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					Presentation The Bayside Marin Rehab Campus Business Model
Complaint Exhibit - California State Department of Alcohol and Drug Programs (DADP) Updated April 18, 2007

Learn More About Bayside Marin
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A group of neighbors have organized to minimize the impact of multi-residence rehab campus operations on our neighborhood. Their web site is: http://NPA.Baysideacres.org Here is an April 2007 article in Treatment Magazine – read this, it is the future of your neighborhood! http://alondon.com/Treatment.pdf May 23, 2007 letter to Hon. Jared Huffman, Assembly Member, State of California http://alondon.com/Huffman.doc

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Prepared by: Allan P. London, CPA Download this file at http://www.alondon.com/adp.ppt

“Six-Bed” Model Operators
“A preferred method of expansion by “six-bed” model operators has been to buy nearby homes, while keeping each house at [no more than] six beds. This has allowed centers like Creative Care in Malibu, and many others, to grow their operations to 30 beds or more, while staying under the “six-bed” radar.”
April 2007 Treatment Magazine NIMBY Battles Are Erupting Across California by John Worley

Prepared by: Allan P. London, CPA Download this file at http://www.alondon.com/adp.ppt

The Bayside Marin Business Model
"There's no limit on how many you can have contiguous to each other," said Perry Litchfield, an attorney, building contractor, and real estate broker …
June 19, 2006 Marin Independent Journal article Ritzy Detox Homes Irk Neighborhood by Tad Whitaker

“I want to buy-up the entire block” said Malibu rehab operator…
December 16, 2006 Wall Street Journal article Sobering Vacation by Christina Binkley

Prepared by: Allan P. London, CPA Download this file at http://www.alondon.com/adp.ppt

Bayside Marin Campus and Facilities

Prepared by: Allan P. London, CPA Download this file at http://www.alondon.com/adp.ppt

Bayside Marin Campus and Facilities

Prepared by: Allan P. London, CPA Download this file at http://www.alondon.com/adp.ppt

Bayside Marin I, II and III Constitute Unreasonable Commercial Activity
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18 patients, 30 to 50 staff and additional staff housing contemplated at 180 Bayview; 3.2 Acre campus; Single gated entrance and parking for 15 vehicles and second parking area for 3 buses; A dozen or more bus trips a day ferrying guests to gym and administrative offices at Loch Lomond Marina out patient facility;

This constitutes unreasonable commercial activity for a residential neighborhood and is a violation of the State Health and Safety Code.
Prepared by: Allan P. London, CPA Download this file at http://www.alondon.com/adp.ppt

All Guests Share Grounds with Single Entrance
Photos From Bayside Marin Web Site

Prepared by: Allan P. London, CPA Download this file at http://www.alondon.com/adp.ppt

Facilities are Shared by ALL Guests
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Common grounds and landscape areas shared by all residents; Shared transportation services; Shared recreational facilities including sweat-lodge, pool, basketball courts & hot tub; Shared treatment programs and services are available to all clients of Bayview I, II and III.
Prepared by: Allan P. London, CPA Download this file at http://www.alondon.com/adp.ppt

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Shared Amenities – Available to All Guests
Photo from Bayside Marin Web Site

Prepared by: Allan P. London, CPA Download this file at http://www.alondon.com/adp.ppt

Program Schedule Indicates Many Activities Include All Residents
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“Morning Check-in meeting describes activities of the day” and the meeting “occurs in a room overlooking San Francisco Bay and Mt. Tamalpais” - Bayside Marin web site. It is likely that most meals are served and/or prepared at 191 Bayview residence as that is where the main kitchen is located. Yoga and other group meetings are held in communal meeting rooms without regard to the patients’ assigned residence. The program schedule indicates group lectures by, among others, Perry Litchfield on Tuesday and the Program Director on Thursdays - Bayside Marin web site.
Prepared by: Allan P. London, CPA Download this file at http://www.alondon.com/adp.ppt

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Bayside Marin Program – All Guests
From Bayside Marin Web Site

Prepared by: Allan P. London, CPA Download this file at http://www.alondon.com/adp.ppt

Residence Meeting Facilities
Photos From Bayside Marin Web Site

Prepared by: Allan P. London, CPA Download this file at http://www.alondon.com/adp.ppt

Appears to be Operating as a Single Integrated Facility
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As presented on the Bayside Marin web site, it is evident that facilities are well integrated. Clients from one licensed residence are routinely provided services at another separately licensed residence. This represents a possible violation of CCR Section 10508(a)(3).

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Prepared by: Allan P. London, CPA Download this file at http://www.alondon.com/adp.ppt

DADP Required Independent and StandAlone Operation of 47 Tweed Residence
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Initial license application was rejected by the DADP until Bayside Marin’s policies and procedures manual was changed to guarantee that 47 Tweed would operate independently from Bayside Marin’s adjacent facilities. This is the first sign of DADP’s stricter interpretation of the “six-bed” rule requiring each location to operate as a separate and independent treatment center.

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Prepared by: Allan P. London, CPA Download this file at http://www.alondon.com/adp.ppt

Bayside Marin Policies and Procedures Manual
In response to ADP’s requirement that Bayside Marin’s Policies and Procedures Manual “must be revised to ensure the individual operation of Bayside Marin III located at 47 Tweed Terrace, San Rafael, California”, the following amendments to the Manual were submitted to ADP: – Under the Facility Management section: “All services including meals, medications and other residential services are provided on site within the residence”. – Under the Counseling and Other Services section: “All onsite groups will be limited to a maximum of six residents. Educational or therapy groups requiring more than six residents will be held off site”. – Under the Program Description section: “Residents at Bayside Marin will experience onsite groups of six or less persons”.
Prepared by: Allan P. London, CPA Download this file at http://www.alondon.com/adp.ppt

DADP Needs to Address the Following Questions Relating to Bayside Marin Operations
Does “all services” and “residential services” include all of the “services” described in the License and Certification issued by ADP for the operation of Bayside Marin III? Further, does it include all of the services advertised on the website? What exactly constitutes “off Site”? Are any of the “off site” educational or therapy groups being held at Bayside Marin I or II? Does the Program Description referring to the “Residents at Bayside Marin” apply to the residents at each of the three licensed facilities?

Why doesn’t the DADP require independent operation of Bayside Marin’s other two adjacent facilities at 189 and 191 Bayview Drive?
Prepared by: Allan P. London, CPA Download this file at http://www.alondon.com/adp.ppt

Solution
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Enforce the independent operation of each facility whereby guests do not cross property lines for treatment, meals, recreation or transport services; OR

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Combine the licenses of Bayside Marin I, II and III into a single license which would either: i) limit treatment to 6 or fewer guests or ii) require a City and/or County zoning variance to operate a rehab hospital in a residential area.
Prepared by: Allan P. London, CPA Download this file at http://www.alondon.com/adp.ppt