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MEMORANDUM <br />Attorney-Client Privilege <br />To:Susan Hsieh, City of Pleasanton <br />From:Marcus Wu <br />Date:March 12, 2025 <br />Re:Proposal: Recovery of Eligible COVID Leave Payments <br />Thank you for your interest in engaging Pillsbury to assist the City of Pleasanton with <br />recovering federal refunds of the City’s eligible COVID leave payments. Our proposed <br />services and fees are detailed below. <br />A. BACKGROUND <br />Since the March 2020 onset of the pandemic, to comply with various federal and state laws, <br />the City has provided paid leave to employees who need time off for certain COVID-related <br />reasons (“COVID leave payments”). Under a little-known federal law, the City is entitled to <br />recover IRS refunds for COVID leave payments made to employees for eligible leaves in the <br />2nd and 3rd quarters of 2021. The refundable amounts include not only the leave payments up <br />to certain limits, but also certain related pension, health, and FICA costs borne by the City. <br />B. PROPOSED SERVICES <br />Our services will comprise the following steps: <br />1. Verify City’s eligibility <br />xx Obtain the City’s Form 941 filings for the 2nd, 3rd, and 4th quarters of <br />2021. <br />x Determine whether the City has already received direct or indirect <br />reimbursements (e.g., via federal grants) for the COVID leave <br />payments. <br />x If the City has received any such reimbursements, assess whether <br />they render the City ineligible for the refunds. If we conclude that the <br />City is ineligible, our services will cease without any charge to the <br />City. <br />Docusign Envelope ID: 408895A5-B882-4B84-8AA4-E757062412A6