A business improvement district (BID) in Los Angeles1 is a geographical area in which the owners of commercial property are assessed an additional fee for various services that aren’t provided by the City. These fees are collected either by the City of L.A. via direct billing2 or, more usually, by the County of Los Angeles as an add-on to property tax bills.
The state law authorizing BIDs requires each BID to be administered by a property owners’ association (POA).3 In the normal course of things these organizations are conjured up by the City at the time the BID is established, although sometimes previously existing nonprofits will end up as a POA. One example of this is the Hollywood Chamber of Commerce, which serves as POA for the East Hollywood BID, although it predates its existence.
Well, dang, friends! How time does fly! It seems like only yesterday that we here at MK.Org secret headquarters were sitting around the metaphorical fire just mocking away at Hollywood Hotel über-düber-Führer Jeff Zarrinnam’s weirdo plans to rebrand-slash-restyle East Hollywood as Ee-Ho or some such nonsense. But in fact, it has been almost a month.
Greetings, friends! If you’ve been wondering what you were going to do this morning after finishing off the Times crossword5 here are a bunch of new public records for your reading pleasure. There’s no single document here that’s mind-blowingly important, but, as I have mentioned many and many a time, we all are strong believers around here in the Mosaic Theory of Intelligence Gathering, and these are just more puzzle pieces, some of them quite important qua puzzle pieces!6
Assorted Fashion District Emails 2017 — These are emails to/from people at the Fashion District BID and various other correspondents. There are no real blockbusters here compared to, e.g., last month’s momentous release of Skid Row Neighborhood Council emails, but there is some interesting stuff. Perhaps most interesting is this set, which includes a bunch of conspiratorial nonsense from the Central City Association as well as a detailed report-out from the BID’s Board retreat in March. This latter document will certainly turn out to be essential in at least one project I’m pursuing in relation to lobbying by BIDs, a sadly and almost surely illegally unregulated activity.
But there is some interesting stuff in there, including some highly suggestive, although unfortunately inconclusive, clues to the real-life identities of whoever is behind the shadowy “entity,” United Downtown LA, incorporated on March 3, 2017 in that notorious paradise of corporate anonymity, the state of Delaware. For instance, there are a number of emails from Scott Gray, director of operations of the shadowy real estate zillionaire conspiracy known as Capital Foresight.
Capital Foresight is famous for its putatively adaptive reuse projects on Skid Row, and thus is highly interested in the project approval process. A Skid Row Neighborhood Council would ostensibly have some clout with the City,9 and that could well threaten big-dollar projects in Skid Row, of which Capital Foresight has many. Thus did Scott Gray tell the Downtown News that the SRNC would be “a huge symbolic blow against growth and development,” although it’s probably not symbolism that he’s worried about.
If you read my earlier article most of this material will be familiar to you, but there’s at least one major new thing, which only occurred to me yesterday. Recall that according to Delgadillo and Nichols, the client who was paying them to oppose the Skid Row Neighborhood Council was a shady anonymous Delaware-incorporated LLC known as United DTLA. According to Delaware state records, United DTLA was incorporated on March 3, 2017.
This means that if and when Liner, Matthew Nichols, and Rockard Delgadillo file their required client disclosures for lobbying that they carried out after March 3, they’re going to disclose nothing more than United DTLA, that shady anonymous Delaware corporation. However, that shady anonymous Delaware corporation did not exist on February 15, 2017, on which day Matthew T. Nichols attended a Town Hall meeting about the Skid Row Neighborhood Council sponsored by the Department of Neighborhood Empowerment. And according to the definition of “lobbying activity” found in the Municipal Lobbying Ordinance at LAMC §48.02, the following is included:
… attending or monitoring City meetings, hearings or other events.
So if Matthew Nichols was carrying out compensated lobbying activities on February 15 but his putative client wasn’t even conjured into existence until March 3, he’s going to have to disclose someone other than United DTLA. And what’s the chance that this other client will be anonymous? Very low, I’m guessing, since if the zillionaires already had an anonymous entity through which to hire lobbyists, why would they go and invent a new one a few weeks later? I suppose we’ll find out, although don’t hold breath, friends. The Ethics Commission moves slowly, but it certainly does move.
The Los Angeles Municipal Lobbying Ordinance, known to the cognoscenti as the MLO and found at Article 8 of the LAMC,10 regulates professional paid lobbyists in the City of Los Angeles.11 It also regulates so-called lobbying firms, which are companies that employ lobbyists to lobby on behalf of paying clients.12
One requirement that the MLO puts on lobbying firms and lobbyists is registration with the City.13 In particular, it is required14 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.15 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,16 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:17
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.
Last night a panel consisting of three neighborhood council presidents from around the City heard General Jeff’s appeal of the election that defeated the Skid Row Neighborhood Council separation from DLANC last month. You can read the whole appeal here, including DONE boss Grayce Liu’s recommendations to the panel. The gist of it is that someone sent around an email that looked like it came from DLANC urging people to vote against the SRNC. If this had been a candidate for a neighborhood council office this evidence would have been enough to incur sanctions from the City based on the rules in the official election manual.
As it was, though, the panel unambiguously recommended that DONE either hold another election without the exceedingly contentious online voting that was unaccountably allowed in this election.18 Note that you can also read a less impressionistic version of this story than mine by Gale Holland, writing in this morning’s Times.
The meeting was well-attended and the level of interest and excitement was high. Unfortunately I had to leave after only three hours, long before anything was decided, but what I did see was well worth the trip. Most exciting was the public comments, which, at least while I was there, were all but one in favor of Skid Row. They were insightful, heartfelt, moving, convincing, enough to restore understandably flagging faiths in democracy. The one guy who was against the new NC was…well, his comments are summarized in the image that appears at the start of this post. It may seem like a joke, but it was not.
Friends, in my role as investigative journalist I put myself in a lot of dangerous situations for the sake of finding out and publishing the truth. But TBH, the most frightened I ever am in this job is when a story takes me down to the mean streets of South Central Hollywood. There’s no scarier place in this City, friends.
Just for instance, starvation is evidently rampant in this racially segregated food desert, as evidenced by the fact that I regularly see adult human beings weighing less than 90 pounds, running through the streets in what appears to the trained anthropological eye to be sheer terror. The fact that they’re mostly women just goes to show that the patriarchal social norms prevalent in South Central Hollywood lead the men to withhold scarce and expensive food from their females, whom they see purely as chattels.
And I’m not kidding about scarce and expensive. Last time I foraged for food in South Central Hollywood I ended up being charged $22.95 for a California Roll, something which can be obtained in more fortunate parts of the City for about $3. And it only had six slices! It’s well-known, of course, that hunger brings on the kind of hopelessness that makes people with nothing to lose, no future that they can see, attack randomly. So I’m always cautious in South Central Hollywood! But nothing can keep me from reporting the truth.
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.20 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.21
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 intransigence22 of PPBID ED Laurie Sale, which presumably they’ve already paid for, weren’t enough in itself.