Number
101025
Version
SUBSTITUTE 2
Reference
Sponsor
ALD. PUENTE
Title
A substitute ordinance implementing recommendations of the private alarm systems task force.
Sections
81-2-0 rc
81-2-2 rc
81-2-3 rc
81-2-4 rc
105-75-2 rc
105-75-3-a am
105-75-3-b-0 am
105-75-3-b-2 am
105-75-3-b-8 rc
105-75-3-d am
105-75-4-b am
105-75-5 am
105-75-8-d-1 am
105-75-8-d-4 rp
105-75-8-d-4 am
105-75-8-d-5 rn
105-75-8-d-5 am
105-75-8-d-6 rn
105-75-8-d-7 rn
105-75-8-e cr
105-75-11 rc
105-75-12 rp
105-75-13 am
105-75-14 rc
105-75-15 rc
200-33-12-a-4 cr
200-33-12-a-5 cr
200-33-12-a-6 cr
200-33-12-a-7 cr
222-11-1-0 am
222-11-1-d cr
222-11-1-e cr
222-11-1-f cr
222-11-1-g cr
222-11-4-d cr
222-11-4-e cr
222-11-4-f cr
222-11-5-e rn
222-11-5-e cr
222-11-5-f cr
222-11-5-g cr
222-11-5-h cr
Analysis
This ordinance codifies and implements recommendations of the Private Alarm Systems Task Force contained in its final report to the Common Council (File #091421, placed on file on July 27, 2010).
This ordinance requires that sales of alarm systems are:
1. Made with a separate additional license for businesses that engage in sales activities.
2. Conducted by register and trained salespersons displaying identification badges.
3. Made by written contracts containing clear language and full disclosure of costs.
4. Accompanied by an informational brochure including information about the penalties for false alarms.
The ordinance authorizes installation of alarm systems by persons licensed under one or more new low-voltage license categories with an initial annual license fee of $228.
The ordinance also requires that first responder services:
1. Obtain a separate license.
2. Employ individuals as first responders who have a state "Security Person" permit.
The ordinance provides definitions for verified response, false alarms and prohibited alarm systems and new penalties for non-verified responses and false alarms.
In addition, the ordinance establishes:
1. Fees of $450 for an initial 2-year license for an alarm business, an alarm sales business and a first responder service.
2. Graduated penalties for multiple violations of the ordinance.
Body
The Mayor and Common Council of the City of Milwaukee do ordain as follows:
Part 1. Section 81-2-0, 2 to 4 of the code is repealed and recreated to read:
81-2. Alarm Licenses.
2. a. The fee for each alarm business or private first responder service license shall be $300.
b. The fee for an alarm sales license shall be $450.
3. License renewal applications shall be filed on or before a date to be established by the city clerk. There shall be an additional fee of $75 for the filing of a late renewal application.
4. a. If an applicant for an alarm business license or a private first responder service license is not granted the license, a portion of the license fee shall, upon written request, be returned to the applicant in the amount of $125.
b. If an applicant for an alarm sales license is not granted a license, a portion of the license fee shall, upon written request, be returned to the applicant in the amount of $225.
Part 2. Section 105-75-2 of the code is repealed and recreated to read::
105-75. Private Alarm Systems and Regulations.
2. DEFINITIONS. In this section:
a. "Alarm business" means any person engaged in providing, selling, leasing, renting, installing, monitoring, servicing, altering, moving or causing any alarm system to be sold, installed, monitored, serviced or altered in or on any other person's building, place of business, structure, residence or other facility for compensation. Excluded from this definition is any person engaged solely in the business of designing the system for the location.
b. "Alarm monitoring service" means any person that provides service to alarm users by receiving signals, at a central station or other site, from an alarm system or systems that indicate an activation of a fire, burglary or robbery alarm, notifies or dispatches alarm representatives or a first responder service to alarm sites or reviews appropriate real-time electronic or other verification, and relays alarm messages to fire or police departments. An alarm monitoring service may be located within the state of Wisconsin or at locations outside this state. An alarm monitoring service does not include monitoring of any person's own business or residential alarm.
c. "Alarm representative" means any person employed or contracted by an alarm business or monitoring service whose duties include the altering, installing, maintaining, repairing, servicing, monitoring or responding to an alarm system.
d. "Alarm sales" means activities related to marketing and sales, rental or leasing of alarm systems, alarm systems installation, and maintenance intended for residential or business alarm users. Alarm sales activities include the distribution of product and service information to members of the public by electronic, telephonic, broadcast, signage, posting of printed material or other written means and include oral information provided door-to-door or otherwise. Excluded from this definition are retail establishment sales of alarm system hardware to on-site customers and who provide no other alarm system services with the exception of equipment warranty coverage.
e. "Alarm sales personnel" means that person or those persons employed by, contracted by, or otherwise engaged in the sale, rental or leasing of alarm systems within the city. "Alarm sales personnel" does not mean a person or persons employed or contracted by a retail establishment to assist customers in on-site sale of alarm system hardware and selling no other alarm system services with the exception of equipment warranty coverage. "Alarm sales personnel" does not mean any person or persons engaged in the preparation or design of marketing or sales information or materials and not engaged in other alarm system sales activities.
f. "Alarm system" means any mechanical or electrical equipment arranged to signal the occurrence of a fire, burglary or robbery alarm requiring immediate fire or police department notification, including local alarms which are audible or visible upon the exterior of a structure.
g. "Alarm user" means the person in control of any building, structure or facility or portion thereof in which an alarm system is in operation.
h. "False alarm" means an alarm notification summoning a city agency to the location of an alarm activation, when the responding officer finds no indication of burglary, attempted burglary, robbery, attempted robbery or fire. "False alarm" does not include an alarm activation signal caused by extraordinary conditions of weather such as high winds, thunder and lightning storms or other systemic electric disturbances.
i. "Falsely verified alarm" means a verified alarm in which the police responded and determined the alarm to be a false alarm.
j. "Local alarm system" means any equipment arranged to signal the occurrence of a robbery or burglary with alarms from the premises in the immediate area of the structure.
k. "Non-verified alarm" means an alarm which has not been verified by a person or private first responder.
L. "Person" means an individual, firm, partnership, association, corporation or any other business entity with the exception of any government agency, government employes or individuals acting in the course of government business.
m. "Private first responder service" means a service provided by an alarm business, either through an alarm representative or through a private security company under contract with the business, that determines, by means of on-site inspection, whether a cause for alarm has occurred at the site of an activated burglary alarm. Excluded from the definition of private first responder service are those services or personnel directly employed or contracted by businesses to respond to their own alarm systems.
n. "Prompt dispatch" means that the arrival at the alarm site of an alarm representative for verifying the alarm occurs within 30 minutes of alarm activation in the absence of unanticipated or extraordinary circumstances.
o. "Verified alarm" means an alarm that a person or private first responder has determined is not a false alarm prior to contacting the police department.
Part 3. Section 105-75-3-a of the code is amended to read:
3. LICENSE REQUIRED. a. No alarm business>>, alarm sales business or private first responder service<< shall engage in business without first [[applying for and receiving]] >>obtaining<< an alarm business license.
Part 4. Section 105-75-3-b-0 and 2 of the code is amended to read:
b. Application for an alarm business license>>, private first responder service license or for an alarm sales license<< shall be filed with the city clerk on a form provided therefore. The application shall be signed by the applicant, if an individual, or by a duly authorized agent or officer of a corporation or limited liability company>> or by the duly authorized agent of the club, association or other organization<<, and sworn to by the applicant. >>An agent shall be a natural person.<<The application shall require:
b-2. The name of the alarm business>>, the alarm sales business, or the private first responder service<<.
Part 5. Section 105-75-3-b-8 of the code is repealed and recreated to read:
b-8. If the applicant is an alarm business or alarm sales business, a detailed plan of operation that includes the following information:
b-8-a. Identification of any subcontracting or cooperating business that provides or will provide services related to alarm systems installed or to be installed within the city, including monitoring services, private first responder services, repair and maintenance services, together with contact information for each. All private first responder services identified under this section, whether or not licensed, shall comply with the verified response requirements of sub. 14-c-4.
b-8-b. Information identifying operations managers or supervisors with oversight of alarm system sales, installation and monitoring of private alarm systems or oversight of private alarm systems response activities within the city including phone numbers, fax numbers, and electronic mail addresses.
b-8-c. A statement detailing the manner in which alarm sales activities will be conducted and certification that all alarm sales personnel will receive a minimum of 14 hours training within the first 2 weeks of employment in sales activities.
b-8-d. If the application is for an alarm sales business license, a certification that a list of alarm sales personnel will be registered with the city clerk and updated within 10 days of employment of any additional alarm sales personnel and within 10 days of the termination of sales activities by any person previously registered as a salesperson.
b-8-e. A certification that photographs of alarm sales personnel will be submitted to the city clerk promptly upon engagement of alarm sales personnel in sales activities.
b-8-f. A list of any additional services provided to alarm users or subscribers which shall be updated within 10 days of any change in service subcontractor.
b-8-g. If a private first responder service is provided either directly or by subcontract, a statement whether prompt dispatch is guaranteed.
b-8-h. A statement whether the applicant will accept service of process or other notice by first class mail and providing the address for receipt of first class mail.
Part 6. Section 105-75-3-d of the code is amended to read:
d. All applicants shall be fingerprinted. If the applicant is a corporation, the agent shall be fingerprinted. If the applicant is a partnership, each partner >> and agent shall be
fingerprinted. If the applicant is a club, association or other organization, the agent << shall be fingerprinted. This requirement shall not apply to a person already licensed by the city when that person is renewing the license. The fingerprinting requirement shall also not apply to the officers and directors of nonprofit corporations which apply for a license, except that the fingerprinting requirement shall apply to the agent of such corporations. If a set of fingerprints is on file with the police department, an additional set shall not be required unless expressly requested by the police department for purposes of verification.
Part 7. Section 105-75-4-b of the code is amended to read:
b. Whenever an alarm business changes any of its corporate officers, directors or agents, the corporation shall file the appropriate application and pay the fee required [[by ch. 81]]>>in s. 81-2-5<<.This application shall [[in all respects be treated]]>>be completed and processed in the same manner<< as a new application subject to all the requirements of this section.
Part 8. Section 105-75-5 of the code is amended to read:
5. FEE. All applications >>for alarm business licenses, alarm sales licenses and private first responder service licenses<< shall be accompanied by the fee specified in s. 81-2.
Part 9. Section 105-75-8-d-1 of the code is amended to read:
8. PROCEDURES FOR NONRENEWAL, SUSPENSION OR REVOCATION.
d. Grounds for Nonrenewal or Revocation.
d-1. Failure of the licensee to meet the municipal qualifications >>, including failure to comply with the plan of operation submitted by the licensee as a part of the license application as it may be amended and including compliance with the requirement to timely report changes in the licensee's plan of operation and changes in the licensee's address for receipt of first-class mail.<<
Part 10. Section 105-75-8-d-4 of the code is repealed.
Part 11. Section 105-75-8-d-5 to 7 of the code is renumbered 105-75-8-d-4 to 6.
Part 12. Section 105-75-8-d-4 and 5 of the code is amended to read:
d-4. Failure of a licensee to obtain, in the case of a burglary alarm, a verified response that [[an attempted or actual crime]]>>a cause for alarm<< has occurred at the alarm site before [[the alarm signal is transmitted to the police department]] >>transmitting the alarm signal or information about the alarm signal to a city agency<<.
d-5. Failure to provide a private first responder service, as required by sub. [[14-f]]
>>14-c-4<<.
Part 13. Section 105-75-8-e of the code is created to read:
e. Licenses to be Treated Separately. A recommendation by the committee that an alarm business license, alarm sales license or a private first responder service license be suspended, revoked or not renewed shall not be based on any adverse recommendation relating to a license separately held by the applicant or licensee. Nothing in this paragraph shall prohibit or limit the discretion of the committee in considering any related business activities of an applicant or licensee in making the committee's recommendation to the common council.
Part 14. Section 105-75-11 of the code is repealed and recreated to read:
11. PROHIBITED SYSTEMS.
a. Automated Alarm Notification Prohibited. No person may use or operate, attempt to use or operate, or cause to be used or operated, or arrange, adjust, program or otherwise provide or install any alarm system that upon activation will initiate, transmit, or deliver an alarm notification to any city agency by automated means except for fire alarms.
b. Panic Alarm Notification Prohibited. No person may initiate, transmit, or deliver an alarm notification in the nature of a panic alert, police alert, medical alert or disturbance alert to any city agency by automated means, electronic or telephonic means, or other miscellaneous signal or message as distinguished from burglary, robbery (hold-up) or fire alarms.
c. Multiple Trip Sensor and Audio Sensor Notification Prohibited. No person may initiate, transmit, or deliver by automatic means, electronic or telephonic means, any request for service to any city agency based upon multiple trip sensors or audio sensors.
d. Exception. d-1. A request for service may be made to any city agency based upon a recorded and reproducible video or 2-way voice intercom by any person able to provide specific information based upon personal observation to the operator, dispatch personnel or officer of a city agency and able to respond to questions of the operator, dispatch personnel or officer to support a conclusion that there exists a cause for alarm or an emergency is in progress. Communications made to a city agency under this paragraph shall be treated as a reported incident and not as an alarm requiring verification by a first responder service.
d-2. Any recordings relating to reproducible video or 2-way voice intercom shall be provided to the police department within 24 hours and submitted as an e-mail attachment sent to a police Internet site or in such other manner as otherwise directed by the police department. Electronic files submitted under this subdivision shall be in a standard format designated by the department.
Part 15. Section 105-75-12 of the code is repealed.
Part 16. Section 105-75-13 of the code is amended to read:
13. ALARM MONITORING SERVICE. a. Any alarm monitoring service providing the service of receiving burglary, robbery or fire alarm messages from alarm systems and relaying alarm information to [[the fire or police department]]>>a city agency<< shall have trained employes on duty at all times. In the case of an activated burglary alarm, the alarm monitoring service shall relay the message to the police department only after the monitoring service's private first responder service has verified that [[an attempted or actual crime has occurred]]>>a cause for alarm exists<< at the alarm site. An alarm monitoring service shall provide pertinent information to the department at the time of telephone notification of the activation of any alarm, which shall include:
a-1. The alarm user name, address location of the activated alarm, identification of the type of alarm signal and telephone number of the alarm user.
a-2. The name and address of the alarm business or agent which has the responsibility for the alarm system activation.
b. Any [[alarm monitoring service]]>>business which maintains keys to the alarm site<< shall >>promptly dispatch<<[[provide the prompt notification of]] an alarm [[user]] representative >>with keys to the alarm site<< [[to the location of each alarm transmitted to the fire or police department, ]]upon request of the responding department.
c. [[Those alarm businesses]]>>An alarm business<< which [[do]]>>does<< not maintain keys to the premises shall operate in the following manner:
c-1. Notification to the fire or police department shall include notice that the alarm business does not maintain keys to the [[premises]]>>alarm site<< and will not arrive at the scene while the department is present.
c-2. [[Those alarm businesses]]>>The alarm business<< shall file a report with the responding department within 72 hours of the occurrence which shall include:
c-2-a. [[Company]]>>Alarm business<< name and address.
c-2-b. [[User]]>>Alarm user<< name and address, and telephone numbers.
c-2-c. Time of occurrence reported to the alarm business and time relayed to the department.
c-2-d. Cause of alarm, if known.
c-2-e. Action taken by alarm business.
c-3. An alarm business which does not maintain keys to the [[premises]]>>alarm site<< shall not be exempt from the requirement of par. a to obtain, in the case of a burglary alarm, a verified response that an attempted or actual crime has occurred before relaying the message to the police department.
Part 17. Section 105-75-14 and 15 of the code is repealed and recreated to read:
14. ALARM SALES AND ALARM BUSINESS REQUIREMENTS.
a. A business engaged in alarm sales activities shall:
a-1. Provide the city clerk with the name, address and an electronic file containing an accurate depiction of the photo-identification badge for alarm sales personnel prior to the conduct of any sales activities by that alarm sales personnel.
a-2. Require all alarm sales personnel to complete 14 hours of sales training within 2 weeks of first engaging in alarm sales activities on behalf of the alarm sales licensee.
a-3. Require that no person employed with or on behalf of the alarm sales licensee engage in sales activities with any prospective alarm user prior to completion of 14 hours of sales training except in the direct presence of a registered sales personnel who has received a minimum of 14 hours of sales training.
a-4. Require that all alarm sales personnel display photo-identification badges that include the names of the sales persons, the names of the alarm sales business, and the names of the alarm business, if different. Photo-identification badges shall also prominently display telephone contact information for the alarm sales business licensee.
b. All contracts with alarm users shall:
b-1. Be in writing and identify the services to be provided by the licensee. A copy of contracts proposed for alarm sale, installation, maintenance, monitoring, responder and any other alarm services shall be written in plain language with key points in bold or 10-point font. Failure of the applicant or licensee to provide an accurate copy of proposed contracts meeting these specifications shall be subject to the penalties provided in sub. 15-d.
b-2. Be presented to prospective individual customers together with a pamphlet or other written information, prepared or approved by the city clerk, that includes a statement of rights and responsibilities of alarm users.
b-3. State that, after a city agency is notified of 2 false alarms within a calendar year, the alarm user is subject to municipal citation as provided in sub. 15.
b-4. Include, at the time of renewal, a written statement of the provisions of subd. 3 together with a written statement of any changes in the terms of service or the identity of service providers from the original or most recently renewed contract.
c. An alarm business shall: c-1. Be responsible for the proper installation of alarm systems by persons licensed under s. 222-11.
c-2. Be responsible for insuring that private alarm systems under maintenance contracts are maintained in good working order and that defects which could cause false alarms are promptly repaired.
c-3. Instruct appropriate personnel as to the operation of private alarm systems, including the setting, activation or resetting of the alarm equipment.
c-4. Provide a private first responder service, unless the alarm system transmits the alarm signal as provided in sub. 11-d, that shall verify, in the case of an activated burglary alarm, that a cause for alarm exists at the alarm site before the alarm signal is transmitted to the police department; any person employed by a first responder service who engages in on-site verification shall hold a valid state private security person permit issued by the Wisconsin department of regulation and licensing.
c-5. In the case of an activated burglary alarm, relay the message to the police department only after a private first responder service has verified that a cause for alarm exists at the alarm site.
15. PENALTIES. a. No alarm user shall cause or permit a city agency to be notified of a false alarm. If after a city agency is notified of 2 false alarms within a calendar year, the alarm user shall be subject to a forfeiture of not less than $50 nor more than $100 for the first false alarm thereafter. Subsequent false alarms shall be subject to a forfeiture of not less than $100 nor more than $250.
b. No alarm business shall cause or permit a city agency to be notified of a non-verified alarm. An alarm business shall be subject to a forfeiture of not less than $50 nor more than $100 for the first non-verified alarm. Subsequent notification of non-verified alarms at the same site within 2 years of the first offense shall subject the alarm business to a forfeiture of not less than $100 nor more than $250.
c. Any violation of sub. 11-b or c is subject to a forfeiture of not less than $100 nor more than $200 for a first offense and not less than $200 nor more than $400 for each subsequent offense occurring at a single site or caused by a single alarm or sensor within 5 years of any prior offense.
d. Except as otherwise provided in this section, any person violating any provision of this section shall upon conviction forfeit not less than $100 nor more than $500, together with the costs of prosecution.
Part 18. Section 200-33-12-a-4 to 7 is created to read:
200-33. Fees.
12. ELECTRICAL LICENSES.
a-4. Type LB Low-Voltage License.
a-4-a. Original license: $228.
a-4-b. Renewal: $114, (renewable each year before August 31.)
a-5. Type LF Low-Voltage License.
a-5-a. Original license: 228.
a-5-b. Renewal: $114, (renewable each year before August 31.)
a-6. Type LV Low-Voltage License.
a-6-a. Original license: $228.
a-6-b. Renewal: $114, (renewable each year before August 31.)
a-7. Multiple Low-Voltage Licenses.
a-7-a. For a second or third low-voltage license under subpars. a-4 to a-6, held concurrently, original license: $114.
a-7-b. For a second or third low-voltage license under subpars. a-4 to a-6, held concurrently, renewal license: $67.
Part 19. Section 222-11-1-0 of the code is amended to read:
222-11. Electrical Licenses. 1. TYPES. There are established [[3]]>>6<< types of electrical licenses as follows:
Part 20. Section 222-11-1-d to g of the code is created to read:
d. Type LB low-voltage (100 volts or less) burglar and security alarm system contractor's license. This license authorizes the holder to obtain low-voltage burglar and security alarm system permits for work regulated by this chapter.
e. Type LF low-voltage (100 volts or less) fire alarm system contractor's license. This license authorizes the holder to obtain low-voltage fire alarm system permits for work regulated by this chapter.
f. Type LV low-voltage (100 volts or less) contractor's license. This license authorizes the holder to obtain low-voltage permits for low-voltage electrical work not including the installation of a fire alarm system or burglar and security alarm system work regulated by this chapter.
g. Any burglar or security alarm system installation conducted under a permit obtained by a Type LB or Type LV low-voltage licensee shall be performed by persons holding a minimum of Electronic Security Association-National Training School (NTS) Level I certification or equivalent determined by the commissioner.
Part 21. Section 222-11-4-d to f of the code is created to read:
4. QUALIFICTIONS FOR LICENSES.
d. Type LB License. An applicant for a Type LB low-voltage (100 volts or less) burglar and security alarm system contractor's license or renewal thereof shall submit an affidavit to the effect that a person holding NTS Level II certification will be a bona fide full-time employe of the applicant, and that the NTS Level II certificate holder will have complete and unquestionable authority and supervision over all work regulated by this chapter. The Type LB license holder shall insure that all work related to the installation of the burglar or security alarm system conducted under the license shall be performed by persons holding a minimum of NTS Level I Certification or equivalent as determined by the commissioner.
e. Type LF License. An applicant for a Type LF low-voltage (100 volts or less) fire alarm system contractor's license or renewal thereof shall submit an affidavit to the effect that a person holding NICET (National Institute for Certification in Engineering Technologies) Level II Fire Alarm Systems certification or equivalent will be a bona fide full-time employe of the applicant, and that the NICET Level II Fire Alarm System certificate holder will have complete and unquestionable authority and supervision over all work regulated by this chapter. The Type LF license holder shall insure that all work related to the installation of the fire alarm system conducted under the license shall be performed by persons holding a minimum of NICET Level I Fire Alarm Systems Certification or equivalent as determined by the commissioner.
f. Type LV License. An applicant for a Type LV low-voltage (100 volts or less) contractor's license or renewal thereof shall submit an affidavit to the effect that the person holding the license will have complete and unquestionable authority and supervision over all work regulated by this chapter.
Part 22. Section 222-11-5-e of the code is renumbered 222-11-5-i.
Part 23. Section 222-11-5-e to h of the code is created to read:
5. LICENSING PROCEDURE.
e. Type LB License. The commissioner shall review and approve or disapprove the license or license renewal application. In the case of approval, the commissioner shall issue a Type LB low voltage (100 volts or less) burglar and security alarm system contractor license permitting the licensee to install, alter, repair, remove, renew, replace, disturb, connect, disconnect or maintain any low-voltage electrical equipment associated with a burglar and security alarm system and accept payment for any of these activities. Before the license or renewal is issued, the applicant shall have on file with the commissioner a certificate of insurance as required in sub. 11 and pay the license fee provided under s. 200-33-12.
f. Type LF License. The commissioner shall review and approve or disapprove the license or license renewal application. In the case of approval, the commissioner shall issue a Type LF low-voltage (100 volts or less) fire alarm system contractor license permitting the licensee to install, alter, repair, remove, renew, replace, disturb, connect, disconnect or maintain any low-voltage electrical equipment associated with a fire alarm system and accept payment for any of these activities. Before the license or renewal is issued, the applicant shall have on file with the commissioner a certificate of insurance as required in sub. 11 and pay the license fee provided under s. 200-33-12.
g. Type LV License. The commissioner shall review and approve or disapprove the license or license renewal application. In the case of approval, the commissioner shall issue a Type LV low-voltage (100 volts or less) contractor license permitting the licensee to install, alter, repair, remove, renew, replace, disturb, connect, disconnect or maintain any low-voltage electrical equipment except for fire alarm systems and burglar and security alarm system and accept payment for any of these activities. Before the license or renewal is issued, the applicant shall have on file with the commissioner a certificate of insurance as required in sub. 11 and pay the license fee provided under
s. 200-33-12.
h. Multiple Low-voltage Licenses. If application is made for more than one license to be held concurrently by the same licensee under pars. e to g, then the licensee shall pay the fees provided in s. 200-33-12-a-7.
Part 24. This ordinance takes effect June 1, 2011.
LRB
APPROVED AS TO FORM
____________________________
Legislative Reference Bureau
Date: ______________________
Attorney
IT IS OUR OPINION THAT THE ORDINANCE
IS LEGAL AND ENFORCEABLE
____________________________
Office of the City Attorney
Date: ______________________
Requestor
Drafter
LRB123542-13
Richard L. Withers
4/11/2011