Tag Archives: Hollywood Media District BID

Ahahahaha And LOL!!! Ellen Riotto Of The South Park BID Is Now Taking Sensitive Legal Advice From Internet Randoms At This Blog!!!

February 21, 2018 Mike Leave a comment

The Brown Act contains many wonderful treasures, but one of the wonderfullest is to be found at §54954.1, which states unambiguously that:

Any person may request that a copy of the agenda, or a copy of all the documents constituting the agenda packet, of any meeting of a legislative body be mailed to that person. … Upon receipt of the written request, the legislative body or its designee shall cause the requested materials to be mailed at the time the agenda is posted pursuant to Section 54954.2 and 54956 or upon distribution to all, or a majority of all, of the members of a legislative body, whichever occurs first.

I ask many of my BID friends to send me these notifications and their agenda packets. It really seems to piss most of them off.¹ I don’t feel bad for asking BIDs to comply with the law, though. After all, it’s voluntary on their part and they’re making an awful damn lot of money out of it.

So anyway, our friends at the South Park BID are reasonably cooperative about complying with the law. They invited me to sign up for their public mailing list, which I did. It’s an open question as to whether this is compliance, since the law requires notifications to be sent at the time that the board receives them, but this presently seems too minor to quibble over. On the other hand they spout an awful lot of spam through that account, and clearly I shouldn’t be required to sort through the junk just to be able to receive notifications that they’re legally mandated to send. Again, though, this is an argument for another day.

However, it turns out that the South Park BID does distribute packets to its board of directors in advance of the meetings and also that those are not available via the public mailing list. I only found out about this recently, so I wrote to the BID boss ladies and asked them to send them goodies my way!

After some nonsense with them interrogating me mercilessly about which email address I wanted the board packets sent to,² we got all the details ironed out. And after that, my friends, it must follow, as the night the day, that I ended up sending Ellen Riotto some of my sage legal advice and, amazingly, she ended up taking it!³ Read on for the details and a bunch of emails!
Continue reading Ahahahaha And LOL!!! Ellen Riotto Of The South Park BID Is Now Taking Sensitive Legal Advice From Internet Randoms At This Blog!!! →

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 argument⁴ 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 operations⁵ Katie Kiefer and her less-than-competent lawyers,⁶ 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

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

August 8, 2017 Mike Leave a comment

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:

An argument that BID consultancy satisfies the definition of lobbying activity found in the the Municipal Lobbying Ordinance at LAMC §48.02.
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 →

Municipal Ethics

City Council Approves Update To Ethics Laws Which, Among Other Changes, Imposes At Long Last A Duty On City Officials And Employees To Report Violations To The Ethics Commission Within Ten Days — A Law Like This Will Cut Down On Apparent Collusion By City Officials Or At Least Provide Another Fruitful Channel For Reporting Them

July 8, 2017 Mike Leave a comment

The Los Angeles Ethics Commission is charged not only with enforcing ethics laws and regulations but also with reviewing and revising them periodically. Because the City Council is subject to these laws it wouldn’t make much sense for them to be able to alter them at will. The temptation to exempt themselves and their creepy zillionaire buddies would ultimately be too much for their corrupt vestigial little senses of morality to bear and we’d end up without any ethics laws at all.

Thus the process, as described in the City Charter at §703(a), requires the Ethics Commission to propose the changes and gives the City Council the authority only to disapprove but not to modify them.⁷ This strikes me as a quite clever way to balance the competing interests involved:

The commission may adopt, amend and rescind rules and regulations, subject to Council approval without modification, to carry out the purposes and provisions of the Charter and ordinances of the City relating to campaign finance, conflicts of interest, lobbying, and governmental ethics and to govern procedures of the commission.⁸
So at its meeting in February, the Ethics Commission approved a bunch of revised enforcement regulations. You can read the original proposal. This was duly sent up to the City Council, where it was placed in Council File 14-0049-S1. Well, on Thursday, after the Mayor’s concurrence was received, the Council finalized the matter and the new regulations are approved and will take effect on August 14.⁹

There were bunches of changes, mostly technical in nature, and beyond my capacity to evaluate. But the one that really excites me is that the new ordinance requires City departments and appointees to report violations of the Ethics laws or the Municipal Lobbying Ordinance within ten days. This is a huge development! Read on for details and for a number of horrific instances in which the lack of a mandate to report created absolutely nauseating scenarios involving law-flouting lobbyists and City officials.
Continue reading City Council Approves Update To Ethics Laws Which, Among Other Changes, Imposes At Long Last A Duty On City Officials And Employees To Report Violations To The Ethics Commission Within Ten Days — A Law Like This Will Cut Down On Apparent Collusion By City Officials Or At Least Provide Another Fruitful Channel For Reporting Them →

Announcements, Business Improvement Districts, Hollywood BID Patrol

New Documents! East Hollywood BID Quarterly Reports, Media District BID Emails, Media District BID Materials About Andrews International Security Switcheroo Including Emails, Draft Contracts, Price Matrices, And So On!

June 16, 2017 Mike Leave a comment

Yesterday I received a bunch of new records from Hollywood BIDboy attorney Jeffrey Charles Briggs, acting on behalf of the East Hollywood BID and also the Media District BID. Some of the stuff had to do with the Media District’s early renewal, which I wrote about yesterday, and today I’m mostly just announcing the balance of the material, which is available from our Archive.Org collections. In particular, we have:

East Hollywood BID quarterly reports 2012-2016 — BIDs are required by their contracts with the City to submit quarterly reports with updates on how they’ve been spending their money.¹⁰ These are useful to have on hand for reference. There’s nothing in these that stands out right now, but I haven’t read them carefully yet nor even looked at all of them.
Media District emails with the City of LA — And also a few from the Hollywood Property Owners Alliance folks, although nothing substantial. Again, it’s essential to have this material on hand for reference. There doesn’t seem to be much of special interest here, although there’s a lot more evidence of Rita Moreno’s uncharacteristically activist style as a BID analyst with the Clerk’s office, which is abstractly a good thing, although certainly she’s not going to be an activist if it upsets the BIDs too much.
Media District emails about Andrews International Security contract — The Media District BID is in the process of hiring infamous private security monolith Andrews International as its security provider, to begin July 1. These are some emails about the process. The most interesting things here are the attachments, which include A/I’s standard contract as well as proposed pricing matrices and so on. Andrews International famously runs the infernal Hollywood BID Patrol for the even-more-infernal Hollwood Property Owners Alliance just North of the Media District, so everything about them is interesting. There is much more material to come regarding this matter, and I will write about it in detail as it comes in, but it’s essential enough that I thought I’d better publish what I had immediately.

So that’s the new stuff, all except for one little email which didn’t exactly fit into any of those categories. It appears to constitute attorney/client communications, and perhaps it was handed over in error. But legally handed over it was, so I’m publishing it, and you can see a copy and read all about it after the break!
Continue reading New Documents! East Hollywood BID Quarterly Reports, Media District BID Emails, Media District BID Materials About Andrews International Security Switcheroo Including Emails, Draft Contracts, Price Matrices, And So On! →

Business Improvement Districts, Fashion District BID

Newly Obtained Documents Reveal That The Hollywood Media District BID Is Paying Urban Place Consulting $1,550.35 More Than The Fashion District BID Is Paying For Renewal Services Because UPC Is Billing Assistants At 20% More! Jeff Briggs Supplies Unredacted UPC Labor Matrix Without Requiring A Freaking Demand Letter! Aaron Aulenta Isn’t As Much Of A “Tech Dinosaur” As Previously Claimed!

June 15, 2017 Mike Leave a comment

You may recall that as part of my long term project to turn as many BID consultants as possible in to the City Ethics Commission for unregistered lobbying, I’ve been trying to track down consulting contracts and other such evidence. I obtained a lot of excellent information from the San Pedro Historic Waterfront BID and, after a prolonged struggle, chronicled in excessive detail here, I obtained an unredacted copy of Urban Place Consulting’s contract with the Fashion District BID.

In the course of that whole mishegoss I had to overcome FDBID executive directrix Rena Leddy’s ultimately untenable position that the so-called “labor matrix,” a chart which detailed how much time UPC meant to spend on each aspect of the BID renewal process and how much they were to be paid for it,¹¹ was a trade secret. Among the many cogent arguments we used¹² was the evident fact that labor costs couldn’t possibly be trade secrets because UPC would of necessity have to share them with prospective clients before a contract was signed. This was a purely logical argument, but now, thanks to a huge trove of records shared with me this evening by the Media District BID and relating to their renewal process, also being handled by UPC, I have definitive proof.
Continue reading Newly Obtained Documents Reveal That The Hollywood Media District BID Is Paying Urban Place Consulting $1,550.35 More Than The Fashion District BID Is Paying For Renewal Services Because UPC Is Billing Assistants At 20% More! Jeff Briggs Supplies Unredacted UPC Labor Matrix Without Requiring A Freaking Demand Letter! Aaron Aulenta Isn’t As Much Of A “Tech Dinosaur” As Previously Claimed! →

Business Improvement Districts, Municipal Ethics

It Appears That East Hollywood BID Director Nicole Shahenian Lied To Los Angeles City Clerk Holly Wolcott About The Circumstances Of The Preparation Of The EHBID’s 2015 Annual Planning Report And, As Shahenian Was A Registered Lobbyist At The Time, Thereby Violated LAMC 48.04(B)

March 12, 2017 Mike Leave a comment

Nicole Shahenian, you got some splainin’ to do!

The background to this post is unavoidably technical and lengthy. If you’re already familiar with the Annual Planning Report process for BIDs as mandated by Streets and Highways Code §36650, you may want to skip directly to the report I submitted to the City Ethics Commission this morning.

One requirement that the Property and Business Improvement District Law places on BIDs, found at §36650, is the submission of annual planning reports (“APRs”) to the City Council:

The owners’ association shall cause to be prepared a report for each fiscal year, except the first year, for which assessments are to be levied and collected to pay the costs of the improvements, maintenance, and activities described in the report. … The report shall be filed with the clerk … The city council may approve the report as filed by the owners’ association or may modify any particular contained in the report and approve it as modified.

And it seems that the BID isn’t allowed to spend money on stuff that’s not discussed in the APR, so it’s not a trivial matter.

The way this piece of code plays out in Los Angeles is that, first, a BID director submits the APR to the Clerk along with a formulaic cover letter. For instance, here is the one submitted by Nicole Shahenian on December 30, 2014 to accompany the East Hollywood BID’s APR for 2015. This is essentially the same letter submitted by all BIDs:

Dear Ms. Wolcott:
As required by the Property and Business Improvement District Law of 1994, California Streets and Highways Code Section 36650, the Board of Directors of the East Hollywood Business Improvement District has caused this East Hollywood Business Improvement District Annual Planning Report to be prepared at its meeting of December 29, 2014.

And don’t forget that state law requires the City Council to adopt the report either with or without modifications. In Los Angeles this part of the process is initiated by the Clerk sending another form letter to City Council, recommending that they adopt the BID’s APR. It’s my impression that the Clerk doesn’t recommend modifications to the report at this stage. These seem to be handled by Miranda Paster before the APR is submitted to Council, as in this example involving the Media District BID. Anyway, take a look at Holly Wolcott’s January 14, 2015 recommendation to City Council with respect to the East Hollywood BID’s APR. Like every such document, this states:

The attached Annual Planning Report, which was approved by the District’s Board at their meeting on December 29, 2014, complies with the requirements of the State Law and reports that programs will continue, as outlined in the Management District Plan adopted by the District property owners.

And it goes on from there to recommend:

That the City Council:

FIND that the attached Annual Planning Report for the East Hollywood Property Business Improvement District’s 2015 fiscal year complies with the requirements of the State Law.

ADOPT the attached Annual Planning Report for the East Hollywood Property Business Improvement District’s 2015 fiscal year, pursuant to the State Law.

But there are a number of problems with this story. First, it appears that the East Hollywood BID Board of Directors did not actually meet on December 29, 2014. In fact, it appears that they did not meet at all in December 2014. Of course, it’s notoriously difficult to prove a negative, but I’m going to give it a go.
Continue reading It Appears That East Hollywood BID Director Nicole Shahenian Lied To Los Angeles City Clerk Holly Wolcott About The Circumstances Of The Preparation Of The EHBID’s 2015 Annual Planning Report And, As Shahenian Was A Registered Lobbyist At The Time, Thereby Violated LAMC 48.04(B) →

Venice Beach BID

More Than Two Months After Its Business Improvement District Came Into Being, The Venice Beach Property Owners’ Association Has Not Yet Signed An Administration Contract With The City Of Los Angeles, But A Comparison With Other Recent BID Establishments Suggests That This May Not Mean Much

March 2, 2017 Mike Leave a comment

Carl Lambert, officer of the Venice Beach Property Owners Association, as he might have appeared on the cover of the late lamented Berkeley Barb which, given the parallel tragedies which have befallen both Berkeley and Venice, is kind of appropriate in a way sorta kinda..

Well, since the first of the year, I have been obsessively checking the contract search tab of the City Clerk’s Council File Management System for any sign of an agreement between the City and the Venice Beach Property Owners Association, as that criminal conspiracy between Carl Lambert and his unindicted co-conspirators Mark Sokol and Steve Heumann is known to the world, for the administration of the Venice Beach BID. The CFMS¹³ is an essential tool, but its built-in search engine is freaking horrible, and it seems even horribler¹⁴ when searching contracts. So the fact that no contract popped up day after day after day didn’t exactly fill me with confidence in the theory that no such contract existed.

But today, after two freaking months with no sign of it, I finally emailed the ever-helpful¹⁵ Shannon Hoppes to ask if there was a contract or not. She answered quickly and told me that there was not yet any such thing. Well, hope springs and so on. Into my head sprang joyous visions of Carl Lambert and his infernal BID-buddies Mark Sokol and Steve Heumann being so overwhelmed with the furor and pushback called into being by their infernal BID that they took their BID-ball and went home. They are being sued, their shadowy BID consultant, the Divine Ms. Tara Devine, has as shaky a grasp on the law and also on the truth and also on basic human decency as her freaking clients, and maybe the pressure was all just too much for them, mused I.

But it also occurred to me that maybe it didn’t mean anything, and it was just runna-the-mill incompetence and sloth. So I decided to check out other recent BID establishments and compare. What I found proves that, while there has been a longer than average delay between the establishment of the VBBID and the signing of the contract, it’s not an outlier, nor is it the longest such lag time among property-based BIDs established in the last few years. Thus while this at-least-two-month delay between the BID establishment may yet turn out to be a sign of good things to come with respect to this BID, for now it’s not possible to draw any conclusions at all about it. Turn the page for the technical details.
Continue reading More Than Two Months After Its Business Improvement District Came Into Being, The Venice Beach Property Owners’ Association Has Not Yet Signed An Administration Contract With The City Of Los Angeles, But A Comparison With Other Recent BID Establishments Suggests That This May Not Mean Much →

Business Improvement Districts, Municipal Ethics

Latest Entry in LAMC 49.5.5(A) Project: Hollywood Media District BID Seems To Have Paid LAPD Hollywood Division SLO Eddie Guerra $400 In Exchange For Homeless Encampment Cleanups (Ostensibly As A Charitable Donation), But Why Was The Check Made Out To Him Personally?

January 10, 2017 Mike Leave a comment

Eddie Guerra, kicking ass and taking checks from the Media District BID, $400 at a time.

How much does a private nonprofit organization have to pay an LAPD officer in exchange for him running off some homeless people who are having a barbecue on the sidewalk and scaring the neighborhood zillionaires? Newly received evidence suggests that the going rate is $200 per running-off incident.

It has been more than two months since the last entry in our ongoing LAMC 49.5.5(A) project, in which we report various City employees to the Ethics Commission in an attempt to discover exactly what the most fascinating ordinance ever,¹⁶ LAMC 49.5.5(A), actually prohibits. It’s high time for another report, and this is it. First, recall what the law actually says:

City officials, agency employees, appointees awaiting confirmation by the City Council, and candidates for elected City office shall not misuse or attempt to misuse their positions or prospective positions to create or attempt to create a private advantage or disadvantage, financial or otherwise, for any person.

Our story begins with a six-month long email chain between Hollywood Division Senior Lead Officer Eddie Guerra and a number of people associated with the Media District BID about scary sidewalk-barbecuing homeless people:
Continue reading Latest Entry in LAMC 49.5.5(A) Project: Hollywood Media District BID Seems To Have Paid LAPD Hollywood Division SLO Eddie Guerra $400 In Exchange For Homeless Encampment Cleanups (Ostensibly As A Charitable Donation), But Why Was The Check Made Out To Him Personally? →

Hollywood Property Owners Alliance, Public Records Act Pragmatics

The Year-Long Saga Of How It Is My Fault That Devin Strecker Was Forced By Kerry Morrison’s Scorched-Earth Anti-CPRA Policies To Tell Lisa Schechter That The Hollywood Property Owners Alliance Did Not Use Dropbox Even Though Everyone Else In The Entire Freaking Universe Uses It

January 7, 2017 Mike Leave a comment

It is all my fault that Devin Strecker is no longer allowed to use Dropbox at work!

Oh dear friends, what a long story I have to tell you this afternoon! And I hope it will repay (or more than) your attention.¹⁷ It’s all about how Kerry Morrison is willing to make her job and the jobs of her minions progressively more impossible for absolutely no better reason than to thwart my research. I’ve written about various stages in this process before, and here’s a brief timeline:

March 2016 — Kerry Morrison amends HPOA document retention policy to require destruction of emails after 90 days unless intentionally kept, unilaterally, retroactively, and illegally redefines emails as not subject to CPRA.
June 2016 — Kerry Morrison rewrites contract with Andrews International so that A/I work product is no longer the property of the HPOA and therefore, she wrongly thinks, is no longer subject to CPRA.

And I just recently acquired an October 2016 email from Devin Strecker to Lisa Schechter of the Media District BID¹⁸ which shows yet another dimension of this phenomenon: Devin Strecker has to tell Lisa Schechter that he is not allowed to click on a link because the HPOA does not use freaking Dropbox.

A demonstration of the HPOA’s forthcoming records retention policy: everything that can’t be stored in human memory will be recorded in the form of knotted strings, presently unreadable by anyone on earth. Take *that*, CPRA users!

Of course, he is not allowed to use Dropbox because of yet another policy instituted by Kerry Morrison to thwart my inquiries, although it’s really not clear what effect this is supposed to have.¹⁹ If this trend continues, she will eventually have all HPOA communication carried out by trained mnemonists who will memorize her messages and recite them in person to the recipients to avoid creating disclosable records. If data must be recorded in tangible form she will only record it by quipu, using the original Inca encoding methods which, conveniently, no one alive today is able to understand. The history of this no-Dropbox policy commences in November 2015, and you can read all about it after the break in excruciating detail, amply documented.
Continue reading →