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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />Veronica Ramirez (SBN 234200) <br />City Attorney <br />Rachel Le Roux (SBN 284986) <br />Deputy City Attorney <br />E-mail: rleroux(i- redwoodcity.org <br />1017 Middlefield Road <br />Redwood City, CA 94063 <br />Attorneys for <br />CITY OF REDWOOD CITY <br />JEANNINE GAUTHIER, <br />Claimant, <br />V. <br />CITY OF REDWOOD CITY and DOES 1- <br />100, inclusive, <br />Respondents. <br />6.5.B. - Page 3 <br />DECLARATION OF ASSISTANT PUBLIC <br />WORKS SERVICES DIRECTOR <br />TERENCE KYAW <br />I, TERENCE KYAW, declare that the matters set forth in this Declaration are stated based <br />on my own personal knowledge and, if called as a witness, I could and would testify competently <br />to such matters, as follows: <br />1. I am the Assistant Director of Public Works Services for the City of Redwood City. I <br />have worked for the City since 1992. The matters stated in this declaration are true to <br />my own personal knowledge, and if called upon to testify, I could and would testify <br />competently thereto. <br />2. I am aware that on or about February 4, 2016, Jeanine Gauthier allegedly suffered <br />injuries as a result of riding her bicycle over an unguarded trench in the driveway to <br />846 Portola Road, Portola Valley, California. <br />-1- <br />DECLARATION OF TERENCE KYAW <br />