Tag Archives: LAMC 48.02

In Defense Of A Change To A Compensation-Based Threshold For Lobbying Registration In Los Angeles

I wrote yesterday about a troubling meeting of the Ethics Commission concerning revisions to the Municipal Lobbying Ordinance. The proposals are still very much in flux, and timely public comments are not only essential for swaying the wavering commissioners in the right direction, but the commissioners, no matter their other flaws, do seem to read them, so they’re likely to be effective if submitted over the next couple of months.1

I had planned to write a letter to the Commission about all the issues together and publish it here as well, but the more I think about it the more I have to say. Thus I thought it would be much easier for everyone if I wrote about one issue at a time and then edited the posts down into a single letter to the Commission. Also, maybe you’ll find some of my ideas useful in framing your own letters, which should be sent to ethics.policy@lacity.org.

This post, then, is the first installment of that project, and the subject is the proposed change from a time-based registration requirement to a compensation-based requirement. If you have no idea what I’m talking about, you’re surely not alone. Turn the page for an introduction to the issue and arguments in favor of making the change.
Continue reading In Defense Of A Change To A Compensation-Based Threshold For Lobbying Registration In Los Angeles

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In Which I Present A General Argument That BID Consultancy Is Lobbying Activity In Order To Simplify And Regularize The Process Of Reporting BID Consultants To The Ethics Commission For Failure To Register

It’s a long term project of mine to turn in as many BID consultants as possible to the City Ethics Commission for failing to register as lobbyists. So far, though, I’ve only managed to report Tara Devine for her work on the Venice Beach BID because the work is so involved. Such a report has two essential components:

  1. An argument that BID consultancy satisfies the definition of lobbying activity found in the the Municipal Lobbying Ordinance at LAMC §48.02.
  2. An argument that a specific BID consultant was paid for sufficiently many hours over sufficiently few months to trigger the registration requirement found in the MLO at LAMC §48.07(A).

It occurred to me recently that the first argument will be the same for all BID consultants, and that therefore it would be possible to streamline the reporting process by writing it up in a generic format that would apply to any given BID consultant. So that’s what I did, and you can read the result here. I will be using this to make a number of complaints against BID consultants in the near future, which I will report on here.

Meanwhile, if you have no idea what I’m talking about, you can find explanations of everything after the break, along with a fairly detailed summary of the argument that BID consultancy qualifies as lobbying under the MLO.
Continue reading In Which I Present A General Argument That BID Consultancy Is Lobbying Activity In Order To Simplify And Regularize The Process Of Reporting BID Consultants To The Ethics Commission For Failure To Register

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Massive Document Dump Concerning Shadowy BID Consultant Tara Devine — What Has She Been Up To Since Destroying Venice Beach And How She Is Probably In Way More Trouble Than Anyone Thought With Respect To Not Having Registered As A Lobbyist

Yesterday I took a little trip South on Flower Street to the dark horse Death Star of downtown, the South Park BID, to look over some public records that they’ve been holding out on since January 2017 and only coughed up because my lawyer can beat up their lawyer.1 I found a hot mess of, among many, many problems, bizarrely damaged emails printed to PDF in random order with unintelligible OCR, missing attachments, purposely scrambled pages, and misnamed and poorly divided files. It’s going to take quite a while to put this nonsense into any kind of useful state,2 but I know a lot of my readers are wondering what’s up with shadowy BID consultant Tara Devine,3 so I thought I’d get the information concerning her up as fast as possible, even though it’s not yet in an ideal format.

That’s the big news, and you can turn the page if you’re in the mood for more detail and discussion. Note, though, that I’ll be posting about this material again once I get it revised into a more useful form.
Continue reading Massive Document Dump Concerning Shadowy BID Consultant Tara Devine — What Has She Been Up To Since Destroying Venice Beach And How She Is Probably In Way More Trouble Than Anyone Thought With Respect To Not Having Registered As A Lobbyist

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Liner LLP And United DTLA Weren’t The Only Zillionaires Gunning For The Skid Row Neighborhood Council: On April 28, 2017, The Central City Association Amended Its Lobbyist Registration With The City Ethics Commission To Disclose Its Work Against The SRNC

Background: You can read my previous stories on the Skid Row Neighborhood Council formation effort and also see Jason McGahan’s article in the Weekly and Gale Holland’s article in the Times for more mainstream perspectives.

We’ve done a lot of reporting on lobbying efforts against the Skid Row Neighborhood Council formation effort, but until today it has focused entirely on Liner LLP, its ethics-free-zone-for-hire-in-human-form Rockard Delgadillo, and the probably illegal campaign they waged against the SRNC on behalf of their shadowy anonymous client United DTLA.

This morning, however, I discovered that that infamous Schatzian horror show, the Central City Association of Los Angeles, was also involved in the lobbying effort against the SRNC. It’s not possible from the evidence to tell when they entered the fray, but amended registration forms filed with the City Ethics Commission prove that it was no later than April 28, 2017.1 Here’s the documentary evidence, and you’ll find more detailed descriptions along with some discussion after the break:

Continue reading Liner LLP And United DTLA Weren’t The Only Zillionaires Gunning For The Skid Row Neighborhood Council: On April 28, 2017, The Central City Association Amended Its Lobbyist Registration With The City Ethics Commission To Disclose Its Work Against The SRNC

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On March 20, 2017 Fashion District BID Exec Direc Rena Leddy and CCEA Exec Direc Estela Lopez Had A Conference Call With Unregistered-As-A-Lobbyist Liner LLP Partner Rockard Delgadillo To Discuss The Skid Row Neighborhood Council

The first part of the quote in Rockard Delgadillo’s mouth is from 2006 when he was hypocritically suing Rockstar Games, makers of Grand Theft Auto, for some Easter egg porn. Now he’s producing and starring in zillionaire porn. Just goes to show… The text in the box is from a poem by Charles Bukowski.
Background: You can read my previous stories on the Skid Row Neighborhood Council formation effort and also see Jason McGahan’s article in the Weekly and Gale Holland’s article in the Times for more mainstream perspectives.

You will certainly, if you’ve been following the issue, recall the fact that the zillionaire-sponsored effort to subvert by any means necessary the Skid Row Neighborhood Council formation effort was in full bloom by early 2017. And the Downtown BIDs were deeply involved in the whole mishegoss. In January, Blair “I don’t know nothin’ ’bout no Brown Act compliance” Besten of the Historic Core BID, Estela Lopez of the Downtown Industrial District, and furtive hereditary downtown zillionaire Michael Delijani were meeting with their sorry little Councilboy, encouraging him to ignore both law and decency in his effort to stop the SRNC.

By March, as we’ve seen, the zillionaires had formed an anonymous Delaware LLC known as United DTLA and hired walking morality-free-zone and former Los Angeles City Attorney Rockard Delgadillo to lobby the City against the SRNC. March 20, 2017 was a milestone day in the campaign. On this day, Fashion District BID executive directrix Rena Leddy began sending out emails to the property owners in her district to rally them against the SRNC. She sent this one out at 11:44 a.m.. At 12:24 p.m. she sent this one out, complete with a copy of Rockard Delgadillo’s infamous letter to the Department of Neighborhood Empowerment, which is the locus classicus of the arguments which ultimately prevailed over the SRNC.

Rena Leddy’s calendar entries for March 20, 2017, showing 11 a.m. conference call with Estela Lopez and Rockard Delgadillo. Click to enlarge.

And today, thanks to the fruits of a Public Records Act request for the 2017 appointment calendars of everyone in the Fashion District BID,1 I’m able to extend our knowledge of the events of that fateful day back 45 more minutes to 11 a.m. Take a look at Rena Leddy’s appointments for March 20, 2017. See that at 11 a.m. she had a conference call with Rockard Delgadillo and Estela Lopez for a “Skid Row Neighborhood Council update.” And, as we’ve seen, right after this, Rena Leddy commenced to rallying her troops against the SRNC.
Continue reading On March 20, 2017 Fashion District BID Exec Direc Rena Leddy and CCEA Exec Direc Estela Lopez Had A Conference Call With Unregistered-As-A-Lobbyist Liner LLP Partner Rockard Delgadillo To Discuss The Skid Row Neighborhood Council

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First The San Pedro BID Hated The Car Show. Then The San Pedro BID Loved The Car Show. Then The San Pedro BID Lobbied The City On The Car Show’s Behalf. But To Keep The BID’s Love The Car Show Had To Agree To Typically Coded Typically Racist Cultural Conditions: No Hip Hop. No Rap Music.

Once upon a time in 2016 an organization called Hot Import Nights was going to host a car show in Downtown San Pedro. This would seem to be a natural fit, since San Pedro is nestled between such motorhead meccas as Torrance and Gardena and Carson and Long Beach, famed hot spots of both formal and informal Southern California car culture due not in small part to the feverish and innovative automotive, aerospace, and marine manufacturing activities centered in the subregion for more than a century at this point.

But if there’s a BID in the woodpile they’re going to have an opinion, either puritanical, stupid, or both, on any proposed activities within their jurisdiction, whether it’s any of their concern or not. And it’s well-known to those who know it well that Downtown San Pedro is cursed by being chronically subject to the tender mercies of the San Pedro Historic Waterfront BID. And thus it is no surprise that the BID weighed in on the car show. And it’s no surprise that they hated it. It’s exactly the kind of thing that knee-jerk puritanical real estate minions will hate.

But what is a surprise is that they changed their little minds and came to love it. They loved it so darn much that they signed an MOU with it and agreed to lobby the City on its behalf. But there’s no such thing as a free lunch and white supremacy will exact payment for any favors it bestows. In exchange for the BID’s aid and comfort, the car show had to agree not to play any rap music or hip hop at their event, and a bunch of other, as weird but possibly less racist, conditions as well.

This unreasoned, or at least publicly unreasoned, hatred for all things insufficiently caucasian, is for whatever reason, a signature element of BIDolatry in the City of Los Angeles. Over the years we’ve uncovered, e.g., the fact that the Hollywood Property Owners Alliance really, really hates Chicano-associated art genres as well as music that attracts dark-skinned patrons. The freaking HPOA even hates Peruvians if they seem like they’re getting too comfy in Hollywood.

These weird, crypto-racist attitudes are not just the province of our frenemies at the HPOA. They are evidently shared by BIDs all over the City. Thus it’s really no surprise to find that the San Pedro BIDdies are a bunch of cultural crypto-racists as well. But, as always, it’s still surprising, still disconcerting, to see the details figured plain as though upon a lighted screen. Turn the page for the story in detail with extensive documentation!
Continue reading First The San Pedro BID Hated The Car Show. Then The San Pedro BID Loved The Car Show. Then The San Pedro BID Lobbied The City On The Car Show’s Behalf. But To Keep The BID’s Love The Car Show Had To Agree To Typically Coded Typically Racist Cultural Conditions: No Hip Hop. No Rap Music.

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Hundreds Of Emails Between Melrose BID And The City Of LA Include (1) Definitive Proof That Executive Director Don Duckworth Violated The Municipal Lobbying Ordinance In 2013 But Unfortunately The Statute Of Limitations Has Effectively Run And (2) More Brown-Act-Violating Bylaws That No One At The Clerk’s Office, For Shame, Seems To Have Even Noticed

Donald Duckworth, who runs both the Westchester Town Center BID and the Melrose BID, is slow but, it seems, pretty steady about fulfilling my incessant CPRA requests. And thus, just yesterday I received from him four jumbo-sized mbox files just chock-full of gooey email goodness! This batch comprises 2016 emails between the City of LA and the Melrose BID, and can be found in various useful formats here on Archive.Org.

I will be writing about various items in this document dump soon enough,1 but today I just want to focus on a couple of interesting items, supplied to me as attachments to some of these emails and cleaned up a little for ease of reading.2 Here’s the short version, and you can find details and the usual ranting mockery after the break:

  • Melrose BID Formation Project Hourly Charge Breakdown — Don Duckworth not only runs the Melrose BID, he was also the consultant who oversaw its establishment, for which he seems to have been paid $80,000 by the City. This is a detailed breakdown of his hours and charges over the course of the project formation. If you’ve been following my ongoing project, aimed at turning in BID consultants for not registering as lobbyists,3 you’ll recognize how astonishing and how important this document is. Unfortunately Don Duckworth’s work on this project wound down in the Summer of 2013, which means that the four year statute of limitations for violations of the Municipal Lobbying Ordinance has essentially run out. The document will be endlessly useful, though, in estimating time spent by consultants on their other projects.
  • Melrose Business Improvement Association bylaws — The Melrose Business Improvement Association is the property owners’ association that administers the Melrose BID. These are their bylaws. I discovered recently that the freaking Larchmont Village BID had bylaws that directly contradicted the Brown Act. Now it turns out that the Melrose BID has precisely the same problem. It’s possible that Larchmont Village changed their ways, but so far, anyway, there’s no reason to suspect that Melrose has done.

Continue reading Hundreds Of Emails Between Melrose BID And The City Of LA Include (1) Definitive Proof That Executive Director Don Duckworth Violated The Municipal Lobbying Ordinance In 2013 But Unfortunately The Statute Of Limitations Has Effectively Run And (2) More Brown-Act-Violating Bylaws That No One At The Clerk’s Office, For Shame, Seems To Have Even Noticed

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The Hollywood Chamber Of Commerce Amended Its Lobbying Registration Form in April 2017 And The Only Change Was The Date They Qualified — More Interesting, Though, Is The Fact That They Consider Their Pro-Establishment Advocacy For Jeff Zarrinnam’s Inchoate Hollywood-Western And Route 66 BIDs To Be Lobbying Activity

It’s well-known that the Municipal Lobbying Ordinance requires lobbyists of all stripes to register with the City Ethics Commission. The Hollywood Chamber of Commerce is no exception to the rule.1 They are also required to amend their registration forms if there are any material changes in the information provided.2

And as you know if you follow this blog, I find everything to do with lobbyists in Los Angeles fascinating, and thus I haunt the Ethics Commission’s lobbying pages, poring over the alphabetical lists of individual lobbyists and of lobbyist firms and employers to see if anything’s changed or if something is newly interesting.

And lo! Last night I noticed that our old friends, the Hollywood Chamber of Commerce, had amended their registration form on April 28. Here are the two forms:

Well, I stared and stared and stared at those two forms just trying to figure out what had changed. Eventually I noticed that the original form had January 31, 2017 as the date they’d qualified as a lobbying entity3 whereas the amended version had January 1, 2017 as the day of qualifying.

One of the Hollywood Chamber’s registration forms superimposed on the other with 38% opacity so that it’s clear that the only difference is in the qualifying date. Click to enlarge, of course.

There’s a lot of information on the forms, though, and I didn’t feel confident that the difference I’d noticed was in fact the only difference. I wasn’t sure what do to until this morning, when it occurred to me that if I put both pages into the GIMP, superimposed one on top of the other, and then faded the opacity up and down I’d be able to notice what changed.4 And it turns out that in fact, it’s correct that the only change was the date of the Hollywood Chamber’s qualifying as a lobbyist.

Which leads irresistibly to the question of why Leron Gubler and/or Nicole Shahenian, who are the Hollywood Chamber’s two registered lobbyists, felt the need to make this tiny change. Read on for speculations and some other chit-chat about the fact that Leron Gubler lists the establishment of the Hollywood Western and the Route 66 BIDs as issues the Chamber is lobbying for this year.
Continue reading The Hollywood Chamber Of Commerce Amended Its Lobbying Registration Form in April 2017 And The Only Change Was The Date They Qualified — More Interesting, Though, Is The Fact That They Consider Their Pro-Establishment Advocacy For Jeff Zarrinnam’s Inchoate Hollywood-Western And Route 66 BIDs To Be Lobbying Activity

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The Fascinating Story Of How It Took Three Months And A Demand Letter From An Attorney To Get Rena Leddy To Disclose That The Fashion District BID Is Paying Steve Gibson Of Urban Place Consulting $215 Per Hour For BID Renewal Consulting, Which Is Less Than Larry Kosmont Gets But More Than Ed Henning

Late last year it occurred to me that BID consultants, who help BIDs with the City processes necessary to establish or renew a BID, are essentially engaging in lobbying activity as defined in the Municipal Lobbying Ordinance at LAMC §48.02 and yet none of them1 seemed to be registered with the Ethics Commission as required by LAMC §48.07(A).

I then spent months piecing together over 100 pages of evidence to show that BID consultant Tara Devine had violated this law. Subsequently it occurred to me that the contracts that the consultants sign with BIDs would provide essential evidence that they’d been acting as lobbyists, so I determined to request these from many renewing BIDs. This led me to the discovery, thanks to the incomparable Laurie Hughes of the Gateway to LA BID, that GTLA’s BID consultant, Larry Kosmont, actually was registered as a lobbyist and had disclosed his BID consultancy as lobbying in his required reporting. The San Pedro BID is also up for renewal, and has recently released a fairly complete set of BID renewal records.

This brings us to the Fashion District. On February 21, 2017 I emailed Rena Leddy to request, among other material:

… all records associated with the renewal process, including but not limited to communications between the BID and the consultant and/or the engineer, contracts with and invoices from the consultant or the engineer, materials prepared by the consultant or the engineer for the renewal process, databases and mailing lists prepared or used by the consultant or the engineer, and also any communications between the consultant and the engineer that aren’t already responsive to the first part of this request.

The story of what happened after that stretched out over three months and generated many many megabytes of discussion. Read on for a (far too) detailed and exceedingly well-documented narrative recounting, complete with a happy, happy ending!
Continue reading The Fascinating Story Of How It Took Three Months And A Demand Letter From An Attorney To Get Rena Leddy To Disclose That The Fashion District BID Is Paying Steve Gibson Of Urban Place Consulting $215 Per Hour For BID Renewal Consulting, Which Is Less Than Larry Kosmont Gets But More Than Ed Henning

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Relatively Complete Set Of Records Pertaining To Ongoing San Pedro Historic Waterfront BID Renewal Process Reveals Hitherto Unknown Details About Costs, Hours, Contract Terms, Etc. Heralding Plausible Case Against Edward Henning For Failure To Register As A Lobbyist But Not, Unfortunately, Against The BID Because They’re Not Paying Him Enough

Last month I learned that the San Pedro BID was paying Edward Henning $20,000 to handle their BID renewal process. This discovery was independently interesting, but also important for my ongoing research project of learning everything possible about BID consultancy with the ultimate goal of shopping as many BID consultants to the City Ethics Commission as possible, mostly for violations of LAMC §48.07, which requires that “[a]n individual who qualifies as a lobbyist shall register with the City Ethics Commission within 10 days after the end of the calendar month in which the individual qualifies as a lobbyist.”

In this clause, someone “qualifies as a lobbyist” when they, according to LAMC §48.02 are “compensated to spend 30 or more hours in any consecutive three-month period engaged in lobbying activities.”1 Note that today I’m mostly skipping the argument that BID consultancy qualifies as lobbying activities, but you can read about it in excruciating detail here.

Part of the evidence that I obtained last month were these two invoices from Edward Henning to the SPHWBID. As you can see, they span the time period from March 2016 through December 12, 2016 and bill for a total of 75 hours. That’s roughly 7.5 hours per month if distributed evenly across the billing period. This is not enough evidence to show that Edward Henning was required to register. In fact, if he did work about 7.5 hours a month he would not have been so required.

It’s precisely that issue that today’s document release shines some light on. The other day, San Pedro BID executive directrix Lorena Parker was kind enough to send me over 100 emails to and from Edward Henning.2 At first I thought I’d be able to pick out 3 consecutive months in which Edward Henning was compensated for 30 hours by assuming that the number of emails in a month was proportional to the number of hours worked. This didn’t pan out for a number of reasons, not least because I don’t yet have emails between Edward Henning and the City of LA that weren’t CC-ed to Lorena Parker. I can tell from internal evidence that there are some of these,3 and I have a pending CPRA request for them, but they’re not yet in hand.

Read on for more detail on the unregistered lobbying case as well as a new theory that I thought at first might actually get the BID itself in some trouble rather than just the consultant. I don’t think it’ll work out in this particular case, but it has interesting implications for the future. Bad scene for the BIDdies and lulz4 all round for humanity!
Continue reading Relatively Complete Set Of Records Pertaining To Ongoing San Pedro Historic Waterfront BID Renewal Process Reveals Hitherto Unknown Details About Costs, Hours, Contract Terms, Etc. Heralding Plausible Case Against Edward Henning For Failure To Register As A Lobbyist But Not, Unfortunately, Against The BID Because They’re Not Paying Him Enough

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