Declaration of Ignacio Dayrit in Support of Application for Temporary Restraining Order

MANUELA ALBUQUERQUE, City Attorney, State Bar No. 67464
ZACH COWAN, Assistant City Attorney, State Bar No. 96372
2180 Milvia Street, Fourth Floor
Berkeley, California 94704
(510) 644-6380
Fax: (510) 644-8641

Attorneys for Plaintiff
CITY OF BERKELEY

IN THE SUPERIOR COURT OF CALIFORNIA

IN AND FOR THE COUNTY OF ALAMEDA, NORTHERN DIVISION

CITY OF BERKELEY,                       )     No. 
                                        )	
        Plaintiff,                      )     DECLARATION OF 
                                        )     IGNACIO DAYRIT IN 
vs.                                     )     SUPPORT OF APPLICATION
                                        )     FOR TEMPORARY 
ALTA BATES MEDICAL CENTER,              )     RESTRAINING ORDER 
a nonprofit corporation, and DOES 1-50. )     AND PRELIMINARY 
                                        )     INJUNCTION
        Defendants.                     )
____________________________________    )     Date:  February 24, 1997
                                                     Time: 1:45 p.m.
                                                     Department 81

I, Ignacio Dayrit, declare:

1. I have lived at 2915 Regent Street, between Ashby and Russell, since 1991. I make this declaration in support of the City of Berkeley’s application for a temporary restraining order and preliminary injunction against the further expansion of the Alta Bates Medical Center.

2. Since I first moved to current address in 1991, I have found it more difficult to park on the street on weekdays, except during lunch time when parking is more available. I normally have to park a block away during these peak periods.

3. It is normal to find both patients and employees rushing for appointments at Alta Bates Medical Center. Every day, during a ten-minute observation period, it is common to find one person per minute with clipboards, envelopes, etc. and/or in hospital attire. It is more common to find patients going for appointments. About 80% of cars parked on the street during business hours do not have Area "B" stickers.

4. Many people cruise for parking in neighborhood streets. It is also common to find persons who return to their cars to erase chalk marks left by parking enforcers, or to move their cars.

5. As early as 6:00 am on any given day, there are deliveries at the Regent Street loading dock of Alta Bates. I go running at that time and always see some form of delivery. Many of these huge trucks are double parked or queued.

6. Many trucks and construction vehicles park on our streets, as early as 7:00 am. One communications systems company sometimes has up to three vehicles on Regent.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February ___, 1997, at Berkeley, California.

_____________________________________
Ignacio Dayrit

Last update: May 12, 1997.