decidiren su conta sn escuchar su versin, Lea la nformactin @ Continues, Tiono 30 DIAS DE CALENDARIO después de que le entrequen este ction y papetes legals para presentar una respuesta por escrito en esta corte y hacer que so entregue una copie al demandante, Une carta 0 una lamada felefGnica no lo protegen. Su respuesta por ascrto tere quo star fen formato legal correcto s desea que procasen su caso on la corte. Es posible que haya un formularo que usted pueda usar para su respuesta Puede encontrar estos formularis de la cortey més informacion enol Centro de Ayuds de las Cortes de California (www sucorte.ca.goy), en la biboteca de leyes do su condado o on la corto que le quede més cerca. Si no puede pagar la cuota de presentactn,pida al secretaio de a cote {que led un formulario de exencicn de pago de cuotes. Sino presenta su respuesta a emo, puede perder el caso por incumpimientoyla corte le Pods quitar su sueldo, diner y Benes sin mas advertencia, "Hay ottos requis legales. Es recomendable que lame a un abogado inmediatamente. Sino conace a un abogado, puede lamar a un servicio do remisién a abogados. Sino puede pagar a un abogado, es posible que cumple con los requsios pare obtener servicios legates gatutos de un programa de servicios legales sin fines de luc. Puede encontrar estos grupos sin fies de luc on! sito web de Calfoma Legal Services, {hee lawhelpealifornia. org), en el Centro de Ayuda de las Cortes de Calfomia, (www sucore.ca gov) 0 poniéndose en contacto con la core oe! ‘colegio de abogados locales AVISO: Por ey, la corte tone derecho @reclamar ls cuotas y os costosexentos por imponer un gravamen sobre ‘cualquier recuperacién de $10,000 6 me de valor recbide mediante un acuerdo o una concesién de arbraj en un caso de derecho oil. iene que pagar ol gravamen de la corte antes de que la corte pueda desechar el caso. Tea a sees oceste eg, SAN FRANCISCO SUPERIOR COURT eee 8-564457 400 McAllister Street San Francisco, CA 94102 ‘The name, address, and telephone number of plaintiff's attomey, or plaintiff without an attomey, (Elnombre, la direccién y el numero de telefono de el demandante, o del demandante que no tiene abogado, es) Scott Nelson, 391 Ellis Street, San Francisco, CA 94102 CLERK OF THE COURT DATE: Clerk, by » Deputy (Fecha) FEB 8.0 2018 (Secretario) (Adjunto) (For proof of envce ofthis summons, use Proof of Senice of Summons (form POS-078)), {Para prueba de entrega de esta citation use el fonmulario Proof of Service of Summons, (POS-10). NOTICE TO THE PERSON SERVED: You are served 1. LJ as an individual defendant 2. [=] as the person sued under the itis name of (speci: 3, (J on behait of (speciy) under; I] cP 416.10 (corporation) cc 416.60 (minon 5) CCP 416.20 (defunct corporation) [=] CCP 416.70 (conservatee) [) CcP 416.40 (association or partnership) [—] CCP 416 90 (authorized person) TF) other (speci) 4. (1 by personal delivery on (date): a Fanaa nary Oe “SUMMONS a ea Pn 235,165 SNEED 947 1208)10 a 12 13 4 15 16 vv ae 19 20 21 22. 23 24 25 © ° ee FIL San Francisco, CA 94102 Feprrencicn Corny Supater O>¥t scott94102@gmail.com Pro Se SUPERTOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO case vo: CG0-18-564457 VERIFIED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELTEF UNDER THE CALIFORNIA PUBLIC RECORDS ACT AND Ti SAN FRANCISCO SUNSHINE ORDINANCE SCOTT NELSON, Plaintife, DEPARTMENT OF HOMELESSNESS AND SUPPORTIVE HOUSING; RANDOLPH QUEZADA; DOES 1 to 10, Inclusive; (CA Government Code Sections 6258 & 6259) (SE Administrative Code Section 67.21(f)) UNLIMITED CIVIL CASE Defendants. Plaintiff Scott Nelson, by this verified complaint, alleges tha PARTIES 1. At all times relevant to this complaint, Plaintiff Scott Nelson was and is a “member of the public” as defined under Government Code section 6252, subdivision (b). 2. At all times relevant to this complaint, Defendant Department of Homelessness and Supportive Housing (“HSH”) was and is local agency as defined under Government Code section 6252, subdivision (a). VERFIED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF15 16 a7 18 19 20 a 22 23 24 25 ° ° 3. At all times relevant to this complaint, Defendant Randolph Quezada (*Quezada”) was and is the HSH Communications and Community Relations Manager. As such, Defendant Quezada’s duties and responsibil es include responding to and timely fulfilling requests submitted by members of the public under the Public Records Act or the Sunshine Ordinance. 4, At all times relevant to this complaint, Defendant Quezada was and is an agent of HSH, and his acts or omissions were or are within the course and scope of his employment. 5. Plaintiff is ignorant of the true names and capacities of Defendants sued herein as DOES 1 to 10, inclusive, and therefore sues these Defendants by these fictitious names. Plaintiff will amend this complaint to a lege their true names and capacities when ascertained. Nevertheless, Plaintiff is informed and believes and thereon alleges that the acts or omissions by each Doe defendant were or are within the course and scope of his or her employment. STATEMENT OF FACTS 6. On November 9, 2017 Plaintiff submitted via email a Public Records Act/ Sunshine Request to Defendant Quezada, stating and requesting in relevant part: {am trying to determine the efforts your agency has taken to provide homeless shelters, feeding programs, of other homeless services on CalTrans-owned property in San Francisco. Please provide access to, and/or copies of all extant documents and, specifically, any emails within the past year between or within personnel working for HSA, HSH, the Mayor's Office, or other affected City agencies, and CalTrans and/or members of the public conceming such efforts. A true and correct copy of this request is attached hereto marked wexhibit A - Initial Request” and incorporated herein by this reference. 7. On November 9, 2017 Defendant Quezada responded to Plaintiff’s initial request by stating in pertinent part: We have received your Public Records Act request for documents. We will respond to you within 10 days, by November 20, if not sooner. If we need clarification or an extension I will be in touch. a VERFIED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF© ° A true and correct copy of this response is attached hereto marked “Exhibit 2 ||b - Response to Initial Request” and incorporated herein by this reference. 3 8. On Novenber 15, 2017 Defendant Quezada further responded to Plaintiff's 4 |]initial request by invoking a permitted extension of time by stating in part: 5 Please be advised that this Office is hereby invoking an extension of time to respond to your Public Records Act Request for records. We are invoking the extension of time under Government Code 6 Section 6253(c) and San Francisco Administrative Code Section 67.25(b) because ofthe need to search for, collect, and appropriately examine a voluminous amount of separate and distinct records AND the ? need for consultation with another agency having substantial interest in the determination of the request. We understand that we are required to conduct this consultation with a practicable speed. We will endeavor to process your request as quickly as possible and anticipate responding no later than. 9 the close of business on 12/4/2017. A true and correct copy of this response is attached hereto marked 11 |[~exnipit c - extension of Time” and incorporated herein by this reference. 9. On December 12, 2017 Plaintife submitted a follow-up email to Defendant 13 |Jouezaca inquiring about the status of Plaintiff's request and offering to clarity’ 14 |land Limit its scope, as follows: 1s Please advise me ofthe status of my pending request. If can help expedite the request by clarifying or otherwise limiting its scope, please let me know. 16 wv A true and correct copy of this email is attached hereto marked “sxhibit D ie ||- ofter Limiting scope of Request” and incorporated herein by this reference. 19 10. On December 12, 2017 Defendant Quezada responded to Plaintiff's above- 20 |[referenced email by stating: a Apologies forthe delay. We will work to gather responsive documents as quickly as possible. Ifyou could narrow the time frame that may help expedite this request. Similarly the more specific you can 22 make your request would help us be able to track down responsive documents. 23 A true and correct copy of this email is attached hereto marked 24 ||~Exnibit E - Response to Offer Limiting Scope” and incorporated herein by this 25 || rererence. VERFIED COMPLATNT FOR DECLARATORY AND INJUNCTIVE RELIEF10 a a2 43 uv 16 19 20 a 22 23 24 25 © ° on December 14, 2017 Plaintifé submitted 2 follow-up email to Defendant Quezada, clarifying and limiting the scope of Plaintiff's request as follows ‘You may limit my request to 6 months for any emails between your agency and CalTrans, DPW, and/or the Mayor's Office), and a year and a half (the launch of HSH) for documents concerning your agency's efforts to allow a shelter or feeding station on Caf Trans property in SF. will separately contact Acting Maror [sic] Breed’s office to seek emails and/or documents between Former Mayor Lee and CalTrans. A true and correct copy of this email is attached hereto marked vexhibit F - Clariti ation and Limitation of Request” and incorporated herein by this reference. 12. On January 5, 2018 Plaintiff sent an email to Defendant Quezada inquiring about the status of Plaintiff's clarified request, stating: Please advise me of the status ofthis request. A teue and correct copy of this email is attached hereto marked “exhibit - Inquiry to Quezada re Status” and incorporated herein by this reference. 13. By January 9, 2018 having not received a response from Defendant Quezada to Plaintifé’s January 5 status inquiry, Plaintiff sent an email to Jeff Kositsky, HSH Director, stating Plaintiff’s efforts thus far and requesting a status update: ‘This concerns a Public Records / Sunshine Request I submitted to your agency via Randy Quezada on November 9, 2017, seeking records of your agency's efforts to provide homeless services on CalTrans- ‘owned property. To date I have not received any ofthe requested records, nor any contact from Randy since December 13, 2017. {As shown in the included emails from myself to Randy and back, on December 14, 2017 I limited the ‘scope of my request in order to help expedite it. However, having heard nothing further by January 5, 2018, | emailed Randy and inquired about the status ofthe request. But as of today, January 9, 2018, | ‘till have not received copies of the records or even a status update. Please let me know the status of my request. A true and correct copy of this email is attached hereto marked VERFIED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF10 n 12 13 4 1s 16 y 18 ° ° “Exhibit H - Inquiry to Kositsky re Status” and incorporated herein by this reference. 14, On January 9, 2018, Plaintiff received an immediate automatic reply from Director Kositsky’s email account, which stated: Thank you for writing, Due to the high volume of emails I receive, it may take a few days to respond. Ifyou require immediate attention, contact christine keener @sfgov.org. A true and correct copy of this email is attached hereto marked “Exhibit T = Kositsky Automatic Reply” and incorporated herein by this reference. 15. On January 10, 2018 plaintiff sent an email to Director Kositsky’s assistant Christine Keener, summarizing several of Plaintiff's efforts to date and requesting @ status update: ‘This concerns a Public Records / Sunshine Request I submitted to your agency via Randy Quezada on ‘November 9, 2017, seeking records of your agency's efforts to provide homeless services on CalTrans~ ‘owned property. As of January 10, 2017, Ihave not received any of the requested records nor any contact from Randy since December 13, 2017. (On January 9, 2017, emailed Jeff seeking his assistance with determining the status of my request His office provided an automated response indicating I should contact your office for immediate attention to this issue. Please advise me of the status of my pending Public Records Act request. A true and correct copy of this email is attached hereto marked “exhibit J - Inquiry to Keener re Status” and incorporated herein by this 16. On January 10, 2018, Plaintife received an immediate automatic reply from Christine Keener’s email account, which stated: Lam out ofthe office. If ths is urgent, please email Becky. Van@sfgov.org. CK. A true and correct copy of this email is attached hereto marked “Exhibit K ~ Keoner Automatic Reply” and incorporated herein by this reference. 17. On January 10, 2018, less than an hour after receiving the above-noted VERFIED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF10 n 12 13 14 15 16 7 18 19 20 a 22 23 24 25 ° 3 response from Christine Keener, Plaintiff received the following response from Defendant Quezada, which provided in its entirety: Scott, ‘Apologies. Working on this now. RQ A true and correct copy of this email is attached hereto marked “Exhibit L - Quezada Last Response” and incorporated herein by this reference. 18. As of February 20, 2018, Plaintiff has not received any further responses from Defendants, nor from anyone acting on Defendants’ behalf. 19. As of February 20, 2018, Plaintiff has not been allowed to inspect the public records at issue nor receive any copies thereof. 20. An actual controversy has arisen and continues to exist between Plaintiff and Defendants concerning their respective rights and duties under the Public Records Act and/or the Sunshine Ordinance. 21. Defendant HSH contends that providing copies of public records to Plaintifé within a reasonable or timely manner or without delay is not required under the Public Records Act or the Sunshine Ordinance. 22. Defendant Quezada contends that providing copies of public records to Plaintiff within a reasonable or timely manner or without delay is not required under the Public Records Act or the Sunshine Ordinance. 23, Plaintifé contends that Defendants’ delay or obstruction of Plaintiff's pending request is unreasonable under the Public Records Act. 24, Plaintifé further contends that under the Public Records Act, Government Code section 6253, subdivision (d), the Defendants are prohibited from delaying or obstructing Plaintiff's access to the public records at issue. VERFIED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF10 cy az 1B u 15 16 vv 18 19 20 21 22 23 24 25 © 3 25. Plaintiff further contends that Defendants’ delay and obstruction of Plaintif#’s pending request is unreasonable under the Sunshine Ordinance. 26. Plaintiff further contends that under the Sunshine Ordinance, San Francisco Administrative Code section 67.21, subsection (c), the Defendants are prohibited from delaying or obstructing Plaintift’s access to the public records at issue. 27. Plaintiff desires a judicial determination of Plaintiffs and Defendants’ rights and duties under the Public Records Act, and a declaration that Defendants have unreasonably delayed or obstructed Plaintiff's access to the public records at issue. 28. Plaintif# desires a judicial determination of Plaintiff's and Defendants’ rights and duties under the Sunshine Ordinance, and a declaration that Defendants have unreasonably delayed or obstructed Plaintiff's access to the public records at issue. 29, Plaintifé desizes an injunction under the Public Records Act, enjoining Defendants from further delaying or obstructing Plaintiff’s access to the public records at issue. 30. A judicial determination is the only appropriate means of ascertaining Plaintiff's and Defendants’ rights and duties under the Public Records Act and/or the Sunshine Ordinance. 31. Defendants’ wrongful conduct, in delaying and obstructing Plaintifé’s access to the public records at issue, unless and until restrained by this Court, has caused and will continue to cause great and irreparable injury to Plaintife. 32, Plaintifé has no adequate remedy at law for the injuries being suffered as a result of Defendants’ wrongful conduct as described above. VERFIED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF10 u 12 13 14 15 16 vv 18 19. 20 21 22 23 24 25 © 8 PRAYER FOR RELIEF WHEREFORE, Plaintiff Scott Nelson prays for a judgment as follows: 1. For a declaration that Defendants, and each of them, have unreasonably delayed or obstructed Plaintifé’/s access to the public records at issue. 2. For a declaration that Defendants, and each of them, are bound by Government Code section 6252, subdivision (d), and are prohibited from unreasonably delaying or obstructing Plaintiff’s access to public records. 4. For a declaration that Defendants, and each of them, are bound by San Francisco Administrative Code section 67.21, subsection (c), and are prohibited from unreasonably delaying or obstructing Plaintiffs access to public records. For an injunction prohibiting Defendants, and each of them, their agents, officers, ox employees, from unreasonably delaying or obstructing Plaintiff's access to the public records at issue. 6. For an award of actual costs incurred by Plaintiff in prosecuting this action. 7. For an award of reasonable legal fees incurred by Plaintiff in prosecuting this action. For an award of reasonable attorney’s fees incurred by Plaintiff in prosecuting this action. For such other, further or additional relief as the Court deems just and proper. DATED: February 20, 2018 Respectfully Submitted, Me Scott Nelson, Pro Se VERFIED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEFo 3 VERIFICATION 2 I, Scott Nelson, declare as follows: 3 Tam the plaintif® in the above-entitled action. I have read the foregoing 4 ||compiaint and know the contents thereof, and state that all facts are true and 5 |[correct, and as to any matters that may be based or stated on information and 6 ||periet, 1 believe them to be true. 7 I declare under penalty of perjury under the laws of the state of a |[calitoraia that the foregoing is true and correct. ° Executed on February 20, 2018 at San Francisco, California. u BeStt Nelson a2 liv a3 fiz aa lis 1s |lvy 16 |r as x8 lis as |l/7 20 |\/7 aa |r 22 |r 23/7 24 iy 2s vv 9 VERETED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEFExhibit A — Initial Request© ° Public Records Act / Sunshine Request ‘Scott Nelson “Thu, Nov, 2017 at 136M “To: Randolph Quezada Randy Quezada Communications and Communty Relatons Manager (Department of Homelessness and Supportive Housing 1380 Mission Steet. 2nd Floor San Francisco, CA 94103 415.385.5207 randobph quezada@stoovorg Randy, ‘Tis ta Pubse Records Act Sunshine Request concerning your agency's efor o prove homeless sences on Carans-cwned property ‘As you may know. lo 1993 Quentin Koop and Wile Brown sponsored Senate Bil 120, which added secon 104.16 to the Streets and Highways Code, to provid in pat nat: ‘Any arspace under a treeway, or eal propery acquired for highway purposes, inthe City and County of San Francisco, which snot excess propery, may be ‘eased by the deparmentto the oty and county oF another pote subdion or @ sate agency for purposes ofan emergency shar or feeding program This section was amended in 2017 (Assembly Bl 857) to add that in adon tothe emergency shelter or feeding program, under adatonal provisions CalTrans property also may now be eased for park recreational, or open-space puposes.” Recent | received tom Carans a copy ofan email dated July 26, 2017 that tated in part ‘On the ane hand, you have the Departmental stance of no hsbtaion undemeath our highways. We have fought the City of San Francisco on this exact topic farmonths now {am tying determine the efforts your agency has taken to provide homeless shelters, feeding programs, or oer homeless services on CafTrans-owned property in San Francisco, Please provide access fo, andlor copes of al extant documents and, special, any mals within the past year between or within personnel working for HSA. HSH, the Mayors Ofice, or other afected Gy agencies, and Caran andor members of te public concerming such effort ‘Thankyou in advance for your atlention to this request. ‘Seat NelsonExhibit B — Response to Initial Request© Q Public Records Act / Suns! ‘Quezada, Randolph (HOM) ‘Tou, Nov8, 2017 at 158 PM To: Scot Nelson Ce: HSHSunshine Ce: HSHSunshine ear Me Nelson, Please be advised that this Office is hereby Invoking an extension of ime to respond to your Pubic Records Act Request fr records. We are woking the ‘extension of tme under Government Code Section 6253(c) and San Francisco Administrative Code Section 67.25(0) because ofthe need to search or, collect, and appropriately examine a voluminous amount of separate and distinet records AND the need for consultation with another agency having substantial interest inthe determination of the request, We understand that we are required o eonduct this consultation witha pracueable speed. ‘We will endeavor to process your request as quickly as posible and antkipate responding no ater than the close of business on 12/4/2017. Randy QuezadaExhibit D - Offer Limiting Scope of Request+) ° Public Records Act / Sunshine Request ‘Scott Nelson “Te, Dee 12,2017 at 1223 PM To: "Quezada, Randolph (HOM «randolh.quezada@stgov.ceg> Bee: scots4t02@gmai.com Randy Pate advise me ofthe status of my pending request. | can help expedi the request by carting or otherwise ing ts scope, pease let me know, ‘Tank you. Seo amsiaenaseExhibit E — Response to Offer Limiting Scope© 9 Public Records Act / Sunshine Request Quezada, Randolph (HOM) “Te, Doe 12,2017 at 232 PM ‘To: Soot Neon Dear scot. ‘Apologies forthe delay. We wil work to gather responsive documents as quickly as possible. Ifyou could narrow tne em frame that may help expedite this request. Similarly the more specific you ean make your request would help us beable to track down responsive documents Best, andy From: Scott Nelson [maio:scot94*02@ gmail.com) Sent: Tuesday, December 12, 2017 12:23 PM ‘To: Quezada, Randoiph (HOM) Sulbject: Re: Public Records Ac / Sunshine Request fst ereExhibit F — Clarification and Limitation of Request° 9 Public Records Act/ Sunshine Request ‘Scott Nelson “Thu, Dee 14,2017 at 734 AM Te: "Quezada, Randolph (HOM « andy, You may ft any request o 6 months for any emis between your agency and Carans, DPW, andor the Mayors fice), and a year and aha (the eure ‘of HSH) for documents concerning your agency's efforts o alow a shat or feoding ation on Crane properyin SF | wil separately contact Acting Maror Breeds ofc o seak emails andor documents between Former Mayor Lee and CatTrans, Thanks forthe reminder. SootExhibit G - Inquiry to Quezada re Status° 9 Public Records Act / Sunshine Request ‘Scott Nelson i dan 5, 2018 at 927 AM, To: Randolph Quezada Randy, Please advise me ofthe satus ofthis request, Scott ——— Forwarded message ——~ From: Seott Nelson Date: Thu, Dec 14,2017 at 7:34 AM Subject: Re: Pubic Records Act / Sunshine Request hots aneExhibit H — Inquiry to Kositsky re Status© 3 Public Records Act / Sunshine Request ‘Scott Neleon Tos, Jan 9, 2018 at 6:05 PM. To; "efkostsky@st90v orp" et, This concems a Pubic Records / Sunshine Request | submited to your agency via Randy Quezada on November 8, 2017, seeking records of your agency's ‘offers to provide homeless services on CafTrans-owned propery. To date | have not received any ofthe requested records, nor any contact fem Randy ‘Shoe December #3, 2017. [As shown inthe included emads fom myself to Randy and back, on December 14,2017 | te the scope of my request inorder to help expedite However, having heard nothing further by January 5, 2018, l email Randy and inquired about he status ofthe request. But a of oday, anvary 9, 2018, 1 sfilhave not received copies ofthe records or even a status update Please lat me know the status of my request. Soot Nelson _——— Forwarded message From: Scott Nelson hotterExhibit I - Kositsky Automatic Reply© 3 ‘Automatic reply: Public Records Act / Sunshine Request Koataky, Jeff (HOM) Too, dan 9, 2078 at 6:08 PM. To Seat Nelson ‘Tank you wetng. Due tote high volume of emis ree. the ew das to respond you rue imma tron, contact csi kaerarD0¥0195 Inquiry to Keener re Status© ° Public Records Act / Sunshine Request ‘Scott Nelwon Date: Tue, Jan 8, 2018 at 805 PM ‘Subject Fwd: Public Records Act / Sunshine Request (OamssincnateyExhibit K — Keener Automatic Reply© ‘Automatic reply: Public Records Act / Sunshine Request ‘Keener, Christine (HOM) ‘To: Soot Neleon "am out of he ofc. his f urgent, please email Becky Van@@stgovorg. CK Wied, Jan 10,2018 a 12:16 PMExhibit L — Quezada Last Response) 3 Public Records Act / Sunshine Request ‘Quezada, Randolph (HOM) ‘Wed, Jan 10, 2018 at 12:50 PM To: Scot Nelson seat Apologies. Working on this now, ro From: Scott Nelson {maito:scot4102@gmal com) Sent: Friday, January 05, 2018 9:22 AM ‘To: Quezada, Randolph (HOM) Subject: Fwd: Public Records Act / Sunshine RequestcM-o1 en * cron ‘Complex Case Designation Unlimited — [_] Limited — med [counter (1 doinder eel Gemondedis | Filed wit frst appearance by defendant exceeds $25,000) _ $25,000 or ess) (Cal. Rules of Cour, rule 3.402) oO For CounT Ose Ou Sor els Ste is Street San Franciseo, CA 94102 FILE D scromeyrongumy PPO S° rane an Francia County SipertrCout "OR aT ge SAN FRANCISCO PUPeROR COURT © “ADB RRCATTISNEY Street FEB 20 2018 ae nese San Francisco, CA 94102 LER, QF THE COURT smmicuae A CASE NAME ; Dep Scott Nelson v Dept. of Homelessness and Supportive Housing, et al. CIVIL CASE COVER SHEET ‘CASE NUMBER: | O80-18-564457— Fi- Check one box Below for the case type that best describes this case: “tems 1-6 below must be completed (see instructions on page 2). ‘Auto Tort ‘Auto (22) Uninsured motorist (46) ‘Other PUPOAWD (Personal Injury/Property Product ability (24) (J Medical maipractice (45) I otner pueoiwn (23) ‘Non-PUPDIWD (Other) Tort Business torvunfae business practice (07) [2 civitiants (08) [J Defamation (13) SS Frava (18) Intellectual property (19) Professional negigence (25) ‘Other non-PUPDAND tort (35) Employment ‘Wrongful termination (38) [[) other employment (15) ‘Contract ‘Breach of contractwarranty (06) Rule 3.740 collections (08) ‘Other collections (08) Ingurance coverage (18) Other contract (37) Real Property Eminent domainfioverse ‘condermation (14) TZ) wrongful eviction (33) TF otter real property (26) Unlawful Detainer Commercial (31) Residential (32) CD nugs 28) Judicial Review ‘Asa oreture (05) Petition re: aritation award (11) 1 writ of mandate (02) [1 other judicial review (38) 00000 Provisionally Complex Civil Litigation (Gal. Rules of Court, rules 3.400-3.403) Antirust Trade regulation (03) TE) construction defect (10) TO mass tort (40) ‘Secures tigation (28) (J) EnwironmentavToxic tort (20) Inaurance coverage claims arising trom the hove ated proveonaly complex cave pest) Enforcement of Judgment 21 Enforcement of judgment (20) Miscellaneous Civil Complaint L recon ‘Other complaint (not specified above) (42) Miscollaneous Civil Petition Partnership and corporate governance (21) 1) other petition (not specified above) (43) 2. Thiscase [lis factors requiring exceptional judicial management: a. ) Large number of separately represented parties b.[_] Extensive motion practice raising difficult or novel Issues that will be time-consuming to resolve c.[] Substantial amount of documentary evidence Number of causes of action (specify): ‘This case (lis is not ate; February 20, 2018 cot Nelson TRE ORPRNT RE] J Coordination a class action suit. there are any known related cases, file and serve a notice of related case. (Yop may use form CM-015.) TetTis not complex under rule 3.400 of the Califomia Rules of Cour. Ifthe case is complex, mark the 4. 1 Large number of witnesses with related actions pending in one or more courts in other counties, states, or countries, or in a federal court 1. [) Substantial postjudgment judicial supervision Remedies sought (check aif that apply): a] monetary _b.[¢7] nonmonetary; declaratory or injunctive relief [punitive z NOTICE Fc pe RM OCA TORREY FOR PRET « Plaintiff must file this cover sheet with the frst paper filed in the action or proceeding (except small claims cases or cases filed under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to fle may result in sanctions. ‘= File this cover sheet in addition to any cover sheet required by local court rule. * If this case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all ‘other partes to the action or proceeding. '* Uniess this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes onl CIVIL CASE COVER SHEET ‘itstogRor day 207) Ta Raton aya STS