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
CITY OF BERKELEY, ) No.
)
Plaintiff, ) DECLARATION OF
) ANNE HARPER 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, Anne Harper, declare:
1. My husband Craig and I have lived at ... north of the corner of Ashby and Regent, for 9 years. 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 have lived at my current address, I have observed a steady increase in the impact of Alta Bates on our neighborhood.
3. In particular, there has been a gradual increase in trucks delivering materials to the Regent Street loading dock of the hospital, at all hours of the day and night. They create congestion at the corner of Regent and Ashby as they turn, and are very noisy. Some of the large semi trucks block all traffic on Ashby as they back into Regent with their backup alarms sounding.
4. Most residents have paid parking permits but have difficulty parking on their own street because spaces are usually occupied by cars of hospital employees, people doing business with the hospital, or visitors. Because parking is theoretically limited to 2 hours, and is posted as such, employees, wearing hospital badges, come out to check their cars and erase chalk marks or move cars down the street as spaces become available. Parking enforcement is spotty, probably because the area one officer covers is so large. This free on-street parking also benefits contractors working at the hospital. For example Nortel Communications, whose people wear hospital badges, have parked their trucks on our block for about a year.
5. Due to recent construction, metered parking spaces on Regent south of Ashby have been taken over by construction vehicles since last summer, adding to parking problems and congestion in surrounding residential areas. Construction equipment, a dumpster on the street which seems to be a permanent fixture, and trucks delivering materials are intrusive, dirty and noisy.
6. We have received no communication from Alta Bates explaining these activities or notifying us of the extent of construction or a time frame for the disruption.
I declare under penalty of perjury that the foregoing is true and correct. Executed on February ___, 1997, at Berkeley, California.
_____________________________________
Anne Harper
Last update: May 12, 1997.