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CLAIM AGAINST THE CITY AND COUNTY OF SAN FRANCISCO

Before completing this form please read the instructions on the back. Untimely claims will be returned. Please submit
this form and supporting documentation to the Controller's Office, Claims Division, 1390 Market Street, 7th Floor,
San Francisco, CA 94102 in person or by mail.

* REQUIRED ** REQUIRED IF KNOWN

1. Claimant's Name and Home Address (Please Print Clearly)
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2. Send Official Notices and Correspondence to:

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Telephone

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I~~Time of Incident

(AM or PM)

Date of Incident

8. Claimant Vehicle License Plate#, Type, Mileage, and Year

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9. Basis of Claim. State in detail all facts and circumstances of the incident. Identify all persons, entities, property and City
departments invol.,ed. State why you believe the City is responsible for the alleged injury, property damage or loss.

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Vehicle License Number and Bus or Train Number

Type of City Vehicle

10. Description of Claimant's injury, property damage or loss

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11. Amount of Claimant's property damage or loss and

method of computation. Attach supporting
documentation. (See Instructions)
ITEMS

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TOTAL AMOUNT
Court Jurisdiction:
12. Witnesses (if any) Name

1.

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Limited (up to $25,000)

Unlimited (over $25,000)

Address

Telephone

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Date
Print Name

Relationship to
Claimant
CRIMINAL PENALTY FOR PRESENTING A FALSE OR
FRAUDULENT CLAIM IS IMPRISONMENT OR FINE OR BOTH.
(PENAL CODE 72)

CAIFORM 02/14

March 17, 2016

City & County of San Francisco

1390 Market St

ih Floor

San Francisco, CA 94102-5402

Attachment to Claim of Douglas O'Connor. San Francisco Passenger Vehicle Driver #73895.
9. Basis of Claim
SFO has violated and will continue to violate the Constitutional rights of numerous licensed ground
transportation providers. This is includes and is not limited to taxi, limo and shuttle operators. SFO
renewed the unlawful TNC pilot program in February 2016 without creating a level playing field. SFO
has required licensed ground transportation providers to submit vehicles for a mechanical inspection,
decal installation and transponder installation by SFO personnel. This has occurred for the year 2016.
Meanwhile TNCs vehicles do not have to submit to the same standards as their respective
counterparts. This is a violation of our constitutional rights.
SFO has mandated full time workers comp coverage in scenarios where a "vehicle for hire" is not
operated by the registered owner, his/her own spouse, a partner of a LLP or general partnership or
officer of a corporation. Many TNC drivers engage in leasing vehicles they do not own for the purpose
of operating at SFO. Their activity requires full time workers compensation. The same type of policy
incumbent ground transportation providers are forced to provide.
SFO has prohibited the use of out of state vehicles and rental vehicles for the taxi, limo and shuttle
industry. SFO allows TNCs to use out of state vehicles and rentals.
SFO provides the benefits of an employer to Uber and Lyft without paying for the actual costs. SFO
allows Uber and Lyft to report and pay the loop fees of its so called "independent contractors". This is
a violation of CA Business Code 17200 and the Constitution. In other blue collar professions such as
construction a contractor would not be allowed to sub contract work to casual"day laborers" at SFO.
SFO discriminates against the ground transportation industry under the guise of promoting
technology.
SFO allows TNCs to use both levels of the terminals for pick up. All other ground transportation
providers must be granted the same privilege.
10.Description of Claimant's injurv. property damage or loss
SFO's promotion of unfair competition and workers comp evasion has artificially lowered the price
TNCs can charge for trips to and from SFO. As result my income as a taxi driver has diminished. Wait
times at SFO increase. SFO is contributing to artificial supply and demand.

11. Calculations of Claimant

Other taxi drivers with experience prior to the TNC pilot program have stated their wait times were
shorter prior to the TNC Pilot Program. No income is generated sitting at the airport. My damages
are unlimited because anything can happen once I drop someone off in San Francisco from SFO. I am
one of many "San Francisco Passenger Vehicle Drivers" adversely effected by SFO's decision to violate
our constitutional and civil rights.