CC SR 20180731 G - Legislative Subpoenas01203.0032/492150.3 1
RANCHO PALOS VERDES CITY COUNCIL MEETING DATE: 07/31/2018
AGENDA REPORT AGENDA HEADING: Consent Calendar
AGENDA DESCRIPTION:
Consider adopting Resolution No. 2018-__ authorizing and then issuing two (2)
legislative subpoenas in connection with the direction given by the City Council of the
City of Rancho Palos Verdes on May 1, 2018, to undertake an investigation into
possible violation(s) of the “closed session privilege” embodied in the Ralph M. Brown
Act, Government Code § 54963, and under the oversight of the City Council ad hoc
subcommittee authorized by Resolution No. 2018-25.
RECOMMENDED COUNCIL ACTION:
(1) Waive further reading and adopt Resolution No. 2018-___ “A RESOLUTION OF
THE COUNCIL OF THE CITY OF RANCHO PALOS VERDES, CALIFORNIA,
AUTHORIZING THE ISSUANCE OF TWO (2) LEGISLATIVE SUBPOENAS FOR
THE PERSONAL APPEARANCE AND EXAMINATION OF INDIVIDUALS IN
CONNECTION WITH THE CITY COUNCIL INVESTIGATION INTO POSSIBLE
VIOLATIONS OF THE RALPH M. BROWN ACT;”
(2) Direct the City Clerk to attest to the two (2) legislative subpoenas authorized by
resolution and authorize the Mayor to sign the same on behalf of the City.
(3) Alternately discuss and take such other action related to this item as the City
Council deems appropriate consistent with the requirements of law.
FISCAL IMPACT: Unknown
Amount Budgeted: ___
Additional Appropriation: ___
Account Number(s): ___
ORIGINATED BY: William Wynder, City Attorney
REVIEWED BY: Gabriella Yap, Deputy City Manager
APPROVED BY: Doug Willmore, City Manager
ATTACHED SUPPORTING DOCUMENTS:
A. Resolution No. 2018-25 (page A-1)
B. Two Letters From the Office of the City Attorney (page B-1)
C. Resolution No. 2018-____ (page C-1)
BACKGROUND:
On May 1, 2018, the City Council adopted Resolution No 2018-25 formally
initiating a legislative investigation into possible violations of the “closed session”
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01203.0032/492150.3 2
privilege of the Ralph M. Brown Act, Government Code §§ 54950 et seq. In that action
the City Council directed taking the following actions:
(1) Formally initiate a City proceeding to investigate possible violation(s) of
the “closed session privilege” codified in the Ralph M. Brown Act,
Government Code § 54963, and common law principles of similar effect;
and
(2) Direct Staff and the Office of the City attorney to conduct such
investigation; and
(3) Task the recently created ad hoc subcommittee to oversee such
investigation and to report the results of the same to the full City Council
as and when appropriate; and
(4) Authorize the issuance of legislative subpoenas, if and as needed, to aid
in such investigation.
A copy of that enabling resolution is attached to this staff report.
In aid of that legislative proceeding, the Office of the City Attorney sent written
requests to several individuals seeking in-person interviews to “determine the extent of
[their] knowledge, if any, of potential violation committed both other(s) of the open
meeting laws.” These letters further requested a response by a July 2, 2018 deadline
and advised that “failure to respond . . . will require our office to take the necessary
steps to secure your interview by legislative subpoena . . . .” Copies of the letters
relevant to this staff report are attached hereto.
Two (2) of the individuals with whom our office sent letters declined to be
voluntarily interviewed absent the issuance of a legislative subpoena to each.
Accordingly, it has now become necessary, in order to obtain the requested interviews,
to issue the legislative subpoenas requested in this report and as previously authorized
by the City Council in Resolution No. 2018-25.
Should the City Council continue in its desire to obtain interviews of Ms. Sharon
Loveys and Mr. Noel Weiss, respectively, it will now be necessary to authorize the
issuance of legislative subpoenas to these individuals to compel their attendance and
the production of requested documents as a part of the on-going legislative proceeding
into possible violations of the Ralph M. Brown Act.
DISCUSSION
A city council has the power to issue subpoenas requiring attendance of
witnesses or production of documents in proceedings pending before it. (Gov. Code §§
37104-37109.) Section 37104 authorizes a “legislative body” of a city to issue
subpoenas to compel witnesses to appear or produce documents “in any action or
proceeding” before that body.
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01203.0032/492150.3 3
Section 37105 of the Government Code and Section 1987 of the Code of Civil
Procedure provide the basic procedures required for the issuance and service of a
subpoena. In the first instance, a subpoena must be signed by the mayor and issued by
the city clerk. While not specified in the statutory framework, it appears that the proper
form to be used for the subpoena is the same as required is the same as set forth in
Code of Civil Procedure Section 1985.
The service of the subpoena is governed by Section 1987 of the Code of Civil
Procedure. (Gov. Code § 37105.) In short, the service of a subpoena is made by
delivering a copy of the subpoena to the witness personally and offering to pay any fees
which the witness is entitled to for travel to and from the place designated for
appearance or, if only production of records is requested, the estimated cost of
producing those records. (Code Civ. Proc. § 1987.) The service of the subpoena must
be made so as to allow the witness a “reasonable time” for preparation and travel.
Any violation of the subpoena is then reported to the superior court within its
jurisdiction. The superior court determines both the validity of the subpoena and
whether it has been violated. Government Code §§ 37105 through 37109 define the
City’s remedy for a failure to comply with a subpoena.
Upon the failure of a person to obey a subpoena, the mayor of a city notifies the
superior court. (Government Code § 37105.) The superior court then issues an
attachment directed to the sheriff of the county where the witness was required to
appear or produce documents commanding the appearance of the person to the court.
(Government Code § 37107.) On the return of the attachment and production of the
witness, the judge has jurisdiction to issue a contempt order. (Government Code §§
37108, 37109.)
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RESOLUTION NO. 2018-25
A RESOLUTION OF THE COUNCIL OF THE CITY OF RANCHO PALOS
VERDES, CALIFORNIA, INITIATING A CITY PROCEEDING TO
INVESTIGATE POSSIBLE VIOLATION(S) OF THE RALPH M. BROWN
ACT, GOVERNMENT CODE§§54950 ET SEQ.; DIRECTING CITY STAFF
AND THE OFFICE OF THE CITY ATTORNEY TO CONDUCT SUCH
INVESTIGATION; TASKING THE RECENTLY CREATED AD HOC
SUBCOMMITTEE TO OVERSEE SUCH INVESTIGATION AND TO
REPORT THE RESULTS OF THE SAME TO THE FULL CITY COUNCIL
AS AND WHEN APPROPRIATE; AND AUTHORIZING THE ISSUANCE OF
LEGISLATIVE SUBPOENAS, IF AND AS NEEDED, TO AID IN SUCH
INVESTIGATION
WHEREAS, in 2002 the Legislature amended the Ralph M. Brown Act, Government
Code § 54950 et seq., to prohibit the unauthorized disclosure of"confidential information"
acquired in a closed session by any person present (Government Code § 54963); and
WHEREAS, only the legislative body acting as a body may agree to divulge
confidential closed session information and, with respect to attorney/client privileged
communications, the entire body is the holder of the privilege and onlythe entire body may
waive that privilege. (Roberts v City of Palmdale (1993) 5 Ca1.4th 363, 373.); and
WHEREAS, the 2002 amendments to the Ralph M. Brown Act went further to
prescribe particular remedies for breaches of confidentiality. These remedies include
injunctive relief; and where the breach is a willful disclosure of confidential information, the
remedies include referral of a member of the legislative body to the district attorney or the
grand jury; and
WHEREAS, Government Code § 1222 makes it a misdemeanor for a public official
to "wilful[ly] omi[t] to perform any duty enjoined by law . . . ."; and
WHEREAS, in privileged and confidential discussions between City staff and the
Office of the City Attorney there exist specific articulable facts and circumstances to
suspect that, over a substantial period of time, there have been circumstances in which
confidential information (know only in the context of a privileged "closed session")that have
been willfully and unlawfully shared outside of the same and in violation of law; and
WHEREAS, members of the City Council have, themselves, shared with the Office
of the City Attorney additional specific articulable facts and circumstances to suspect that,
over a substantial period of time, there have been circumstances in which confidential
information (know only in the context of a closed session) have been willfully and unlawfully
shared outside of the closed session; and
WHEREAS, the City Council has the legal authority to investigate potential violations
of Section 54963 and report the same to the Public Integrity Division of the Los Angeles
County District Attorney and/or the Los Angeles County Criminal Grand Jury.
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NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF RANCHO PALOS
VERDES, CALIFORNIA, DOES HEREBY RESOLVE AS FOLLOWS:
Section 1. The City Council finds and determines that the foregoing recitals are
true and correct, and adopt the recitals as findings in support of the actions taken herein.
Section 2. The City of Rancho Palos Verdes does hereby initiate a legislative
proceeding before the City Council to investigate and determine whether and when the
privilege of the "closed session" may have been violated in contravention of Government
Code § 54963 (and common law principles of similar effect) and to take such action, as
may be warranted by law, including possible reference of such violation(s) to the Public
Integrity Division of the Los Angeles County District Attorney and/or the Los Angeles
County Criminal Grand Jury.
Section 3. The City Council hereby tasks the ad hoc subcommittee, comprised of
Mayor Pro Tern Jerry Duhovic and Councilmember Eric Alegria, first created by Resolution
No. 2018-22, to oversee the legislative proceeding and investigation authorized in this
resolution. The ad hoc subcommittee shall have the authority, with the concurrence of the
City Attorney, to determine if, when, and to whom any legislative subpoena(s) need be
issued pursuant to this Resolution requiring attendance of witnesses or production of
books, records, or other documents for evidence or testimony in this proceeding and in aid
of the investigation authorized herein.
Section 4. The City Council hereby authorizes the issuance of such legislative
subpoena(s) as may be deemed necessary or appropriate by the ad hoc subcommittee,
City Manager, and City Attorney to undertake the investigation and in aid of the proceeding
authorized herein.
Section 5. The City Council hereby orders that any legislative subpoena issued
pursuant to the authority provided by this Resolution shall be in a form provided by the City
Attorney, shall be signed by the Mayor and attested to by the City Clerk in the manner
required by law. The City Council hereby declares that failure to comply with any
subpoena(s) issued pursuant to this Resolution shall subject the subpoenaed party(ies)to
the remedies set forth in Government Code §§ 37104 et seq. or such other remedies as is
provided by law.
Section 6. The City Council hereby authorizes the Mayor, City Manager, City
Clerk and the City Attorney to take such actions as may be necessary or proper to issue,
serve and enforce any subpoena(s) issued pursuant to this Resolution. This authority
includes the issuance of such subpoena(s)to any person or entity,their officers, employees
and agents, in furtherance of obtaining public records, testimony and/or other information
that will assist the City, its staff, and attorneys in their efforts to investigate possible
violation(s) of the privilege of the"closed session" under the Ralph M. Brown Act. Should a
witness fail to produce the subpoenaed documents and/or evidence, the Mayor is
01203.0001/467758.4
Resolution No. 2018-25
Page 2 of 3
A-2
authorized to report such failure to abide by the subpoena to the Superior Court and seek
any and all lawful remedies including a ruling holding the subpoenaed witness in contempt.
Section 7. Severability. If any section, subsection, subdivision, sentence, clause,
phrase, or portion of this resolution or the application thereof to any person, is for any
reason held to be invalid or unconstitutional by the decision of any court of competent
jurisdiction, such decision shall not affect the validity of the remainder of this ordinance.
The City Council hereby declares that it would have adopted this resolution, and each and
every section, subsection, subdivision, sentence, clause, phrase, or portion thereof,
irrespective of the fact that any one or more sections, subsections, subdivisions, sentences,
clauses, phrases, or portions thereof be declared invalid or unconstitutional.
Section 8. The City Clerk shall certify to the passage and adoption of this
Resolution and enter it into the book of original Resolutions. This Resolution shall be
effective immediately upon passage and adoption.
PASSED, APPROVED and ADOPTED this 1st day of May, 2018.
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Isla orY
Attest: 111,
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State of California
County of Los Angeles ss
City of Rancho Palos Verdes )
I, Emily Colborn, City Clerk of the City of Rancho Palos Verdes, hereby certify that
the above Resolution No. 2018-25 was duly and regularly passed and adopted by the said
City Council at a regular meeting thereof held on May \018.
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01203.0001/467758.4
Resolution No. 2018-25
Page 3 of 3
A-3
B-1
B-2
B-3
B-4
01203.0032/492151.3
RESOLUTION 2018-____
A RESOLUTION OF THE COUNCIL OF THE CITY OF RANCHO PALOS
VERDES, CALIFORNIA, AUTHORIZING THE ISSUANCE OF TWO (2)
LEGISLATIVE SUBPOENAS FOR THE PERSONAL APPEARANCE AND
EXAMINATION OF INDIVIDUALS IN CONNECTION WITH THE CITY
COUNCIL INVESTIGATION INTO POSSIBLE VIOLATIONS OF THE
RALPH M. BROWN ACT
WHEREAS, Government Code §§ 37104 et seq. authorize the City Council to issue
legislative subpoenas “requiring attendance of witnesses or production of books or other
documents for evidence or testimony in any action or proceeding pending before it”; and
WHEREAS, on May 1, 2018, the City Council adopted Resolution No. 18-____, “A
RESOLUTION OF THE COUNCIL OF THE CITY OF RANCHO PALOS VERDES,
CALIFORNIA, DIRECTING CITY STAFF AND THE OFFICE OF THE CITY ATTORNEY
TO INVESTIGATE POSSIBLE VIOLATION(S) OF THE RALPH M. BROWN ACT,
GOVERNMENT CODE § 54963, TASK THE RECENTLY CREATED AD HOC
SUBCOMMITTEE TO OVERSEE SUCH INVESTIGATION AND REPORT THE RESULTS
OF THE SAME TO THE FULL CITY COUNCIL, AND AUTHORIZE THE ISSUANCE OF
LEGISLATIVE SUBPOENAS, IF AND AS NEEDED, TO AID IN SUCH INVESTIGATION;”
and
WHEREAS, in aid of that legislative proceeding, the Office of the City Attorney sent
written requests to an identified group of individuals seeking in-person interviews to
“determine the extent of [their] knowledge, if any, of potential violation committed both
other(s) of the open meeting laws.” These letters further requested a response by a July 2,
2018, deadline and advised that “failure to respond . . . will require our office to take the
necessary steps to secure your interview by legislative subpoena . . . .” and
WHEREAS, two (2) of the individuals to whom letters were sent declined to be
interviewed absent the issuance of a legislative subpoena; and
WHEREAS, in aid of the City Council legislative proceeding it will now be necessary
to issue two (2) legislative subpoenas in order to compel the personal attendance of the
individuals in question.
NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF RANCHO PALOS
VERDES, CALIFORNIA, DOES HEREBY RESOLVE AS FOLLOWS:
Section 1. The City Council finds and determines that the foregoing recitals are true and
correct, and adopt the recitals as findings in support of the actions taken herein.
Section 2. The City Council hereby authorizes and directs the issuance of two (2)
legislative subpoenas directed to Ms. Sharon Loveys and Mr. Noel Weiss, respectively,
commanding their personal appearance and the production of documents in aid of the
legislative proceeding before the City Council.
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01203.0032/492151.3
Section 3. The legislative subpoenas shall be signed by the Mayor and attested to by the
City Clerk. A copy of this Resolution shall be attached to any subpoenas and shall be
incorporated by reference into each subpoenas. Any subpoenas shall be served upon the
subpoenaed parties in the same manner as subpoenas are served in a civil action.
Section 4. The City Council hereby declares that failure to comply with the subpoenas
issued pursuant to this Resolution shall subject the subpoenaed parties to the remedies set
forth in Government Code §§ 37104 et seq. or such other remedies as is provided by law.
Section 5. The City Council hereby authorizes the Mayor, City Manager, City Clerk and
the City Attorney to take such actions as may be necessary or proper to issue, serve and
enforce the subpoenas issued pursuant to this Resolution.
Section 6. The City Council further finds and determines that, in order to assist the City
Council in the conduct of its investigation, the ad hoc subcommittee may, from time to time,
recommend that the Council issue additional subpoenas in this matter in the event new
CPRA requests are made following the adoption of this Resolution and the issuance of the
subpoena.
Section 7. Exhibits. All exhibits to this Resolution are incorporated herein by reference
and made a part hereto.
Section 8. Severability. If any section, subsection, subdivision, sentence, clause, phrase,
or portion of this resolution or the application thereof to any person, is for any reason held
to be invalid or unconstitutional by the decision of any court of competent jurisdiction, such
decision shall not affect the validity of the remainder of this ordinance. The City Council
hereby declares that it would have adopted this resolution, and each and every section,
subsection, subdivision, sentence, clause, phrase, or portion thereof, irrespective of the fact
that any one or more sections, subsections, subdivisions, sentences, clauses, phrases, or
portions thereof be declared invalid or unconstitutional.
Section 9. The City Clerk shall certify to the passage and adoption of this Resolution and
enter it into the book of original Resolutions. This Resolution shall be effective immediately
upon passage and adoption.
PASSED, APPROVED and ADOPTED this 31st day of July 2018.
____________________
Susan Brooks, Mayor
Attest:
___________________
Emily Colborn, City Clerk
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01203.0032/492151.3
State of California )
County of Los Angeles ) ss
City of Rancho Palos Verdes )
I, Emily Colborn, City Clerk of the City of Rancho Palos Verdes, hereby certify that
the above Resolution No. _________ was duly and regularly passed and adopted by the
said City Council at a regular meeting thereof held on July 31, 2018.
____________________________
Emily Colborn, City Clerk
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01203.0032/492151.3
EXHIBIT “A”
LEGISLATIVE SUBPOENAS
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LEGISLATIVE SUBPOENA
(Government Code §§ 37104 et seq)
Date: August 10, 2018
Time: 10:00 a.m., PD ST
Address: City of Rancho
Palos Verdes City Hall, 30940 Hawthorne
Blvd., Rancho Palos Verdes, California
90275
TO: Ms. Sharon Loveys
FROM: CITY COUNCIL OF THE CITY OF RANCHO PALOS VERDES,
CALIFORNIA
1. On July 31, 2018, the City Council of Rancho Palos Verdes adopted Resolution No.
2018-____ authorizing and directing the issuance of this subpoena. A true and copy of such
Resolution No. 2018-____ is attached hereto as Exhibit “2” and incorporated by this reference.
2. YOU ARE HEREBY ORDERED & COMMANDED by the City Council of the City
of Rancho Palos Verdes to appear in person to testify in response to this subpoena. Your
testimony will be recorded stenographically.
3. YOU ARE FURTHER ORDERED & COMMANDED by the City Council of the City
of Rancho Palos Verdes and deliver true, complete, legible, and durable copies of the document
and things described in Exhibit “1” hereto.
4. The personal attendance of the custodian or other qualified witness and the production of
the original records are required by this subpoena. The procedure authorized by Evidence Code
§§ 1560(b), 1561, and 1562 will not be deemed sufficient compliance with this subpoena.
5. All documents and other things produced to the City shall be accompanied by a
declaration or affidavit warranting to their authenticity and completeness sufficient to meet the
requirements of California Code of Civil Procedure § 2020.430. The City will pay all
reasonable documented costs associated with photocopying the requested documents. If costs
exceed $500.00 please contact William W. Wynder, Esq., at (310) 527-6667 before copying.
6. This subpoena is issued pursuant to California Government Code §§ 37104 et seq. and
was authorized at a duly noticed meeting of the City of Rancho Palos Verdes City Council.
7. Disobedience of this subpoena will be referred to the Superior Court for enforcement and
is punishable as contempt pursuant to California Government Code §§ 37104 et seq. and as
otherwise provided by law. Should you have any questions regarding this subpoena please
contact:
IN RE:
SHARON LOVEYS
SUBPOENA FOR
PERSONAL APPEARANCE &
PRODUCTION OF DOCUMENTS & THINGS
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William W. Wynder (SBN 84753)
Attorney for the City of Rancho Palos Verdes
Aleshire & Wynder, LLP
2361 Rosecrans Boulevard, Suite 475
El Segundo, CA 90245
Date Issued: July ____, 2018
City of Rancho Palos Verdes¶
BY:
ATTEST:
BY:
Susan Brooks Emily Colborn
Mayor, City of Rancho Palos Verdes City Clerk
APPROVE AS TO FORM
BY:_____________________
William W. Wynder
City Attorney
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EXHIBIT “1”
DEFINITIONS
"DOCUMENT" or "DOCUMENTS" means all writings, originals and duplicates
as defined in California Evidence Code §§ 250, 255, and 260;
"COMMUNICATIONS" as used herein means the transfer of information from
one person or entity to another person or entity by any means, including, but not limited to,
letter, electronic mail, or facsimile.
“RELATE TO” shall mean and refer to constituting, containing, embodying,
reflecting, identifying, stating, referencing to, evidencing in any way or being relevant to the
subject referenced therein.
REQUESTED DOCUMENTS
1. Produce all DOCUMENTS or COMMUNICATIONS between yourself and Mr.
Brian Campbell which refer or RELATE TO Short Term Rentals or Party Houses in the City of
Rancho Palos Verdes.
2. Produce all DOCUMENTS or COMMUNICATIONS between yourself and Mr.
Brian Campbell which refer or RELATE TO Mr. Eric Mark.
3. Produce all DOCUMENTS or COMMUNICATIONS between yourself and Mr.
Brian Campbell which refer or RELATE TO Green Hills Memorial Park.
4. Produce all DOCUMENTS or COMMUNICATIONS between yourself and Mr.
Brian Campbell which refer or relate to Vista Verde Condominiums, located at 2110 Palos
Verdes Drive, Lomita, CA.
5. Produce all DOCUMENTS or COMMUNICATIONS between yourself and Mr.
Brian Campbell which refer or RELATE TO Mr. Michael Huang.
6. Produce all DOCUMENTS or COMMUNICATIONS between yourself and Mr.
Brian Campbell which refer or RELATE TO Mr. Dave Tomblin.
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EXHIBIT “2”
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LEGISLATIVE SUBPOENA
(Government Code §§ 37104 et seq)
Date: August 10, 2018
Time: 2:00 p .m., PD ST
Address: City of Rancho
Palos Verdes City Hall, 30940 Hawthorne
Blvd., Rancho Palos Verdes, California
90275
TO: Mr. Noel Weiss
FROM: CITY COUNCIL OF THE CITY OF RANCHO PALOS VERDES,
CALIFORNIA
1. On July 31, 2018, the City Council of Rancho Palos Verdes adopted Resolution No.
2018-_____ authorizing and directing the issuance of this subpoena. A true and copy of such
Resolution No. 2018-____ is attached hereto as Exhibit “2” and incorporated by this reference.
2. YOU ARE HEREBY ORDERED & COMMANDED by the City Council of the City
of Rancho Palos Verdes to appear in person to testify in response to this subpoena. Your
testimony will be recorded stenographically.
3. YOU ARE FURTHER ORDERED & COMMANDED by the City Council of the City
of Rancho Palos Verdes and deliver true, complete, legible, and durable copies of the document
and things described in Exhibit “1” hereto.
4. The personal attendance of the custodian or other qualified witness and the production of
the original records are required by this subpoena. The procedure authorized by Evidence Code
§§ 1560(b), 1561, and 1562 will not be deemed sufficient compliance with this subpoena.
5. All documents and other things produced to the City shall be accompanied by a
declaration or affidavit warranting to their authenticity and completeness sufficient to meet the
requirements of California Code of Civil Procedure § 2020.430. The City will pay all
reasonable documented costs associated with photocopying the requested documents. If costs
exceed $500.00 please contact William W. Wynder, Esq., at (310) 527-6667 before copying.
6. This subpoena is issued pursuant to California Government Code §§ 37104 et seq. and
was authorized at a duly noticed meeting of the City of Rancho Palos Verdes City Council.
7. Disobedience of this subpoena will be referred to the Superior Court for enforcement and
is punishable as contempt pursuant to California Government Code §§ 37104 et seq. and as
otherwise provided by law. Should you have any questions regarding this subpoena please
contact:
IN RE:
NOEL WEISS
SUBPOENA FOR
PERSONAL APPEARANCE &
PRODUCTION OF DOCUMENTS & THINGS
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William W. Wynder (SBN 84753)
Attorney for the City of Rancho Palos Verdes
Aleshire & Wynder, LLP
2361 Rosecrans Boulevard, Suite 475
El Segundo, CA 90245
Date Issued: July ____, 2018
City of Rancho Palos Verdes¶
BY:
ATTEST:
BY:
Susan Brooks Emily Colborn
Mayor, City of Rancho Palos Verdes City Clerk
APPROVE AS TO FORM
BY:__________________________
William W. Wynder
City Attorney
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EXHIBIT “1”
DEFINITIONS
"DOCUMENT" or "DOCUMENTS" means all writings, originals and duplicates
as defined in California Evidence Code §§ 250, 255, and 260;
"COMMUNICATIONS" as used herein means the transfer of information from
one person or entity to another person or entity by any means, including, but not limited to,
letter, electronic mail, or facsimile.
“RELATE TO” shall mean and refer to constituting, containing, embodying,
reflecting, identifying, stating, referencing to, evidencing in any way or being relevant to the
subject referenced therein.
REQUESTED DOCUMENTS
1. Produce all DOCUMENTS or COMMUNICATIONS between yourself and Mr.
Brian Campbell which refer or RELATE TO Short Term Rentals or Party Houses in the City of
Rancho Palos Verdes.
2. Produce all DOCUMENTS or COMMUNICATIONS between yourself and Mr.
Brian Campbell which refer or RELATE TO Mr. Eric Mark.
3. Produce all DOCUMENTS or COMMUNICATIONS between yourself and Mr.
Brian Campbell which refer or RELATE TO Green Hills Memorial Park.
4. Produce all DOCUMENTS or COMMUNICATIONS between yourself and Mr.
Brian Campbell which refer or relate to Vista Verde Condominiums, located at 2110 Palos
Verdes Drive, Lomita, CA.
5. Produce all DOCUMENTS or COMMUNICATIONS between yourself and Mr.
Brian Campbell which refer or RELATE TO Mr. Michael Huang.
6. Produce all DOCUMENTS or COMMUNICATIONS between yourself and Mr.
Brian Campbell which refer or RELATE TO Mr. Dave Tomblin.
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EXHIBIT “2”
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