Tag Archives: LAMC 48.07

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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United Downtown LA Paid Liner LLP More Than $45,000 To Lobby Against Skid Row Neighborhood Council In Q2 2017. Payments From First Quarter Are Still Undisclosed

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 may recall that shady downtown municipal lobbying firm Liner LLP was hired by the even shadier anonymous Delaware incorporated United Downtown LA to lobby against the Skid Row Neighborhood Council formation effort and that I turned them in to the City Ethics Commission for failing to amend their disclosure forms to disclose United Downtown as a client as required by LAMC §48.07.

Well, yesterday was the filing deadline for Second Quarter disclosures, and Liner filed theirs on time. It’s required by law for lobbying firms like Liner to disclose their clients and also how much money they got paid by each client. This time they actually did list United DTLA1 and it turns out that they were paid a stunning total of $45,010.40 to lobby against the SRNC. And this is just for Q2.2 It’s likely, or at least possible, that when the Ethics Commission gets around to investigating my complaint they’ll find that Liner was paid even more in Q1.

Oh, and check out the address that they put on the form for United Downtown. That’s Liner’s address. Full-service anonymization going on. That this much money was spent to stop a neighborhood council suggests that the NC system is really badly broken somehow.
Continue reading United Downtown LA Paid Liner LLP More Than $45,000 To Lobby Against Skid Row Neighborhood Council In Q2 2017. Payments From First Quarter Are Still Undisclosed

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The Central City Association Seems To Have Failed To Amend Its Lobbying Entity Registration Form In A Timely Manner And John Howland Didn’t Disclose The Fact That He Lobbied The Board Of Neighborhood Commissioners Against The Skid Row Neighborhood Council. So I Filed A Complaint With The Ethics Commission About It

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.

A few days ago I wrote a post about the fact that the Central City Association was involved in the lobbying effort against the Skid Row Neighborhood Council and briefly noted a few violations of the Municipal Lobbying Ordinance I’d noticed with respect to CCA’s disclosure of this fact. Today I completed and submitted a report on this matter to the City Ethics Commission. Here’s a copy:

There are two main issues: First, the MLO requires lobbying firms1 to (a) register every year, (b) disclose the issues they’re lobbying for on their registration forms, and (c) amend their registrations within 10 days of a change in the information. The CCA began lobbying against the SRNC no later than March 20, 2017, when John Howland appeared before the Board of Neighborhood Commissioners and spoke on the issue. Thus they should have amended their registration form no later than March 30. But they did not do so until April 28.
Continue reading The Central City Association Seems To Have Failed To Amend Its Lobbying Entity Registration Form In A Timely Manner And John Howland Didn’t Disclose The Fact That He Lobbied The Board Of Neighborhood Commissioners Against The Skid Row Neighborhood Council. So I Filed A Complaint With The Ethics Commission About It

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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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New MK.Org Coffee Mug Honoring Leron Gubler And The Hollywood Chamber Of Commerce For Being Extra Super Duper Law Abiding, Also Tons Of New Fashion District BID Emails

My recent post about the Hollywood Chamber of Commerce and its lobbying disclosure activity was so popular, or at least the picture that accompanied the post was so popular, that, effectively although not actually by popular demand, we here at MK.Org created yet another souvenir gift mug, an accessory with which you too can tell the world that you’re opposed to bad BIDness in Los Angeles and also is very handy for the drinking of coffee and other hot beverages! We here at MK.Org feel that this item has the potential to outsell our current bestselling item, the Blair Besten anti-CPRA award mug. Help us make that dream come true, friends!

Turn the page for link to newly obtained emails from the Fashion District.
Continue reading New MK.Org Coffee Mug Honoring Leron Gubler And The Hollywood Chamber Of Commerce For Being Extra Super Duper Law Abiding, Also Tons Of New Fashion District BID Emails

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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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