Declaration of Christine Martin

DECLARATION OF CHRISTINE MARTIN
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Dennis J. Hayes, Esq. Bar No. 123576
Christopher H. Conti, Esq. Bar No. 275032
Hayes & Cunningham, LLP
5925 Kearny Villa Road, Suite 201
San Diego, California 92123
Telephone: (619) 297-6900
Facsimile: (619) 297-6901

Attorneys for Party in Interest San Bernardino
Public Employees Association

UNITED STATES BANKRUPTCY COURT
CENTRAL DISTRICT OF CALIFORNIA RIVERSIDE DIVISION

In re:

CITY OF SAN BERNARDINO,
CALIFORNIA,

Debtor.

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CASE NO. 6:12-bk-28006 MJ

CHAPTER 9

IN SUPPORT OF SAN BERNARDINO
PUBLIC EMPLOYEES ASSOCIATIONS
OBJECTION TO DEBTOR CITY OF SAN
BERNARDINOS PETITION AND
STATEMENT OF QUALIFICATION
UNDER TITLE 11 U.S.C. SECTION 109(c)

Date: November 5, 2012 (Status Conference)
Time: 10:00 a.m.
Judge: Hon. Meredith Jury
Dept.: 301

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I, Christine Martin, declare as follow:
1. I am currently a principal analyst with Harvey M. Rose Associates, LLC (HRA), a
public sector management consulting firm based in San Francisco, California. I hereby make this
declaration in support of San Bernardino Public Employees Associations Objection to Debtor City
of San Bernardinos Petition and Statement of Qualification Under Title 11 U.S.C. Section 109(c). I
have personal knowledge of the facts stated herein, and if called upon to testify, I could and would
testify competently thereto.
2. My education background includes a Bachelor of Arts Degree in Business Economics
with an emphasis in accounting from the University of California at Santa Barbara in 1992, and a
Masters Degree in Public Policy from the Goldman School of Public Policy, University of
California at Berkeley in 2001.
3. From 1997 to 1999, I worked in administration for the Santa Barbara County Auditor-
Controller as Division Chief, where I managed the general revenue budget. From May 2001 to
September 2007, I worked as a Principal Analyst for HRA, where I served as a Budget Analyst for
the San Francisco Board of Supervisors between August 2002 to September 2007, and a Budget
Analyst for Santa Clara County Board of Supervisors between May 2001 and August 2002.
Between May 2001 and September 2007, I conducted fiscal analyses for City and County agencies
annual budgets and supplemental appropriation requests, performed management audits of complex
agencies, oversaw the legislative report process for the San Francisco Budget and Finance
Committee, and conducted fiscal analyses and management audits of other local government
agencies. From October 2007 to September 2008, I served as Budget and Finance Manager of the
Department of Technology for the City and County of San Francisco. From 2008 to April 2010, I
served as Chief of Staff of the Department of Technology for the City and County of San Francisco,
where I directed the finance and administrative functions of the department while overseeing a
budget of $93 million. From May 2010 to the present, I have served as a Public Sector Finance and
Management Consultant, where I have conducted assessments of the financial condition and budget
reviews of local government agencies. During this time, I also conducted management performance
reviews for local government agencies. As a certified public accountant, I currently hold credentials

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in California and Tennessee. Attached hereto as Exhibit A is a true and correct copy of my resume.
4. HRA was engaged by San Bernardino Public Employees Association (SBPEA) to
determine the financial condition of the City of San Bernardino (San Bernardino or City), if
there are any potential monies available to alleviate the fiscal condition of the City, and/or when it
would have been readily apparent that the City was suffering fiscal distress.
5. In performing this request, HRA reviewed financial statements of the City for the
years ending in June 30, 2008, 2009, and 2010, including the Citys available Comprehensive
Annual Financial Reports (CAFR), and the unaudited financial data and information provided by
the City for FY 2010-11 and FY 2011-12. Additionally, HRA reviewed documents provided by the
City that pertain to FY 2012-13 budget projections, and other various financial records and
comments pertaining to the City that were voluntarily produced.
6. I am informed and believe that comprehensive audited financial statements, including
a CAFR for FY 2010-11 or FY 2011-12, are yet to be completed by the City. Therefore, the latest
available audited financial statements provided by the City are for FY 2009-10.
7. In addition to reviewing the aforementioned information, HRA compared the Citys
General Fund, expenditure data, indebtedness and other financial indicators with ten (10)
comparable California peer cities. The cities that were used for this comparison were Santa Clarita,
Fontana, Glendale, Irvine, Moreno Valley, Huntington Beach, Oxnard, Chula Vista, Fremont, and
Modesto.
8. On October 19, 2012, HRA concluded an analysis of the Citys finances and a
comparison with its ten (10) peer cities. On the same day, HRA issued to SBPEA a report
summarizing its key findings (the HRA Report), a true and correct copy of which is attached
hereto as Exhibit B.
Analysis of the General Fund
9. HRAs analysis began with a review of the financial condition of the Citys General
Fund. A review of the Citys supporting schedules showed that as of June 30, 2010, the Citys
General Fund balance was $410,293.00, or 0.3% of its expenditures. The General Funds balance as
of June 30, 2010, represented a decrease of 84.9% from the June 30, 2009 balance of $2.7 million.

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Additionally, the required reserves of fund balance actually exceed the amount available in the
General Fund. Thus, the Citys General Fund had a negative unreserved and undesignated fund
balance as of June 30, 2010. EXHIBIT (Ex.) B, pp. 1-2.
10. As of June 30, 2010, the General Fund cash and investment balance was only
$2,120.00. Additionally, as of June 30, 2009, the General Fund cash balance was only $4,930.00.
Ex. B, p. 1.
11. The Citys financial reports indicate $9.1 million due from other governments as of
June 30, 2010. This amount is not explained in the financial statements, and collection would have
greatly improved the Citys cash position in the near term. Any changes to accounts receivable or
accounts payable since that period are not reconciled. Ex. B, p. 4.
12. Although the City has not provided financial statements or even unaudited balances of
its General Fund, it is reasonable to expect that the financial position of the City did not improve
over the subsequent two years based on a review of budget documents. The City reported a negative
unaudited General Fund balance of $1,181,603.00 as of June 30, 2011. Additionally, a review of the
budget initially adopted by the City Council for FY 2011-12 shows a decrease in fund balance of
$760,400.00. A footnote within the budget schedules also indicates that the General Fund balance
does not include $3 million in loan liabilities. Ex. B, p. 3-4.
13. Additionally, the fact that the expenditures exceeded the original FY 2011-12 adopted
budget by $14.5 million, or 11.5%, demonstrates a complete lack of budgetary control during that
year. Ex. B, p. 3-4.
14. Based on this trend, it was foreseeable that the City would have a projected negative
cash balance of $18.3 million as of June 30, 2012, which represents the cumulative monies owed to
other funds as of June 30, 2010, as well as the operating deficits for FY 2010-11 and FY 2011-12.
Ex. B, p. 4.
15. A review of the Citys General Fund balances for the last ten years reveals that the
General Fund has experienced a deficit, where annual revenues exceeded annual expenditures, in
every year since FY 2001-02. Ex. B, p 13.
///

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Analysis of Other Government Funds
16. In addition to the General Fund, the FY 2009-10 CAFR reported 39 other government
funds, including 16 special revenue funds, 6 debt service funds, and 17 capital project funds. These
funds had a total combined fund balance of $198.4 million and available cash of $68.5 million. Ex.
B, p. 4.
17. Although these funds may or may not be restricted, it is unclear based on the
documents provided by the City if these funds were available for transfer, reimbursement of costs,
or a viable source of inter-fund loans.
18. The City operates eight internal service funds to account for activities and balances
related to the internal administration of the City. Said funds include workers compensation and
general liability insurance; information and telecommunications systems; utilities; and other central
services. Ex. B, p. 6.
19. As of June 30, 2010, the total combined net assets of the internal service funds were
negative $7.8 million, and held cash of $59,019.00. However, six of the eight internal service funds
maintained a deficit unrestricted fund balance and the two remaining funds had virtually no cash on
hand to meet obligations. Rather, all of the internal service funds deferred charges to other City
funds in the combined amount of $5.6 million or received loans from other funds in the combined
amount of $1.0 million. This represents a $1.5 million (23.5%) deterioration of financial position
from the prior year. In fact, since at least FY 2007-08, the City has been using and exceeding any
reserves held in its internal service funds. Ex. B, pp. 6-7.
20. It is best practice for internal service funds to maintain sufficient net assets to cover
estimated liabilities and sufficient working capital. However, as of June 30, 2010, the City had not
maintained sufficient reserves and actually put its internal services funds in a deficit position. Ex. B,
p. 7.
Analysis of Enterprise Funds
21. The City operates three enterprise funds; the Water Enterprise, the Sewer Enterprise,
and the Integrated Waste Enterprise. Although these funds may be restricted to funding enterprise
activity, the financial health of these funds has a direct impact on the overall financial health of the

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primary government. Additionally, these funds may have potential for direct and indirect financial
support to the General Fund. Ex. B, p. 8.
22. As of June 30, 2010, the total net assets of these combined funds were approximately
$252.7 million. Of that amount, $39.7 million was unrestricted and $32.7 million was supported by
available cash and investments. Almost all of these balances were held in the Sewer Enterprise and
Water Enterprise, with $23.5 million and $11.6 million in unrestricted fund balance, respectively.
The Sewer Fund and Water Fund held sufficient cash for over three months and eleven months of
operating expenditures, respectively. Ex. B., p. 8.
23. With the exception of the Integrated Waste Fund, which the City reports having a
negative cash balance of $2.0 million as of June 30, 2010, the City did not incorporate other
enterprise funds in its recent analysis of the Citys fund balance and cash position. Ex. B, p. 8.
24. Per the City Charter, the City may transfer up to 10% of Water Enterprise revenues to
the General Fund on an annual basis. In FY 2009-10, the City transferred $2.3 million from the
Water Enterprise to the General Fund. However, Water Enterprise financials show that as of June
30, 2011, a transfer was not made in FY 2010-11. It is also not clear if the City made such a transfer
in FY 2011-12. Ex. B, pp. 8-9.
Comparison With Peer Cities
25. As part HRAs overall analysis, HRA conducted a comparison of the Citys General
Fund, expenditures, cash position, functional expenditures, indebtedness, retirement funding, and
post-employment benefits with ten (10) of its peer cities. Because San Bernardino has not provided
audited financials for FY 2010-11, comparisons were made for San Bernardino as of June 30, 2010,
and all other cities as of June 30, 2011. Ex. B, p. 11.
26. The Citys General Fund balance in proportion to annual General Fund expenditures
was 0.3%, which was the lowest of all of the peer cities by a wide margin. The average General
Fund balance as a percentage of annual General Fund expenditures for the peer cities, excluding San
Bernardino, was 56.5%. The second lowest after San Bernardino was the City of Modesto, whose
General Fund balance in proportion to annual General Fund expenditures was 15.5%. Ex. B, p. 11.
///

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27. The Citys General Fund had a balance approximately of $2.00 per capita, which was
also the lowest among the peer cities by a wide margin. The average fund balance for San
Bernardinos peer cities was $308.00 per capita. Modesto was again the second lowest, and
maintained $74.00 of fund balance per capita. Ex. B, p. 11.
28. Despite the dire condition of the General Funds balances, the Citys General Fund
expenditures in San Bernardino were the fourth highest of all the comparison cities. The City had
expenses of $619.00 per capita, which was 109% of the average of $566.00 for its peer cities. Ex.
B, p. 11.
29. The Citys General Fund cash balance was merely $2,120.00, or 0.0% of annual
General Fund expenditures. For the sake of comparison, San Bernardino had no peers from a cash
balance standpoint. The average available cash among its peer cities at this time was 39.9% of
annual General Fund expenditures. Modesto maintained the next lowest cash balance of $5.8
million, or 6.0% of its annual expenditures. Ex. B, p. 11.
30. The City had the second highest level of indebtedness of all the comparison cities in
relation to its total assets, with $1.10 billion of assets and $444.3 million in liabilities. Ex. B, p. 12.
The Citys Declaration of Fiscal Emergency
31. On information and belief, the City based its declaration of fiscal emergency in July
of 2012 primarily upon the facts that, (1) the General Fund was operating in a long-term deficit
position, (2) other reserves and resources had been exhausted, (3) long-term liabilities had not been
addressed, and (4) reductions in service levels were unacceptable. However, there are a number of
weaknesses in the Citys supporting schedules for the existence of a fiscal emergency and a
declaration that it was unable to meet its obligations for the sixty (60) days following its July 18,
2012, declaration of a fiscal emergency. These weaknesses include:
a. The Citys Fiscal Emergency Operating Plan, dated July 23, 2012, reports that the
Citys total cash and investment portfolio held $27 million in assets as of June 30, 2012. The Citys
supporting schedules do not address the availability of this amount for its short-term cash
requirement. Additionally, there may be transfers and/or loans available from the Enterprise Funds,
as nothing precludes the formal loaning of available cash balances. Ex. B, p. 13.

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b. The Citys Selected Monthly Cash Flow Analysis (Attachment C to the Fiscal
Emergency Operating Plan) addresses the General Fund only. The Citys cash flow analysis does
not include other City funds that have a direct financial impact on the Citys overall ability to meet
its obligations. Ex. B, p. 13.
c. The Citys Summary of Revenues, Expenditures, and Changes in Fund Balance
(Attachment B to the Fiscal Emergency Operating Plan) reports a significant budget increase of
General Government expenditures primarily as a result of funding long-term liabilities. These
increases include, but are not limited to, $6.7 million for Retiree Health, $4.9 million for General
Liability, and $3.3 million for Workers Compensation, for a total of $14.9 million. However, these
aforementioned budget line items were not only historically unfunded by the City, but also do not
require cash payments. As such, nearly half of the FY 2012-13 estimated deficit appears to pertain
to long-term liabilities that are not a current year cash requirement. Ex. B, pp. 13-14.
d. The Citys Selected Monthly Cash Flow Analysis Measures to Manage Cash
Flow (Attachment E to the Fiscal Emergency Operating Plan), indicates City managements
recommendation to reduce General Fund Cash outflows. There is no explanation for these
measures, such as why only 20% of internal service charges are reduced, nor are they maximized.
Additionally, the City does not address the funding of long-term liabilities that do not require cash
payouts. Ex. B, p. 14.
e. As previously discussed, the Citys financial reports indicate that $9.1 million was
due from other governments as of June 30, 2010. Accounts receivable and account payable have
direct impact on cash balances, yet current data and information on these accounts has not been
provided by the City. Ex. B, p. 3.
32. Based on the foregoing HRA believes the City had available solutions to its short-
term cash shortage that may have allowed it to pay its debts and obligations for sixty (60) days
following the Citys July 18, 2012 declaration of a fiscal emergency. Therefore, the Citys
declaration of a fiscal emergency may have been premature. Ex. B, p. 14.
33. It is HRAs opinion that the delay in the issuance of the FY 2010-11 audited financial
statements is indicative that the financial structure of the City is in disarray. However, despite

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delays in the latest financial statements, City Council and City management should have known,
and acted much earlier and more aggressively, to the financial constraints facing the City. As
previously mentioned, the audited financial statements for FY 2007-08 showed that the General
Fund had a cash balance of $0.00 on June 30, 2008, while the General Fund expenditures were
averaging $11.9 million per month. Such a trend was not only fiscally imprudent, but also fiscally
unsustainable. Ex. B, p. 2.
34. Budget reductions and revenue enhancement ideas discussed in the Citys Budgetary
Analysis and Recommendations for Budget Stabilization and Pre-Pendency Plan include improving
the Citys cost allocation and charge-back processes, increasing existing fees and fines to fully
recover costs, establishing new fees, organizational restructuring and contract service reductions.
These actions were not only viable options, but are also actions that have been taken by many other
California local governments years ago. Establishing an aggressive cost recovery program, both by
an enhanced cost allocation and charge-back program as well as through increased fees, has an
immediate impact on local government revenues in that such changes frequently do not require
voter approval.
35. Based on the foregoing, it is my opinion that the events leading up its July 2010
declaration of a fiscal emergency could not have been sudden, unknown, or unforeseeable to City
officials.

I declare under penalty of perjury under the laws of the State of California and the United
States of America that the foregoing is true and correct.

Executed this 23 day of October, 2012, at Knoxville, Tennessee.

Christine Martin

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Appendix of Attachments To HRA Report
Attachment 1 June 2008 Balance Sheet, Government Funds
Attachment 2 June 30, 2008 Statement of Revenues, Expenditures, and Changes in Fund
Balance
Attachment 3 Analysis of General Fund Fund Balance
Attachment 4 Three-Year Comparison of Internal Service Funds
Attachment 5 Comparison of General Fund with Selected Cities
Attachment 6 Comparison of City-wide Expenditures by Function with Selected Cities
Attachment 7 Comparison of City-wide Indebtedness with Selected Cities
Attachment 8 Comparison of Employee Retirement System Funding with Selected Cities
Attachment 9 Post Retirement Health Insurance Program, Comparison of Liabilities and
Funding as of June 30, 2009 with Selected Cities

EXHIBIT A
POSITION: PRINCIPAL ANALYST
EXPERIENCE:
Conduct fiscal and budget analyses for local government agencies including reviews of accounting and fmance
activities and internal controls, organization and programmatic budgets, fmancial reports and forecasts. Possess
in-depth knowledge of governmental budgetary and accounting policies and procedures, internal controls, best
practices, and information systems. Recent projects include a line-item review of the City of Los Angeles
Proposed Budget and a r.eview of the financial status of a large Northern California water district.
Conduct management and performance reviews to identify and refme organizational issues and challenges,
develop solutions, prepare written reports, and present fmdings in a public forum. Specialize in accounting,
fmance and administrative functions, including contracting and procurement, billing and collections, capital
projects and asset management, and fmancial reporting. Recent projects include a review of accounting and
fmance practices and internal controls of a large health and human services agency in Los Angeles County.
Management audits of complex City and County of San Francisco agencies, including audits of accounting and
fmance functions, information systems, capital project management, and human resource functions. Project
experience includes a comprehensive audit of the San Francisco Office of the Controller and a review of billing
and collections for San Francisco General Hospital.
Conducted fiscal analyses of City and County of San Francisco agencies' annual budgets and supplemental
appropriation requests including line-item review of the City and County's annual budget, including reviews of
Public Health, Human Services, Public Utilities, and Port departmental budgets, among others.
Oversaw the legislative report process for the San Francisco Budget and Finance Committee including
assignment of staff, review of reports, and preparation of reports requiring more in-depth analysis.
Former Chief of Staff, Department of Technology, City and County of San Francisco
Directed the fmance and administrative functions of an internal service and public facing department with a
budget of$93 million and approximately 300 employees.
Assisted the Chief Information Officer in setting departmental and City information technology policy and
the organizational migration of information technology from a decentralized discipline to a consolidated
framework within the City and County.
Participated in a City-wide effort to consolidate information technology functions across departments and
agencies and to fmance information technology infrastructure and projects.
Specific oversight responsibilities included Accounting and Finance, Contracts, Procurement, Budget,
Human Resources, Performance Measurement, and Planning.
Former Budget and Finance Manager, Department of Technology, City and County of San Francisco
Conducted fiscal analyses and management audits of other local government agencies. Projects included an
internal control review and staffmg analysis of the Sutter County Auditor-Controller's Office; budget review of
Santa Clara Valley Water District; a management audit of the Monterey County budget process; and billing and
collections for the Sacramento County Regional Sanitation District.
Former Division Chief, Santa Barbara County, Auditor-Controller, 1997-1999
CREDENTIALS AND EDUCATION:
Public Accountant, State of California
Master's Degree in Public Policy, Goldman School of Public Policy, University of California at Berkeley, May
2001
Bachelor of Arts Degree, Business Economics, emphasis in accounting, University of California at Santa
Barbara, March 1992
Harvey M. Rose Associates, LLC

EXHIBIT B

October 19, 2012

Mr. Christopher Conti, Esq.
Hayes & Cunningham, LLP
5925 Kearny Villa Rd., Suite 201
San Diego, CA 92103

Dear Mr. Conti:

We have completed the review of the City of San Bernardinos FY 2009-10 audited
financial statements and subsequent financial documents produced in FY 2010-11 and
FY 2011-12 to provide a financial assessment as it pertains to the Citys recent filing for
Chapter 9 bankruptcy. In addition to reviewing these documents, we compared the
Citys General Fund, expenditure data, indebtedness and other financial indicators with
those of 10 comparable California cities. Based on this review and analysis, we would
characterize the financial condition of the City of San Bernardino as poor both on a
stand-alone basis and relative to the 10 comparison cities. This rating is derived from a
100 point scoring system that ranks cities and counties as excellent, very good, good,
fair, weak or poor based on the assessment of nine factors as described in this report.

As of June 30, 2010, the Citys General Fund fund balance was $410,293, or 0.3 percent
of annual General Fund expenditures and cash on hand was $2,120. Further, other
financial attributes included:

- Unknown impacts from the dissolution of the Citys Economic Development
Agency, pursuant to Assembly Bill X1 26;
- Limited cash and fund balances in other governmental funds;
- Deficit fund balances in internal service funds;
- Average funding levels for pension obligations, but significantly greater other
post-employment benefit liabilities as a percentage of expenditures when
compared to other cities;
- Second highest level of indebtedness when compared to other cities; and


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- Despite low cash and fund balances, a greater than average expenditure per
capita on services indicating that service levels are not sustainable.

In addition, several observations have been made in regard to the financial
management of the City over the past several years, up to and including the filing for
Chapter 9 bankruptcy protection.
The delay in the issuance of the FY 2010-11 audited financial statements
indicates a financial structure that is in disarray.
Despite delays in the latest financial statements, City Council and City
management should have known and acted much earlier and more
aggressively to the financial constraints facing the City. The audited financial
statements for FY 2007-08 showed that the General Fund had a cash balance
of $0.00 on June 30, 2008, while General Fund expenditures were averaging
$11.9 million per month (Attachments 1 and 2).
1

Budget reduction and revenue enhancement ideas discussed in the Pre-
Pendency Plan are actions taken by many other California local governments
years ago.
City management has taken an extreme position by claiming reductions in
service levels create a fiscal emergency as stated in the Pre-Pendency Plan.
Over half of the FY 2012-13 estimated deficit appears to pertain to long-term
liabilities and is not a current year cash requirement.

The remainder of the report discusses these issues and related pertinent financial data.
As noted above, the City reports that at the FY 2010-11 audited financial statements
have not yet been issued at a time when the subsequent year, FY 2011-12, should be in
the process of being finalized. Thus, limited data and information is available for
review and analysis for the last 27 months and what is available has not been
substantiated through an audit or by an independent third party. Further, the FY 2009-
10 audited financial statements contain inconsistencies and incomplete information that
make definitive estimates and projections difficult. Given the financial distress of the
City, and the Governors proposal at that time to dissolve redevelopment agencies, both
the Citys management and the independent auditors should have considered

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State and federal accounting guidelines as delineated in OMB A-87 permit local government agencies to
accumulate and maintain a 60-day working capital cash balance, which would have amounted to about $23 million
in FY 2007-08.


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additional disclosures.
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The events leading up to this time were not sudden or
unknown. Despite these issues, and ultimately because of them, the City had limited
options at the time it made the determination to declare a fiscal emergency and file for
bankruptcy. That said, more comprehensive analysis and decisive budget reductions
may have spared the City from insolvency.

GENERAL FUND

The Citys General fund balance was $410,293, or 0.3 percent of expenditures, as of June
30, 2010, a decrease of 84.9 percent from the June 30, 2009 balance of $2.7 million.
Further, required reserves of fund balance, such as monies required to pay for open
contracts (encumbrances) or set aside as deposits actually exceeded the amount
available, resulting in negative unreserved and undesignated fund balance (or available
resources). Attachment 3 provides a three year analysis of General Fund fund balance
that shows a declining financial position since at least FY 2008-09.

With respect to solvency, the General Fund cash and investments balance was only
$2,120 as of June 30, 2010, similar to the $4,930 balance the prior year. However, the
City also reported $9.1 million due from other governments as of June 30, 2010, which is
not explained in the financial statements. While such a receivable is already
incorporated in the fund balance, collection would have greatly improved the Citys
cash position at least in the near term as the Citys liabilities of $10.7 million, primarily
monies owed to other City funds, exceeded this amount.

While audited financial statements or even unaudited balances have not been provided
by the City, it is reasonable to expect that the financial position did not improve over
the subsequent two years based on a review of budget documents. The City reported a
negative unaudited General Fund fund balance of $1,181,603 as of June 30, 2011,
increasing to a projected deficit of $10,576,590 as of June 30, 2012 in the Finance
Departments Budgetary Analysis and Recommendations for Budget Stabilization issued July
9, 2012. A review of the budget initially adopted by the City Council for FY 2011-12, not
even taking into account any subsequent mid-year revisions, shows a decrease in fund
balance of $760,400. Curiously, the budget schedules footnote that the General Fund
fund balance presented does not include $3 million in loan liabilities.
3
That

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By way of comparison, the City of Los Angeles in the FY 2009-10 audited financial statements issued in February
2011 disclosed with substantial narrative both the proposed dissolution of California redevelopment agencies as well
as it own challenges with on-going and mid-year budget deficits.
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Adopted Budget FY 2011-2012, D-19.


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expenditures exceeded the original adopted budget by $14.5 million or 11.5 percent is
unfathomable and demonstrates a complete lack of budgetary control during the year.
Therefore, it is not surprising that the City reports that as of June 30, 2012, the General
Fund cash balance was a negative $18.3 million, which would be the cumulative of the
monies owed to other funds as of June 30, 2010 plus FY 2010-11 and FY 2011-12
operating deficits. In terms of liquidity, however, the $9.1 million due from other
governments as of June 30, 2010 and any changes to accounts receivable or accounts
payable balances since that period is not reconciled.

OTHER GOVERNMENTAL FUNDS

In addition to the General Fund, the Citys Comprehensive Annual Financial Report
(CAFR) reported 39 other governmental funds, including 16 special revenue funds, six
debt service funds, and 17 capital projects funds, with a total combined fund balance of
$198.4 million and available cash balance of $68.5 million. Governments use these
funds to separately account for discrete activities and revenue sources. However,
monies may be moved to a degree between funds for expenditure, reimbursement of
costs, or inter-fund loans.

The most significant of these funds were three funds associated with the Citys
redevelopment agency, the Economic Development Agency, which had a combined
June 30, 2010 fund balance of $168.2 million and an available cash balance of $42.6
million. Assembly Bill X1 26 dissolved all California redevelopment agencies effective
February 1, 2012. The remaining assets, liabilities, and activities of the dissolved RDA,
should be reported in a City fiduciary fund (i.e. trust fund) as the City elected to be the
Successor Agency. The financial impacts of the dissolution on all California jurisdictions
has yet to be determined, but for the City would include both positive and negative
impacts on its financial status. The City reports in the Cash Cross Fund report a $19.2
million cash balance in the Successor Agency Retirement Obligations trust fund, but the
use and ultimate disposition are and will be guided by State law.
4

Of the remaining 36 governmental funds, the total combined fund balance as of June 30,
2010 was $30.2 million, or a $4.2 million and 12.2 percent decrease from June 30, 2009.
Combined available cash was $25.9 million, a $6.7 million and 20.6 percent decrease
from the prior year. These again demonstrate a significant decline in financial position.
A brief description of each category of funds is provided below.

4
Cash Cross Fund Report, file: Cash Flow 7 24 2012 Corrected Final BATES 10798-10819.


5
Special Revenue Funds are established to account for monies that are restricted
in purpose, based on their source, usually by State and Federal law. The City had
15 special revenue funds, excluding the Economic Development Agency, for a
wide range of services including libraries, cemetery operations, animal control,
transportation, and sewer line maintenance, among others. These funds had a
total fund balance of $10.1 million and available cash of $6.0 million as of June 30,
2010. However, much of these resources were restricted for transportation-
related activities due to their funding source.

Debt Service Funds are used to account for the accumulation of resources and
the payment of principal and interest for certain City debt obligations. None of
the Citys debt service funds held any unrestricted fund balance as of June 30,
2010 and one fund, Assessment District #1015, had a deficit fund balance of
$368,344.

Capital Projects Funds are used to account for the acquisition and construction
of major capital facilities other than those financed by proprietary funds. The
City had 16 capital projects funds, excluding the Economic Development
Agency, for a variety of projects throughout the City. These funds had a total
fund balance of $20.4 million and available cash of $19.8 million as of June 30,
2010. Most of these funds were derived from assessments and/or development
impact fees for specific purposes, such as sewer and storm drain construction.

Similar to the General Fund, it is reasonable to expect that the financial position of these
funds did not improve over the past two years. A review of the budget initially
adopted by the City Council for FY 2011-12 shows a significant budgeted decrease in
the fund balances during the year as shown in the following table.


6
Table 1
FY 2011-12 Adopted Budget
Other Governmental Funds
Changes in Fund Balances

7/1/2011 6/30/2012 Change As a %
Special Revenue Funds 3,184,400 $ 915,500 $ (2,268,900) $ -71.3%
Capital Project Funds 27,647,600 5,696,600 (21,951,000) -79.4%
Debt Service Funds* (306,000) (286,800) 19,200 -6.3%
Total 30,526,000 $ 6,325,300 $ (24,200,700) $ -79.3%
* The summary budget schedule only includes two debt service funds.
Fund Balance as of

Source: Adopted Budget FY 2011-2012, D-19.

Further, the Citys detailed schedule of cash balances in these funds as of June 30, 2012
was $18.5 million, barely enough to cover the $18.3 million cash deficit in the General
Fund.
5

INTERNAL SERVICE FUNDS

The City operates eight internal service funds to account for activities and balances
related to the internal administration of the City, including workers compensation and
general liability insurance; information and telecommunication systems; utilities; and
other central services such as the Citys motor pool and reproduction services. Internal
service funds are designed to operate on a break-even basis and should not accumulate
surpluses or deficits, but recover costs over a period of time pursuant to Federal OMB
A-87 Accounting Standards. These standards are applicable to all states, counties, cities
and special districts that receive federal funds.

The total combined net assets of the internal service funds as of June 30, 2010 were a
negative $7.8 million and these funds held only $59,019 in cash, almost all of it in the
Liability Insurance Internal Service Fund. Much of the deficit is the result of the
Workers Compensation Internal Service Fund not maintaining sufficient reserves to
cover current and non-current claims and judgments. However, six of the eight internal
service funds maintain a deficit unrestricted fund balance and the remaining two have
virtually no cash on hand to meet obligations. Rather, all of the internal service funds
either deferred charges to other City funds in the combined amount of $5.6 million or

5
Cash Cross Fund Report, file: Cash Flow 7 24 2012 Corrected Final BATES 10798-10819.


7
received loans from other funds in the combined amount of $1.0 million. In essence,
these funds ceased billing for services provided or costs incurred on behalf of other
funds. This is a $1.5 million or 23.5 percent deterioration of financial position from the
prior year which had a deficit fund balance of $6.3 million. In fact, as shown in
Attachment 4, since FY 2007-08, the City has been using and exceeding any reserves
held in its internal service funds.

A review of the budget initially adopted by the City Council for FY 2011-12 shows
marginal improvement in financial position with a budgeted decrease in the combined
deficit of $260,500 or 2.6 percent.
6
The City has subsequently projected that as of June
30, 2012, these funds would have approximately $375,574 of cash on hand. When
compared to the $24.0 million in annual operating expenses in FY 2009-10, this is
insufficient to meet even immediate obligations.

In California, the Office of the State Controller has provided additional OMB A-87
guidelines for use by local government agencies. These guidelines state:
Each ISF should regularly prepare and examine its financial condition at
least midway through each fiscal year. If a material profit or loss is
projected for the end of the fiscal year, the funds billing rates should be
adjusted during the year. An immaterial deficit or profit at year-end
should be offset by adjusting the billing rates for the following fiscal
period.

Typically, internal service funds maintain sufficient net assets to cover estimated
liabilities and sufficient working capital, which best practices establishes at
approximately 60 days operating expenses. Thus, it appears that not only has the City
not maintained sufficient reserves, but has actually put these funds in a deficit position
that ultimately will be borne by user funds, primarily the General Fund.

6
Adopted Budget FY 2011-2012, D-19.


8
ENTERPRISE FUNDS

The City operates three enterprise funds: the Water Fund, the Sewer Fund, and the
Integrated Waste Fund. Enterprise funds are established to account for government
activities that have elements of risk and more closely resemble private business
activities. Consequently, the customers served by enterprise fund activities are
typically charged user fees to pay for the cost of the services provided and such
revenues are restricted for funding enterprise activities. However, the financial health
of these funds is important for due to the impact on the overall financial health of the
primary government as well as the potential for direct and indirect financial support.

The total net assets of the enterprise funds as of June 30, 2010 were approximately
$252.7 million, of which $39.7 million was unrestricted and $32.7 million was supported
by available cash and investments. Almost all of these balances were held in the Sewer
Fund and the Water Fund, with $23.5 million and $11.6 million in unrestricted fund
balance, respectively. Additionally, the Sewer Fund and the Water Fund held sufficient
cash for over three months and 11 months of operating expenditures, respectively. The
Government Finance Officers Association and best practices typically set this threshold
at 60 days. Conversely, the Integrated Waste Fund held only $2,333 in cash as of June
30, 2010.

With the exception of the Integrated Waste Fund, which the City reports as having a
negative cash balance of $2.0 million as of June 30, 2012, the City has not incorporated
the other enterprise funds in its recent analysis of the Citys fund balance and cash
position. The City may view these funds as restricted and, therefore, unavailable.

However, as previously noted, these funds can both directly and indirectly impact the
overall financial position of the City as well as its General Fund. The City Charter
allows for 10 percent of Water revenues to be transferred to the General Fund, but
Water Enterprise financial statements as of June 30, 2011 show that this transfer was not
made in FY 2010-11.
7
In FY 2009-10, the transfer was $2.3 million. Further, to the extent
that the Water or Sewer Funds assets were originally purchased by the General Fund,
or to the extent that the General Fund directly subsidized these funds in prior years,
these monies are available to reimburse the General Fund. It is unknown if the City has
ever done such an analysis.

7
The Municipal Water Department issued stand-alone audited financial statements for FY 2010-11.


9
Additionally, administrative charges increased significantly in FY 2010-11. The City
may have an opportunity to review prior years and recoup unfunded administrative
charges. These funds should be reimbursing other funds, primarily the General Fund
and the internal service funds, for 100 percent of overhead or administrative costs.
Based on statements made in the Pre-Pendency Plan, it is unclear the extent to which
the City has a sufficient cost allocation program.

Finally, while funds are restricted for expenditure on enterprise activities, we do not
know of any prohibition on the loaning of cash balances to the primary government,
especially if formalized and established as an interest paying debt-instrument approved
by the City Council.

RETIREMENT FUNDING

The City contributes to the California Public Employees Retirement System (PERS),
which provides retirement, death and disability benefits to members and beneficiaries.
PERS acts as a common investment and administrative agent for participating public
entities within the State of California.

PERS maintains separate accounts for the Citys Miscellaneous and Safety employee
retirement funds. Based on the latest actuarial valuation report from PERS as of June 30,
2010, the Miscellaneous Employee account was funded at 86.3 percent, based on a total
liability of $406.9 million and actuarial value assets of $351.0 million. The Safety
Employee account was funded at 84.2 percent, based on a total liability of $552.3 million
and actuarial value assets of $464.8 million. However, when incorporating the Citys
outstanding liability for pension bonds issued in 2005, on a combined basis, the Citys
pension funds were funded at 80.1 percent of normal entry age accrued liability as of
June 30, 2010 ($959.2 million liabilities and $768.0 million assets).

Because the actuarial valuation process excludes a portion of excess investment gains
and losses by amortizing them over a 15-year period, the annually reported market
value of assets and liabilities is a more accurate measure of the current funded status as
of the valuation date. On a market basis, the Citys employee retirement accounts were
only funded 66.7 percent as of June 30, 2010 ($959.2 million of liabilities and $639.7 of
assets). However, this analysis does not consider investment gains since FY 2009-10
and the next valuation should present an improved position.

The City could have reduce its required annual employer contribution to PERS in prior


10
years by choosing the prepayment option, which offers employers the option to pay a
reduced lump sum at the beginning of each fiscal year instead of paying the standard
full amount incrementally throughout the fiscal year. According to the most recent
PERS actuarial reports, the combined Miscellaneous and Safety plan lump sum option
for the City in FY 2012-13 is approximately $24,582,804, a savings of $886,857 over the
standard amount, including the loss of interest revenue that would be generated by
keeping available cash funds in the Local Area Investment Fund (LAIF) pool and in
short-term money market funds of $47,953 based on the most recent rates available
from the California State Treasurers Office. However, given the cash position of the
General Fund it is currently not possible for the City to fully prepay its annual PERS
employer contribution, even if it were to borrow available cash resources from other
City funds. Consequently, to the extent the City could prepay a portion of its annual
PERS employer contribution in the future, it would generate net savings of
approximately $36,000 per $1,000,000 prepaid.

Finally, the City has adopted a supplemental retirement plan to PERS for certain police
safety and management employees. As noted in Note 18 to the FY 2009-10 CAFR, the
Public Agency Retirement System (PARS) plan is entirely funded by City contributions
that totaled $546,801 and $559,119 in 2010 and 2009, respectively. Based on the note
disclosure, it is unclear whether these benefits are vested, but the City should review
the policy of these excessive benefits to potentially save over one-half million dollars a
year.

Retiree Health Insurance Funding

The City provides retiree health insurance benefits which are funded in part by the City
and in part by plan members depending upon individual labor agreements. The
contribution requirement of plan members and the City is based on projected pay-as-
you-go financing requirements. As of June 30, 2010, the most recent valuation date, the
actuarial accrued liability for the retiree health plan for Water Department employees
was $26.0 million, which was zero percent funded. For all other City employees, as of
June 30, 2009, the most recent valuation date, the actuarial accrued liability for the
retiree health plan was $61.4 million, which was zero percent funded. Additionally, as
of June 30, 2009, retiree health insurance benefits provided to employees of the
Economic Development Agency totaled $749,000, but this liability should have been
transferred and held, along with associated reserves, by the redevelopment agencys
successor agency for holding until the settlement of all redevelopment activities.


11
COMPARISON WITH OTHER CITIES

To provide a comparative perspective on the financial condition of the City of San
Bernardino, financial data was obtained from the Comprehensive Annual Financial
Reports (CAFR) of 10 comparable California cities selected based on population. The
results from this comparison are included in Attachments 5 through 9.

General Fund Comparison

Attachment 5 provides the year-end General Fund balances in 10 California cities
selected for comparison with the City of San Bernardino. As shown in Attachment 5, the
Citys FY 2009-10 General Fund fund balance in proportion to annual General Fund
expenditures was 0.3 percent, the lowest of all of the comparison cities by a wide
margin. The average General Fund fund balance as a percent of annual General Fund
expenditures for the comparison cities, excluding San Bernardino, was 56.5 percent,
with the next lowest being the City of Modesto at 15.5 percent.

On a per capita basis, the Citys fund balance of $2 per capita was again the lowest of all
of the comparison cities by a wide margin with the next lowest being the City of
Modesto at $74 of fund balance per capita. The average per capita fund balance of all
comparable cities, excluding San Bernardino, was $308.
Expenditure Comparison

Conversely, General Fund expenditures in San Bernardino were the fourth highest of all
the comparison cities in FY 2009-10. At $619 per capita, expenditures in San Bernardino
were 109 percent of the average of $566 of the 10 comparison cities. Thus, the City of
San Bernardino spends a little more than average on services to the community.

Cash Comparison

San Bernardinos June 30, 2010 General Fund cash balance of $2,120, which equated to
0.0 percent of annual General Fund expenditures, had no peers within the 10
comparison cities, which averaged 39.9 percent of annual General Fund expenditures.
The City of Modesto maintained the next lowest cash balance of $5.8 million, which was
6.0 percent of its annual expenditures.


12
Functional Expenditures

Attachment 6 delineates FY 2009-10 General Fund expenditures by function and
compares the reported spending of San Bernardino with the comparison cities. Due to
reporting variances between cities, some cities categorized the same expenditures
differently. Therefore, only broad comparative observations are appropriate when
comparing expenditure categories between cities. This comparison found that San
Bernardinos spending on public protection, which amounted to 30.8 percent of total
City-wide expenditures, was slightly higher than the average expenditure of 28.3
percent by the comparison cities.

The City was ranked second in both Sewer and Sanitation and Community
Development spending. However, the City reported no Public Works expenditures,
which were likely included in other categories including those previously mentioned
and Transportation.

City-wide Indebtedness Comparison

The level of City-wide indebtedness was also analyzed. Attachment 7 shows that the
City of San Bernardino had the second highest level of indebtedness of all the
comparison cities in relation to its total assets at 40.1 percent, with $1.10 billion of assets
and $443.3 million in liabilities. The average indebtedness of the comparison cities,
excluding San Bernardino, was 23.1 percent, with a range from 3.2 percent in Irvine to
52.4 percent in Fontana. To the extent that a city has less debt, it can devote less of its
ongoing resources to interest expense and more to providing direct public services.

Retirement Funding

As shown in Attachment 8, the pension funds of the 10 comparison cities were, on
average, funded at 79.9 percent on an actuarial basis. The City of San Bernardino is
funded at 80.1 percent, which is on par with the other jurisdictions.

As previously noted, neither the full effects of the recession and the substantial decline
in the investment markets are not reflected in the most recent PERS actuarial valuation
report dated June 30, 2010, nor is the investment gains since that time included in the
market valuation. Accordingly, the Citys actuarial funded percentage will decline
when the June 30, 2011 actuarial valuation is issued, while market value funded
percentage will increase.


13
Other Post-Employment Benefits

When compared to the 10 survey cities in Attachment 9, the Citys unfunded liability
ranked 4th highest with an unfunded liability equal to 28.2 percent of its annual
expenditures versus an average of 16.4 percent of annual expenditures in the
comparison cities.

INSOLVENCY

While the Citys financial position is poor and has been for some time, these issues
where not sudden and unknown. At least since FY 2007-08, the Citys financial
statement showed signs of financial distress and budget-balancing actions that would
not be considered fiscally prudent. In fact, the Citys General Fund experienced a
deficit where annual revenues exceeded annual expenditures in every year since FY
2001-02.

The City based its declaration of fiscal emergency in July of 2012 primarily upon the fact
that 1) the General Fund was operating in a long-term deficit position, 2) other reserves
and resources had been exhausted, 3) long-term liabilities had not been addressed, and
4) reductions in service levels were unacceptable. However, there are a number of
weaknesses in the Citys supporting schedules for insolvency, including:

The Fiscal Emergency Operating Plan dated July 23, 2012 reports that the Citys
total cash and investment portfolio (unaudited) was $27 million as of June 30,
2012. Depending upon what this balance includes, it may be available for short-
term cash requirements. As discussed earlier, there may be legitimate transfers of
available resources from the Enterprise funds and, additionally, nothing
precludes the formal loaning of available cash balances. That said, cash retained
by the City as the Successor Agency may not be available.

The Selected Monthly Cash Flow Analysis (Attachment C to the Fiscal
Emergency Operating Plan) is for the General Fund only and does not include
other City funds that have a direct financial impact of the Citys overall ability to
meet its obligations.

The Summary of Revenues, Expenditures, and Changes in Fund Balance
(Attachment B to the Fiscal Emergency Operating Plan) reports a significant
budgeted increase of General Government expenditures primarily as a result of


14
funding long-term liabilities that, until this time, were unfunded, including $6.7
million for Retiree Health, $4.9 million for General Liability, and $3.3 million for
Workers Compensation. These budget line-items do not require cash payments.
The increase in Cashouts from $576 to over $3.4 million may or may not be a
cash requirement.

The Selected Monthly Cash Flow Analysis Measures to Manage Cash Flow
(Attachment E to the Fiscal Emergency Operating Plan) details City
managements recommendations to reduce General Fund cash outflows. These
are not explained, such as why only 20% of internal service charges are reduced,
nor are they maximized. For example, the City should consider reducing
overtime expenditures to zero from $613,933. Further, all funding for long-term
liabilities that do not require cash payout should be suspended, such as the
monthly $554,833 allocation for Retiree Health.

While the Citys options in mid-summer were very limited, the findings indicate that
the declaration of insolvency may have been premature. Budget reduction actions do
take time for implementation, especially given that the City needs to reduce service
levels and, therefore, staffing levels. While it will take years to bring the City back to
financial stability, definitive decision-making and leadership may have stabilized the
immediate cash shortage, but would not have absolutely prevented insolvency.

SUMMARY

In summary, we believe the City has been in poor financial condition for some time.
City leadership should have known since at least FY 2007-08 that significant and
immediate budget reductions would have to be made. While the City maintained very
limited options by mid-summer of 2012, comprehensive analysis of the City as a whole
along with decisive and immediate budget reductions may have prevented insolvency
at least in the near-term or at least delayed the filing for Chapter 9 bankruptcy.

If you have any questions on this report or the attachments submitted, please call me at
(510) 387-7152.

Sincerely,

Christine Martin, CPA
City of Sao Bernardino
Balance Sheet
Governmental Funds
June 30, 2008
(with prior year data for comparative purposes only)
SJ2eclal Revenue Funds
;x
Federal Economic
and State Development
General Programs
Aeenc:t
ASSETS
$c;:) Cash and investments $ $ 19,002,155
Cash and investments with fiscal agents 3,555,249
Deposits
Receivables, net
Accounts 3,680,860 85,670
Interest 36,612 17,331 116,555
Leases
Taxes
Special assessments
Notes 19,606,561
Other 1,570
Inventory 19,489
Prepaids 19,033
Due l'tom other governments 10,728,536 1,699,134 1,241,955
Due from other funds 182,234
Advances to other funds 289,640
Property held for resale 39.190,207
Sewer capacity rights held 22.668
Other assets 54,062 125
Total assets $ 18,2931841 $ 11802,160 $ 79,651,745
The accompanying notes are an integral part of these financial statements.
-20-
Attachment 1
Attachment 2
City of San Bernardino
Statement of Revenues, Expenditures, and Changes In Fund Balances
Governmental Funds
For the year ended June 30, 2008
(with prior year data for comparative purposes only)
Revenue Funds
;><.
Economic
Federal and Development
General State Programs Age
REVENUES
Taxes $100,443,781 $ $
Licenses and permits 10,122,997
Impact fees
Rnes and forfeitures 1,499,214
Investment income 1,441 ,416 15 1,056,327
Intergovernmental 9,181 ,679 7,599,874 7,487,962
Charges for services 6,388,869
Other revenues 4,181.440 77,862 617,204
Total revenues 133,259,396 7,677?51 9!1611493
EXPENDITURES
Current:
General govemment 24,307.456 62,385
Public safety 95,611,918 2,451 ,230
Streets 9,666,812 1,870
Culture and recreation 6,899,521 371,894
Community development 2,482,040 120,233 6,761,496
Community service 3,750,054
Economic development 6,937,529
Debt Service:
Principal 1,780,591
Interest 2,219,639
Total expenditures
CJi2,967,977)
6,757,666 13,699,025
Excess (deficiency) of revenues
over (under) expenditures {9. 708,581l 920,085
OTHER FINANCING SOURCES (USES)
Issuance of debt 3,620,684
Transfers in 10,072,200 16,315,036
Transfers out {6,427,907} {3501000} {2.763,063}
Total other financing sources (uses) 7,264,977 {350,000} 13,551,973
SPECIAL ITEM
Forgiveness of debt
Net change In fund balances (2.443,604) 570,085 9,014.441
Fund balances (defiCit), beginning of year, restated 1815961648 {11354,040l 55.728.459
Fund balances (deficit). end of year $ 16,153,044 $ (783,955) $ 64,742.900
The accompanying notes are an integral part of these financial statements.
-26-
Attachment 3
CITY OF SAN BERNARDINO
Ana!vsis of General Fund - Fund Balance
Description of Reserve/ Designat ion FY 2009- 10 FY 2008- 09 FY 2007-08
Beginni ng Fund Balance
$ 2, 708,319 $ 16, 153, 044 $ 18, 596, 648
Reserves
Reserved for Encumbrances
$
697,720 $ 197,900 $ 250,400
Reserved for Deposits 78,960
Reserved for rnventory 19,133 19,327 19,489
Reserved for Prepaid Items
0 0 19,033
Reserved for Advances 306,389 0 306,389
Reserved for Petty Cash 5030 4 930 4 930
Total Reserves
$
1, 107, 232
$
222, 157
$
600, 241
Designated for contmumg appropriations
- 610,000
Designated for budget reserve
-
2 486 162 LO 779 300
Total Unreserved Desi gnations
$ - $ 2,486, 162 $ 11,389, 300
Unreserved, Undesignated Fund Balance (696, 939) 0 4, 163, 503
Endi ng General Fund Balance
$ 410, 293 $ 2, 708 319 $ 16 153 044
Cash and Investments-Unrestricted
$ 2,120 $ 4, 930
$ -
Annual General Fund Expenditures
$ 131,090, 605 $ 144, 052, 242 $ 142, 967, 977
Fund Bal ance as a % of Annual Expenditures 0.3% 1.90/o 11.30/o
Attachment 4
Three-Year Comparison of Internal Service Funds
Unemployment Insurance FY 2009-10 FY 2008- 09 FY 2007- 08 Workers' Compensation FY 2009-10
FY 2008- 091
FY 2007-08
Operating Expenses-Annual 497,086 299,617 149,783
Operattng Profit-Annual
I
(39,249) 106,106
Assets-June 30 Balance 0

259,210
Liablllbes-June 30 Balance 40,632 0
Net Assets-June 30 Balance (40,632) 1 219,961 259,210
Operating Expenses-Annual 3,754,572 5,394,861 2,720,087
Operating ProntAnnual ( 75,206)
(1,62! ,148)1
1,209,603
Assets-June 30 Balance 445 264,460 265,666
Uabllltles-June 30 Balance 9,042,814 9,231,789 7,996,047
Nel Assets-June 30 Balance I (9,042,369) 1 (8,967,329) (7,730,381)
Unrestricted FB-June 30 ( 40,632) 219, 961 259,210 Unrestricted FBlune 30 < 9, 042,369 > 1 c 8,967,329 > (7,731,070)
Advances to Other Funds 0

0
Cash-June 30 Balance
OJ 259, 210
Advances to Other Funds 0
179,74; I
0
I o I 199, 096
Liability Insurance FY 2009-10 FY 2008- 09 FY 200708 Motorpool
I FY 2009-10
FY 2008-09 FY 2007-08
Operating Expenses-Annual
3, 078,101 I
2,812,290 1,895,544
Operating Profit-Annual (2,201) 270,110 1,348,956
ASsets-June 30 Balance
I
4,562,000 4,538,118 3,999,769
30 Balance 5,234,541
5,258,9271 5,484,227
Net Assets-June 30 Balance (672,5411 (720,809) (1,484,458)
Unrestricted FB-lune 30
I
(672,541) (720,809) (1,487,466)
Advances to Other Funds 4,488,172 4,462,288 3,937,122
l
7,425,515 7,607,355 9,446,831
Operating Profit-Annual (578,170) (475,529) 203,219
Assets-June JO Balance 3,485,458 4,610,849 4,376,183
1
\:_@bllltles-June 30 Balance
2,7.13,3841
2.077,986
Net Assets-June 30 Balance
1,015,3391
l ,897,465 2,298,197
Unrest ricted FB-June 30
'
918,997 227,095 50,381
Advances l:o Other Funds 0 290,327 0
-
Cash-June 30 Balance 58,769 43, 228 23,880 cash-June 30 Balance
I
2501 250 90,870
Telephone Support
I FY 200910 FY 2008-091
FY 2007-08 Information Systems FY 200910 FY 2008-09 FY 2007- 08
Operating Expenses-Annual 843,040 800,500 845,583
Operating Profit-Annual
(233,060)1
(257,793)1
38,603
Assets-June 30 Balance 123,811 353,572 589,!80
Llatlllltles-June 30 tsatance
l
54,942 59, 172 48,986
Net Assets-June 30 Balance 68 869 294,400 540,!94
Unrestricted FB-June 30
I
68,869
294, 4001
497, 319
Advances to Other funds 73,306 275,169 471,369
Operat1ng Expenses-Annual 4,084L289
I
4,908,585
I
(396,789) 1
(776,775) (464,081)
Assets-June 30 Balance 1.678,674 2,290,650 3,027,495
LlabiiiLies-June 30 687,613 857,119 1, 174,315
Net Assets-June 30 Balance 991,061 !,433,531 1,853,l80
I
40, 001 229,421
Advances to Other funds
I
659,508 424,040 0
l
0 0 0 Cash-June 30 Balance
I
0( 0 939 246
Utility FY 2009-10 I FY 2008-091 FY 2007-08 Central Services FY 2009-10 FY 2008-09 FY 2007-08
I
4,088,639 4,.ll5,837 3,955,970
Operating_ ProfilAnnual _ 64,761
(265,636)1
18,390
Assets-June 30 Balance
970,7521
705,571 1.14, 731
Uabllltles-June 30 Balance 1Jl59,812 !,109,496 5!7,274
Net Assets June 30 Balance (89,060) -403,925 (402,543)
I (19,77221

(360, 599)
Advances to Other Funds 381 0921 0
I OJ 0
1
222,023 247,946 260,452
(72tQ49) ( 63&84) 1 (39,199)
Assets-June 30 Balance
I
_, 498[
6,536 28,.l85
Uablllties-June 30 Balance 57,780 64,269 66,050
Net Assets-June 30 Balance (51,282) (57,733) (37,865)
I
(51,282)
(57,733} 1
(37, 865)
Advances to Other Funds 6,498 3,550 0
Cash-June 30 15alance
I
0 0 23,760
All ISF Funds Combi ned FY 2009- 10 FY 2008- 09 FY 2007-QS
Operatlng Expenses-Annual
I
23,993,265 26, 210,28j 24,182,835
Operating Profit-Annual (l, SS3,307) 2,42!,597
Assets-June 30 Balance !0,827,638 12,989,717 12,660,419
Uabllltleslune 30 Balance
18,648,253 1
19,294, 156 17,364,885
Net Assets June 30 Balance (7,820,615) (6,304,439) (4,704,466)
(9,729,479)1 (8,652,640) 1 (8,403,955)
Advances to Other Funds 5,608,576 5,855,082 4,408,491
Cash-June 30 Balance 59,019 1 43,478 1,53&,062
Attachment 5
Comparison of General Fund Balances
With Selected Cities
Fund Balance Analysis Cash Balance Analysis
Fund General Percent of Fund Expend. General Percent of Cash
Balance Clty Annual Fund Ending Annual Estimated Balance Expend. Per Capita Fund Annual Bal
Rank Expenditures Bala.nce Expend. Population* Per Capita Per Capita Rank Cash Balance Expenditures Rank
1- 1
2anta Clarita
_ $
83,690,219 __ 124.3% 177,445 $ __ 472 $_
379 __ 11 __$ 64,178,073 -- 95.3% 1
-
2 Fontana
--
8W8,277_ 79,916,228 __ 93. 199,898 ____1_00
__ 427 __ 9 30,630,485 35.9% __ 5
-- -- --
3
--
Glendale __ 163,698,0QO 134,055,000 81.9% 696 850 2 _ 83,71l,OOO 51. 1% _1_
-- --
--
t
f- 4
__ Irvine
-- --
148,751,000 108,754,000 __ 73.1% 223,729
--
486
--
66_5 _ 3
--
102,575,000 -- 69.0% 2
-
_ 5_ Moreno Vai!!L.
--
74,585,694 __
46,365,519 --62.2&.__ 196,495

--
380
__ 10
--
43,017,864
--
57.7% __
3
Huntington Beach __ 170,717,00_0 _24,556,000 32.0% 283 _ l _ , __ 47,339,000 27.7% _...
1- 7
__Q.xnard __
--
U0,680,580 33,120,83_5 _ _ 29.9% 200,390
--
165
--
55_2_ 5
--
22,005,593 -- 19.9% 8
-
_ 8_ Chula Vista __
--
127,842,253 __ 35,740,399 -- 249, 382 143
--
513 7 19,641,248
--
15.4% 9
9 Fremont __ 116,046,208 _ 28;061,604 24. 2% - 217, 700 129 _ 6 _ _ 24,439,219 _1_1.1% 7
--
- - --

--
1- 10 __
--
14,987,384 __ 15.5% 203,085 -- 74
--
47_6 _ 6
--
2J!.11,695 __ 6.0% 10_
11 San Bernardino**-- 131, 090, 605 __ 410, 293 -- 211, 674 2 619 4 0.0% 11
-- --
-,-
--
Average Excl San Bernardino I $ 116, 159, 2.92 s 61, 924 719 56.5% 205,330 $ 308 $ 566 s 44, 334, 918 39.9 %
PopulaMn estimates are as of 1/1/12, by t he calif Dept of Finance
Flgtires for the City of San Semardlno are as of June 30, 2010: all tJf ti'le other dtles are as of June 30, 2011.
Fremonc
Compaf'lson of City-wide Expenditures by Function
With Sel ected Cities
a o <(.2,075,8.01 15,.639,514 45,7,180
5 19.9%__ 7
6,373,866
30%
0
[LQ%
01
0.0'.
0.0% 0.0% _ _ _
0 -0- D
o.o%,
HuntonatDfl Beach 20,:367.000 95,585,000 27,2l2,00...Q.:_
6,287,000 31,71.2,000 17,271

1
000 ll 0+--=- 0
a.o'llo __ _ _ 7S'IIo _ _ _ 66'11o __ t2.4'11o __ &.8'11o ___ o.OC!'o __ o_.O% ___ o,ll"'l
Oxnard
- 13,001.J<!O 59,640,431 34,432,579 __ 10,003
1
780 8.,333,540 ----a
79% __ 36. 1"' __ 20.8"' _ _ _ __ 6. 1% __ S.O'Ift __ 0.0'1\o
_!h__ o___ o _ o 14, 807,788
0.0% _ Jl.O% 0.0%. _QJ)% 9 .0'111
0
o:ci%"
: 83,381,)10 7,393,809
1
t<i;960,68J 28,301,160...::._;;,609,345 36,305,860 __ 3,676,135 7,G19,939 "0, 118,903 - CL 0
4 5'1\o __1!).8% __ __ S.S'IIo __ 10.5'!ro _ _ 1.3'\oo 13.4'!'. __ 1_2.1% 1.4% 2.8% 14 ___ O.Q'llo ,
J0,0!!_1
1
U1 96, 151, 341 _ 0 14, n5, 617 4'8,915
1
410 13, 852,035
_!W!_"JJt L6.o .,.
o-__!I 26,308, 124 - - -.....L- - - 0-
o.o.... O.O!t!._ O.O"JJt ....
20,845.._702 92,702,882
29.8%
__ o 3l,9s8,o32 26.225,688 s,S03,3JO l-4,062.940 __ of _ o_
o.ocv. 1 o.J'IIo _ _ 8_.cv. to 9%
10,521,098 -----0 __
J .4o/o_ _ _ 0.0%
Chula lllS!,B __ ; 46,ill._ll2 75,664,246 71,857,158. 11,505,488 5,688,738,. 11,.538,707
17.9'11. 291%
__ o 30,369.213 _ _ o_ o C1_ o
19,064,060. 53,809,019 29,054,582 >2,472,879; 15,621,402 77,027,473
7:!!!!._. 11 2:.!!!_ .....&2! 31.3%
O.ll'!<t
0
0.0%
0
0.0'14.
O.O'IIo _ _ _ 28'!1o_' _ __ O.O'IIo O.D'!It
Dl 0
D 0%1 0 0%-,--
0
o.o% _ _ _ o,o'l'o u . 9%
20,261,000 . 57.!1!!..000 SB,7..Qb._OOO 47,753,000 21,747,000, 68,000.- 0 , - __9, - 0 -a_ _o_ _ _
236.!!__ 88% D.O.,. OO'IIt _ _ _ O.O'IIo 0.0%
_-__ 25,700,000, 1
1
598,000, 36,221,000 75,.890<000 12,696,0001 35, 790,000 36, 394,D00
1
7,76J...QQQ__ IL_ 0 ! 188,569,000 _ 0
4.3.!!__ 71!!_ 6.2% 13% _ _ _ 0.011\ _ _ O.Oo/o __ 3_19% O.O"'o
,Sal1ta aami"" I u ,28t,SS2
----r 2911.!!_ 13 159%_ 70'11o_
U,5"7,650
7. 1'1\o
4,650,566 0
O.lJO!t
0 --- 0 2,127,043 0-- 0
O.D'I'o . O.O'!Io 0.0'1\o l _ 14 9'l'o 0.0"1" O.Oo/o

33.814. 5101 22, 681,7001 25, 738,4601 13,608,783113. 787,0801 18, 110.2551 1. 14], 9141 761. 994 8,1.99,483120,337, 679
ll..4"1ol 8.3"JJt! 9 .5"J\tl 5.0 .... 1 S. J. .... I 6 . .,./ol 0. 4 .... 1 O. l "'o 3..0 .... 1 7.S"'o

Due to and classofic:allon vanances llf!tWee<1 rounnH, compariS<ln of deta between ax'"tles shOUld only be used to Cll:uln a 9ener.1J rndlcauan d spenOJng patterns.
Attachment 6
0
O.O'IIo
0
0.0%
TOtlll
67,7351212. 106. 166
3 .8 "JJt l 10-0.0 "J\t
Rank City
1 Fontana
- 2 San Bernardino
3 Modesto --
4 Glendale
5 Oxnard --
6 __ FremQ!!L
Total
Assets
Comparison of City- wide Indebtedness
Total
LlabiiJties
Net
Assets
Percentage
Assets I Population
Financed
Debt
Per
Capita
Attachment 7
Net Assets I Date of
Per Finandal
Capita Statements
-- $ ____h393,77i,811_ $_ 729,851,496 $ - 663,920,315 - 52.4%- 199,898 $ 3,651 3,321- 6/30/201l
1
-- 1,104,809, 800 443,299,0Q.Q_ 661, 510, 800 40.1% 211, 674 2, 094 3, 125 6 / 30/ 2010
_ t,554,586,t6L 524,244,540__ t,o3o,34t,625 __ 33.7% 203,08_5_ 2,51!!_ 5,07_ 3 _ 6/30/20.!!..
- 2,226,232,000 -- 570,565,000 __ 1,655,667,000 __ 2,962 __ 8,594 6/30/2011
_2)_4, 445,818 ____!&53,088,720 24.3% 200,390 ___b.266 6/30/2011.
_ 264,601,352__ 927,709,404 2D,700 1,215 4,261 6/30/2011
1
7 VISta __ , _ 1,246,152,059 __ 265,078,449 __ 981,073,610 __ 21.3% __ 1,063 __ 3,934___'30/2011
,_ 8 Huntington Beach -4 _ 170,892,000 __ 884,061,000 16.2% 192,524 __ 888 6/30/2011
_9 __ Santa Clarita __ 1,06_?,979,745 171,394,17JL_ 894,585,ill_ 16.1% 177,445 5,041 6/30/2011
10 _ _ MorenoVal ley L . 1, 139,038, 18_ 9 _ 180,545,647 __ 958,492, 542, __ 15.9% __ 196,495 __ 9 19__ 4,87_8 __ 6/30/2011
11 lrvine 2.174.706.000 68,840,000 2,105,866,000 3.2o/o 223,729 308 9,413 6/30/2011
Average Excl. San Bemardlno $ 1,549,526, 426 $ 354,045,848 $ 1,195,480,578 23.1% 205,330 $ 1,752 $ 5,836
Rank City
1 Modesto
- -
2 Glendale
- -
3 Oxnard*
- - -
Comparison of Employee Retirement System Funding
Market Value of Actuarial Value of Entry Age Normal
Assets Assets Accrued Liab
_j_ 153 _j 626,825,454 _i 713,616,321
--
892,968,020 - 1,143,619,464 - 1,348,740,561
430,6701237 - 549,069,525 - 651,842,296 ,_
4 _ Huntington
-

-
719,733,273 - 883,395,051
5 Santa Clarita** 581575t.17 73,450,348 90,181,004
- - - -t-
- -
6 _ Chula Vista_ _ 1 _ 412
1
394,016 526,973,547 651,284,199
- -
7 _ San Bernardino_ _ 639_&69,303 - 959,219, 357
8 Fremont - 478,957,010 - 794,811,281
- - - - -
9 Irvine - 222,061,729 - - 366,474,793
- - -l
10 Fontana - 153,002,321 - 1926_46,360 259,654,766
- - -
--
-
11 _ Moreno Valley** _ - 68, 133,478 - 851693,181 120,692,084
-
Averaae Excluding San Bernardino I$ 481,o2s,o93 I $ s88,o69,236 I
Notes:
Attachment 8
Percent Date of
Funded*** Valuation
87.8% 6/30/201Q
- -
84.8% 6/30/2010
- -
-
84.2% _ 6/30/2010
-
81.5% _ 6/30/2010
81.4% _ 6/30/2010
-
80.9% _ 6/30/2010
-
80. 1/o
-
6/30/2010
77.0% _/30/2010
-
76.4% _'30/2010
-
74. 1% __./30/2010
-
71.0% __}_30/20 10
-
79.9/ol
* Includes separate firefighter plan, for which actuarial asset value was estimated using the market and actuarial value of police plan.
'"' * Data shown above pertains to the miscellaneous employee and fire sarety employee plans only. City does not have a separate police safety
plan, but Is Included in a State-wide PERS pool which is funded at 82.6 percent based on the actuarial value of assets.
***Percent funded is based on actuarial value of assets. Due to significant FY 2008-09 mvestment loss by PERS, the percent funded is
substantially less when calculated based on the market value of assets. For example, San Bernardino's percent funded Is only 66.7 percent,
based on market value.
Total
Post Retirement Health Program
Comparison of liabilities and Funding as of June 30, 2009
Total Unfunded Annual Percent
Attachment 9
Expenditures Unfunded Liability
Rank City Liabilities Assets Liability Required Funded All vs.
Contribution Funds All Fund Expend
- -- - - -- -- - - - -- -- -- -- -- - - -
1 Modesto _ _$ -_ $ 104,399,231 $ 12,170,874 0.0% $ 270,511,205 38.6%
- - -- --
2 Fremont _____?,049,000 -
67,049,000_ 6,071,000 _j!_.O% __ 210,916,446 __ 31.8%
- -- -- -- -- - - -
_3_ FontDna _ -l- 74,664,00_Q__ - 74,664,000 0.0% 246, 482,811 30.3%
- - -- --
4 Bernardi no** 88,120,000 - 8,602,490 0 .0% _ 312,012,065 28.2%
-- --I
-
5 Santa danta - 41,425,000 - 41,425,0QQ_ 0.0% 25.6%
-- -- -- -- -- --
6 Glendale 103,947,000 - 103,947,0QO _!_01445,000 0.0% 590,980Jl00 17.6%
7__! Moreno
- -
-- - -
$ 2,386,000 _ 11,214,0QQ__ 1,564
1
00Q____J.7,SOL_ 165,266,3Q__ 6.8%
-- --
8 __ 22,447,000 __!, 559,000 42.9% 5.0%
9 Chula Vista _ 11,885,000 -
11,885,000_ 1,470,000 __ 0.0% 254,559, 71&__ . 4.7%
--
- r
- -

10 Oxnard ll,OBl,O!!L_ - __111081,083 __h.?99,856 0.0% _1!_1,219,195 3.6%
-
-- -- -- --
11 Irvine 4 031,000 - 4 031 000 527 ODD 0.0% 248,406 000 1.6%
Average Excluding S.B. $ 45,049,731 $ 1,202,500 $ 43,847 231 $ 4,428 873 6.0% $ 246,696,692 16.4%

This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.

June 2012 F 9013-3.1.PROOF.SERVICE
PROOF OF SERVICE OF DOCUMENT

I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is:

Hayes & Cunningham, LLP, 5925 Kearny Villa Road, Suite 201, San Diego, CA 92123

A true and correct copy of the foregoing document entitled DECLARATION OF CHRISTINE MARTIN IN SUPPORT OF SAN
BERNARDINO PUBLIC EMPLOYEES ASSOCIATIONS OBJECTION TO DEBTOR CITY OF SAN BERNARDINOS
PETITION AND STATEMENT OF QUALIFICATION UNDER TITLE 11 U.S.C. SECTION 109(c) will be served or was
served (a) on the judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in the manner stated below:

1. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Pursuant to controlling General
Orders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On October 24, 2012, I
checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined that the following persons are on the
Electronic Mail Notice List to receive NEF transmission at the email addresses stated below:

Service information continued on attached page

2. SERVED BY UNITED STATES MAIL:
On October 24, 2012, I served the following persons and/or entities at the last known addresses in this bankruptcy case or adversary
proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail, first class, postage prepaid, and
addressed as follows. Listing the judge here constitutes a declaration that mailing to the judge will be completed no later than 24 hours
after the document is filed.

DEBTOR
City of San Bernardino, California
City Hall
300 North D Street
San Bernardino, CA 92418


3. SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL, FACSIMILE TRANSMISSION OR EMAIL (state method
for each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on October 24, 2012, I served the following
persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing to such service method), by
facsimile transmission and/or email as follows. Listing the judge here constitutes a declaration that personal delivery on, or overnight
mail to, the judge will be completed no later than 24 hours after the document is filed.

Via Overnight Delivery
Honorable Meredith A. Jury
United States Bankruptcy Court
Central District of California
3420 Twelfth Street, Suite 325 /
Courtroom 301
Riverside, CA 92501-3819


I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct.

October 24, 2012 Stephanie Kierig

/s/ Stephanie Kierig
Date Printed Name Signature


1. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF):

Jerrold Abeles abeles.jerry@arentfox.com
Franklin C. Adams franklin.adams@bbklaw.com; Arthur.johnston@bbklaw.com; lisa.spencer@bbklaw.com;
bknotices@bbklaw.com
Joseph M. Adams jadams@lawjma.com
Andrew K. Alper aalper@frandzel.com; efiling@frandzel.com; ekidder@frandzel.com
Thomas V. Askounis taskounis@askounisdarcy.com
Anthony Bisconti tbisconti@bmkattorneys.com
Jeffrey E. Bjork jbjork@sidley.com
Sarah C. Boone sboone@marshackhays.com; ecfmarshackhays@gmail.com
J. Scott Bovitz bovitz@bovitz-spitzer.com
Jeffrey W. Broker jbroker@brokerlaw.biz
Deana M. Brown dbrown@milbank.com
Michael J. Bujold Michael.J.Bujold@usdoj.gov
Christopher H. Conti chc@sdlaborlaw.com; sak@sdlaborlaw.com
Christina M. Craige ccraige@sidley.com
Alex Darcy adarcy@askounisdarcy.com
Susan S. Davis sdavis@coxcastle.com
Robert H. Dewberry Robert.dewberry@dewlaw.net
Todd J. Dressel dressel@chapman.com; lubecki@chapman.com
Chrysta L. Elliott elliottc@ballardspahr.com; manthiek@ballardspahr.com
Scott Ewing contact@omnimgt.com; sewing@omnimgt.com
Paul R. Glassman pglassman@sycr.com
David M. Goodrich dgoodrich@marshackhays.com
Everett L. Green Everett.l.green@usdoj.gov
Chad V. Haes chaes@marshackhays.com; ecfmarshackhays@gmail.com
James A. Hayes jhayes@cwlawyers.com
M. Jonathan Hayes jhayes@hayesbklaw.com; roksana@hayesbklaw.com; Carolyn@hayesbklaw.com;
Elizabeth@hayesbklaw.com
D. Edward Hays ehays@marshackhays.com; ecfmarshackhays@gmail.com
Eric M. Heller eric.m.heller@irscounsel.treas.gov
Bonnie M. Holcomb bonnie.holcomb@doj.ca.gov
Whitman L. Holt wholt@ktbslaw.com
Michelle C. Hribar mch@sdlaborlaw.com
Steven J. Katzman SKatzman@bmkattorneys.com
Jane Kespradit jane.kespradit@limruger.com; amy.lee@limruger.com
Mette H. Kurth kurth.mette@arentfox.com
Michael B. Lubic michael.lubic@klgates.com
Richard A. Marshack rmarshack@marshackhays.com; lbergini@marshackhays.com;
ecfmarshackhays@gmail.com
Gregory A. Martin gmartin@winston.com
David J. McCarty dmccarty@sheppardmullin.com; pibsen@sheppardmullin.com
Reed M. Mercado rmercado@shheppardmullin.com
Aron M. Oliner roliner@duanemorris.com
Scott H. Olson solson@seyfarth.com
Dean G. Rallis drallis@sulmeyerlaw.com
Christopher O. Rivas crivas@reedsmith.com
Kenneth N. Russak krussak@frandzel.com; efiling@frandzel.com; dmoore@frandzel.com
Gregory M. Salvato gsalvato@salvatolawoffices.com; calendar@salvatolawoffices.com
Mark C. Schnitzer mschnitzer@rhlaw.com; mschnitzer@verizon.net
Benjamin Seigel bseigel@buchalter.com; IFS_filing@buchalter.com
Diane S. Shaw diane.shaw@doj.ca.gov
Jason D. Strabo jstrabo@mwe.com; losangelestrialdocket@mwe.com
Matthew J. Troy matthew.troy@usdoj.gov
United States Trustee (RS) ustpregion16.rs.ecf@usdoj.gov
Anne A. Uyeda auyeda@bmkattorneys.com


Annie Verdries verdries@lbbslaw.com
Brian D. Wesley brian.wesley@doj.ca.gov
Kirsten A. Roe Worley kworley@wthf.com; bcordova@wthf.com

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