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Letter to Attorney
General Edmund G. Brown, Jr.
20 pp.; 728 Kb
Exhibits A & 112
395 pp.; 15,231 Kb
from PART 1 above:
A (8 pages, 266 Kb)
ATTORNEY GENERAL OPINION 93-1205, MAY 12, 1994
1 (165 pages, 4618
IRVINE COAST DEVELOPMENT AGREEMENT 1988
2 (93 pages, 2352 Kb)
CERTIFIED LCP DEVELOPMENT PLAN, JANUARY 1982
3 (3 pages, 91
IRVINE COAST LCP DEVELOPMENT
REQUEST, OCTOBER 28, 1987
4 (30 pages, 4908
EXECUTIVE SUMMARY; ROAD PHOTO MAP AMENDED REQUEST, MARCH 1987
5A (5 pages, 146 Kb)
ORIGINAL GRANT DEED TO COUNTY OF ORANGE FOR LCP, AUGUST 22 1988
5B (4 pages, 158 Kb)
AMMENDED GRANT DEED GIVEN TO TCA FREE, MARCH 16, 1993
6 (4 pages, 124 Kb)
O.C. EMA TALKS ABOUT CERTIFIED LCP OF APRIL 20, 1988
7 (2 pages, 71
ADDITIONAL OF SITE MITIGATION EMA REPORT OF CERTIFIED LCP OF
8 (17 pages, 552 Kb)
CCC APPLICANT THE IRVINE COMPANY LCP ROAD PERMIT, DECEMBER 9,
9 (2 pages, 51 Kb)
PELICAN HILL RD. REPORT, ROBERT BEIN & FROST, 1987
10 (9 pages, 189
IRVINE COAST MASTER COASTAL DEVELOPMENT, FIRST AMENDMENT, 1989
11 (1 page, 33 Kb)
CHUCK DAMM LETTER, 1994; COPIED TO ME FROM RODENY LILYQUIST Esq.,
12 (6 pages, 195 Kb)
MEMORANDUM FROM CHUCK DAMM REGARDING LCP, DECEMBER 4, 1987
(Chuck Damm to Coastal
November 19, 1987)
52 pp.; 1,720 Kb
207 pp.; 5,578 Kb
from PART 3 above:
14 (5 pages, 149
Attorney General Reply
ASSEMBLYMAN FERGUSON ORIGINAL REQUEST FOR OPINION, DECEMBER 9,
15 (1 page, 37
A.G. OFFICER Ms. MAISER REQUEST FOR MY DEBATE DOCUMENTS, DECEMBER
16 (8 pages, 303
JIM TOLEDANO Esq. OPINION; FAX OPINION REPLY, MAY 4, 1994
17 (2 pages, 48
ASSEMBLYMAN FERGUSON CHANGED REQUEST FOR OPINION, MAY 10, 1994
18 (4 pages, 109
APPLICANT FOR LCP, THE IRVINE COMPANY OPINION LETTER, APRIL 1,
19 (2 pages, 56
NEWPORT BEACH CITY MANAGER BOB WYNN OPINION LETTER
20 (6 pages, 137
RON KENNEDY ROAD & BONDS SOLD OPINION LETTER, JANUARY 8,
21 (1 page, 51
DAILY PILOT FERGUSON URGES TOLL ROAD INVESTIGATION, DECEMBER
22 (1 page, 43
DAILY PILOT CONICIALMAM SANSONE TOLD NOT TO MUDY THE WATER, FEBRUARY
23 (86 pages, 2287
STEPHEN COONTZ ESQ. ORANGE COUNTY RESOLUTIONS, JULY 12, 1996
24 (4 pages, 119
CCC MARK DEPLAINE FEDRAL CONSISTENCY LETTER TO TCA, FEBRUARY,
25 (4 pages, 150
TCA EIS FINANCED BY TOLLS, APRIL, 1992
26 (2 pages, 62
FAST CORRIDOR FACTS TWO MAPS SHOW ROADS AS SEPERAT 7 1, 1990
27 (2 pages, 61
FAST CORRIDOR FACTS; TWO MAPS SHOW ROADS AS SEPARATE, NOVEMBER
28 (8 pages, 288
$1,078,692,411.05 TCA TOLL ROAD REVENUE BONDS, MARCH 4,1993
29 (16 pages, 424
COURT OF APPEAL 4TH DISTRICT, SILLS P.J. JUDGE OPINION, OCT.
30 (28 pages, 662
NOSSAMAN, GUTHNER, KNOX & ELLIOT, TCA LAWERS OPINION LETTER,
31 (3 pages, 93
ORANGE COUNTY COUNSEL OPINION LETTER, MARCH 24, 1994
32 (2 pages, 92
DAILY PILOT OPENING OF NEWPORT COAST DRIVE, NOVEMBER 16, 1991
33 (4 pages, 106
A.G. REPLY IN REQUEST OF TCA, LCP APPROVAL, AUGUST 22, 2007
34 (8 pages, 154
A.G. REPLY IN REQUEST OF TCA; LCP APPROVAL, SEPTEMBER 5, 2007
35 (4 pages, 102
TCA LAWERS TO WILLIAM WOOLLETT, CEO OF TCA, FEBRUARY 20, 1996
36 (5 pages, 119
LETTER TO A.G. FOR EARLIER REVIEW OF OPINION, PLUS REPLY "DECLINE"-"NO
BASIS UPON WHICH TO REVISIT THE QUESTIONS,'' MAY 10, 2000.
plus Additional Letters
Exhibit C Irvine Coastal Local Coastal
Plan Findings Of Approval And Supporting Documents June 9, 1988."
were Approved and Certified by the California Coastal Commission.
The LCP Road Mitigation is FIRST IN TIME & FIRST IN RIGHTS.
Public Resources Code 30334 calls out your good offices as Legal
Council for the California Coastal Commission. And Code 30820
persons violating this subdivision may be held for Civil Liability.
STATMENT OF "DEMONSTRATED EXHIBIT FACTS".
The San Joaquin Hills Transportation Corridor Agency ("TCA")
and County of Orange. And there Lawyer's I belive are knowingly
in violation or Ignorant of the Findings in the Development Agreement
of the "Irvine Coast Development Agreement County Of Orange
& Exhibit C. Irvine Coastal Local Coastal Plan Findings Of
Approval And Supporting Documents. June 9,1988." The LCP
Traffic Mitigation's are clearly shown in the Finding of exhibit
C. a total of 63 pages alone for resolving LCP Questions. TCA
Lawyers Nossaman, Gunther, Knox & Elliott As Lawers for the
TCA & Officers of the Court ignored these clear callouts'
of Exhibit C. As the Irvine Coastal Local Coastal Plan Findings
would show. Which is a Fraud on the TCA, California Coastal Commission
& the Court's of California if done for a fee?
[Exhibit 1 ] The IRVINE COAST
DEVELOPMENT AGREEMENT COUNTY OF ORANGE And Exhibits C. &
Recorded in Official Records of Orange County, California # 88
- 272903 June - 9 1988. [ Note at bottom gives Orange County
contact information for a certified copy ]
Page -3- - - "COUNTY and the Coastal Commission have determined
that the Development plan meets the various objectives of the
California Coastal Act,"
Page -11- 2.2 " Consistency with County's General plan and
Certified Local Coastal Program "
Page -11 - 2.3 " Summary of Major Public Benefits.
Page -12- 2.3.1 "Transportation Improvements, (a) Pelican
Hill Road." (later renamed Newport Coast Drive) "(i)
Relives congestion - by providing a bypass rout around Corona
Page -20- 2. 4.1 " Cost of Pelican Hill Road Construction.
The requirements for the early completion of four lanes of Pelican
Hill Road by the OWNER necessitates major construction activities
with ultimate costs of approximately $40 million (which amount
includes the cost of
certain related infrastructure)"
Exhibit C. Irvine Coast Local Coastal Plan Findings Of Approval
And Supporting Documentation
Page -21- 3)" Pelican Hill Road, in Particular, Provides
Regional Traffic Benefits in Excess of Project Needs"
Page -22- (top of page) "recreational access capacity by
connecting inland areas directly to Crystal Cove State Park (
see Exhibit 13 in the Executive Summary)."
Irvine Coast Development Agreement. " Exhibit C. Irvine
Coast Local Coastal Plan Findings Of Approval And Supporting
Documentation " on page 22 call's out"( see Exhibit
13 in the EXECUTIVE SUMMARY )." Which is the Irvine
Coast Proposed Land Use Plan Amendment, EXECUTIVE SUMMARY March
1987. (my exhibit # 4. below.) on
page 22. The MAP Yellow Road on Green Fields shows just what
actually was promised for all to see clearly regarding Pelican
Hills RD. / Newport Coast Drive Shortest Direct Bypass link.
From Pacific Coast Highway ( PCH ) to MacArthur Boulevard. As
proposed by The Irvine Company ( TIC ). Land Owner & Developer
as part of there Quid Pro Quo for a LCP Coastal Development Permit.
Part of Pelican Hills / Newport Coast Drive P. 22 . was dedicated
& built out side the Coastal zone as offsite mitigation.
And was planed to be part of the Orange County TCA. Corridor
as a Free of Charge Free Way, or a separate county free road
link. In their early county planing road evaluations.