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<br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br />September 19, 2012 <br />Ryan O. Hodge <br />Assistant City Attorney <br />City of Santa Ana <br />20 Civic Center Plaza * P O Box 1988 <br />Santa Ana, CA 92702 <br /> <br />Re: Your Request for Advice <br /> Our File No. A-12-126 <br /> <br />Dear Mr. Hodge: <br /> <br />This letter responds to your request for advice on behalf of Santa Ana City <br />Councilmember Vince Sarmiento regarding the conflict-of-interest provisions of the Political <br />1 <br /> <br /> <br />QUESTION <br /> <br /> Does the Act prohibit Councilmember Sarmiento from participating in governmental <br />decisions regarding Santa Ana Downtown Community Management District due to his status as <br />beneficiary of a revocable trust or as a local practicing attorney? <br /> <br />CONCLUSION <br /> <br />Based on the facts you provided, Councilmember Sarmiento does not have a <br />disqualifying conflict-of-. We do not have enough <br />information to analyze any other economic interests. <br /> <br />FACTS <br /> <br /> You represent Vince Sarmiento, city council member for Santa Ana. Several years ago, <br />, which levies certain <br />assessments on businesses in the district. Since its inception in 2008, Councilmember Sarmiento <br />has abstained from participating in governmental decisions regarding the CMD due to his <br />interest in a family trust, which owns a business in the CMD. <br /> <br />1 <br /> The Political Reform Act is contained in Government Code Sections 81000 through 91014. All statutory <br />references are to the Government Code, unless otherwise indicated. The regulations of the Fair Political Practices <br />Commission are contained in Sections 18110 through 18997 of Title 2 of the California Code of Regulations. All <br />regulatory references are to Title 2, Division 6 of the California Code of Regulations, unless otherwise indicated. <br /> <br />