24 (01)
Susana Barrios
From:Concerned Anaheim Residents <concernedanaheimresidents@gmail.com>
Sent:Monday, May 11, 2026 12:44 PM
To:Theresa Bass; Public Comment; Ashleigh Aitken; Carlos A. Leon; Ryan Balius; Natalie
Rubalcava; Norma C. Kurtz; Natalie Meeks
Cc:Robert Fabela; Gregory Garcia; _City Council
Subject:\[EXTERNAL\] FORMAL OBJECTION: Agenda Item #24 (May 12, 2026) – Documentation
of Systemic Bad Faith & Record Suppression
Attachments:K1 - Timeline of Coordinated Influence & Predetermined Outcomes.pdf; EXHIBIT N-2
- Documentation of Unregistered Lobbying and Material Omission .pdf; Exhibit L -
Notice of Administrative Default & Record Suppression.pdf
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To the Honorable Mayor and City Council:
The Stakeholder Audit Team hereby submits this formal objection to Resolution 1.14 and 1.15. on
Agenda Item #24 for the upcoming City Council Meeting on 5-12-26. While these are presented as
"modernizations," they are, in fact, Selective Enforcement Tools being codified only after heavy public
scrutiny from the Arzola Family and East Anaheim Residents. To adopt these restrictive measures
while documented forensic violations remain unaddressed is an act of Administrative Bad Faith and
a premeditated denial of meaningful public participation.
I. Constructive Admission & The "Huddle" Safe Harbor
Resolution 1.14 (Glitch Recess) serves as a defensive reaction to the evidence in Exhibit N-2, which
captured the staggered exits of 6 out of the 7 Council Members/Mayor and the City Attorney during
the 3/24/26 hearing before deciding to Reject the Appeal for the Festival Proposal AND voted to
approve the 2nd vote for that development. While Council Member Norma Campos Kurtz remained at
the dais, her documented use of a cellular device suggests continued coordination either of. By voting
to approve these today, the City is attempting to codify a "Safe Harbor" for these unrecorded huddles
while continuing to suppress the requested live meeting text logs and key video footage from inside
and outside of the dais during that time window. Stakeholders also witnessed registered and
unregistered lobbyists (Younus Zeshaan, Joel Saldivar, & Jack Truman) engaged in perceived active
texting chains between multiple Council Members leading up to the vote. By voting "YES" today, the
City is attempting to codify a "Safe Harbor" for this unrecorded coordination.
II. Systematic Suppression, Pattern of "Record Scrubbing," & Multiple Ethics Violations
The City cannot "clean up" its rules while the following Multiple Ethics and Transparency Violations
remain unaddressed:
Stakeholders formally object to the City’s ongoing Administrative Default (Exhibit L). We have
documented a pattern of "Record Scrubbing" intended to sanitize the administrative record, including:
1
The 3/21 Portal Deletion: The removal of 870 page appeal for the Festival Development
Proposal & the 7 page Staff Report recommending denial of the appeal, that was posted to the
3-24-26 Meeting Agenda that was visible on 3/21/26, but later scrubbed from the City's page
during a critical review window.
Calendar Scrubbing: Documented forensic gaps in the public calendars of Council Member
Natalie Meeks and Ted White regarding project coordination with Curt Pringle. Additional
discrepancies amongst City Council Members calendars and those of their fellow Council
Members. Additionally, Lobbyists have shown clumping date patterns in their quarterly reports
in a perceived attempt to hide the exact dates and frequency they reached out to Council
Members and key City Staff during critical decisions making windows regarding the Festival
Development.
Social Media Viewpoint Discrimination: The deletion of resident comments on official City
pages, which only "reappeared" after Stakeholders provided a comment explaining they had
screenshotted proof of the censorship.
The "1-Minute" Muzzle: While 1-minute limits existed in writing, they were never enforced until
residents began presenting complex evidence of misdemeanor lobbying perjury, wildfire
safety concerns, and lack of infrastructure in a High Fire Severity Area. Using this
"discretionary power" now is a direct strike against meaningful participation on upcoming
projects like Deer Canyon and Saddle Ranch.
III. Unified Tactic Against Resident Oversight & Life-Safety Testimony
Agenda Item #24 is a coordinated attempt to 'time out' the most critical and informed voices in our
community. By implementing a restrictive 90-minute cap and enforcing a 1-minute discretionary limit,
the City is ensuring that evidence-heavy testimony on matters of life and death is effectively
suppressed.
Suppression of Justice Efforts: These rules directly target the Arzola family, who for months
have been forced to repeatedly attend meetings to seek justice for Albert, demanding the
release of unedited bodycam footage and the names of involved officers. While they have only
recently received the name of the officer involved, the officer is still working, bodycam footage
remains unprovided, and this change would severely impact their ability to continue fighting for
justice for Albert. The family also reports repeated instances of harassment from police
officers at their home.
Suppression of Public Safety Concerns: Similarly, these rules target East Anaheim residents
fighting for safety in a Very High Fire Hazard Severity Zone. Residents are raising alarms
about high-risk, large-scale projects, such as the Hills Festival Project (DEV2023-00043), the
resurgent Deer Canyon/Hills Preserve, and upcoming projects like Saddle Ranch, that fail to
address critical infrastructure deficits, bottlenecks, and evacuation gridlock.
Withholding of Evidence: The City continues to operate in Administrative Default by
withholding the broader Anaheim Hills Cumulative Wildfire Evacuation Study, which by the
City's own prior findings was deemed necessary to properly evaluate cumulative development
impacts. Approving high-density projects while suppressing the very data needed to prove their
safety is a failure of informed decision-making.
By adopting these new procedural hurdles today, the City is choosing to prioritize 'meeting efficiency'
over its legal and moral obligation to allow meaningful participation from residents whose lives are at
stake."
2
IV. Financial Conflicts (Levine Act § 84308)
Documentation proves aggregated contributions exceeding statutory limits from Applicant agents to
the "YES" voting block within 12 months. This disqualifies the majority from voting on any project-
related items, including these procedural "fixes."
V. Notice of Formal Referrals
Referrals regarding these criminal and ethical violations are currently in process with the OCDA
Public Integrity Unit, the California FPPC, and the Orange County Civil Grand Jury. Stakeholders
reserve all rights, including the filing of a Writ of Mandate to stay all project activity should the City
fail to Cure and Correct the documented procedural and Brown Act violations associated with Project
DEV2023-00043.
VI. NOTICE OF PROTECTED WHISTLEBLOWER STATUS
Per GC § 8547.10, the identity of this Audit Team is strictly confidential. Any attempt to use City
resources to identify or retaliate against these volunteers will be reported as a criminal violation of
whistleblower protections.
Respectfully,
Stakeholder Audit Team
3
1
K1: Timeline of
Coordinated Influence &
Predetermined Outcomes
2
Exhibit K-1: Documentation of Coordinated Influence & Predetermined Outcomes
I. Introductory Summary
The evidence compiled in this installment establishes a systemic pattern of institutional
coordination between the City of Anaheim leadership and the private lobbying firm
Curt Pringle & Associates (CP&A). This coordination bypassed legally mandated
public transparency standards and created a predetermined administrative outcome
for Project DEV2023-00043.
The forensic record, detailed in the tables and supplemental communications below,
proves:
1. Voting Block Alignment: A 100% correlation between the City Council's "YES"
majority and their respective Planning Commission appointees.
2. The Money-to-Meeting Pipeline: A direct temporal link between large campaign
contributions from CP&A principals and project-altering huddles with Council
leadership.
3. Institutional Inconsistency: A direct contradiction between the Council
members' public pledges of "ethical and transparent governance" and their
documented participation in "Shadow Team" activities.
This exhibit establishes that the project’s approval was not the result of an independent,
evidence-based review, but rather a multi-year managed operation intended to favor
private development interests over the legally protected right of resident stakeholders to
meaningful public participation.
3
Exhibit K-: Table Showing Coordinated Voted Block Between Planning Commissioners & Planning Commission "Shadow" Voting
Block
Based on official records, the voting breakdown for the 4-3 City Council approval and the 6-1 Planning Commission recommendation
is as follows:
Planning Commissioner (Voted YES) Appointing Council Member District Council Vote on Project Coordinated Alignment?
Jeanne Tran-Martin Carlos Leon District 2 YES Yes
AB Abdulrahman Ryan Balius District 1 YES Yes
Michelle Lieberman Natalie Rubalcava District 3 YES Yes
LuisAndres Perez Norma Campos Kurtz District 4 YES Yes
Amelia Castro Natalie Meeks District 6 NO No (Split), Castro voted Yes
Christopher P. Walker Kristen Maahs District 5 NO No (Split), Walker voted Yes
• Dissenting Pair: Deirdre Kelly (At-Large) and Mayor Ashleigh Aitken both voted NO, maintaining 100% alignment in their opposition to
the project.
4
Analysis of Coordinated Institutional Bias
The data in the table above (page 2) demonstrates a 100% lockstep alignment between the Planning Commission majority and the City
Council "YES" block. This pattern represents a predetermined administrative outcome and proves that the "independent" review process
was a managed operation designed to favor the developer over the public interest. This alignment is a direct result of the Direct
Appointment System codified in the Anaheim City Charter.
• Administrative Proxies: Under Anaheim Municipal Code § 1.04.391, Planning Commissioners are nominated by a specific Council
Member or the Mayor and serve at the "pleasure" of their appointing official. They effectively function as administrative proxies whose
primary role is to align recommendations with the policy platform of the official they represent, rather than acting as a non-partisan
"checks and balances" body.
• Pre-Clearance Mechanism: The total uniformity observed among appointees, specifically AB Abdulrahman, Jeanne Tran-Martin,
Michelle Lieberman, and LuisAndres Perez, suggests that the Commission’s near-unanimous recommendation acted as a pre-
clearance mechanism for the Council majority’s agenda.
• Tiered Accountability Gaps: This predetermined nature is further reinforced by the fact that some Council Members, such as Norma
Campos Kurtz, were themselves appointed to their seats rather than elected. This creates a tiered system of appointments where
land-use decisions, like the Anaheim Hills Festival Project (DEV2023-00043), are steered by individuals twice removed from direct
voter accountability.
• Failure of Independent Safety Findings: While the "Proxy" system successfully streamlined the project through the Commission, it
ultimately prioritized the developer’s objectives over the independent safety findings required for projects located in Very High Fire
Hazard Severity Zones.
Conclusion: The total uniformity across all six districts confirms that the "Administrative Review" was a seamless continuation of private
lobbying goals rather than an independent evaluation of resident concerns.
5
Exhibit K-1: The "Shadow" Calendar & Continuance Tracker
This table documents the synchronization between private lobbying and public "pauses" that allowed the project to be finalized behind the
scenes.
Date Lobbyist Action (CP&A) Key Project Milestone / City Action Targeted City Officials
7/12/23 Cawelti & Zeshaan dual-track huddles. Entitlements Extension: Project "saved" from
expiration.
N. Campos-Kurtz & Ted
White
11/17/25 Zeshaan reports huddles on project status. Planning Commission: Votes 6-1 for approval. Heather Allen
12/16/25 Full House Blitz: Zeshaan meets 7 Council
members. Continuance #1: Meeting postponed to 1/13/26. Entire City Council
1/13/26 "The Union Pincer": Lobbyists coordinate Union
huddles. Continuance #2: Meeting postponed to 2/3/26. N. Rubalcava
2/3/26 "The Extension Request": Coordination with City
Attorney. Continuance #3: Final postponement to 3/3/26. Heather Allen
3/3/26 The Final Vote: Project approved 4-3. Final Project Approval. YES Voting Block
3/24/26 The Perjury Window: Zeshaan at dais (Exhibit N). Final Ordinance Vote. Heather Allen & Staff
6
II. The "Done Deal" Continuance Tracker
These three delays provided the "Shadow Team" the window needed to manage proponents and suppress the record.
Continuance Date Motion / Initiative By Seconded By Purpose Given
12/16/2025 (Administrative) Consent Calendar "Staff review of project revisions."
01/13/2026 Natalie Rubalcava Carlos Leon "To allow for further community benefit negotiation."
02/03/2026
Project Applicant
Natalie Rubalcava
Norma Campos Kurtz
Supported by City Atty
"Additional time for technical analysis."
Forensic Analysis: Coordinated Timing & Administrative Bad Faith
• The "Union Mirage" Delay (Jan 13): The January 13th continuance, moved by Rubalcava and seconded by Leon, provided the critical
window for the Western States Carpenters Union coordination. This proves the "Union Contingency" was a managed political
maneuver rather than a spontaneous negotiation.
• The "Applicant-Led" Delay (Feb 3): The final continuance was requested directly by the project applicant, Shea Properties. This
specific motion was moved by Natalie Rubalcava and seconded by Norma Campos Kurtz. This demonstrates that the Council
majority was actively facilitating the developer's strategic schedule to finalize terms behind closed doors before the final public vote.
• The "Shadow" Administrative Track: Lobbyist Younus Zeshaan reported huddles with Heather Allen (Planning Director) and Ted
White (Deputy City Manager) on the exact dates that these continuances were being processed, proving a continuous line of private
communication throughout the "public" delay period.
• The Material Omission (Criminal Perjury): In his Q1 2026 report, Zeshaan certified under penalty of perjury that his project activity
ended on 3/12/26. However, Exhibit N-2 proves his attendance and lobbying activity on 3/24/26. This constitutes a verified material
omission.
7
III. Timeline of Coordinated Huddles: The "Union Mirage"
• Jan 13, 2026 – The "Contingency" Statement: During the initial public hearing, Council Member Natalie Rubalcava states on the
record that her support for the project is "contingent on a deal with the Union." This provides the political cover to justify three
subsequent postponements.
• Jan 20, 2026 – The "Intermediary" Pincer:
o 11:00 AM: Norma Campos Kurtz holds a 30-minute call with Jimmy Elrod (Carpenters Union).
o 2:00 PM: Norma Campos Kurtz holds a 30-minute call with Lobbyist Younus Zeshaan.
o Forensic Note: This 3-hour window proves the Council was acting as the direct intermediary between the Union and the
Lobbying Firm.
• Jan 26, 2026 – The "Mega-Huddle":
o Stage 1 (30 mins): Rubalcava, Kurtz, and Meeks privately had a call with 2 members from the Project Developer Team
(Shea).
o Stage 2 (60 mins): The Western States Carpenters Union is immediately joined to the same call to finalize the "Shadow"
agreement terms.
• Feb 26, 2026 – The "Signing Day" Huddle:
o 9:30 AM: Norma Campos Kurtz holds a call with Jimmy Elrod (Union).
o Milestone: The Union contract is reportedly signed this same day.
o Audit Note: Discrepancies in afternoon logs for this date suggest a potential scrubbing of further lobbyist coordination
following the signing.
• Mar 3, 2026 – The Vote: The Union is absent from the final hearing on 3-24-26, and the initial vote on 3-3-26. Despite the absence of a
finalized public agreement, the Council majority (Rubalcava, Kurtz, Meeks, and Leon) votes YES, proving the "Union Contingency"
was a scripted narrative.
8
Carpenter ’s Presence at 1/13/26 Meeting as Documented by the “Voice of OC” – Electronic Newspaper Article
Source: https://voiceofoc.org/2026/03/anaheim-hills-festival-housing-project/
9
Exhibit K-1 (Continued): Documented Failure to Meet Stated Transparency Standards.
In this August 24, 2023, public pledge, Council Members Rubalcava, Kurtz, and Meeks explicitly committed to 'ethical and transparent
governance' and supporting a process that provides 'public access to our meeting calendars.'
The forensic record contradicts this pledge. The City is currently in Administrative Default (Exhibit B-1) regarding the production of digital
communication logs for the 3/24/26 hearing. Furthermore, the systematic omission of Lobbyist Curt Pringle from official meeting calendars
and the documented huddles with unregistered CP&A agents proves that the 'access' promised in this statement is willfully being
suppressed to protect private development interests.
10
Concerned AnaheimResidents <concernedanaheimresidents@gmail.com>
URGENT: NOTICE OF DEFAULT & INTENT TO ESCALATE - PRA #03162026-8 &
#04102026-4
1 message
Concerned Anaheim Residents <concernedanaheimresidents@gmail.com>Tue, May 5, 2026 at 12:39
PM
To: rfabela@anaheim.net, ggarcia@anaheim.net, tbass@anaheim.net
Cc: etrejo@anaheim.net, aengeln@anaheim.net, bmorley@anaheim.net, Public Records Requests
<recordsrequest@anaheim.net>
ATTENTION: OFFICE OF THE CITY ATTORNEY; OFFICE OF THE CITY MANAGER
Mr. Fabela and Mr. Garcia,
As of 12:30 PM today, May 5, 2026, the City has failed to comply with the Stakeholders’ final
demand for the production of "identified" records regarding Project DEV2023-00043.
By remaining silent after admitting in writing that responsive records exist, and by failing to
acknowledge the Formal Notice of Duty to Preserve Evidence issued on May 4, the City is in
documented Continued Administrative Bad Faith.
Formal Notice of Escalation:
As the City has willfully exhausted the administrative timeline and failed to produce the
administrative record, Stakeholders are currently transmitting a formal Investigative Referral to
the California Fair Political Practices Commission (FPPC).
This filing includes comprehensive forensic evidence of:
Criminal Perjury & Filing Fraud (GC § 81004): Documented in Exhibit N and Exhibit P-1.
Unregistered Lobbying Activity: Specifically regarding agents Saldivar and Truman.
Non-Disclosure of Activity Expenses: Documented $0.00 repor ting despite paid
coordination.
Administrative Record Suppression: The intentional deletion of the 3/21/26 records.
The City is further notified that Stakeholders are finalizing mirror referrals for the OCDA Public
Integrity Unit and the Orange County Civil Grand Jury regarding the potential criminal perjury and
systematic record suppression. These will be submitted as the next phase of our formal escalation
following the City's default on today's production deadline.
Any subsequent production that is missing metadata or contains over-redaction without a
corresponding Privilege Log will be cited as willful spoliation of evidence in upcoming judicial
proceedings.
Sincerely,
Stakeholders of Save Anaheim Hills / Concerned Residents
(Community Volunteer Team - Administrative Audit Division)
5/7/26, 5:05 PM Gmail - URGENT: NOTICE OF DEFAULT & INTENT TO ESCALATE - PRA #03162026-8 & #04102026-4
https://mail.google.com/mail/u/2/?ik=bb7ab00bd6&view=pt&search=all&permthid=thread-a:r2576061196758237564&simpl=msg-a:r587111418252533…1/3
On Mon, May 4, 2026 at 8:35 PM Concerned Anaheim Residents <concernedanaheimresidents@gmail.com> wrote:
CC: Office of the City Manager; Office of the City Attorney; Office of the City Clerk
Ms. Engeln and Ms. Morley,
Stakeholders acknowledge your 5:10 PM correspondence. The City is now in documented
Continued Administrative Bad Faith regarding the systemic and intentional withholding of
"identified" records for Project DEV2023-00043.
1. Confirmation of Production & Demand for Consolidated Delivery:
Stakeholders formally confirm our intent to proceed with the immediate production of all
identified records. On April 10, 2026, the City stated records for #03162026-8 were "currently
being prepared for production." It has been 24 days since that admission. Stakeholders demand
the immediate electronic delivery of all "identified" records for BOTH requests no later than
12:00 PM tomorrow, Tuesday, May 5, 2026.
2. Systemic Statutory Violations & Deficient Extensions:
Stakeholders have documented a pattern of illegal stalling via procedurally deficient 14-day
extensions that failed to set forth "unusual circumstances" as mandated by Gov. Code §
7922.535(b):
PRA #03162026-8: Deficient extension issued 3/26/26; initial request submitted 3/16/26.
PRA #04102026-4: Deficient extension issued 4/20/26; initial request submitted 4/10/26.
The City was formally notified of these deficiencies for both PRA #03162026-8 and PRA
#04102026-4 and the resulting Constructive Denial on April 21, 2026, yet intentionally
failed to provide compliant determinations. As the City now admits records are "identified,"
there is no further legal basis for delay. We reject the "20-day arrangement" window;
production must be prompt.
3. Anti-Redaction & Privilege Log Mandate:
For every redaction made, the City must provide a specific Privilege Log identifying the author,
recipient, date, and the specific legal justification for the withholding. All records must be
produced in their native electronic format (including full metadata/timestamps).
Failure to produce these records by 12:00 PM tomorrow will be cited as a willful suppression of
evidence in our pending referrals to the OCDA Public Integrity Unit, particularly in light of the
5:00 PM City Council meeting on May 5, 2026.
Sincerely,
Stakeholders of Save Anaheim Hills / Concerned Residents
(Community Volunteer Team - Administrative Audit Division)
---------- Forwarded message ---------
From: Amy Engeln <AEngeln@anaheim.net>
Date: Mon, May 4, 2026 at 5:10 PM
Subject: Public Record Act Request No. 04102026-4
To: concernedanaheimresidents@gmail.com <concernedanaheimresidents@gmail.com>
Please find attached correspondence regarding your Public Records Request No. 04102026-4.
5/7/26, 5:05 PM Gmail - URGENT: NOTICE OF DEFAULT & INTENT TO ESCALATE - PRA #03162026-8 & #04102026-4
https://mail.google.com/mail/u/2/?ik=bb7ab00bd6&view=pt&search=all&permthid=thread-a:r2576061196758237564&simpl=msg-a:r587111418252533…2/3
Have a great rest of the day.
Amy Engeln
Paralegal
Office of the City Attorney
City of Anaheim
p: 714.765.5169 x 5538
e: aengeln@anaheim.net
200 S. Anaheim Blvd., Suite 356
Anaheim, CA 92805
www.anaheim.net
This communication is intended only for the person to whom it is addressed, and may be confidential or privileged by law. If you are not the
intended recipient or you receive this email in error, any review, use, dissemination, distribution, or copying is strictly prohibited. Please notify the
Anaheim City Attorney’s Office of the error immediately at 714-765-5169 and delete this communication and any attached documents from your
system. Thank you for your cooperation.
5/7/26, 5:05 PM Gmail - URGENT: NOTICE OF DEFAULT & INTENT TO ESCALATE - PRA #03162026-8 & #04102026-4
https://mail.google.com/mail/u/2/?ik=bb7ab00bd6&view=pt&search=all&permthid=thread-a:r2576061196758237564&simpl=msg-a:r587111418252533…3/3
1
EXHIBIT N-2:
Documentation of
Unregistered Lobbying
and Material Omission
2
Exhibit N-2: Documentation of Unregistered Lobbying Agent.
Digital evidence (LinkedIn) confirms Respondent Saldivar was a paid agent of Curt Pringle & Associates during the Q1 2026 period.
Photographic evidence (2/19/26) proves Respondent performed active outreach/lobbying services at a City-sponsored event. Per AMC §
1.11.070.010, Respondent failed to register within the mandatory 15-day window. The Firm’s subsequent certification of '$0.00 Activity' for
this period constitutes a material omission and a violation of disclosure statutes.
3
"Verification of Non-Registration Status: This official City of Anaheim Lobbyist Registry audit confirms that Respondents Joel Saldivar and
Jack Truman are not registered as lobbying agents. This is contrasted against the successful registration of other Firm associates
(highlighted in blue boxes), proving that the Firm possesses the institutional knowledge to comply with AMC § 1.11.070.010, but willfully
chose to withhold the registration of these specific field agents.
The red boxes indicate where Respondents’ names are legally required to appear. Per AMC § 1.11.070.010, Respondents were required to
register within 15 days of initial activity. Official Registry records (timestamped May 7, 2026) confirm that both remain unregistered despite
documented activity starting as early as February 19, 2026 (Saldivar) and City Council Meeting March, 3 2026 (Truman). These agents are in a
state of continuous violation, and the Firm’s subsequent certification of '$0.00 Activity' constitutes a material omission and a violation of
disclosure statutes.
4
Joel Saldivar & Jack Truman Employment:
Joel Jan 2026
Jack Feb 2026 (picture to be provided in future installment)
5
The Perjury Table for Exhibit N-2
Title: Forensic Conflict: Documentation of Material Omission Under Penalty of Perjury
Data Source Reported/Documented Date Reported Activity Status
Official Q1 2026 Lobbyist Report March 12, 2026 Final Date of Project Activity
Physical Evidence (Exhibit N) March 24, 2026 Active Outreach & Coordination
Pictured: Zeshaan Younus, Pictured with Shea Development Team, and unregistered Lobbyists Joel Saldivar and Jack Truman at 3-24-26
meeting.
6
Screenshot: Pictured is Younus Zeshaan’s Q1 lobbying report (Jan-Mar 2026) claiming under perjury that he ended lobbying for Shea
Properties on 3-12-26, despite picture above showing him in attendance of 3-24-26 City Council Meeting (Final Vote) and seated with the
developer and other lobbyists from his firm.
Description:
Per GC § 81004, all lobbying reports must be signed under penalty of perjury. Respondent Zeshaan certified that his project activity
concluded on 3/12/26. However, Exhibit N provides undeniable photographic documentation of the Respondent huddling at the dais and
performing active outreach/coordination on 3/24/26. This 12-day discrepancy constitutes a verified material omission and a violation of
state disclosure statutes.
Susana Barrios
From:Concerned Anaheim Residents <concernedanaheimresidents@gmail.com>
Sent:Monday, May 11, 2026 3:40 PM
To:Theresa Bass; Public Comment; Ashleigh Aitken; Carlos A. Leon; Ryan Balius; Natalie
Rubalcava; Norma C. Kurtz; Natalie Meeks
Subject:\[EXTERNAL\] SUPPLEMENTAL EVIDENCE: Item #24 – ADA Barriers & Discriminatory
Impact on Life-Safety Testimony
You don't often get email from concernedanaheimresidents@gmail.com. Learn why this is important
Warning: This email originated from outside the City of Anaheim. Do not click links or open
attachments unless you recognize the sender and are expecting the message.
To the Mayor, Council, and Members of the Media:
This is a supplemental filing to the Master Objection submitted earlier today at 12:44pm. Upon review
of the full Item #24 Agenda Report, the Stakeholder Audit Team identifies the following critical
failures:
ADA & Physical Barriers: While the City proposes 'remote' ADA fixes, it continues to ignore the
non-compliant physical podium in the Chambers, which prevents wheelchair-bound members
of the Arzola family from addressing the Council in person.
The 'Midnight' Squeeze: Public hearings for high-risk projects (e.g., Festival, Deer Canyon, &
Upcoming Saddle Ranch) routinely have extend from 10:00 PM until midnight. Codifying a 90-
minute cap on the first comment period is a mathematical guarantee that critical life-safety
testimony will be buried in the middle of the night.
Bad Faith Outreach: Section 3 of the 'Reasonable Efforts' Resolution is a 'Get Out of Jail Free'
card that attempts to strip the Hispanic community of legal standing when the City fails to
provide adequate noticing.
The City cannot 'modernize' participation while the chambers remain physically and linguistically
inaccessible to the very families seeking justice and safety.
Respectfully,
Stakeholder Audit Team
On Mon, May 11, 2026 at 12:44 PM Concerned Anaheim Residents
<concernedanaheimresidents@gmail.com> wrote:
To the Honorable Mayor and City Council:
The Stakeholder Audit Team hereby submits this formal objection to Resolution 1.14 and 1.15. on
Agenda Item #24 for the upcoming City Council Meeting on 5-12-26. While these are presented as
"modernizations," they are, in fact, Selective Enforcement Tools being codified only after heavy
public scrutiny from the Arzola Family and East Anaheim Residents. To adopt these restrictive
measures while documented forensic violations remain unaddressed is an act of Administrative Bad
Faith and a premeditated denial of meaningful public participation.
1
I. Constructive Admission & The "Huddle" Safe Harbor
Resolution 1.14 (Glitch Recess) serves as a defensive reaction to the evidence in Exhibit N-2, which
captured the staggered exits of 6 out of the 7 Council Members/Mayor and the City Attorney during
the 3/24/26 hearing before deciding to Reject the Appeal for the Festival Proposal AND voted to
approve the 2nd vote for that development. While Council Member Norma Campos Kurtz remained
at the dais, her documented use of a cellular device suggests continued coordination either of. By
voting to approve these today, the City is attempting to codify a "Safe Harbor" for these unrecorded
huddles while continuing to suppress the requested live meeting text logs and key video footage
from inside and outside of the dais during that time window. Stakeholders also witnessed registered
and unregistered lobbyists (Younus Zeshaan, Joel Saldivar, & Jack Truman) engaged in perceived
active texting chains between multiple Council Members leading up to the vote. By voting "YES"
today, the City is attempting to codify a "Safe Harbor" for this unrecorded coordination.
II. Systematic Suppression, Pattern of "Record Scrubbing," & Multiple Ethics Violations
The City cannot "clean up" its rules while the following Multiple Ethics and Transparency Violations
remain unaddressed:
Stakeholders formally object to the City’s ongoing Administrative Default (Exhibit L). We have
documented a pattern of "Record Scrubbing" intended to sanitize the administrative record,
including:
The 3/21 Portal Deletion: The removal of 870 page appeal for the Festival Development
Proposal & the 7 page Staff Report recommending denial of the appeal, that was posted to
the 3-24-26 Meeting Agenda that was visible on 3/21/26, but later scrubbed from the City's
page during a critical review window.
Calendar Scrubbing: Documented forensic gaps in the public calendars of Council Member
Natalie Meeks and Ted White regarding project coordination with Curt Pringle. Additional
discrepancies amongst City Council Members calendars and those of their fellow Council
Members. Additionally, Lobbyists have shown clumping date patterns in their quarterly
reports in a perceived attempt to hide the exact dates and frequency they reached out to
Council Members and key City Staff during critical decisions making windows regarding the
Festival Development.
Social Media Viewpoint Discrimination: The deletion of resident comments on official City
pages, which only "reappeared" after Stakeholders provided a comment explaining they had
screenshotted proof of the censorship.
The "1-Minute" Muzzle: While 1-minute limits existed in writing, they were never enforced until
residents began presenting complex evidence of misdemeanor lobbying perjury, wildfire
safety concerns, and lack of infrastructure in a High Fire Severity Area. Using this
"discretionary power" now is a direct strike against meaningful participation on upcoming
projects like Deer Canyon and Saddle Ranch.
III. Unified Tactic Against Resident Oversight & Life-Safety Testimony
Agenda Item #24 is a coordinated attempt to 'time out' the most critical and informed voices in our
community. By implementing a restrictive 90-minute cap and enforcing a 1-minute discretionary
limit, the City is ensuring that evidence-heavy testimony on matters of life and death is effectively
suppressed.
2
Suppression of Justice Efforts: These rules directly target the Arzola family, who for months
have been forced to repeatedly attend meetings to seek justice for Albert, demanding the
release of unedited bodycam footage and the names of involved officers. While they have
only recently received the name of the officer involved, the officer is still working, bodycam
footage remains unprovided, and this change would severely impact their ability to continue
fighting for justice for Albert. The family also reports repeated instances of harassment from
police officers at their home.
Suppression of Public Safety Concerns: Similarly, these rules target East Anaheim residents
fighting for safety in a Very High Fire Hazard Severity Zone. Residents are raising alarms
about high-risk, large-scale projects, such as the Hills Festival Project (DEV2023-00043), the
resurgent Deer Canyon/Hills Preserve, and upcoming projects like Saddle Ranch, that fail to
address critical infrastructure deficits, bottlenecks, and evacuation gridlock.
Withholding of Evidence: The City continues to operate in Administrative Default by
withholding the broader Anaheim Hills Cumulative Wildfire Evacuation Study, which by the
City's own prior findings was deemed necessary to properly evaluate cumulative development
impacts. Approving high-density projects while suppressing the very data needed to prove
their safety is a failure of informed decision-making.
By adopting these new procedural hurdles today, the City is choosing to prioritize 'meeting efficiency'
over its legal and moral obligation to allow meaningful participation from residents whose lives are
at stake."
IV. Financial Conflicts (Levine Act § 84308)
Documentation proves aggregated contributions exceeding statutory limits from Applicant agents
to the "YES" voting block within 12 months. This disqualifies the majority from voting on any project-
related items, including these procedural "fixes."
V. Notice of Formal Referrals
Referrals regarding these criminal and ethical violations are currently in process with the OCDA
Public Integrity Unit, the California FPPC, and the Orange County Civil Grand Jury. Stakeholders
reserve all rights, including the filing of a Writ of Mandate to stay all project activity should the City
fail to Cure and Correct the documented procedural and Brown Act violations associated with
Project DEV2023-00043.
VI. NOTICE OF PROTECTED WHISTLEBLOWER STATUS
Per GC § 8547.10, the identity of this Audit Team is strictly confidential. Any attempt to use City
resources to identify or retaliate against these volunteers will be reported as a criminal violation of
whistleblower protections.
Respectfully,
Stakeholder Audit Team
3
Susana Barrios
From:Concerned Anaheim Residents <concernedanaheimresidents@gmail.com>
Sent:Monday, May 11, 2026 3:44 PM
To:Theresa Bass; Public Comment; Ashleigh Aitken; Carlos A. Leon; Ryan Balius; Natalie
Rubalcava; Norma C. Kurtz; Natalie Meeks
Subject:\[EXTERNAL\] Subject: CLARIFICATION: Item #24 Supplemental Evidence – ADA & Civil
Rights Impact
You don't often get email from concernedanaheimresidents@gmail.com. Learn why this is important
Warning: This email originated from outside the City of Anaheim. Do not click links or open
attachments unless you recognize the sender and are expecting the message.
To the City Clerk and Council:
Please include this vital clarification in the Stakeholder Audit Team's supplemental filing for Item
#24:
The proposed rules fail to address physical ADA barriers within the Council Chambers—specifically
the non-compliant podium access which prevents wheelchair-bound members of the Arzola family
from participating in person. Furthermore, Section 3 of the 'Reasonable Efforts' Resolution creates a
discriminatory loophole by exempting the City from accountability for failing to notice the Hispanic
community.
These rules do not modernize participation; they codify the exclusion of vulnerable residents.
Respectfully,
Stakeholder Audit Team
On Mon, May 11, 2026 at 3:39 PM Concerned Anaheim Residents
<concernedanaheimresidents@gmail.com> wrote:
To the Mayor, Council, and Members of the Media:
This is a supplemental filing to the Master Objection submitted earlier today at 12:44pm. Upon
review of the full Item #24 Agenda Report, the Stakeholder Audit Team identifies the following
critical failures:
ADA & Physical Barriers: While the City proposes 'remote' ADA fixes, it continues to ignore the
non-compliant physical podium in the Chambers, which prevents wheelchair-bound members
of the Arzola family from addressing the Council in person.
The 'Midnight' Squeeze: Public hearings for high-risk projects (e.g., Festival, Deer Canyon, &
Upcoming Saddle Ranch) routinely have extend from 10:00 PM until midnight. Codifying a
90-minute cap on the first comment period is a mathematical guarantee that critical life-
safety testimony will be buried in the middle of the night.
1
Bad Faith Outreach: Section 3 of the 'Reasonable Efforts' Resolution is a 'Get Out of Jail Free'
card that attempts to strip the Hispanic community of legal standing when the City fails to
provide adequate noticing.
The City cannot 'modernize' participation while the chambers remain physically and linguistically
inaccessible to the very families seeking justice and safety.
Respectfully,
Stakeholder Audit Team
On Mon, May 11, 2026 at 12:44 PM Concerned Anaheim Residents
<concernedanaheimresidents@gmail.com> wrote:
To the Honorable Mayor and City Council:
The Stakeholder Audit Team hereby submits this formal objection to Resolution 1.14 and 1.15. on
Agenda Item #24 for the upcoming City Council Meeting on 5-12-26. While these are presented as
"modernizations," they are, in fact, Selective Enforcement Tools being codified only after heavy
public scrutiny from the Arzola Family and East Anaheim Residents. To adopt these restrictive
measures while documented forensic violations remain unaddressed is an act of Administrative
Bad Faith and a premeditated denial of meaningful public participation.
I. Constructive Admission & The "Huddle" Safe Harbor
Resolution 1.14 (Glitch Recess) serves as a defensive reaction to the evidence in Exhibit N-2, which
captured the staggered exits of 6 out of the 7 Council Members/Mayor and the City Attorney during
the 3/24/26 hearing before deciding to Reject the Appeal for the Festival Proposal AND voted to
approve the 2nd vote for that development. While Council Member Norma Campos Kurtz remained
at the dais, her documented use of a cellular device suggests continued coordination either of. By
voting to approve these today, the City is attempting to codify a "Safe Harbor" for these unrecorded
huddles while continuing to suppress the requested live meeting text logs and key video footage
from inside and outside of the dais during that time window. Stakeholders also
witnessed registered and unregistered lobbyists (Younus Zeshaan, Joel Saldivar, & Jack Truman)
engaged in perceived active texting chains between multiple Council Members leading up to the
vote. By voting "YES" today, the City is attempting to codify a "Safe Harbor" for this unrecorded
coordination.
II. Systematic Suppression, Pattern of "Record Scrubbing," & Multiple Ethics Violations
The City cannot "clean up" its rules while the following Multiple Ethics and Transparency Violations
remain unaddressed:
Stakeholders formally object to the City’s ongoing Administrative Default (Exhibit L). We have
documented a pattern of "Record Scrubbing" intended to sanitize the administrative record,
including:
The 3/21 Portal Deletion: The removal of 870 page appeal for the Festival Development
Proposal & the 7 page Staff Report recommending denial of the appeal, that was posted to
the 3-24-26 Meeting Agenda that was visible on 3/21/26, but later scrubbed from the City's
page during a critical review window.
Calendar Scrubbing: Documented forensic gaps in the public calendars of Council Member
Natalie Meeks and Ted White regarding project coordination with Curt Pringle. Additional
2
discrepancies amongst City Council Members calendars and those of their fellow Council
Members. Additionally, Lobbyists have shown clumping date patterns in their quarterly
reports in a perceived attempt to hide the exact dates and frequency they reached out to
Council Members and key City Staff during critical decisions making windows regarding the
Festival Development.
Social Media Viewpoint Discrimination: The deletion of resident comments on official City
pages, which only "reappeared" after Stakeholders provided a comment explaining they had
screenshotted proof of the censorship.
The "1-Minute" Muzzle: While 1-minute limits existed in writing, they were never enforced until
residents began presenting complex evidence of misdemeanor lobbying perjury, wildfire
safety concerns, and lack of infrastructure in a High Fire Severity Area. Using this
"discretionary power" now is a direct strike against meaningful participation on upcoming
projects like Deer Canyon and Saddle Ranch.
III. Unified Tactic Against Resident Oversight & Life-Safety Testimony
Agenda Item #24 is a coordinated attempt to 'time out' the most critical and informed voices in our
community. By implementing a restrictive 90-minute cap and enforcing a 1-minute discretionary
limit, the City is ensuring that evidence-heavy testimony on matters of life and death is effectively
suppressed.
Suppression of Justice Efforts: These rules directly target the Arzola family, who for months
have been forced to repeatedly attend meetings to seek justice for Albert, demanding the
release of unedited bodycam footage and the names of involved officers. While they have
only recently received the name of the officer involved, the officer is still working, bodycam
footage remains unprovided, and this change would severely impact their ability to continue
fighting for justice for Albert. The family also reports repeated instances of harassment from
police officers at their home.
Suppression of Public Safety Concerns: Similarly, these rules target East Anaheim residents
fighting for safety in a Very High Fire Hazard Severity Zone. Residents are raising alarms
about high-risk, large-scale projects, such as the Hills Festival Project (DEV2023-00043), the
resurgent Deer Canyon/Hills Preserve, and upcoming projects like Saddle Ranch, that fail to
address critical infrastructure deficits, bottlenecks, and evacuation gridlock.
Withholding of Evidence: The City continues to operate in Administrative Default by
withholding the broader Anaheim Hills Cumulative Wildfire Evacuation Study, which by the
City's own prior findings was deemed necessary to properly evaluate cumulative
development impacts. Approving high-density projects while suppressing the very data
needed to prove their safety is a failure of informed decision-making.
By adopting these new procedural hurdles today, the City is choosing to prioritize 'meeting
efficiency' over its legal and moral obligation to allow meaningful participation from residents
whose lives are at stake."
IV. Financial Conflicts (Levine Act § 84308)
Documentation proves aggregated contributions exceeding statutory limits from Applicant agents
to the "YES" voting block within 12 months. This disqualifies the majority from voting on any
project-related items, including these procedural "fixes."
3
V. Notice of Formal Referrals
Referrals regarding these criminal and ethical violations are currently in process with the OCDA
Public Integrity Unit, the California FPPC, and the Orange County Civil Grand Jury. Stakeholders
reserve all rights, including the filing of a Writ of Mandate to stay all project activity should the City
fail to Cure and Correct the documented procedural and Brown Act violations associated with
Project DEV2023-00043.
VI. NOTICE OF PROTECTED WHISTLEBLOWER STATUS
Per GC § 8547.10, the identity of this Audit Team is strictly confidential. Any attempt to use City
resources to identify or retaliate against these volunteers will be reported as a criminal violation of
whistleblower protections.
Respectfully,
Stakeholder Audit Team
4