6. Complainant's Position

Complainant's President, Frank Saslow, testified that Western Referral has been in business for six years and is licensed by the City of San Diego to provide referral service. Western Referral denies any involvement in prostitution activities and stated that, to the contrary, it carefully trains its employees and independent contractors to avoid such conduct.

Complainant also offered several legal challenges. First, complainant argues that the Rule 22 process violates the due process rights of the United States constitution. Second, complainant also contends that it has been deprived of a valuable property right, its telephone service, without compensation. Third, on the merits of the case, complainant asserts that the Los Angeles Police Department has failed to meet its burden of proof.

Finally, complainant alleges that it was denied its discovery rights because the Police Department refused to provide copies of police reports without a formal request through the Department's established process.