Latest Episode In The Brown Act Enforcement Project Targets Studio City BID For Three Violations — Most Importantly They Require An ID And Permission From The BID To Attend Meetings — Also They Totally Screwed Up Closed Session Requirements — And Also They Deliberate Via Email Just Like The Byzantine BIDdies — So I Fired Off Another Demand Letter — Now We Wait Thirty Days To See If They Capitulate!

Last week I attended my first meeting of the Studio City BID‘s board of directors, and what a fiasco, friends! Aggressively clueless board member Matthew Dunn walking out because I was filming him and so on. But I put off telling you about the most interesting parts! Which is why I’ve gathered you all here this morning! You see, the BID violated the Brown Act in two very serious ways at the meeting.

First of all, the BID holds its meetings inside CBS Studio Center,1 It not only requires an ID to get in there and the registration of one’s name and an image of one’s driver’s license, but also convincing a hostile security guard who thinks BID meetings aren’t open to the public and some other problems. All together these are, of course, violations of the Brown Act at §54953.3, which states unequivocally that:

A member of the public shall not be required, as a condition to attendance at a meeting of a legislative body of a local agency, to register his or her name, to provide other information, to complete a questionnaire, or otherwise to fulfill any condition precedent to his or her attendance.

We’ve seen exactly this kind of thing with BIDs around the City, who hold their meetings in so-called secure buildings, where IDs are required by the property owners rather than the BID itself. E.g. in October 2014, the very same month I founded this blog, Kerry Morrison and her Central Hollywood Coalition were guilty of this. More recently, in April I reported the South Park BID to the LA County DA for violating this exact provision. The universal excuse seems to be that it’s legal for the property owner to require ID, just not the BID.

Of course, the plain language of the statute shows that that argument is entirely fallacious. The law doesn’t say anything about who’s not allowed to require ID, so therefore no one is allowed to require ID. And because, as you know, I haven’t gotten much if any satisfaction from the LA County DA on Brown Act violations, I have decided to take matters into my own hands and use the provisions in the law which allow private citizens to enforce it.

I kicked off this project last month with a demand to the Byzantine Latino Quarter BID which was entirely successful, at least so far, in that the BID caved entirely and unconditionally agreed never ever ever to violate the law again. And the Studio City ID and name registration requirement is a perfect test case for the enforcement of §54953.3. Thus did I fire off this demand letter to BID secretary Gilbert Stayner yesterday afternoon, making Studio City the honored second participant in my private Brown Act enforcement project. They have thirty days to capitulate, and if they don’t, we’re off to Superior Court!2

And Brown Act violations are like cockroaches in the usual cliched sense, and this case is no exception to that rule. The BID also seriously messed up its closed session, which of course I added to the demand, and there was a little problem in May 2018 involving them deliberating via email, which I also added. The first of these is highly technical and the second is fairly repetitious, so I put all the details after the damn break!
Continue reading Latest Episode In The Brown Act Enforcement Project Targets Studio City BID For Three Violations — Most Importantly They Require An ID And Permission From The BID To Attend Meetings — Also They Totally Screwed Up Closed Session Requirements — And Also They Deliberate Via Email Just Like The Byzantine BIDdies — So I Fired Off Another Demand Letter — Now We Wait Thirty Days To See If They Capitulate!

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Hollywood Media District BID, The Hapless Client Of Hapless Hollywood Superlawyer Jeffrey Charles Briggs, Actually Hands Over Thirty Thousand Actual Dollars To My Lawyer As They Were Ordered To Do By The Judge! — Commemorative Mug Issued For This Historic Occasion! — Get Yours Today! — Maybe This’ll Learn Some Of His Other Clients That They Oughta Just Gimme The Damn Records — Talking To You Los Feliz Village BID, East Hollywood BID, Historic Core BID, And, Believe It Or Not, The Media District BID All Over Again

Of course you remember in July 2018 when Superior Court judge Mary Strobel splained in terms that were anything at all but uncertain to Hollywood Superlawyer Jeffrey Charles Briggs that his client, the freaking Hollywood Media District BID, was going to have to pay my lawyer $30,000 in fees essentially because both they and their lawyer are a bunch of loserific morons?1

Anyway, since the ruling, Jeffrey Charles Briggs and, presumably, his clients, have been stumbling about the place not paying and mumbling semicomprehensible nonsense about how they were going to appeal, about perversions of justice,2 and so on, the upshot of all of which mumbling is that, by God, they weren’t gonna pay. But a court order is a scary, scary thing. So yesterday, September 26, 2018, they paid the damn money to my lawyer, the incomparable Colleen Flynn!

And in honor of their new-found, belated and, sadly, coerced, commitment to actually following the damn law and also to making it continue to be economically feasible for lawyers to help me encourage the City of Los Angeles and its damnable business improvement districts to actually follow the laws that regulate them, I have issued this commemorative coffee mug! Get yours today! And look at all the other mugs while you’re at the store!! And stay tuned for more BID news, as always!!
Continue reading Hollywood Media District BID, The Hapless Client Of Hapless Hollywood Superlawyer Jeffrey Charles Briggs, Actually Hands Over Thirty Thousand Actual Dollars To My Lawyer As They Were Ordered To Do By The Judge! — Commemorative Mug Issued For This Historic Occasion! — Get Yours Today! — Maybe This’ll Learn Some Of His Other Clients That They Oughta Just Gimme The Damn Records — Talking To You Los Feliz Village BID, East Hollywood BID, Historic Core BID, And, Believe It Or Not, The Media District BID All Over Again

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Bye Bye BIDdies! — City Of Los Angeles Finally Concedes The Street Vending Battle As Curren Price And José Huizar Move In Council Today To Instruct The City Attorney To Draft An Ordinance That’s Consistent With Lara’s Safe Street Vending Act

As you know the City of Los Angeles has been arguing over how to regulate street vending for pretty much forever now, with business improvement districts and chambers of commerce and other such-like weaponized implements of zillionaire-aligned white supremacy using every last bit of their political juice to introduce all kinds of complex conditions like opt-in districts, opt-out districts, permission from business owners, limitations on number of vendors per block, immediate confiscation of equipment, fees paid to BIDs, and on and on and on, all obviously designed for the sole purpose of continuing the wholesale arrest of street vendors.

But as I’m sure you also know just last week governor Jerry Brown signed Ricardo Lara’s Safe Street Vending Bill into law, severely limiting the power of cities to regulate vending. This bill has been working its way through the legislature since January 2018 and was well known to have an excellent chance of becoming law, and obviously voids pretty much every single feature of the City’s proposals, and yet nevertheless the City Council didn’t even start thinking about it officially until August.

But oh, they do have to think about it now. If the City doesn’t have an actual regulatory ordinance in place by January 1, 2019 they won’t have the power to regulate vendors at all. This, I guess, was enough to move them to action, and therefore this morning Councilmembers Curren Price And José Huizar introduced a motion in Council instructing the City Attorney to draft an ordinance that would comply with SB-946. The whole deal is memorialized in Council File 13-1493-S5.

And the BIDdies don’t have any leverage over this ordinance because state law compels all the essential features. This is a huge blow for our City’s business improvement districts and other nasty, selfish opponents of vending, and a huge win for humanity. We’re going to see some snakey creepy nasty rhetoric from the BIDs over this, you wait and see! Turn the page for the complete text of Price and Huizar’s motion.
Continue reading Bye Bye BIDdies! — City Of Los Angeles Finally Concedes The Street Vending Battle As Curren Price And José Huizar Move In Council Today To Instruct The City Attorney To Draft An Ordinance That’s Consistent With Lara’s Safe Street Vending Act

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Summer Of 2017 — Pacific Palisades BID Decides To Try To Collect Full Assessments From LAUSD — Which Does Not Pay Them To Any BID In Los Angeles — BID President Elliot Zorensky — His Burgeoning Paranoia In Full And Ample Abundance — Tells Laurie Sale That Miranda Paster Is Fighting Against The BID — And Also Goes Behind Laurie Sale’s Back To Negotiate With The City — Making Her Look Even More Foolish Than Even She Could Reasonably Pull Off Under Her Own Power

It’s well known to local BIDdologists that the Los Angeles Unified School District doesn’t keep pace with its companions amongst City entities, no doubt because it hears the beat of a distinctly different drummer.1 For instance we’ve seen recently how the LAUSD even voted against renewing a bunch of BIDs! Not only is it impossible to imagine the City of Los Angeles doing such a thing2 but it’s actually illegal for the City Clerk to vote against BIDs unless the City Council specifically authorizes it, and how is that ever going to happen?

And somewhat famously, the LAUSD evidently voids all its BID petitions by inserting some kind of unauthorized limiting clause. However, these symptoms of the LAUSD’s idiosyncratic attitude towards BIDs are minor quirks compared to the radical agenda set forth in this 2003 memo on LAUSD BID policy.

There’s a lot going on in that memo, but the first thing to look at is the fee schedule on the last page. The short version is that the LAUSD has unilaterally decided that it will not pay the entire amount of its BID assessments. Instead, they pay between 15% and 50% depending on a number of factors regardless of what the BID has decided to bill them.

And evidently BIDs around Los Angeles have just learned to slurp down that bitter draught, because what else exactly are they going to do about it? They have no power to make the LAUSD pay so they have to be content with what they can get rather than what they should get. That is, evidently most BIDs have so learned. The ones run by the marginally competent, the marginally sane, the marginally realistic, and so on. In short, the ones not run by Elliot Zorensky and Laurie Sale of the marginally famous Pacific Palisades BID.

And here is where today’s story begins! It seems that last summer this pair of super-geniuses, almost certainly at the behest of Elliot Zorensky, the superest super-genius of them all, decided that they were going to get that damnable LAUSD to pay the damn money that they damn well owed to the damn BID! Never mind that this was a path every other BID in this City of Angels feared to tread, Elliot Freaking Zorensky was going to rush in! Turn the page for the play by play!
Continue reading Summer Of 2017 — Pacific Palisades BID Decides To Try To Collect Full Assessments From LAUSD — Which Does Not Pay Them To Any BID In Los Angeles — BID President Elliot Zorensky — His Burgeoning Paranoia In Full And Ample Abundance — Tells Laurie Sale That Miranda Paster Is Fighting Against The BID — And Also Goes Behind Laurie Sale’s Back To Negotiate With The City — Making Her Look Even More Foolish Than Even She Could Reasonably Pull Off Under Her Own Power

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Chinatown BID Fails To File Answer To CPRA Writ Petition Before Deadline — Maybe George Yu Considers Himself Beyond The Reach Of The Law — Which Certainly Wouldn’t Be Uncharacteristic Of That Thuggish Little Weirdo

I mean I don’t know what it is with these thuggish little business improvement districts around Los Angeles. They won’t comply with the public records act and when I am thereby forced to file petitions against them they won’t even respond. This famously happened in May with that wonky little gang of white supremacists out in the Larchmont Village BID and now it just happened again with the Chinatown BID, due to the off-the-chain intransigence of which we were forced in August to file a petition.

Of course George Yu is well-known in these parts to be a screamer, a bully, and a freaking self-proclaimed criminal, so it’s not strange to learn that he doesn’t feel like he has to play by other rules of civil society. And for all that, the consequences of these failures may be minimal. In ordinary lawsuits if you don’t answer on time you just lose, but the California Code of Civil Procedure at §1088 rules out this result for writs of mandate, which is what we’re seeking. Also in July at the trial setting conference for the Larchmont BID petition, the judge granted the BID an extra 30 days to reply without them even having to explain their lapse.

So like I said, there may not be any consequences, or any serious consequences. But on the other hand there may be. We’ll see! Stay tuned and you can see also!
Continue reading Chinatown BID Fails To File Answer To CPRA Writ Petition Before Deadline — Maybe George Yu Considers Himself Beyond The Reach Of The Law — Which Certainly Wouldn’t Be Uncharacteristic Of That Thuggish Little Weirdo

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Jocelyn Duarte Wrote A Letter To Mitch O’Farrell Supporting Herb Wesson’s Anti-Gadfly Motion — In Fact It Was Her Kid Whose Ears Famously Got Covered Due To Armando Herman’s Foul Mouth — Duarte Is The Interim Executive Director Of The Salvadoran-American Leadership And Educational Fund — O’Farrell Staffie David Giron Is SALEF’s Vice President — Who Presumably Will Decide If Her Position Is Made Permanent — Astroturfing Much? — Daily Irony Supplement: A Bunch Of Angry Rich White People Disrupt Public Meeting — Scream At David Ryu About Homeless Shelters — Don’t Get Banned From Future Meetings — Let Alone Ejected From That One — Or Even Arrested For Violating §403 PC

Oh man, the whole damn city is buzzing over Herb Wesson’s latest attempt to use the U.S. and the California Constitutions as so much toilet paper just in order to score an ephemeral point or two against his nemeses Armando Herman and Wayne Spindler. Noted civil rights lawyer Stephen Rohde, who’s grown rich and fat from our City Council’s previous transgressions against freedom and decency, even had a piece in City Watch about it.

Kerry Morrison of the Hollywood Property Owners’ Alliance, who never met a fascist she didn’t worship the walking-on-ground of,1 predictably wrote an intensely stupid letter to the Times supporting Wesson. And the interim executive of the Salvadoran-American Leadership and Educational Fund, Jocelyn Duarte, famously had to cover her kid’s ears to keep out Armando Herman’s admittedly foul language and then she wrote this letter to Mitch O’Farrell begging him to think of the damn children.2

Herb Wesson famously solicited the letter from Duarte, just as this master of astroturfing famously solicits letters of support for all manner of his crackpot ideas.3 But this letter from Jocelyn Duarte is astroturfed in a whole different dimension. Take another look at the actual letter. See the board of directors on the left. Notice Mitch O’Freaking Farrell’s legislative director David Giron listed there. Note that Jocelyn Duarte is the interim executive director. And who else but David Giron and his board cronies is going to be filling the permanent position? Oh, of course, Mitch O’Farrell, who also never met a fascist he didn’t adore, seconded Wesson’s motion.

In one sense there’s nothing that shocking here. Our City’s council files are, it turns out, just full to the very rim with this kind of stage-managed illusion of popular support for every random whim of every random Council repster, submitted on demand in the hope of currying favor for God knows what sinister purposes. In another sense, it really is shocking, or at least interesting enough for me to keep writing about! Of course there’s a transcription of the letter after the break.

Before that, though, watch this video of a bunch of angry rich white anti-homeless people screaming at David Ryu last night to the point where he could no longer speak. See the cops standing around watching? No one’s getting clubbed, tased, banned from future meetings, arrested, or even ejected, which is amazing because, unlike saying “fuck” at a Council meeting, this kind of thing is actually a freaking crime.4 But of course these rich angry white people don’t bother Herb Wesson and the rest of them at all. No need to pass new laws against them or even to enforce existing ones. These angry rich white people make freaking campaign contributions!
Continue reading Jocelyn Duarte Wrote A Letter To Mitch O’Farrell Supporting Herb Wesson’s Anti-Gadfly Motion — In Fact It Was Her Kid Whose Ears Famously Got Covered Due To Armando Herman’s Foul Mouth — Duarte Is The Interim Executive Director Of The Salvadoran-American Leadership And Educational Fund — O’Farrell Staffie David Giron Is SALEF’s Vice President — Who Presumably Will Decide If Her Position Is Made Permanent — Astroturfing Much? — Daily Irony Supplement: A Bunch Of Angry Rich White People Disrupt Public Meeting — Scream At David Ryu About Homeless Shelters — Don’t Get Banned From Future Meetings — Let Alone Ejected From That One — Or Even Arrested For Violating §403 PC

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Two New Coffee Mugs! — One Featuring Angry Studio City Clown And Board Member Matthew Dunn! — Commemorating His Epic Freakout Slash Walkout! — The Other In Honor Of Councildude Gil Cedillo’s Propensity For Being All Things To All People! — Featuring An All New Never Before Seen Cartoon! Get Both Today!!

After Monday’s epic freakout by Studio City BID board member Matthew Dunn, in which he ended up storming out of his own meeting because he hates America, freedom, mom, apple pie, and the California Constitution, I was so moved that just merely writing this mocking post about the guy wasn’t enough to express my feelings. Hence I designed an entirely new coffee mug, which, as always, you can buy on the MK.Org CafePress store by clicking right here! It’s a perfect gift for commemorating birthdays, bat mitzvahs, retirements, involuntary commitments, every significant family occasion!

And while you’re at the store you should check out this other brand new mug! This one features Gil Cedillo and plays on his propensity for being all things to all people, talking up immigrant rights and radical Latino politics on the one hand while selling off the neighborhoods in his council district to developers who then price the present inhabitants right out of there. The cartoon appears at the head of this post!

And, as always, turn the page for links to the full-sized image files used to generate the mugs so you can see exactly what you’re spending your money on.
Continue reading Two New Coffee Mugs! — One Featuring Angry Studio City Clown And Board Member Matthew Dunn! — Commemorating His Epic Freakout Slash Walkout! — The Other In Honor Of Councildude Gil Cedillo’s Propensity For Being All Things To All People! — Featuring An All New Never Before Seen Cartoon! Get Both Today!!

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Studio City BID Board Meeting Spectacular! — Legally Captured On Video For Your Amusement And Edification! — Board Member And Angry Clown Matthew Dunn Flips Out At Being Filmed! — Throws Tantrum! — Storms Out! — Like A Whiny Damn Baby! — This Is The Kind Of Person The City Of Los Angeles Entrusts Its Public Funds To! — Pedantically Incompetent Flunky Damian Gatto Almost Violates The Brown Act! — Saved At Last Moment By Emmy-Winning Zeck Dreck John Walker! — A Fun Time For All! — Or At Least For Me!

Oh for goodness sake, friends! Day before yesterday I took an astonishingly complex combination of public transit routes out to the the wild and untamed-by-rule-of-law hinterlands of Studio City to attend my very first meeting of the board of directors of the Studio City BID. And Lord, what a scene! What a raving conglomeration of angry white men! I have a serious topic to write about with respect to this meeting, but there are some things I have to take care of first, so it’ll have to wait. Thus, tonight, you get a lighthearted highlights slash bloopers reel of some of the oh so crazy antics of these oh so crazy folks.

When I first arrived in the meeting room1 there were board packets at every seat at the table. Board packets everywhere! Additionally, incompetently pedantic flunky Damien Gatto was shuffling self-importantly about the place so I asked him to see a copy of the packet. Now, I don’t tend to ask BIDdies for any favors, because what’s the point? And this request for a board packet to look at was not asking for a favor. The Brown Act at §54957.5 requires any materials distributed to the board for a meeting to be made available to the audience immediately.2

Evidently pedantically incompetent flunky Damian Gatto never heard about this, though, because, says he, he’s only going to give me the minutes and the agenda, and not the financials cause, says he, they’re secret. So I said “why” and he said, in a performative demonstration of his pedantry, his incompetence, “because we don’t have to, that’s why.” Hmmm. Gotta love the intense commitment to public service evinced by this pocky little sucker on the public tit, eh?

Anyway, he then stumbled off to his lair where, I am guessing, he was set straight by Emmy-award-winning zeck dreck John Walker,3 because when he came back with the goodies they did, lo and behold and so on, include the top secret financials. You can read that toppest secretest board packet, complete with the ultra-toppest ultra-secretest financials that spotty little minion Damian Gatto did not want you to see by clicking right here!

Now, that’s all interesting, I’m sure, but by now it’s not news that these rampaging BIDdies don’t have the first clue how the Brown Act works.4 This little incident, though, was far, far from being the weirdest, lunatic-est, most-signifying-of-a-delusional-level-of-cluelessness-est, incident at this meeting. Those honoraria go to the bizarre little hissy pitched by board member Matthew Dunn who, it seems, doesn’t like to have his picture taken5 even though the right to record meetings is explicitly guaranteed by the Brown Act.6 Turn the page for details, links, and, of course, a transcription!
Continue reading Studio City BID Board Meeting Spectacular! — Legally Captured On Video For Your Amusement And Edification! — Board Member And Angry Clown Matthew Dunn Flips Out At Being Filmed! — Throws Tantrum! — Storms Out! — Like A Whiny Damn Baby! — This Is The Kind Of Person The City Of Los Angeles Entrusts Its Public Funds To! — Pedantically Incompetent Flunky Damian Gatto Almost Violates The Brown Act! — Saved At Last Moment By Emmy-Winning Zeck Dreck John Walker! — A Fun Time For All! — Or At Least For Me!

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SB 946, Ricardo Lara’s Safe Street Vending Bill, Signed Into Law By Governor Jerry Brown Yesterday! — This Is A Huge Victory For Human Beings In California Over The Dark Forces Of Money, Racism, And Weirdo Puritanical White Privilege — Also A Huge Slap-Down For The BIDs Of Los Angeles, Who Evidently Don’t Control Everything

It has been a long and exciting eight months since Ricardo Lara introduced SB 946 in order to limit the ways in which cities in California are allowed to regulate street vending. Yesterday, thank goodness, it was signed into law by Jerry Brown. The preamble1 is a powerful statement of the value that street vendors bring to our City and to other cities around the state:

SECTION 1. (a) The Legislature finds and declares all of the following:

(1) Sidewalk vending provides important entrepreneurship and economic development opportunities to low-income and immigrant communities.

(2) Sidewalk vending increases access to desired goods, such as culturally significant food and merchandise.

(3) Sidewalk vending contributes to a safe and dynamic public space.

(4) The safety and welfare of the general public is promoted by encouraging local authorities to support and properly regulate sidewalk vending.

(5) The safety and welfare of the general public is promoted by prohibiting criminal penalties for violations of sidewalk vending ordinances and regulations.

(b) It is the intent of the Legislature to promote entrepreneurship and support immigrant and low-income communities.

The law reads as if it were written explicitly in response to the weirdo racist antics of the business improvement districts of Los Angeles, displayed during their years-long struggle to keep street vending illegal here. Also, this law completely moots the ridiculous regulatory framework that the City of Los Angeles has been struggling with for years on end, riddled as it’s become with hyperspecific carve-outs meant to appease this or that BID.2

It’s really informative to compare this law with this set of proposals made earlier this year by the Central City Association, which speaks exclusively for the BIDs and zillionaires of Los Angeles. For instance, the CCA and the BIDs want to limit vendors to two per block face. But the law says:3

A local authority shall not restrict the overall number of sidewalk vendors permitted to operate within the jurisdiction of the local authority, unless the restriction is directly related to objective health, safety, or welfare concerns.4

The CCA and the BIDs want to require vendors to obtain property and/or business owner consent. As we’ve seen, this kind of restriction is really easily exploitable to function as a de facto ban. The law says:5

A local authority shall not require a sidewalk vendor to first obtain the consent or approval of any nongovernmental entity or individual before he or she can sell food or merchandise.

And turn the page for more comparisons as well as the full text of the law.
Continue reading SB 946, Ricardo Lara’s Safe Street Vending Bill, Signed Into Law By Governor Jerry Brown Yesterday! — This Is A Huge Victory For Human Beings In California Over The Dark Forces Of Money, Racism, And Weirdo Puritanical White Privilege — Also A Huge Slap-Down For The BIDs Of Los Angeles, Who Evidently Don’t Control Everything

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Victory!! — Byzantine Latino Quarter BID Totally Caves To My Brown Act Demand Letter! — Unequivocally Abject Submission On The Part Of The BID! — BID Issues Unconditional Commitment Never Ever Ever To Violate The Brown Act By Deliberating In Secret Via Email! — If They Do I Get To File Suit Against Them Without Notice! — Yay!

Last month, faced with an unending series of violations of the Brown Act by the business improvement districts of Los Angeles and an astonishing unwillingness of the LA County DA to do anything about it, I kicked off a private enforcement project by sending a demand letter to the Byzantine Latino Quarter BID, which had been discussing BID business in secret by email in flagrant violation of §54952.2(b).1

The process I’m using relies on the Brown Act at §54960.2, which requires a government agency, such as a BID, to respond within thirty days to such a demand with an unequivocal commitment never to break the law again or else to face a petition asking a judge to declare that they did indeed break the law.

And I was indeed poised to file against the BID if they didn’t cooperate with the process, but it turns out not to be necessary! Yesterday afternoon I received this letter, signed by BID president Leonardo Magaña, caving in to every last one of my2 demands! Of course this is by far the wisest course for the BID to take.

They’re not required to admit guilt, although they were guilty beyond any level of doubt. They’re just required to promise not to break the law in the future. Why wouldn’t they promise this given that it immunizes them from a lawsuit?

The only catch for them is that if they do violate this section of the Brown Act again I can file a petition without warning them first. And don’t worry, I will do exactly that! Turn the page for a transcription of the BID’s unconditional abject capitulation!
Continue reading Victory!! — Byzantine Latino Quarter BID Totally Caves To My Brown Act Demand Letter! — Unequivocally Abject Submission On The Part Of The BID! — BID Issues Unconditional Commitment Never Ever Ever To Violate The Brown Act By Deliberating In Secret Via Email! — If They Do I Get To File Suit Against Them Without Notice! — Yay!

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