20180403 Late CorrespondenceAGENDA ITEM:
cEIVED FROM:
AND MAD PARTOF ERF-rtORPATTHE
COUNCIL MEETING OF: "z
OFFICE OF THE CITY CLERK
Negative Impact on IV Homes from Nature Preserve
1 message
Mr. G <golong888@gmail.com>
Roni Long <gitwon@aol.com> Tue, Apr 3, 2018 at 5:57 PM
To: Susan.brooks@rpvca.gov, Jerry.duhovic@rpvca.gov, Ken.dyda@rpvca.gov, John.cruikshank@rpvca.gov,
Eric.a!egria@rpvca.gov
Cc: dddrpv@verizon.net, golong888@gmail.com, Roni Long <gitwon@aol.com>, ariel@scottmgmt.com
Dear RPV City Council members, Susan Brooks, Jerry Duhovic, Ken Dyda,
John Cruikshank, and Eric Algeria,
We are writing to each of you collectively, as a group who represent the city we reside in, Rancho Palos Verdes. Our
names are Gary and Roni Long and we live in the Island View Development. Our neighborhood has been negatively
impacted
since the city opened the Nature Preserve at the end of Crenshaw Blvd. The list of NEGATIVE concerns which impact our
residents has been growing EXPONENTIALLY as the Preserve has grown in popularity through word-of-mouth, social
media, news print sources, and television highlights of secret locales places for FREE recreational hiking and dirt bike
riding.
What does it feels like to live in our once tranquil close-knit neighborhood
today? We once were free from speeding traffic, outsiders (and I mean up to 50miles away!), TRESPASSERS,
neighborhood petty crime (ie.graffiti,destructive acts), littering! And I mean not just trash, raw and rotting foodstuff
garbage,
plus plenty of empty alcoholic containers, but condoms, drug paraphernalia, homeless encampment, and more!
Since the City started eliminating parking spaces close to the Preserve, the
people fight to secure a parking space to the Preserve starting at lam. We live
at the corner house along Crenshaw and Crest and are awakened by people parking along Crenshaw, slamming their
doors, and talking with loud voices
early mornings;(. The majority of parking spaces have been eliminated
closest to the entrance. Marked permitted parking spaces and handicapped
parking are the closest proximity. The rest of the majority of legal parking
spaces are from Island View entrance southward, then across the street
starting from St. John Fisher CHurch driveway north to beyond on Crenshaw past Crest Rd. Parking is illegal on the side
of the street going south past St. John Fisher all the way down to the Preserve. So more than 90% of hikers must
walk past IV entrance toward the FIRST visible signage marking Rattlesnake
Trail on the Island View wrought iron fence. People take this trail rather than
continuing past Del Cerro Park to the Formal Preserve Entrance area.
The PROBLEM is people don't stay on the city marked trail and disregard
the Trail Boards with rules and directions to stay to the LEFT ON PRESERVE
TRAIL. Instead, they are lured by the steps leading to the canyon floor on PRIVATE PROPERTY OF IVHOA. Despite the
large signs, lack of City
enforcement to cite trespassers on private property—these trespassers
hold exercise classes on the IV lawn outside our tennis courts, damage
property by installing heavy exercise fire hoses attached to our stair
banisters, pull heavy raking equipment along our once beautiful lawns
to exercise, and more. Yet when asked to leave by residents citing they
are trespassing on private property, BELLIGERENT, ANGRY INTIMIDATION
THREATS, and CONFRONTATION occur from these TRESPASSERS as
though they are entitled to stay and use the IV residential tennis court area,
passive park and steps! Fewer and fewer residents are afraid to go here
on our own property that we pay for because of the type of incidents
reported here in the past. THIS IS NOT RIGHT!! ENCROACHMENT from
TRESPASSERS scaring residents from usage of our own private property
and confrontation with them!
THEREFORE.... RESOLUTIONS NAMED....
1) IF YOU WOULD REMOVE THAT TRAILHEAD SIGN AND we could REPLACE
it with a PRIVATE PROPERTY SIGN, MORE USERS WOULD WALK
TO THE FORMAL ENTRANCE OF THE PRESERVE. THUS, ALLEVIATING ANY
POTENTIAL LIABILITY CLAIMS of TRESPASSERS on private property.
2) Open up parking spaces on the vacant piece of land on Palos Verdes Dr.
South and get the word out about a South entrance to alleviate the problems
facing neighborhoods from Crenshaw Blvd. The City opened this Preserve WITHOUT adequate ample parking to
accommodate the demand for usage!
All residents of the City need to share this burden.
3) It is legal to charge for entry to the Preserve, attendance could be declined
to an acceptable level to accommodate available parking. The City could
use the revenue to pay for employees necessary to enforce the Preserve.
The biggest win would be greatly reducing the number of hikers in our
once pastoral neighborhood.
4) If the City Council can't take immediate action to reduce the parking
problem and numerous issues already listed, they should close the Preserve.
The City Council's duty is to its residents. We CANNOT HAVE THE
CIRCUS -LIKE ENVIRONMENT OF RUNYON CANYON AND ITS HIGHLY
PUBLICIZED HIKERS and RESIDENT'S PARKING and PEOPLE BEHAVIOR PROBLEMS, CLOSURE, and ONGOING
PROBLEMS
PLEASE PLEASE VALUE THE MISSION STATEMENT TO THE RESIDENTS OF
RANCHO PALOS VERDES AND KEEP OUR LANDS SAFE & NON -HOSTILE TO
ITS RESIDENTS ...... P -L -E -A -S -E !!!!
Thank you!
Gary and Roni Long
Residents
Island View Homeowner
Sent from my iPad
q
j
CITYOF RANCHO PALOS VERDES
TO: HONORABLE MAYOR & CITY COUNCIL MEMBERS
FROM: CITY CLERK
DATE: APRIL 3, 2018
SUBJECT: ADDITIONS/REVISIONS AND AMENDMENTS TO AGENDA
Attached are revisions/additions and/or amendments to the agenda material presented
for tonight's meeting.
Item No. Description of Material
1 Email from Gary Randall
2 Email from Tracy Burns
3 Email from Park Place Residents HOA
** PLEASE NOTE: Materials attached after the color page(s) were submitted
through Monday, April 2, 2018**.
WA01 City Clerk\LATE CORRESPONDENCE\2018 Cover Sheets\20180403 additions revisions to agenda.doc
From: Teresa Takaoka
Sent: Tuesday, April 03, 2018 9:00 AM
To: Nathan Zweizig
Subject: FW: City Council to Review Film Permit Regulations and Procedures on April 3rd
Follow Up Flag: Follow up
Flag Status: Flagged
Late carr
From: grapecon@cox.net [mailto:grapecon@cox.net]
Sent: Monday, April 02, 2018 5:58 PM
To: Kit Fox <KitF@rpvca.gov>; Film <Film@rpvca.gov>; CC <CC@rpvca.gov>; CityManager <CityManager@rpvca.gov>
Subject: RE: City Council to Review Film Permit Regulations and Procedures on April 3rd
Hello Kit:
Thank you for informing me of this agenda item. I will not be able to attend the meeting in person, but wanted to let the
council know that I support the staff recommendations, namely:
• Concur with Staff's suggested prohibition against the future issuance of film permits for Rancho Palos Verdes Beach;
• Direct Staff to complete revisions to the administrative instructions for film permits; and;
• Adopt the draft resolution to establish a Film Permit Cancellation Fee.
RPV Beach is not suitable for filming activities due to access difficulties and sensitive habitat and tidepool areas. I hope the City
Council concurs.
Regards
Gary Randall
From: Kit Fox <KitF@rpvca.gov>
Sent: Tuesday, March 27, 2018 6:17 PM
To: Film <Film@rpvca.gov>
Cc: gr p con cox.ntt; Camille Hoheb <camille a catnillehc�h b„com>; cinthiaethornton <emmashoes@aol.com>;'edmundo
hum mel' <ecarloshum mail.com>; PB Club <office beachc_lub.com>
Subject: City Council to Review Film Permit Regulations and Procedures on April 3rd
Dear Interested Party:
In response to concerns raised during a film shoot on Rancho Palos Verdes Beach in October 2017, the City Council will be
reviewing the City's film permit regulations and procedures at its upcoming meeting on Tuesday, April 3rd. Please click here to
review the Staff report. The City Council meets at 7:00 PM in McTaggart Hall at Hesse Park Community Building, located at
29301 Hawthorne Blvd., Rancho Palos Verdes, CA 90275.
Please feel free contact me if you have any questions or need additional information.
Sincerely,
Kit Fox, AICP
Film Permit Coordinator
City of Rancho Palos Verdes
30940 Hawthorne Blvd.
Rancho Palos Verdes, CA 90275
T: (310) 5445226
F: (310) 5445291
E: film@rpvca.gov
E: kitf@rpvca.gov
W: http://www.rpvca.8ov/261/Filen-Permits
From: Teresa Takaoka
Sent: Tuesday, April 03, 2018 3:58 PM
To: Nathan Zweizig
Subject: FW: RPV - CC Meeting 04/03/18, please include for Agenda Item #2 PRA
Follow Up Flag: Follow up
Flag Status: Completed
Late Corr
From: Tracy Burns [mailto:akamomma@gmail.com]
Sent: Tuesday, April 03, 2018 3:50 PM
To: CC <CC@rpvca.gov>; Doug Willmore <DWillmore@rpvca.gov>; Ara Mihranian <AraM@rpvca.gov>; Teresa Takaoka
<TeriT@rpvca.gov>
Subject: RPV - CC Meeting 04/03/18, please include for Agenda Item #2 PRA
From the Daily Breeze (March 26th, 2018) -
"Campbell, who is on the Palos Verdes Library District Board of Trustees, says he used a personal Gmail because it
was more efficient. The city email service had problems with firewalls and emails not getting through, he said, and he
had multiple iterations of city email addresses. Eventually, he asked the IT department to forward the emails from all
the different addresses to a Gmail account he created for city business. "
How many other employees or elected officials use their personal email for city business?
How many different email addresses has Campbell used or directed the city to use? If more than one is this
common?
"I have made a consistent effort since last year to get the city attorney to cooperate with me to save money in running
a more efficient city attorney legal process," Campbell said.
Hasn't it been more than 2 years and the records have still not been turned over to the city? How is that
"efficient"?
"Brian is in a funny position because if he just turns over a thousand emails and there's sensitive content in them, the
city could say, `Hey, you turned over sensitive content,' " said Campbell's attorney, Jeff Lewis. "It would put him in
legal jeopardy."
• Isn't there sensitive content in some of the city emails already? - This is NOT new.
• If it is considered "sensitive content" or something that could put the city in "legal jeopardy" doesn't the city
ask the city attorney to review the records AS NEEDED before releasing them?
• Wasn't Jeffrey Lewis a former city Planning Commissioner, including when Green Hills received approval for
their mausoleum?
• If Campbell is in legal jeopardy because of his emails, that is HIS problem not the city's.
Source - https://www.dailybreeze.com/2018/03/26/former-rancho-palos-verdes-mayor-costin city-nearly-90000-in-
legal-fees-officials-sa /�qus thread
All of the above statements made in the article - in my humble opinion - are horse manure. Due to PRA requirements,
the RPV residents/taxpayers are on the hook for any legal fees or penalties for not providing ANY and all records
FORMER Mayor Campbell has in his possession from his entire tenure on the City Council. The city is ultimately
responsible for any current PRA's and any FUTURE PRA's. So, instead of paying $90k to hear NO or to be ran in
circles, I request the legal fees be used in a more proactive approach to get the public records from Campbell.
Sincerely,
Tracy Burns
From: Teresa Takaoka
Sent: Tuesday, April 03, 2018 11:13 AM
To: Nathan Zweizig
Subject: FW: Very unsafe Park Place can not exit/access homes
Attachments: IMG_1860.JPG; ATT00001.txt; IMG_1861.JPG; ATT00002.txt; IMG_1863.JPG; ATT00003.txt
Late corr
-----Original Message -----
From: Dr. 01 [mailto:pvpprof@gmail.com]
Sent: Tuesday, April 03, 2018 11:11 AM
To: CC <CC@rpvca.gov>; Elias Sassoon <esassoon@rpvca.gov>; Cory Linder <CoryL@rpvca.gov>
Cc: Park Place HOA Rodgveller, Hilda & Barry <rodgfamily@gmail.com>; Del Cerro HOA - Rick Charles Daniels President 2018 w
wife Lori <rdaniels@cox.net>; Island View Don Douthwright - HOA President <dddrpv@verizon.net>
Subject: Very unsafe Park Place can not exit/access homes
Honorable City Council & Directors,
Please find 3 pictures attached.
Please notice in each picture that all parking stalls are full BUT no persons are present in or enjoying Del Cerro Park. All vehicle
occupants believed to be on the City / Conservancy trails.
On each day, residents not able to leave home for religious holiday preparations and services.
In the 1st picture please see no egress (exit) at all to prepare for Good Friday and next 2 days.
Wait time to clear — 12 minutes.
In the 2nd picture please observe blocked roadway / driveway on Passover Saturday by vehicles
1) parked at red curb unloading bicycles for trails, 2) parked in front of driveway AND
3) closing ingress lane.
Wait time to clear — 22 minutes.
In the 3rd picture please notice blocked roadway / driveway on Easter Sunday by vehicles
1) parked in front of driveway AND
2) closing ingress lane.
Wait time to clear — 8 minutes.
We look forward to Council meeting tonight to discuss the horrific conditions on Park Place.
We ask all attending and throughout RPV, would anyone find it acceptable:
to not be able to exit or enter your home day after day after day - essentially every day? ...and to continually confront the
ever growing adverse safety hazards including confrontations, 'visitor' profanity, assault and much more day as well as night?
Thankyou
Respectfully,
Park Place residents HOA
AKm
iia v
00�
-01T
ph&
.6
.haw
41 }
Alk�
xr FE is q
y(pTT�,.
TO: HONORABLE MAYOR & CITY COUNCIL MEMBERS
FROM: CITY CLERK
DATE: APRIL 2, 2018
SUBJECT: ADDITIONS/REVISIONS AND AMENDMENTS TO AGENDA
Attached are revisions/additions and/or amendments to the agenda material received
through Monday afternoon for the Tuesday, April 3, 2018 City Council meeting:
Item No. Description of Material
1 Email from Chris Agnew
2 Emails from: William Patton; Jeff Lewis; Letter from Jeff Lewis
Respectfully submitted,
A�—
Emily Co orn
WA01 City Clerk\LATE CORRESPONDENCE\2018 Cover Sheets\20180403 additions revisions to agenda thru Monday.doc
From: Chris Agnew
To: Kit Fox
Subject: RE: City Council to Consider Adopting Film Permit Cancellation Fee on April 3rd
Date: Wednesday, March 28, 2018 9:41:02 AM
Attachments: Irnaga0021pna
You should do it. Most cities do. Your time is money.
Chris Agnew, Vice President
Pacific Production Services
1481 E 4" St
Los Angeles, CA 90033
Phone — 323-260-4777
Fax — 323-415-6180
From: Kit Fox [mailto:KitF@rpvca.gov]
Sent: Tuesday, March 27, 2018 6:38 PM
To: Film <Film@rpvca.gov>
Ce: ERICK TRAN <erick.tran@imestudios.com>; Jordan & Michaela Wright
<abeautifuldaypermits@gmail.com>; Jessica Loeb <jessica@filmpermits.com>; Victoria Hadeler
<vhadeler@gmail.com>; Elvina Oganyan <elvina@filmpermits.com>; ELISA SMITH
<elisa@filmthis.net>; Dennis De Leon <Dennis@lafilmpermits.com>; Brandon Dickson
<brandon@lafilmpermits.com>; Hannah Lee <Hannah@moontidemedia.com>; Kelly Jacobson
<jacobson.kellyh@gmail.com>; Noah Grange <Noah@lafilmpermits.com>; Rosemary Marks
<rosemary@tallordersproductions.com>; Josh Kirschner <joshk90@gmail.com>; Trish
<trisha@filmthis.net>; Alice Kim <Alice@imagelocations.com>; John Wheeler
<john@filmpermits.com>; denise wheeler <denise@filmpermits.com>; Chris Agnew
<Chris@lafilmpermits.com>; Christie Hazlet <Christie@lafilmpermits.com>; Jennifer McNeil
<Jennifer@lafilmpermits.com>; Jason Del Paine (JDP) <jdp@lafilmpermits.com>; Serena Zahler
<szahler@janusetcie.com>; Gavin Baustian <gavin5656@gmail.com>; Ivonne Grisales
<ivonne@world locations.com>; Joey Lewis <jlewis@trumpnational.com>; PB Club
<office@pbcbeachclub.com>; Alethea Geges <aletheag3@gmail.com>; Ben Stolte
<benstolte@gmail.com>; LisaSteen <lisamsteen@gmail.com>; BRENDA FERRELL
<brendaferrell@mac.com>; Sheri Salinas <sheri@scoutmonster.com>; Kris Bunting
<kristopherbunting@hotmail.com>; Murray Miller <mur.locations@gmail.com>; Mike Taris
<mike.taris@yahoo.com>; Barrow Davis-Tolot <Barrow@photofighter.com>; Christopher Carrico
<ccarrico@origprod.com>; janet@thmlclothing.com; Stacey Brewer <stacey@launchdrtv.com>;
Stewart Carrico <Stewart@lafilmpermits.com>; Peter McClafferty <peterinca@verizon.net>; Rene
Garcia <rene.filmthis.net@gmail.com>; Bridget Gray <bgray@bonobos.com>; Stanley Permits
<SPS@Stanleypermits.com>; Brad Zocchi <brad.zocchi@gmail.com>; Chris Woong Bae Choi
<chrisgbchoi@gmail.com>; Owen Lee <Owen@lafilmpermits.com>; anthony rizza
<arizza72@yahoo.com>; Annee Elliot <annee@anneeelliot.com>; Samantha Mitchell
<samantha@esemproductions.com>
Subject: City Council to Consider Adopting Film Permit Cancellation Fee on April 3rd
Dear Film Permit Professional:
The Rancho Palos Verdes City Council will be conducting a public hearing on Tuesday, April 3rd to
consider adopting a Film Permit Cancellation Fee. Please click hp[te to review the Staff report. As
currently proposed by City Staff, the cancellation fee would be $100 or one-half of the film permit
application fee, whichever amount is greater. The fee would be imposed upon film permit
applications that are canceled more than one (1) business day after they are filed with the City's
Film Permit Desk.
The City Council meets at 7:00 PM in McTaggart Hall at Hesse Park Community Building, located at
29301 Hawthorne Blvd,, Rancho Palos Verdes, CA 90275. Please feel free contact me if you have
any questions or need additional information.
Sincerely,
Kit Fox, AICP
Filen Permit Coordinator
Cifij of Rancho Palos Verdes
50940 Hawthorne Blvd.
Rancho Palos Verdes, CA 90275
T: (310) 5445226
F. (310) 5445291
Ejil.iaa.(q
E: ki @xWvca. ov
W. ft !lv,rivc.�:riMl..0 z.��r.:,.Pxzat
From: Teresa Takaoka
Sent: Wednesday, March 28, 2018 8:04 AM
To: Nathan Zweizig
Subject: FW: Daily Breeze: City Threatening Suit with Brian Campbell
Follow Up Flag: Follow up
Flag Status: Flagged
Late carr
From: William Patton[mailto:billpatton2l@icloud.com]
Sent: Tuesday, March 27, 2018 6:24 PM
To: CC <CC@rpvca.gov>
Cc: Ken DeLong <ken.delong@verizon.net>
Subject: Re: Daily Breeze: City Threatening Suit with Brian Campbell
Just a quick note to hope that the City of RPV is not serious re the below Daily Breeze article.
There are many residents including PVP Watch that will defend Brian Campbell! And will do so aggressively.
<div id="articletext" ?="" style="margin: Opx; padding: Opx; color: rgb(51, 51, 51); font -family: Arial, Helvetica, sans -serif,
Georgia; font -size: 16px; width: 450px;">
Daily Breeze: 3/27/18; page 3
RANCHO PALOS VERDES
formerCity may sue mayor
Ex -official's use of a personal Gmail account is costing community thousands
By Valerie Osier
vosier scnq.com
The city of Rancho Palos Verdes is threatening to sue a former mayor to force him to produce emails from his private account
that are considered public record.
City Attorney Dave Aleshire said Brian Campbell has cost the city $87,500 in legal fees because he refuses to respond to
multiple records requests dating back to 2016. The requests come from lawyers for Green Hills Memorial Park, which has
been entangled in a lawsuit with the city and residents of an adjacent condominium complex in Lomita over the construction of
a mausoleum.
The city cannot access the emails because Campbell used a personal Gmail account, rather than the city's server, to conduct
city matters. By law, the emails are public record because Campbell was a public official.
While Campbell was in office, city policy only discouraged the use of personal email servers for city business. Only recently
did City Council change the policy to outright ban the use of private servers and require officials to use the city account.
Campbell, who is on the Palos Verdes Library District Board of Trustees, says he used a personal Gmail because it was more
efficient. The city email service had problems with firewalls and emails not getting through, he said, and he had multiple
iterations of city email addresses. Eventually, he asked the IT department to forward the emails from all the different
addresses to a Gmail account he created for city business.
But efficiency for Campbell has created a headache for the city, which can't simply override his access to the account to get
the emails for records requests.
i
Under the California Public Records Act, the public has the public the right to request and review government records, unless
they are exempted by law. Public records include email correspondence to and from public officials unless the emails include
privileged information.
"Brian is in a funny position because if he just turns over a thousand emails and there's sensitive content in them, the city
could say, 'Hey, you turned over sensitive content,' " said Campbell's attorney, Jeff Lewis. "It would put him in legal jeopardy."
Since Campbell can't release the emails haphazardly, he needs to go through them with a city attorney to identify which
emails can be released and which cannot.
According to Aleshire, Campbell has refused to meet with members of the city's legal team — even when meetings have been
scheduled — to go through his emails. And every time a meeting is canceled, it's still billed to the city.
But Campbell insists it's Aleshire who has been uncooperative.
"I have made a consistent effort since
CAMPBELL)) PAGE 6
Campbell
i
FROM PAGE 3
last year to get the city attorney to cooperate with me to save money in running a more efficient city attorney legal process,"
Campbell said. "I think that the city attorney has spent an unfortunate amount of time avoiding cooperating in regards to some
of these records requests."
He can't meet with just any lawyer from Aleshire's firm, he said, because it was Aleshire who attended all the City Council's
closed -session meetings.
"It's a delay tactic," Aleshire said. "... His latest excuse is that he has to do it with me."
Aleshire said that an attorney in his office has been appointed to handle the records requests and to meet with Campbell. If
the attorney is unsure if an email has sensitive information, they can ask Aleshire, he said.
City Manager Doug Willmore and Aleshire agreed that Campbell should meet and work with only that attorney to maintain
continuity.
Before requesting to meet only with Aleshire, Campbell told the city attorney he would provide the emails by early March, but
did not when the time came, saying he needed to go through it with the city attorney himself, Aleshire said.
Campbell has produced some emails to the attorneys at Green Hills, Lewis said, but in a recent deposition for the case the
city is no longer party to, Campbell stated he needed the city attorney's advice before he could provide the rest.
City Council members will discuss taking Campbell to court in closed session sometime during the next few council meetings,
but they will have to decide if it's really worth taxpayer money to do that.
"It would be unprecedented and I can't imagine that Dave Aleshire would want his lack of cooperation out for all to see in a
lawsuit," Lewis said.
"This has been an inefficient process and, if these two gentlemen could just sit in a room and hash it out, it would be resolved
a hell of a lot faster than in a lawsuit."
Copyright O 2018 Torrance Daily Breeze. Please review new arbitration language here. 3/27/2018
Sent from my Whone
From:
Jeff Lewis <jeff@jefflewislaw.com>
Sent:
Friday, March 30, 2018 4:51 PM
To:
Dave Aleshire
Cc:
CC; Valerie Osier
Subject:
Request for Retraction / Inaccurate Information Supplied to Daily Breeze and the City
Council
Attachments:
Pages from Agenda_Report-1.xlsx; ATT00001.htm; BC Agenda Report.pdf;
ATT00002.htm
Dave,
I read with interest the Daily Breeze story that Brian Campbell cost RPV "nearly 90,000 in legal fees." I have
also read the staff report / hit piece you put together for Tuesday's city council discussion of this item. I hope
the City Council will check your math and look at your staff report. Attached please find an alternative version
of your spreadsheet with some notes by me. I have segregated approximately $24,000 in legal costs that you
attribute to Brian Campbell that have nothing to do with him. For example, the public records act request sent
by me last year has nothing to do with Brian Campbell - they have to do with the City's relationship with the
Palos Verdes Land Conservancy. It also appears that you have billed a lot of time relating to the City's October
2017 violation of the Brown Act and negotiation of a settlement agreement of that violation and attributed that
to Brian Campbell. As you may recall, the City convened an illegal closed session meeting when Brian
Campbell stepped outside to get his reading glasses. While I understand why the City chose to settle the Brown
Act litigation, attributing your time to settle that case to Brian Campbell is not fair. If anything, the City
Attorney present for that meeting should have counseled the acting mayor - not Brian - that its actions were
illegal.
I also note from the staff report that your staff spent thousands of dollars doing legal research and other acts to
decide not to represent Brian Campbell at his deposition noticed by Green Hills. Compared to the five hours of
attorney time to simply attend the deposition, these dollars seem like a waste.
I will conclude with observing that the City has incurred legal fees in response to the improper approval of a
burial structure spitting distance from residents of Lomita. Green Hills filed a lawsuit and sent the City public
records act requests and there has been discovery. The true cause of the city's legal fees was the decision to
approve the burial structure. Pinning this on Brian Campbell is not accurate or fair.
Now that I have seen your billing summaries, on behalf of Brian Campbell, I request that you personally, your
law firm and the City offer a written retraction of the following statement attributed to you in the Daily Breeze
in its March 26, 2018 : "City Attorney Dave Aleshire said Brian Campbell has cost the city $87,500 in legal
fees because he refuses to respond to multiple records requests dating back to 2016." I ask that you send that
written retraction to me and the Daily Breeze. I also ask that you notify your malpractice carrier of this potential
claim. Finally, I ask that you preserve all evidence bearing on this issue as litigation is quite likely.
a
7
7
7
7
7
7
7
7
7
7
)
7
)
7
7
CAMPBELL RELATED PUBLIC
OJA
2/2/2018
87.50 (BROWN ACT LEWIS)
OJA
2/9/2018
35.00 (BROWN ACT-LEWIS)
OJA
2/8/2018
140.00 (CAMPBELL - LOGO)
EQG
2/2/2018
525.00 (CAMPBELL DEFENSE CLOSED
EQG
2/2/2018
52.50 (CAMPBELL DEFENSE CLOSED
JSA
2/21/2018
64.50 (CAMPBELL REPO)
JSA
2/14/2018
64.50 (CAMPBELL DEPO)
JSA
2/14/2018
64.50 (CAMPBELL DEPO)
JSA
2/22/2018
64.50 (CAMPBELL DEPO)
JSA
2/21/2018
21.50 (CAMPBELL DEPO)
CMB
9/14/2016
66.00 (COUNCIL MEMBER PRA)
EQG
12/28/2017
129.00 (COUNCIL POLICY 46)
EQG
1/2/2018
236.50 (COUNCIL POLICY NO. 46)
OJA
1/5/2018
1,170.00 (COUNCIL PROCEDURES)
OJA
1/4/2018
385.00 (COUNCIL PROCEDURES)
CMB
5/16/2016
66.00 (COUNCILMEMBER PRA)
JT
2/5/2018
43.00 (DAILY BREEZE/PV NEWS)
AEM
2/12/2018
192.50 (DEFENSE OF CAMPBELL
AEM
2/12/2018
420.00 (DEFENSE OF CAMPBELL
OJA
2/23/2018
150.50 (DEPOSITION)
OJA
2/16/2018
322.50 (DUTY TO DEFEND)
EOG
2/7/2018
17.50 (IMPROPER USE OF CITY
R51
5/22/2017
130.00 (JEFF LEWIS PRA)
CMB
6/13/2016
181.50 (LADERA LINDA FIELDS)
CMB
6/14/2016
132.00 (LADERA LINDA)
CMB
6/10/2016
33.00 (LADERA LINDA)
CMB
9/6/2016
33.00 (LEWIS PRA)
OJA
2/1/2018
430.00 (LITIGATION)
EQG
12/4/2017
35.00 (MEETING WITH DOUG
CMB
6/6/2016
16.50 (PILOLLA PRA)
CMB
6/14/2016
33.00 (PILOLLA PRA)
JSA
12/21/2017
86.00 (PLANNING COMMISSION
MWR
4/6/2017
322.50 (PRA - NOEL WEISS)
MWR
4/7/2017
64.50 (PRA - NOEL WEISS)
MWR
4/5/2017
236.50 (PRA - NOEL WEISS)
MWR
4/12/2017
279.50 (PRA REQUEST - NOEL WEISS)
MWR
4/13/2017
172.00 (PRA REQUEST - NOEL WEISS)
JT
10/2/2017
21.50 (PV LAND CONSERVANCY)
JT
10/16/2017
150.50 (PV LAND CONSERVANCY)
JT
10/11/2017
43.00 (PV LAND CONSERVANCY)
JT
10/26/2017
817.00 (PV LAND CONSERVANCY)
JT
12/6/2017
494.50 (PV LAND CONSERVANCY)
JT
1/16/2018
537.50 (PV LAND CONSERVANCY)
JT
1/26/2018
387.00 (PV LAND CONSERVANCY)
JT
1/23/2018
344.00 (PV LAND CONSERVANCY)
JT
1/24/2018
322.50 (PV LAND CONSERVANCY)
JT
2/1/2018
322.50 (PV LAND CONSERVANCY)
JT
2/3/2018
258.00 (PV LAND CONSERVANCY)
JT
2/11/2018
688.00 (PV LAND CONSERVANCY)
JT
2/15/2018
537.50 (PV LAND CONSERVANCY)
JT
2/16/2018
774.00 (PV LAND CONSERVANCY)
JT
10/14/2017
731.00 (PV LAND CONSERVANCY)
7
7
7
7
7
7
7
7
7
7
)
7
)
7
7
JT
10/19/2017
279.50 (PV LAND CONSERVANCY)
JT
10/21/2017
451.50 (PV LAND CONSERVANCY)
JT
10/24/2017
559.00 (PV LAND CONSERVANCY)
JT
10/20/2017
365.50 (PV LAND CONSERVANCY)
JT
11/13/2017
365.50 (PV LAND CONSERVANCY)
JT
11/16/2017
301.00 (PV LAND CONSERVANCY)
JT
11/17/2017
537.50 (PV LAND CONSERVANCY)
JT
11/21/2017
322.50 (PV LAND CONSERVANCY)
JT
11/24/2017
774.00 (PV LAND CONSERVANCY)
JT
i 1/27/2017
258.00 (PV LAND CONSERVANCY)
JT
11/28/2017
150.50 (PV LAND CONSERVANCY)
JT
11/29/2017
580.50 (PV LAND CONSERVANCY)
JT
11/30/2017
322.50 (PV LAND CONSERVANCY)
JT
12/1/2017
258.00 (PV LAND CONSERVANCY)
JT
12/1/2017
537.50 (PV LAND CONSERVANCY)
JT
12/5/2017
236.50 (PV LAND CONSERVANCY)
JT
1/11/2018
516.00 (PV LAND CONSERVANCY)
JT
11/20/2017
43.00 (PV LAND CONSERVANCY)
RB1
12/14/2017
150.00 (PV LAND CONSERVANCY)
R61
12/11/2017
100.00 (PV LAND CONSERVANCY)
R61
12/8/2017
125.00 (PV LAND CONSERVANCY)
JT
12/14/2017
860.00 (PV LAND CONSERVANCY)
R131
10/13/2017
100.00 (PV LAND CONSERVANCY)
JT
9/21/2017
215.00 (PV LAND CONSERVANCY)
JT
1/22/2018
580.50 (PV LAND CONSERVANCY)
JT
10/12/2017
559.00 (PV LAND CONSERVANCY)
JT
11/1/2017
215.00 (PV LAND CONSERVANCY)
JT
1/10/2018
537.50 (PV LAND CONSERVANCY)
OJA
2/7/2018
172.00 (SETTLEMENT LETTER)
OJA
2/5/2018
322.50 (SETTLEMENT LETTER)
OJA
2/8/2018
107.50 (SETTLEMENT)
OJA
2/1/2018
193.50 (SETTLEMENT)
OJA
2/6/2018
172.00 (SETTLEMENT)
OJA
2/2/2018
193.50 (SETTLEMENT)
JSA
2/23/2018
21.50 (DEPOSITION)
24,414.50
7
7
7
7
9
7
7
7
7
7
7
)L JEFFREY LEWIS
ATTORNEY AT LAW
March 26, 2018
VIA E-MAIL AND CONFIRMED BY U.S. MAIL
City of Rancho Palos Verdes
30940 Hawthorne Blvd.
Rancho Palos Verdes, CA 90275
Mayor Susan Brooks
susan.brooks@rpvca.gov
Mayor Pro Tem Jerry Duhovic
jerry.duhovic@rpvca.gov
Councilman Eric Alegria
eric.alegria@rpvca.gov
Councilman John. Cruikshank
john.cruikshank@rpvca.gov
Councilman Ken Dyda
ken.dyda@rpvca.gov
RE: Potential Litigation Against Former Mayor Brian Campbell
Dear Mayor Brooks and Members of the City Council,
I read with interest in the Daily Breeze that the City is contemplating filing a
lawsuit against former Mayor Brian Campbell. He was not aware of this
threat. I represented Brian Campbell at the recent deposition by Green Hills.
As you deliberate in closed session on the question of whether to authorize a
lawsuit, I would urge you to consider the following questions:
1. Is there precedent for either our City or any city suing a former official
for this type of claim?
2. What is the City Attorney's estimate of the total attorney's fees that
will be incurred by the City to pursue this lawsuit and will the City
recover such fees if the City prevails?
3. What is the City's exposure to counterclaims against it or individual
councilmembers or an adverse fee award to former Mayor Campbell?
4. Has Green Hills filed or threatened to sue the City over this issue? If
not, is the City creating a problem that does not exist? If Green Hills
has threatened to sue the City does a suit against Brian Campbell
provide the City any protection from Green Hills? If not, what is the
point except for political gain? Brian Campbell has indicated over and
p: 310,935.4001 t 310.872.5389
609 Deop Malley (:hive. Suite; 200 1 Rolling Hills Estate, CA 610274
JefftewisLawxom
March 26, 2018
over that he is attempting to cooperate. Why hasn't the City or City
Attorney reciprocated and cooperated?
The controversy presents a "he said, she said" dispute between Dave
Aleshire and Brian Campbell. is Dave Aleshire presenting a non -
biased recommendation to the Council? Should a neutral opinion be
sought? Former Mayor Campbell says he has ample email evidence of
Dave Aleshire's biased misrepresentations to the council and examples
of his undermining the very council he is supposed to represent.
Shouldn't you explore those before a decision is made?
6. What does this mean for public trust in our city government if former
officials are sued on the authority of present officials? During this time
that the City is urging passage of charter city and trying to improve
public trust, is this the time to file this lawsuit?
1 thank you each for consideration of these issues and for your service to the
community.
Very truly yours,
Jeffrey Lewis
cc: Via Email Only
Dave Aleshire (daleshire@awattorneys.com)
Doug Willmore (dwillmore@rpvca.gov)