You may recall that a couple weeks ago I published a big stack of emails from the famed Los Feliz Village BID. Amongst these were this little gem of an email chain, wherein the entire Board of Directors of the LFVBID, over the course of about two weeks in May 2017, discuss some nonsense relating to something called Urban Air Market. The facts themselves are as tedious as can be but, as I noted previously, the Brown Act at §54952.2(b)(1) explicitly forbids this kind of thing:
A majority of the members of a legislative body shall not, outside a meeting authorized by this chapter, use a series of communications of any kind, directly or through intermediaries, to discuss, deliberate, or take action on any item of business that is within the subject matter jurisdiction of the legislative body.
Well, I’ve been so busy working on matters related to the revisions to the Municipal Lobbying Ordinance that’s presently being worked on by the Ethics Commission that I’ve barely had time to think of anything else. Yesterday, though, I needed a little break from lobbying and decided to take the time to write up a report to the LA County DA’s Public Integrity Division regarding this egregious violation. You can download a copy of the complaint or read a reasonably faithful transcription after the break.1
Continue reading How I Reported The Los Feliz Village BID To The LA County District Attorney’s Public Integrity Unit For Brown Act Violations
Tag Archives: Jeffrey Charles Briggs
A Bunch Of Emails Between The Los Feliz Village BID And The City Of Los Angeles Reveal A Number Of Interesting Issues, Not Least Of Which Is City BID Analyst Giving The BID Legal Advice On CPRA Requests Contrary To Holly Wolcott’s Position That This Does Not Happen
The other day I received a big pile of emails between the Board of the Los Feliz Village BID and people at the City of Los Angeles. They’re available here on Archive.Org. Note that the BID produced these by using some kind of bulk forwarding utility for Gmail to send these to their attorney, uniquely repetitive chair of the famed Hollywood Chamber of Commerce, Mr. Jeffrey Charles Briggs Esq.
Attorney Briggs then exported the forwarded emails as MSG files and passed them along to me. Unfortunately this process mangled the metadata and made it more trouble than it seems to be worth to sort and rename the files by date and time. Sr. Briggs seems to be willing at least to consider instructing his clients to provide actual exact copies of emails in the future, but for now we’ll work with what we got, especially since the whole process has taken more than six months to get to this point. Anyway, turn the page for discussion of a few highlights.
Continue reading A Bunch Of Emails Between The Los Feliz Village BID And The City Of Los Angeles Reveal A Number Of Interesting Issues, Not Least Of Which Is City BID Analyst Giving The BID Legal Advice On CPRA Requests Contrary To Holly Wolcott’s Position That This Does Not Happen
110 New Emails Between The City of LA And The East Hollywood BID Reveal Essentially Nothing About Anything, As Do The BID’s Bylaws — Also A Bunch Of Advertising Slash Branding Bullshit From The Fashion District Is Easy To Mock But Not So Informative After All
Ah, friends, just another desultory announcement of yet another batch of public records obtained from our friends at the BIDs, the meaning of none of which is yet clear, but we don’t let that worry us here in MK-dot-Org-landia. Everything happens for a reason, as they say, and I’m sure all this junk is no exception and some day it will prove to comprise crucially important pieces in puzzles whose very existence is as yet undiscerned. But for now I’m just announcing its existence, and do with it what you will. Anyway, here’s what I got:
- Emails between the East Hollywood BID and the City of LA — March 2017 through July 2017. There are 110 emails here, attachments are attached to the emails, it’s amazing how empty of content this batch is. About 84% of them consist of Nicole Shahenian trying to get people to use her new email at ehbid.org. I don’t know for sure but I’d bet money that she made this switch because of my CPRA requests. Also, Aram Taslagyan’s replacement as CD13 East Hollywood field deputy introduces himself herein, but I already forgot his name.
And turn the page for the rest of the junk and more random commentary!
Continue reading 110 New Emails Between The City of LA And The East Hollywood BID Reveal Essentially Nothing About Anything, As Do The BID’s Bylaws — Also A Bunch Of Advertising Slash Branding Bullshit From The Fashion District Is Easy To Mock But Not So Informative After All
In June 2017 The East Hollywood BID Board Of Directors Approved Minutes From Five Of Its 2016 Meetings. Here’s How I Think That Came About And Some Speculation On What It Might Mean
Maybe you remember that in March of this year I noticed that Nicole Shahenian, executive directrix of the East Hollywood BID, seems to have told the City of Los Angeles a lie with respect to the BID’s 2015 annual planning report.1 Briefly, the problem was that Shahenian submitted a letter to the City claiming that the Board had approved the report at its meeting of December 29, 2014, but my collection of minutes suggested that the Board had not met in December 2014.
This fact in itself seems to have some serious ramifications, my theories concerning which you can read all about in the original post. But the discovery of this ghost meeting led me to scrutinize my collection of EHBID minutes more closely. This closer look revealed that a number of meetings from 2016 seemed to have taken place but their minutes seemed never to have been approved by the Board. So in March 2017 I asked EHBID lawyer extraordinaire2 Jeffrey Charles Briggs Esq. for copies of all the ones that appeared to be missing.
Continue reading In June 2017 The East Hollywood BID Board Of Directors Approved Minutes From Five Of Its 2016 Meetings. Here’s How I Think That Came About And Some Speculation On What It Might Mean
New Documents! East Hollywood BID Quarterly Reports, Media District BID Emails, Media District BID Materials About Andrews International Security Switcheroo Including Emails, Draft Contracts, Price Matrices, And So On!
Yesterday I received a bunch of new records from Hollywood BIDboy attorney Jeffrey Charles Briggs, acting on behalf of the East Hollywood BID and also the Media District BID. Some of the stuff had to do with the Media District’s early renewal, which I wrote about yesterday, and today I’m mostly just announcing the balance of the material, which is available from our Archive.Org collections. In particular, we have:
- East Hollywood BID quarterly reports 2012-2016 — BIDs are required by their contracts with the City to submit quarterly reports with updates on how they’ve been spending their money.1 These are useful to have on hand for reference. There’s nothing in these that stands out right now, but I haven’t read them carefully yet nor even looked at all of them.
- Media District emails with the City of LA — And also a few from the Hollywood Property Owners Alliance folks, although nothing substantial. Again, it’s essential to have this material on hand for reference. There doesn’t seem to be much of special interest here, although there’s a lot more evidence of Rita Moreno’s uncharacteristically activist style as a BID analyst with the Clerk’s office, which is abstractly a good thing, although certainly she’s not going to be an activist if it upsets the BIDs too much.
- Media District emails about Andrews International Security contract — The Media District BID is in the process of hiring infamous private security monolith Andrews International as its security provider, to begin July 1. These are some emails about the process. The most interesting things here are the attachments, which include A/I’s standard contract as well as proposed pricing matrices and so on. Andrews International famously runs the infernal Hollywood BID Patrol for the even-more-infernal Hollwood Property Owners Alliance just North of the Media District, so everything about them is interesting. There is much more material to come regarding this matter, and I will write about it in detail as it comes in, but it’s essential enough that I thought I’d better publish what I had immediately.
So that’s the new stuff, all except for one little email which didn’t exactly fit into any of those categories. It appears to constitute attorney/client communications, and perhaps it was handed over in error. But legally handed over it was, so I’m publishing it, and you can see a copy and read all about it after the break!
Continue reading New Documents! East Hollywood BID Quarterly Reports, Media District BID Emails, Media District BID Materials About Andrews International Security Switcheroo Including Emails, Draft Contracts, Price Matrices, And So On!
Newly Obtained Documents Reveal That The Hollywood Media District BID Is Paying Urban Place Consulting $1,550.35 More Than The Fashion District BID Is Paying For Renewal Services Because UPC Is Billing Assistants At 20% More! Jeff Briggs Supplies Unredacted UPC Labor Matrix Without Requiring A Freaking Demand Letter! Aaron Aulenta Isn’t As Much Of A “Tech Dinosaur” As Previously Claimed!
You may recall that as part of my long term project to turn as many BID consultants as possible in to the City Ethics Commission for unregistered lobbying, I’ve been trying to track down consulting contracts and other such evidence. I obtained a lot of excellent information from the San Pedro Historic Waterfront BID and, after a prolonged struggle, chronicled in excessive detail here, I obtained an unredacted copy of Urban Place Consulting’s contract with the Fashion District BID.
In the course of that whole mishegoss I had to overcome FDBID executive directrix Rena Leddy’s ultimately untenable position that the so-called “labor matrix,” a chart which detailed how much time UPC meant to spend on each aspect of the BID renewal process and how much they were to be paid for it,1 was a trade secret. Among the many cogent arguments we used2 was the evident fact that labor costs couldn’t possibly be trade secrets because UPC would of necessity have to share them with prospective clients before a contract was signed. This was a purely logical argument, but now, thanks to a huge trove of records shared with me this evening by the Media District BID and relating to their renewal process, also being handled by UPC, I have definitive proof.
Continue reading Newly Obtained Documents Reveal That The Hollywood Media District BID Is Paying Urban Place Consulting $1,550.35 More Than The Fashion District BID Is Paying For Renewal Services Because UPC Is Billing Assistants At 20% More! Jeff Briggs Supplies Unredacted UPC Labor Matrix Without Requiring A Freaking Demand Letter! Aaron Aulenta Isn’t As Much Of A “Tech Dinosaur” As Previously Claimed!
Yet Another Example Of City Of LA Indifference To Illegal BID Shenanigans: City Clerk BID Analyst Rita Moreno Hands Out (Literal) Gold Stars To BIDs For Minimal Brown Act Compliance But Doesn’t Do Or Even Say Anything To BIDs Who Are Not Only In Violation Of The Law But Have Been Flouting It For Years On End
Yesterday evening, BID-lawyer-to-the-stars Jeffrey Charles Briggs passed along almost 200 emails between Media District BID executive director Lisa Schechter and various people at the City of Los Angeles. These are available en masse at Archive.Org. As always, there’s a lot of chaff in there and a few super-interesting things.1 Perhaps today’s story is an example of the latter.
It began on February 28, when Rita Moreno, newly of the Neighborhood and Business Improvement Division of the City Clerk’s office, the unit that’s meant to oversee the operations of BIDs and make sure that they follow the law and stuff, emailed a bunch of BIDdies to introduce herself and note that only a few of them had their meeting times posted on their websites. Of course, the Brown Act explicitly requires BIDs to notice their meetings on their websites,2 but that’s actually not why Rita was on about this. She was just trying to find out when they met so that she could attend. In fact, it’s not even clear that Rita Moreno knew about the Brown Act requirement.
However, the very next day, our old friend Lisa Schechter of the Hollywood Media District BID, who is not generally known for her law-abiding behavior but who has by now been educated by years of our intense scrutiny to the point where, I hope, she’s beginning to realize that it’s just easier to follow the law,3 wrote back to Rita Moreno, fishing for praise from this unlikely authority figure:
Dear Rita:
Just to reiterate, all of our meetings are posted in accordance with the Brown Act (Committee as well as Board) – Further you have been placed on our automatic distribution list which triggers and [sic] email directly to you for all of our meetings. If you should require any further information please do not hesitate to contact myself or our operations manager, Jim Omahen.
And, a couple hours later, Rita Moreno replied:
Yes…you got a star ★
And if you’re new to BID studies, you’re probably wondering why this puerile exchange is not just idiotic, sycophantic, and moronic, but also deeply offensive and discouraging to anyone who cares about the rule of law in Los Angeles. Well, read on!
Continue reading Yet Another Example Of City Of LA Indifference To Illegal BID Shenanigans: City Clerk BID Analyst Rita Moreno Hands Out (Literal) Gold Stars To BIDs For Minimal Brown Act Compliance But Doesn’t Do Or Even Say Anything To BIDs Who Are Not Only In Violation Of The Law But Have Been Flouting It For Years On End
Pacific Palisades BID Poised To Spend Almost 3% Of 2017 Assessments Fighting My CPRA Requests. Is This Really The Best Use Of Property Owner’s Money?? Also, Rick Lemmo’s Vow To Thwart Me By Proceeding “According To The Strictest Rules Of Law” May Reveal Hitherto Unsuspected Paradox In CPRA!!
In any case, whatever her manifold faults as a CPRA client may be, Laurie Sale, executive directrix of the Palisades BID, is at least a reliable source of minutes and agendas. You may recall that she was previously kind enough to send me the PPBID’s 2016 minutes and agendas, and this weekend she sent me the 2017 minutes and agendas through February. There’s some interesting stuff in there, primarily about street vending, which I will write on quite soon. The minutes also suggest that CD11 field deputy Sharon Shapiro2 is an actual member of the PPBID’s Board of Directors. I’ll be looking into this, not least because it’s reminiscent of Debbie Dyner Harris’s ill-fated attempt to nab a voting seat for CD11 on the Board of the Venice Beach Property Owners Association, which was slapped down ignominiously by City Attorney Mike Feuer as a conflict of interest.
But never mind that for now. The text for today’s sermon is this little slab of nonsense, found in the BID’s minutes for February 1, 2017:
BID received requests for public records – copies of meeting minutes, agenda, emails back and forth within the City, etc. from a gentleman who is requesting this from many BIDs. Elliot made a motion to retain attorney not to exceed $4,000. Rick seconded, all approved, motion carried. In the event that this person wants copies made, then we need to request payment. Rick motioned: “we don’t want to make it difficult for him, but to rather provide him every access to public records according to the strictest rules of law so that it doesn’t provide any financial detriment to the property owners of our business improvement district.” Susan seconded. Unanimously approved, motion carries.
Continue reading Pacific Palisades BID Poised To Spend Almost 3% Of 2017 Assessments Fighting My CPRA Requests. Is This Really The Best Use Of Property Owner’s Money?? Also, Rick Lemmo’s Vow To Thwart Me By Proceeding “According To The Strictest Rules Of Law” May Reveal Hitherto Unsuspected Paradox In CPRA!!
It Appears That East Hollywood BID Director Nicole Shahenian Lied To Los Angeles City Clerk Holly Wolcott About The Circumstances Of The Preparation Of The EHBID’s 2015 Annual Planning Report And, As Shahenian Was A Registered Lobbyist At The Time, Thereby Violated LAMC 48.04(B)
One requirement that the Property and Business Improvement District Law places on BIDs, found at §36650, is the submission of annual planning reports (“APRs”) to the City Council:
The owners’ association shall cause to be prepared a report for each fiscal year, except the first year, for which assessments are to be levied and collected to pay the costs of the improvements, maintenance, and activities described in the report. … The report shall be filed with the clerk … The city council may approve the report as filed by the owners’ association or may modify any particular contained in the report and approve it as modified.
And it seems that the BID isn’t allowed to spend money on stuff that’s not discussed in the APR, so it’s not a trivial matter.
The way this piece of code plays out in Los Angeles is that, first, a BID director submits the APR to the Clerk along with a formulaic cover letter. For instance, here is the one submitted by Nicole Shahenian on December 30, 2014 to accompany the East Hollywood BID’s APR for 2015. This is essentially the same letter submitted by all BIDs:
Dear Ms. Wolcott:
As required by the Property and Business Improvement District Law of 1994, California Streets and Highways Code Section 36650, the Board of Directors of the East Hollywood Business Improvement District has caused this East Hollywood Business Improvement District Annual Planning Report to be prepared at its meeting of December 29, 2014.
And don’t forget that state law requires the City Council to adopt the report either with or without modifications. In Los Angeles this part of the process is initiated by the Clerk sending another form letter to City Council, recommending that they adopt the BID’s APR. It’s my impression that the Clerk doesn’t recommend modifications to the report at this stage. These seem to be handled by Miranda Paster before the APR is submitted to Council, as in this example involving the Media District BID. Anyway, take a look at Holly Wolcott’s January 14, 2015 recommendation to City Council with respect to the East Hollywood BID’s APR. Like every such document, this states:
The attached Annual Planning Report, which was approved by the District’s Board at their meeting on December 29, 2014, complies with the requirements of the State Law and reports that programs will continue, as outlined in the Management District Plan adopted by the District property owners.
And it goes on from there to recommend:
That the City Council:
- FIND that the attached Annual Planning Report for the East Hollywood Property Business Improvement District’s 2015 fiscal year complies with the requirements of the State Law.
- ADOPT the attached Annual Planning Report for the East Hollywood Property Business Improvement District’s 2015 fiscal year, pursuant to the State Law.
But there are a number of problems with this story. First, it appears that the East Hollywood BID Board of Directors did not actually meet on December 29, 2014. In fact, it appears that they did not meet at all in December 2014. Of course, it’s notoriously difficult to prove a negative, but I’m going to give it a go.
Continue reading It Appears That East Hollywood BID Director Nicole Shahenian Lied To Los Angeles City Clerk Holly Wolcott About The Circumstances Of The Preparation Of The EHBID’s 2015 Annual Planning Report And, As Shahenian Was A Registered Lobbyist At The Time, Thereby Violated LAMC 48.04(B)
Documents, Documents, Documents! Emails From Wilshire Center And The Media District, Brentwood Village BID Meeting Minutes, East Hollywood BID By-Vendor Transactions
- 2016 emails between Wilshire Center BID, the City of Los Angeles, and Tara Devine
- Brentwood Village BID Board minutes
- East Hollywood BID by-vendor transaction reports
- Emails between the Media District, the City of LA, and the HPOA, December 2016 and January 2017
And you can turn the page for some comments on each of these sets of goodies.
Continue reading Documents, Documents, Documents! Emails From Wilshire Center And The Media District, Brentwood Village BID Meeting Minutes, East Hollywood BID By-Vendor Transactions