Category Archives: Municipal Ethics

Announcements, Fashion District BID, Municipal Ethics

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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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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Business Improvement Districts, Municipal Ethics

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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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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Business Improvement Districts, Municipal Ethics

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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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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Municipal Ethics, Skid Row Neighborhood Council

Tales From The BONC-Side Part 1: In Which Scott Gray And Debbie Welsch Of Capital Foresight Reveal Themselves As Whiny Ignorant Little Liars And John Howland, Formerly Of The Central City Association, Reveals That He May Be Whiny, He May Be Ignorant, He May Be Little, But He’s Not A Liar, At Least Not When He Would Violate LAMC §48.04(B) By Lying

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Background: You can read my previous stories on the Skid Row Neighborhood Council formation effort and also see Gale Holland’s article in the Times for a more balanced perspective.

As you may recall, I’ve been tracking the illegal lobbying carried out by and on behalf of various shady downtown zillionaires with the support and connivance of the staff of various downtown business improvement districts in opposition to the Skid Row Neighborhood Council formation effort. As part of their creepy conspiracy, the usual motley crew of zillionaires and zillionaire-identified-groupies showed up at the March 20, 2017 meeting of the Board of Neighborhood Commissioners (affectionately known as BONC) to speak what passes for their minds in zillionairelandia.

In the ordinary course of events, BONC posts audio of their meetings on the open internet, but, for whatever reason, when I took a look a few weeks ago, the March 20 meeting did not appear. After a few weeks worth of pleasant emails with various City employees, though, the audio has now been posted. I also published it on Archive.Org along with a copy of the minutes so you can follow along if you wish.

There’s a lot of interesting stuff in there, some of it inspiring, most of it horrifying in that special spine-tingly manner that glimpses into the seething caucasian-hot liquid id-core of the local politics of resentment are wont to horrify. I plan to write occasionally on episodes from this meeting, as the mood strikes, and today’s story concerns comments by Scott Gray and Debbie Welsch of shadowy zillionaire real estate conspiracy Capital Foresight,1 and shadowy lobbyist-to-the-zillionaires, John Howland.2

The gist of the matter is this, though. Debbie Welsch and Scott Gray told lie after lie, some of them beyond surreal in their fundamental disconnect with reality. On the other hand, John Howland, who at the time of the meeting was employed as a registered lobbyist with CCA, mostly, although he is quite an evil fellow indeed, told the truth. This is arguably less due to his inherent honesty than it is to the fact that registered lobbyists are required to sign a form upon registration acknowledging that they are aware of LAMC §48.04(B), which states that:

No lobbyist or lobbying firm subject to the requirements of the Article shall…[f]raudulently deceive or attempt to deceive any City official with regard to any material fact pertinent to any pending or proposed municipal legislation.

Anyway, after the break you will find embedded audio and transcriptions of the comments of all three of these dimwits, along with as much detailed mockery as I was able to type before I had to run off to the loo to eat lunch backwards​.
Continue reading Tales From The BONC-Side Part 1: In Which Scott Gray And Debbie Welsch Of Capital Foresight Reveal Themselves As Whiny Ignorant Little Liars And John Howland, Formerly Of The Central City Association, Reveals That He May Be Whiny, He May Be Ignorant, He May Be Little, But He’s Not A Liar, At Least Not When He Would Violate LAMC §48.04(B) By Lying →

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Municipal Ethics, Skid Row Neighborhood Council

Complaint Filed This Morning With City Ethics Commission About Liner Law’s Failure To Disclose So-Called United DTLA As Client. Also Matthew Nichols Appears To Have Lobbied Before Incorporation Of United DTLA, Possibly Requiring Disclosure Of Actual Human Clients As Well

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Last weekend I outlined what seem to be serious violations of the Municipal Lobbying Ordinance by registered lobbying firm Liner Law and its sleazeballs-for-hire Rockard J. Delgadillo and his creepy little sadly-not-imaginary playmate, Mr. Matthew T. Nichols in the course of the zillionaire downtown real estate cabal’s cowardly moronic greedheaded campaign against the Skid Row Neighborhood Council. Well, this morning I finished up an actual complaint on this matter and filed it with the Ethics Commission, and it is available on Archive.Org for your reading pleasure!

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.

Matthew Nichols monitoring a City meeting on SRNC formation on February 15, 2017, almost three weeks before United DTLA was even incorporated. This is potentially huge! Click to enlarge.
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.

And another newly uncovered bit of information is that both Delgadillo and Nichols not only attended the March 22, 2017 meeting of City Council’s Rules and Elections Committee, but they both spoke. Although Nichols didn’t say much. His entire speech is quoted in the cartoon that decorates the beginning of this post. As a special bonus for reading this far, turn the page for images of the speaker cards filled out by these two dimwits and also actual audio recordings of their comments!
Continue reading Complaint Filed This Morning With City Ethics Commission About Liner Law’s Failure To Disclose So-Called United DTLA As Client. Also Matthew Nichols Appears To Have Lobbied Before Incorporation Of United DTLA, Possibly Requiring Disclosure Of Actual Human Clients As Well →

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Municipal Ethics, Skid Row Neighborhood Council

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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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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Business Improvement Districts, Municipal Ethics

Kosmont Invoices For Gateway To LA BID Reveal How Much Time It Takes To Get A BID Renewed, And It Doesn’t Look Good For BID Consultants, Like Tara Devine, Like Urban Place Consulting, That Are Not Registered As Lobbyists With The City

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Larry Kosmont handled the Gateway to LA BID’s 2014-5 renewal and was, very properly, registered as a lobbyist while doing so.
You may recall that the Los Angeles Municipal Lobbying Ordinance requires qualified lobbyists to register with the City Ethics Commission and also disclose a bunch of interesting information about their clients and their income. Also, the process of establishing or renewing a BID is fairly complex, and most property owners’ associations1 hire a consultant to guide them through the process. These consultants are regulated and recommended by the City Clerk’s office.

The process of getting a BID established or renewed, it turns out, looks an awful lot like the definition of lobbying activity to be found at LAMC §48.02, which is essentially preparing information and discussing it with City officials as part of influencing the passage of municipal legislation. The law requires anyone who’s paid for thirty or more hours of this over three consecutive months to register as a lobbyist, and it’s generally extremely hard to prove that someone’s met this criterion. You may, e.g., recall that earlier this year, in order to make a reasonably convincing case that Venice Beach BID consultant Tara Devine had passed this threshold, I spent months piecing together more than a hundred pages of evidence regarding her BID consultancy work.

But recently it’s occurred to me that these consultants have contracts with the BIDs they service, and that at least in the case of BID renewals, the contracts will be accessible via the Public Records Act.2 The contracts will contain some information about how much time the consultants spend on the project, and thus should be useful as evidence in reporting consultants to the Ethics Commission for lobbying without a license.

The project started to produce results at the end of February, when the incomparable Laurie Hughes of the Gateway to LA BID supplied me with her BID’s contracts with Larry Kosmont, who was handling the renewal process.3 Well, late last week, Laurie Hughes gave me an absolutely essential set of documents, consisting of detailed monthly invoices from Kosmont to the BID during the 15+ month renewal process. These are fascinating,4 containing as they do detailed inventories of every individual task involved in the renewal process broken down into fifteen minute billing increments. Turn the page for more descriptions, discussion, and speculations.
Continue reading Kosmont Invoices For Gateway To LA BID Reveal How Much Time It Takes To Get A BID Renewed, And It Doesn’t Look Good For BID Consultants, Like Tara Devine, Like Urban Place Consulting, That Are Not Registered As Lobbyists With The City →

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Announcements, Municipal Ethics

New Documents: Lisa Trifiletti and Omar Pulido Emails, Wilshire Center BID And East Hollywood BID Emails To/From City Of LA From February 2017

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This is just a short note to announce three new sets of documents for your entertainment, your edification, and, if you’re interested, a little puzzle for you to solve.

First we have a couple of monthly sets of emails between BIDs and the City of Los Angeles. This turns out to be a useful request for keeping finger on pulse, often leading to unexpected discoveries, so I make it every month of all my favorite BIDs.1 Perhaps there are some lurking here:

And turn the page for the most interesting item of all for today!
Continue reading New Documents: Lisa Trifiletti and Omar Pulido Emails, Wilshire Center BID And East Hollywood BID Emails To/From City Of LA From February 2017 →

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Fashion District BID, Municipal Ethics

Urban Place Consulting Set To Earn $55,712.20 For Dealing With The 2017/2018 Fashion District BID Renewal Process According To Contract, Which May Also Shed Light On The Intersection Between BID Consultancy And L.A.’s Muncipal Lobbying Ordinance

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The Fashion District BID in Downtown Los Angeles is set to expire at the end of 2018. This means that they’ll be collecting petitions roughly in the first quarter of 2018 and going to City Council approximately in the Summer of 2018. The process is complicated for property-based BIDs and usually requires a consultant, and the consultant has to start early. The Fashion District is using Urban Place Consulting.1 Work began on the process in January 2017.

Thanks to the competence, kindness, and evident commitment to transparency of the Fashion District BID’s executive director, Rena Masten Leddy,2 we have copies of (at least most of) the FDBID’s contract with UPC3 as well as the first three months worth of invoices. You can get these:

Crucially, the contract reveals that the Fashion District will pay UPC more than $55,000 over the course of the two year process. The contract is supposed to include a schedule of hourly rates and the invoices are supposed to include an hourly breakdown, but, at least so far, they do not.

Apart from the general interest created by the essential role that BID renewal plays in the life cycle of BIDs, this kind of data is also crucial to my ongoing study of the intersection between the BID renewal process in Los Angeles and the Municipal Lobbying Ordinance. Turn the page for a brief discussion of those issues as well as a brief outline of the renewal process itself.
Continue reading Urban Place Consulting Set To Earn $55,712.20 For Dealing With The 2017/2018 Fashion District BID Renewal Process According To Contract, Which May Also Shed Light On The Intersection Between BID Consultancy And L.A.’s Muncipal Lobbying Ordinance →

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Business Improvement Districts, Los Angeles City Government, Municipal Ethics

Open Letter To Holly Wolcott And Miranda Paster Regarding Nicole Shahenian’s Violation Of LAMC 48.04(B) In 2014

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Here’s a letter I sent this morning to Holly Wolcott and Miranda Paster about the fact that East Hollywood BID Director Nicole Shahenian appears to have violated LAMC 48.04(B) by stating that the EHBID’s 2015 Annual Planning Report had been prepared at a Board meeting on December 29, 2014, when in reality no such meeting took place. Also maybe look at the actual complaint I filed with the Ethics Commission.

The main points are that the Clerk ought to institute some kind of oversight to make sure that this nonsense stops happening. The Ethics Commission will rule on Nicole Shahenian’s violation of the Municipal Lobbying Ordinance, but that only applies because she was coincidentally registered as a lobbyist in 2014. Most BID directors are not registered lobbyists,1 but many of them apparently lie about the APR approval process. This could potentially create dire consequences due to the fact that, e.g., BIDs can actually be disestablished for such transgressions, whether or not the Municipal Lobbying Ordinance is involved. Anyway, as I said, here is the letter as a PDF, and turn the page for a transcription.
Continue reading Open Letter To Holly Wolcott And Miranda Paster Regarding Nicole Shahenian’s Violation Of LAMC 48.04(B) In 2014 →

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