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From YouTube: Public Integrity Subcommittee Meeting | July 16, 2018
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A
Okay,
so
I'll
call
it
order
the
whatever
I
guess
it's
a
special
meeting,
but
it's
the
City
Council
public
integrity,
standing
subcommittee
that
councilmember
Jeff
Kors
council
member,
at
least
some
Middleton.
Thank
you
for
people
who
are
here.
This
is
on
the
air.
There
are
these
new
cards.
You
can
see
this
when
people
know
they're
on
the
air,
and
so
this
is
the
first
of
what
will
be
quarterly
Public
Integrity
Standing
Committee
meetings
to
update
the
public
on
what
we're
doing
how
the
ordinances
are
working
changes.
B
A
Yes,
so
order
the
day
as
we'll
do
public
comment.
First
then,
we'll
do
what
is
now
item
three
discussion
and
update
re
Public,
Integrity
matters
and
then
after
that,
we'll
do
item
2,
which
is
review
of
the
draft
Public
Integrity
ordinance.
So
we
can
get
everyone
here
copies
with
enough
time
to
look
at
them
as
we're
going
through
them.
So
I
agree.
C
A
A
D
Being
there,
oh,
do
you
have
a
couple
of
comments
on
the
in
threes
yeah,
please,
okay,
good
evening,
council
members,
my
name
is
David
Friedman.
As
you
know,
I
served
as
the
co-chair
of
the
transparency
Committee
of
the
ethics,
transparency
and
governmental
reform
task
force
on
item
3d.
D
Finally,
on
item
3a
I:
ask
that
you
establish
a
regular
quarterly
meeting
date
holding
special
meetings
such
as
today's
limits.
Public
matter
comment,
two
matters
on
the
meaning
agenda
and
our
residents
should
feel
free
to
speak
about
any
issue
within
the
jurisdiction
of
the
subcommittee
at
its
quarterly
meetings.
The
extent
that
public
comment
is
not
limited.
Three
minutes
I
wasn't
clear,
but
that
can
be
specified
on
the
agenda.
A
E
Expensive
beating
a
dead
horse
I
just
want
to
raise
the
question
about.
Where
is
my
pet
toy?
The
Google
whistleblower
I
know
that
the
last
meeting
we
had
they
corrected
some
of
the
stuff,
but
they
were
you're
going
to
seek
outside
resources
to
see
if
we
could
have
it
turned
over
to
an
outside
agency.
Can
somebody
tell
me
where
we
stand
on
that
that.
A
Would
be
in
the
discussion
on
the
city
attorney
over
for
oh
okay,
ethics
and
transparency
that
will
in
that,
and
that
was
written
just
in
response
to
your
comment
David
to
keep
that
open
to
really
anything
the
people
want
to,
but
I
think
we
do
need
to
have
sort
of
a
catch-all
because
the
goal.
This
is
good
public
comment
on
any
public
integrity
related
issue.
So
we
write
the
agenda
to
make
that
clear.
Can.
E
I
suggest
I'm
Steve
bones.
Is
that
as
dave
did,
would
you
identify
yourself
as
we
speechless
as
we
speak,
I'm
sorry,
my
name
is
Russ
you--they
we
are
on
the
air
and
I.
Don't
know
if
I
should
tell
you.
I
I
serve
on
the
ethics
committee
as
I
guess,
chairman
out,
cuz
you're,
the
co-chairman
has
been
gone
for
the
last
year
and
a
half
okay.
A
So
why
don't
we
go
in
number
three
discussion
and
update
republic
integrity
matters
meet
thing
I
have
because
most
of
it'll
be
in
the
City
Attorney's
report
in
thinking
about
this
is
whether
it's
a
whistleblower
complaint
or
an
actual
complaint
that
you
receive,
or
someone
on
council
receives
and
refers
to
you
often
there's
personnel
information
or
turn
to
client
privilege
information,
I.
Think
it's
really
important
that
contemporaneously,
you
keep
a
record
of
it
that
someone
did
do
a
report.
A
What
investigation,
if
any,
was
done,
what
conclusions
were
done
and
how
it
was
handled,
and
that
should
probably
come
to
the
subcommittee
in
a
confidential
way
and
then
we
can
make
it
an
analysis
of
it,
but
I
think
we
don't
have
a
record
of
those.
You
know
we
will
all
at
some
point
not
be
here
and
something
could
come
up
and
then
it's
we
don't
know
what
happened
so
I
think
just
keeping
that
kind
of
contemporaneous
report
I
think
would
be
helpful.
So
that
was
my
only
thing.
I
wanted
to
suggest.
C
F
B
Right
now,
the
process
is
a
little
bit
paused,
because
mr.
youth,
he
made
his
comments
at
the
last
meeting,
and
the
subcommittee
seemed
somewhat
receptive
to
the
notion
of
an
outside
party
potentially
being
responsible
for
administration
of
the
whistleblower
program.
So
on
a
certain
level,
I'm
happy
to
report
that
we
did
actually
receive
our
first
whistleblower
complaint
and
I
can
tell
you
that
it
has
been
sitting
just
for
a
short
amount
of
time
pending
further
sub
committee
direction.
B
When
we
have
data
to
present
to
the
subcommittee
regarding
the
potential
third
parties
commensurate
with
my
other
responsibilities
to
the
city,
I
am
right
now
it
so
happens
in
the
process
of
compiling
a
list
of
ten
attorneys
that
I'm
going
to
be
transmitting
to
mr.
Friedman
for
another
purpose.
Any
and
all
of
these
attorneys
would
be
equally
competent
and
qualified
to
administer
the
whistleblower
hotline
in
the
event
that
the
subcommittee
wants
to
make
a
recommendation
to
the
council
in
that
regard
or
take
action.
Independent
of
the
council
in
that
regard,
but
dr.
B
ready
and
I
would
probably
necessarily
consult
and
confer
and
he'll
make
a
recommendation
to
you.
I
suspect,
with
regard
to
staffing
and
financial
impacts
of
any
decision
that
the
council
might
make
to
park
that
program
in
the
lap
of
someone
who
will
likely
charge
us
well
north
of
$200
per
hour,
as
opposed
to
it
being
no
cost.
If
the
City
Attorney's
office
administers
the
program
and
I'm
well
aware
that
there
are
certain
things
that
are
worth
a
price
and
certain
things
that
are
not.
B
But
that's
why
the
two
of
you
were
elected
and
why
we're
providing
you
with
those
options.
So
I
expect
that
at
the
next
subcommittee
meeting
we'll
be
moving
forward
with
a
staff
report.
In
that
respect,
and
there's
only
been
the
one
complaint,
as
I
mentioned,
it
is
as
one
of
you
PI
think,
counselor
and,
of
course
made
the
comment
that
these
are
going
to
often
be
personnel
related
matters.
It
is
a
personnel
related
matter.
C
B
Larger
cities,
just
as
a
matter
of
course,
a
very
best
friend
from
my
mean
streets
of
New
Jersey
days-
is
currently
employed
by
the
city
of
San
Francisco
as
an
employment
investigator.
So
there
are
plenty
of
larger
organizations
that
have
these
independent
and
trusted
employees,
and
we
don't
happen
to
have
that
so
using
a
service
like
what
you're
describing
councilmember
Middleton
well
within
the
purview
of
the
City
Council,
but.
E
But
there
may
be
a
threshold
that
where
one
would
want
to
bring
in
an
outside
agency,
I'd
hate
to
have
every
quote.
Whistleblower
thing
go
to
an
outside
agency
when
it
could
very
appropriately
be
handled
inside,
but
city
attorney,
and
it
would
be
up
to
the
city
attorney
unless,
of
course,
the
city
attorney
is
the
subject
of
the
whistleblower
to
decide
where
it
goes.
A
Which
is
how
we
initially
did.
It
was
as
long
as
it's
not
the
city
attorney
but
I
think
the
point
Russ
made
and
maybe
is
some
kind
of
hybrid,
is
you
know,
here's
a
normal
process
on
the
website
which
would
go
to
the
city
attorney
if
you're
not
comfortable
talking
to
the
city
attorney,
because
the
city
attorney
does
work
for
the
members
of
the
council,
here's
an
independent
anonymous
number.
You
can
call
to
see.
A
A
member
of
the
City
Council,
the
City
Attorney's
gonna,
send
it
to
someone
outside
anyway,
so
I
think
that
might
be
a
way
to
handle
it.
You
know
some
kind
of
hybrid,
the
other
thing
just
because
you
mentioned
it
Eddie
that
you
sent
a
list
of
ten
attorneys
to
David
Friedman
on
another
matter,
just
to
be
clear
that
he's
not
limited
to
those
10
attorneys
correct,
there's
just
some
ones.
You
know
who
you
happen
to,
let
him
know
that's.
A
B
So,
with
respect
to
our
Public
Integrity
programs,
I'm
happy
to
say
that
we've
had
the
opportunity
through
dialogue,
mr.
Friedman
and
I
have
refined
even
further
beyond
the
point
of
the
staff
report
that
you're
going
to
be
receiving
in
a
few
moments,
the
ordinance
and
the
direction
we
wanted
to
go
with
respect
to
the
ordinance.
There
certainly
are
some
things
that
are
left
right
now,
pending
one
being
the
very
good
example
that
Friedman
gave
with
respect
to
our
documentation
and
accessibility
of
documentation
regarding
Public
Integrity
matters.
B
The
city
attorney
section
of
the
website
is
very,
very
bare-bones.
It's
a
single
page.
If
you've
ever
looked
at
it
and
it
simply
says
a
very,
it
provides
a
very
short
description
of
my
job
and
it
also
affords
members
of
the
public
with
a
few
suggested
organizations
and
I
think
some
contact
information
regarding
ethical
issues.
That's
well
short
of
I
think
what
was
envisioned
by
the
working
groups
and
the
task
force,
and
this
council
subcommittee,
when
you
all,
took
up
that
gauntlet.
B
So
it
occurs
to
me
that
now,
with
a
short
break
before
we
have
another
City
Council
meeting,
it's
an
ideal
time
for
us
to
start
investigating
and
implementing
some
of
the
reforms
that
mr.
Friedman
quite
correctly
notes,
have
been
the
subject
of
ample
discussion.
I'm,
not
sure,
frankly,
that
the
council
subcommittee
would
want
them
to
return
to
this
agenda
for
even
more
discussion.
B
There
are
a
total
of
six
areas
of
taskforce,
work
that
really
haven't
yet
evolved
into
the
moment
into
the
point
where
we're
legislating
so
I
suspect
that
this
subcommittee
and
any
members
of
the
community
who
are
interested
in
assisting
it,
will
probably
move
forward
and
provide
direction
to
my
office
with
respect
to
other
legislation
that
may
be
necessary
and
appropriate.
We're
certainly
ready
and
willing
to
accommodate
that
I
guess.
Last
but
not
least
with
respect
to
Public
Integrity
is
the
fact
that
and
I
think
it's
agendized
I'm
gonna
include
it.
B
If
I
may
in
the
report
that
I
deliver
now
so
as
not
to
speak,
more
than
I
need
to
I
want
to
be
clear
and
be
very
happy
to
tell
you
that
the
allegations
and
there
were
multiple
allegations
that
the
city
missed,
stepped
and
erred
with
respect
to
the
political
reform
act
regarding
publicity
and
documentation.
That
was
educational
on
measure
C.
B
Those
allegations
were
simply
rejected
by
the
FPPC
I'd,
also
like
to
note
on
behalf
of
councilmember
holstege
who's,
not
here
today
that
there
was
actually
a
pair
of
allegations
that
she
had
violated
the
conflict
of
interest
laws.
Those
weren't
even
investigated,
so
they
weren't,
even
deemed
by
the
FPPC,
to
be
worthy
of
that
investigation.
Dr.
B
Reddy
did
direct
that
there
be
a
press
release
at
the
time,
but
in
case
any
of
you
missed
that
as
an
item
I
think
it's
imperative
that
the
folks
who
are
most
concerned
about
the
ethics
of
the
city
are
aware
that
twice
now,
since
I've
been
City
Attorney,
the
FPPC
has
cleared
the
city
of
any
allegation
of
wrongdoing
with
respect
to
educational
mailers
in
the
initiative
process.
I
think
that
really
speaks
well
of
our
organization
and
our
staff
work
and
the
direction
that
we've
received
frankly
from
the
City
Council,
which
has
been
really
very
helpful.
B
We're
not
the
policymakers
at
the
staff
level
and
they
make
sure
that
when
we
are
educating
our
community
that
we're
doing
so
in
a
fashion
that
is
consistent
with
the
council's
take
on
these
issues
and
and
frankly
that
is
all
we
can
do
when
we
educate.
We
can
provide
you
with
information
that
we
deem
reliable,
that
we
hope
that
the
voting
community
will
rely
upon,
and
it
gives
me
real
great
pleasure
to
make
a
report
particularly
to
this
group
that
the
city
was
cleared
and
I.
Think
that's
enough
for
today.
A
Conflict
is
if
you
owned,
and
also
if
we
had
a
fiduciary
relationship
being
a
member
of
a
board
of
directors
of
a
nonprofit
organization
or
another
entity,
as
well
as
a
pro
bono
lawyer,
and/or
accountant
financial
person,
because
that's
fiduciary,
so
those
should
have
all
been
turned
in
by
now
right.
I
think
June
30th
was
the
deadline
so
just
sort
of
what
it
have
people
turn
those
in
and
have.
We
notified
folks
where
they're,
clearly
conflicts
of
people
who
are
serving
on
boards,
Commission's
or
councils
that
they
can't
vote
and
what
they
need
to
do.
A
B
E
A
A
A
On
many
things,
I
understand
yeah.
The
other
thing
just
to
share
is
that
one
things
that's
been
requested
for
quite
some
time
is
that
we
not
only
notify
property
owners
of
things
that
you
need
to
notify
under
state
law
within
500
feet,
sort
of
radius,
but
tenants,
because
if
you
live,
there
impacts
to
you
as
much
as
if
you
own
the
property
and
we're
having
some
challenge
with
apartment
buildings,
how
the
addresses
and
have
that
work.
A
But
that's
been
worked
out,
and
now
we
do
have
a
system
where
we
can
actually
notify
people
in
apartment
buildings
as
well,
because
we've
had
that
with
street
cleaning
where
people
you
know
find
they
can't
go
out
of
their
driveway
because
their
an
apartment
building
and
they
didn't
get
the
notice.
But
we
now
have
that's
gotten
fixed
at
the
staff
level.
They
found
a
way
to
do
that,
so
I
just
want
to
share
that
with
the
public.
A
B
Are
right
now
locking,
in
a
date
to
train
department
heads
internally
with
respect
to
Public
Records
Act
I've,
delivered
one
ethics,
training
to
the
community
and
I
offered
at
that
time
and
made
a
commitment
that
I
would
provide
additional
training,
whether
it's
going
to
be
mr.
king
or
myself?
That's
my
assistant
city
attorney
who's.
A
very
well
experienced
ethics.
Trainer
were
well
positioned
to
offer
that
training
on
an
immediate
basis.
We
could
probably
put
something
together
in
the
space
of
a
couple
of
weeks.
A
B
A
B
Actually,
if
you
write
the
title
correctly-
and
it
tells
you
what's
actually
going
on-
that's
actually
what
the
Brown
Act
requires.
So
we
have
here
an
ordinance
that
amends
the
existing
chapter
of
the
municipal
code
that
we
adopted
again.
This
is
the
second
half
of
the
package,
and
we
are
dealing
here
with
noticing
with
lobbying
with
applicant
disclosure
and
we're
identifying
forthcoming
changes
in
relation
to
these
items.
Now
the
particulars
and
the
details
are
obviously
considerably
more
than
that.
B
I
think
it's
probably
fair
to
summarize
our
our
noticing
approach
exactly
the
way
that
councilmember
Coors
did.
The
notion
that
you
don't
have
an
interest
in
what's
happening
around
you
are
rented
or
leased.
Property
is
a
little
bit
silly.
The
flip
side
of
that
is
that,
as
we
go
through
the
course
and
scope
of
this
we're
learning,
because
we're
doing
things
that
a
lot
of
government
agencies
perhaps
have
not
done
so.
B
We've
decided
just
by
way
of
example,
with
respect
to
some
of
the
disclosures
of
rental
and
leased
property
that
we're
not
going
to
require
our
commissioners
or
our
board
members
or
our
other
officials
filing
these
special
Palm
Springs
forms
to
make
specific
disclosure
of
their
residence.
That
is,
if
you
side
in
a
leased
or
rented
property
you're
not
going
to
be
held
to
a
higher
standard
than
someone
who
happens
to
be
lucky
enough
to
own
their
home.
B
That
was
under
direction
and
pursuant
to
direction
from
the
subcommittee,
and
it
certainly
makes
a
lot
of
sense
to
me
as
the
city
attorney
that
we
wouldn't
want
to
punish
somebody
who
happens
to
rent
or
lease
with
a
greater
disclosure
obligation
than
the
owners.
But
the
noticing
provision,
as
councilmember
Coors
says.
It
really
is
a
very
important
and
quite
linked
component
of
this
approach
to
Public,
Integrity
and
noticing
and
transparency.
Because
at
this
point
we
feel
like
we'll
be
able
to
sufficiently
augment
our
process
internally
to
reach
everybody.
B
We
did
need
to
think
a
little
bit
about
what
we
were
doing
and
I
can't
promise
you
that
we've
nailed
it
precisely.
But
by
way
of
example,
one
of
the
things
that
we
had
to
do
that
sort
of
to
avoid
the
law
of
unintended
consequences
is
when
we
expanded
the
group
of
residents
that
we
would
be
providing
notice
to.
We
had
to
also
expand
the
number
of
people
that
would
allow
a
party
providing
notice
to
take
publication
as
a
path
apart
from
mailing.
B
So
we
doubled
the
the
number
that
was
in
the
code
in
most
instances,
from
five
hundred
to
a
thousand
and
I
think
that's
an
important
evolution
because
we
didn't
want
to
have
our
greater
transparency
result
in
more
publication
and
less
noticing
regarding
the
lobbying
provisions
of
the
ordinance,
it's
safe
to
say
that
most
of
them
have
been
lifted
rather
deliberately
and
and
with
shameless
plagiarism
from
the
City
of
West
Hollywood,
because
they
had
a
very
I
thought,
reasonably
simple
approach.
That
really
did
get
the
job
done.
B
That
process
has
been
tweaked
and
has
been
improved
slightly
by
my
drafting
slightly
based
on
input
from
mr.
Freedman
and
I.
Think
we've
reached
a
point
where
I'm
happy
to
tell
you
lobbyists
and
their
activities
will
be
known
and
that'll
include
not
only
parties
who
lobby
for
third
parties,
private
parties,
but
also
parties
who
who
lobby
for
the
city,
registration
and
transparency
are
obviously
the
goals,
and
this
is
not
a
gotcha
thing
for
the
city
and
I
think
that
probably
warrants
mentioned
for
all
of
these
Public
Integrity
ordinances.
I.
B
Don't
think
that
the
task
force
and
I
don't
think
that
the
council
subcommittee
was
interested
in
setting
up
a
series
of
ways
to
catch
people.
I
think
they
were
interested
in
setting
up
a
group
of
sort
of
aspirations
for
greater
transparency,
greater
communication,
greater
disclosure
and
higher
public
integrity
and
the
goal
here
again
not
to
punish
so
we're,
allowing
just
by
way
of
example
in
that
principle,
if
a
lobbyist
hasn't
registered
appropriately
or
allowing
alternate
forms
of
registration.
B
B
We
realized
that
our
staff
was
having
a
lot
of
problems
with
the
business
principle
disclosure
when
it
came
to
providing
business
principle
disclosure
in
the
staff
report,
because
we
had
written
an
ordinance
that
required
disclosure
down
to
a
threshold
of
$2,000
worth
of
ownership.
That
is
an
ownership
interest
of
$2,000
or
more
in
value,
and
that
was
based
on
some
some
old
regulations.
That
I
found
very
helpful
and
meaningful.
B
It's
your
job
to
know
whether
your
owners,
whether
your
managers,
whether
your
directors,
whether
the
people
running
your
company,
have
financial
relationships
of
significance
with
our
officials
and
if
you
have
those
relationships,
you
need
to
disclose
those
really
chips.
That's
going
to
actually
I
think
conform
to
what
I
believe
was
the
purpose
of
again
the
task
force
and
the
subcommittee's
work.
B
B
B
B
We
can
certainly
and
will
certainly
ask
every
time
we
make
these
disclosures,
we'll
ask
the
people
with
whom
were
speaking
well,
who
owns
the
company,
but
in
many
instances
what
we
discovered
is
that,
particularly
with
some
of
the
relatively
smaller
companies,
you
had
people
who
had
real
significant
privacy
concerns
with
respect
to
their
investments
in
these
companies
that
these
developers
and
other
parties
articulated
to
my
staff
and
I
will
tell
you
that
the
the
concern
was
not
about
the
identities.
The
concern
was
about
preserving
the
confidentiality
with
which
these
investments
were
accumulated.
B
So
we
took
the
approach
that,
with
respect
to
disclosure
we
weren't
going
to
require
disclosure
down
to
that
$2,000
level.
We
were
going
to
simply
say
that
if
you
have
an
owner
that
has
a
2,000
dollar
interest
in
the
company
that
that
owner
or
operator
make
that
disclosure.
So
the
council
can
be
certain
that
it
you'll
have
the
full
disclosure
of
all
of
the
leaders
of
the
company.
The
people
who
run
the
company
and
you'll
also
have
to
closure
of
ownership,
to
the
extent
that
it's
at
that
macro
level
as
a
matter
of
course.
A
A
No,
not
necessarily
if
the
applicants
gave
us
the
names
and
we
kept
them
confidential
for
privacy
reasons,
and
we
saw
them.
Then
we
would
know
the
person
who's
applying
may
not
realize
that
I
have
a
financial
relationship
with
this
person
right
so
they're
being
truthful.
They
don't
know
that,
so
we
could
be
voting
on
conflicts
which
actually
is
not
in
their
interest
because
they
can
end
up
with
a
10
90
problem
and
lose
all
their
benefit.
So
it's
I
I
think
we
still.
We
need
to
see
it.
A
I
understand
their
privacy
concerns,
but
counsel
or
Planning,
Commission
or
HSP.
Be
people
who
are
making,
especially
those
kind
of
decisions
need
to
confidentially
see
that
list.
In
order
to
know
if
we
have
a
conflict
now,
the
2000
level
is
what
you
picked,
and
maybe
it's
too
low
and
I'm
open
to
that
conversation,
but
I
need
to
know
if
I
don't
want
to
vote
on
something.
If
I
don't
know
that
I
may
have
a
conflict
and
their
concern
was
privacy.
A
B
Correct
and
the
problem
for
me
is
the
Public
Records
Act.
If
I
have
that
information
I'm,
not
sure
exactly
that,
I
will
be
successful
in
asserting
that
there's
a
confidentiality
or
privacy
interest
with
respect
to
that
information.
So
it
is
a
difficult
problem
and
I'm
open
to
any
direct
from
the
council
has
what
we
have
on
the
books
was
very
challenging
to
implement.
C
Transportation,
commissioners
voting
on
any
item
that
they
may
have
a
conflict
of
interest
on
it's
in
a
section
of
law
that
I
had
no
knowledge
of
before
getting
involved
in
with
that
Commission
I
bring
it
up
because
what
happens
on
the
agenda
is:
if
there
are
financial
holdings
that
could
create
any
conflict
for
anyone,
it
is
identified
who?
What
all
of
the
financial
interests
are?
It's
a
part
of
the
agenda.
You
get
your
package
and
it
says:
do
you
have
any
relationship
with
the
following
and
I
can
break
that
out
and
show
it?
You.
B
C
B
A
Bigger
issue
is
that
they
don't
know
right
if
you're
a
four
person
company.
You
know,
if
you
have
a
hundred
investors,
you
don't
know
right.
They
don't
know
that
you
know
right.
Let's
just
take,
you
know
you
could
clearly
have
a
familial
a
family
relationship.
You
could
have
a
financial
interest
because
of
without
knowing
and
so
I
just
want
to.
It's
I
think
we
need
to
look
at
this
a
little
more
I'm.
B
Happy
to
look
at
it
as
as
carefully
as
as
you're
directing
I
would
just
say
that
the
the
conflict
of
interest
law
that
were
concerned
about
violating
is
at
this
level
with
respect
to
this
issue.
If
I
understand
the
council's
direction,
the
state
law
standard
we're
not
trying
to
create
a
higher
level.
A
B
B
That's
really
what
I
was
driving
at.
Let's
say:
hypothetically,
here's
a
hypothetical
to
respond
that
you
have
somebody
who
has
an
interest
worth
five
thousand
dollars
in
a
very
small
company,
that's
getting
a
contract
with
the
city
and
that
person
has
some
level
of
financial
relationship
with
one
of
the
officials
who's
going
to
be
voting
that
relationship.
B
Ninety
nine
percent
for
sure
has
absolutely
no
state
legal
significance
at
what
level
are
we
going
to
say
it
is
a
material
confident,
that's
that
that's
the
state
law
question
how
the
state
law
deals
with
it
materiality
of
the
relationship.
What
I
tried
to
do
here
is
reduce
the
concept
of
materiality
to
a
manageable
succinct
definition.
I
didn't
want
to
adopt
an
entire
regulatory
code
like
the
FPPC
has
okay.
F
If
the
consequences
are
that
the
development
permit
or
the
ordinance
is
invalid
or
void
or
voidable
or
subject
to
legal
challenge
as
a
result,
then
you
might
draft
your
ordinance
in
one
way
if
it's
not
subject
to
public
challenge,
because
it's
a
good
faith
test,
unless
there's
some
deliberate
misleading,
it
wouldn't
void
the
ordinance
or
the
permit,
then
you
might
draft
it
another
way.
So
what
is
the
consequence
of
not
doing
this
of
making
a
mistake
and
not
pointing
out
this
material
financial
relationship
between
an
investor
and
somebody
on
the
City
Council
I.
E
C
E
To
believe
in
not
creating
recreating
wheels
there,
there
must
be
other
jurisdictions
that
go
above
and
beyond
state
law
that,
rather
than
trying
to
make
it
up
yes,
totally
beginning
from
scratch,
so
because
others
would
have
experienced.
This
would
have
tried
different
things
that
were
onerous.
That
didn't
work.
So
is
there
any
way,
just
like
you
did
with
a
city
of
West
Hollywood
whether
things
are
there
other
jurisdictions
that
have
done
this
gone
above
and
beyond
state
law,
but
made
something
reasonably
and.
A
C
And
I
think
the
question
of
the
consequence
is
really
the
nub
of
the
the
issue.
The
other
part
to
me
is
intent
and
where
there
is
an
intent
to
to
withhold
information
that
someone
should
have
known
and
that
becomes
very
difficult
to
to
write
into
an
ordinance.
But
it's
it's.
What
we're
trying
to
get
at
yes
and.
A
Just
as
we
know
at
the
state
level,
with
1090
right,
even
if
the
people
voting
didn't
know,
there
was
a
conflict
and
even
if
the
applicant
didn't
know,
there's
a
conflict,
the
consequences
are
extra
significant
for
the
applicant
right.
If
it's
material,
they
lose
all
benefit
of
the
contract.
The
city
keeps
all
the
benefit,
even
if
it's
not
what
knowledge.
So,
if
we're
doing
it,
what
we're
doing
needs
to
have
defined
mounds
to
find
all
those
pieces
need
to
be
very
clearly
defined.
So
people
know
what
the
rules
are
and
and.
B
All
I
would
say
is
the
nature
of
the
conflict.
If
we
want
to
assert
that
it
is
a
conflict
at
these
very
low
levels
of
threshold
with
respect
to
ownership
interest,
it's
not
going
to
be
a
1090,
it's
going
to
be
a
violation
of
the
problem,
Springs
code
and
in
terms
of
defining
that
I
I
think
that
it's
going
to
be
extremely
daunting
to
do
something
like
this,
but
I'm
I
will
take
all
the
direction
and
I
will
certainly
investigate
all
over
the
state.
I
will.
D
The
point
that
I
had
raised
just
to
clarify
well,
first
of
all,
there
are
marks
which
I
won't
bother
with
thank
you
for
clarifying
the
owners
versus
renters
for
disclosure
of
home,
because
that
is
an
issue
that
I
had
raised
with
you
guys
a
few
months
ago.
So
thank
you
for
taking
care
of
that
the
rest
of
it
clearly
with
the
lobbyists.
That
was
part
of
our
recommendation.
So
thank
you
again.
I
think
my
last
comment
was
particularly
working
with
those
sort
of
the
1ps
world
and
I
can
deal
with
that
within
one
BS.
A
Yeah
and
I
want
to
be
careful
on
things
like
boards
of
advisors,
because
often
you're
on
a
Board
of
Advisors
that
actually
has
no
fiduciary
relationship.
All
Board
of
Directors
does
and
we're
going
to
the
fiduciary
relationship.
So
I
get
your
point.
We're
gonna
have
to
be
very
careful
how
we
award
it
yeah
to
make
sure
we
don't,
if
someone's
on
an
advisory
board
that
has
no
fiduciary
relationship.
A
That's
not
what
we're
going
after
all
right
we're
going
after
the
fiduciary,
the
legal
relationship
we
don't
want.
If
you,
the
whole
idea
is,
if
you
have
a
legal
duty
to
this
organization,
and
you
have
one
to
the
city,
you
can't
serve
two
masters.
If
you
are
an
advisor
and
don't
have
a
legal
relationship
to
the
organization
and
you
do
to
the
city,
you
can
well.
D
I
mean
so
sorry
to
be
picky
about
it.
It's
the
question
of
governing
board.
In
other
words,
if
you
are
on
the
governing
board,
my
suggestion
is
that,
if
you're
on
the
governing
board,
regardless
of
what
it
is
called
so
that
was
my
suggestion-
I
mean
there
could
be
boards
of
advisers
that
are
not
the
governing
boards.
So
I
suggested
some
language
about
governing
board
with
governing
body
or
board.
Yes,
language
and
the
unincorporated
Corporations.