Tag Archives: Unregistered Lobbying

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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Business Improvement Districts, Hypocrisy, Skid Row Neighborhood Council

Historic Core BID Executive Directrix Blair Besten Seems OK With The Crimes Of Her Employers, E.g. HCBID Board Members Ruben “The Homicidal Slumlord” Islas And Michael “Asshole Buddy With Ultra-Corrupt Tax Assessor John Noguez” Delijani, Even While Claiming That “The increase in crime lowers the morale of the neighborhood”

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The fact that, as I reported on Friday, Blair Besten, batty little fusspot queen of the Historic Core BID, along with her ne’er-do-well companions in corruption, Estela Lopez and Michael Delijani, were meeting as early as January 2017 with CD14 Councilswordsman José Huizar to oppose the Skid Row Neighborhood Council more or less overshadowed the parallel discovery that, at roughly the same time, Ms. Blair Besten was also setting up a meeting between Mr. José and Ruben Islas, one of her bosses from the HCBID Board of Directors.1

Now, Ruben “the homicidal slumlord” Islas is famous not just for whatever it is he does to be a zillionaire, but also for the fact that he and a bunch of his co-conspirators were arrested and charged with manslaughter and a host of other crimes in 2010 related to the fact that the slums they were then lording over were in such bad shape that three people died as a result. This incident followed the now-seen-to-be-cruelly-ironic series of criminal counts filed against Islas‘s firm for roughly similar misconduct by then-City-Attorney Rockard Delgadillo, lately working under the table as an anti-human lobbyist for a shadowy Downtown law firm.

And similarly, the other one of Ms. Blair Besten’s bosses whose name has come up a lot recently, that is to say furtive hereditary imperialist downtown zillionaire Michael Delijani, has also availed himself of Blair Besten’s probably-illegally-exercised2 skills at relationship building with CD14 repster3 José Huizar. Just see here for six pages of blathering between Blair Besten and various CD14 staffers about a meeting she’s trying to arrange between the CM and the Delijani.

Michael Delijani has also been involved in some exceedingly shady-if-as-yet-unindicted activities in relation to the deep corruption in the office of the LA County Assessor as personified by former assessor, now jailbird, John Noguez. The details are too involved to discuss here, but essentially Noguez reduced zillionaires’ property tax bills in exchange for campaign contributions, and a bunch of the deals were made at fundraising events for Noguez at Michael Delijani’s house. Delijani himself gave Noguez more than $20,000, and you can draw your own conclusions from that.

As far as I can see, Michael Delijani has never been convicted of a crime related to the bribery of Noguez. And it’s true that Ruben Islas’s manslaughter charges were dropped, and also, as part of a deal in which the corporation itself pleaded guilty, Delgadillo’s criminal charges were also dropped against the firm’s principals, including Ruben “the Alexandria Hotel assassin” Islas. So in some technical sense, these guys are not criminals. But in some strong but nontechnical sense they certainly are criminals, and Blair Besten is certainly a hypocrite when it comes to these zillionaire bad BID boys.
Continue reading Historic Core BID Executive Directrix Blair Besten Seems OK With The Crimes Of Her Employers, E.g. HCBID Board Members Ruben “The Homicidal Slumlord” Islas And Michael “Asshole Buddy With Ultra-Corrupt Tax Assessor John Noguez” Delijani, Even While Claiming That “The increase in crime lowers the morale of the neighborhood” →

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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

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Greetings, friends! If you’ve been wondering what you were going to do this morning after finishing off the Times crossword1 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!2

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 →

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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

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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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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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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Announcements, Business Improvement Districts

New Documents: January 2017 Emails Between East Hollywood BID and City of LA, Also Gateway To LA BID By-Vendor Reports

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Just a brief note to announce a couple more sets of documents:

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Business Improvement Districts, Municipal Ethics

Is There Such A Thing As An Honest Lobbyist? Probably Not, But Nevertheless, Larry Kosmont Handled The Gateway To LA BID’s Recent Renewal And Registered With The Ethics Commission To Do So, Casting Further Doubt On Any Theory That Implies That Shadowy BID Consultant Tara Devine Was Not Also Required To Register

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We’ve been discussing BID consultants a lot recently because of shadowy BID consultant Tara Devine and the fact that it looks so much like BID consultancy satisfies the LAMC’s definition of lobbying that it’s very likely that she broke the laws requiring registration, causing me, in the throes of a well-developed sense of civic duty, to report her transgressions to the Ethics Commission and then again to report some associated transgressions to Mike Feuer. What will come of these matters no one can now know, of course, but one aspect that troubled me slightly is the apparent novelty of the charges. That is, all the BID consultants I knew of at the time weren’t registered. This doesn’t mean they don’t have to register. After all, consider what happened with BID security and the Police Commission as a result of our reporting. But nevertheless, one never wants to be the first to make an argument if it’s possible to avoid it.

So imagine my pleasure in discovering that, first, the famous Gateway to LA BID, one of Mike Bonin’s babies out there by the Airport in CD11, renewed for 10 years in 2015, and they used a BID consultant named Larry Kosmont to handle the process for them. And second, that Larry Kosmont was not only registered as a lobbyist during this process, but that he specifically, explicitly, disclosed his work for the Gateway BID to the City and specifically, explicitly listed the City Clerk as one of the City offices he’d lobbied in furtherance of the renewal project. This is going to make it a lot harder for Tara Devine and her defenders, if any she has by now, to argue that it never occurred to anyone that BID consultants were lobbyists and therefore subject to registration. Turn the page for links to all relevant documents!
Continue reading Is There Such A Thing As An Honest Lobbyist? Probably Not, But Nevertheless, Larry Kosmont Handled The Gateway To LA BID’s Recent Renewal And Registered With The Ethics Commission To Do So, Casting Further Doubt On Any Theory That Implies That Shadowy BID Consultant Tara Devine Was Not Also Required To Register →

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Municipal Ethics, Venice Beach BID

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 Venice Beach Property Owners Association

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Tara Devine at the Venice Beach BID hearing on August 23, 2016, a day on which she engaged in at least 2.5 hours of lobbying activity.
The TL;DR is that I believe that in the course of her consultancy with the Venice Beach BID, Tara Devine qualified as a lobbyist within the meaning of the Los Angeles Municipal Lobbying Ordinance, was therefore required to register with the Ethics Commission, and failed to do so, putting her in violation of the law. If you know what all those terms mean, you may want to go straight to the complaint (Warning: 23MB PDF). For a detailed explanation of the background, though, read on!

The key is found in Section 48.07, which states that “An 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.” After all, anyone can search the Ethics Commission’s database and see that Tara Devine has never registered as a lobbyist. So the question is whether Tara Devine is “An individual who qualifies as a lobbyist.” This turns out to be a fairly complicated thing to determine.

The first place to start when interpreting any law is with the definitions. In the case of the Municipal Lobbying Ordinance (henceforth “MLO”) they are found at LAMC §48.02. In particular, we will find that the word “lobbyist”:

means any individual who is compensated to spend 30 or more hours in any consecutive three-month period engaged in lobbying activities which include at least one direct communication with a City official or employee, conducted either personally or through agents, for the purpose of attempting to influence municipal legislation on behalf of any person.

And in order to see whether this applies to Tara Devine, we need to understand the following terms:

  • Lobbying activities
  • Municipal legislation
  • Attempting to influence


And once we understand what those three phrases mean, we have to show that Tara Devine was paid for 30 or more hours lobbying on behalf of someone else. The details, as always, are after the break!
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 Venice Beach Property Owners Association →

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