HomeMy WebLinkAbout4241 E BRUNDAGE LN 5-1-201441%r
8 IE R S F l D
FIRE
wRTM r
www.HakersfieldFire.us
e -mail: firecetbakersfieldfire.us
Douglas R. Greener
Fire Chief
Deputy Chief Tyler Hartley
Operations /Training /Arson
661 - 326 -3655
Deputy Chief Ross Kelly
Fire Prevention /EMS /USAR
661 - 326 -3652
Fire Department Headquarters
2101 H Street, Floor 1
Bakersfield, CA 93301
(661) 326 -3911 (main)
(661) 852 -2170 (fax)
Fire Department Community
Services / Public Information
2101 H Street, Floor 1
Bakersfield, CA 93301
(661) 326 -3688 (office)
(661) 852 -2170 (fax)
Fire Prevention Division
2101 H Street, Floor 2
Bakersfield, CA 93301
(661) 326 -3979 (main)
(661) 852 -2171 (fax)
Fire Training Division
5642 Victor Street (ODFTF)
Bakersfield, CA 93308
(661) 399 -4697 (main)
(661) 399 -5763 (fax)
Arson Division
2101 H Street, Floor 2
Bakersfield, CA 93301
(661) 326 -3911 (main)
(661) 852 -2172 (fax)
March 12, 2014
Mr. Joe Landa
Elite Collision Centers Inc.
4241 E. Brundage Ln
Bakersfield, CA 93307
Certified Mail
RE: ELITE COLLISION CENTERS INC. DOCKET NO: 2014 -01
Dear Mr. Landa,
Enclosed is a Consent Agreement concerning violations of section
25113(1) of the California Health and Safety Code for Elite Collision
Centers Inc. in Bakersfield California. Your facility was found to have
illegally disposed of hazardous waste during a recent inspection.
This Consent Agreement is in response to assurances your business
manager has provided that the hazardous waste is now managed to prevent
any further violations. Accordingly, the penalty has been revised
downward from $5,000 to $1,250 in recognition of the good faith efforts.
Please remit the penalty and signed agreement within 30 days as stipulated.
If you have any questions, please feel free to call me at (661) 326 -3659.
Sincerely,
Howard H. Wines, III PG 7239
Director of Prevention Services
Enclosure
cc: J. Rudnick, City Attorney's Office
R. Kelly, Deputy Fire Chief
T. Crosby, Business Manager
BAICERSFIELD FIRE DEPARTMEi,,IT o 2101 H STREET o BAKERSFIELD, CA, 93301 x661- 3:26 -391 1
"Serving the Community for Over a Century"
STATE OF CALIFORNIA
CITY OF BAKERSFIELD
CERTIFIED UNIFIED PROGRAM AGENCY
In the Matter of:
ELITE COLLISION CENTERS INC
Docket No.: 2014-01
ORDER OF CONSENT AGREEMENT
A BAKERSFIELD CITY BUSINESS # 127946 1 Health and Safety Code Section 25187
Respondent.
INTRODUCTION
1. Parties. The Office of Prevention Services for the City of Bakersfield Fire
Department, a Certified Unified Program Agency (CUPA) authorized by the Secretary of the
California Environmental Protection Agency (Cal/EPA) to administer and enforce the
Hazardous Substances Act in the City of Bakersfield, issues this Enforcement Order (Order)
to ELIETE COLLISION CENTERS INC, doing business in the City of Bakersfield.
1.2. Owner / Operator. Respondent owns and operates this business at 4241 E.
BRUNDAGE LANE in Bakersfield, California 93307.
1.3 Generator. The Respondent generated the following hazardous wastes:
Paint waste containing VOC.
1.4 Jurisdiction. Section 25187 of the Health and Safety Code (HSC) authorizes
the CUPA to order action necessary to correct violations and assess a penalty when the
CUPA determines that any person has violated specified provisions of the Health and
Safety Code or any permit, rule, regulation, standard, or requirement issued or adopted
pursuant thereto.
DETERMINATION OF VIOLATIONS
2. The CUPA hereby determines.that Respondent violated:
2.1 The Hazardous Waste Control Law, California Health and Safely Code section
25113(1), to wit: The discharge, deposit, injection, dumping, spilling, leaking,
1
or placing of f any waste so that that the waste or any constituent of the waste
is or may be emitted into the air or discharged into or on any land or waters,
including groundwater, or may otherwise enter the environment.
2.2 Noted April 17, 2014, on a routine hazardous materials inspection several
canisters of waste paint materials discarded into a standard metal trash can
with a plastic liner.
SCHEDULE FOR COMPLIANCE
3. Based on the forgoing DETERMINATION OF VIOLATIONS, IT IS HEREBY
ORDERED THAT:
3.1 The Respondent shall make arrangements to properly dispose of hazardous
waste by obtaining an approved hazardous waste drum.
3.2 Submittals. A copy of the required documentation designed to demonstrate
full compliance with both this Enforcement Order shall be forwarded within fifteen (15) days
from the date of this Order to:
Mr. Howard H. Wines, III PG 7239
Director of Prevention Services
City of Bakersfield
2101 H Street
Bakersfield, California 93301
3.3 Communications. All approvals and decisions of the CUPA made regarding
submittals and notifications will be communicated to Respondent in writing by the Director of
Prevention Services or his /her designee. No informal advice, guidance, suggestions, or
comments by the CUPA regarding reports, plans, specifications, schedules, or any writings
by the Respondent shall be construed to relieve Respondent of the obligation to obtain such
formal approvals as may be required.
3.4 CUPA Review and Approval. If the CUPA determines that the schedule or
other submitted for approval pursuant to this order fails to comply with the order or fails to
protect public health or safety or the environment, the CUPA may:
N
a. Modify the document as deemed necessary and approve the document as
modified, or
b. Return the document to Respondent with recommended changes and a date
by which Respondent with recommended changes and a date by which Respondent must
submit to the CUPA a revised document incorporating the recommended changes.
3.5 Compliance with Applicable Laws. Respondent shall carry out this Order in
compliance with all local, State, and federal requirements, including but not limited to
requirements to obtain permits and to assure worker safety.
3.6 Endangerment during Implementation. In the event that the CUPA determines
that any circumstances or activity (whether or not pursued in compliance with this Order) are
creating an imminent or substantial endangerment to the health or welfare of people on the
site or in the surrounding area or to the environment, the CUPA may order Respondent to
stop further implementation of this Order for such period of time as needed to abate the
endangerment. Any deadline in this Order directly affected by a Stop Work Order under this
section shall be extended for the term of the Stop Work Order.
3.7 Liabilit . Nothing in this Order shall constitute or be construed as a
satisfaction or release from liability for any conditions or claims arising as a result of past,
current, or future operations of Respondent other than those violations alleged in section 2
of this order. Notwithstanding compliance with the terms of this Order, Respondent may be
required to take further actions as are necessary to protect public health or welfare or the
environment.
3.8 Data and Document Availability. Respondent shall permit the CUPA and its
authorized representatives to inspect and copy all sampling, testing, monitoring, and other
data generated by Respondent or on Respondent's behalf in any way pertaining to work
undertaken pursuant to this Order. Respondent shall allow the CUPA and its authorized
representatives to take duplicates of any samples collected by Respondent pursuant to this
Order. Respondent shall maintain a central depository of the data, reports, and other
documents prepared pursuant to this Order. All such data, reports, and other documents
shall be preserved by Respondent for a minimum of three years after the conclusion of all
3
activities under this Order. If the CUPA requests that some or all of these documents be
preserved for a longer period of time, Respondent shall comply with that request, deliver the
documents to the CUPA, or permit the CUPA to copy the documents prior to destruction.
3.9 Government Liabilities. The City of Bakersfield shall not be liable for injuries
or damages to persons or property resulting from acts or omissions by Respondent or
related parties specified in paragraph 3.15 in carrying out activities pursuant to this Order,
nor shall the City of Bakersfield be held as a party to any contract entered into by
Respondent or its agents in carrying out activities pursuant to the Order.
3.10 Additional Enforcement Actions. By issuance of this Order, the CUPA does
not waive the right to take further enforcement actions.
3.11 Incorporation of Plans and Reports. All plans, schedules, and reports that
require CUPA approval and are submitted by respondent pursuant to this Order are
incorporated in this Order upon approval by the CUPA.
3.12 Extension Request. If Respondent is unable to perform any activity or submit
any document within the time required under this Order, the Respondent may, prior to
expiration of the time, request an extension of time in writing. The extension request shall
include a justification for the delay.
3.13 Extension Approvals. If the CUPA determines that good cause exists for an
extension, it will grant the request and specify in writing a new compliance schedule.
3.14 Penalties for Noncompliance. Failure to comply with the terms of this Order
may also subject Respondent to costs, penalties, and /or punitive damages for any costs
incurred by the CUPA or other government agencies as a result of such failure, as provided
by HSC section 25188 and other applicable provisions of law.
3.15 Parties Bound. This Order shall apply to and be binding upon Respondent,
and its officers, directors and agents, including but not limited to individuals, and upon the
CUPA and any successor agency that may have responsibility for and jurisdiction over the
subject matter of this order.
2
PENALTY
4. The CUPA assesses a penalty of one thousand, two hundred and fifty dollars
($ 1,250.00). Payment of the total penalty of one thousand, two. hundred and fifty dollars ($
1,250.00) is due within thirty (30) days from the effective date of the Order. Respondent's
check shall be made payable to the City of Bakersfield, Certified Unified Program Agency
and shall identify the Respondent and the Docket Number, as shown in the heading of this
case. Respondent shall deliver the penalty payment to:
Ms. Toni Crosby
Business Manager
City of Bakersfield Fire Department
2101 H Street
Bakersfield, California 93301
A photocopy of the check shall be sent to:
Mr. Howard H. Wines, III PG 7239
Director of Prevention Services
2101 H Street
Bakersfield, California 93301
5. This Order is final and effective upon execution by the City and Respondent.
6. "Days" for purposes of this Order means calendar days.
Date of Issuance: May 12, 2014
Mr. Howard H. Wines III PG 7239
Director of Prevention Services
City of Bakersfield
ELITE COLLISION CENTERS INC
Typed or Printed Name of
Respondent's Representative
cc: Mr. Joshua Rudnick
Deputy City Attorney
5
Date
Date
Douglas -
a Fire Chief v
Deputy Chief Tyler Hartley
Operations /Training /Arson
661- 326 -3655
Deputy Chief Ross Kelly
Fire Prevention /EMS /USAR
661 -326 -3652
Fire Department Headquarters
2101 H Street, Floor 1
Bakersfield, CA 93301
(661) 326 -3911 (main)
(661) 852 -2170 (fax)
Fire Department Community
Services / Public information
2101 H Street, Floor 1
Bakersfield, CA 93301
(661) 326 -3688 (office)
(661) 852 -2170 (fax)
Fire Prevention Division
2101 H Street, Floor 2
Bakersfield, CA 93301
(661) 326 -3979 (main)
(661) 852 -2171 (fax)
Fire Training Division
5642 Victor Street (ODFTF)
Bakersfield, CA 93308
(661) 399 -4697 (main)
(661) 399 -5763 (fax)
Arson Division
2101 H Street, Floor 2
Bakersfield, CA 93301
(661) 326 -3911 (main)
(661) 852 -2172 (fax)
April 21, 2014
Mr. Joe Landa
Elite Collision Centers Inc.
4241 E. Brundage Lane
Bakersfield California 93307
Certified Mail
RE: ELITE COLLISION CENTERS INC. Docket No: 2014 -01
Dear; Mr. Landa
Enclosed is an Enforcement Order concerning violations of 25113(l) of
the California Health and Safety Code for Elite Collision Centers Inc. in
Bakersfield, California. Your facility was found to . have illegally
disposed of hazardous waste during a recent inspection.
You are invited to attend an informal conference at 10:00 am on
Wednesday May 8, 2014 at 2101 H Street, Bakersfield, California
93301.
If you have any questions, please feel free to call. m C- - s 6 ,
Sincerely,
Howard H. Wines, III PG 7239
Director of Prevention Services
Enclosures
cc: J. Rudnick, City Attorney's Office
R. Kelly, Deputy Fire Chief
T. Crosby, Business Manager
BAKERSFIELD FIRE DEPARTMENT' a 2101 H STREET e BAKERSFIE:LD, CA. 93301 0661 -326 -391 1
"Serving the Community for Over a Century"
STATE OF CALIFORNIA
CITY OF BAKERSFIELD
CERTIFIED UNIFIED PROGRAM AGENCY
In the Matter of:
ELITE COLLISION CENTERS INC
A BAKERSFIELD CITY BUSINESS # 127946
Respondent
TO THE ABOVE RESPONDENT:
Docket No.: 2014-01
STATEMENT TO RESPONDENT
Enforcement Order
An Enforcement Order ("Order") is attached to this statement and is hereby
served upon you. The Order has been filed by the City of Bakersfield Certified Unified
Program Agency (CUPA).
Unless a written request for a hearing signed by you or on your behalf is
delivered or mailed to the CUPA within fifteen (15) days after you have received a copy
of the Order, you will be deemed to have waived your right to a hearing in this matter. If
you do not file a timely hearing request, the Order becomes final automatically.
The request for a hearing may be made by delivering or mailing one copy of the
enclosed form entitled "Notice of Defense" or by delivering or mailing a Notice of
Defense as provided in Section 11506 of the Government Code to:
Mr. Joshua Rudnick
Deputy City Attorney
City Attorney's Office
City of Bakersfield th
1600 Truxtun Avenue 4 Floor
Bakersfield, California 93301
Telephone: (661) 326-3721
1
The enclosed Notice of Defense, if signed and filed with the CUPA, is deemed a
specific denial of all parts of the Order, but you will not be permitted to raise any
objection to the form of the Order unless you file a further Notice of Defense as provided
in Section11506 of the Government Code within fifteen (15) days after service of the
Order upon you.
If you file a Notice of Defense within the time permitted, a hearing on the
allegations made in the Order will be conducted by the Office of Administrative Hearings
of the Department of General Services in accordance with the procedures specified in
Health and Safety Code section 25187 and Government Code sections 11507, et seq.
The hearing may be postponed for good cause. If you have good cause, you
must notify the CUPA within ten (10) working days after you discover the good cause.
Failure to notify the CUPA within ten (10) working days will deprive you of a
postponement.
Copies of Government Code Sections 11507.5, 11507.6 and 11507.7 are
attached. If you desire the names and addresses of witnesses or an opportunity to
inspect and copy items in possession, custody or control of the CUPA, you may contact:
Mr. Joshua Rudnick
Deputy City Attorney
City Attorney's Office
City of Bakersfield
1600 Truxtun Avenue 4t" Floor
Bakersfield, California 93301
Telephone: (661) 326 -3721
Whether or not you have a hearing, you may confer informally with the CUPA to
discuss the alleged facts, determinations, corrective actions and penalty. An informal
conference does not, however, postpone the fifteen (15) day period you have to request
a hearing on the Order. An informal conference may be pursued simultaneously with
the hearing process.
You may, but are not required, to be represented by counsel at any or all stages
of these proceedings.
INFORMAL CONFERENCE
If you wish to discuss this matter with the CUPA, an Informal Conference has
been scheduled for:
Date: Thursday May 8, 2014
Time: 10:00 AM
Location: Bakersfield Fire Department
Prevention Services Division
City of Bakersfield
2101 H Street
Bakersfield, California 93301
(661) 326-3979
You may inform the CUPA at the conference whether you wish to pursue a
formal hearing or waive your right to a formal hearing, as explained below.
FORMAL HEARING RIGHTS
YOU MUST FILE A WRITTEN REQUEST FOR A HEARING WITHIN FIFTEEN
(15) DAYS IF YOU WISH TO HAVE A FORMAL HEARING.
K,
STATE OF CALIFORNIA
CITY OF BAKERSFIELD
CERTIFIED UNIFIED PROGRAM AGENCY
In the Matter of:
ELITE COLLISION CENTERS INC
A BAKERSFIELD CITY BUSINESS # 127946
Respondent.
Docket No.: 2014-01
ENFORCEMENT ORDER
Health and Safety Code Section
25187
INTRODUCTION
1. Parties. The Office of Prevention Services for the City of Bakersfield Fire
Department, a Certified Unified Program Agency (CUPA) authorized by the Secretary of the
California Environmental Protection Agency (Cal/EPA) to administer and enforce the
Hazardous Substances Act in the City of Bakersfield,, issues this Enforcement Order (Order)
to ELIETE COLLISION CENTERS INC, doing business in the City of Bakersfield.
1.2. Owner / Operator. Respondent owns and operates this business at 4241 E.
BRUNDAGE LANE in Bakersfield, California 93307.
1.3 Generator. The Respondent generated the following hazardous wastes:
Paint waste containing VOC.
1.4 Jurisdiction. Section 25187 of the Health and Safety Code (HSC) authorizes
the CUPA to order action necessary to correct violations and assess a penalty when the
CUPA determines that any person has violated specified provisions of the Health and
Safety Code or any permit, rule, regulation, standard, or requirement issued or adopted
pursuant thereto.
DETERMINATION OF VIOLATIONS
2. The CUPA hereby determines that Respondent violated:
2.1 The Hazardous Waste Control Law, California Health and Safety Code section
25113(1), to wit: The discharge, deposit, injection, dumping
spilling, leaking,
1
or placing of any waste so that that the waste or any constituent of the waste
is or may be emitted into the air or discharged into or on any land or waters,
including groundwater, or may otherwise enter the environment.
2.2 Noted April 17, 2014, on a routine hazardous materials inspection several
canisters of waste paint materials discarded into a standard metal trash can
With a plastic liner.
SCHEDULE FOR COMPLIANCE
3. Based on the forgoing DETERMINATION OF VIOLATIONS, IT IS HEREBY
• HMI IS, a I-M I M F.", I
3.1 The Respondent shall make arrangements to properly dispose of hazardous
waste by obtaining an approved hazardous waste drum.
3.2 Submittals. A copy of the required documentation designed to demonstrate
full compliance with both this Enforcement Order shall be forwarded within fifteen (15) days
from the date of this Order to:
Mr. Howard H. Wines, III PG 7239
Director of Prevention Services
City of Bakersfield
2101 H Street
Bakersfield, California 93301
3.3 Communications. All approvals and decisions of the CUPA made regarding
submittals and notifications will be communicated to Respondent in writing by the Director of
Prevention Services or his/her designee. No informal advice, guidance, suggestions, or
comments by the CUPA regarding reports, plans, specifications, schedules, or any writings
by the Respondent shall be construed to relieve Respondent of the obligation to obtain such
formal approvals as may be required.
3.4 CUPA Review and Approval. If the CUPA determines that the schedule or
other submitted for approval pursuant to this order fails to comply with the order or fails to
protect public health or safety or the environment, the CUPA may:
2
a. Modify the document as deemed necessary and approve the document as
modified, or
b. Return the document to Respondent with recommended changes and a date
by which Respondent with recommended changes and a date by which Respondent must
submit to the CUPA a revised document. incorporating the recommended changes.
3.5 Compliance with Applicable Laws. Respondent shall carry out this Order in
compliance with all local, State, and federal requirements, including but not limited to
requirements to obtain permits and to assure worker safety.
3.6 Endangerment during Implementation. In the event that the CUPA determines
that any circumstances or activity (whether or not pursued in compliance with this Order) are
creating an imminent or substantial endangerment to the health or welfare of people on the
site or in the surrounding area or to the environment, the CUPA may order Respondent to
stop further implementation of this Order for such period of time as needed to abate the
endangerment. Any deadline in this Order directly affected by a Stop Work Order under this
section shall be extended for the term of the Stop Work Order.
3.7 Liability. Nothing in this Order shall constitute or be construed as a
satisfaction or release from liability for any conditions or claims arising as a result of past,
current, or future operations of Respondent other than those violations alleged in section 2
of this order. Notwithstanding compliance with the terms of this Order, Respondent may be
required to take further actions as are necessary to protect public health or welfare or the
environment.
3.8 Data and Document Availability. Respondent shall permit the CUPA and its
authorized representatives to inspect and copy all sampling, testing, monitoring, and other
data generated by Respondent or on Respondent's behalf in any way pertaining to work
undertaken pursuant to this Order. Respondent shall allow the CUPA and its authorized
representatives to take duplicates of any samples collected by Respondent pursuant to this
Order. Respondent shall maintain a central depository of the data, reports, and other
documents prepared pursuant to this Order. All such data, reports, and other documents
shall be preserved by Respondent for a minimum of three years after the conclusion of all
3
activities under this Order. If the CUPA requests that some or all of these documents be
preserved for a longer period of time, Respondent shall comply with that request, deliver the
documents to the CUPA, or permit the CUPA to copy the documents prior to destruction.
3.9 Government Liabilities. The City of Bakersfield shall not be liable for injuries
or damages to persons or property resulting from acts or omissions by Respondent or
related parties specified in paragraph 3.15 in carrying out activities pursuant to this Order,
nor shall the City of Bakersfield be held as a party to any contract entered into by
Respondent or its agents in carrying out activities pursuant to the Order.
3.10 Additional Enforcement Actions. By issuance of this Order, the CUPA does
not waive the right to take further enforcement actions.
3.11 Incorporation of Plans and Reports. All plans, schedules, and reports that
require CUPA approval and are submitted by respondent pursuant to this Order are
incorporated in this Order upon approval by the CUPA.
3.12 Extension Request. If Respondent is unable to perform any activity or submit
any document within the time required under this Order, the Respondent may, prior to
expiration of the time, request an extension of time in writing. The extension request shall
include a justification for the delay.
3.13 Extension Approvals. If the CUPA determines that good cause exists for an
extension, it will grant the request and specify in writing a new compliance schedule.
3.14 Penalties for Noncompliance. Failure to comply with the terms of this Order
may also subject Respondent to costs, penalties, and /or punitive damages for any costs
incurred by the CUPA or other government agencies as a result of such failure, as provided
by HSC section 25188 and other applicable provisions of law.
3.15 Parties Bound. This Order shall apply to and be binding upon Respondent,
and its officers, directors and agents, including but not limited to individuals, and upon the
CUPA and any successor agency that may have responsibility for and jurisdiction over the
subject matter of this order.
0
F ► IN rV/
4. The CUPA assesses a penalty of five thousand ($ 5,000). Payment of the
total penalty of five thousand ($ 5,000) is due within thirty (30) days from the effective date
of the Order. Respondent's check shall be made payable to the City of Bakersfield,
Certified Unified Program Agency and shall identify the Respondent and the Docket
Number, as shown in the heading of this case. Respondent shall deliver the penalty
payment to:
Ms. Toni Crosby
Business Manager
City of Bakersfield Fire Department
2101 H Street
Bakersfield, California 93301
A photocopy of the check shall be sent to:
Mr. Howard H. Wines, III PG 7239
Director of Prevention Services
2101 H Street
Bakersfield, California 93301
5. This Order is final and effective upon execution by the City and Respondent.
6. "Days" for purposes of this Order means calendar days.
Date of Issuance: April 21, 2014
Mr. Howard H. Wines III PG 7239
Director of Prevention Services
City of Bakersfield
ELITE COLLISION CENTERS INC
Typed or Printed Name of
Respondent's Representative
cc: Mr. Joshua Rudnick
Deputy City Attorney
Date
Date
STATE OF CALIFORNIA
CITY OF BAKERSFIELD
CERTIFIED UNIFIED PROGRAM AGENCY
In the Matter of:
ELITE COLLISION CENTERS INC.
A BAKERSFIELD CITY BUSINESS #
12:946
Respondent.
Docket No.: 2014-01
NOTICE OF DEFENSE
Health and Safety Code
k
section 25187
t
1, the undersigned Respondent, acknowledge receipt of a copy of the
Enforcement Order, Statement to Respondent, Government Code sections 11507.5,
11507.6 and 11507.7, and two copies of this Notice of Defense.
I request a hearing to permit me to present my defense to the allegations
contained in the Enforcement Order.
Dated:
(Signature of Respondent)
Please Type or Print the Name and Mailing
Address of Respondent
(Name)
(Street Address)
(City) (State) (zip)
(Telephone Number)
1
Government Code Section 11507.5
The provisions of Section 11507.6 provide the exclusive right to and
method of discovery as to any proceeding governed by this chapter.
Government Code Section 11507.6
After initiation of a proceeding in which a respondent or other party
is entitled to a hearing on the merits, a party, upon written request
made to another party, prior to the hearing and within 30 days after
service by the agency of the initial pleading or within 15 days after
the service of an additional pleading, is entitled to (1) obtain the
names and addresses of witnesses to the extent known to the other
party, including, but not limited to, those intended to be called to
testify at the hearing, and (2) inspect and make a copy of any of the
following in the possession or custody or under the control of the
other party:
(a) A statement of a person, other than the respondent, named in the
initial administrative pleading, or in any additional pleading, when it
is claimed that the act or omission of the respondent as to this person
is the basis for the administrative proceeding;
(b) A statement pertaining to the subject matter of the proceeding
made by any party to another party or person;
(c) Statements of witnesses then proposed to be called by the party
and of other persons having personal knowledge of the acts, omissions
or events which are the basis for the proceeding, not included in (a)
or (b) above;
(d) All writings, including, but not limited to, reports of mental,
physical and blood examinations and things which the party then
proposes to offer in evidence;
(e) Any other writing or thing which is relevant and which would be
admissible in evidence;
(f) Investigative reports made by or on behalf of the agency or
other party pertaining to the subject matter of the proceeding, to the
extent that these reports (1) contain the names and addresses of
witnesses or of persons having personal knowledge of the acts,
omissions or events which are the basis for the proceeding, or (2)
reflect matters perceived by the investigator in the course of his or
her investigation, or (3) contain or include by attachment any
statement or writing described in (a) to (e), inclusive, or summary
thereof.
For the purpose of this section, "statements" include written
" statements by the person signed or otherwise authenticated by him or
her, stenographic, mechanical, electrical or other recordings, or
transcripts thereof, of oral statements by the person, and written
reports or summaries of these oral statements.
Nothing in this section shall authorize the inspection or copying of
any writing or thing which is privileged from disclosure by law or
otherwise made confidential or protected as the attorney's work
product.
Government Code Section 11507.7
(a) Any party claiming the party's request for discovery pursuant to
Section 11507.6 has not been complied with may serve and file with the
administrative law judge a motion to compel discovery, naming as
respondent the party refusing or failing to comply with Section
11507.6. The motion shall state facts showing the respondent party
failed or refused to comply with Section 11507.6, a description of the
matters sought to be discovered, the reason or reasons why the matter
is discoverable under that section, that a reasonable and good faith
attempt to contact the respondent for an informal resolution of the
issue has been made, and the ground or grounds of respondent's refusal
so far as known to the moving party.
I (b) The motion shall be served upon respondent party and filed
within 15 days after the respondent party first evidenced failure or
refusal to comply with Section 11507.6 or within 30 days after request
was made and the party has failed to reply to the request, or within
another time provided by stipulation, whichever period is longer.
(c) The hearing on the motion to compel discovery shall be held
within 15 days after the motion is made, or a later time that the
administrative law judge may on the judge's own motion for good cause
determine. The respondent party shall have the right to serve and file
a written answer or other response to the motion before or at the time
of the hearing.
(d) Where the matter sought to be discovered is under the custody or
control of the respondent party and the respondent party asserts that
the matter is not a discoverable matter under the provisions of
Section 11507.6, or is privileged against disclosure under those
provisions, the administrative law judge may order lodged with it
matters provided in subdivision (b) Of Section 915 of the Evidence
Code and examine the matters in accordance with its provisions.
(e) The administrative law judge shall decide the case on the
matters examined in camera, the papers filed by the parties, and such
oral argument and additional evidence as the administrative law judge
may allow.
(f) Unless otherwise stipulated by the parties, the administrative
law judge shall no later than 15 days after the hearing make its order
denying or granting the motion. The order shall be in writing setting
forth the matters the moving party is entitled to discover under
Section 11507.6. A copy of the order shall forthwith be served by mail
by the administrative law judge upon the parties. Where the order
grants the motion in whole or in part, the order shall not become
effective until 10 days after the date the order is served.
Where the order denies relief to the moving party, the order shall be
effective on the date it is served.