June 4, 2009

Wilfredo Laboy, Superintendent
Lawrence Public Schools
200 Common Street
Lawrence, MA 01840

The Honorable Michael Sullivan
Mayor
City of Lawrence
255 Essex Street
Lawrence, MA 01840

Re: Request for Information
Health Insurance

Dear Sirs:

As the representative of the Lawrence Teachers Union, Local 1019, AFT Massachusetts, AFL-CIO, I am hereby requesting public records and/or documentation from the City of Lawrence and/or the Lawrence Public Schools in accordance of our rights pursuant to M.G.L. Chapter 66 Section 10 (the Public Records Law), M.G.L. Chapter 150E (the Public Employee Collective Bargaining Law) and Article VII Section E, Paragraph 1 of the Collective Bargaining Agreement between the Lawrence Teachers’ Union and the Lawrence School Committee.

Please note that M.G.L. Chapter 66 Section 10 requires that you provide all requested public records within ten (10) calendar days after your receipt of this letter. You also have other clear legal obligations pursuant to the other bases of our request. You have a reasonable amount of time to comply with this request pursuant to M.G.L. Chapter 150E and Article VII Section E, Paragraph 1 of the CBA. The Union believes that this reasonable amount of time is the same period of time under M.G.L. Chapter 66 Section 10.

Below is our request for records, information and documentation:

1. Copies of all healthcare claim reports encompassing all of fiscal year 2008 and fiscal year 2009 from July 1, 2008 to the present.

2. Copies of your health care consultants’ recommendations for health insurance rates (including but not limited to GBS) for fiscal years 2008, 2009 and 2010.

3. Copies of your health care insurance carriers (BS/BC, Harvard Pilgrim) renewal reports for fiscal years 2008, 2009, and 2010.

4. Year end balances of the Health Insurance Trust Fund for Fiscal years 2007, 2008, and balance to date. I note that there were no beginning or ending balances in the financial data that you forwarded regarding income and expenditures.

In addition you have yet to provide the following records as requested in my letter of January 27, 2009. In addition to being public records, both this and the above information are relevant and reasonably necessary to the Union’s duties as collective bargaining unit representative.

1. A copy of the collective bargaining agreement between the City of Lawrence and the union representing the Fire Department employees immediately preceding the current Memorandum of Agreement.

2. A copy of the collective bargaining agreements between the City of Lawrence and the two unions representing the Police Department employees immediately preceding the current Memorandum of Agreement.

3. A copy of the Health Insurance Trust Agreement, any and all amendments thereto, and copies of any and all additional documents relative to the formation of said trust.

4. Records reflecting all the deposits to and withdrawals from, along with a description of same, the Health Insurance Trust Fund from July 1, 2008 to the present. The data you provided us on May 27, 2009, in response to this request appears to have no beginning and ending balances. Please provide this information with beginning and ending balance for each period in which deposits to and withdrawals are recorded, along with dates for each action.

Again, the Union is requesting these public records and/or documentation in accordance with our rights and your legal obligations as set forth in M.G.L. Chapter 150E, Article VII, Section E, paragraph 1 of the contract and M.G.L. Chapter 66, Section 10. We take these rights and obligations seriously and are confident that you do as well. Therefore, we appreciate your anticipated prompt and timely compliance with these requests.






Please feel free to contact me with any questions. Thank you for your attention to this matter.


Sincerely,




Philip Katz
Field Representative


c: Frank McLaughlin, LTU President
Haidee Morris, AFT MA General Counsel
Andrew Powell, Boston Benefit Partners
Naomi Stonberg, Lawrence Public Schools Labor Counsel
Salvatore Petralia, HR Lawrence Public Schools
Charles Boddy, Esq, City Attorney
Alan Cote, Supervisor of Records, Secretary of State