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General (11) Susana Barrios From:Hannah Tayfour <hannah@learninglight.org> Sent:Monday, September 21, 2026 5:35 PM To:Public Comment; Ashleigh Aitken; Ryan Balius; Carlos A. Leon; Natalie Rubalcava; Norma C. Kurtz; Kristen Maahs; Natalie Meeks Cc:City Clerk; Gregory Garcia; Robert Fabela; Debbie Moreno; Rudy Emami Subject:\[EXTERNAL\] September 22 Council Correspondence: Request for Council Review Before Further Litigation Spending | Case No. 30-2025-01471860-CU-EI-CJC Attachments:FINAL_Public_Accounting_Letter_2026-09-21.pdf You don't often get email from hannah@learninglight.org. 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. Mayor Aitken and Council Members: Attached is my September 21, 2026 public oversight letter requesting Council review before further discretionary litigation spending in Orange County Superior Court Case No. 30-2025-01471860-CU-EI- CJC. Please distribute the letter to every Councilmember and include it in the public correspondence for the September 22, 2026 Council meeting. The letter requests review at the earliest practicable, properly noticed meeting; it does not request a decision on the litigation at the September 22 meeting. Please confirm receipt and distribution, identify the office coordinating the response, and advise when and through what process the requested review can occur. Respectfully, Hannah Tayfour Writing in my individual capacity hannah@learninglight.org 1 September 21, 2026 Mayor Ashleigh Aitken and Members of the Anaheim City Council City of Anaheim 200 South Anaheim Boulevard Anaheim, California 92805 Re: Council review before further discretionary litigation spending Orange County Superior Court Case No. 30-2025-01471860-CU-EI-CJC Dear Mayor Aitken and Council Members: Before Anaheim commits additional public resources to take this case through trial, I ask the Council to require clear answers to four questions: 1. What concrete relief and public result does the City still seek through judgment? 2. What records support each component of the City’s pleaded $829,006 figure and its attribution to each defendant? 3. What additional outside-counsel and expert spending is proposed, and what net public benefit is expected from it? 4. Who has authority to continue, narrow, dismiss, or otherwise conclude the City’s claims, and what current review has occurred? The Learning Light Foundation, Inc. dismissed its complaint in October 2025. The City’s cross-complaint remains pending against the Foundation and me individually. The City’s May 19, 2026 First Amended Cross-Complaint alleges $829,006 in accrued compensatory damages, plus additional damages and other relief. That is an allegation, not a judgment. The case is presently set for jury trial on October 26, 2026. (ROA 330, paragraph 23 and prayer.) The Foundation operates a nonprofit day program for adults with developmental disabilities at 1212 East Lincoln Avenue. I submit this public oversight request in my individual capacity as a named cross-defendant. Define the result the City still seeks The City’s published reports listed the Lincoln Avenue widening project from East Street to Evergreen Street at 83 percent construction completion in December 2025 and 97 percent in April 2026. Those project-wide historical figures neither establish nor disprove a past damages claim. They do make the present question unavoidable: what remains that this litigation is expected to accomplish? Please distinguish the relief sought through judgment from any confidential settlement position. Identify the practical public result the requested judgment would produce. If the project objective has been achieved, say so. If not, identify what remains. Distinguish work already completed, work that remains, work the City contends was delayed or prevented by a specific act of either defendant, and work that is no longer necessary. For each claimed delay, identify the affected activity, dates, duration, actual incremental cost, and conduct attributed to each defendant. Completed work does not eliminate a properly supported historical claim. But unfinished work alone does not establish who caused a delay or what recoverable loss resulted. Litigation is a means; it is not itself the public objective. Require a current reconciliation of the pleaded figure The Council should not rely on the pleaded total without a documented reconciliation identifying: • amounts actually paid, incurred but unpaid, disputed contractor requests, and estimates or forecasts; • each cost category included in the demand, with construction or corrective costs and historical-delay damages stated separately from litigation spending; • the conduct, dates, affected activity, actual schedule effect, and incremental expense attributed to each defendant; • utility, design, procurement, sequencing, contractor-performance, concurrent-delay, and other contributing causes; and • changes from earlier calculations, together with credits, reimbursements, adjustments, and overlapping categories. A pleaded total is not a cost accounting. The City should be able to connect each claimed loss to the conduct it alleges. The Council’s internal review should consider all material litigation risks reflected in the existing record, without presuming liability in either direction. Decide what the next public dollar is expected to buy Please obtain an internal assessment of outside-counsel and expert costs paid or incurred to date, projected additional expense through trial, likely net recovery after further expense, and any remaining nonmonetary objective. I do not request public billing narratives or litigation strategy. A public response may be limited to confirmation that the review occurred, any nonprivileged aggregate information, and any action the City may lawfully report. Money already spent does not, by itself, justify spending more. The question is what additional public result the next dollar is expected to buy. Identify the accountable decision path Anaheim Charter section 703 places the City’s legal business and proceedings under Council control. Sections 604 and 607 address City administration and coordination through the City Manager. I urge the Council to have the City Manager coordinate Finance, Public Works and risk-management input, and to ask the City Attorney to provide the legal assessment and oversee outside-counsel input needed for one coordinated recommendation. That recommendation should state the remaining objective, reconcile the pleaded figure, assess risk and projected further cost, and recommend the City’s next course. Outside counsel may advise the City and act within delegated authority. Anaheim remains responsible for defining the objective, approving the expenditure, and deciding whether continued litigation serves the City. Please identify the current source and limits of delegated authority to continue, narrow, dismiss, or otherwise conclude these claims. If the matter is outside that delegation, place it before the Council. I seek the decision path and litigation objective, not public negotiation of settlement terms. Mayor Aitken, please support placement of this matter on a properly noticed Council agenda at the earliest practicable meeting. Please advise when and through what process the requested review can occur. If the City Attorney advises that Government Code section 54956.9 applies, the Council may confer with legal counsel in a properly noticed closed session concerning this existing litigation, subject to the statute’s identification and disclosure requirements. Any matter requiring public consideration or action should be handled accordingly. I request confirmation that the review occurred and any action the City is required or permitted to report, not privileged advice or closed-session deliberations. Nothing in this request asks the City to disregard a court order or deadline. I ask that any further discretionary expenditure be tied to a defined objective, budget, and accountable decision-maker. Please acknowledge receipt, confirm distribution to every Councilmember, identify the office coordinating the response, and advise the anticipated review timetable. If review will occur under delegated authority rather than before the Council, please identify the responsible official or body and the public source and limits of that authority. This letter is a public oversight request. It is not a settlement proposal, demand for compensation, authorization for property access or work, or substitute for any claim presentation, pleading, or court procedure. Any proposal that would alter the Foundation’s litigation position or commit either defendant must be made separately through an authorized representative or counsel. Please include this letter in the public correspondence provided to the Council. Respectfully, Hannah Tayfour hannah@learninglight.org Copies requested: City Manager; City Attorney; Finance Director and City Treasurer; Public Works Director; Office of the City Clerk. Public and record references: ROA 330, paragraph 23 and prayer; Anaheim December 2025 and April 2026 project reports; Anaheim City Charter sections 604, 607 and 703; Government Code section 54956.9.