CITIZENS' CAMPAIGN TO FIX THE EXPO RAIL LINE

Led by Save Leimert, Expo Communities United & Baldwin Hills/Crenshaw Homeowners' Coalition
P. O. Box 781267 • Los Angeles, CA 90016 • Phone & Fax: (323) 761-6435 • www.FixExpo.org

July 14, 2008

Los Angeles County Metropolitan Transportation Authority

ATTN: Records Management Center
One Gateway Plaza
Los Angeles, CA 90012

Re: MTA’s Failure to Respond to Fix Expo’s Public Records Act Requests of May 6, 2008 & May 13, 2008

Dear Los Angeles County Metropolitan Transportation Authority:

This letter is in response to the Metropolitan Transportation Authority’s (“MTA”) violation of the California Public Records
Act (“CPRA”) regarding information requested under the act by the Citizens’ Campaign to Fix the Expo Rail Line (“Fix
Expo”) for Blue Line and Gold Line incidents/accidents involving youths and youngsters, originally dated May 6, 2008.

To recap the series of communication:

• On May 6, 2008, the Fix Expo CPRA request as corrected (see “Exhibit A”) was hand delivered to and received by
the Records Management Control (“RMC”) office at MTA headquarters.

• On May 13, 2008, David Lor, MTA’s Records & Information Coordinator sent an email (see “Exhibit B”) with an
attached letter from MTA’s RMC Supervisor Joe Parise (see “Exhibit C”) to myself indicating that information
regarding requests #4 – 9 of the Fix Expo CPRA request is exempt from disclosure stating, “the documentation is
a matter of personal privacy.” Requests #4 - 9 are for documents/information regarding train/vehicle and
train/pedestrian incidents and accidents with the Blue Line and Gold Line and youths and youngsters. Why MTA
did not simply redact the names and addresses of the individuals involved, as is the standard practice of
every public agency in the State of California, is beyond any logical explanation.

• Nonetheless, to further address the concern stated in Mr. Lor’s letter, on May 13, 2008, I responded to Mr. Lor
via an email, which was CCed to Mr. Parise (see “Exhibit B”), clarifying the request and limiting it solely to the
location, time, date of incident and age of individuals:

“Information on such reports may be redacted if found legally necessary to fulfill this request, but
among the information that should not be redacted shall be: the location, time and date of the
incident, and the age of all individuals involved…”

• The Records Management Control office has failed to respond to the request as clarified.

The Fix Expo CPRA request is not complex or uneasy to understand, and the documents/information is not difficult for
your Records Management Center to obtain. Fix Expo is requesting documents/information from the MTA about youths
and youngsters that have been injured and killed in accidents and incidents with publicly financed and operated MTA
trains, and the MTA, a public agency, is refusing to supply it.

The public is entitled to this information, and Fix Expo has patiently waited over 68 days to receive it. The request as
clarified on May 13, 2008 is hereby resubmitted, and Fix Expo expects to receive the requested documents/information
expeditiously.

All requests for further information can be directed to:

Damien Goodmon
EMAIL: xx@xxxxxxx.xxx
PHONE: (xxx) xxx-xxxx

1 of 2
Sincerely,

_________________________________
Damien W.C. Goodmon
Coordinator

ATTACHED: Resubmitted Fix Expo CPRA Request hand and email delivered to MTA on July 14, 2008
Exhibit A: Fix Expo CPRA Request hand delivered to MTA on May 6, 2008
Exhibit B: Email Communication between Damien Goodmon and David Lor of MTA RMC on May 13, 2008
Exhibit C: May 13, 2008 Letter from Joe Parise of MTA RMC rejecting Fix Expo CPRA Requests #4-9

CC:
Law Firm of Sonnenschein, Nath & Rosenthal, LLP
Law Firm of Heller & Edwards
Law Firm of Strumwasser & Woocher, LLP
FTA Administrator James Simpson
FTA Region IX Administrator Leslie Rogers
FTA Los Angeles Office
U.S. Senator Dianne Feinstein
U.S. Senator Barbara Boxer
Congresswoman Diane Watson
California Attorney General Edmund G. Brown, Jr.
State Senator Mark Ridley-Thomas
Assembly Speaker Karen Bass
Assembly Member Mike Davis
MTA Board of Directors
Expo Line Construction Authority Board of Directors
Los Angeles City Board of Education

2 of 2