Tag Archives: Tara Devine

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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Venice Beach BID Still Not Operational Despite The Fact That Their Contract Was Attested More Than Two Months Ago — Mark Sokol Sent Out A Letter, Likely Ghosted By Tara Devine, Two Weeks Ago Begging For Patience And Donations And Offering A Freaking Unmonitored Email Account For Consolation!

It’s been a long, long year for the Venice Beach BID, friends. Last August they had their first hearing but due to generalized arrogance they messed up the process and so the City Attorney called a do-over, which happened last November. For undisclosed reasons it took until June of this year for their administration contract to get signed and as of today they still have not commenced operations.

And evidently the property owners are getting restless out there on the very West side, because on July 31, Mr. Venice Beach himself, Mark Sokol, sent out a letter to the property owners (transcription after the break) begging their forbearance, asking them if they had any office space to donate, and telling them they weren’t going to get any money back even if the BID didn’t start working until freaking December cause that’s the way they roll.

And if you have questions you’re welcome, according to this letter, to send them to admin@venicebeachbid.com even though, and I am not making this up, no one checks that account. Just as an aside, not in the letter, but you may have more luck with tara@venicebeachbid.com or marksokol@hotmail.com or mark@mphotel.com or carl@lambertinc.com or sheumann@sidewalkent.com. Property owners were also offered a chance to sign up for a mailing list, although signups seem to be closed now. Anyway, there’s a transcription after the break, and I’m not sure what it all means, but it seemed important to publish it.
Continue reading Venice Beach BID Still Not Operational Despite The Fact That Their Contract Was Attested More Than Two Months Ago — Mark Sokol Sent Out A Letter, Likely Ghosted By Tara Devine, Two Weeks Ago Begging For Patience And Donations And Offering A Freaking Unmonitored Email Account For Consolation!

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Apparently The City Attorney Of Los Angeles Has Opined That Business Improvement Districts Can’t Spend Money On Things That Aren’t In Their Management District Plans Unless The Plans Are Amended — At Least That’s What Shadowy BID Consultant Tara Devine Said In 2012 And Why Would She Lie About That?

When business improvement districts in California are created, it’s required by the Property and Business Improvement District Act of 1994 at §36622 to file a so-called management district plan (MDP) with the City. This is meant to describe exactly what the BID is going to spend its money on, and it’s incorporated into the City’s Ordinance of Establishment, by which means the BID is created. It must be approved by the City Council, and the City has the power to revise it at will. The law makes it pretty clear that BIDs are actually forbidden from spending money on activities that aren’t in the MDP, although this facet of the law is generally ignored by the City.

And I’m presently working on a project that requires a close reading of invoices submitted by Tara Devine1 to the South Park BID over the years, which I obtained last month as the fruit of a CPRA request.2 Although 2012 is outside the timeline I’m working on, I was fascinated to note that Tara Devine seems to have been engaged by the South Park BID to actually write that year’s annual planning report3 for them. One of the things that she billed for in the course of performing her contract to do so Tara Devine billed for was a conversation with accounting firm RBZ, since merged with Armanino, and the subject of that conversation was wholly new to me:
Continue reading Apparently The City Attorney Of Los Angeles Has Opined That Business Improvement Districts Can’t Spend Money On Things That Aren’t In Their Management District Plans Unless The Plans Are Amended — At Least That’s What Shadowy BID Consultant Tara Devine Said In 2012 And Why Would She Lie About That?

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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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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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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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Lobbying Firm Liner LLP And Lobbyist Matthew Nichols Seem To Have Violated The LA Muncipal Lobbying Ordinance While Working Against The Skid Row Neighborhood Council On Behalf Of Shady Delaware-Incorporated Anonymous Shell Corporation United DTLA And It Appears At Least Plausible That Rocky Delgadillo Did Also

The Los Angeles Municipal Lobbying Ordinance, known to the cognoscenti as the MLO and found at Article 8 of the LAMC,1 regulates professional paid lobbyists in the City of Los Angeles.2 It also regulates so-called lobbying firms, which are companies that employ lobbyists to lobby on behalf of paying clients.3

One requirement that the MLO puts on lobbying firms and lobbyists is registration with the City.4 In particular, it is required5 that:

A lobbyist or lobbying firm shall register each client on whose behalf or from which the lobbyist or lobbying firm receives or becomes entitled to receive $250 or more in a calendar quarter for engaging in lobbying activities related to attempting to influence municipal legislation.

Note also that you might rightly wonder if the Skid Row Neighborhood Council Formation process counts as “municipal legislation.” It does, but the reason’s a little technical.6 Also, note that Liner LLP is a lobbying firm and they filed the required registration form for 2017, listing all their clients. And, although Rocky Delgadillo is employed by Liner, he’s not registered as a lobbyist himself. However, when he wrote his famous letter to DONE advocating against the SRNC he wrote as a Liner employee.

It’s almost certain that Liner received the negligible sum of $250 from their client, United DTLA, for their services. According to the MLO,7 then, Liner is required to disclose “The client’s name, business or residence address, and business or residence telephone number” as well as “The item or items of municipal legislation for which the firm was retained to represent the client.” But look again at Liner’s registration form. There is nothing there about their client, United DTLA.

Naturally, though, it’s possible that lobbying firms might add clients after they file their annual registrations. In this case they registered on January 1, 2017, but certainly didn’t start representing United DTLA until around February and quite possibly not until March. The law has a procedure for this kind of thing:8

Lobbyists and lobbying firms shall file amendments to their registration statements within 10 days of any change in information required to be set forth on the registration statement.

Take yet another look at Liner’s registration form. You can see that it was amended on April 27, which is long after Liner’s representation of United DTLA began, but there is no mention of this client. This is the first likely violation of the MLO arising from Liner’s anti-SRNC work.
Continue reading Lobbying Firm Liner LLP And Lobbyist Matthew Nichols Seem To Have Violated The LA Muncipal Lobbying Ordinance While Working Against The Skid Row Neighborhood Council On Behalf Of Shady Delaware-Incorporated Anonymous Shell Corporation United DTLA And It Appears At Least Plausible That Rocky Delgadillo Did Also

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Urban Place Consulting Charged Palisades BID 62% Less For Establishment Than They Are Charging Fashion District For Renewal, $21K vs. $55K. The Resulting Linear Model Suggests That Each Additional Parcel Adds Around $18 To The Price Of BID Consultancy, But Comparison With San Pedro Casts Some Doubt On Accuracy

This chain of emails from December 2015 reveals that the Pacific Palisades Business Improvement District paid Urban Place Consulting $21,000 for guiding the establishment process and an additional $4,000 to the consulting engineer.1 This is yet another piece of the BID consultancy puzzle that I’ve been trying to decipher since it became clear that almost certainly BID consulting qualified as lobbying under the Municipal Lobbying Ordinance and that almost all of the qualified consultants were breaking the law by not being registered with the City Ethics Commission like, e.g., Tara Devine.2

And this small piece of evidence is especially valuable given the fact that by now it’s essentially impossible to coax records out of the Palisades BID. They’ve even hired a lawyer specifically to thwart my requests, as if the bred-in-the-bone intransigence3 of PPBID ED Laurie Sale, which presumably they’ve already paid for, weren’t enough in itself.

In particular, because we already knew that Urban Place was charging the Fashion District $55,000 for renewal consulting and because it’s the first time we’ve known the rates that a single consultant is charging two different BIDs, it’s possible for the first time to attempt to model UPC’s fee structure. The gory details are available after the break, but the upshot it’s possible to estimate that UPC’s baseline fee for establishing/renewing an ideal BID with zero parcels in it is about $19,583 and that each additional parcel adds a little more than $18 to the cost of establishing/renewing the BID.
Continue reading Urban Place Consulting Charged Palisades BID 62% Less For Establishment Than They Are Charging Fashion District For Renewal, $21K vs. $55K. The Resulting Linear Model Suggests That Each Additional Parcel Adds Around $18 To The Price Of BID Consultancy, But Comparison With San Pedro Casts Some Doubt On Accuracy

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The San Pedro BID Is Paying BID Consultant Edward Henning Only $20,000 To Handle Their Impending Renewal. This Is 64% Less Than The Fashion District Will Pay Urban Place Consulting And 75% Less Than The South Park BID Will Pay Tara Devine. Why The Huge Variation In Compensation For A Job Whose Elements Are Delineated By The City?

You may recall that Edward Henning is an engineer who works with a number of BID consultants on BID establishment and renewal, writing the engineer’s reports required by Streets and Highways Code §36622(n). I’ve previously reported, e.g., that he seems to get paid about $9,000 for writing these things.1 Well, TIL that Ed Henning is also a BID consultant his own self!

The story begins with Lorena Parker, executive director of the San Pedro Historic Waterfront BID, sending me the contract that Ed Henning and her BID signed for consulting services, along with some ancillary information:

These materials are also available on the Archive, which is useful because of OCR and so forth. And that’s today’s goodies. Turn the page for discussion!
Continue reading The San Pedro BID Is Paying BID Consultant Edward Henning Only $20,000 To Handle Their Impending Renewal. This Is 64% Less Than The Fashion District Will Pay Urban Place Consulting And 75% Less Than The South Park BID Will Pay Tara Devine. Why The Huge Variation In Compensation For A Job Whose Elements Are Delineated By The City?

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