DAVID C.

CASARRUBIAS
ASSOCIATE
DIRECT DIAL (415) 995-5893
DIRECT FAX (415) 995-3589
E-MAIL dcasarrubias@hansonbridgett.com

February 10, 2020

VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED

AND E-MAIL BRUCEGETTY@ICLOUD.COM

Bruce C. Getty
Getty Photography
1315 Francis St., #5
Crockett, CA 94525-1346

Re: “Golden Gate Bridge Blood Moon” Print

Trespass & Illegal Profits
Our File No. 800.1

Dear Mr. Getty:

Our law firm represents the Golden Gate Bridge, Highway and Transportation District (the
“District”) which operates and maintains the Golden Gate Bridge spanning between the City and
County of San Francisco and the County of Marin.

As a bridge and highway district, the District has the power to hold, use, and enjoy real property
within its jurisdiction. (Sts. & Hy. Code, § 27163.) This includes the non-public property
immediately adjacent to and surrounding the Golden Gate Bridge that is demarcated by physical
barriers, including chain-link fencing.

The District has received information that you were on and about the District’s non-public
property, without lawful purposes, on January 31, 2018. The District is also informed that while
you were on its non-public property, you took one or more pictures of the Golden Gate Bridge
with the “Super Blue Blood Moon” in the background (the Super Blue Blood Moon was last
visible over the Bay Area on January 31, 2018). The referenced picture is currently published
at: https://gettyphotography.com/collections/golden-gate-bridge/products/golden-gate-bridge-
blood-moon-collaboration, and retails from $132.00 to $2,633.00 per unit, depending on size
and medium.

California state law protects the District’s right to possess and use its property to the exclusion
of others. (Civ. Code, § 654.) Your presence on the District’s non-public property on January
31, 2018, constitutes an actionable trespass. Additionally, because it appears that you are
profiting from a picture described as the “Golden Gate Bridge Blood Moon” that was obtained
through the unlawful act of trespass, any profits you have made from selling this picture have
been wrongly obtained. Under applicable law, the District has the right to seek disgorgement of
any and all profits that you have obtained as a direct result of your wrongful trespass. (Civ.
Code, § 3334.)

Hanson Bridgett LLP

425 Market Street, 26th Floor, San Francisco, CA 94105
16208605.3
Bruce C. Getty
February 10, 2020
Page 2

Notice is hereby given to you to stay off of and away from the District’s non-public property.
Should you be on this non-public property, your presence will constitute a trespass, and you will
be considered a trespasser. Should you trespass on this non-public property again, the full
extent of the law will be sought to prosecute you for trespass and the District will seek
disgorgement of any and all profits wrongfully obtained as a result of any trespass, both past
and future.

Additionally, and in light of the District’s legal rights against you, we must ask that you cease
and desist from any and all further sales of the picture described as “Golden Gate Bridge Blood
Moon,” or any other picture taken from the District’s non-public property. We must also ask that
you immediately depublish the picture described as “Golden Gate Bridge Blood Moon” and any
other pictures taken from the District’s non-public property. This includes removing them from
any and all outlets—public and private—including but not limited to websites, blogs, portfolios,
and other publications.

Please advise us in writing of your willingness to comply with these requests as soon as
possible and no later than two weeks (fourteen days) from this notice. If you are represented by
counsel in this matter, please forward that person’s name and contact information immediately.

Very truly yours,

David C. Casarrubias

16208605.3