Preview
Brent J. Borchert (State Bar No. 223917)
2930 Westwood Blvd Ste 204
E-FILED
Los Angeles, CA 90064-4138 2/16/2021 9:58 AM
Telephone: (310) 991-8635 Superior Court of California
Facsimile: (310) 773-9230 County of Fresno
bjborchert@hotmail.com By: S. Nunez, Deputy
Attorney for Petitioner RONALD AUSTIN
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF FRESNO
10 RONALD AUSTIN, Case No. 20CECG01297
Petitioner and Plaintiff,
11
IREPLY BRIEF
vs.
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CITY OF COALINGA; and DOES | through
13 Trial Date: February 25, 2021
10, inclusive,
Time: 3:30 p.m.
14
Respondents and Defendants. Department: 501
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16 Petitioner Ronald Austin hereby submits the following Reply Brief:
17 I INTRODUCTION
18 The Opposition remarkably shows the Court exactly how and why Respondent violated
19 the CPRA, giving other public agencies a road map of what not to do. Utterly remarkable. It
20 discloses a host of facts directly relevant to Petitioner’s CPRA request which Respondent has
21 concealed from Petitioner until now. These facts include:
22 e While investigating the burglary, Coalinga Police Department learned that suspect, Mr.
23 Love, tracked down the victim of the burglary and cursed at him or her and was
24 threatening him or her. (MND Decl. §7.) See Opposition, page 2, lines 8-10.
25 The victim stated to Coalinga Police Officer, Tony Henderson, during the investigation
26 that he or she feared for his or her life and believed he or she was being threatened to
27 dissuade him or her from cooperating with the burglary investigation. (MND Decl. § 8.)
28 See Opposition page 2, lines 10-13, lines 19-21.
-1-
REPLY BRIEF
e Respondent was concerned about the sender of the email [i.e. Petitioner]. See
Opposition, page 2, lines
These are the alleged facts supporting Respondent’s claim that the victim’s name is
exempt. But the CPRA required Respondent to disclose these facts not after time and money
was spent on litigation, but when it denied Petitioner’s CPRA request. Indeed, if an exemption
applies, Govt. Code § 6255 requires that public agencies "shall justify withholding any
record by demonstrating that the record in question is exempt.” By attempting to
demonstrate that now, Respondent inadvertently admits that it did not do so when it responded to
the CPRA request.
10 On the issue of exemption, Respondent falsely claims that the information was not public
11 record. The question is not whether it’s a public record — it most certainly is. The question is
12 whether it’s an exempt record. On that question, Respondent failed to demonstrate an
13 exemption. Respondent now claims the name is exempt because of the section 6254(f)
14 investigatory record exemption, but that exception contains a specific exception for the name of
15 the victim. See § 6254(f)(2)(A). Respondent also argues that information is exempt if disclosure
16 would endanger the safety of the victim, but the Opposition fails to meet that burden, even
17 admitting that the suspect has already managed to track down the victim and knew where the
18 victim lived.
19 Last, the Opposition discloses but one reason it chose to behave this way. It says it did
20 not trust who was making the CPRA request, apparently concerned there might be some
21 connection to the perpetrator. But Respondent made no effort to ascertain the man behind the
22 email. None. Nope, the request was made late on a Friday night and denied the following
23 Tuesday morning.
24 IL. RESPONDENT’S CPRA RESPONSE VIOLATED THE CPRA WHETHER
25 OR NOT THE INFORMATION IS EXEMPT
26 Ifa public agency determines that the requested records are not subject to disclosure, the
27 agency must promptly notify the person making the request and provide the reasons for its
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-2-
REPLY BRIEF
determination. §6253(c). If an exemption applies, Govt. Code § 6255 requires that public
agencies "shall justify withholding any record by demonstrating that the record in question is
exempt.” The reason is to prevent secrecy in government and to contribute significantly to the
public understanding of government activities. See International Federation of Professional &
Technical Engineers, Local 21, AFL-CIO v. Superior Court (2007) 42 Cal.4th 319, 329. This
requires maximum disclosure of the conduct of government operations. California State
University Fresno Assn., Inc. v. Superior Court (2001) 90 Cal.App.4th 810, 823 (“California
State University”). A police department “may not shield a document from disclosure with the
bare assertion that it relates to an investigation." Williams v. Superior Court (1993) 5 Cal.4th
10 337, 356.
11 Here, Respondent claims that its attorney Megan Dodd — not a city attorney, but an
12 attorney from a law firm retained by Respondent -- determined that the information sought by
13 Petitioner was not subject to disclosure. But Dodd and her firm failed to notify Petitioner of the
14 reasons for that determine. Instead, Respondent falsely claimed that the information simply was
15 not a public record and blindly cited § 6254(f). Respondent made no effort to justify
16 withholding any record by demonstrating that the record in question is exempt. At least not until
17 now. Although not originally cited as a reason for withholding the victim’s name, Respondent
18 now claims that disclosure would have risked the victim’s safety. It cites a handful of allegations|
19 suggesting that Respondent feared the suspect might intimidate the victim and had indeed
20 already tracked the victim down. As explained later in this brief, these purported facts fail to
21 demonstrate that the safety exemption applies, but even if they did, it would not matter because
22 the CPRA required Respondent to disclose these facts to Petitioner when it responded to his
23 request. Therefore, even if the Court ultimately finds that the victim’s name is exempt,
24 Petitioner requests a judicial determination that Respondent violated the CPRA by failing to
25 show an exemption applied when it responded to Petitioner’s request.
26 il. THE INVESTIGATORY RECORDS EXEMPTION CONTAINS AN
27 EXEMPTION FOR THE INFORMATION SOUGHT BY PETITIONER
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-3-
REPLY BRIEF
§ 6254(f) exempts from disclosure investigatory records. Despite the exemptions for
investigatory records and files, state and local law enforcement agencies must disclose the time,
substance, and location of all complaints or requests for assistance received by the agency and
the time and nature of the response thereto including, to the extent the information regarding the
crimes or incident investigated is recorded, the time, date, and location of occurrence, the time
and date of the report, the name and age of the victim, the factual circumstances surrounding
the crime or incident, and a general description of any injuries, property, or weapons involved.
§6254(£)(2)(A); Haynie, supra, 26 Cal.4th at 1072.
Nobody disputes that the victim’s name is part of an investigatory record. But the
10 exemption is irrelevant because the statute specifically creates an exemption for the victim’s
11 name.
12 Iv. RESPONDENT FAILS TO DEMONSTRATE THAT THE SAFETY
13 EXEMPTION APPLIES
14 Respondent’s brief argues for the first time that disclosing the victim’s name could
15 endanger the victim’s safety or endanger the investigation. Indeed, Govt. Code § 6254(f)
16 permits a public agency to withhold a victim’s name if disclosure would endanger the safety of
17 the victim. The CPRA does not say could, it says would. Respondent was required to
18 demonstrate that disclosing the victim’s name “would” endanger the victim’s safety. See Govt.
19 Code § 6255. Respondent does not meet that burden. Instead, Respondent states that “Because
20 we had no way to identify the sender of the email as well as the already existing danger to the
21 victim, Respondent determined it was in the best interest of the victim to not disclose his or her
22 name.” See Opposition, page 5, lines 12-14. But Respondent did have a way to identify the
23 sener. Respondent could have asked. Respondent could have spoken to Petitioner on the phone.
24 But Respondent did nothing to try to confirm the identity of Petitioner and that disclosing to
25 Petitioner would not jeopardize the victim’s safety. Respondent also concedes that it
26 “determined it was in the best interest of the victim,” but this is not the standard. It is perhaps
27 always in the best interest of a victim to keep the name confidential, but the name is only exempt
28 if there is a specific risk to the victim’s safety. The Dodd Declaration also discusses the city’s
-4-
REPLY BRIEF
“feelings” as if relevant to this action. For example, Dodd declares “Respondent was concerned
about the sender of the email and felt it was best to protect the victim.” See Dodd Declaration,
paragraph 12. The cities feelings are irrelevant — the test is whether the law requires disclosure.
Respondent did not identify a risk and admits that the suspect already tracked down the victim to
“curse at him.” The fact that the suspect was able to locate the victim — with or without the name|
— suggests that disclosing the name to a member of the public could not further risk the victim’s
safety. In fact, the new stories concerning this crime suggest that the victim actually knows the
suspect because the victim “heard” who had his stuff. See Declaration of Ronald Austin, Exhibit
A (“They say the victim heard where some of his stolen property was.”) Further, to the extent
10 that Respondent complains that disclosure would have interfered with the investigation, it does
11 not say why it cannot disclose the name now that the investigation is complete.
12 Vv. RESPONDENT SUBMITS NO ADMISSIBLE EVIDENCE SUPPORTING ITS
13 UNCLEAN HANDS DEFENSE
14 The Court should dismiss the unclean hands defense out of hand because it is not a
15 defense to CPRA actions. But if it were, Respondent cites no admissible evidence supporting
16 that defense. It just complains. Respondent relies almost entirely on hearsay filings and
17 speculates as to Petitioner’s motives. For example, Respondent purposely deceives this Court by
18 falsely claiming that Petitioner sends CPRA requests with inappropriate terms “in hopes that his
19 emails will be sent to spam, and he can receive an easy pay day.” Respondent does not explain
20 how an email going to spam would cause a pay day to Petitioner. Indeed, his email to
21 Respondent did not go to spam, and received a prompt — and unlawful — response. Here are the
22 facts: Petitioner is a well-known advocate for government transparency and single handedly
23 responsible for causing the largest university system in the world to completely reform its CPRA
24 procedures. This is why the CPRA exists. It incentivizes “members of the public to seek
25 judicial enforcement of their right to inspect public records subject to disclosure.” Law Offices
26 of Marc Grossman v. Victor Elementary School Dist. (2015) 238 Cal.App.4th 1010, 1013; See
27 also Community Youth Athletic Center v. City of National City (2013) 220 Cal.App.4th 1385,
28 1447. Therefore, “the petitioner's motive in making the request is essentially irrelevant.” Bertoli
-5-
REPLY BRIEF
1 v. City of Sebast (2015) 233 Cal.App.4th 353, 370. The Legislature effectively deputized
government transparency advocates such as Petitioner to enforce the public’s rights under the
CPRA and compel compliance therewith by public agencies.
Dated: February 15, 2021
/s/ Brent Borchert
Brent J. Borchert, Esq.
Counsel for Petitioner and Plaintiff
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REPLY BRIEF
DECLARATION OF RONALD AUSTIN
I, Ronald Austin, declare:
1 I am the Petitioner and Plaintiff in the above-entitled action. The facts stated in
this declaration are true and correct of my own personal knowledge. I could and would testify to
the truth of the facts stated in this declaration if called upon to do so.
2 Attached as Exhibit A is a copy of the news report concerning the victim which I
downloaded from internet.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
10 Executed on February 15, 2021, in Los Angeles, ifornia.
11
Ronald Austin
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REPLY BRIEF
Exhibit A
2/4/2021 Man arrested for stealing items from Coalinga storage warehouse: Police - ABC30 Fresno
Man arrested for stealing items from Coalinga
storage warehouse: Police
SHARE TWEET EMAIL
Sunday, January 12, 2020
PN?) al ee Alea EL]
EMBED > MORE VIDEOS.
A search of his home revealed more stolen property that has been returned to the owner.
FRESNO, Calif. (KFSN) -- A man is in jail after he stole several items from a storage
warehouse in Coalinga.
Officers determined Zachary Love as the prime suspect in the case.
https://abe30.com/theft-robbery-coalinga-storage-warehouse/5842988/ 1/4
2/4/2021 Man arrested for stealing items from Coalinga storage warehouse: Police - ABC30 Fresno
They say the victim heard where some of his stolen property was.
When officers searched the house, they found items belonging to the victim. They found clues
tying Love to the crime.
Officers say as the investigation was underway, Love made threats to the victim.
Love was found at his home, where he was taken into custody.
A search of his home revealed more stolen property that has been returned to the owner.
Report a correction or typo
RELATED TOPICS:
coalinga robbery
SHARE TWEET EMAIL
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PROOF OF SERVICE
I declare that I am over the age of eighteen (18) and not a party to this action.
On February16, 2021, I served the following document(s):
1 Reply Brief
on the interested parties in this action as indicated below or on the attached service list, together
with this declaration, as follows:
Mario Zamora email: zamora@griswoldlasalle.com
Counsel for CITY OF COALINGA .
10 () (By Mail) I am readily familiar with the business' practice at my place of business for
11 collection and processing of correspondence for mailing with the United States Postal Service. I
12 know that the correspondence is deposited with the United States Postal Service on the same day
13 this declaration was executed in the ordinary course of business. I know that the envelope was
14 sealed and, with postage thereon fully prepaid, placed for collection and mailing on this date,
15 following ordinary business practices, in the United States mail at Marina del Rey, California.
16
17 (X ) (By E-Mail) Pursuant to Emergency Rule 12(b) of the California Rules of Court, adopted
effective A pril 17, 2020, I emailed the documents to the e-mail addresses listed above.
18
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20 (X_ ) (State) I declare under penalty of perjury under the laws of the State of California that the
21 above is true and correct. Executed on February16, 2021, at Los Angeles, California.
22
/Brent Borchert/
By aH ee oe
23 Brent Borchert
24
25
26
27
28
1
PROOF ' OF SERVICE
Preview
Brent J. Borchert (State Bar No. 223917) 2930 Westwood Blvd Ste 204 E-FILED Los Angeles, CA 90064-4138 2/16/2021 9:58 AM Telephone: (310) 991-8635 Superior Court of California Facsimile: (310) 773-9230 County of Fresno bjborchert@hotmail.com By: S. Nunez, Deputy Attorney for Petitioner RONALD AUSTIN SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF FRESNO 10 RONALD AUSTIN, Case No. 20CECG01297 Petitioner and Plaintiff, 11 IREPLY BRIEF vs. 12 CITY OF COALINGA; and DOES | through 13 Trial Date: February 25, 2021 10, inclusive, Time: 3:30 p.m. 14 Respondents and Defendants. Department: 501 15 16 Petitioner Ronald Austin hereby submits the following Reply Brief: 17 I INTRODUCTION 18 The Opposition remarkably shows the Court exactly how and why Respondent violated 19 the CPRA, giving other public agencies a road map of what not to do. Utterly remarkable. It 20 discloses a host of facts directly relevant to Petitioner’s CPRA request which Respondent has 21 concealed from Petitioner until now. These facts include: 22 e While investigating the burglary, Coalinga Police Department learned that suspect, Mr. 23 Love, tracked down the victim of the burglary and cursed at him or her and was 24 threatening him or her. (MND Decl. §7.) See Opposition, page 2, lines 8-10. 25 The victim stated to Coalinga Police Officer, Tony Henderson, during the investigation 26 that he or she feared for his or her life and believed he or she was being threatened to 27 dissuade him or her from cooperating with the burglary investigation. (MND Decl. § 8.) 28 See Opposition page 2, lines 10-13, lines 19-21. -1- REPLY BRIEF e Respondent was concerned about the sender of the email [i.e. Petitioner]. See Opposition, page 2, lines These are the alleged facts supporting Respondent’s claim that the victim’s name is exempt. But the CPRA required Respondent to disclose these facts not after time and money was spent on litigation, but when it denied Petitioner’s CPRA request. Indeed, if an exemption applies, Govt. Code § 6255 requires that public agencies "shall justify withholding any record by demonstrating that the record in question is exempt.” By attempting to demonstrate that now, Respondent inadvertently admits that it did not do so when it responded to the CPRA request. 10 On the issue of exemption, Respondent falsely claims that the information was not public 11 record. The question is not whether it’s a public record — it most certainly is. The question is 12 whether it’s an exempt record. On that question, Respondent failed to demonstrate an 13 exemption. Respondent now claims the name is exempt because of the section 6254(f) 14 investigatory record exemption, but that exception contains a specific exception for the name of 15 the victim. See § 6254(f)(2)(A). Respondent also argues that information is exempt if disclosure 16 would endanger the safety of the victim, but the Opposition fails to meet that burden, even 17 admitting that the suspect has already managed to track down the victim and knew where the 18 victim lived. 19 Last, the Opposition discloses but one reason it chose to behave this way. It says it did 20 not trust who was making the CPRA request, apparently concerned there might be some 21 connection to the perpetrator. But Respondent made no effort to ascertain the man behind the 22 email. None. Nope, the request was made late on a Friday night and denied the following 23 Tuesday morning. 24 IL. RESPONDENT’S CPRA RESPONSE VIOLATED THE CPRA WHETHER 25 OR NOT THE INFORMATION IS EXEMPT 26 Ifa public agency determines that the requested records are not subject to disclosure, the 27 agency must promptly notify the person making the request and provide the reasons for its 28 -2- REPLY BRIEF determination. §6253(c). If an exemption applies, Govt. Code § 6255 requires that public agencies "shall justify withholding any record by demonstrating that the record in question is exempt.” The reason is to prevent secrecy in government and to contribute significantly to the public understanding of government activities. See International Federation of Professional & Technical Engineers, Local 21, AFL-CIO v. Superior Court (2007) 42 Cal.4th 319, 329. This requires maximum disclosure of the conduct of government operations. California State University Fresno Assn., Inc. v. Superior Court (2001) 90 Cal.App.4th 810, 823 (“California State University”). A police department “may not shield a document from disclosure with the bare assertion that it relates to an investigation." Williams v. Superior Court (1993) 5 Cal.4th 10 337, 356. 11 Here, Respondent claims that its attorney Megan Dodd — not a city attorney, but an 12 attorney from a law firm retained by Respondent -- determined that the information sought by 13 Petitioner was not subject to disclosure. But Dodd and her firm failed to notify Petitioner of the 14 reasons for that determine. Instead, Respondent falsely claimed that the information simply was 15 not a public record and blindly cited § 6254(f). Respondent made no effort to justify 16 withholding any record by demonstrating that the record in question is exempt. At least not until 17 now. Although not originally cited as a reason for withholding the victim’s name, Respondent 18 now claims that disclosure would have risked the victim’s safety. It cites a handful of allegations| 19 suggesting that Respondent feared the suspect might intimidate the victim and had indeed 20 already tracked the victim down. As explained later in this brief, these purported facts fail to 21 demonstrate that the safety exemption applies, but even if they did, it would not matter because 22 the CPRA required Respondent to disclose these facts to Petitioner when it responded to his 23 request. Therefore, even if the Court ultimately finds that the victim’s name is exempt, 24 Petitioner requests a judicial determination that Respondent violated the CPRA by failing to 25 show an exemption applied when it responded to Petitioner’s request. 26 il. THE INVESTIGATORY RECORDS EXEMPTION CONTAINS AN 27 EXEMPTION FOR THE INFORMATION SOUGHT BY PETITIONER 28 -3- REPLY BRIEF § 6254(f) exempts from disclosure investigatory records. Despite the exemptions for investigatory records and files, state and local law enforcement agencies must disclose the time, substance, and location of all complaints or requests for assistance received by the agency and the time and nature of the response thereto including, to the extent the information regarding the crimes or incident investigated is recorded, the time, date, and location of occurrence, the time and date of the report, the name and age of the victim, the factual circumstances surrounding the crime or incident, and a general description of any injuries, property, or weapons involved. §6254(£)(2)(A); Haynie, supra, 26 Cal.4th at 1072. Nobody disputes that the victim’s name is part of an investigatory record. But the 10 exemption is irrelevant because the statute specifically creates an exemption for the victim’s 11 name. 12 Iv. RESPONDENT FAILS TO DEMONSTRATE THAT THE SAFETY 13 EXEMPTION APPLIES 14 Respondent’s brief argues for the first time that disclosing the victim’s name could 15 endanger the victim’s safety or endanger the investigation. Indeed, Govt. Code § 6254(f) 16 permits a public agency to withhold a victim’s name if disclosure would endanger the safety of 17 the victim. The CPRA does not say could, it says would. Respondent was required to 18 demonstrate that disclosing the victim’s name “would” endanger the victim’s safety. See Govt. 19 Code § 6255. Respondent does not meet that burden. Instead, Respondent states that “Because 20 we had no way to identify the sender of the email as well as the already existing danger to the 21 victim, Respondent determined it was in the best interest of the victim to not disclose his or her 22 name.” See Opposition, page 5, lines 12-14. But Respondent did have a way to identify the 23 sener. Respondent could have asked. Respondent could have spoken to Petitioner on the phone. 24 But Respondent did nothing to try to confirm the identity of Petitioner and that disclosing to 25 Petitioner would not jeopardize the victim’s safety. Respondent also concedes that it 26 “determined it was in the best interest of the victim,” but this is not the standard. It is perhaps 27 always in the best interest of a victim to keep the name confidential, but the name is only exempt 28 if there is a specific risk to the victim’s safety. The Dodd Declaration also discusses the city’s -4- REPLY BRIEF “feelings” as if relevant to this action. For example, Dodd declares “Respondent was concerned about the sender of the email and felt it was best to protect the victim.” See Dodd Declaration, paragraph 12. The cities feelings are irrelevant — the test is whether the law requires disclosure. Respondent did not identify a risk and admits that the suspect already tracked down the victim to “curse at him.” The fact that the suspect was able to locate the victim — with or without the name| — suggests that disclosing the name to a member of the public could not further risk the victim’s safety. In fact, the new stories concerning this crime suggest that the victim actually knows the suspect because the victim “heard” who had his stuff. See Declaration of Ronald Austin, Exhibit A (“They say the victim heard where some of his stolen property was.”) Further, to the extent 10 that Respondent complains that disclosure would have interfered with the investigation, it does 11 not say why it cannot disclose the name now that the investigation is complete. 12 Vv. RESPONDENT SUBMITS NO ADMISSIBLE EVIDENCE SUPPORTING ITS 13 UNCLEAN HANDS DEFENSE 14 The Court should dismiss the unclean hands defense out of hand because it is not a 15 defense to CPRA actions. But if it were, Respondent cites no admissible evidence supporting 16 that defense. It just complains. Respondent relies almost entirely on hearsay filings and 17 speculates as to Petitioner’s motives. For example, Respondent purposely deceives this Court by 18 falsely claiming that Petitioner sends CPRA requests with inappropriate terms “in hopes that his 19 emails will be sent to spam, and he can receive an easy pay day.” Respondent does not explain 20 how an email going to spam would cause a pay day to Petitioner. Indeed, his email to 21 Respondent did not go to spam, and received a prompt — and unlawful — response. Here are the 22 facts: Petitioner is a well-known advocate for government transparency and single handedly 23 responsible for causing the largest university system in the world to completely reform its CPRA 24 procedures. This is why the CPRA exists. It incentivizes “members of the public to seek 25 judicial enforcement of their right to inspect public records subject to disclosure.” Law Offices 26 of Marc Grossman v. Victor Elementary School Dist. (2015) 238 Cal.App.4th 1010, 1013; See 27 also Community Youth Athletic Center v. City of National City (2013) 220 Cal.App.4th 1385, 28 1447. Therefore, “the petitioner's motive in making the request is essentially irrelevant.” Bertoli -5- REPLY BRIEF 1 v. City of Sebast (2015) 233 Cal.App.4th 353, 370. The Legislature effectively deputized government transparency advocates such as Petitioner to enforce the public’s rights under the CPRA and compel compliance therewith by public agencies. Dated: February 15, 2021 /s/ Brent Borchert Brent J. Borchert, Esq. Counsel for Petitioner and Plaintiff 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -6- REPLY BRIEF DECLARATION OF RONALD AUSTIN I, Ronald Austin, declare: 1 I am the Petitioner and Plaintiff in the above-entitled action. The facts stated in this declaration are true and correct of my own personal knowledge. I could and would testify to the truth of the facts stated in this declaration if called upon to do so. 2 Attached as Exhibit A is a copy of the news report concerning the victim which I downloaded from internet. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 10 Executed on February 15, 2021, in Los Angeles, ifornia. 11 Ronald Austin 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -7- REPLY BRIEF Exhibit A 2/4/2021 Man arrested for stealing items from Coalinga storage warehouse: Police - ABC30 Fresno Man arrested for stealing items from Coalinga storage warehouse: Police SHARE TWEET EMAIL Sunday, January 12, 2020 PN?) al ee Alea EL] EMBED > MORE VIDEOS. A search of his home revealed more stolen property that has been returned to the owner. FRESNO, Calif. (KFSN) -- A man is in jail after he stole several items from a storage warehouse in Coalinga. Officers determined Zachary Love as the prime suspect in the case. https://abe30.com/theft-robbery-coalinga-storage-warehouse/5842988/ 1/4 2/4/2021 Man arrested for stealing items from Coalinga storage warehouse: Police - ABC30 Fresno They say the victim heard where some of his stolen property was. When officers searched the house, they found items belonging to the victim. They found clues tying Love to the crime. Officers say as the investigation was underway, Love made threats to the victim. Love was found at his home, where he was taken into custody. A search of his home revealed more stolen property that has been returned to the owner. Report a correction or typo RELATED TOPICS: coalinga robbery SHARE TWEET EMAIL Copyright© 2021 KFSN-TV. All Rights Reserved. MORE VIDEOS From CNN Newsource affiliates TOP STORI ES Fresno pleads with President Biden for more COVID vaccine Updated 2 hours ago Fresno Unified, Central Unified to continue with remote learning for now Updated 2 hours ago https://abe30.com/theft-robbery-coalinga-storage-warehouse/5842988/ 24 2/4/2021 ‘Man arrested for stealing items from Coalinga storage warehouse: Police - ABC30 Fresno 12-year-old girl sexually assaulted: Victim's mother and suspect's wife both arrested Updated 2 hours ago Fresno man accused of raping 15-year-old Parlier girl, human trafficking Updated 2 hours ago Fresno working to fight hunger among seniors Updated 2 hours ago School districts in Tulare County continue to face hurdles in reopening Updated 2 hours ago J&J submits 1-shot COVID vaccine for emergency use in US SHOW MORE Home AccuWeather Traffic Local News Categories Station Info Shows Apps Follow Us: https://abc30.com/theft-robbery-coalinga-storage-warehouse/5842988/ 34 PROOF OF SERVICE I declare that I am over the age of eighteen (18) and not a party to this action. On February16, 2021, I served the following document(s): 1 Reply Brief on the interested parties in this action as indicated below or on the attached service list, together with this declaration, as follows: Mario Zamora email: zamora@griswoldlasalle.com Counsel for CITY OF COALINGA . 10 () (By Mail) I am readily familiar with the business' practice at my place of business for 11 collection and processing of correspondence for mailing with the United States Postal Service. I 12 know that the correspondence is deposited with the United States Postal Service on the same day 13 this declaration was executed in the ordinary course of business. I know that the envelope was 14 sealed and, with postage thereon fully prepaid, placed for collection and mailing on this date, 15 following ordinary business practices, in the United States mail at Marina del Rey, California. 16 17 (X ) (By E-Mail) Pursuant to Emergency Rule 12(b) of the California Rules of Court, adopted effective A pril 17, 2020, I emailed the documents to the e-mail addresses listed above. 18 19 20 (X_ ) (State) I declare under penalty of perjury under the laws of the State of California that the 21 above is true and correct. Executed on February16, 2021, at Los Angeles, California. 22 /Brent Borchert/ By aH ee oe 23 Brent Borchert 24 25 26 27 28 1 PROOF ' OF SERVICE