PAGE 6

Letter to Attorney General Edmund G. Brown, Jr., continued

Page 1

Page 2

Page 3

Page 4

Page 5

Page 6

Page 7

Page 8

Page 9

Page 10

Page 11

Page 12

Page 13

Page 14

Page 15

Page 16

Page 17

Page 18

Page 19

Page 20

Ronald Douglas Kennedy
otrkennedy@aol.com

All documents in PDF format—please be patient for dial-up connections
(left-click to load in browser; RECOMMEND right-click to download to your computer)

Requires FREE Acrobat Reader

Letter to Attorney General Edmund G. Brown, Jr.
20 pp.; 728 Kb

PART 1:
Exhibits A & 1–12
395 pp.; 15,231 Kb

OR

Separate Files
from PART 1 above:

EXHIBIT A (8 pages, 266 Kb)
ATTORNEY GENERAL OPINION 93-1205, MAY 12, 1994
EXHIBIT 1 (165 pages, 4618 Kb)
IRVINE COAST DEVELOPMENT AGREEMENT 1988
EXHIBIT 2 (93 pages, 2352 Kb)
CERTIFIED LCP DEVELOPMENT PLAN, JANUARY 1982
EXHIBIT 3 (3 pages, 91 Kb)
I
RVINE COAST LCP DEVELOPMENT REQUEST, OCTOBER 28, 1987
EXHIBIT 4 (30 pages, 4908 Kb)
EXECUTIVE SUMMARY; ROAD PHOTO MAP AMENDED REQUEST, MARCH 1987
EXHIBIT 5A (5 pages, 146 Kb)
ORIGINAL GRANT DEED TO COUNTY OF ORANGE FOR LCP, AUGUST 22 1988
EXHIBIT 5B (4 pages, 158 Kb)
AMMENDED GRANT DEED GIVEN TO TCA FREE, MARCH 16, 1993
EXHIBIT 6 (4 pages, 124 Kb)
O.C. EMA TALKS ABOUT CERTIFIED LCP OF APRIL 20, 1988
EXHIBIT 7 (2 pages, 71 Kb)
ADDITIONAL OF SITE MITIGATION EMA REPORT OF CERTIFIED LCP OF 1987
EXHIBIT 8 (17 pages, 552 Kb)
CCC APPLICANT THE IRVINE COMPANY LCP ROAD PERMIT, DECEMBER 9, 1987
EXHIBIT 9 (2 pages, 51 Kb)
PELICAN HILL RD. REPORT, ROBERT BEIN & FROST, 1987
EXHIBIT 10 (9 pages, 189 Kb)
IRVINE COAST MASTER COASTAL DEVELOPMENT, FIRST AMENDMENT, 1989
EXHIBIT 11 (1 page, 33 Kb)
CHUCK DAMM LETTER, 1994; COPIED TO ME FROM RODENY LILYQUIST Esq., 1994
EXHIBIT 12 (6 pages, 195 Kb)
MEMORANDUM FROM CHUCK DAMM REGARDING LCP, DECEMBER 4, 1987
-

PART 2:
Exhibit 13—Complete
(Chuck Damm to Coastal Commisioners,
November 19, 1987)
52 pp.; 1,720 Kb

PART 3:
Exhibits 14–36
207 pp.; 5,578 Kb

OR

Separate Files
from PART 3 above:

EXHIBIT 14 (5 pages, 149 Kb)
ASSEMBLYMAN FERGUSON ORIGINAL REQUEST FOR OPINION, DECEMBER 9, 1993
EXHIBIT 15 (1 page, 37 Kb)
A.G. OFFICER Ms. MAISER REQUEST FOR MY DEBATE DOCUMENTS, DECEMBER 8, 1993
EXHIBIT 16 (8 pages, 303 Kb)
JIM TOLEDANO Esq. OPINION; FAX OPINION REPLY, MAY 4, 1994
EXHIBIT 17 (2 pages, 48 Kb)
ASSEMBLYMAN FERGUSON CHANGED REQUEST FOR OPINION, MAY 10, 1994
EXHIBIT 18 (4 pages, 109 Kb)
APPLICANT FOR LCP, THE IRVINE COMPANY OPINION LETTER, APRIL 1, 1994
EXHIBIT 19 (2 pages, 56 Kb)
NEWPORT BEACH CITY MANAGER BOB WYNN OPINION LETTER
EXHIBIT 20 (6 pages, 137 Kb)
RON KENNEDY ROAD & BONDS SOLD OPINION LETTER, JANUARY 8, 1994
EXHIBIT 21 (1 page, 51 Kb)
DAILY PILOT FERGUSON URGES TOLL ROAD INVESTIGATION, DECEMBER 9, 1993
EXHIBIT 22 (1 page, 43 Kb)
DAILY PILOT CONICIALMAM SANSONE TOLD NOT TO MUDY THE WATER, FEBRUARY 26, 1993
EXHIBIT 23 (86 pages, 2287 Kb)
STEPHEN COONTZ ESQ. ORANGE COUNTY RESOLUTIONS, JULY 12, 1996
EXHIBIT 24 (4 pages, 119 Kb)
CCC MARK DEPLAINE FEDRAL CONSISTENCY LETTER TO TCA, FEBRUARY, 1991
EXHIBIT 25 (4 pages, 150 Kb)
TCA EIS FINANCED BY TOLLS, APRIL, 1992
EXHIBIT 26 (2 pages, 62 Kb)
FAST CORRIDOR FACTS TWO MAPS SHOW ROADS AS SEPERAT 7 1, 1990
EXHIBIT 27 (2 pages, 61 Kb)
FAST CORRIDOR FACTS; TWO MAPS SHOW ROADS AS SEPARATE, NOVEMBER 15, 1990
EXHIBIT 28 (8 pages, 288 Kb)
$1,078,692,411.05 TCA TOLL ROAD REVENUE BONDS, MARCH 4,1993
EXHIBIT 29 (16 pages, 424 Kb)
COURT OF APPEAL 4TH DISTRICT, SILLS P.J. JUDGE OPINION, OCT. 12, 1999
EXHIBIT 30 (28 pages, 662 Kb)
NOSSAMAN, GUTHNER, KNOX & ELLIOT, TCA LAWERS OPINION LETTER, MARCH 1994
EXHIBIT 31 (3 pages, 93 Kb)
ORANGE COUNTY COUNSEL OPINION LETTER, MARCH 24, 1994
EXHIBIT 32 (2 pages, 92 Kb)
DAILY PILOT OPENING OF NEWPORT COAST DRIVE, NOVEMBER 16, 1991
EXHIBIT 33 (4 pages, 106 Kb)
A.G. REPLY IN REQUEST OF TCA, LCP APPROVAL, AUGUST 22, 2007
EXHIBIT 34 (8 pages, 154 Kb)
A.G. REPLY IN REQUEST OF TCA; LCP APPROVAL, SEPTEMBER 5, 2007
EXHIBIT 35 (4 pages, 102 Kb)
TCA LAWERS TO WILLIAM WOOLLETT, CEO OF TCA, FEBRUARY 20, 1996
EXHIBIT 36 (5 pages, 119 Kb)
LETTER TO A.G. FOR EARLIER REVIEW OF OPINION, PLUS REPLY "DECLINE"-"NO BASIS UPON WHICH TO REVISIT THE QUESTIONS,'' MAY 10, 2000.
-

Attorney General Reply
plus Additional Letters
coming soon!

Road Mitigation for a Local Coastal Development Permit's. In our out side the actual Coastal Zone, or any other type of LCP mitigation. The TCA has no Law to site to alter " LCP Mitigation " at a later time with their so called parochial Police Powers. They are totally wrong in their argument's:


as found in [my exhibit 30 ]

page 4. " On October 17, 1988, the County and the city members of the TCA amended the Joint Powers Agreement to exercise the power authorized by the legislature to impose and collect tolls on the Corridor."

Note: {There argument is late in Date and Time also as the Memorialized LCP Mitigation was first by four months. Irvine Coast Development Agreement of June 9,1988. Also the 1988 LCP is an Amendment of the 1982 LCP certified plan [ my exhibit 2 ] }

I do not belive there is a new Amending Coastal Commission approval of the original Irvine Coast Development Agreement Coastal Commission approval of the 1988 Findings? [ my exhibit 1 ]

page 11." On October 17,1988, the TCA also has the authority to exercise this power under the Joint Exercise of Powers Act and the Joint Powers Agreement as necessary to construct the Corridor."

page 12. " In this instance, the Legislative bodies of the County and cities have authorized the TCA to exercise there common powers to "fund, plan, acquire and construct" the Corridor."

page 29 "In addition the Corridor has received approvals from over 25 Federal, state and local agencies, including the California Coastal Commission"
.
Note} I have requested a Copy of this Coastal Commission approval from the A. G. office your reply of September 5, 2007 " we do not have any records within our control or custody responsive to your request." [ my exhibit 34 ]. Also I do not belive there is a new Amending Coastal Commission approval of the original Irvine Coast Development Agreement and Coastal Commission approval of the 1988 Findings? [ my exhibit 1 ]


The Police Powers amending argument assumed by TCA Lawyers & County Lawyers [my exhibit's 30 and 31 below] for the Opinion 93 -1205 regarding Irvine Coast LCP. Irvine Coast Development Agreement is a terrible wrong headed assumption by: Nossaman, Gunther, Knox & Elliott. And County Lawyers.


This wrong headed assumption has been repeated by the Appellate Court [my exhibit 29 ] at Page 11." The argument is utterly without merit. As a joint powers agency, the Agency may exercise any power common to its constituent agencies. (Gov. Code,;; 6502 & 6508.)" This Appellant Court Opinion to leave unchallenged by your good offices as the Attorney General. And Legal Council to the State Coastal Commission. That LCP Mitigation can be Altered by County, City / State, using Police Powers at a later time must be corrected so it can not be used as a PRESIDENCS by future: City, County, State's arguments in Court's of Law to take LCP Mitigation from the "Public's Domain".


//////// The EXECUTIVE SUMMARY, MAP my exhibit 4 above, and the Original Grant Deed of 1988, exhibit 5 . visually & literly answers the seminal question that the entire Pelican Hill / Newport Coast Drive was given & built as Mitigation for the Irvine Coastal Development Agreement, Local Coastal Plan & Finding's. The below: Representations Exhibits & Documentations, support's this only Germane question I have argued from day one regarding Opinion No. 93-1205.


The GRAVE STONE STATEMENTS are found in exhibit 1. Irvine Coast Development Agreement Exhibit C & D

Page D-10 1. Transportation Improvements, a. Pelican Hill Road. - - " Under the 1988 Local Coastal Program, Pelican Hill Road will be constructed at four lanes from Pacific Coast continued...

Page 1

Page 2

Page 3

Page 4

Page 5

Page 6

Page 7

Page 8

Page 9

Page 10

Page 11

Page 12

Page 13

Page 14

Page 15

Page 16

Page 17

Page 18

Page 19

Page 20


© Copyright 2008 Ron Kennedy. All rights reserved.