Gary M. Zeiss, Esq. May 27, 2025 Heather Baker City AKorney for Culver City Culver City Hall 9770 Culver Blvd Culver City, CA 90232 [email protected] Re: Request to IniRate a LiRgaRon Hold Heather: Due to likely liRgaRon regarding the City Council’s acRons regarding the propriety and consRtuRonality of the Jubilo Village project, I respecZully request that the city iniRate a liRgaRon hold regarding the following informaRon. First, all documents, communicaRons, recordings, emails, aKachments, text messages, videos, photos, data, reports, analyses, opinions, and other records (collecRvely, the “InformaRon”) related to the Jubilo Village project from 2019 unRl present. Second, all InformaRon arising from or related to the City’s or the City Council’s interacRon with any employee, consultant, officer, or representaRve of the Community CorporaRon of Santa Monica (including all related enRRes) since the iniRal concepRon of the Jubilo Village project in 2019. Third, all InformaRon arising from or related to the City’s or the City Council’s interacRon with any employee, consultant, officer, or representaRve of the Culver-Palms United Methodist Church (including all related enRRes) since the iniRal concepRon of the Jubilo Village project in 2019. Fourth, all InformaRon arising from or related to any City Councilor’s communicaRons with Disa Lindgren, whether expressly menRoning Jubilo Village or not, since 2019.
Request for Li-ga-on Hold May 27, 2025 Page 2 of 2 Please retain such informaRon in a manner that makes it readily available when necessary and unRl the prospecRve legal claim is either withdrawn or dismissed. Note that I will be making a simultaneous public records request for this informaRon through the Culver City portal. I know that this creates extra work for an already overburdened staff, and I apologize for the imposiRon. However, conRnued access to this informaRon may be necessary to determine the propriety of the project and its structure. Certainly, feel free to contact me with any quesRons. Thank you. RespecZully, Gary M. Zeiss, Esq.