Cadena

I.

BACKGROUND

A. Underlying Facts The City leased several floors of a high-rise office building in downtown San Diego (the Building) where it stationed many of its employees in 2017. The City knew the Building contained asbestos. In July 2017, the City sent its employees an e-mail notifying them the Building owner would be replacing all exterior windows. The e-mail stated a comprehensive study had been done to identify the locations of asbestos in the Building; the locations included window channels on floors leased by the City; and daily monitoring of air quality in locations where renovations would affect asbestos-containing materials would be done. An estimated 40 tons of asbestos-containing materials would be removed during the renovations. The City designated Karen Johnson, a manager in its Real Estate Asset Department, as the liaison between City employees working at the Building and the Building owners and renovation contractors. Within days of the City’s e-mail notice about the window renovation project, Johnson received an e-mail on behalf of employees expressing concerns about exposure to asbestos. Over the next several months, she and

2 other City officials…