In Donnellan v. City of Novato (2001) 86 Cal.App.4th 1097, the city council issued a written decision suspending appellant Donnellan from his job as a police officer. The city manager mailed a copy of the city council's decision to Donnellan on September 10, 1998, with a cover letter. The written decision provided that judicial review was governed by section 1094.6. Donnellan filed his petition for a writ of administrative mandamus on December 21, 1998, and the city raised the defense of untimeliness. At the hearing on the writ petition, the city submitted a declaration by the city manager stating that he had placed the decision addressed to Donnellan in the mail on September 10, 1998. Donnellan conceded that he had received the decision soon after it was mailed to him, but argued that the city had not complied with the service requirements of section 1094.6; thus the 90-day limitations period never began to run. The city contended that it had substantially complied with section 1094.6 and that in any event Donnellan had received the written decision. The court in Donnellan first observed that section 1094.6 is a procedural limitations provision and is thus jurisdictional. Although statutes of limitations in general serve to prevent the assertion of stale claims that would be difficult to defend because of the passage of time, such technical defenses "should be strictly construed to avoid the forfeiture of a person's rights." (Donnellan v. City of Novato, supra, 86 Cal.App.4th at p. 1103.) The Court in Donnellan found that "the statutory language on its face requires the agency to include an affidavit or certificate of mailing when mailing the decision." (Donnellan, supra, at p. 1104.) The court continued: "The obvious purposes of the affidavit or certificate of mailing requirement of section 1094.6, subdivision (b), are to establish the fact of the date of mailing of the agency's decision, and to inform the party seeking the writ of the effective date of the mailing. Since subdivision (b) establishes that the 90-day period in which to file the writ petition is triggered only after the decision is mailed, proof of the mailing necessarily establishes, and informs the party of, the date the 90-day limitations period begins." (Id. at p. 1104.)