April 20th, 2012

Anaheim Office of the City Clerk Records Section Re: Public Records Act Request

Dear Office of the City Clerk, Records Section:

This letter is to request access to records in the possession of the City of Anaheim for the purpose of inspection and copying pursuant to the California Records Act (Government Code Section 6250 et seq.) and Article I, Section 3 of the California Constitution.

As used throughout this Public Records Act request, the term “communications” includes, without limitation, all documents and other materials relating or referring to the subject of the specific request – e.g., e-mail or other electronically delivered messages, memoranda, letters, notes or transcripts of phone conversations, notes or transcripts of meetings or videoconferences, calendars, contracts, agreements, memoranda of understanding, guarantees, proposals, requests for proposals requests for qualifications, letters of intent, notices, agendas, minutes, reports, analyses, statements, term sheets, budgets, appraisals, structural outlines, plans, projections, studies, estimates, drawings, charts, graphs, PowerPoint or other audiovisual presentations, press releases, etc.

The information that I ask to inspect is as follows:

1. All communications(1) between the City of Anaheim (including, without limitation, its Mayor, Council Members, City Manager, Assistant City Manager, City Treasurer, departments and staff) [collectively the “City”] and any representatives of Maloof Sports and Entertainment Inc. and/or the Sacramento Kings Basketball Team from the period from April 1, 2011, to the present regarding the City’s entertainment and sports arena facility, Anaheim Arena, also known as “Honda Center;”

2. All communications between the City and any representative of Anaheim Arena Management LLC during the period from April 1, 2011, to the present regarding Maloof Sports and Entertainment Inc. as relating to “Honda Center;”

3. All communications between the City and any representatives of Anaheim Arena Management LLC during the period from April 1, 2011, to the present regarding the Sacramento Kings Basketball Team as relating to “Honda Center;”

4. All communications between the City and any representatives of Rengel+Company Architects during the period from April 1, 2011, to the present regarding “Honda Center;”

5. All communications between the City and any representatives of Banyan Group Construction Inc. during the period from April 1, 2011, to the present regarding “Honda Center”

6. All communications between the City and California State Senator Mimi Walters or any of her staff/representatives during the period from April 1, 2011, to the present regarding “Honda Center;”

7. All communications between the City and California State Assembly member Jose Solorio or any of his staff/representatives during the period from April 1, 2011, to the present regarding “Honda Center;”

8. All communications between the City and United States Representative Loretta Sanchez or any of her staff/representatives during the period from April 1, 2011, to the present regarding “Honda Center;”

9. All communications between the City and Christopher Thornberg of Beacon Economics or his representatives during the period from April 1, 2011, to the present.

10. All communications between the City and any representatives of the California Department of Transportation during the period from April 1, 2011, to the present regarding potential impacts to the state and/or interstate highway system which may result from the “Honda Center” upgrade project known as the “Grand Terrace Project;”

11. All communications between the City and any representatives of the County of Orange and/or its Department of Transportation during the period from April 1, 2011, to the present regarding “Honda Center;”

12. All communications between the City and Douglas Mirell of Loeb & Loeb LLP or his representatives during the period from April 1, 2011, to the present;

13. All communications between the City and Scott Zolke of Loeb & Loeb LLP or his representatives during the period from April 1, 2011, to the present;

14. All communications between the City and Harvey Englander of Englander Knabe & Allen or his representatives during the period from April 1, 2011, to the present;

15. All communications between the City and Eric Rose of Englander Knabe & Allen or his representatives during the period from April 1, 2011, to the present;

16. All communications between the City and any representatives of the Orange County Transportation Authority during the period from April 1, 2011, to the present regarding “Honda Center;”

17. All communication between the City and any representatives of the Anaheim Chamber of Commerce during the period from April 1, 2011, to the present regarding “Honda Center;”

18. All communications between the City and any representatives of the Anaheim Ducks Hockey Club LLC during the period from April 1, 2011, to the present regarding “Honda Center;”

19. All communication between the City and any representatives of H&S Ventures LLC during the period from April 1, 2011, to the present regarding “Honda Center;”

20. All communication between the City and any representatives of H&S Ventures LLC during the period from April 1, 2011, to the present regarding Maloof Sports and Entertainment Inc.;

21. All communication between the City and any representatives of H&S Ventures LLC during the period from April 1, 2011, to the present regarding the Sacramento Kings Basketball Team;

22. All proposals made to the City from April 1, 2011, to the present regarding improvements to and/or remodeling of “Honda Center;”

23. All proposals made to the City from April 1, 2011, to the present regarding the nancing of improvements to and/or remodeling of “Honda Center;”

24. All documents from April 1, 2011, to the present discussing, concerning, referring or otherwise relating to permits for improvements to and/or remodeling of “Honda Center;”

25. All documents from April 1, 2011, to the present discussing, concerning, referring or otherwise related to the relocation of the Sacramento Kings Basketball Team to “Honda Center;”

26. All documents from April 1, 2011, to the present discussing, concerning, referring or otherwise related to the need to supplement the Environmental Impact Report in association with improvements to and/or remodeling of “Honda Center;”

27. All documents from April 1, 2011, to the present discussing, concerning, referring or otherwise related to timing and construction duration of improvements to and/or remodeling of “Honda Center.”

This request reasonably describes identifiable record or information to be produced from that record. If you are unable to comply with this request because you believe it is not focused or effective, California Government Code Section 6253. 1(a) requires you to: (1) assist me in identifying the record and information that are responsive to my request or to the purpose of my request; (2) describe the information technology and physical location in which the records exist; and (3) provide me with suggestions for overcoming any practical basis for denying access to the records or information I am seeking.

Pursuant to Government Code Section 6253(b), I ask that you make the records “promptly available,” for inspection and copying, based on my payment of “fees covering direct costs of duplicate or statutory fee, if applicable.” I believe that no express provisions of the law exists that exempt the records from disclosure. As you determine whether this request seeks copies of disclosable public records, be mindful that Article I, Section 3 (b)(2) of the California Constitution requires you to: (1) broadly construe a stature, court rule or other authority of if furthers the right of access to the information I have requested; and (2) to narrowly construe a statute, court rule or other authority if it limits my right of access.

If a portion of the information I have requested is exempt from disclosure by express provisions of law, Government Code Section 6253(a) additionally requires segregation and deletion of that material in order that the remainder of the information may be released. If you determine that an express provision of the law exists to exempt from disclosure all or a portion of the material I have requested, Government Code Section 6253(c) requires notification to me of the reasons for the determination not later than 10 days from your receipt of this request.

Government Code Section 6253(d) prohibits the use of the 10-day period, or any other provision of the Public Records Act, “to delay access for purposes of inspecting public records.”

Thank you for your timely attention to my request.

Sincerely, Robbie Waters