LEVINE, B. -PUBLIC SPEAKER CORRESPONDENCE

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ILUS GP US, LLC c/o Feinberg Mindel Brandt&Klein,TIP 12424 Wilshire Blvd. I.os Angeles,California 90025 November 12, 2013 © 0 pY Via FedEx and email Sonia R. Carvalho, Esq. Office of the City Attorney of the City of Santa Ana 20 Civic Center Plaza Santa Ana, California 92701 Re: Excessive Political Contributions, Theft of City Files, Corporate Suspension and Derogatory Statements by Applicant and Ryan Ogulnick Dear Ms. Carvalho: I write in further reply to your email to me dated November 4, 2013. In that email, you requested additional information concerning the unreported gifts Mr. Ogulnick and his affiliates conferred on members of the Santa Ana City Council, as well as undisclosed relationships and/or common ownership by Ryan Ogulnick and/or Rachel Ogulnick in entities. Below and enclosed, please see the information you requested. As you know, the Municipal Code of the City of Santa Ana prohibits City Councilmembers from soliciting or accepting any campaign contribution of $250.00 or more from any person for a 3-month period following the date a final decision is rendered in any proceeding before the council that involves entitlements, if the councilmember knows or should know the person making the contribution had a financial interest in the proceeding. See, Santa Ana, California Code of Ordinances Sec. 2-107. As you may also know, for purposes of Section 2-107 of the Santa Ana Code of Ordinances, "financial interest" has the same meaning as it is defined to have in Title 9 of the California Government Code. Title 9, also known as the Political Reform Act (the"Act"), defines financial interest as follows: A public official has a financial interest in a decision within the meaning of Section 87100 if it is reasonably foreseeable that the decision will have a material financial effect, distinguishable from its effect on the public generally, on the official, a member of his or her immediate family, or on any of the following: [...] (e) Any donor of, or any intermediary or agent for a donor of, a gift or gifts aggregating two hundred fifty dollars ($250) or more in value provided to, received by, or promised to the public official within 12 months prior to the time when the decision is made. The amount of the value of gifts specified by this subdivision shall be adjusted biennially by the commission to equal the same amount determined by the commission pursuant to subdivision (f) of Section 89503. Cal. Gov. Code § 87103 (emphasis added).