Tag Archives: LAMC 52.34

November 2016 Email From Suzanne Holley To Officer Eugene Shin Confirms That The Downtown Center BID’s Security Guards Were Already Registered With The Police Commission, Proving Yet Again That Major Criminals Strictly Follow Minor Laws To Divert Attention Away From Their Serious Transgressions

Here’s a brief summary of the background: Late last year, on the basis of my complaint to the Police Commission, the City of LA resumed enforcement of LAMC 52.34 against BID security forces.1 Since then I’ve been tracking the progress of this massive project via various CPRA requests. In November 2016 the Police Commission informed all BIDs of the registration requirement. In December 2017 the Police Commission told the BIDs to quit whining and comply with the law.

Yesterday, after numerous failed attempts on her part,2 Suzanne Holley of Carol Schatzie’s baby-doll of a Downtown Center BID, sent me a bunch of emails between her staff and the LAPD. You can get all of these at Archive.Org in various useful formats.3 Amongst these was yet another copy of Eugene Shin’s email to all BIDs directing them to get their security patrols registered with the Police Commission.

But much more interesting than that was DCBID Executive Directrix Suzanne Holley’s response, sent precisely 59 minutes later, informing Eugene Shin that…well, I’ll let Suzanne Holley tell you in her own words, right after the break!
Continue reading November 2016 Email From Suzanne Holley To Officer Eugene Shin Confirms That The Downtown Center BID’s Security Guards Were Already Registered With The Police Commission, Proving Yet Again That Major Criminals Strictly Follow Minor Laws To Divert Attention Away From Their Serious Transgressions

February 2, 2017 Email From Eugene Shin Of The LA Police Commission To Nicole Shahenian Of The East Hollywood BID Confirms Continued Progress Of BID Patrol Registration Project But Leaves Unanswered Question Of Whether Or Not The EHBID Has A BID Patrol

You may recall that late last year, on the basis of my complaint to the Police Commission, the City of LA resumed enforcement of LAMC 52.34 against BID security forces.1 Since then it’s been possible to track the progress of this massive project via various CPRA requests. So in November 2016 the Police Commission informed all BIDs of the registration requirement and, at the same time, told them that their BID patrollies would be subject to arrest if they didn’t submit. In December 2017 the Police Commission told the BIDs to quit whining about it because the law is the law.

Well, just yesterday, as part of a larger release of records from the East Hollywood BID, I discovered a February 2017 email from Eugene Shin to Nicole Shahenian. Eugene Shin, as you may recall, is the Police Commission investigator that’s heading up the registration project. Nicole Shahenian is the Executive Director of the East Hollywood BID. The email confirms that not only is registration still ongoing, but that the Police Commission is pursuing it fairly aggressively. Turn the page for a transcription and some discussion.
Continue reading February 2, 2017 Email From Eugene Shin Of The LA Police Commission To Nicole Shahenian Of The East Hollywood BID Confirms Continued Progress Of BID Patrol Registration Project But Leaves Unanswered Question Of Whether Or Not The EHBID Has A BID Patrol

Newly Obtained Email From November 2016 Reveals That LAPD Threatened Non-Compliant BID Patrol Officers With Arrest For Failing To Register With Police Commission In Accordance With LAMC 52.34

Recall that in June 2016 I sent a petition to the Police Commission asking them to clarify why BID security guards were not registered in compliance with LAMC 52.34. In October I learned that the City Attorney agreed that BID security was subject to the registration requirement and that steps would be taken to get BIDs to comply.

In January 2017 I obtained a December 1, 2016 email from Police Commission investigator Eugene Shin confirming that the registration process was ongoing. In that email Officer Shin hinted that he’d received a bunch of complaints about the new registration policy from BIDs. This, in turn, suggests that he or someone had sent an earlier communication about registration. I do not yet have copies of any of the complaints, bitching, and moaning, although I’m certainly working on getting them. However, just yesterday, as part of a significant email release from the FCBID1 I received this November 29, 2016 email from Eugene Shin to all the BIDs, announcing that their security guards would have to register. This seems to be what caused the firestorm of unhappiness hinted at in the December 1 email.

There is a full transcription of this fascinating document after the break, and it’s well worth reading. But the most interesting bit of all is this threat, with which Eugene Shin ends his missive:

Failure to register and obtain the permits may result in criminal charges being filed against the security company and citations or arrests of their security officers.

Reading that is almost, but not quite, enough to make me sympathize with the BIDs. After all, they’d managed to go 16 years without complying with the law and all of a sudden they’re being threatened with having their security guards ARRESTED if they don’t register? It’s a hard world for law-abiding citizens, friends! As I said, turn the page to read the whole email if you don’t like PDFs.
Continue reading Newly Obtained Email From November 2016 Reveals That LAPD Threatened Non-Compliant BID Patrol Officers With Arrest For Failing To Register With Police Commission In Accordance With LAMC 52.34

Email From Police Commission Definitively Confirms Ongoing Registration of BID Security, Procedure Includes Individual Background Checks of BID Patrol Officers!

BID Security has been flipping off the Los Angeles Police Commission for the last 16 years, but that is most definitely over now!
I reported a couple months ago that as a direct result of my June 2016 petition to the Police Commission, BID Security would be required to abide by LAMC 52.34 and register with the City like all other private security patrol operators must do. At that time I had only the oral assurance1 of Police Commission enforcement officer Ernesto Vicencio that this was the case.

However, just this evening, as part of ongoing production of responsive materials to my recent CPRA request to the good old Hollywood Media District BID, I received a copy of this December 1, 2016 email from Eugene Shin of the Police Commission to every freaking BID in the City telling them that yes, as a matter of fact, they do have to obey the law. He mentions that he has “received numerous emails and voicemails and I feel this is the most efficient way to answer your questions.” And I just bet the tone was not joyous and grateful!2 Anyway, it’s important to have independent written confirmation that this registration is actually going to happen. Shin also makes it clear that the registration process involves individual background checks of every BID security officer, which is absolutely fabulous news. Turn the page for excerpts if you’re PDF-averse.
Continue reading Email From Police Commission Definitively Confirms Ongoing Registration of BID Security, Procedure Includes Individual Background Checks of BID Patrol Officers!

VICTORY!! All Los Angeles BID Security Patrols To Register With Police Commission Per City Attorney, BID Patrol Excessive Force Complaint Under Investigation By LAPD; Direct Result of MK.Org Reporting!

Earlier this afternoon I spoke with Ernesto Vicencio, who is an LAPD investigator assigned to the Police Commission. He told me that the City Attorney either has sent or will soon send a letter to all Los Angeles Business Improvement Districts informing them that their security patrols are required to register with the Los Angeles Police Commission per LAMC 52.34.

This incredibly welcome development is a direct result of my discovery in the Summer of 2016 that it was likely that BID security registration had inadvertently ceased in 2000 due to an oversight. I don’t believe I mentioned it at the time, but in addition to writing a number of posts on the subject, I also sent a petition to the Police Commission asking them to look into the matter and to conclude that BID security ought in fact to register with them.

According to Officer Vicencio the City Attorney has decided to implement this request.1 This development is hugely important, not least because LAMC 52.34 requires private patrol services to have a procedure for investigating citizen complaints. It also grants the Police Commission a great deal of regulatory power over the activities of security patrols who are required to register.

Which brings us to the second stunning and absolutely unexpected thing that Officer Vicencio told me. You may recall that I recently reported on what seemed like a clear use of excessive force by members of the Andrews International Hollywood BID Patrol. Well, about three weeks ago I submitted a report on this matter to Kerry Morrison of the HPOA and also to the Police Commission, as instructed by the Commission’s executive director, Richard Tefank.

Today Vicencio told me that he is handling this matter. He has tried, without success so far, to locate the victim, and he is going to investigate further. Obviously there’s no guarantee that any of these officers will suffer any consequences,2 but again, the larger implications of the fact that they’re being investigated by the City are huge. This means that the Police Commission agrees that they have jurisdiction over citizen complaints against BID security. This changes everything.
Continue reading VICTORY!! All Los Angeles BID Security Patrols To Register With Police Commission Per City Attorney, BID Patrol Excessive Force Complaint Under Investigation By LAPD; Direct Result of MK.Org Reporting!

Audio Recordings of Three City Council Public Safety Committee Meetings from 1999 and 2000 May Shed Further Light on BID Patrol Police Commission Registration Issues

Former Los Angeles City Council Member Laura Chick (right).
Former Los Angeles City Council Member Laura Chick (right).
Through the good graces of Los Angeles City archivist Michael Holland I recently obtained recordings of three meetings of the Public Safety Committee of the LA City Council from 1999 and 2000 at which the issue of BID Security registration with the LA Police Commission was discussed. If you’ve been following the story you’ll recall that LAMC 52.34 seems to require that BID security register with the Police Commission, and that they do not so register, and that no one seems to know why. I copied the entire Council file on the issue but the reason is still not clear. These meetings may shed some light on what’s going on. There’s a brief guide to one of them after the break.
Continue reading Audio Recordings of Three City Council Public Safety Committee Meetings from 1999 and 2000 May Shed Further Light on BID Patrol Police Commission Registration Issues

Further Speculation on Why BID Patrols Aren’t Registered with the Los Angeles Police Commission

This is not a police officer, it's unregistered-with-the-police-commission BID Patrol officer M. Gomez (Badge #148) looking a lot like a police officer.
This is not a police officer, it’s unregistered-with-the-police-commission BID Patrol officer M. Gomez (Badge #148) looking a lot like a police officer.
Recently I discovered that BID security contractors weren’t registered with the LA Police Commission and that no one seemed to know why. Further investigation suggested that perhaps registration had just fallen through the cracks. Well, after rereading the material from the Council file and requesting and receiving the Police Commission minutes from April 25, 2000, I noticed that there was at least one possibly significant difference in the April 25, 2000 version of LAMC 52.34 that the Commission sent over to the Council on April 27 as compared to the version that the City Attorney sent to the Council on March 31 and that it’s possible to make some kind of a case that this difference answers the BID security question. It’s not a likely case, though. Read on for details on both the potential argument and some potential objections to it.
Continue reading Further Speculation on Why BID Patrols Aren’t Registered with the Los Angeles Police Commission

Council Votes to Repeal Unconstitutional Street Sleeping Ordinance, Which Maybe Has Implications For BID Security Registration with Police Commission

Your civil liberties at work.
Your civil liberties at work.
Today the LA City Council repealed LAMC 85.02, which prohibited sleeping in cars, and which the Ninth Circuit found to be unconstitutional in 2014 (even though the BID Patrol never seems to have gotten the message). The Council File is here, and the most interesting part is the the City Attorney’s report explaining why they ought to repeal the law.

Here’s a possibly wack but superficially plausible theory of why this situation might lend independent support to the idea that BID security actually ought to register with the Police Commission.
Continue reading Council Votes to Repeal Unconstitutional Street Sleeping Ordinance, Which Maybe Has Implications For BID Security Registration with Police Commission

Update on the Question of Why BID Security Patrols Aren’t Registered with the Los Angeles Police Commission

Richard Tefank, Executive Director of the LA Police Commission.
Richard Tefank, Executive Director of the LA Police Commission.
I have some new information about, although not an answer to, the question, which I wrote about last week, of why BID security patrols aren’t registered with the Los Angeles Police Commission even though LAMC 52.34 would seem to require registration. If this is the first time you’re hearing about this, you should read that post first for background.

First of all, I exchanged a number of emails with William Jones, a senior management analyst with the LAPD permit processing section. He directed me to Officer Vicencio in the Police Commission’s Enforcement section. Vicencio was on vacation last week, but I finally got a chance to speak to him on the phone. He told me that BID Patrols were exempt from the LAMC 52.34 requirement because state law exempted them. He did not know what section of state law exempted them. He also told me that “about fifteen years ago” the City Attorney issued an opinion stating that BID Patrols were not subject to the registration requirement. He said that any private security firm that was under contract to the City or had an MOU with the City was not required to register.
Continue reading Update on the Question of Why BID Security Patrols Aren’t Registered with the Los Angeles Police Commission

Lots of Pictures of BID Patrol Officers Illegally Dressing Like Police Officers

BID Patrol officer M. Gomez (Badge #148) looking a lot like a police officer.
BID Patrol officer M. Gomez (Badge #148) looking a lot like a police officer.
One of the most important consequences of the Andrews International Hollywood BID Patrol’s failure to register with the Los Angeles Police Commission, as they’re almost surely required to do, is that they evade enforcement of LAMC 52.34(d)(1), which regulates uniforms and badges. It states:

Any badge, insignia, patch or uniform used or worn by any employee, officer, member or associate of a private patrol service, while on duty for said patrol service, shall be in compliance with State law. Any such badge, insignia, patch or uniform shall not be of such a design as to be mistaken for an official badge, insignia or uniform worn by a law enforcement officer of the City of Los Angeles or any other law enforcement agency with jurisdiction in the City.

BID Patrol Officer Ki Nam (Badge #131, on right) looking a lot like a police officer.
BID Patrol Officer Ki Nam (Badge #131, on right) and an as-yet-unidentified BID Patrol officer, looking a lot like a police officer.
In this post I’m collecting and discussing a number of images of BID Patrol officers looking especially like police (all these images and many more can be found on this new Archive collection). The only differences between BID Patrol uniforms and LAPD uniforms seem to be that the LAPD doesn’t always wear shoulder patches and the LAPD does wear nameplates. However, the LAPD is not the only Los Angeles agency that employs law enforcement officers.
Los Angeles Airport Police Officers, wearing shoulder patches and looking an awful lot like BID Patrol officers.
Los Angeles Airport Police Officers, wearing shoulder patches and looking an awful lot like BID Patrol officers.
There are also the School Police and the Airport Police1 and both of those agencies have uniforms with shoulder patches, and to which BID Patrol uniforms are also essentially identical. It’s true that the uniforms of BID Patrol officers say “BID PATROL” in big letters across the back, but many police uniforms say stuff across the back. For this message to have the requisite effect, it’s necessary to already know that BID Patrol officers aren’t a kind of police. Also, the Hollywood Property Owners Alliance is famous for worrying about tourists who don’t know that they don’t have to tip street characters. Where’s the analogous worry about tourists who don’t know that the BID Patrol aren’t police officers? Turn the page for many more examples.
Continue reading Lots of Pictures of BID Patrol Officers Illegally Dressing Like Police Officers