MOTION-- The City Administrative Officer (CAO) intends to assign the defense of LAPD Captain Lillian
Carranza to conflict counsel panel firm Olivarez Madruga Lemieux & O'Neill ("the Olivarez
firm”) in the matter of Jonathan Tom and Yoomi Tom v. City of Los Angeles; Los Angeles
Police and Revolver Athletic Club; Lillian Carranza, et al. (22STCV00224).

The Olivarez firm notified the CAO that it currently represents the City of Inglewood and
Mayor James T. Butts in a case against the City of Los Angeles arising out of an unrelated
traffic collision case (City of Los Angeles v. James Thurman Butts, Jr., et al., 20STCV20284)
where Inglewood's mayor was in a traffic collision that injured a City of Los Angeles
employee. In that case the City of Los Angeles is represented by outside subrogation
counsel.

Noting the conflict of the firm having a case against the City of Los Angeles, the Olivarez
firm alerted the CAO and requested a waiver of conflict of interest. The CAO consulted with
the City Attorney’s Office to determine if the City of Inglewood case has any overlapping
facts of elements with the Tom case. Inasmuch as the Tom case is primarily an employment
case against the Los Angeles Police Department (LAPD) with allegations of Fair
Employment and Housing Act (FEHA) violations, while the City of Inglewood cases involves
a traffic collision, there is no likely overlap of facts or elements of law, and there is no great
risk to the City in granting a waiver.

Because of the firm’s representation of the City, Rule 3-310 of the California Rules of
Professional Conduct preclude its adverse representation without a waiver from the City.
The firm has requested such a waiver and the CAO, recommends that the waiver be
approved.

I THEREFORE MOVE that the request from the firm for a waiver of conflict of interest, as
presented above, be approved and that the CAO or his designee be authorized to execute
the waiver on behalf of the City.