Case 2:12-cv-01282-JLR Document 578 Filed 08/15/19 Page 1 of 7 THE HONORABLE JAMES L. ROBART 1 2 3 4 5 6 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 8 UNITED STATES OF AMERICA, 9 Plaintiff, 10 v. 11 CITY OF SEATTLE, 12 Defendant. 13 ) ) Case No. 2:12-cv-01282-JLR ) ) DECLARATION OF ) KERALA T. COWART ) ) ) ) ) 14 I, KERALA T. COWART, being familiar with the facts set forth herein based on my 15 personal knowledge, and being competent to testify, hereby declare under penalty of perjury 16 that the following is true and correct: 17 18 1. I am the Assistant City Attorney representing Defendant City of Seattle as counsel of record in the above-captioned matter. 19 2. Attached as Exhibit B is a true and correct copy of a letter sent on June 12, 2019, by 20 City of Seattle Director of Labor Relations to the Labor Relations Policy Committee 21 and the Gender Equity, Safe Communities, New Americans & Education Committee 22 of the Seattle City Council. The letter provides notification that the City will seek to 23 commence collective bargaining with the Seattle Police Management Association in DECLARATION OF KERALA T. COWART - 1 (12-CV-01282-JLR) Peter S. Holmes Seattle City Attorney 701 Fifth Avenue, Suite 2050 Seattle, WA 98104 (206) 684-8200 Case 2:12-cv-01282-JLR Document 578 Filed 08/15/19 Page 2 of 7 1 December 2019. 2 3. Attached as Exhibit B is a true and correct copy of a letter sent on August 14, 2019, by 3 City of Seattle Director of Labor Relations to the Labor Relations Policy Committee 4 and the Gender Equity, Safe Communities, New Americans & Education Committee 5 of the Seattle City Council. The letter provides notification that the City will seek to 6 commence collective bargaining with the Seattle Police Officers Guild by no later than 7 April 2020 and as early as March 2020. 8 9 I declare under penalty of perjury that the foregoing is true and correct. 10 DATED this 15th day of August, 2019 at Seattle, King County, Washington. 11 12 s/ Kerala T. Cowart KERALA T. COWART 13 14 15 16 17 18 19 20 21 22 23 DECLARATION OF KERALA T. COWART - 2 (12-CV-01282-JLR) Peter S. Holmes Seattle City Attorney 701 Fifth Avenue, Suite 2050 Seattle, WA 98104 (206) 684-8200 Case 2:12-cv-01282-JLR Document 578 Filed 08/15/19 Page 3 of 7 CERTIFICATE OF SERVICE 1 2 I hereby certify that on August 15, 2019, I electronically filed the foregoing with the Clerk 3 of the Court using the CM/ECF system, which will send notification of such filing to the following: 4 Brian T. Moran Brian.Moran@usdoj.gov 5 Christina Fogg Christina.Fogg@usdoj.gov Matt Waldrop james.waldrop@usdoj.gov 6 Gregory Colin Narver gregory.narver@seattle.gov 7 Kerry Jane Keefe kerry.keefe@usdoj.gov Peter Samuel Holmes peter.holmes@seattle.gov Jeff Murray jeff.murray@usdoj.gov Ronald R. Ward Ron@wardsmithlaw.com Timothy D. Mygatt timothy.mygatt@usdoj.gov Gary T. Smith gary.smith@seattle.gov Hillary H. McClure hillarym@vjmlaw.com Kristina M. Detwiler kdetwiler@unionattorneysnw.com David A. Perez dperez@perkinscoie.com 13 Anna Thompson annathompson@perkinscoie.com 14 Merrick Bobb mbobb@pacbell.net Bruce E.H. Johnson brucejohnson@dwt.com Eric M. Stahl ericstahl@dwt.com 8 9 10 11 12 15 16 DATED this 15th day of August, 2019, at Seattle, King County, Washington. 17 s/ Kerala T. Cowart Kerala T. Cowart, WSBA #53649 Assistant City Attorney E-mail: kerala.cowart@seattle.gov 18 19 20 21 22 23 DECLARATION OF KERALA T. COWART - 3 (12-CV-01282-JLR) Peter S. Holmes Seattle City Attorney 701 Fifth Avenue, Suite 2050 Seattle, WA 98104 (206) 684-8200 Case 2:12-cv-01282-JLR Document 578 Filed 08/15/19 Page 4 of 7 EXHIBIT B TO COWART DECLARATION Notice of Commencement of Collective Bargaining with Seattle Police Management Association Case Document 578 Filed 08/15/19 Page 5 of 7 GUS City of Seattle Seattle Department of Human Resources Bobby Humes, Interim Director June 12, 2019 Seattle City Council Labor Relations Policy Committee Gender Equity, Safe Communities, New Americans Education Committee 600 Fourth Ave. 2nd Floor Seattle, WA 98104 Dear Committee Members: Pursuant to SMC this letter serves to inform you regarding the anticipated commencement of collective bargaining with the Seattle Police Management Association which is set to begin in December, 2019. Sincere Regards, Laurie Brown Director of Labor Relations City of Seattle cc: Jenny Durkan, Mayor Pete Holmes, City Attorney Carmen Best, Chief of Police Bobby Humes, Interim SDHR Director Lisa Judge, Inspector General Andrew Myerberg, Of?ce of Police Accountability Director Jennifer Greenlee, Civil Service Commissions Executive Director Bessie Marie Scott, Community Police Commission Interim Executive Director Kirstan Arestad, City Council Central Staff Director Peter Q. Nguyen, Labor Negotiator Scott Bachler, SPMA President Seattle Department of Human Resources Seattle Municipal Tower, 700 5th Avenue Suite 5500, PO Box 34028, Seattle, WA 98124-4028 (206) 684-7999 0 Fax: (206) 684?4157 0 Employment Website: An equal employment opportunity employer. Accommodations for people with disabilities provided upon request. Case 2:12-cv-01282-JLR Document 578 Filed 08/15/19 Page 6 of 7 EXHIBIT C TO COWART DECLARATION Notice of Commencement of Collective Bargaining with Seattle Police Officers Guild Qil� City of Seattle Case 2:12-cv-01282-JLR Document 578 Filed 08/15/19 Page 7 of 7 Seattle Department of Human Resources Bobby Humes, Director August 14, 2019 Seattle City Council Labor Relations Policy Committee and GENSCA Committee 600 Fourth Avenue, 2nd Floor Seattle, Washington 98104 Dear Committee Members: With the current Collective Bargaining Agreement with the Seattle Police Officers Guild (SPOG) expiring on December 31, 2020, the City of Seattle will seek to commence bargaining no later than April 2020 in accordance with city and state laws. Pursuant to SMC 4.04.120(F ), this letter serves to inform you regarding the anticipated commencement of collective bargaining with SPOG, which may begin as early as March 2020. As contemplated in SMC 4.04.120(F ), a joint meeting of the Council's Labor Policy Committee and Gender Equity, Safe Communities, New Americans & Education Committee should be held at least 90 days before the beginning of bargaining. The City is bound by law to "consider in good faith whether and how to carry forward the interests expressed at the public hearing. Those suggested changes that are legally required to be bargained with the SPOG, SPMA or their successor labor organizations will be considered by the City, in good faith, for inclusion in negotiations." I look forward to working with LRPC and the Executive to bargain this upcoming Collective Bargaining Agreement. Jana Sangy Director of Labor Relations cc: Jenny Durkan, Mayor Pete Holmes, City Attorney Carmen Best, Chief of Police Bobby Humes, SOHR Director Lisa Judge, Inspector General Andrew Myerberg, OPA Director Jennifer Greenlee, Executive Director, Civil Service Commission Bessie Marie Scott, Interim Executive Director, Community Police Commission Kirstan Arestad, City Council Central Staff Director Debra Hillary, SOHR Labor Negotiator Kevin Stuckey, SPOG President Seattle Department of Human Resources Seattle Municipal Tower, 700 5th A venue Suite 5500, PO Box 34028, Seattle, WA 98124-4028 (206) 684-7999 • TTY:7-1-1 Fax: (206) 684-4157 • Employment Website: www.seattle.gov/jobs An equal employment opportunity employer. Accommodations for people with disabilities provided upon request. 'f•� ��