HomeMy WebLinkAbout0210.094·'
~staff 12 ~ . :te1)CNt-------
Karch ll, 199-4
'I'IlII HONORABLE CITY COUNCIL
~.lo Alto, Ca~ifQrni.
Nem~rs of the Council:
This report requests that Council award a contract in the amount of
$58,000 to Dsloitte .& Touche of Oakland, California for the gene:r'al
fixed assets inventory. The consultant wOlk will include
deteraining values and service lives of those assets, and providing
other informatiQn necessary for irnplementat~on of the City's fixed
assets data base. In addition, staff recommends that Council
authorizQ th~ city Manager or her desi9n~e to e~ecute one or more
chanqe ()t'ders to the contrac.t with beloitte & Touche for additional
related but unfol:eSf);sa;ble work. The value of those change orders
shall not "o)(ceed $5 1 800. Funds for this project are budgeted in
the Financ& Dopartmont's 1993-1994 budget. The Finance committee,
Which" had indicated a desire to participate in the consultant
salection for this contract, agreod to allow the contract to go
directly to counoil because of the short timeline for t.he
consultant's 'Work -in order to have the results incorporated into
the 1993-94 audit .
.b.21sgr9\ln"
Th" city established capi,tal assets"records for its utilities funds
in 1986. Accurate fixed assets list.ings are also maintained for
the City's internal service funds, and t.he City has an inventory of
:t·eal proporty for insurance purposes. However, no comprehensive
~nven~ory of the Cityls general fixed assets has been performed.
Since the end of fiscal year 1985-86, the Cit y's, external auditors
have qualified their opinion on the City's financial statements.
This :me-ana that the a'lditors are unable to issue a Ilclean" opinion
~ecauso they cannot verify that the finan,~ial statements fairly
presont tho financial condition of the City in all material aspects
CMR:210:94
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~nleBs they are able to audit the general fixed assets. They have
also given a management letter co~ent 1n each year since 1985-86 f
citing' the ir.t{)ortance of fixCQ assots records in J\;aintaining
accountabilly for the city's property.
Although Council initially approved funding tor the establishment
of ~ Fixed Aosets Inventory and Accounting System in 1991-92, the
additional accounting position needed to direct the inventory and
fixed assets system, ll!1pl()r..entation was r()rlloved· from tho budqot due
. to budget li~ltations. The project Was poatponed to tha curront
tiscal year. WorK on th" project" "as scheduled to begin in
sept.al:lber 1993, but wau .again postponed due to the cOJMl;itment ,of
Pinance Oepart~ent resources to assist Palo ~lto co~unity
Chlldcare in restructuring their financial operattons. Fin:llnce
staff havQ reprioritized othor \lork in ordor to complete the
valuation priOr. to the end of tho fiscal year, which concludes on
June 30, 1994.
In o~dor to substantiate and nonitor its largo investment in
general fixed assets, th~ City seeks a cOr;Jprehensive review,
inventory, and w'Iluation with which to establish accur8lte
accounting records. Daloitto'& 1'ouche will take advantage of the
cityfs QXisting n~cord5 to minit!)ize the cost of inventorying and
valuing the Gonoral "'Und. The scopo of work of the project
involves the following co~ponent9:
o In cooperation with City Rt6ff , davolop d work plan for the
reView, inventory and -ialuation of the cityrs genet"al fixed
assets.
o [)otenine Which fixed assets require physical inventories
based on a review of all I&xis.tinq fixed assets information.
(The City intonds to naintain a record ot all assets with a
value of at least $1,000 and a usetUl service lifa of greater
than three y('·ars). Conduct rlecessary physical inventories and
assign identifying code numbars to assets.
o Develop estimated date$: of acquisition and estimated or"iginal
costs for the assot,s invontQried, as well as estimated
replacement valuos for the City's buildings and fixtures.
o Provide, upon completion of the project, specific data base
reports to the City and ensure final acceptance by external
auditors of the worK product.
o Develop and assemble a property ~anual describing policies,
procedurot;s, and controls tor maintailling the inventory.
Advise city staff of l'ccol'rlmonded policies and procedures which
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will aid the city in the successful development and
maintenance of fixed assets information.
o Prepare a report for presentation to City staff and the
Finance Committee describinq nethodology employed and projoct
results.
8i4 IValuations
The project was sent Qut to ten qualified potential cOl1t,ractorE:-for
competitive proposals, includin9 both accountancy firRB and
professional appraisers.
The firms invited to subnit " proposal tor the project woro
selected in an effort to award the contract to a firm vhlch would
meat tho City's primary goals: to obtain al.lditable information on
the City's fixed assets in accordance with GoneX'.ollly AGceptoc1
~ccountll'lg PrinciplQs (GMP), to receive and retain lm unqualifiE:d
audit opinion for tho city's Comprehensive AnnuOll rir:Hlllci~l Report
and to aid in the development of procedures which will ensut:e
proper maintenance of the new property accounting system.
Proposals were received from four qualiCiea bidders on March IS,
1994. In addition to tho proposal fr'om Oololtto & 'l'()ucha, three
bids were received from professional appraisal tirrllB with
experience in professional valuation consulting services to
municipalities. The bids ranged from $25,800 to,$107,OOO.
Staff assessed the hids on the following criteria: I\pproach, cost,
industry experience, accounting experience, and project t_irnellne.
Ths greatest consideration was placed on the consultant's proposed
approach to the project and Oll it. ability to .aUsty aU the
requirements set forth by tho City. After careful oVAluation,
staff determined that the proposal 'Which meets or eX¢f:'lods all of
the Cityls requirements is Deloitte & Touche. Tne proposal
submitted by Deloitte & Touche olearly demonstrates th&ir
understanding of the city's needs. Beyond merely establishing the
fixed ~ssets accounting record, th~ consultant is needed to aid th3
city in establishing proper controls, assuring the Ability to
adequately maintain the fixed assets data base, and providing tor
prop~r finanoial reporting of the city/s assatsc staff believes
Delo!tte & Touche is best qualified to perform the work with this
emphasis ..
~U8Se!lSment
This project has no'environmental impact. No environmental review
is necessary.
CMR:210:94 3
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staff recommends that Council:
l. Authorize the Mayo .... to execute a contract liith Deloitt. &
Touche of Oakland, California in the amount of $58,000.00 for
General Fixed Assets Inventory; and
2. AuthorizB th~ city Manager or her deaignate to negotiate and
execute one or more change orders to tho General Fixed Assets
Inventory with Daloitte " Touche, the value of 'Which change
orders shall not exceed $et~oo.OO.
Respectfully submitted,
~t!~~
~~/f:Zj
Y HARRISON
n nee Dire.c
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AGREEMENT BETWEEN THE CITY OF PALO ALTO AND
DEWITTE &. TOUCHE FOR GENERAL FIXED ASSET INVENTORY
VALUATION AND CONSULTING SERVICES
This AGREEMENT.is mada and antered Into this __ day of • bv
end belwAen the CITY OF PALO ALTO. a municipal corporation of California.
hereinafter referred to as the ·City·. and DF,lOITIE & TDUCHE. a partnership.
whose address Is 2101 Webster Streat. Oakland. California 94612, hereinafter
feferred to 8S tIIConsultant lO
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WHEREAS. jt Is the Intenllon of the City to provide for the implementation of a
Genoral Fixed Asset system, which entails the initial inventory and valuation of
specific assets 01 the City~ and establishment of policies and procedures adequate
to Insure the proper maintenance of the Fixed Asset data base;
WHEREAS, Consultant is a partnership of cenHied public accountants, duly
.outhorized to practice and licenstld a,o; such by the California Board of
Accountancy;
WHEREAS. Consultant rapresents that it has the professional qualifications and
sklils to provrde the inventory, valuation and consultant services required, and th8
City wishes to retaln the Consultant'S services in relIance thmeon;
NOW~ THEREFORE, in consideration of their mutual covenants, the parties hereto
agros as follows:
1. SCOPE OF SERVICES
A, The Consultant will develop, in joint cooperation with personnel of the City:
a comprehensive approach and work plan for th8 review, inventory and
valuation of the City's general fixed aSi:iets.
B. The Consultant will compile and review all existing fixed asset information
lncluding Inventories of land and improvements, buildings and structures,
and equipment, regardless of the funding source. Based on this review, a
determination will be made of which fixed assets will r,-quire phvsical
inventories, "
It is propo.,ed that all assets with. value of $1000 and a useful life of
greater than three years will be maintained wilhin the fixed asset
"91"-"1'14111 ~tW'M 1M City of Po$ICI Alto
111M Defoatt. &. Tooche lor Vet--~,tiO" 0& Con~Llltlll11 S er,·;ce.
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subsidiary ledger. Supply Inventories and s~ar. parts will not be
Included. InfraSiruclUre fiKed assets (roads, bridges, curbs and
guners., streets and sidowalkt not 8ssocisled with City structures or
pa{l<s, str8(tt signs and street lighting systoms/ parking moters,
traffic signal svstemsl, will not b. recorded.
C. Upon reviow 01 lixlstlng fixed asset information, proposed coding and
Inlormalicn roqu){emOnls, and Ihroughout the remaining work plan,
Consultant will a\lvis.City projoct porsonnel as to recommanded policies,
procedures and prac"esses which will aid the City in successful development
and malntenarice of fixed assets Information.
D." The Consultant will conduct the Inventories as identified in the preliminary
review. Tho Cons'JHant will fntOJ(8ce as needed willl the project manager 10
ensure that advanco nOlic'O is provided to all locations, necessary access is
obtafnsd. and dlsrupt<on of the regular wo,k day is Il'linimized.
E. Tho Consullant will obtaIn the following data (or each asset 8S applicable:
A~sot description
Vendor
Manufacturer
Ma~o
Model
Sorial Number
Location
Department
Account
Project numoer
Classification
Prlmary
Secondory
Normallifa, by class
Condition 01 Assel
Speclfio codes have been developed lor all of the above data items. wilh the
axceptlon of the assel (lescriptlon. TIl. assat dasc{iplion will follow 8
proscribed format in order to provide consistency to the fixed asset listing
and "noble Iho data baso to be purposefully Salted by Ihis data field. Asset
ktentiflcatlon numbors will be assigned separately; the system of assigning
unique 8sset idel1tifjcation numbers has not yet been established.
Identification tags wiH not be utiffzed.
F. In addition 10 tho above data, the Consultant will dovelop and assign
AIl'otOW11 btl ",un tll.e City..:ll p~o AI!.o
aM o.1<><lt" &. T~ hr \l1IIi.i .t~ &. ConwlUn! S .Nic~ I
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estimates of dates 01 acquisition and estimated original costs to the assets
Inventoried; Estimates of teplacement valuo lot tho CiW's buildings and
fixture. will also be ptovided by Itlll Consulta"!.
G, The City will provide the consultant with a file layout of the required fields
with field format. The Consultant will then provide tha CHy with tila
Inventory data In an ASCII fila on a m<ldia to ba dotormlned.
H. Tho Consultant will provide specific reporls to tho City of tho data .base as it
aKists at the completion of the project, Including bul not nocossarily limit.d
to:
Fixed assot. by depBltmont, site and class
FIxed assets by sito. dass. and departfll(Jf1t
Fixed assets by class, departmont and SilO
Fixod assets bV exp1!cted retirement dales, by department
Classification summary and detail
Departmontal summary and datail
Fixed 8SS0ts by fund
l. Because an important reason for developing tho fixed 8sset management
system is to ensure an unquatified audilor's roport with rtJspcct to the City's
goneral fix.ed assot information, the tinsf work product must be acceptable
for these purposes by tho City'S auditolS.
J. The Consultant will be resPQnsiblo for tho development of a property manual
descfiblng poticies end procodures for maintaining the Inventory.
K. The Consultant will propere and ptesent to City staff a dreft repon descrilling
the Consultant's methods and the prolect's.results, Aller ravi6w by tho
staff, tho Consultant will present a final repotl to tho City Manager, and will
be available to present tha raport and answer questions at a City Council
meeting.
2. INVOICES, COSTS, AND SCHEDULES
A. Consultant shall submit billings 8S tho work progresses. A final ten parcont
(10%1 of tho reos stipulated in Section 2.0. of this Agreemont will be held
as a retainer contingent upon the CilY'S deto(mrnation that tho Consultant
has satisfactorily perlotmod tho servic"s described In Section 1 of this
Agreement.
B. Consultant shall submit invoices 8S the work progrosses. Costs shall be
A~"M'101'11 ~twun 1M City of Pao ,0\1(0
and O&lo;tl6 .. T(;Uf;M for V6/veti?n" ~n"'."l'''l Suvleu
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Identified 8S defined In section 1 of this agreement with sufficient detail to
provide verification of the Invoiced amount. Invoices shall be submitted to
the,
City of Palo Alto
P.O. Box 10250
Palo Alto, CA 94303
Attention: Carer ferrell, Accounting M.anagar
C. Consultant shall maintain bOOKS and records supporting all reimbursable
costs for services herein. The City shall have aC(;oss during Consultant's
regular business hours to such books and fecords of Consultant 8S requirod
to verify any and all roimbursable costs invoiced.
D. rn consideration of the services to be performed, as liescribed 1n Section 1 of
this Agreement, the total payment to Consu!!ant .hall not exceed ~58,OOO.
plus $5,800 for any additional consultant work required and authorized in
writing by the City.
E. Services to be performed under this Agreement by the Consultant shali
include the delivery of the roports and documents described in Sections 1,G.,
1.H., I.J., and 1.K. of this Agreement. The General Fixect Asset Policy and
Procedures Menuat described in Section 1.J. shall be dOlivered on electronic
media as prescribed by the City, as well as in hard copy ..
3. SPECIAL CONDITIONS
A.
B.
Entir.§ .. ilru§,Il!I!.ru!l; The Agreement between the City and Consultant will
constitute the entire agreement of the parties hereto, and will sllperseda any
previous agreement or understandings with respeci to lis subject matter.
The Agreement may not be modified except in writing and executed by both
parties. The Cit~1 Manager is authorized by the City Council to execute any
ammendments to this agreement.
Force Majeure, Perlormance of the Agreement by each party shall be
pursued with due diligence in all requirements hereof; howover. neither
party shalJ be tiable for any loss or damage for delay or nonpiHformance due
10 causes not reasonably within its control. In the event of any delay
resulting ,from such causes~ the time for performance and payment hereunder
shaH be e.'<tended for a period of time reasonably necessary to overcomo the
effect of slich delays. In the event of any delay or nonperformance causod
by such uncontrollable forces, the party affected shall promptly notify tile
other in writing of the nalUre, cause, date of commoncement thereof and tllO
AQrtO!'M M bth¥tHllhe City of Plilo Aflo ..... ond O~loine a.. TOUCM f~ Va/u8Iior'l &. ConS\Alent Sern(~,
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anticipated extent of such delay, and shall Indicate whether It Is anticipated
that the completion dates would be affected thereby.
c. Wyta= Consultent must provide a cenificale of insurance in a form
acceptable to City'. Risk Manager prior to entering into the Agreement
evidencing the Consultant's insurance cOl/fJrage in the forms and amounts
set forth In Exhibit A to this Agreement. Consultant shall maintain such
Insurance as will cover and include 1he entire obligation assumed in the
Agreement as well as such Insurance as will protect the Consullant from
claims and liability under Worker's Compensation Acts, personslliability,
property damage, and .11 other claims for damages, Including personal Injury,
and death, which may .rlse from operations under the Agreement.
D. Scheduling; Consultent shall develop and maintain a detailed schedule for
the work requirod under the Agreement. Consultant shalf subrnit progress
data as required by the City Consultant.
E. S.l!mHil¥Jltl>J!le~ All data provided by or for the City shall:
111 be kept in confidence and nOI disclosed to third parties without the
prior written approval of City; and
(21 not be used in the production, or design of any atticle or material,
report or press release, without City'S prior written conS{lnt.
These obligations $hall survive the termination of the Agreemen~. The
ConslJltant shall be fully responsible for the care and protection of
workpapers.
F. SlJbcontrw~ Consurtant is encouraged to consider subcon1facting
portions of the wOlk or services under the Section 1 to small firms or firms
owned and controlled by socially and economically disadvant~ged
Individuals. If this is to be done, Consultant shall submit a description of the
work or selvices to be done under such subcontractlsl together wilh the
name of the proposed subcontractor's) who shall perform any pari of the
services.
G. ~ Except where specificallv provided, the feos stipulated in Section
2.F. of this Agreement shall include all federal, stale, and local salos, use,
excise, Iransponatian, privilege, occupational, and other taxes applicabla to
servlc8 1 materIals or equipment furnished under the Agreement or by the
Consultant's payroll. The Consultant agrees to indemnify and keep City
harmless from and against any liability for any slich taxes, or payroll
premiums and contributions payable by the Consultant.
Agrtementblllw .. on 1M Cily of Pa1'o Alto
6nd De!GlIIIII It TOOCM 10' I/alualion" Con..-Jltenl S'MCOS 'ag" 5
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C!,aoge~ The Agreemeot shell oot be assigoed or traosl.rred without the
writton ~onsent of City. No changes or variations of any kind are authorized
without a slgoed amendment to the Agreement. Anv additional work or
changes to the scope Of tho Agreement cannot be authorized bV anvane
excopt the City'S Accounting Manager.or Finance Director. Such
authorization must be obtained in writing in advance.
III Consultant shall unconditionallv warrant that it shall use sound and
professional principles and practices in the performance of the
services req'uired herein. Con:;:ultant sl~all utilizo the princrpars as set
forth In Generallv Accepted Accounting Principles IGAAP) and
~rilBntaI Accounting. Auditing and Financial Reporting (GAAFRI
in establishing the fixed asset records required.
(2) If Consultant fails to fulfill the foregoing warralltf witl,in the term of
tho Agreement, and fails 10 cure such failure within 30 days after
writton notice thereof by the City to the Consultant, then the City may
trrminate tho Agreement and requ!m reimbursement of all expenses
necessary to roplace or restore, such services.
J. I..ill1!Hnn.i1Y~ Consul[anl hereby agrees to protect. indemnify, defend and hold
hrumless 'City. its officers, agents, and employees from cmy and all
demands, claims or liability of any nature, in each case solely tor bodiiy
Injurv to indi,iduals, including wrongful death, and physical damage to real
or tangiblo personal properly. to the extent directtv and proximately caused
by the Consultant's, its officers~. agents~ or emplovees' negligent acts,
Or(or5, or omission, or willful misconduct. or conduct for which the law
imposos strict liability on the Consullant in the performance or non·
performanco of the Agreement; providod, howover. that if thete is also fault
on the pelt of an-; indemnified party or any lhird party, the foregoing
indomnlty shaH be on a comparative faull basis. As a condition to the
foregoing indemnification Obligation, the City shall provide the Consultant
with prompt notice of any claim tor which indemnification may bo sought
hereunder and shall cooperate in all reasonable respects with the Consultant
In connection with any such claim. The Consultant shall be entitled to
control tho handling of any such claim and the defonse or settlement thereo(
in tts sole discretion, with counsel of its own chOOSing.
K. .8f(irmative Action Requiremen..t In performing services under this
Agreement, the Consultant shall be required to complv with all laws
concerning non-discrimination and affirma1ive action in employment. and
shall be subject to all penaltios, including penalties set fonh in tho Palo Alto
Municipal Code. in the event of a violation of this provision.
"OJu.",..,.1'\t ~1 woeo ... 1M Citv 01 f'&!() Alto
.. nd bol~lt6 & Tou<:ho lor V&lUII>or, &. Con$\.lllal'll SeMen
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l, l0terest of CowactoG At ell tlrno$ the Consultant shall be deamed to be an
ind.pendant contractor end the ConsuHant shail not be authorized to bind
City 10 aoy conll.e! or other obl'getlon. Under to" Agreement, the
Consultant will cenlfy th.t no ona who has or will have any financial intorost
under the Contract Is en oUieer or employee of City.
(Remainder 01 p.oe Intentlon.lly loft bJ"nk)
AIt"tmont btl ""ttl'! 1M City 01 P .. .,. All>:!
.rod Pol«rt~ &. twch-t 10( \I_\,I~tiM & eor,$vlllI~ SeMc-il1
IN WITNES~. WHEREOf, City end ConsuM~t have eXfcut,d t~s AG",e~nt the
day and ve41 first ebove w~1ton. .
ATTEST: CITY OF PALO ALTO
C;ty Clerk Mayor
APPIlOVEO AS TO FORM: DElOlne & TOUOH~
By: _t'~_~~"L"~ __
Ito: ~~d.:2 r:_"" ___ _
APPRoveo:
FiOBnc& Director.
AocounUng Manege'
Risk Mooegtr
AglUlTIIrnl teu", In h C(ty.oP PO!o A!w
.aM Otl"rt. & T9VWI' '«t v .. "-Wc~" CU""'(lInt GIMwI
r== " ---,----A t ta.s!!~n! __ ~ ~_~~ ____ =~=_=_=_,=,= __ =_= __ = __ ~ __ ., __
Insuwnce flequi mments for Contractors -
CONTRACCOR: ~o1t~e & To uclCe ____________ . ___ _
l'ROJECf MANAGER: Carol Ferrell • Acco un t f...rJs .. l:fM..ag.er _~ __ ~ __________ • __ ~ ___ ._
~N!RAcr NAMIl: Gen.eral Flxed Asset_Jl1ventory, Va)tJat~a.ruL.LAn.s~ __ _
GENERIILTER MS AND INSTRUCTIONS Services
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RETURN THE COMPLE'}ID CERTIFICATE TO THE ClTYOf PALO ALTO. PURCHASING &: CONfRAC1'
ALTONJO}. ADMINISTRATION, 250 HAMILTON AVENUE. PALO :;;:-~:;;:-.-;~-~--~--~--:,-"~--~,~"~~-""-~,,---~ .-.-------
THE INSURANCE REQtl1RE~IENTSrHECKEI) DELOW ARE REQUIRED FOR TUIS courRACT.
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ALLDAMMES
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-fiHE CrTYOF PALO At. TO IS TO B F.: NAM£D}S AN A DDrTlONAIl NSUII r;D --------------",----------------------
NO INSURANC.EC~TlfICATElS J::EQULRED
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A. Thllo CilV ~f Pelo Allo. ils offic6!!. _ij~rlu _rod .!'{rof)lovus '10 Mfrle.:i~, e~dd;QnJl inol\,ue", bUl ~r~'I n,lo \.,.o;k plrfclIm&:j 1/;"0<:101
<'onolr8cl. S~;;I c., ... ele~O' u 1" l!,& Cil'f 01 f"do All", e10::., $"&'1 be prim"y ':"YCflgl, l'ri,fy.>lJ1 ofltel e\lo1M' Cily"$ ""i","'lI itll,,H",,<",,
er.d env olh:&r imlHlII1C" c&rl;eo'l b'( ll-r.e Ci1r bsiMjuc.ss iruurlrlce IIrJy.
B. WMf« thIS Ylork irll'\ll ... e, Qr"din9. pev:r>~, ")cNl'elOng. driFlif1t,1 0' "Ihff uodtrll,Co\Jr4 ,",Qrk. ,'''" pr;ol!.:'( !r,.dW&, de 5 Irv:l:"no (}l I'>,r""
coooui", P'PO$, mlllM. Cor "lh~1 s,mj~el plQSlefll' 01 env epp&t;!;ll!' ino c"Nucti"f1 l~.un.'lh boloY/ I"~ :lu.I(e 0/ lh~ "lo\JM 'nN!~'H
ol'lf1.ed bV IMt::! p;!;Ili", or th, Cily oj Polio A'lco.
C. \'/hiHO' thO' '1'/0110: In'f(~"'69 'I\C"I'II~"II, .:oIl~~;~ CO"'~fPg8 j~ pr,,\-h:l!d in th" 6rr,:;,It'lU IIbr,lre.
D. 11'111 rxJ'iey rnoeh.lc:let rI "S~~'e r~bil;IV of lralefo.," p rO""$I(ln.
E. Doducliblu over $5,000 "'IU" bl indic610d OM rll" .ubject 10 Ippr"Y"t,
F. If s-lJch pl)licru lore ~ ~l"ICtfed 01 cl'1Bnolle:! c:lLJrirlIJ I"', po.io<!' 01 eOVN~ W e U SllIled "'~Iein. ino SI.ICI'1I1 rnonrw n 10 ~lro c t llu CGI[jfkol0,
thirlY 130J 4e'($ WJiuen nol.lu wi!1 oe m":ioo to L'-& City o!,P~:o AIIO, ContfaeL A~rT;r':)Irelion, P.O. Box 10150, 94.303
G, Th" liebjilly insLJru;O:8 pO~CV i"tlLJ(/e $ " cont'llclo.lal ti&!:oi1ill' e 1'Id01$~m tnt Jlroy.di,.,~ inWI ~ ['co C<lv,~oij" lor CO"lrO~IN· ... ~ .. r.m~"1
to inclrmfllly tho Cilv.
I-I. Tl'1o (O\l"fIlO' .lroJd~d under Ih' polic<os i~ $ut;.je!;'llo 811 telms or l"e p,~id(lo' dui"l1"tl.j hHel" e rod meot'i.:1 ellf,,, JHO.i!;Of,' c ~=,1
OAT[,~;~;;--::: .. cr AO~N~~;;lk~7!iJ;~~/;r:t.'1~"'.-::,.=,:,:.::~."Lm'~,,,,,,'00,,,-_