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GRESHAM, SAVAGE, NOLAN &: TILDEN, LLP
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DONALDW. JOIDAH (1907-1919)
JOHN 8. LONIlIOAN (IlEI1UD 1976)
August 9, 2000
Mayor Judith Valles
City Attorney James F. Penman
City of San Bernardino
City Hall
300 North "0" Street
San Bernardino, CA 9241 It
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Re: Section 241 of the City Charter
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Dear Mayor Valles and Mr. Penman:
As you are aware, by his letter of July 18, 2000 the City Attorney requested that our law firm
prepare an analysis of Section 241 of the existing Charter of the City of San Bernardino.
Since the request related specifically to the Charter rather than Chapter 2.20 of the Municipal
code which deals with the engagement of "outside" counsel, it is presumed that the request relates
only to Charter authority, as opposed to the authority created by ordinance. Accordingly, this letter
directs itself exclusively to the Charter.
Section 241 states:
"The Mayor and Common Council shall have power and
authority to employ and engage such legal counsel and services and
other assistants, as may be necessary and proper for the interest and
benefit of the City and the inhabitants thereof. "
Thus, in order to pursue an analysis of that Section, an inquiry must be made into what is
meant by "necessary and proper".
Section 55 of the Charter, in pertinent part, provides:
"
(d) The City Attorney shall be the chief legal officer of the City; he or she
shall represent and advise the Mayor and Common Council and all City officers
in all matters of law pertaining to their offices; he or she shall represent and
appear for the City in all legal actions brought by or against the City, and
prosecute violations of City ordinances, and may prosecute violations of State
law which are misdemeanors or in.nctions and for which the City Attorney is
specifically granted the power of enforcement by State law without approval of
the District Anorney, or those violations which are drug or vice related; he or
RiveBide Office' 3403 Tenth Slreel, Suite 518, Riverside, CA 92501 .(909) 684-2171. Facsimile (909) 684-2150
ViclOlVille Office' 14350 Civic Drive, Suite 120. ViClOlVille, CA 92392. (760) 243-2889. Facsimile (760) 243-0467
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SHAM, SAVAGE, NOLAN & TILDEN, LLP
I. G..-m
Mayor Judith Valles
City Anorney James F. Penman
August 9,2000
Page 2
she shall also act and appear as attorney for any City officer or employee who is
a party to any legal action in his or her official capacity; he or she shall attend
meetings of the City Council, draft proposed ord;n~""~s and resolutions, give
his or her advice or opinion in writing when requested to do so in writing by the
Mayor or Common Council or other City official upon any matter pert~;ning to
Municipal affairs; and otherwise to do and perform all services incident to his or
her position and required by statute, this Charter or general law.
"
Prom the foregoing Charter description of the duties of the City Attorney, it is seen that the
person occupying that position has a great many areas of responsibility and is to act as "the chief
legal officer of the City" .
As a public officer, the City Anorney is, by law, expected to properly and timely provide the
services required of the office. Indeed, it would be tantamount to a waste of taxpayer funds if
"outside" counsel were hired to perform duties that were those which the City Attorney was
e~pected to discharge.
There are, however, areas of law so specialized or that require such special talents or
experience that a general legal practitioner would not be expected to provide them. Additionally,
occasions can arise where the City Attorney may, by reason of a conflict of interest, not be able to
discharge all the duties usually expected of the office. In such instances it would be appropriate for
"outside" counsel to be utilized because, without such use, the service could not otherwise be
performed.
This concept of avoidance of unnecessary dUDlication of expenditures and services has long
been followed in California. However, in most of the situations where the matter has been
considered, Counties rather than cities have been involved.
In Anorney General Opinion 52-36, it was stated that:
" ... the courts have held that the board is without authority to contract with
private parties for the performance of duties which the law enjoins upon county
officers. "
Additionally, in Attorney General Opinion 49-202 it was pointed out that:
"It has been held that the supervisors have no power to employ an attorney to
conduct litigation which by law is devolved upon the district anorney, though
they may employ an anorney to assist him in such matter."
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SHAM, SAVAGE, NOLAN & TILDEN, LLP
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Mayor Judith Valles
City Attorney James F. Penman
August 9, 2000
Page 3
As early as 1897 the California Supreme Court held:
" ...it is clearly the intention of the law that the district attorney, and no one else,
shall be and act as the legal advisor of the board,...
The contract, then, was merely an attempt on the part of the board of
supervisors to pay special counsel by the month for performing a duty which the
law imposed on the district attorney....
...to permit compensation for them would be to override the law, and to destroy
one of the strongest safeguards cast about the expenditure of county funds."
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Merriam v. Barnum (1897) 116 Cal. 619, at 623-625.
Again, in the next year, the Supreme Court held:
"If the board of supervisors could portion out the legal business of the county as
appertaining to license matters to outside attorneys, it could likewise apportion
to such anorneys all other branches of legal business in which the county was
directly interested, and thus relieve and deprive the district attorney of the very
labors which are devolved upon him by the law, and which he was elected by
the people to perform, and which under his oath of office he is bound to
perform. The law as it is framed does not allow such a practice. It was framed
for the very purpose of preventing such a practice."
Merced County v. Cook (1898) 120 Cal. 275, at 278.
A city case did come up in 1916 when the Appellate Court stated:
"The charter having provided a city attorney upon whom the board can call
when a defense to a suit is necessary, it by implication makes it incumbent upon
the board to avail itself of his services, and it cannot ignore this provision and
employ some other attorney to render those services which it is the duty of the
city attorney to perform. "
Rafael v. Bovle (1916) 31 Cal.App. 619, at 626.
Then, as recently as 1975, the Appellate Court again held that the duplication of attorney
effort applies to Charter cities because of the obligation of the city attorney to act. Montlromerv v.
SUDerior Court (1975) 46 Cal.App.3d 657.
Prom these authorities it is our belief that since the City Attorney is someone whom the
Charter specifically directs to perform legal duties, the City Attorney is compelled to do them unless
a conflict exists or specialized experience is essential.
RESHAM, SAVAGE, NOLAN & TILDEN, LLP
lea. B. GreIIauD
Mayor Judith Valles
City Attorney James F. Penman
August 9, 2000
Page 4
Since the determination of a conflict or the need for specialization is something that the City
Anorney is most aware of, it seems most logical that before "outside" counsel can be engaged,
inquiry should be made of the City Attorney to determine if a conflict exists or a need for
specialization is present. If the City Attorney indicates that either of those two situations is present,
then the engagement of outside counsel would be appropriate. .
Insofar as the selection of "outside" counsel is concerned, reference should again be made to
Article 55 and its recitation of the duties of the City Attorney. There it is seen that the City Attorney
is to ".. .advise the Mayor and Common Council and all City officers in all matters of law pertaining
to their offices;...".
Prom the quoted language it is noted that the City Attorney is to "advise" the Mayor and
Common Council on matters of law which would appear to include evaluation and selection of
"outside" counsel. Certainly, it is to be expected that, as an attorney, the City Attorney would be
aware of the expertise and reputations of attorneys that might be needed by the City. The City
Attorney can also be expected to be conversant with fee ranges and other aspects of compensation.
,Accordingly, practicality would appear to indicate that the City Attorney should be directly involved
with, and an active participant in, the selection, and terms of engagement, of "outside" counsel.
~~~
AIlen B. Gresham for
GRESHAM, SAVAGE.
NOLAN & TILDEN, LLP
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:ical Association
i ty Chapter
lairperson
1~:~E9~I~O~
87-6027
'01 JAN 16 P,10:~
January 16, 200 I
Japter of the Mexican American Political
:spected city policy makers to thank you
:ity ordinanc~and urge you to cast
~..:t.<o
.t is imperative that our city return to the
l supported by California state law. This
lunsel for our city should be handled by
Illes established in our city charter as well
ecks and balances of the elected city
. for our city to function efficiently and
sary to repeal ordinanc~
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natter.
Mexican American Po1itica1 As8ociation
San Bernardino City Chapter
Gi1 Navarro, Chairper80n
P.O. Box 1396 i~FCF!VI'
San Bernardino, Ca. 92402
Te1. (909) 787-6027 ]1
,JAil 16 PlO :~.
January 16, 2001
Mayor and Common Council
City of San Bernardino
City Hall
300 North 0 Street
San Bernardino, Ca. 92418
Dear Mayor and Council Members,
We, the members of the San Bemllrdino City Chapter of the Mexican American Political
Association, are writing this open letter to our respected city policy makers to thank you
for your recent adoption of a measure to repeal city ordinance..2.9 and urge you to cast
your vote today to finalize this action. ::4 d. tJ
As past unfortunate events have demonstrated, it is imperative that our city return to the
policy originally set forth in our city charter and supported by California state law. This
policy clearly states that the hiring of outside counsel for our city should be handled by
the mayor and council.
The current ordinance, which runs against the rules established in our city charter as well
as current state law, does not provide for the checks and balances of the elected city
policy makers, our mayor and council. In order for our city to function efficiently and
represent the needs of all its citizens, it is necessary to repeal ordinance 2.6.
2.2..0
Thank you for your attention to this important matter.
Sincerely,
rc/) I
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Gil Navarro, Chairperson
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Mexican American ~olitical Association
San Bernardino City Chapter
Gil Navarro, Chairperson
P.O. Box 1396 ""CtIV''''. >I!
San Bernardino, Ca. 924~2~ '
Tel. (909) 787-6027
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'01
JAN 16 A10:3
January 16, 2001
Mayor and Common Council
City of San Bernardino
City Hall
300 North 0 Street
San Bernardino, Ca 92418
Dear Mayor and Council Members,
We, the members of the San Bernardino City Chapter of the Mexican American Political
Association, are writing this open letter to our respected city policy makers to thank you
for your recent adoption of a measure to repeal city ordinance-t:e-and urge you to cast
your vote today to finalize this action. -:2: ,;2 <:)
As past unfortunate events have demonstrated, it is imperative that our city return to the
policy originally set forth in our city charter and supported by California state law. This
policy clearly states that the hiring of outside counsel for our city should be handled by
the mayor and council.
The current ordinance, which runs against the rules established in our city charter as well
as current state law, does not provide for the checks and balances of the elected city
policy makers, our mayor and council. In order for our city to function efficiently and
represent the needs of all its citizens, it is necessary to repeal ordinance~
'LZo
Thank you for your attention to this important matter.
Sincerely,
GffJJ!g:~
,
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CITY OF SAN BERNARDINO
INTEROFFICE MEMORANDUM
TO:
FROM:
Mayor and Common Council
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James F. Penman, City Attorney
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RE:
DATE:
CINEMA STAR MULTI-PLEX THEATER PROJECT DOCUMENTS
December 21, 1998
At the September 29, 1998 Adjourned Regular Meeting of the Mayor and Common Council
and the Community Redevelopment Commission, the Council/Commission declined to
, approve the Subordination and Intercreditor Agreement that had been prepared by GMAC.
Instead, the Council/Commission voted to purchase the GMAC funded permanent loan on
the same conditions as would otherwise have been obtained by GMAC upon sale of said
permanent loan to an underwriter of pooled mortgage loans along with an agency
permanent loan commitment for $3,600,000. and other language contained in the motion
approved on September 29 (copy attached).
Attached is a memorandum from Huston T. Carlyle analyzing the three documents that will
be presented to the Council/Commission at the Monday, December 21 meeting.
Mr. Carlyle points out that the same language in the permanent loan Subordination and
Intercreditor Agreement that the Council/Commission refused to approve in September
is still present. New language from GMAC in the construction loan document requiring us
to get the written permission and full release of the developer before we could "buy-out"
the senior loan from the senior lender and, if that failed, requiring us to indemnify, defend
and hold GMAC harmless in an amount not less than $12,000.000 and requiring us to
collateralize the $12,000,000 was proposed. Late Friday, however, GMAC dropped that
provision after our strenuous objection.
It is still our opinion as it was on September 29, that it would be unwise for the City/EDA
to agree to the language as detailed in Mr. Carlyle's memorandum.
We decline to approve the Subordination and Intercreditor Agreement (Permanent Loan)
and the Agency's Loan Commitment as written, We recommend that the
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To: Mayor and Common Council
Page 2
December 21,1998
Council/Commission not approve these documents due to the serious and
disadvantageous legal position such approval would attach to the City/EDA.
It has been proposed that we not sign the subordination and Intercreditor Agreement
(Permanent) now, but agree in writing to do so only if we decide not to make the loan
ourselves. This solution still obligates us to the objectional provisions in paragraph 1 (j) on
pages B-5 and 6 in the Permanent loan. These legal terms are not in the best interests of
the City and should not be approved. Surrendering our rights under the Bankruptcy laws
is imprudent.
Another proposal, to obtain another loan with higher interest but no objectional language
has been discussed. If such a loan is ultimately obtained it resolves one of our immediate
concerns. It is a policy decision to do so however. It is noted that even with such a
change, the lender may still demand that we agree now to approve a subordination and
intercreditor agreement in the future in the event we are unable to produce an alternate
permanent loan. Such a demand leaves us in the same legal quandary regarding this
objectionable language.
Respectfully submitted,
9~
ames F Penman
City Attorney
Attachment: two (2)
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CITY OF SAN BERNARDINO
INTEROFFICE MEMORANDUM
TO:
James F. Penman
City Anorney !J h
Huston T. Carlyle, Jr. ~
Sr. Assistant City Anorney
FROM:
DATE:
December 21, 1998
RE:
December 21, 1998 Community Development Commission Meeting Re:
a. Subordination and Intercreditor Agreement (Construction Loan)
b. Subordination and Intercreditor Agreement (permanent Loan)
c. Permanent Loan Commitment Letter
Reference is made to the above-indicated three documents relative to the MDA-San
Bernardino Associates -- Cinema Star Multi-Plex Theater Project -- set for discussion and possible
action at Monday's Commission meeting (agenda item #R-26).
As a result of the Commission's action at the September 29, 1998 meeting, steps were
undertaken to implement the direction so given. The three aforementioned documents are part of
the Commission's back-up for its December 21 meeting. These are the proposed final versions for
each of the three documents. The first two are "driven" by the willingness of GMAC (the senior
lender) to be accommodating; the last one has been prepared by the law firm of Sabo & Green.
Following is an analysis of the critical points in the first two documents (the document prepared by
Sabo & Green appears to be consistent with the Commission's directive, but will be mentioned
briefly at the end of this memorandum) which the Commission should be aware of before
authorizing staff to proceed with effecting the close of escrow.
Subordination and Intercreditor Agreement (Construction Loan):
There are four sections in this document which should be brought to the Commission's
attention. Section l(j) still contains language which prevents the Redevelopment Agency of the City
of San Bernardino (Agency), as Junior Lender, from exercising any of its rights in bankruptcy,
reorganization or insolvency proceedings without the prior written consent ofGMAC, which may
be given or withheld in GMAC's sole and absolute discretion. If the developer seeks the protection
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of bankruptcy court during the effective period of this document, the Agency is at the mercy of
GMAC relative to protecting its rights in such proceedings. There is one "out" to such a situation,
however, and that leads to an analysis of the second section in question, section 1(1).
It is probable, but not automatically the case in all instances, that the filing of bankruptcy,
reorganization or insolvency by the developer will be considered an event of default rising to the
level of a "Purchasing Event" as defined in said section 1 (1). If such is the case, then the Agency has
the right "to purchase the Senior Loan from the Senior Lender for a purchase price payable in cash
or immediately available funds equal to the total amount of the Senior Indebtedness and otherwise
on terms and conditions acceptable to Senior Lender...."
Section 1 (1) also contains additional language not heretofore seen that requires the Agency
to get the wrinen permission and full release of the Borrower (developer) to the Senior Lender for
such a transaction! buy-out and, failing that, the Agency will indemnify and defend and hold GMAC
harmless from any claims, damages, losses, and expenses incurred relating from this transactionlbuy-
out in an amount of not less than $12,000,000.00 (the estimated value of the project) and acceptable
to GMAC in its "reasonable discretion." We have been advised that GMAC is agreeable to
eliminating this language and merely requiring the Agency to use commercially acceptable
reasonable efforts in obtaining the Borrower's wrinen permission and full release.
The third section to be brought to the Commission's anention is not new, it simply has not
, and will not be deleted by GMAC: Section 4 reaffirms and spells out in more detail that the
Agency's ability to obtain any relief should the developer create a "Bankruptcy Event" is virtually
non-existent absent the wrinen permission of GMAC.
The fourth section of note is not a completely new concept per se, but it makes it crystal clear
the path that the Agency will be proceeding down should it not buyout the permanent senior loan
as specified in the future subordination and intercreditor agreement. Section 15 specifically refers
to Exhibit "B," which is the proposed second agreement now to be discussed.
Subordination and Intercreditor Agreement (Permanent Loan):
Section 1(1) of this document sets forth the terms and conditions by which the Agency has
a one-time right to purchase the Senior Loan from GMAC at 102% of the total amount of the Senior
Indebtedness within specified time frames. Again, GMAC is agreeable to deleting the required
indemnification of $12,000,000 should the Borrower's wrinen permission and release not be
obtained. obligating the Agency to once again use commercially acceptable reasonable efforts.
Execution of the first document obligates the Agency to execute this second document.
Should the Agency not purchase said Senior Loan under the terms and time frame specified in said
second document in Section 1(1), then the Agency will be bound by the terms contained in this
second document which contain all of the troublesome language of the first, plus more.
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Section 1 (j) contains not only the same language relative to bankruptcy, reorganization and
insolvency as did the first agreement, but also contains all of the classic "standstilI" language
discarded in the first agreement.
Section 4 is the same as in the first agreement - eliminating any rights the Agency may have
in a "Bankruptcy Event" absent the written permission of GMAC.
Permanent Loan Commitment Letter
This document was prepared by the law firm of Sabo & Green pursuant to the Commission's
directive at the September 29, 1998 meeting. It appears to be consistent with such direction. I would
note that the developer is to be required to first seek the permanent loan from the Agency. The letter
also obligates the Agency to sign the Subordination and Intercreditor Agreement (permanent Loan)
with the standstill provisions in it if GMAC ultimately funds the permanent loan.