CC 02-07-2023 Item No. 17 Consider approval of 2022 Cival Grand Jury Report Written CommunicationsCC 02-07-2023
Item No. 17
Consider approval of
response to 2022 Civil
Grand Jury of Santa
Clara Report
Written Communications
From:Peggy Griffin
To:Christopher Jensen; City Council
Cc:City Clerk
Subject:2023-02-07 CC Item17 - Response to Grand Jury Report - A House Divided
Date:Tuesday, February 7, 2023 3:15:59 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
Please include this email as part of the Written Communication for Agenda Item #17 Response to the
Civil Grand Jury Report entitled “A House Divided”.
Dear City Attorney Jensen, City Manager Wu and City Council,
Thank you for your Draft Response to the Grand Jury Report “A House Divided”. I particularly would
like to point out and thank you for pointing out that specific instances may (your words) /are (my
words) inaccurate. (See paragraphs below.)
People being accused should be given an opportunity to see the proof and be given an opportunity to
counter the attack with proof of their own yet everything is anonymous.
Bottomline, you, as a City, must respond to their Findings/Recommendations regardless of the words in
their report. Thank you.
Sincerely,
Peggy Griffin
STAFF REPORT Page 3, last paragraph
ATTACHMENT B – Draft Response to Grand Jury – House Divided
From:Peggy Griffin
To:Christopher Jensen; City Council
Cc:City Clerk
Subject:2023-02-07 CC Item17 - Response to Grand Jury Report - A House Divided QUESTIONS
Date:Tuesday, February 7, 2023 3:40:29 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
Please include this email as part of the Written Communication for Agenda Item #17.
Dear City Attorney Jensen, City Manager Wu and City Council,
I have a few questions regarding your proposed Draft Response:
PAGE 3, Finding 3 – improving City’s financial risk profile, Response, last bullet
Q1: Did the City present the 9th policy to the internal auditor Moss Adams, for review by January 31,
2023?
Paragraph after last bullet “…City is “in compliance with financial reporting requirements”
Q2: How does the public know this?
The Treasurer’s Reports are no longer going to be presented to the Council.
They are sent by Council Memo that the public has no access to without doing a Public
Records Request.
It is not clear when the report is written versus when it actually is sent to Council. It’s
supposed to be monthly.
If Audit Committee is reviewing it, they only meet every other month so it is no longer a
monthly review of this report. They’ll be reviewing 2 months at a time.
Sincerely,
Peggy Griffin
From:Kitty Moore
To:City Clerk
Subject:Written Communication for Agenda Item 17
Date:Tuesday, February 7, 2023 4:08:38 PM
Attachments:Councilmember Moore GJ.pdf
Dear City Clerk,
Please add the attached for item 17.
Kitty Moore
Kitty Moore
Councilmember
City Council
Kmoore@cupertino.org
(408) 777-1389
COUNCILMEMBER MOORE, REPRESENTING MYSELF ONLY, RESPONSE TO THE FINDINGS OF
THE 2022 SANTA CLARA COUNTY CIVIL GRAND JURY REPORT, “A HOUSE DIVIDED:
CUPERTINO CITY COUNCIL AND CITY STAFF”
The City of Cupertino’s response letter to the Grand Jury Report “A House Divided” did not
correct the findings error on page 8 of that report. The Grand Jury did not inform me of the
allegation in the report for a response, which one would expect in a proper investigation. While I
do appreciate the immense time that the citizen volunteers willingly donate to the Grand Jury,
it’s very important that they, and the City Staff providing information, get it right.
Paragraph 1 on page 8 states that I “…questioned a subordinate of the City Manager about
charges the staff member incurred on a City credit card. The staff member presented an
explanation of the charges. Councilmember Moore did not accept the explanation and requested
copies of the documentation to pursue her own investigation.” This is untrue.
What actually happened is that I had observed very high credit card charges on the Accounts
Payable which City Council accepts by Resolution. Because credit card charges have had
nothing associating the charges with what they are for, what Budget Items they relate to, just
dollar amounts which reached $95,000 in one month alone, I asked about them. These charges
would total $400,000 and more per year with no reporting to the public for what the City’s
money was spent on or a formal audit of the charges. It should be noted that I had been
concurrently serving on the Audit Committee, eventually chairing it.
I had seen the City’s Credit Card policy and had spoken to friends who have company and
government issued cards and was told what they were required to document for their card use,
and read the San Jose P Card report “Procurement Cards: Clarification on Policies and
Additional Oversight Can Improve the P-Card Program” (provided by link here:
https://www.sanjoseca.gov/home/showpublisheddocument?id=39070) for insight.
I brought the credit card concern up a number of times and finally with Interim City Manager
Greg Larson in 2021. We had a discussion about the potential issues with lacking transparency
and he asked me to request a single month to do a spot check on the receipts of, and limit the
request to two card users, which I did. Later, I met again with Interim City Manager Larson, who
gave me a folder which had an internal Memo written to him regarding the card uses and the
supporting documentation for the charges, I never spoke to either employee the supporting
documentation came from. Separately, an employee was found to have used their card for
personal items and I was informed they had been let go. City Attorney Jensen has the folder I
describe and can share what he deems is disclosable. The Interim City Manager had also asked
me to do another spot check in the future.
Given that I was handed the information in hard copy, it is very possible no other Staff members
knew I had it. I hope this corrects the record adequately.
Sincerely,
Kitty Moore, representing myself only
From:Liang Chao
To:City Clerk
Subject:I Got Interviewed by the Civil Grand Jury!
Date:Tuesday, February 7, 2023 4:12:45 PM
Please enter this into the written communication of the Feb. 7, 2923 meeting.
======
(First Draft)
I Got Interviewed by the Civil Grand Jury!
The Civil Grand Jury (CGJ) serves as a watchdog group to investigate public agencies and
elected officials based on anonymous complaints. They summarize their investigation in a
report with recommendations. The public agencies are required to respond in 90 days on
whether they accept the recommendation or not. In Cupertino’s response on the “If You
Only Read the Ballot, You’re Being Duped” was on the Dec. 20, 2022 Council Agenda, the
City Attorney disagrees with two of the 6 recommendations and thinks another one is not
applicable.
It’s important to understand how the CGJ conducts its investigations in order to assess the
credibility of claims made in their reports. Are they based on actual evidence or merely
opinions of the interviewees? Did they fairly present all the relevant information?
Did they follow the due process normally followed by the court system?
The Santa Clara County CGJ consists of 19 ordinary volunteer jurors who commit 25 hours
a week at the pay of $20/day and serve for a one-year term. For the 2022 Civil Grand
Jury can, among the 69 applicants, 75% is white, 12% is Asian, 1% for other categories.
60% are over the age of 65. 85% are over the age of 55. These jurors dedicate their free
time to investigate and create reports, which takes considerable commitments.
Anyone can file an anonymous confidential complaint form to the CGJ. The CGJ decides
which complaints to investigate. The investigations are conducted in strict privacy until the
report is published.
The CGJ decides who they interview or what documents they read and which portions are
included in the final report. They do not reveal their interviewee list, transcripts, document
list or what they leave out of a report.
The interviewees are not asked to swear to tell “the truth, the whole truth, and nothing but
the truth.” (Thus, they are not “witnesses” as in a trial court.) The interviewees are not
informed of the nature of the complaints or anything about the complaints. The interviewees
have to sign a non-disclosure form to not reveal anything about the interview until a final
report is made public or until authorized by the CGJ or the court to disclose.
(The above portion is completely factual based on public data on the CGJ. The portion
below is factual, but also includes some of my opinions on the process.)
The 2022 CGJ received multiple complaints for Cupertino City Council. Likely the
complainants were interviewed and they know exactly the subject and nature of the
complaint. Therefore, one could make a coordinated effort to submit complaints to the CGJ
so their “opinions” and “accusations” on Cupertino City Council become the content of a
CGJ report. The accuser nor the CGJ has any obligation to provide evidence to prove their
claims. The CGJ just makes a reasonable effort to investigate in privacy.
For the accused, they do not get informed of the accusations against them so they were not
given a chance to provide evidence to the contrary even though the accusations might be
completely false. This is against the Sixth Amendment “Rights to be Informed of the
Charges” if this were a trial court jury.
For the accusers, they have a good idea of the nature and the subject of the complaints so
they can share anything they choose, or frame their comments in a way, to reach their goal
of indicting elected officials through CGJ. They also have complete anonymity to anything
they say to CGJ.
Often, the accusers make their own assumptions or interpretations about an incident, which
they might believe are true, but they might reveal their unintentional false assumptions or
assumed interpretation after cross examination.
Since the investigations by the CGJ are conducted in complete secrecy without revealing
the complaint, the interviewees nor the documents they use, the accused has no way to
introduce additional interviewees or documents to provide full background of an accusation.
This is against the Fifth Amendment “Rights to Due Process” if this were a trial court.
Since there is cross examination as seen in the due process, a vague accusation from an
interviewee without specifics on dates, the context and details of an incident would merely
be an opinion or hearsay unless there is concrete evidence.
One might wonder which part of an accusation made in a CGJ and their basis is any of the
following:
hearsay: “information received from other people that one cannot adequately
substantiate”
slander: “the action or crime of making a false spoken statement damaging to a
person's reputation”
evidence: “objects, documents, official statements, etc. that are used to prove
something is true or not true,”
opinion: “a view or judgment formed about something, not necessarily based on fact
or knowledge.”
selective facts: “The selective perception of facts that support prejudices and the
blindness to facts that disprove them.”
With this understanding about the CGJ process, I would like you to read the CGJ report “A
House Divided”
(https://www.scscourt.org/court_divisions/civil/cgj/2022/A%20House%20Divided%20-
%20Cupertino%20City%20Council%20and%20City%20Staff.pdf) carefully with a truth-
seeking mindset.
=====
City Hall Renovation vs New City Hall
The CGR Report stated: “Although the 2015 City Council allocated funds for the renovation,
the monies were subsequently redirected to expand the City Library.”
The above statement is false. Here are the facts:
The 2015 Council never allocated nor approved any plan for renovation since they
favored a brand new city hall.
The 2015 Council approved the $70M Civic Center Master Plan, which includes a
new City Hall and the library expansion, but they never allocated any budget for it.
There is no “re-directing” of any fund since the 2015 Council or after did not pursue to
allocate funds after they examined the financing options for $70M.
Perhaps, some members of the public misunderstood the approval of a plan as approval of
the funding. And they likely did not follow subsequent Council meetings for financing
options.
Here are the meeting dates
July 7, 2015 - Council adopted the Civic Center Master Plan, which includes a new
city hall with added space and underground garage.
August 18, 2015 - Council did not approve the $5M item start architectural design.
Council asked the staff to come back with financing options.
November 17, 2015 - Council directed the staff to come back with a creative solution
to keep the cost lower than $40M
December 10, 2015 - The staff report concludes "Because we were not successful in
our attempts to discover a project delivery process that could develop a $70 million
estimated cost project for less than the maximum $40 million authorized by Council,
we will not be bringing the project for further consideration unless so directed by City
Council."
It appears that the CGJ was misled by some interviewees who did not understand the city
operation and did not follow the city council meeting closely.
Unfortunately, the CGJ did not write to the city to seek any document to verify the claim
either.
====
The CGJ stated “Certain staff regard the present City Council’s unwillingness to fund the
renovation as confirmation that their health and safety concerns are not a priority.”
The delay over the years (since 2015) was caused by financial concerns since the 2015
Civic Center Plan includes a brand new city hall with underground garage and the library
expansion with a price tag of $70M. Cupertino will have to borrow most of the fund, while
we are still paying off the previous loan for the existing Cupertino Library.
The 2019 Council decided to break up the projects and did the following:
Prioritize Library Expansion since the lack of programming space is an ongoing issue
since Cupertino Library is the only library in the County system without its own
programming room.
Purchased a building one block from the City Hall (named City Hall Annex), since it’s
much cheaper to purchase existing building and renovate. And this builds up real
estate assets for the City.
Rather than building a new city hall, the Council directed the staff to propose options
to renovate the City Hall, which was on the 2021-22 Capital Improvement Plan (CIP).
The Council was expecting options for renovation which we can approve by Spring 2022.
But the city staff somehow proposed a plan for a new city hall and three-story garage as
one of the projects in the 2022-23 CIP, which will cost $70 million alone.
The Council then formed a subcommittee in 2022 to study the earthquake retrofit options
for City Hall renovation. The subcommittee proposed to put the EOC (Emergency
Operations Center) in the City Hall Annex, which reduces the cost of renovating the City
Hall.
It appears that the CGJ was misled by some interviewees who did not understand the full
scope of what the Council has done over the years.
If such sentiment came from the city staff, perhaps the City Manager should have
communicated better with the staff to provide them complete background on Council
decisions.
The CGJ interviewed only a few people who have provided inaccurate information based
on their own perception. Unfortunately, the CGJ did not ask for verification of statements of
facts and did not expand their interviewee list to provide them a fuller picture.
====
Monthly Treasurer’s Report
The CGJ Report stated “Despite the legal requirement to comply with Government Code
section 41004, no City staff member was preparing and delivering a monthly treasurer’s
report. When this issue was raised during an Audit Committee meeting, the rationale
provided by City staff was that many of the surrounding cities do not comply with this
requirement…. It took a few months for City staff to comply with the law.”
This part of the report is accurate. But it neglected to mention that it was Councilmember
Kitty Moore, serving also on the Audit Committee, who pointed out the legal requirement for
the Monthly Treasurer’s Reports. And she had the support of the full Council to direct the
staff to fix the issue.
Councilmember Kitty Moore would not be able to discover irregularities such as the overuse
of credit cards, the ongoing payments without contracts, if the city staff is allowed to refuse
to provide information. When an information request might require significant workload, the
full Council should decide after hearing the rationale from their fellow Councilmember.
The CGJ Report: “Absence of the monthly treasurer’s report impaired the councilmembers’
ability to fully exercise fiscal oversight.”
It’s great that the CGJ recognizes the role of the City Council to provide oversight and the
importance of the accessibility to fiscal information in order to provide the oversight, on
behalf of the voters who elected us.
=====
Fiscal and Risk Management
The CGJ Report stated:
“The Civil Grand Jury learned of the existence of a 14-year embezzlement scheme by a
former City staff member of almost $800,000 that purportedly occurred between 2000 and
2014. Further investigation revealed that after the discovery of the embezzlement scheme
in 2014, no financial policy or procedural changes were developed and implemented by the
City.”
The above statement “no financial policy or procedural changes were developed and
implemented by the City” is not true. Likely, no changes were made before 2018. But after
2019, since I joined the Council, there have been quite a few improvements. One important
change is to separate the approval flow so the person who writes the check is not the
same person who approves a check.
Every year Moss Adams, the Internal Auditor, with the Audit Committee, would make
recommendations on what procedures or policies to improve on. I also am anxious to see
more changes of policies and procedures. However, it’s important to first assess the current
process before blindly adopting changes.
In the July 21, 2023 staff report on the Fiscal Policy Inventory and Gap Analysis Final
Report” (Item 31), the “Next Steps” section:
“Staff will develop an implementation plan to implement the report’s
recommendations. The implementation plan and status reports will be available on
the City’s website at cupertino.org/budget under Internal Audit.
In addition, if approved as part of the FY 2022-23 internal audit work plan, Moss
Adams would review the City’s formalized P&Ps and report back to the Audit
Committee and City Council on the status of the P&Ps.”
In Item 34 of the same July 21, 2023 meeting, the Council adopted “the FY 2022-23
Internal Audit Program”
Item,
The concern of CGJ seems to be led by some interviewees who do not trust the city staff in
the Finance department and the Internal Audit team. It takes time to identify gaps and
identify better policies and these are in fact operational issues that the City Council should
put in the hands of the City Manager.
=======
Staff Turnover
The CGJ Report stated “The Civil Grand Jury learned of an abnormally high turnover rate
among City staff, including key top staff positions. For example, half of the Planning
Division and 60 percent of senior management staff have left the City since January 2022.
…
Documents researched and reviewed by the Civil Grand Jury provided information that did
not fully support these conclusions.“
It’s unclear what documents the CGJ had access to derive information from. I have
requested for any data on staffing level or turn over numbers. I’m told that the city does not
have such information. Thus, likely any information available is adecdocal or isolated
instances.
In a City Council-City Manager form of government, the City Council relies on the City
Manager to implement policies and also bring forward potential concerns to address. The
Council does not and should not seek out disgruntled employees or rely on a few hearsay
to paint a picture of the entire staff.
However, if any Councilmember hears of any concern at all, we should find out more about
the concern and cause of the concern.
I would trust a City Manager, who is a professional in managing a large organization, to
bring any such concern to the Council to have a discussion and find methods to improve it if
staff retention is an issue. I trust that an experienced City Manager would bring the concern
to the Council and propose options to address the concerns, rather than telling a third party
to undermine the integrity of the organization they work for.
In my 4 years on the Council, no city employee has written to the Council to express any
concern and no city manager has brought up such concern. Thus, I have never requested
any information on staffing levels from the City Manager. This issue of staff turnover was
only brought up before the election by people with political motives. Thus, I did not find it
appropriate to request information on this issue. After the CGJ Report came out, I then
asked for information. The City Manager wrote there is not data available to share. I trust
that the City Manager will take appropriate steps to collect data and present solutions if the
concern is substantiated.
I appreciate the CGJ for raising the concern. But as a City Councilmember, I trust the City
Manager to inform the Council if she needs our support for any actions to support her staff.
====
Code of Ethics
Now finally coming to my interview with the CGJ. On December 1, 2022, I was interviewed
virtually and only two of the 19 jurors were present, but the interview was recorded.
I was told that they cannot tell me the subjects of their investigation and I cannot tell anyone
about the content of the interview until the report is published. I was not asked to provide
any document or suggest any more witnesses to support my statements.
I was asked about some “enforcement method” for the 2018 Code of Ethics (CoE) and why
it was taken out of the 2021 adopted Code of Ethics. I said I have no knowledge of anyone
expressing any concern about the “enforcement method” at all. I did not know what
“enforcement method” they were referring to.
After the interview, I looked in my documents and forwarded some evidence to them to
substantiate these facts:
1.
Cupertino did not have any adopted “Code of Ethics” prior to 2018.
2.
The 2018-19 work program did not include any item related to “Code of Ethics”.
3.
After deciding to not consolidate Library Commission and the Public Safety
Commission, the 2018 Council directed the staff on July 31, 2018 to “Explore ways to
improve Council/Commission communication”.
4.
The agenda item on November 20, 2018 was titled “Overview of City Commissions
and recommendations for improving their effectiveness and communications with the
City Council", but somehow one of the 6 documents to be approved is titled “Code of
Ethics and Conduct” (CoEC)
5.
The staff report of November 20, 2018 Council Meeting clearly indicated the 15-page
“Code of Ethics and Conduct” was newly added. There is no mention of any earlier
public engagement or notification.
6.
The Nov. 20, 2018 staff report stated “Commissions were very supportive of adopting
a code of ethics and conduct.” But there is no record of any written comments from
commissioners or commissions.
7.
The 2018 CoEC broadly applied the standard normally used for quasi-judicial
decisions (to comply with existing laws, such as project approvals) to legislative
decisions (to make laws and policies). This is evidenced by the following two quotes
from the 2018 CoEC.
Item 6 under Ethics: “decision makers … will base their decisions on the facts
presented at the hearing and the law”, which is supposed to apply only for
quasi-judicial decisions.”
Item 7 under Ethics: "Communication. ... City Officials will rely on the agenda
materials and information received at the public meeting to support their
decision."
8.
The 2018 CoEC expanded the normal “Conflict of Interest” on financial interests to
include one’s opinions or positions on policy issues. This is evidenced by this quote:
Item 8 under Ethics: "Conflict of Interest. ... Consistent with the law, decision-
makers will not use their official positions to influence government decisions in
which they have (a) a material financial interest, (b) an organizational
responsibility to or personal commitment to others that creates a conflict of
interest or the appearance of one, or (c) a strong personal bias as to one party
or position."
(This portion below includes my opinion on the quoted items above)
According to Ethics Item 6 and Item 7, City Officials appear to have to ignore public
comments received through emails or at any meeting with community members. City
Officials cannot use their past experiences based on reading articles or information derived
from their own research on the issues.
Ethics Item 8 goes beyond the state law on Conflict of Interest, which is limited to financial
interest. According to such broad interpertation of Conflict of Interest, all members of the
Bike and Pedestrian Commission would have to recuse themselves since they have a
"strong person bias" towards some bike paths and actively advocate for it. Most
Sustainability Commissioners have "personal commitment" to Clean Energy. Most Housing
Commissioners have a "personal commitment" towards affordable housing. Most Parks and
Recreation Commissioners have a "strong personal bias" towards all-inclusive playground
to accommodate children of special needs.
Should these commissioners all recuse themselves on the issues they strongly care about
in order to comply with the 2018 CoEC? As the Nov. 20, 2018 staff report stated: “any
violation of the code of ethics and conduct are grounds for removal as a commissioner.”
Is the 2018 CoEC quoted above what you think the City of Cupertino must adopt and
enforce?
Is the process of adopting the 2018 CoEC the kind of “transparent” process you support?
Now coming back to the CGJ report.
The CGJ Reported stated:
“In a City Council vote on January 15, 2019, the City Council rescinded its Code of Ethics
and Conduct that had just been voted on and passed the prior November. A year later, in
January 2020, the City Council adopted a new Ethics Policy. … the year-long gap during
which the City had no ethics policy is a concern.”
The CGJ seems to be completely ignorant of the fact that there was no Code of Ethics
before Nov. 20, 2018. Perhaps, the interviewees misled them and they did not see the need
to verify the information they received.
I have sent multiple emails to explain the improper process the 2018 Code of Ethics was
adopted with links to evidence (as outlined earlier). The CGJ seems to have completely
ignored the list of evidence.
I would think that the CGJ would agree that it’s inappropriate for a City Council to adopt a
brand new Code of Ethics policy under an agenda titled “Overview of City Commissions
and recommendations for improving their effectiveness and communications with the City
Council” without a study session to take public input first.
Perhaps, they were misled by the interviewees and did not have time to find evidence to
verify their claims.
The policy making process requires the public to engage in the normal “process” through
oral or written comments at a Council Meeting or meetings with Councilmembers. Policies
are never set in stone. When there are public concerns, we often bring back a policy to
consider possible revisions to address the concerns.
However, if certain individuals or groups never expressed any concern during the “normal
policymaking process” and only expressed certain never-before-mentioned “concerns”
through either lawsuit, complaints to CGJ or campaign materials, it undermines our
Democratic process. I encourage everyone to get engaged in the “normal policymaking
process”, rather than making policies through lawsuits or political attacks.
I encourage the CGJ to ask the interviewees to show evidence that they have made good
faith efforts to express their concerns with the City Council and the City Staff before taking
on a complaint, especially during an election year.
I encourage the CGJ to find sufficient numbers of interviewees who both support and
oppose a complaint in order to get the full picture of pretty complex situation.
One would not wish to see that the respected volunteer jurors of the CGJ were taken
advantage of by certain well connected individuals for their political gains.
Liang Chao
Cupertino City Council
representing only myself
Liang Chao
Council Member
City Council
LiangChao@cupertino.org
408-777-3192