Attachment C
Workers' Compensation Alternative Dispute Resolution Labor- Management Agreement between the City of Pasadena and the Pasadena Police Lietenants Association
City of Pasadena and Pasadena Police Lieutenants'
Association (PPLA)
Workers' Compensation Alternative Dispute
Prevention and Resolution Program
Agreement
This Workers' Compensation Alternative Dispute Prevention and Resolu- tion Agreement ("Agreement) is entered into by and between the City of Pasa- dena (City) and the Pasadena Police Lieutenants Association (PPLA)on behalf of its represented members, pursuantto the authority granted to the parties in Cali- torn ia Labor Code section 3201 .7.
RECITALS
Whereas, the parties are desirous of entering into an agreement whereby repre- sented employee members ofPPLAwill receive benefits and resolve all dis- putes for claims arising under Division 4 the California Labor Code ("Workers' Compensation Law") pursuant to the process and procedures authorized under California Labor Code section 3201.7; and,
Whereas, the parties intend that this Agreement not diminish statutorily guar- anteed rights of employees or the City; erode or impairthe rights of individual employees to compensation payments for total or partial disability, supple- mental job displacement benefits, medical treatment and any other benefits as may be required by California law; and
The purpose of this Agreement is to provide a mechanism under Labor Code Section 3201.7 to provide timely and efficient medical treatment to employees who have sustained work-related injuries and to hasten their return to work where possible.
It is the intentof ttie parties to this Agreement to constizict an alternative dispute resolution program ("ADR program") authorized by California law which will pro- vide that those injured PPLA active members, covered by this Agreement, who
claim to have sustained injuries or illnesses compensablepursuantto the Work- ers' Compensation laws of the State of California with:
a) timely and efficient determination of claims status; b) timely and efficient access to high quality medical care; c) the best opportunity reasonably possible to return to work in a timely fash- ion;
d) an alternative dispute resolution program that provides the best oppor- tunity reasonably possible to:
1. promote theefficient,timelyandfairresolutionofalldisputesthatdo arise in the processing of claims, including, but not limited to the compensability of claims within the jurisdiction of this program; and
2. prevent disputes, and reduce the frequency and severity of those disputes that do arise, that otherwise delay freatment, atimely return to work and the ultimate resolution of the claim.
e) provide the foregoing on a stable and long-term basis.
The parties intend that this Agreement will not:
a) diminish, erode or impair the rights of the City or of individual retirees or active employees to compensation payments for total or partial disability, supplemental job displacement benefits, medical treatment, and any other benefits as required by California law to be fully paid for by the City; or b) impair, restrict or condition the rights of the City or of a retired or active em- ployee member to be represented by legal counsel of their choosing throughout the entire alternative dispute resolution program; or c) impair, restrict or condition the rights of the City or of a retired or active em- ployee to pursue legal remedies and appeals after exhausting the altema- tive dispute resolution program procedures as allowed under the Labor Code.
TTie parties further intend friat this Agreement create and accommodate an en- hanced method to provide Workers' Compensation benefitsin a way th at improves labor managementrelationships, efficiencies of benefitto all parties andorganiza-
tional effectiveness. The parties also recognize that there will be certain Depart- mental and City efficiencies associated with the implementation ofthisAgreement.
Such efficiencies shall be recognized by the parties through ongoing communica- tion, participation and assessment of the effectiveness of the alternative dispute resolution program.
It is agreed that the parties will make every good faith effort to apply the terms of this Agreement consistent with the intent of the parties as expressed above.
1. General Provision
1.1 Th is Agreement shall become effective on the issuance of a recognition letter by frie Administrative Director of the Division of Workers' Compensation of the Department of Industrial Relations and is subjectto approval of the City Coundl of the City of Pasadena, PPLA and the California Departmentof Industrial Relations.
The Agreementshall remain in effectfor at least one year from the date of execu- U'on, continuing yearto year thereafter, unless terminated by one of the parties by giving sixty (60) days written notice to the other party. Unless otherwise specifically noted in'th is Agreement, any reference to "days" shall mean calendar days not working days. Should this program be terminated it is the intentofthe parties that those claims (including cumulative injuries thatallegedly began before the Agree- ment butthe claim was not filed until after the Agreementwas in effect) with dates of injury or illness occurring during the period of the program, or in the case of a cumulative trauma claim where the date of injury began within 365 days of the date of termination of th is agreement, or those claims which have been submitted pursuanttothe "opt in" provision of Section 1.3(b) shall continue to be covered by the terms of this Agreement. Regardless of the effective date of this Agreement, the formal jurisdiction of this program shall commence on a date agreed upon by the Joint Committee ("JC") and reduced to writing in a memorandum issued by the JC to the City and PPLA.
1.2. This Agreement shall constitute the complete understanding of the parties with regard to the issues addressed herein. Nothing in th is Agreement shall be con- sidered or construed as a modification of the substantive provisions of California Workers' Compensation Law except as specifically set forth herein in accordance
with Labor Code section 3201 .7 or any rules adopted pursuant to this Agreement.
1.3. As to all claims with dates of injury on or after the effective date of this ADR program, as agreed to by the City and PPLA, itis the intentofthe parties to replace all dispute resolution procedures set forth in the California Labor Code with those dispute resolution procedures outlined herein tothe greatest extentallowed by law.
In any conflict, the provisions of this Agreement shall take precedence over the provisions of the California Labor Code, but only so far as permitted by Labor Code section 3201.7.
a) All injuries filed by PPLA members on or after the effective date of this agreement shall adhere to its provisions.
b) Any active employee with an active or pending claim filed with the WCAB before the effective date of this ADR program may be permitted to "opt in" to the ADR program. On a case-by-case basis, and upon written request by the active employee to the City and the ADR Director of the intentto participate in the ADR program, the ADR Director shall take all necessary and appropriate steps to evaluate the feasibility of ta'ansitioning the previouslyfiledclaim(s) and proceedings to the ADR program. As a condition of the employee participating in the ADR pro- gram, the Joint Committee shall establish conditions and requirements for partici- pation, including but notlimited to dismissing any and all pending applications with theWCAB (see Section 2.8), executing written acknowledgements of the terms of this ADR Agreement and waivers of certain procedural Workers' Compensat'on rights. TheADR Director shall make recommendation s to the Joint Committee as to whether a previously filed claim shall be accepted into the ADR program.
Tills Agreement is notintendedto diminish anyrightto compensation thatinjunsd employees or the City as the employer are entitled to under the Workers' Com- pensation laws of the State of California. The parties acknowledge that no retired or active employee covered by this Agreement or the program established herein will lose or compromise any rights to Labor Code section 4850 pay, any presump- tions allowed by California Law, or any other substantive right allowed by law.
1.4. The terms of this Agreement shall apply only to City employees, represented by PPLA. It is the parties' intention thatthis Agreement will be implemented as a
pilot program, subject to penodic review and modification. The parties anticipate that this ADR program will result in savings to the City, which shall be used to per- petiate to costs of the program.
1.5 This Agreement shall apply only to injuries or illnesses compensable oral- leged to be compensable under the Workers' Compensation laws of the State of California, including all claims, defenses, and lien claims. Further, this Agreement applies to injuries, as defined by Waiters' Compensation Law, claimed by 1)ac- tive employees; 2) retirees who, while active employees, made a claim alleging injury or illness; 3) retirees who, while active employees, made a report, con- sistentwith Department policy, of an industrial incidentthat may lead to injury or illness; 4) retirees, who were active employees on or after the effective date of this Agreement, and claim a new presumptive injury as defined by Labor Code section 3212, et seq.; and 5) any retiree or active employee who "opts in" to the ADR program pursuant to Section 1 .3(b) above. Subject to the "opt in" provisions of Section 1.3(b), this Agreement does not cover post-retirement amendments to claims filed prior to the term of the Agreement. This Agreement does not currently apply to any other retired employees. Discrimination claims filed under section 132a and Serious and Willful Misconduct claims filed under section 4551 etseq. may be litigated only within the program by the written agreement of the injured member/employee and the City.
1.6. The City may delegate to its third-party administrator (TPA") the perfor- mance of its obligations under th is Agreement, but it may not relieve itself of the legal responsibility for those obligations.
1.7. Committee
This Agreement establishes a Joint Committee ("JC") which holds the exclusive authority to administer th eADR program; including but not limited to the authority to enforce the terms of the Agreement, establish policies, manage the implemen- tation of the ADR program, promulgate and modify any mles of the program. The JC shall be made up of three (3) members selected by PPLA and three (3) mem- bers selected by the City. The JC shall meet as it deems necessary, but no less than once each month for the first six (6) months from the date of this Agreement,
and quarterly thereafter. The JC will establish rules and procedures to guide the internal governance of the JC. The meetings shall be held at a location agreed upon by both parties. An agenda of each meeting shall be provided to all mem- bers of the JC at least one(1) week prior to the meeting date. Any disputes that arise between the members of the JC where action must be taken to administer the Program and cannot be resolved, shall be submitted to a three member "Dis- pute Resolution Committee" comprised of the ADR Director, and one JC member each from PPLA and the City. Any two members shall be authorized to seek reso- lution of a dispute by the Dispute Resolution Committee upon impasse. The Dis- pute Resolution Committee is to be guided by the terms of this Agreement and authorized to interpret this Agreement but not create additional terms. Unless agreed by the parties, any meetings of the Dispute Resolution Committee shall be scheduled within sixty (60) days and a decision issued thirty (30) days after sub- mission.
A. The Joint Committee shall engage the services of an actuarial consultant to annually track the costs and savings of the program. The first actuar- ial evaluation will be after three (3) full years from the start of the Carve Out Program, to allow for sufficient capturing of data.
B. Each program year shall be July 1 to JuneSO. Followingthe initial actuarial evaluation, at the end of each subsequent program year (i.e., June 30), the actuary will calculate a number of claims ex- perience statistics and other pertinent data and compare the results of a program year or years under the agreement to the average of the three prior program years' experience for em- ployees represented by the PPLA; TTie objective of this compari- son isto identify the amount of savings, net of program expenses, that have been produced after implementation of the carve out program created by the ADR Agreement. TTie Parties shall evalu- ate the methodology and manner of calculating the savings on an ongoing basis.
C. The calculation of savings as identified in Section 4 shall also con-
template savings from any reduction of overtime incurred by the Po- lice Department as a result of the program. The City will provide the Joint Committee the baseline data and supporting documentation to calculate the overtime costs for the 3-years prior to the commence- ment of the program. TTie actuarial consultant will calculate that sav- ings as part of its responsibility. The Parties will continue to evaluate the manner by which the overtime savings shall be calculated.
D. The City and the claims administrator will provide all necessary claims and statistical information to the actuary and Joint Committee no later than September 1 of each year following the program year. The City may perform a data check to insure the information transmitted to the actuary is without error. If the City finds errors it will instruct the City and/orthird-party administrator to make the necessary corrections and advise the Joint Committee accordingly. All of the prior history. statisti- cat data and claims information related to the members of PPLA that may be provided to the actuary, shall also be provided to the Joint Committee. The Parties will provide claims and statistical information to the actuary on an ongoing basis and all such information shall also be provided to the Joint Committee.
1.8. If any provision of th is Agreement or its application is held invalid, the inva- liditywill not affect other provisions or applications of this Agreement that can be given withoutthe invalid provisions or applications, and thus the provisions of this Agreement are deemed to be severable.
1.9. From time to time, this Agreement may be modified by the mutual written agreement of all parties specified in Section 1.1.
2.0 Workers' Compensation Claim Dispute Prevention and Resolution
2.1 All disputes involving Workers' Compensation claims within the jurisdiction of this ADR program, including medical disputes, shall be subject to this dispute pre- vention and resolution process.
2.2 The component steps of this dispute prevention and resolution process are:
a. The Ombudsperson
b. Mediation
c. Arbifration
d. Appeal by Petition for Reconsideration to the Workers' Compensation Appeals Board
2.3 TTie Joint Committee shall select an ADR Director, Ombudsperson , and the ar- bifrators. The Joint Committee also has the authority to adopt rules of practice and procedure for the ADR Director, Ombudsperson, and the arbitrators as they deem necessary to execute the letter and spirit of this Agreement. TTie JC may establish other positions which are necessary to effectively accomplish the goals and pur- poses of this Agreement.
2.4 The ADR Director shall oversee the work of the Ombudsperson and other ADR professionals on an ongoing basis, train the other ADR professionals in conjunc- tion with training the claims staff assigned to this program, attend all JC meetings and assist in the gathering and submission of data required to be provided to the Division of Workers' Compensation annually or as required by law. The ADR Direc- tor may also conduct mediations and provide a written report outlining the issues in dispute and the disposition of the mediation session. The JC may establish other duties and assignments consistent with the position ofADR Director.
2.5 TTie Ombudsperson shall consider the interests of the City and the injured PPLA members in performing his/her duties. In that regard, he/she should provide aid, counsel and advocacy for an individual injured PPLA member in an effort to establish common interests with the City so that disputes can be prevented or effi- cientiy resolved within the Program. The Ombudsperson shall be proactive and seek to identify disputes before they occurwhere possible and attempt to ensure
that all injured PPLA members are receiving the compensation to which they are entitled. The City shall compensate the Ombudsperson and his/her services are free of cost to the injured PPLA member. The Ombudsperson is not responsible for timely completing or filing ADR forms or other documents for the employee, as this is the employee's responsibility. However, the Ombudsperson may assist in the completion of forms if requested.
The Ombudsperson will also receive all documents filed with theADR program and will assign case numbers to each claim filed and will keep an electronic claims file containing all documents related to the claim. To the extent possible, claim num- bers shall be consistent with claim numbers customarily established by the third- party administrator, the WCAB, or the City. The JC may establish other duties and assignments consistent with the position of the Ombudsperson.
2.6 Mediators and arbifrators shall be selected and assigned to the Panel by the JC.TTie mediators/arbitrators shall be attorneys or retired Workers' Compensation Judges knowledgeable in the field of California Workers' Compensation. The medi- ators shall be responsible for mediating any and all issues in dispute upon the filing of a request for mediation. The arbifrators shall be responsible for adjudicating all disputes between the injured employee and the City arising out of the submission and processing of Workers' Compensation claims covered by this Agreement. The arbitrator is authorized to include in any award all relief available from a Workers' Compensation Judge including but not limited to enhancements to compensation due to any unreasonable delay in the payment of compensation by the City as pro- vided for by law, and/or Labor Code Section 4553 and/or attorneys' fees and costs.
The arbitrator is authorized to resolve all liens not settled by the parties, provided that written notice of the time and place of the mediation or arbitration is given to the lienhdders advising them of the right to appear and present argument and tes- timonyin support of their lien claim.
2.7 In the event of the reporting of an injury or illness regarding an employee cov- ered by this Agreement, the City, or its third party administrator, shall notify the Ombudsperson within one (1) working day of receipt by the third party adminisfra- tor of the first notice of injury/illness, and provide the name, address and telephone
number of the injured employee. TTiereafter, copies of the initial claim form, all medical treatment reports, all medical-legal reports, all notices to the injured em- ployee denying, reducing, terminating or renewing compensation, all pleadings and anyother documents of significance, otherthan documents that constitute attorney work product or other privileged documents, shall be served on the Ombudsperson electa-onically as soon as possible, but no later than five (5) days of receipt.
The Ombudsperson shall contact each injured member within the jurisdiction of the program as soon as possible, but no later than five (5) days of receipt of notice of the injury. Conversations between the Ombudsperson and the injured member, or the Ombudsperson and the City, or its third party administrator, are confidential (see Evidence Code section 1115, etseq.). Injured members may contact the Om- budsperson with any questions, to seek clarification or when they believe they are not receiving compensation to which they are entitled or have any other concern or dispute arising out of the processing of any claim.
2.8 Applications filed with the WCAB with an alleged date(s) of injury occurring on or after the effective date of this ADR program, and those applications that were filed prior to the effective date and have been accepted by the JC, shall be immedi- ately dismissed and removed to the jurisdiction of this ADR program which is the sole means of dispute resolution for claims within the jurisdiction of this program.
Every issue regarding the transfer of a claim from the WCAB to this program shall first be submitted to the Ombudsperson who shall seek a voluntary resolution of the issue, prior to filing any petitions, motions, declarations of readiness to proceed or any other documents or actions with the WCAB.
2.9 Where there is an acceptance, delay, or denial of a claim, or there is a change of position by the claims examiner, the Ombudsperson shall be advised forthwith by the claims department and shall then advise each injured member no later th an five (5) working days of the stated position of the claims administrator. The 5-day period may be extended by agreement, or on a showing of good cause.
2.10 No dispute may proceed to mediation until the Ombudsperson has been ad- vised of all the issue(s) in dispute and has had an opportunity to resolve the dis- pute. Where theOmbudsperson is unable to resolve a dispute, any party, including the Ombudsperson, may request mediation of the dispute. The Ombudsperson shall, in his/her discretion, schedule mediation where it is necessary to move a case toward resolution or is in the best interest of the program. Except where good cause exists, or unless the parties agree otherwise, the mediation process will be concluded within thirty (30) calendar days of the request for mediation.
2.11 With the approval of the ADR Director, the Ombudsperson may in his/her dis- cretion attend any mediation if necessary to move the claim toward resolution or if necessary to further the interests of the program.
2.12 In the eventthat any dispute is not resolved in mediation, the matter may be set for arbifration at the request of either party. The Ombudsperson shall, as soon as practical, appoint an arbitrator from the list of those arbitrators chosen by the JC.
2.13 TTie Ombudsperson may in his/her discretion attend any arbito-ation if neces- sary to move the claim toward resolution or if necessary to further the interests of the program. The Ombudsperson shall secure the approval of the ADR Director when attending an arbitration. The Ombudsperson may provide general assistance to the injured member, if unrepresented, but may not act as the injured member's attorney.
2.14 The arbitrator shall apply the same presumptions of compensability, statutory constiziction and rules of admissibility of evidence as would a Workers' Compensa- tion Administrative Law Judge, and shall have the same authority as a Workers' Compensation Administrative Law Judge over discovery, the production of docu- ments, the issuance of subpoenas and other procedural matters related to the hearing.
2.15 The JC shall promulgate specific rules for the location of the hearings, but un- less good cause exists, all arbitration hearings must be venued in the greater Pas- adena area.
2.16 All arbitration hearings shall be recorded by a certified court reporter and such record, including documentary evidence, shall be retained by the arbitrator un less the parties agree to other methods of creating a record.
2.17 The arbitrator shall file with the Ombudsperson and serve on the parties and counsel his or her findings offset, conclusions of law, orders and opinion within thirty (30) days of the submission of the matter for decision which shall be final and binding except for any appeal to the WCAB Appellate Panel. Any such appeal to the California Workers' Compensation Appeals Board shall be in the same manner as provided for reconsideration of a final order, decision or award made and filed by a Workers' Compensation Judge and by the California Courtof Appeal. Any finding of fact, award, order or decision of the arbitrator shall be in the same form and have the same force and effect as findings of fact, and award, order or deci- sion of a California Workers' Compensation Judge.
2.18 Nothing in this Agreement shall be interpreted as restricting in any way the City's or an injured member's rightto retain legal counsel of their choosing, per La- bar Code section 3201.7. The PPLA, the City of Pasadena, and the JC shall not be responsible or liable for any attorneys' fees associated with representation of any member. Attorneys' fees shall be established consistent with California Workers' Compensation law. The terms and conditions of any agreement between an em- ployee and the employee's retained legal counsel are not subject to this Agree- ment nor does this Agreement in any fashion alter or replace any or all California law applicable to an agreement between an attorney and a worker pursing Work- ers' Compensation benefits.
2.19 All parties shall have the right to discovery as per the California Labor Code and California Code of Regulations.
2.20 In the eventofa lien dispute, any lien claimant allowed to file a lien claim in the statutory system shall be allowed to file a lien claim in this alternative dispute resolution program where the alleged right to file stems from activity in a claim within the jurisdiction of this Program. The Ombudsperson, at the request of the City or a lien claimant may bypass the mediation step, in the dispute resolution process and set the lien dispute immediately for arbitration, if the Ombudsperson is unable to resolve the dispute. A lien resolution firm may be utilized to address any lien claims prior and/or during arbitration.
2.21 The scheduling and cost of interpreters will be handled pursuant to Workers' Compensation law. The ADR Director and/orOmbudsperson shall have the au- thority to select an appropriate interpreter if one is required.
2.22 The ADR Director and/or Ombudsperson shall have the authority to appoint assigned permanent disability raters as necessary.
2.23 The ADR Director or an assigned arbitrator must approve all settlements by determining their adequacy based upon the evidentiary record and standards con- sistentwith the Workers' Compensation laws.
2.24 All documents filed by any party with the ADR program regarding claims within theADR program shall be filed with theOmbudsperson or any other place or designee as determined by the JC.
2.25 The City shall pay all costs incurred in retain ing the ADR professionals neces- sary to carry out the responsibilities set forth in this Agreement.
2.26 TTie Ombudsperson, and all other ADR professionals retained to provide pro- fessional ADR sewices within the jurisdiction of this ADR program. shall exercise independent discretion in fulfilling the responsibilities required under this ADR Agreement on a case-by-case basis. While the JC holds the responsibility for su- pervising these ADR professionals to assure quality performance in fulfilling their obligations under this ADR Agreement, it is also understood by the parties to this
ADR Agreement that in order for these ADR professionals to maximize their effec- tiveness, theirindependence and credibility with all parties involved in claims within the jurisdiction of this ADR program must be protected.
3. Medical Treatment
3.1. The JC shall establish a network of health care providers authorized to pro- vide treatment to those injured within the jurisdiction of the alternative dispute res- olution program. This network shall be identified in writing or through other elec- tronic means and made available to those utilizing this program.
3.2. An injured employee shall have the rightto choose any of the authorized med- ical providers that offer freatment consistent with the nature of the injuries.
3.3.1n an emergency, an injured employee covered by this Agreement may seek freatment from a health care provider or facility not authorized by this Agreement for the purpose of obtaining emergency treatment only. Treatment shall be trans- ferred to an authorized provider as soon as possible, consistentwith sound medical practices.
3.4. In the event th at th ere is no authorized provider with in the appropriate med- ical specialty to provide the treafrnent required, the authorized primary treating phy- sician shall recommend a provider or providers that he/she believes is best qualified to provide the treatment required.
3.5. If medical treatment becomes a disputed issue and UR (Utilization Review) creates the dispute, the remedy will be to go through the expedited Medical-Legal Evaluation process and not utilize the State of California Independent Medical Re- view (IMR). See attachment for Utilization Review protocols.
3.6.Wh ere AOE/COE (arising outof and in the course of employment) compensa- bility is in dispute and the City has denied responsibility for the payment of medical treatment, the injured employee is not required to obtain ta-eatinent by an authorized provider, pending the resolution of the issue of compensability.
3.7. It is the intent of the parties and a primary goal of the ADR program, and
therefore a directive to the JC, that to the greatest extent reasonably possible in- ju red employees shall be returned to work as soon as practical. Such eariy return to work shall occur only where the lighter modified work offered is consistent with any restrictions imposed by the injured employee's treating physician. PPLA shall reference PPLA policy and union agreements for all early retum-to-work efforts.
Specifically reference the Light Duty Program in the current PPLA MOU.
4. Medical Leaal Evalu"
ation
4.1.7Tie JC shall establish a network of medical-legal examiners to serve as the exclusive source of comprehensive medical-legal evaluations within thejurisdiction of this program. Said physician shall serve as an IME, (Independent Medical Ex- aminer). Any issue of the appropriateness of medical treatment shall be resolved in this program and shall be submitted to the appointed IME. It is the parties' inten- tion to not utilize the independent medical review provisions of Labor Code Section 4616.4 Utilization Review (UR)andtheregulationsthereunder. If a medical dispute arises between the treating physician and UR, the remedy is to seek a medical- legal evaluation withtheexclusivemedical-legal provider list per this agreementfor thelME.
4.2. The injured employee and the City may each schedule an appointment wWi the IME in any medical specialty relevantto the case in dispute. Absent good cause to the contrary, the injured employee shall be entitled to one examination with an IME in each relevant specialty. Any dispute regarding whethera report in any par- ticu far medical specialty is relevant shall be submitted to mediation, and arbitration, if necessary. The Ombudsperson shall also have the authority to schedules med- ical-legal exam if necessaryto move the case toward resolution orit is found to be in the best interests of the program. The selected IME in each case has the autiior- ityto resolve any question that requires independent medical-legal review.
4.3. Physicians who actin a medical-legalcapacity(IME) cannot act as the same employee's treating physician, u nless otherwise mufcially agreed to. Pre-designa- tion of a physician must comply with LC Section 4600(d)(1).
4.4. All employees with a disputed medical issue must be evaluated by an IME from the exclusive list.
4.5. The exclusive list(s) shall include specialties as agreed upon by the parties.
4.6. Any communications with an IME shall be in writing and shall be served on the opposing party.
5. Discovery
5.1. Employees will be expected to provide fully executed medical, employment and financial releases, and any other documents, when requested, consistent with the law.
5.2. The parties agree to the use of releases to be used under this Agreement.
The parties shall review any document in question within thirty (30) calendar days of a party's request for review.
5.3. Employees are expected to cooperate in providing a written or recorded state- ment(s), subject to his/her right to legal representation.
5.4. If a formal deposition is necessary, the applicants attorney shall be paid at a rate consistent with LC5710.
Executed at Pasadena, California.
City of Pasadena:
Dated:
Pasadena Police Lieutenants' Association:
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By:
Dated:
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By:
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APPROVED AS TO FORM AND CONTENT: APPROVED AS TO FORM AND CONTENT:
Dated:
Dated:
Lesley Cheung
City Attorney
Legal Counsel for PPLA