CC 07-03-18 Written Communication Special Meeting Item #1Kirsten Squarcia
From:Joseph Fruen <jrfruen@gmail.com>
Sent:Tuesday, July 03, 2018 4:57 PM
To:City Attorney's Office
Cc:City Clerk; Grace Schmidt
Subject:Re: Today's closed session on pending litigation: Friends of Better Cupertino v. City of
Cupertino
To the Acting City Attorney and those concerned:
I note that today's closed session of city council includes discussion of an action brought against the City of
Cupertino last Monday by Friends of Better Cupertino (writ petition verified by Caryl Gorska) and Cupertino
residents Kitty Moore, Ignatius Ding, and Peggy Griffin. Owing to Councilmember Steven Scharf's association
with Better Cupertino and its relationship to Friends of Better Cupertino (to the extent that a meaningful
distinction between these two exists), including Mr. Scharf's own litigation against the City of Cupertino now
pending before the Court of Appeal (Committee Supporting Cupertino Citizen's Sensible Growth Initiative, et
al. v. City of Cupertino, et al., Case No. H043940) on his own behalf and in support of Better Cupertino, I ask
that your office carefully consider the potential for waiver of the city's litigation privileges in this matter
through disclosure to a presumed member of the organization presently bringing action against the City of
Cupertino.
As the scope of any waiver of privilege is generally narrowly construed (Manela v. Superior Court, 177 Cal.
App. 4th 1139 (2009)), please carefully consider the nature and extent of any information to be disclosed in
today's session to ensure that the city's litigation privileges may be preserved in future should the Friends of
Better Cupertino action continue. In particular, I highlight the precedents laid down in Rodriguez v. Superior
Court, 14 Cal. App. 4th 1260 (1993), and People v. Hayes, 21 Cal. 4th 1211 (1999), which illustrate how the
disclosure of some information need not constitute a waiver as to all privileged information.
Many thanks for your time and attention,
--
J.R. Fruen, Esq.
Cupertino resident
408-828-2859
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CC 7/3/18 Special Meeting Item #1
From:Ignatius Y. Ding
To:Darcy Paul
Cc:City Council; City Attorney"s Office; City Clerk; Cupertino City Manager"s Office
Subject:Resident communication -- re: Item 1 of Special meeting on July 3, 2018 (Legal matter regarding litigation
"Friends of Better Cupertion," et al vs City of Cupertino.
Date:Tuesday, July 03, 2018 5:02:42 PM
** Please please this letter in the city record archive for future reference. Thank
you.
Dear Mayor Paul and members of the Cupertino City Council,
Despite of repeated clear verbial and written warnings from Cupertino
residents, based on a series of extensive research, study, thorough investigation
and close analysis in the past few months, the city staff, who are in charge of
the ministerial review and approval of the development plan for the “Vallco
Site” submitted by developer/owner Sand Hill Property under the state
legislation SB35, have chosen to overlook or ignore the colossal failure to
meet many critical criteria stipulated by the California state laws, including
SB35.
That has made it necessary for the residents and a community organization, i.e.
the “Friends of Better Cupertino,” to file a “Mandamus Petition” in the
Superior Court of the Santa Clara County to demand the city to perform its
judicial duty to properly examine the said development proposal according to
all relevant government codes, regulations and laws.
The lawsuit is now pending between “Friends of Better Cupertino” and the
City of Cupertino.
The City Council has the legal obligation and responsibility to the voters to
provide oversight and guidance in this matter that would have tremendous
impact to the future of the city and the quality of life of all current and future
Cupertino residents.
. . . Among other things, this court petition details why the
proposed “Vallco Site” development project is NOT eligible for
SB35 benefits because
i. it does not offer 2/3 residential square
footage; and
ii. the site is listed on the statewide hazardous
waste site list
Also, as noted on p. 22 of the document, the Vallco project does
not comply with the General Plan in that some of the proposed
buildings offer no first-floor commercial facilities.
Numerous other eligibility issues are discussed in detail
in Exhibits 5, 6 and 7.
Under the SB35 statute, the entire application fails if any one of
the eligibility criteria is not satisfied.
We demand the city to do its due diligence!!
In short . . .
By filing the “writ of mandamus petition” before the legal 90 day
deadline in conjunction with City’s filing of its formal response, i.e.
“the eligibility letter for the Vallco Town Center SB 35
Application,” the “Friends of Better Cupertino” has, in turn,
preserved its right to challenge the substantive aspects of the City’s
“eligibility approval” of the application.
Filing this Petition has become necessary all because either the city staff,
including the acting city manager and the planning staff, are completely
incompetent or unconscionably colluding with the developer, or both to fail
performing their legally required duty to ascertain the applicant of the Vallco
project to fully comply with the state laws, including the particular criteria
mandated by the SB35 that developer is trying to take advantage of.
A majority of the council members has repeatedly obstructed the
effort to remove the provisional 2 million square feet of office
space allocation at the Vallco site.
We are all painfully aware the ongoing and rapidly deteriorating
housing shortage crisis in Cupertino and in the Greater San Francisco
Bay Area. The deliberate attempt by the city staff and certain
members of the city council to collude with commercial developers to
push an agenda to continue building more offices, while there is no
demand or shortage nor it’s desirable or supported by the majority of
the Cupertino residents (as demonstrated in the defeat of Measure D in
2016), it would gravely worsen the imbalance of the office and
housing supply ratio as time and again warned by various experts and
nonpartisan independent organizations.
We strongly urge the city council to take immediate corrective actions
to remedy its own failure.
Thanks you for your attention.
Ignatius Y. Ding
41-year resident of Cupertino
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To: cityclerk@cupertino.org
From: ignatius.ding@gmail.com
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