Law Office Bush, Ackley, Milich & Hallinan Established 1923 2845 East Hatch Road #22*

The IPM was not a resident of the City during the 2008-2010 Mayoral Term. Respondent disagrees with this finding. In order to qualify for a loan modification for her home, the IPM quit making payments on it in September 2009. In March of 2010, A Notice of Default was filed on the subject property. In August of 2010 the bank took back the home. Beginning in September of 2010, the IPM resided with her mother in the City of Patterson until the completion of her term a few months later. Respondent also disagrees with the finding regarding the alleged gift of public funds in relation to the settlement of a potential lawsuit. The Stanislaus County Grand Jury negligently failed to recognize, or surreptitiously withheld knowledge from the minute reporting on the action item which stated in pertinent part, "The City Council voted 3-2 to reimburse John Ramos $27,101.74 for legal fees incurred in his appeal of the Health Care District zoning issue, subject to verification of cost. These costs were in fact reviewed by the City Council prior to the decision, and later verified by the City Manager and the City Attorney. In addition, Councilmember A within her motion to reimburse stipulated that the claimant sign a waiver to cease all legal action against the city related to the matter.

Between 2008 and 2010, the IPM was not in compliance with AB 1234 Ethics Training. Respondent agrees with this finding. However, Councilmember's C or D also did not comply with his/her AB 1234 training. The Grand Jury requested and received validation of this fact, and chose to ignore their own discovery. This selective prosecution of the IPM by the Grand Jury taints the entire report. LAW OFFICE <b>BUSH, ACKLEY, MILICH & HALLINAN</b> ESTABLISHED 1923 2845 EAST HATCH ROAD #22 MODESTO, CALIFORNIA 95351 LEO MILCH 1948-1997 DAVID F.BUSH 1923-1955 209-324-6205 THOMAS N. HALLINAN 1966-2006 <b>GEORGE H. ACKLEY 1935-1975</b> HARTLEY H. BUSH 1954-1995 tompathallinan@gmail.com THOMAS P. HALLINAN 1994-PRESENT – Patterson 2010/2011 Grand Jury Response

Violations of the Patterson Municipal Code/City Council Handbook. Failure to follow proper chain of command as it relates to approaching city employees to request information, expedite permit processes, manipulate city policy, and request the waiver of fees owed to the city. Respondent disagrees with this finding which is redundant with the alleged violation set forth immediately below. Regarding the other allegations, the IPM insists that although questions may have been asked, no pressure for improper action was ever exerted. The IPM signed a letter authored by a business owner who was in the process of obtaining a conditional use permit. Respondent disagrees with the allegation that the IPM attempted to represent the entire council regarding the letter she signed in support of the subject business. When the process for the business was stopped, the IPM did not intervene on behalf of either the entire council or as an individual member. The IPM was instrumental in the resignations of the IPCM and the CDD. Respondent disagrees with this finding. The IPCM and the CDD voluntarily resigned and have since secured other employment. RECOMMENDATIONS

In the Stanislaus County Civil Grand Jury's opinion, the vote by the City of Patterson's City Council to provide the gift of public funds to the landlord/developer was invalid. Respondent disagrees with this finding. Firstly, this finding is a conclusionary redundancy. Secondly, it is an invalid assumption based upon the responses to the findings previously set forth in this document. RECOMMENDATIONS