HomeMy WebLinkAboutResolution 2008-51 Establishing Procedures for the Hearing O MC (S1A-511
Council/Agency Meeting Held: i2Vr ce
Deferred/Continued to:
prov d ❑ Conditi nally Approved ❑ Denied C y lera Sig a re
Council Meeting Date: 8/18/2008 Department ID Number: CA 08-10
CITY OF HUNTINGTON BEACH
REQUEST FOR CITY COUNCIL ACTION
SUBMITTED TO: MAYOR and CITY UNCIL MEMBERS
SUBMITTED BY: JENNIFER McGR rdWy
ty Attorney
PREPARED BY: JENNIFER MCGR Attorney
SUBJECT: Adopt Resolution Establishing Procedures for the Hearing Officer to
Process Claims for the (legally Converted Condominiums
Statement of Issue,Funding Source,Recommended Action,Alternative Action(s),Analysis,Environmental Status,Attachment(s)
Statement of Issue: On April 21, 2008, the City Council approved hiring Thomas W. Allen
for hearing officer services to establish procedures for processing claims and administer the
Condo Conversion Restitution Fund. The claims period has ended and the hearing officer
has established procedures to process the claims.
Funding Source: N/A
Recommended Action: Motion to:
�CSo�c�no� /()O. SOD
1. Approve the Resolution Establishing a Procedure for Processing Claims and Distribution
of the Condominium Conversion Restitution Fund.
Alternative Action(s):
1. Do not approve the Resolution Establishing a Procedure for Processing Claims and
Distribution of the Condominium Conversion Restitution Fund.
REQUEST FOR CITY COUNCIL ACTION
MEETING DATE: 8/18/2008 DEPARTMENT ID NUMBER: CA 08-10
Analysis: On April 21, 2008, the City Council approved to hire Thomas W. Allen for
hearing officer services to administer the Condominium Conversion Restitution Fund and
establish procedures to process the claims pursuant to Judge Carter's Order. After
conducting a chain of title search dating back to December 1999 of each of the
approximately 122 illegally converted condominiums, the City Attorney's Office identified and
mailed notices and claim forms to approximately 420 potential claimants on May 1, 2008.
The notice required each potential claimant to submit to the City, within 90-days of the notice,
a claim form indicating the amount of out-of-pocket expenses that they are claiming and
actual proof of such expenses in the form of receipts, invoices, etc. The 90-day claim period
ended on August 1, 2008. The City Attorney's Office has received a total of 15 claims to
date.
Meanwhile, Hearing Officer Thomas W. Allen has established procedures for processing the
claims pursuant to Judge Carter's Order and distributing the $220,975.00 in restitution
currently available for disbursement in the Condominium Conversion Restitution Fund. The
City Council must approve the resolution titled, "A Resolution of the City Council of the City of
Huntington Beach Establishing a Procedure for Processing Claims and Distribution of the
Condominium Conversion Restitution Fund," so that Mr. Allen may begin to process the
claims.
Strategic Plan Goal: Provide quality public services with the highest professional standards
to meet community expectations and needs, assuring that the city is sufficiently staffed and
equipped overall.
Environmental Status: N/A
Attachment
(s):
eescripTiOn
1. A Resolution of the City Council of the City of Huntington Beach
Establishing a Procedure for Processing Claims and Distribution of the
Condominium Conversion Restitution Fund
-2- 8/4/2008 10:06 AM
ATTACHMENT # 1
RESOLUTION NO. 2008-51
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
HUNTINGTON BEACH ESTABLISHING A PROCEDURE FOR
PROCESSING CLAIMS AND DISTRIBUTION OF THE
CONDOMINIUM CONVERSION RESTITUTION FUND
WHEREAS, in 2004 the City became aware of a scheme being perpetrated whereby
existing apartment units in the City had been and were being illegally sold to purchasers as if
they were legally created condominium units; and
The City commenced an investigation into this scheme and found that approximately 122
of these apartment units had been sold and that a substantial percentage of the purchasers were
unaware of the illegality involved while others were aware of, or participants in the scheme and
had purchased them for investment purposes; and
In 2004 the United States Attorney's Office commenced criminal actions against the
perpetrators of the scheme and in 2006/2007, seven individuals involved in this scheme were
convicted of felonies involving Mail Fraud, Honest Services Fraud and Aiding and Abetting; and
As a part of the sentencing Federal District Judge David Carter in the United States
District Court for the Central District of California ordered each of the seven defendants to pay
restitution to the City of Huntington Beach as follows:
Name of Defendant Amount to be Paid Paid to Date
Howard Richey $220,000 $220,000
Philip Benson(deceased) $679,000 0
Thomas Bagshaw, Jr. $261,000 $925
Jeffrey Crandall $ 63,000 $50
Harvey DuBose $679,000 0
Pamela Houchen $140,000 0
Michael McDonnell $361,000 0
(Although the amounts Judge Carter required each defendant to pay vary, the total amount of the
entire Fund will not exceed $679,000)
Judge Carter stated in each Defendant's Judgment and Probation/Commitment Order that
the "Victim" for purposes of payment of restitution is the "City of Huntington Beach in a
segregated fund for the benefit of good faith purchasers of fraudulently converted
condominiums;" and
As of August 4 2008 the Condominium Conversion Restitution Fund balance is
$220,975; and
Resolution No. 2008-51
On April 21, 2008 the City Council approved the appointment of Thomas W. Allen,
Attorney at Law, as the Hearing Officer to review, consider and rule on claims submitted; and
The City Council's objective in these proceedings is to achieve a fair and equitable
distribution of the restitution funds available in accordance with Judge Carter's pronouncement;
and
Pursuant to City Council direction given on October 15, 2007, the City Attorney's Office
mailed over 400 claim forms to individuals whose names were obtained by a title search
performed on each unit identified as having been fraudulently converted; and
The mailed claim forms describe the process for claim evaluation and invite the
addressees to file if they feel they qualify for reimbursement from the Fund.
NOW THEREFORE, the City Council of the City of Huntington Beach does hereby
resolve as follows:
SECTION 1. PURPOSE
The purpose of this Resolution is to establish the criteria by which the appointed Hearing
Officer shall consider and approve or deny Out-of-Pocket Expense claims made against the
Condominium Conversion Restitution Fund by Bona Fide (Good Faith) Purchasers of
Fraudulently Converted Units.
SECTION 2. DEFINITIONS
For purposes of this process, the following terms shall have the following meanings
A. Condominium Conversion Restitution Fund means the sum of money collected by
the Federal Court Probation Office from the individual named defendants and transmitted to the
City of Huntington Beach.
B. Fraudulently Converted Unit means a dwelling unit originally constructed as an
apartment in the City of Huntington Beach for which no condominium map or approval had been
granted by the City of Huntington Beach but which through a scheme developed individually or
collectively by the defendants in the Federal District Court case had been sold as an individual
condominium unit.
C. Good Faith (Bona Fide) Purchaser means a person or entity who purchased a
fraudulently converted condominium unit in good faith for valuable consideration and without
notice (actual or constructive) of any irregularity or impropriety in the creation
(documentation/title) of the condominium purchased. As used herein, "good faith" and "bona
fide" are synonymous.
Resolution No. 2008-51
D. Out of Pocket Expense means an expenditure of money actually made by a
Claimant as a cash disbursement for an item or service which would not have been required but
for the fact the Claimant was the victim of the condominium conversion scheme. The test will
include:
i. Whether the expense was incurred as a direct result of the fraud;
ii. Whether the expense would not have been incurred but for the fraud; and
iii. Whether the expenditure was appropriate and reasonable under the
circumstances at the time incurred.
SECTION 3. PROCESS FOR REVIEW OF CLAIMS
A. Initial Review:
The City Clerk provided all claims received to the Hearing Officer. On or before
September 8, 2008 the Hearing Officer shall have completed an initial review of the claims
submitted. Between September 22, 2008 and September 28, 2008, the Hearing Officer may hold
an open meeting to which all claimants will be invited at which time the Hearing Officer can
explain the hearing process and receive input from the persons present.
Each claim presented shall initially be evaluated by the Hearing Officer to
preliminarily determine whether the Claimant was a Good Faith (Bona Fide) Purchaser of a
Fraudulently Converted Unit and whether each amount claimed appears to qualify as an Out-of-
Pocket expense.
B. Hearing Process:
i. Commencing September 29, 2008, the Hearing Officer shall set and notice
hearing times and dates for all claimants.
ii. Each Claimant shall be notified as herein provided of the date, time and
place for the hearing. Each Claimant shall be entitled to only one change
of hearing date; any additional changes are subject to documentation based
upon emergency or illness.
iii. The hearings shall be conducted on an informal basis. After being sworn
as a witness, the Claimant will be asked to briefly explain the nature and
amount of the expenditures described in the filed claim form. The Hearing
Officer may ask questions of the Claimant for purposes of evaluation and
clarification.
In the event contentions are made by any other person that a Claimant is not a
good faith purchaser or that the expense claimed does not qualify as an out-of-pocket expense,
the Hearing Officer shall inquire of the person making the accusation to state the basis for the
contention and then shall allow the Claimant to respond. The Hearing Officer shall have the right
to continue the hearing to a date certain for the purpose of evaluating any such contentions. The
Hearing Officer may require any person making contentions in the hearings to reduce their
Resolution No. 2008-51
contentions to writing and submit them to the Hearing Officer by a date certain. The Hearing
Officer may also require the Claimant or any other participant to provide additional
documentation or other information.
If the Hearing Officer determines that significant contentions have been made
which cannot be resolved in the informal setting then the matter may be continued by the
Hearing Officer to a date certain at which time the matter shall be heard in accordance with the
Rules for Formal Hearings set forth in Section C..
C. Rules For Formal Hearings.
i. The hearing shall be conducted in accordance with the following
procedures and any additional procedures as announced and provided to
the participants in writing by the Hearing Officer.
ii. Oral evidence shall be taken only on oath or affirmation, administered by
the reporter, if present, or by the Hearing Officer.
M. The Parties shall have the following rights:
a. The right to call and examine witnesses (no subpoena power is
available), the number of which may be limited by the Hearing
Officer;
b. The right to introduce exhibits relevant to the issues of the case;
C. The right to cross-examination is not afforded; however, persons
present may request the Hearing Officer to make inquiry of
witnesses on specific, relevant questions.
iv. The Hearing Officer shall rule on all evidentiary issues and the following
shall apply:
a. The hearing need not be conducted according to technical rules
relating to evidence and witnesses, except as hereinafter provided.
Any relevant evidence shall be admitted if it is the sort of evidence
on which responsible persons are accustomed to rely in the conduct
of serious affairs, regardless of the existence of any common law
or statutory rule which might make improper the admission of the
evidence over objection in civil actions.
b. Hearsay evidence may be used for the purpose of supplementing or
explaining other evidence but over timely objection shall not be
sufficient in itself to support a finding unless it would be
admissible over objection in civil actions.
C. Judicial notice may be taken of any generally accepted information
or technical or scientific matter or fact that may be judicially
noticed by the courts of the state of California.
Resolution No. 2008-51
V. The Hearing Officer is authorized to establish rules and time frames for
any of the following:
a. Production of all documents, reports, videotapes, witness lists, and
any other evidence that will be relied upon in the hearing;
b. Any briefs on the issues or motions with respect to the
admissibility of any evidence;
C. Any documents that were not previously exchanged and provided
to the Hearing Officer, or witnesses and experts that were not
previously identified, may not be considered by the Hearing
Officer at the hearing, unless agreed otherwise by the Parties (term
defined ?)or upon a showing of good cause.
vi. Before the hearing, the Parties should pre-mark exhibits and should
attempt to resolve any disputes regarding the admissibility of exhibits.
vii. The Hearing Officer shall render a written ruling with respect to the
subject matter of the case, based upon a preponderance of the evidence as
the basis for the decision(s). The Claimant will proceed with presentation
of its case first and the order of the hearing shall then follow in an orderly
manner as determined by the Hearing Officer.
viii. Witnesses may be excluded upon the request of either party at the
commencement of the hearing and with the consent of the Hearing
Officer.
ix. The record of the hearing shall be maintained by the Hearing Officer or
the City and shall consist of a reporter's transcript or tape recording of all
oral evidence, arguments and rulings; copies of all exhibits offered and/or
admitted into evidence; copies of any written comments, arguments,
reports, documents, or other written materials presented to or relied upon
by the Hearing Officer; and the written decision of the Hearing Officer.
The record of the hearing shall be maintained by the Hearing Officer or
City until all appeals and court hearings have been concluded.
SECTION 4 PLAN FOR DISTRIBUTION
A. At the conclusion of the Process for Review of Claims, the Hearing Officer shall
determine the amount to which each Claimant is entitled and shall render a decision in writing.
If the Fund amount is sufficient to pay all approved claims in full then they shall be paid. If the
Fund amount is insufficient to pay all approved claims in full then all approved claims will be
paid on a pro-rata basis. The ratio for payment shall be determined by dividing the total approved
claims into the amount of the restitution fund and arriving at a percentage which shall then be
used to calculate each Claimant's share.
Resolution No. 2008-51
B. If an unexpended amount remains in the Fund after payment of all approved
claims, the City Council shall determine the distribution.
C. At a City Council meeting at least one year after the initial distribution of the
Fund pursuant to this Resolution, and annually thereafter for a period of xx years, the City's
Director of Finance shall report the current balance of the Fund and the City Attorney's Office
shall make a recommendation to the City Council for distribution of the balance.
SECTION 5. MISCELLANEOUS
A. There will be no priority or preferential categories established based on the nature
of claims, the type of expense incurred by the Claimant or the individual needs or circumstances
of the Claimant.
B. There will be no individualized preferential treatment for any individual, class or
group-
C. The Hearing Officer will not engage in evaluation of proposed future projects or
consider approval of future projects on Fraudulently Converted Condominiums; provided
however if a Claimant is contractually obligated to a future expenditure, and the expenditure
otherwise qualifies, it may be approved.
D. The notices of initial hearing dates, meeting times, rulings and acceptance or
rejection of claims shall all be done in writing, using the U.S. Postal Service. All notices shall be
mailed at least 5 days before the event is to occur. Continuance dates and times will either be
announced in a hearing or noticed in writing.
E. The Hearing Officer shall discourage telephone or email exchanges with
Claimants or other participants.
F. The hearings shall be open to the public; provided, however, the hearings are for
the purpose of considering each individual's claim and not as a forum for discussion of public
policy or political discourse. The Hearing Officer may limit or prohibit discussion and testimony
by and between attendees.
G. The decisions of the Hearing Officer are the final and conclusive administrative
decisions and are binding on all parties, including the City. There are no appeal rights to any
administrative agency or appointed/elected body. All written decisions of the Hearing Officer
shall include an advisement pursuant to California Code of Civil Procedure Section 1094.6, that
any court action to review a decision shall be commenced not later than the ninetieth day after
the date the decision is mailed.
BE IT FURTHER RESOLVED, that the Hearing Officer is authorized to interpret or
supplement the provisions of this Resolution with procedures and determinations not inconsistent
herewith in order to achieve the stated objective of a fair and equitable distribution of the
Condominium Conversion Restitution Fund.
Resolution No. 2008-51
PASSED AND ADOPTED by the City Council of the City of Huntington Beach at a
regular meeting thereof held on the 18th day of August 2008.
9
Mayor
REVIEW, A AP ROVED:
INITIATED AND APPROVED AS TO
FORM:
i
Cit Administrat r p-0- i
Q18 �3
Ir.City Attorney
Res. No. 2008-51
STATE OF CALIFORNIA
COUNTY OF ORANGE ) ss:
CITY OF HUNTINGTON BEACH )
1, JOAN L. FLYNN the duly elected, qualified City Clerk of the City of
Huntington Beach, and ex-officio Clerk of the City Council of said City, do hereby
certify that the whole number of members of the City Council of the City of
Huntington Beach is seven; that the foregoing resolution was passed and adopted
by the affirmative vote of at least a majority of all the members of said City Council
at a regular meeting thereof held on August 18, 2008 by the following vote:
AYES: Hansen, Hardy, Bohr, Cook, Coerper, Green, Carchio
NOES: None
ABSENT: None
ABSTAIN: None
Clerk and ex-offici Clerk of the
City Council of the City of
Huntington Beach, California
RCA ROUTING SHEET
INITIATING DEPARTMENT: City Attorney
SUBJECT: Resolution Establishing Hearing Officer Procedures for
Processing Claims for the Condo Conversion Fund
COUNCIL MEETING DATE: August 18, 2008
RCS` ATTAC�I STATUS
Ordinance (w/exhibits & legislative draft if applicable) Attached ❑
Not Applicable
Resolution (w/exhibits & legislative draft if applicable) Attached
Not Applicable ❑
Tract Map, Location Map and/or other Exhibits Attached ❑
Not Appiicable
Contract/Agreement (w/exhibits if applicable) Attached ❑
(Signed in full by the City Attorne ) Not Applicable
Subleases, Third Party Agreements, etc. Attached ❑
(Approved as to form by City Attorney) Not Applicable
Certificates of Insurance (Approved by the City Attorney) Attached ❑
Not Applicable
Fiscal Impact Statement (Unbudgeted, over $5,000) Attached ❑
Not Applicable
Bonds (If applicable) Attach
El
Not A educable
Staff Report (If applicable) Attached F-1 Applicable
Commission, Board or Committee Report (If applicable) Attached ❑
Not Applicable
Findings/Conditions for Approval and/or Denial Attached ❑
Not Applicable
EXPLANATION FOR MISSING� TACHIVIENTS
REVIEWED RETURNS® FOGR A. DED
Administrative Staff ( ) )
Deputy City Administrator (initial)
( ) )
City Administrator Initial )
City'Clerk ( )
IEXPLANATION::FOR RETURN OFWl—T8M:
S3/t/• �
RCA Author: JM/hh 25041
Public Comments for 08/18/08 City Council Meeting Page 1 of 2
Esparza, Patty
From: Flynn, Joan
Sent: Monday, August 18, 2008 12:44 PM
To: Lisa Schick; Esparza, Patty
Subject: RE: Public Comments for 08/18/08 City Council Meeting
Thank you Lisa --this will be submitted to City Council as a late communication at tonight's meeting.
From: Lisa Schick [mailto:lisa.schick@att.net]
Sent: Monday, August 18, 2008 11:16 AM
To: Flynn, Joan
Subject: Public Comments for 08/18/08 City Council Meeting
Importance: High
Hello Joan,
I am sending this e-mail with Public Comments for the 08/18/08 Huntington Beach City Council meeting because I
would like to voice my opinion but will not be able to attend in person as I am currently out of state.
Comments Regarding the Condo Conversion Restitution Fund Allocations:
I feel that the intent of the Condominium Conversion Restitution Fund is not being upheld by the City
of Huntington Beach based on their request for the victims of this fraudulent act to provide receipts
for expenses incurred as a result of the fraud. Judge Carter's directive specifically stated that the
restitution should be paid to the "City of Huntington Beach in a segregated fund for the benefit of the
good faith purchasers of the fraudulently converted condominiums." Providing proof that an owner
of one of these incurred expenses for repairs to their unit or replacing hot water heaters has nothing
to do with the illegally converted units. Any expenses for repairs to affected units would be an
individual's responsibility and should be handled through their buyer's home warranty policy or
directly with the contractors who performed the work. Many of the victims were first time home
buyers and trusted the "system" including their real estate agents, title companies and escrow firms
to make certain everything was done legally. These are the people who deserve damages paid to
them for the pain and suffering they endured for several years of not knowing if the biggest
investment they made in their lives was going to go down the drain.
The restitution should be divided among ALL of the good faith purchasers who signed the settlement
agreement with the City of Huntington Beach and worked with the City to ensure their units were in
line with the condominium guidelines provided as part of this settlement. There are several
homeowners who were victims of this fraud who were unable to refinance or sell their properties at
the height of the real estate market because of this case against the previous owners of the
properties. Also, in the documentation provided to each good faith purchaser there was no option to
request restitution if one did not have a "receipt"for their expense.
I would ask the City of Huntington Beach to reconsider the guidelines under which this Restitution
Fund is being disbursed and divide it equally among ALL good faith purchasers who tried to do the
right thing.
Thank you,
Lisa Schick
8/18/2008
Public Comments for 08/18/08 City Council Meeting Page 2 of 2
16741 Green Street HOA
If you need additional information or would like me to provide these comments in some other format, please let
me know.
Regards,
Lisa Schick
President, 16741 Green Street
714-330-1369
8/18/2008
Page 1 of 2
Esparza, Patty
From: Flynn, Joan
Sent: Monday, August 18, 2008 3:14 PM
To: Angelbeybe@aol.com
Cc: Esparza, Patty
Subject: RE: Late Communication - Item#23 - Public Comment
This will be included as requested. Joan
From: Angelbeybe@aol.com [mailto:Angelbeybe@aol.com]
Sent: Monday, August 18, 2008 3:11 PM
To: Flynn, Joan; esparza@surfcity-hb.org
Subject: Late Communication - Item #23 - Public Comment
Hi Joan,
Can you please include the below as "Late Communication for Item #23" (Condo conversion
Restitution Fund Allocations) as I would like to contribution my opinion and reasoning
behind, not submitting a claim.
In the letter I received dated May 1, 2008, from the office of Huntington Beach City Attorney,
it states I was sent the notice because I may be entitled to restitution...I am here to say, I am
entitled to restitution. I am a good faith purchaser and a victim of the fraudulently converted
condo scandal. Regarding "out of pocket costs" for repairs / improvements, I have not
submitted any receipts as requested for they were repairs and improvements that were
completed after we closed on our property, and they were not directly related to the
fraudulent activity. These repairs would have had to be completed regardless of the state of
ownership and some of them were covered by the home warranty policy that was in effect.
However, should I be misunderstanding the guidelines and you accept these types of out of
pocket expenses, hopefully, I will be allowed the opportunity to do so.
Based on your current procedures /guidelines for processing a claim, no option was made
available for "non-receipt" request for restitution. Per the letter received, it states "You must
provide actual proof of the amount you are claiming, in the form of receipts, invoices and any
other evidence that represents the amount of actual out of pocket expenses you suffered as
a good faith purchase and victim of the fraud." Also " without any actual proof of the amount
of out of pocket expenses you are claiming, your claim will be denied". Thus, I was
presented the lack of opportunity to submit a claim, because a receipt for my time involved
with city personal, title company representatives, HOA meetings, discussion and everything
else involved in the last 4 years does not fit the guidelines provided. What price can one put
on the stress of not knowing when, how and if my investment will become a default to the
system. In addition I had to deal with extreme stress and suffering that caused health
issues.
I also lost the greatest profit opportunity, during the height of the real estate market. I could
not sell my unit, at top dollar, knowing that my unit was still going thru the system, confusion
and uncertainly of becoming a legal condo.
f f , �
8/18/2008
Page 2 of 2
1 ask that you reevaluate your current guidelines for the distribution of restitution funds taking
into consideration the following:
Not all damages incurred were out of pocket expenses
Personal emotions, stress and time, should be taken into consideration.
The restitution funds should be equally distributed among the victims who worked with the
City, the title companies, inspectors, attorneys and other to comply with the City's requests,
sign the settlement and do what was requested to come to closure on this issue.
Sincerely,
Janelle Evink
16741 Green Street Unit D
Huntington Beach, CA 92649
714/846-8896
VP - HOA 16741 Green Street
It's only a deal if it's where you want to go. Find your travel deal here.
8/18/2008
e
�I
CITY OF HUNTINGTON BEACH
Interdepartmental Communication
TO: MAYOR AND CITY COUNCIL MEMBERS
FROM: JENNIFER MCGRATH, City Attorney
DATE: August 18, 2008
SUBJECT: LATE COMMUNICATION
Agenda Item: 23
Meeting: 8/18/08
A change has been made to Section 3 A of Resolution No. 2008-51 regarding dates.
Please substitute the attached revised resolution with the one currently in the agenda
packet.
— JENNIFER MCGRATH,
City Attorney
/K
Attachment as above
i
25538
RESOLUTION NO. 2008-51
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
HUNTINGTON BEACH ESTABLISHING A PROCEDURE FOR
PROCESSING CLAIMS AND DISTRIBUTION OF THE
CONDOMINIUM CONVERSION RESTITUTION FUND
WHEREAS, in 2004 the City became aware of a scheme being perpetrated whereby
existing apartment units in the City had been and were being illegally sold to purchasers as if
they were legally created condominium units; and
The City commenced an investigation into this scheme and found that approximately 122
of these apartment units had been sold and that a substantial percentage of the purchasers were
unaware of the illegality involved while others were aware of, or participants in the scheme and
had purchased them for investment purposes; and
In 2004 the United States Attorney's Office commenced criminal actions against the
perpetrators of the scheme and in 2006/2007, seven individuals involved in this scheme were
convicted of felonies involving Mail Fraud, Honest Services Fraud and Aiding and Abetting; and
As a part of the sentencing Federal District Judge David Carter in the United States
District Court for the Central District of California ordered each of the seven defendants to pay
restitution to the City of Huntington Beach as follows:
Name of Defendant Amount to be Paid Paid to Date
Howard Richey $220,000 $220,000
Philip Benson(deceased) $679,000 0
Thomas Bagshaw, Jr. $261,000 $925
Jeffrey Crandall $ 63,000 $50
Harvey DuBose $679,000 0
Pamela Houchen $140,000 0
Michael McDonnell $361,000 0
(Although the amounts Judge Carter required each defendant to pay vary, the total amount of the
entire Fund will not exceed $679,000)
Judge Carter stated in each Defendant's Judgment and Probation/Commitment Order that
the "Victim" for purposes of payment of restitution is the "City of Huntington Beach in a
segregated fund for the benefit of good faith purchasers of fraudulently converted
condominiums;" and
As of August 4 2008 the Condominium Conversion Restitution Fund balance is
$220,975; and NO ACTION
25048 1 TAKEN
Resolution No. 2008-51
On April 21, 2008 the City Council approved the appointment of Thomas W. Allen,
Attorney at Law, as the Hearing Officer to review, consider and rule on claims submitted; and
The City Council's objective in these proceedings is to achieve a fair and equitable
distribution of the restitution funds available in accordance with Judge Carter's pronouncement;
and
Pursuant to City Council direction given on October 15, 2007, the City Attorney's Office
mailed over 400 claim forms to individuals whose names were obtained by a title search
performed on each unit identified as having been fraudulently converted; and
The mailed claim forms describe the process for claim evaluation and invite the
addressees to file if they feel they qualify for reimbursement from the Fund.
NOW THEREFORE, the City Council of the City of Huntington Beach does hereby
resolve as follows:
SECTION 1. PURPOSE
The purpose of this Resolution is to establish the criteria by which the appointed Hearing
Officer shall consider and approve or deny Out-of-Pocket Expense claims made against the
Condominium Conversion Restitution Fund by Bona Fide (Good Faith) Purchasers of
Fraudulently Converted Units.
SECTION 2. DEFINITIONS
For purposes of this process,the following terms shall have the following meanings
A. Condominium Conversion Restitution Fund means the sum of money collected by
the Federal Court Probation Office from the individual named defendants and transmitted to the
City of Huntington Beach.
B. Fraudulently Converted Unit means a dwelling unit originally constructed as an
apartment in the City of Huntington Beach for which no condominium map or approval had been
granted by the City of Huntington Beach but which through a scheme developed individually or
collectively by the defendants in the Federal District Court case had been sold as an individual
condominium unit.
C. Good Faith (Bona Fide) Purchaser means a person or entity who purchased a
fraudulently converted condominium unit in good faith for valuable consideration and without
notice (actual or constructive) of any irregularity or impropriety in the creation
(documentation/title) of the condominium purchased. As used herein, "good faith" and "bona
fide" are synonymous. NO ACTION
1`AKEN
2
Resolution No. 2008-51
D. Out of Pocket Expense means an expenditure of money actually made by a
Claimant as a cash disbursement for an item or service which would not have been required but
for the fact the Claimant was the victim of the condominium conversion scheme. The test will
include:
i. Whether the expense was incurred as a direct result of the fraud;
ii. Whether the expense would not have been incurred but for the fraud; and
iii. Whether the expenditure was appropriate and reasonable under the
circumstances at the time incurred.
SECTION 3. PROCESS FOR REVIEW OF CLAIMS
A. Initial Review:
The City Clerk provided all claims received to the Hearing Officer. On or before
August 20, 2008 the Hearing Officer shall have completed an initial review of the claims
submitted. Between August 25, 2008 and August 31, 2008, the Hearing Officer may hold an
open meeting to which all claimants will be invited at which time the Hearing Officer can
explain the hearing process and receive input from the persons present.
Each claim presented shall initially be evaluated by the Hearing Officer to
preliminarily determine whether the Claimant was a Good Faith (Bona Fide) Purchaser of a
Fraudulently Converted Unit and whether each amount claimed appears to qualify as an Out-of-
Pocket expense.
B. Hearing Process:
i. Commencing September 2008, the Hearing Officer shall set and
notice hearing times and dates for all claimants.
ii. Each Claimant shall be notified as herein provided of the date, time and
place for the hearing. Each Claimant shall be entitled to only one change
of hearing date; any additional changes are subject to documentation based
upon emergency or illness.
iii. The hearings shall be conducted on an informal basis. After being sworn
as a witness, the Claimant will be asked to briefly explain the nature and
amount of the expenditures described in the filed claim form. The Hearing
Officer may ask questions of the Claimant for purposes of evaluation and
clarification.
In the event contentions are made by any other person that a Claimant is not a
good faith purchaser or that the expense claimed does not qualify as an out-of-pocket expense,
the Hearing Officer shall inquire of the person making the accusation to state the basis for the
contention and then shall allow the Claimant to respond. The Hearing Officer shall have the right
to continue the hearing to a date certain for the purpose of evaluating any such contentions. The
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Resolution No. 2008-51
Hearing Officer may require any person making contentions in the hearings to reduce their
contentions to writing and submit them to the Hearing Officer by a date certain. The Hearing
Officer may also require the Claimant or any other participant to provide additional
documentation or other information.
If the Hearing Officer determines that significant contentions have been made
which cannot be resolved in the informal setting then the matter may be continued by the
Hearing Officer to a date certain at which time the matter shall be heard in accordance with the
Rules for Formal Hearings set forth in Section C..
C. Rules For Formal Hearings.
i. The hearing shall be conducted in accordance with the following
procedures and any additional procedures as announced and provided to
the participants in writing by the Hearing Officer.
ii. Oral evidence shall be taken only on oath or affirmation, administered by
the reporter, if present, or by the Hearing Officer.
iii. The Parties shall have the following rights:
a. The right to call and examine witnesses (no subpoena power is
available), the number of which may be limited by the Hearing
Officer;
b. The right to introduce exhibits relevant to the issues of the case;
C. The right to cross-examination is not afforded; however, persons
present may request the Hearing Officer to make inquiry of
witnesses on specific, relevant questions.
iv. The Hearing Officer shall rule on all evidentiary issues and the following
shall apply:
a. The hearing need not be conducted according to technical rules
relating to evidence and witnesses, except as hereinafter provided.
Any relevant evidence shall be admitted if it is the sort of evidence
on which responsible persons are accustomed to rely in the conduct
of serious affairs, regardless of the existence of any common law
or statutory rule which might make improper the admission of the
evidence over objection in civil actions.
b. Hearsay evidence may be used for the purpose of supplementing or
explaining other evidence but over timely objection shall not be
sufficient in itself to support a finding unless it would be
admissible over objection in civil actions.
C. Judicial notice may be taken of any generally accepted information
or technical or scientific matter or fact that may be judicially
noticed by the courts of the state of C l�i�fornia.
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Resolution No. 2008-51
V. The Hearing Officer is authorized to establish rules and time frames for
any of the following:
a. Production of all documents, reports, videotapes, witness lists, and
any other evidence that will be relied upon in the hearing;
b. Any briefs on the issues or motions with respect to the
admissibility of any evidence;
C. Any documents that were not previously exchanged and provided
to the Hearing Officer, or witnesses and experts that were not
previously identified, may not be considered by the Hearing
Officer at the hearing, unless agreed otherwise by the Parties (term
defined ?) or upon a showing of good cause.
vi. Before the hearing, the Parties should pre-mark exhibits and should
attempt to resolve any disputes regarding the admissibility of exhibits.
vii. The Hearing Officer shall render a written ruling with respect to the
subject matter of the case, based upon a preponderance of the evidence as
the basis for the decision(s). The Claimant will proceed with presentation
of its case first and the order of the hearing shall then follow in an orderly
manner as determined by the Hearing Officer.
viii. Witnesses may be excluded upon the request of either party at the
commencement of the hearing and with the consent of the Hearing
Officer.
ix. The record of the hearing shall be maintained by the Hearing Officer or
the City and shall consist of a reporter's transcript or tape recording of all
oral evidence, arguments and rulings; copies of all exhibits offered and/or
admitted into evidence; copies of any written comments, arguments,
reports, documents, or other written materials presented to or relied upon
by the Hearing Officer; and the written decision of the Hearing Officer.
The record of the hearing shall be maintained by the Hearing Officer or
City until all appeals and court hearings have been concluded.
SECTION 4 PLAN FOR DISTRIBUTION
A. At the conclusion of the Process for Review of Claims, the Hearing Officer shall
determine the amount to which each Claimant is entitled and shall render a decision in writing.
If the Fund amount is sufficient to pay all approved claims in full then they shall be paid. If the
Fund amount is insufficient to pay all approved claims in full then all approved claims will be
paid on a pro-rata basis. The ratio for payment shall be determined by dividing the total approved
claims into the amount of the restitution fund and arriving at a percentage which shall then be
used to calculate each Claimant's share.
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Resolution No. 2008-51
B. If an unexpended amount remains in the Fund after payment of all approved
claims,the City Council shall determine the distribution.
C. At a City Council meeting at least one year after the initial distribution of the
Fund pursuant to this Resolution, and annually thereafter for a period of xx years, the City's
Director of Finance shall report the current balance of the Fund and the City Attorney's Office
shall make a recommendation to the City Council for distribution of the balance.
SECTION 5. MISCELLANEOUS
A. There will be no priority or preferential categories established based on the nature
of claims, the type of expense incurred by the Claimant or the individual needs or circumstances
of the Claimant.
B. There will be no individualized preferential treatment for any individual, class or
group.
C. The Hearing Officer will not engage in evaluation of proposed future projects or
consider approval of future projects on Fraudulently Converted Condominiums; provided
however if a Claimant is contractually obligated to a future expenditure, and the expenditure
otherwise qualifies, it may be approved.
D. The notices of initial hearing dates, meeting times, rulings and acceptance or
rejection of claims shall all be done in writing, using the U.S. Postal Service. All notices shall be
mailed at least 5 days before the event is to occur. Continuance dates and times will either be
announced in a hearing or noticed in writing.
E. The Hearing Officer shall discourage telephone or email exchanges with
Claimants or other participants.
F. The hearings shall be open to the public; provided, however, the hearings are for
the purpose of considering each individual's claim and not as a forum for discussion of public
policy or political discourse. The Hearing Officer may limit or prohibit discussion and testimony
by and between attendees.
G. The decisions of the Hearing Officer are the final and conclusive administrative
decisions and are binding on all parties, including the City. There are no appeal rights to any
administrative agency or appointed/elected body. All written decisions of the Hearing Officer
shall include an advisement pursuant to California Code of Civil Procedure Section 1094.6, that
any court action to review a decision shall be commenced not later than the ninetieth day after
the date the decision is mailed.
BE IT FURTHER RESOLVED, that the Hearing Officer is authorized to interpret or
supplement the provisions of this Resolution with procedures and determinations not inconsistent
herewith in order to achieve the stated objective of a fair and equitable distribution of the
Condominium Conversion Restitution Fund.
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Resolution No. 2008-51
PASSED AND ADOPTED by the City Council of the City of Huntington Beach at a
regular meeting thereof held on the day of 2008.
Mayor
REVIE RD AND APPROVED:
INITIATED AND APPROVED AS TO
FORM:
City Administra r <
City A orney
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