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SUBMIT TO CITY CLERK


City Hall
2263 Santa Clera Ave" SUlt6 :380
Alameda, CA 94501

J\iMl A AJN$T TI-it; PITY OJ:.ALAMeD.,

Claimant' jams;

Cliilmant' s Address;

Cisimant' s Daytime Ph0l16 No: Cell. No:

Gender. M

Driver s

When did t"'e damage


P. Date of Birth

License No:

OJ: injury occur (date ari


Stat IExp.

time)?
SSN:

Date:--
December 28 , 2. O l O at the 5 : 30
pm Special Meeting of the City Council

Piar;eofoccurrnCe.: Alameda City HalJ, 2263 Sta. Clara Ave. AlamedSf, CA 94501
What happenad and why. is the City responsible 1.3ee At ta.. rnen t

Name of cay's employ. (s) GatJ jng injury or df;mcsge , If known: Lena Tam, Hari e Gilmore

Rob Bonta
Description of damage N ioss: vJaqe loss, emotional dlstress. damaqes
attorney fees and costs

Tota! arn-ounl de/moo: The amount claimed, as of the date of presen..ft tio:l
of the claim, exceeds the jurisdictional mlnimum ror the C:i Unli,nited
Supenol J:Ct. The amount claimed exceE:-\s $25, 000.
! r,, 1-"'1 Y%",,
Oats: /?i.J' Sfgnod: f tl r.o
. Under a!\ 1:11 e9, tt1\ " IGm ac&!lo;, F.n Hlf ion fA' 1' of :aGO? (MMSEt.i" , rnand(ttory ro\'o;11Ui0
roq\,!rnmlinw. ro ai cfa!fTnt$ r0'\.Ii, at Soc.lal (;I.rl NUrn r bt! !UO , uMef penally o.f 1m'\,
""f tate! amOlin than
YI;ilmucl 1m tilE/a! $10, 01;1). 00, Bn!!Or Iimol.i' cJl5lmed ""d thl' Dt:lJln for oomp t1cm e: thai !lmol.nt If It I
mOfI !GI $10, DOO. , Im:!le1w WhGHI"-r h(j rnunjcipl1! or !B!.r,tWI r (;ourt WOIlt! JijW JUr1$QIC'IOfl, Gc;v!;rmmmt Cadi! 8!1cUam
010(1'.
( \,, . _

Phone 831531.4211
Fax 831634. 0333

LAW GROUP, LLP . pola rislawgroup. com


501 San Benito Street , Suite 200
Hollister , California 95023

(:\1:"
Direct Di9l (ST1) 531- 4214
Email: bil(ipolarislawgroup. com

March 8 , 2011

City Clerk
City Hall
2263 Santa Clara Ave. , Suite 380
Alameda , CA 94501

Via Certified U. S. Mail

Re: TOliClaim of Ann Marie Gallant

To Whom It May Concern:

I represent Ann Marie Gallant. Please find enclosed a tort claim on behalf of Ann
Marie Gallant. Please direct all notices to me.

Note: your tort claim form seeks personnel information which is protected by the
California Constitution , Article I , Section 1. Specifically, the address , phone number
social security number , and driver s license information are confidential personnel
inforn1ation. Please redact this information from any versions of this document that are
available to the public.

If you have any questions or concerns , please do not hesitateto contact me.

Very truly yours

Polaris Law Group LLP

Wiliam 1. Marder
Attachment to Tort Claim of Ann Marie Gallant

I was terminated because (1) I refused to participate in illegal activity; and (2) I disclosed
information pertaining to ilegal activity to government agencies. The illegal conduct
was done by City Council Member Lena Tam. The laws violated include , but are not
limited to ,the Ralph M. Brown Act , Government Code section 54950 et. seq. (" The
Brown AcC), Government Code sections 3060- 3075 , Sections 7- 2 and 7- 3 of the City
Charter , and Article I , Section 1 of the California Constitution. Ms. Tam s ilegal
conduct is discussed in detail in a March 26 2010 letter from Michael G. Colantuono
Esq. to Lawrence Blazer , Assistant District Attorney, Alameda County District
Attorney s Office.

I reported all of the information regarding Ms. Tam s illegal conduct to (1) Michael G.
Colantuono , Esq. , the Special Counsel for the City of Alameda; (2) the Alameda City
Attorney, Teresa Highsmith; (3) and the Alameda County District Attorney s Offce. I
made the decision to hire Special Counsel Michael Colantuono to investigate my
concerns ofillegal conduct. Mr. Colantuono s investigation confirmed that Ms. Tam
engaged in the ilegal conduct and resulted in Ms. Tam s ilegal conduct being reported to
the Alameda County District Attorney s Offce.

On December 28 2010 , the Alameda City Council voted to terminate my contract. Ms.
Tam influenced two other council members , Marie Gilmore-now the mayor-and Rob
Bonta-a newly elected council member-to vote to terminate my contract. Council
Member Tam used her inf1uence to help get Marie Gilmore and Rob Bonta elected. Ms.
Tam publicly endorsed Ms. Gilmore and Mr. Bonta and she raised money for both of
their campaigns.

The December 28 , 2010 vote to terminate my contract was done in violation of Section 2-
2 of the City Charter. Specifically, Mr. Bonta was sworn in on December 21 , 2010.
Pursuant to Section 2- 2 of the City Charter , the City Council was prohibited from
terminating my contract until ninety days had elapsed from December 21 2010.

The legal claims that wi1 be brought include , but are not limited to , Labor Code
II02, 5(b), Labor Code 11 02. 5( c), and declaratory relief.
PROOF OF SERVICE
I am employed by the POLARIS LAW GROUP LLP in the County of San Benito,
California. I am over the age of 18 and not a party to the within action. My business address is
501 San Benito Street , Suite 200, Hollister , California 95023.

On this date I caused to be served the within Claim Against The City of Alameda on
the parties in his action , by placing copies of same in envelopes, addressed as follows and
delivered in the manner indicated:

City Clerk
City Hall
2263 Santa Clara Ave. Ste. 380
Alameda , CA 94501

- (By CERTIFIED Mail) I caused each envelope , with postage prepaid to be placed in the
United States mail at Hollister , California. lam readily familiar with the business practices of the
firm regarding the collection and. processing of correspondence for. mailing with the United

States Postal Service. Pursuant to such business practices, and in the . ordinary course of
business , all correspondence is deposited with the United States Postal Service on the same
day it is placed for collection and mailing.
(By Courier) I delivered the envelopes to UPS who contracted to deliver the envelope
to the addressee on the same day 1L next day.
(By Hand) I delivered the envelope to addressee.
(By Telecopier) I also caused each documentto be sent by telecopierto the fax numbers
stated above. The transmissions were reported as complete and without error.
- By E= Mail) I caused each document to be send via e-mail to the e-mail stated above. The
transmission was reported as complete and without error.
I declare under penalty of perjury that the foregoing is true and correct. Executed at
Hollister, CA on March 9, 2011

roo f S ervIce

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