Tag Archives: Bradley & Gmelich

Business Improvement Districts, Municipal Ethics

How I Reported Shadowy BID Consultant Tara Devine To The City Ethics Commission For Failing To Register As A Lobbyist Based On Her Work For The South Park BID In 2017

August 25, 2017 Mike Leave a comment

So you may recall that I’ve been working on establishing the fact that BID consulting constitutes lobbying as defined in the Municipal Lobbying Ordinance. I kicked off this project in February with shadowy BID consultant Tara Devine, whom I reported to the Ethics Commission for working as a lobbyist but failing to register as a lobbyist. Meanwhile, if you have no idea what I’m talking about, here is a reasonable introduction to the concepts of both BID consultancy and why it’s almost certainly the kind of thing for which registration with the Ethics Commission is required.

My theory gained some credibility with the discovery that some BID consultants in Los Angeles do register as lobbyists. Since February I’ve been collecting evidence against Ed Henning for his work with the San Pedro BID and also against Urban Place Consulting for their work on Fashion District BID renewal and also Media District BID renewal.

And, of course, against Tara Devine for her ongoing work with the South Park BID. Finally, a few weeks ago I completed a generic argument¹ that BID consultancy constitutes lobbying. And this morning I’m pleased to announce that, despite the twisted CPRA-defying machinations of South Park BID director of operations² Katie Kiefer and her less-than-competent lawyers,³ I have submitted yet another complaint to the Ethics Commission against Tara Devine, this time for her BID consulting for South Park. You can read the whole complaint here.

And turn the page for a technical discussion of an interesting issue which came up while I was putting this complaint together. Note that I discussed this same issue the other day, so if you read that post, you might want to just skip the rest of this one.
Continue reading How I Reported Shadowy BID Consultant Tara Devine To The City Ethics Commission For Failing To Register As A Lobbyist Based On Her Work For The South Park BID In 2017 →

Business Improvement Districts, Municipal Ethics, Public Records Act Pragmatics

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

July 12, 2017 Mike 2 Comments

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.⁴ 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,⁵ but I know a lot of my readers are wondering what’s up with shadowy BID consultant Tara Devine,⁶ 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.

The documents on Archive.Org — This is four gigantic PDF spools of emails and (hallelujah!) a bunch of invoices. They’re almost unusable, but single word search at least works. Phrase search not so much. The invoices are the really essential item, though, and are linked-to directly and described in the next line.
All invoices from Devine Strategies to SPBID since 2012 — This is damning with respect to constructing further reports to the Ethics Commission on Tara Devine’s unregistered lobbying. You may recall that my first attempt at this required an inordinate amount of painstaking analysis to prove a violation of the Municipal Lobbying Ordinance. With these invoices in hand the next few cases won’t be nearly as difficult to make.

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 →

Fashion District BID, Public Records Act Pragmatics

Remember That Cost Matrix That Rena Leddy And Urban Place Consulting Claimed In March 2017 Was A Trade Secret And Even Hired A Lawyer To Prevent Its Release Under CPRA? Well, Rena Leddy Herself Released It Into The Public Domain In October 2016. The Proper Response Is (a) WTF?! (b) Is Paying Lawyers To Fight Already-Lost Battles An Acceptable Use Of The BID’s Money? (c) All Of The Above

July 10, 2017 Mike Leave a comment

A couple days ago I published a collection of Rena Leddy’s reports to the Board of Directors of the Fashion District BID. This is turning out to be an incredibly rich source of information, revealing, e.g., that a marketing consultant hired by the BID thinks, among other deeply stupid thoughts, that lobster rolls confuse Latinos. And today I have another gem, but, for good or for ill, this one’s more technical although no less interesting.

Perhaps you recall that Urban Place Consulting is working for the Fashion District coordinating the BID’s pending renewal with the City. I obtained UPC’s contract with the BID from Rena Leddy via the California Public Records Act, but she claimed that the chart showing the actual hourly rates of UPC bossboy Steve Gibson and his assorted flunkies was exempt from release because it was a trade secret. Then we spent three months arguing about it and everybody got lawyered up and eventually she gave in and sent me an unredacted copy of the contract showing how much money all the UPC folks were getting paid.

Well, it turns out it was all for nothing. You see, in October 2016, UPC submitted a proposal to the BID for the consulting job. Here is a copy (transcription after the break, as always). And Rena Leddy included this proposal in the November 2016 Board Packet. And the proposal contained an unredacted copy of the cost matrix. To see why this action of Rena Leddy’s obviated our entire subsequent dispute about whether or not the cost matrix was exempt, turn the page, friend!
Continue reading Remember That Cost Matrix That Rena Leddy And Urban Place Consulting Claimed In March 2017 Was A Trade Secret And Even Hired A Lawyer To Prevent Its Release Under CPRA? Well, Rena Leddy Herself Released It Into The Public Domain In October 2016. The Proper Response Is (a) WTF?! (b) Is Paying Lawyers To Fight Already-Lost Battles An Acceptable Use Of The BID’s Money? (c) All Of The Above →

Fashion District BID, Public Records Act Pragmatics

The Fascinating Story Of How It Took Three Months And A Demand Letter From An Attorney To Get Rena Leddy To Disclose That The Fashion District BID Is Paying Steve Gibson Of Urban Place Consulting $215 Per Hour For BID Renewal Consulting, Which Is Less Than Larry Kosmont Gets But More Than Ed Henning

May 28, 2017 Mike 2 Comments

Late last year it occurred to me that BID consultants, who help BIDs with the City processes necessary to establish or renew a BID, are essentially engaging in lobbying activity as defined in the Municipal Lobbying Ordinance at LAMC §48.02 and yet none of them⁷ seemed to be registered with the Ethics Commission as required by LAMC §48.07(A).

I then spent months piecing together over 100 pages of evidence to show that BID consultant Tara Devine had violated this law. Subsequently it occurred to me that the contracts that the consultants sign with BIDs would provide essential evidence that they’d been acting as lobbyists, so I determined to request these from many renewing BIDs. This led me to the discovery, thanks to the incomparable Laurie Hughes of the Gateway to LA BID, that GTLA’s BID consultant, Larry Kosmont, actually was registered as a lobbyist and had disclosed his BID consultancy as lobbying in his required reporting. The San Pedro BID is also up for renewal, and has recently released a fairly complete set of BID renewal records.

This brings us to the Fashion District. On February 21, 2017 I emailed Rena Leddy to request, among other material:

… all records associated with the renewal process, including but not limited to communications between the BID and the consultant and/or the engineer, contracts with and invoices from the consultant or the engineer, materials prepared by the consultant or the engineer for the renewal process, databases and mailing lists prepared or used by the consultant or the engineer, and also any communications between the consultant and the engineer that aren’t already responsive to the first part of this request.

The story of what happened after that stretched out over three months and generated many many megabytes of discussion. Read on for a (far too) detailed and exceedingly well-documented narrative recounting, complete with a happy, happy ending!
Continue reading The Fascinating Story Of How It Took Three Months And A Demand Letter From An Attorney To Get Rena Leddy To Disclose That The Fashion District BID Is Paying Steve Gibson Of Urban Place Consulting $215 Per Hour For BID Renewal Consulting, Which Is Less Than Larry Kosmont Gets But More Than Ed Henning →

Announcements, Business Improvement Districts, Downtown Center BID, Fashion District BID

Sunday Morning Document Dump: Emails From Fashion District, Figueroa Corridor, North Hollywood, Downtown Center, Also Fashion District Transactions February Through April

May 14, 2017 Mike Leave a comment

Greetings, friends! If you’ve been wondering what you were going to do this morning after finishing off the Times crossword⁸ 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!⁹

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.
Fashion District Transactions February through April 2017 — More transaction reports. These are essential in ways that are hard to predict in advance. The big surprise here is that the Fashion District has recently spent $1647¹⁰ consulting with downtown legal beagles Bradley & Gmelich, the same law firm that the criminal conspiracy known as the South Park BID seems recently to have hired to (mis)handle its CPRA affairs and practices.¹¹

And turn the page for more emails: North Hollywood BID, Figueroa Corridor BID, and our old friends, the Downtown Center BID!
Continue reading Sunday Morning Document Dump: Emails From Fashion District, Figueroa Corridor, North Hollywood, Downtown Center, Also Fashion District Transactions February Through April →

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

April 15, 2017 Mike Leave a comment

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’ associations¹² 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.¹³ 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.¹⁴ 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,¹⁵ 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 →