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Motion to Sanction Expo Authority

Motion to Sanction Expo Authority

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Expo Communities United motion to sanction the Expo Authority for Ex Parte violation
Expo Communities United motion to sanction the Expo Authority for Ex Parte violation

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06/15/2009

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BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
In the Matter of the Application of theExposition Metro Line Construction Authorityfor an order authorizing the construction of atwo-track at-grade crossing for the ExpositionBoulevard Corridor Light Rail Transit Lineacross Jefferson Boulevard, Adams Boulevard,and 23rd Street, all three crossings locatedalong Flower Street in the City of Los Angeles,County of Los Angeles, California.And Consolidated Proceedings.
Application 06-12-005
(Filed December 6, 2006)Application 06-12-020(Filed December 19, 2006)Application 07-01-004(Filed January 2, 2007)Application 07-01-017(Filed January 8, 2007)Application 07-01-044(Filed January 24, 2007)Application 07-02-007(Filed February 7, 2007)Application 07-02-017(Filed February 16, 2007)Application 07-03-004(Filed March 5, 2007)Application 07-05-012(Filed May 8, 2007)Application 07-05-013(Filed May 8, 2007)
MOTION TO REJECT THE EXPO AUTHORITY'S FEBRUARY 13 LETTER ANDREQUEST FOR ALL EXPO AUTHORITY-DECISIONMAKER COMMUNICATIONDAMIEN WESLEY CLARK GOODMON
Executive Director, Get LA Moving3062 Stocker PlaceLos Angeles, CA 90008On Behalf ofEXPO COMMUNITIES UNITEDP.O. Box 781267Los Angeles, CA 90016
 
Pursuant to Rules 8.2(j) and 11.1 of the Rules of Practice and Procedure, ExpoCommunities United (“ECU”) hereby files this “Motion to Reject the Expo Authority'sFebruary 13 Letter and Request for All Expo Authority-DecisionmakerCommunication.”On February 13, 2008, in total disregard of the “Assigned Commissioner andAdministrative Law Judge's Ruling Revising Scoping Memo Prohibiting Further
ExParte
Communications” (“RSM“), Martin Mattes, Attorney for the Exposition MetroLine Construction Authority (“Expo Authority”) sent an email to ALJ Koss and CCed tothe Service List (“Exhibit A”). The letter, by the experienced litigator who is employedby the experienced firm of Nossaman, Guthner, Knox & Elliott, LLP, is clearly Ex ParteCommunication and thus a violation of the clearly defined RSM. Accordingly, the lettershould be rejected and Rule 8.2(j) requires the imposition of a penalty or sanction on theExpo Authority, or another order appropriate to ensure the integrity of the record and toprotect the public interest.Further, since the Expo Authority, despite their vast legal knowledge and experiencestill don't understand what is and is not Ex Parte Communication, to “ensure theintegrity of the record and to protect the public interest” ECU request all “Documents”and all “Information” between the Expo Authority (including their representatives,agents, and interested persons) and Decisionmakers (including their personal advisors)be made available to the entire service list and entered into the record, whethercurrently considered Ex Parte or not.“Documents” is defined to have the same meaning as the term “Writing” as defined inEvidence Code § 250: “handwriting, typewriting, printing, photostating,photographing, photocopying, transmitting by electronic mail or facsimile, and everyother means of recording upon any tangible thing, any form of communication orrepresentation, including letters, words, pictures, sounds, or symbols, or combinationsthereof, and any record thereby created, regardless of the manner in which the record1

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