Hermosa Beach Taxpayer Group v. School District

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If you’d like to read the complaint I drafted for Hermosa Beach Taxpayer Group alleging that the Hermosa Beach City School District is illegally using school bond money towards the demolition of North School, it’s available here:

2017.09.27 FAC Conformed

I filed it along with four volumes of exhibits, also available here:

EXHIBITS VOLUME 1

EXHIBITS VOLUME 2

EXHIBITS VOLUME 3

EXHIBITS VOLUME 4

A description of all exhibits is below:

VOLUME 1

Exhibit 1               Photographs of North School

Exhibit 2              Map of Hermosa showing its schools

Exhibit 3              Photos of Pier Avenue before and after the 1933 earthquake

Exhibit 4              Map of Pier Avenue School facilities

Exhibit 5              California Education Code §§ 17280 and 17280.5 and Executive Summary of 2002 Seismic Safety Inventory of California Public Schools

Exhibit 6              March 13, 1934 Los Angeles Times article “School Repair Funds Arrive” and September 2, 1934 Los Angeles Times article “Awards Made of Contracts for New Work”

Exhibit 7              June 16, 1995 Los Angeles Times article “Samuel E. Lunden; Veteran L.A. Architect”; June 18, 1995 New York Times article “Samuel E. Lunden, Architect, 97, Dies”; images of Pacific Stock Exchange and USC Doheney Memorial Library

Exhibit 8              Application No. 382 for reconstruction of North School, filed 6/21/1934

Exhibit 9              Six (6) pages of architectural drawings for North School Reconstruction

Exhibit 10             Correspondence between Chris Miller and Amy H. Crain, State Historian II

Exhibit 11             Email from Debi Howell-Ardila obtained by Hermosa Beach Taxpayer Group

Exhibit 12             December 27, 1984 Easy Reader article, “Despite election reversals, HB presses on with one school plan”

Exhibit 13             Two pages from 10/14/1975 City Council meeting minutes; page from 11/25/1975 City Council meeting minutes; page from 12/9/1975 City Council meeting minutes; page from 12/15/1975 School Board meeting minutes

Exhibit 14             November 26, 1975 Daily Breeze Article, “Hermosa Closer to School Buy”

Exhibit 15             Appraisal letter from William S. Crosbie, M.A.I., C.R.E., and real estate appraiser

Exhibit 16             “Purchase Agreement”, and all exhibits, obtained by Hermosa Beach Taxpayer Group

VOLUME II

Exhibit 17             Minutes from City Council meeting dated 6/14/77

Exhibit 18             Minutes for workshops #1-8, dated from 10/26/1977 through 1/1/1978

Exhibit 19             Grant Deed transferring Parcel 4 from the City to South Bay Alano Club

Exhibit 20             California Code of Civil Procedure § 526a

Exhibit 21             Children’s Journey lease agreements, and photograph of Children’s Journey sign at North School

Exhibit 22             Unsigned South Bay Adult School lease

Exhibit 23             Children’s Journey Fact Sheet and No on S campaign flyer

Exhibit 24             February 25, 1993 Easy Reader article “New superintendent explains needs for second Hermosa Beach school”

Exhibit 25             School District’s 2015/2016 Enrollment Report

Exhibit 26             November 22, 2013 Beach Reporter article, “City attorney questions document in Pier Avenue School sale”

Exhibit 27             Transcript reflecting a portion of the May 31, 2016 Joint City Council and School Board meeting (video here)

Exhibit 28             Summary of District expenditures on temporary solutions to overcrowding between 2012-2016

Exhibit 29             December 12, 2012 memo from Superintendent to Board recommending establishment of FPAC

Exhibit 30             BCA Architects’ estimates to renovate and rebuild North School

Exhibit 31             9/30/09 Bond Measure J Citizen’s Oversight Committee Final Report

Exhibit 32             Transcript of meeting from April 10, 2013 School Board meeting (video here)

Exhibit 33             Transcript of May 28, 2014 Joint City/District Meeting, see pp. 4-5 (video here)

Exhibit 34             Emails from Monique Ehsan, FPAC chair, in mid-late 2014

Exhibit 35             OPSC letter dated March 26, 2014

Exhibit 36             Easy Reader News, Letter to Editor by Tom Bakaly (City Manager) dated October 9, 2014

Exhibit 37             January 1, 2014 list of Hermosa Beach Community Center (aka Pier Avenue School) tenants

Exhibit 38             Volume 1, No. 10 of HBCSD ~ Board Highlights newsletter, May 2014 edition

Exhibit 39             S.T.A.R. brochure

Exhibit 40             June 5, 2014 Beach Reporter article, “HBCSD considers administrative move to South Park

Exhibit 41             October 8, 2013 Update on Proposed Expansion

Exhibit 42             Summary of District expenditures renovating South School

Exhibit 43             July 9, 2014 email from Mayor DiVirgilio attaching official letter response

Exhibit 44             July 30, 2003 letter from David Breiholtz, obtained by Hermosa Beach Taxpayer Group

Exhibit 45             Transcript of a portion of May 4, 2016 Hermosa Beach City Council Meeting

Exhibit 46             February 10, 2015 City Council meeting agenda and attachment (watch the video here)

Exhibit 47             Executive Summary of Martin & Associates Report

Exhibit 48             CivilSource 2015 Building & Facilities Condition Assessment

Exhibit 49             Email between School Board Member Jack Burns and community member

Exhibit 50             Summary of purchase orders greater than $500 on North School maintenance expenses from 2008-2016, prepared by Hermosa Beach Taxpayer Group

VOLUME III

Exhibit 51             Photographs of “antique” fixtures at North

Exhibit 52             Schedule of Financial Trends and Analysis for the Year Ended June 30, 2008

                             Schedule of Financial Trends and Analysis for the Year Ended June 30, 2015

Exhibit 53             Full text of Measure S

Exhibit 54             Impartial Analysis of Measure S

Exhibit 55             California Education Code § 7054

Exhibit 56             District contract with Isom Advisors

Exhibit 57             District contract with TPRC Communications

Exhibit 58             (blank)

Exhibit 59             Decision Insite’s 2015 Composite TK-12 Forecast

Exhibit 60             Decision Insite 2016 Chart of Enrollment History and Five Year Projection

Exhibit 61             Screenshot of Isom’s website (check it out here)

Exhibit 62             March 30, 2016 emails between Escalante and Isom

Exhibit 63             March 28, 2016 emails between Escalante, Collins, and Isom

Exhibit 64             March 27, 2016 emails between Escalante, Fox, Collins, and Isom

Exhibit 65             March 26, 2016 emails between Collins, Escalante, Fox, and Isom

Exhibit 66             April 22, 2016 email from Isom to Fox, Collins, and Escalante

Exhibit 67             March 28, 2016 email from Escalante to Tracy Robinson with attachment

Exhibit 68             November 2014 email from TPRC Communications to District employee

Exhibit 69             Sample Facebook posts by the District after hiring TPRC (link: their Facebook page)

Exhibit 70             California Department of Education Guide to School Site Analysis and Development

Exhibit 71             Measure S page of District website (link: District’s Measure S homepage, now missing language of Measure S)

Exhibit 72             Decision Insite Invoices

VOLUME IV

Exhibit 73             Cover page and pp. 1-2 of Notice Of Preparation of EIR re: North School Reconstruction (update: draft EIR available here)

Exhibit 74            Table of costs associated with renovations performed on Newport Beach Elementary School, obtained by Hermosa Beach Taxpayer Group

Exhibit 75            Email between Melissa Moore of El Segundo Unified School District and Hermosa community member regarding cost of renovations at Richmond Street Elementary and time to complete

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