OFFICEOFTHEGENERALCOUNSEL

October19,2015

DouglasH.Appel
RegionalUniServeStaff
OaklandRegionalResourceCenter
1211EmbarcaderoSuite204
Oakland,CA94606

RE:MeasureFFApplicability

DearDoug:

Thank you so much for your patience as we inquired deeper into the applicability of Measure FF on
OaklandUnifiedSchoolDistrict(District). Asweindicatedinvariousconversationsfollowingthepassageof
Measure FF, wedonotbelievethattheDistrictisboundbythechangesinthemunicipalcodegivenitsstatusas
a separate public entity. However, we have been willing to negotiate with our labor partners to consider
including aspects of the spirit or intent of Measure FF into our bargaining agreements. In contrast, the
amendments to the California Labor Code (AB 1522 & AB 304) appear to apply to school districts and to
providesickleavebenefitsthatvaryinpartfromthosecurrentlyprovidedtosomeDistrictemployees. Wehave
begun to implement these legislative changes and welcome the opportunity to discuss the implementation and
negotiatepotentialimpactswithyou.

Even though the City Attorneys office provided you with the generic definition of employer under
the amended city municipal code, it does not appeartoconstitutelegaladviceoranalyzetheDistrictsstatusas
a distinct legal entity. OUSDs exemption from certainmunicipallawsisrootedintheCaliforniaConstitution.
Among other things, the California Constitution creates state and county education offices, authorizes the
creation of school districts, and specifies minimum salaries for teachers. Cal. Const. art. IX, 23.3, 6. The
public school system and education ingeneralispurelyastatefunction,whichthecourtshavelongrecognized.
Butt v. State of Cal.
, 4Cal.4th668,680(1992).
Californiacourtshaveadheredtothefollowingprinciples:
Public education is an obligation which the State assumed by the adoption of the Constitution. See also
San
Francisco Unified School Dist. v. Johnson 3 Cal.3d 937, 951952, (1971)
Piper v. Big Pine School Dist. 193
Cal.664,669(1924).

Furthermore, the control and management of the states public schools falls under the directionofstate
legislature, not local measures.
Butt v. State of Cal.
, 4 Cal. 4th 668, 681 (1992)quoting
Kennedyv.Miller97
Cal. 429, 432, 431 (1893).
"[M]anagement and control of the public schools [is] a matterofstate,[notlocal,]
care and supervision. . ." See also
Hallv.CityofTaft
,47Cal.2d177,181(1956)
CaliforniaTeachersAssn.v.
Huff
, 5 Cal.App.4th 1513, 15231524 (1992). The management and control of the school district, which
extends to wages and salaries of its employees, is limited only by the California Constitution, and is not
governed by local measures or ordinances.
Butt v. State of Cal.
, supra atpp.681.
TheLegislature's"plenary"
power over public education is subject only to constitutional restrictions. See also
Hallv.CityofTaft
,supra,
at pp. 180181
Tinsley v. Palo Alto Unified School Dist
. (1979) 91 Cal.App.3d 871, 903904. Notably, the

1000Broadway,Suite680,Oakland,CA94607

510.879.8535ph|510.879.4046fax
www.ousd.org

OFFICEOFTHEGENERALCOUNSEL

exemption between independent public entities has been echoed and implemented in several other state
1
municipalities with progressive minimum wage measures, including the City of Mountain View , the City of
2
3
SanJos ,andtheCityofSanFrancisco .

In short, although we do not believe that the Measure FF sick leaveprovisionsapplytotheDistrict,we

believe that many of our employees who did not previously qualify for sick leave benefits will receive such
benefits under the current state laws. We are hoping that the new upgrades to IFAS will facilitate the
implementation and tracking of such sick leave benefits. We welcome the opportunity to negotiate impactsof
the implementation of these new laws with OEA. Pleasecontinuetoworkwithourlaborteam,JenineLindsey
and Amy Brandt to arrange a convenient time. It would likely be helpful for Linda PulidoEsquiveltoalsobe
presentinthatmeeting.

Sincerely,

/s/MarionMcWilliams

MarionMcWilliams
DeputyGeneralCounsel

MountainViewCityCode,art.II,42.15.
Exemptorganizations.State,federalandcountyagencies,includingschool
districts,shallnotberequiredtopayminimumwagewhentheworkperformedisrelatedtotheirgovernmentalfunction.
2
SanJoseMinimumWageOrdinanceCityAttorneysOfficeFAQs,
Stateandfederalagencies,includingschool
districts,arenotrequiredtopayminimumwagewhentheworkperformedisrelatedtotheirgovernmentalfunction.
https://www.sanjoseca.gov/DocumentCenter/View/12423
3
SanFranciscoUnifiedSchoolDistrict,ResolutionNo.14812A2,
WHEREAS:AsanentityoftheState,theSan
FranciscoUnifiedSchoolDistrictisnotsubjecttotheSanFranciscoMinimumWageOrdinance.
http://www.sfusd.edu/en/assets/sfusdstaff/aboutSFUSD/files/resolutions/Haney%20Minimum%20Wage%20for%208%2
012%2014%20final.pdf
1

1000Broadway,Suite680,Oakland,CA94607

510.879.8535ph|510.879.4046fax
www.ousd.org

OFFICEOFTHEGENERALCOUNSEL

October19,2015

DouglasH.Appel
RegionalUniServeStaff
OaklandRegionalResourceCenter
1211EmbarcaderoSuite204
Oakland,CA94606

RE:MeasureFFApplicability

DearDoug:

Thank you so much for your patience as we inquired deeper into the applicability of Measure FF on
OaklandUnifiedSchoolDistrict(District). Asweindicatedinvariousconversationsfollowingthepassageof
Measure FF, wedonotbelievethattheDistrictisboundbythechangesinthemunicipalcodegivenitsstatusas
a separate public entity. However, we have been willing to negotiate with our labor partners to consider
including aspects of the spirit or intent of Measure FF into our bargaining agreements. In contrast, the
amendments to the California Labor Code (AB 1522 & AB 304) appear to apply to school districts and to
providesickleavebenefitsthatvaryinpartfromthosecurrentlyprovidedtosomeDistrictemployees. Wehave
begun to implement these legislative changes and welcome the opportunity to discuss the implementation and
negotiatepotentialimpactswithyou.

Even though the City Attorneys office provided you with the generic definition of employer under
the amended city municipal code, it does not appeartoconstitutelegaladviceoranalyzetheDistrictsstatusas
a distinct legal entity. OUSDs exemption from certainmunicipallawsisrootedintheCaliforniaConstitution.
Among other things, the California Constitution creates state and county education offices, authorizes the
creation of school districts, and specifies minimum salaries for teachers. Cal. Const. art. IX, 23.3, 6. The
public school system and education ingeneralispurelyastatefunction,whichthecourtshavelongrecognized.
Butt v. State of Cal.
, 4Cal.4th668,680(1992).
Californiacourtshaveadheredtothefollowingprinciples:
Public education is an obligation which the State assumed by the adoption of the Constitution. See also
San
Francisco Unified School Dist. v. Johnson 3 Cal.3d 937, 951952, (1971)
Piper v. Big Pine School Dist. 193
Cal.664,669(1924).

Furthermore, the control and management of the states public schools falls under the directionofstate
legislature, not local measures.
Butt v. State of Cal.
, 4 Cal. 4th 668, 681 (1992)quoting
Kennedyv.Miller97
Cal. 429, 432, 431 (1893).
"[M]anagement and control of the public schools [is] a matterofstate,[notlocal,]
care and supervision. . ." See also
Hallv.CityofTaft
,47Cal.2d177,181(1956)
CaliforniaTeachersAssn.v.
Huff
, 5 Cal.App.4th 1513, 15231524 (1992). The management and control of the school district, which
extends to wages and salaries of its employees, is limited only by the California Constitution, and is not
governed by local measures or ordinances.
Butt v. State of Cal.
, supra atpp.681.
TheLegislature's"plenary"
power over public education is subject only to constitutional restrictions. See also
Hallv.CityofTaft
,supra,
at pp. 180181
Tinsley v. Palo Alto Unified School Dist
. (1979) 91 Cal.App.3d 871, 903904. Notably, the

1000Broadway,Suite680,Oakland,CA94607

510.879.8535ph|510.879.4046fax
www.ousd.org

OFFICEOFTHEGENERALCOUNSEL

exemption between independent public entities has been echoed and implemented in several other state
1
municipalities with progressive minimum wage measures, including the City of Mountain View , the City of
2
3
SanJos ,andtheCityofSanFrancisco .

In short, although we do not believe that the Measure FF sick leaveprovisionsapplytotheDistrict,we

believe that many of our employees who did not previously qualify for sick leave benefits will receive such
benefits under the current state laws. We are hoping that the new upgrades to IFAS will facilitate the
implementation and tracking of such sick leave benefits. We welcome the opportunity to negotiate impactsof
the implementation of these new laws with OEA. Pleasecontinuetoworkwithourlaborteam,JenineLindsey
and Amy Brandt to arrange a convenient time. It would likely be helpful for Linda PulidoEsquiveltoalsobe
presentinthatmeeting.

Sincerely,

/s/MarionMcWilliams

MarionMcWilliams
DeputyGeneralCounsel

MountainViewCityCode,art.II,42.15.
Exemptorganizations.State,federalandcountyagencies,includingschool
districts,shallnotberequiredtopayminimumwagewhentheworkperformedisrelatedtotheirgovernmentalfunction.
2
SanJoseMinimumWageOrdinanceCityAttorneysOfficeFAQs,
Stateandfederalagencies,includingschool
districts,arenotrequiredtopayminimumwagewhentheworkperformedisrelatedtotheirgovernmentalfunction.
https://www.sanjoseca.gov/DocumentCenter/View/12423
3
SanFranciscoUnifiedSchoolDistrict,ResolutionNo.14812A2,
WHEREAS:AsanentityoftheState,theSan
FranciscoUnifiedSchoolDistrictisnotsubjecttotheSanFranciscoMinimumWageOrdinance.
http://www.sfusd.edu/en/assets/sfusdstaff/aboutSFUSD/files/resolutions/Haney%20Minimum%20Wage%20for%208%2
012%2014%20final.pdf
1

1000Broadway,Suite680,Oakland,CA94607

510.879.8535ph|510.879.4046fax
www.ousd.org

From: Brigitte Marshall [mailto:brigitte.marshall@ousd.org]

Sent: Monday, November 23, 2015 4:21 PM
To: Barnes, Deborah
Cc: Marion McWilliams
Subject: Recent communication from

From: Brigitte Marshall [mailto:brigitte.marshall@ousd.org]

Sent: Monday, November 23, 2015 4:21 PM
To: Barnes, Deborah

Cc: Marion McWilliams

Subject: Recent communication from Doug Appel with CTA

Good afternoon, Ms. Barnes;

Shona Scott reached out to me to let me know that the City has been contacted by
Doug Appel from CTA regarding his assertions that the Oakland Unified School
District is not complying with the terms of Measure FF. Please find attached a copy
of the communication sent to Mr. Appel earlier this month by our Deputy General
Counsel, Marion McWilliams. Please let me know if you have any questions about
our position on this issue; I'm sure that Deputy General Counsel McWilliams will be
happy to follow up with you.

-In Partnership Brigitte Marshall, Chief Talent Officer

Talent Division
Oakland Unified School District
1000 Broadway, 2nd Floor, Suite 295
Oakland, CA 94607
Telephone: (510) 879-8887

Like our Facebook page and share our recruiting posts!

Check out our website: www.ousd.org/hiring
***NOTE new website & E-mail:
www.OUSD.org | Brigitte.Marshall@ousd.org
Every Student Thrives!
Community Schools, Thriving Students
The Oakland Unified School District does not discriminate in any program, activity, or in employment on the basis of
actual or perceived race, religion, color, national origin, ancestry, age, marital status, pregnancy, physical or mental
disability, medical condition, genetic information, veteran status, gender, sex, or sexual orientation.

-In Partnership Brigitte Marshall, Chief Talent Officer

Talent Division

Oakland Unified School District

1000 Broadway, 2nd Floor, Suite 295
Oakland, CA 94607
Telephone: (510) 879-8887

Like our Facebook page and share our recruiting posts!

Check out our website: www.ousd.org/hiring
***NOTE new website & E-mail:
www.OUSD.org | Brigitte.Marshall@ousd.org
Every Student Thrives!
Community Schools, Thriving Students
The Oakland Unified School District does not discriminate in any program, activity, or in employment on the basis of
actual or perceived race, religion, color, national origin, ancestry, age, marital status, pregnancy, physical or mental
disability, medical condition, genetic information, veteran status, gender, sex, or sexual orientation.

_____________________________________________
From: Berens, Matt
Sent: Friday, October 16, 2015 5:19 PM
To: Barnes, Deborah
Subject: RE: Oakland Sick Leave

Debbie,
and I left a message for him. Im waiting for him to get back to
I called
me so we can move forward with this issue.
Matt Berens
Minimum Wage Enforcement Officer
Office of the City Administrator:
Division of Contracts and Compliance
City of Oakland
250 Frank Ogawa Plaza: Suite 3341
Oakland, CA 94612
Phone: 510.238.7735
Fax: 510.238.3363

mberens@oaklandnet.com
www.oaklandnet.com/minimumwage

-----Original Message----From: Parker, Barbara [mailto:BParker@oaklandcityattorney.org]

Sent: Friday, October 16, 2015 9:33 AM
To: Schaaf, Libby;
; Barnes, Deborah
Cc: Moss, Tomiquia
Subject: RE: Oakland Sick Leave
We will review the ordinance and determine options and procedures and get back to
you ASAP. This is egregious.
-----Original Message----From: Libby Schaaf [mailto:libbyforoakland@gmail.com]
Sent: Friday, October 16, 2015 8:24 AM
To:
; Barnes, Deborah
Cc: Parker, Barbara; Moss, Tomiquia
Subject: Re: Oakland Sick Leave
This is serious!
Deborah Please advise how we proceed.
Sent from my iPhone

> On Oct 16, 2015, at 7:46 AM,

wrote:
>
> Libby,
> It's come to my attention that Schintzer Steel is not adhering to the sick leave law in
any form or fashion.
> There is a large Hispanic component working there and I am quite sure they will not
come forward to file complaints.
> Who can I get from the city to investigate ?
> I appreciate any help you can give me.
>
>

From:
Sent:
To:
CC:
Subject:
Attachments:

"Darensburg, Shelley" <CITY OF OAKLAND/CITY

CENTER/RECIPIENTS/DAREN9S>
3/9/2015 10:39:38 PM +0000
"Schlenk, Sarah" <SSchlenk@oaklandnet.com>; "Hom, Donna"
<DHom@oaklandnet.com>; "Cook, Allyson E."
<ACook@oaklandcityattorney.org>
"Barnes, Deborah" <DBarnes@oaklandnet.com>
FW: Request for Minimum Wage Complaint Form
minimumwagecomplaintform.pdf

Greetings everyone,
Please be advised that I received a telephone call from a woman by the name of
She requested a minimum wage complaint.
Thank you,
Shelley

From: Darensburg, Shelley

Sent: Monday, March 09, 2015 2:45 PM
To: Darensburg, Shelley;
Subject: Request for Minimum Wage Complaint Form

Hi
Thank you for your call today regarding the Oakland Minimum Wage Law. Attached
per your request, please find the complaint form.

Should you have any questions or need additional information, please do not
hesitate to contact me.

Shelley Darensburg
Senior Contract Compliance Officer
City of Oakland
City Administrator's Office
Contracts and Compliance Unit
250 Frank H. Ogawa Plaza, Suite 3341
Oakland, California 94612

(510) 238-7325
(510) 238-3363 fax
sdarensburg@oaklandnet.com

Oakland Ranked #5 Place to Visit in the World!

New York Times, January 2012 http://bit.ly/GB3s8f

For iSupplier Login visit us at: http://www2.oaklandnet.com/Government/o/CP/index.htm

For iSupplier online guide visit us at:
http://www2.oaklandnet.com/oakca/groups/contracting/documents/form/oak024312.pdf
"The only tyrant I accept in this world is still the voice within." -- Mahatma Gandhi

"No work is insignificant. All labor that uplifts humanity has dignity and importance and should be
undertaken with painstaking excellence." -- Dr. Martin Luther King, Jr.

CITY OF OAKLAND
CITY ADMINISTRATORS OFFICE - CONTRACTS AND COMPLIANCE DIVISION
MINIMUM WAGE: Employee Questionnaire & Declaration in Support of Claim
Employee Name:

Date:

Employee Phone Number:

Business Name:

Employee Email:

Business Phone Number:

Employee Address:

Business Address:

1. Briefly describe why you are submitting this complaint (for example, Im not being paid the required
minimum compensation, Im not receiving sick leave or I am not receiving my service charges from my
employer)

2. What is your position or description of your duties (for example, driver, cook, etc.)? ________________
3. When did you begin to work for this employer? Include the starting date._____________________
4. Are you still employed by this employer? YES ___ or NO ___.
If NO, when was your last day of work? ____________________ and why are you no longer working for
this employer?
5. Who sets your schedule and supervises your work? _________________
6. Do you have records of the hours you work? YES___ or NO___
7. Are you required to record your start and end time? YES ___or NO___
If YES, do you punch in and out on a time clock or do you use a hand-written time sheet/time
card? ______________
If NO, explain how your hours are tracked.
8. List your regular work schedule below. If you punch in and out multiple times during the day, list that
in the space provided.
Monday

Tuesday

Wednesday

Thursday

Friday

Saturday

Sunday

Time In
Time Out
Time In
Time Out
Time In
Time Out

Contracts and Compliance 250 Frank Ogawa Plaza 3rd Floor, (510) 2386258

Page 1

9. If you do not have a regular work schedule each week, how many hours per week do you work, on
average? __________________

10. What is your current rate of pay per hour? _______________

11. Has your rate of pay changed over time? YES___or NO___ If YES, list the start and end dates during which
you received each pay rate.
Start Date
End Date

12. Have you been paid for all hours worked? YES___ or NO___ If NO, explain.
13. Do you receive one-and-a-half your regular rate of pay when you work more than 8 hours in a day or
40 hours in a week? YES ___ or NO ___
14. Are you paid by check ___, in cash____, or both__?
15. Do you have any pay stubs or receipts? YES ___ or NO ___
16. When is your regular payday? _______________
17. Does your employer provide you with health insurance? YES___ or NO___ If YES, (a) What insurance
company?
(b) Do you have to pay any part of the premium? YES ___ NO___
(c) What date did your coverage begin?
18. Do you receive paid time off (e.g. vacation, holidays, sick leave)? YES or NO
If YES, how many days per year? __________
19. Can you take unpaid time off? YES ___ or NO___
If YES, how many days per year? _____
20. Are you a member of a union? YES or NO If YES,
(a) What is the name of your union local?
(b) Do you have a copy of your collective bargaining agreement (union contract)?
(c) What is the name of your business agent / union rep?
21. Have you ever complained or asked your employer questions about your pay or benefits? YES__ or NO ___If
YES, please provide the date of your inquiry/complaint, the name and title of who you talked to,
and their response:
22. Has your employer ever retaliated against you for raising issues about your pay or benefits? YES___or NO
______If YES, please describe what happened:
23. Do you wish to keep this complaint anonymous (i.e. keep your name confidential from your
employer)?
_ Yes, I want to keep this complaint confidential.
_ No, it is OK for my employer to know I submitted this complaint.
_ It doesnt matter. I dont care if my employer knows that I submitted this complaint
24. How many employees work for your employer? __________

Contracts and Compliance 250 Frank Ogawa Plaza 3rd Floor, (510) 2386258

Page 2

25. What are the names of some of your co-workers? Please provide contact information.
Name

Contact

26. Are there any other witnesses or any other evidence that would help you substantiate your case? (For
example, names of regular customers or delivery drivers, group photographs, etc.)

27. Do you have anything else to add?

I declare under penalty of perjury that the above statement is true and correct to the best of my knowledge.

Employee Signature:

Interviewed by:

Date:

Date:

Organization:

Assigned Compliance Officer: ______________________________

Contracts and Compliance 250 Frank Ogawa Plaza 3rd Floor, (510) 2386258

Page 3

From:
Sent:
To:
Subject:

minwageinfo@oaklandnet.com
C
i
RE: not getting minimum wage
minimumwagecomplaintform.pdf

Please accept my sincere apology for the delay in responding to your email. I earnestly believed a
response had been sent.
Unfortunately, the City cannot render an opinion based on the information in the email
alone. Your situation requires a formal complaint investigation.
Attached is a complaint form. Please complete the form and return to the City as soon as possible.
Thank you,
Shelley Darensburg, Senior Contract Compliance Officer
City of Oakland
Contracts and Compliance Division
Office of the City Administrator
250 Frank H Ogawa Plaza, Suite 3341
Oakland, CA 94612
510-238-6258
510-238-3363 (FAX)
From:
Sent: Sun 3/22/2015 9:43 PM
To: minwageinfo@oaklandnet.com
Subject: not getting minimum wage
I work for Lithograph Reproductions, a print shop in Oakland. My
boss, does not believe the new minimum wage law applies to me, because

In addition, the boss is refusing to pay sick days. One of the press
operators told him that paid sick days are now required, and the boss
said "Not in this shop. You already get too many benefits."
Here are the details of my situation:

Please advise me if I should be getting $12.25 per hour for the

hours I'm required to be at the office.

CITY OF OAKLAND
CITY ADMINISTRATORS OFFICE - CONTRACTS AND COMPLIANCE DIVISION
MINIMUM WAGE: Employee Questionnaire & Declaration in Support of Claim
Employee Name:

Date:

Employee Phone Number:

Business Name:

Employee Email:

Business Phone Number:

Employee Address:

Business Address:

1. Briefly describe why you are submitting this complaint (for example, Im not being paid the required
minimum compensation, Im not receiving sick leave or I am not receiving my service charges from my
employer)

2. What is your position or description of your duties (for example, driver, cook, etc.)? ________________
3. When did you begin to work for this employer? Include the starting date._____________________
4. Are you still employed by this employer? YES ___ or NO ___.
If NO, when was your last day of work? ____________________ and why are you no longer working for
this employer?
5. Who sets your schedule and supervises your work? _________________
6. Do you have records of the hours you work? YES___ or NO___
7. Are you required to record your start and end time? YES ___or NO___
If YES, do you punch in and out on a time clock or do you use a hand-written time sheet/time
card? ______________
If NO, explain how your hours are tracked.
8. List your regular work schedule below. If you punch in and out multiple times during the day, list that
in the space provided.
Monday

Tuesday

Wednesday

Thursday

Friday

Saturday

Sunday

Time In
Time Out
Time In
Time Out
Time In
Time Out

Contracts and Compliance 250 Frank Ogawa Plaza 3rd Floor, (510) 2386258

Page 1

9. If you do not have a regular work schedule each week, how many hours per week do you work, on
average? __________________

10. What is your current rate of pay per hour? _______________

11. Has your rate of pay changed over time? YES___or NO___ If YES, list the start and end dates during which
you received each pay rate.
Start Date
End Date

12. Have you been paid for all hours worked? YES___ or NO___ If NO, explain.
13. Do you receive one-and-a-half your regular rate of pay when you work more than 8 hours in a day or
40 hours in a week? YES ___ or NO ___
14. Are you paid by check ___, in cash____, or both__?
15. Do you have any pay stubs or receipts? YES ___ or NO ___
16. When is your regular payday? _______________
17. Does your employer provide you with health insurance? YES___ or NO___ If YES, (a) What insurance
company?
(b) Do you have to pay any part of the premium? YES ___ NO___
(c) What date did your coverage begin?
18. Do you receive paid time off (e.g. vacation, holidays, sick leave)? YES or NO
If YES, how many days per year? __________
19. Can you take unpaid time off? YES ___ or NO___
If YES, how many days per year? _____
20. Are you a member of a union? YES or NO If YES,
(a) What is the name of your union local?
(b) Do you have a copy of your collective bargaining agreement (union contract)?
(c) What is the name of your business agent / union rep?
21. Have you ever complained or asked your employer questions about your pay or benefits? YES__ or NO ___If
YES, please provide the date of your inquiry/complaint, the name and title of who you talked to,
and their response:
22. Has your employer ever retaliated against you for raising issues about your pay or benefits? YES___or NO
______If YES, please describe what happened:
23. Do you wish to keep this complaint anonymous (i.e. keep your name confidential from your
employer)?
_ Yes, I want to keep this complaint confidential.
_ No, it is OK for my employer to know I submitted this complaint.
_ It doesnt matter. I dont care if my employer knows that I submitted this complaint
24. How many employees work for your employer? __________

Contracts and Compliance 250 Frank Ogawa Plaza 3rd Floor, (510) 2386258

Page 2

25. What are the names of some of your co-workers? Please provide contact information.
Name

Contact

26. Are there any other witnesses or any other evidence that would help you substantiate your case? (For
example, names of regular customers or delivery drivers, group photographs, etc.)

27. Do you have anything else to add?

I declare under penalty of perjury that the above statement is true and correct to the best of my knowledge.

Employee Signature:

Interviewed by:

Date:

Date:

Organization:

Assigned Compliance Officer: ______________________________

Contracts and Compliance 250 Frank Ogawa Plaza 3rd Floor, (510) 2386258

Page 3