Cities Index.
4.20.26 SC - 14 Emails

City Council/Public Financing Authority
April 21, 2026

Document
4.20.26 SC - 14 Emails
Meeting
April 21, 2026
Body
City Council/Public Financing Authority
Pages
19
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36.6 MB
Text extracted from the city's file for reading and search. Open the original on huntingtonbeach.legistar1.com. That file is the official record.

From: Tom McDaniel
To: [email protected]
Subject: Request for Continuance - Huntington Club Project Date: Thursday, April 16, 2026 8:26:01 AM
Attachments: Exhibit A-THC Rules & Regulations 2026,pdf Exhibit B-THC Section 1.3(b) Detailing membership rights.pdf Exhibit C: THC Updates to the Rules & Regulations 2026.pdf Exhibit D- THC email dated Feb. 7, 2026-Camaraderie Clubs to Members.pdf You don't often get email from [email protected]. Learn why this is important Dear Mayor McKeon,
I presented at the March 17 hearing on the Huntington Club project in support of the appellants. As a long time resident of Huntington Beach and member of the Huntington Club, I want to share these further observations on the project for your consideration now because I will be out of the State for the April 21 continuance hearing on the project.

I truly appreciated your questions at the March 17 hearing regarding how and who the lodging component would be operated by and integrated with the club's existing facilities and operations.

The attached letter expands on those concerns and highlights areas where the operational framework and relationship between the land owner and the operating manager remains unclear.

In short, the letter requests a further continuance so that key gaps in the record-particularly around construction phasing, operational planning, and financial analysis of the bungalow/loft component of the project-can be addressed before a final decision.

Please find attached my letter regarding The Huntington Club project, along with supporting materials referenced in the letter.

Thank you for your time and consideration.

Tom McDaniel
April 2, 2026
Dear Mayor and Members of the City Council,
I attended and provided testimony at the March 17 public hearing regarding the proposed project by Golf Realty Fund to demolish and replace the existing tennis, fitness, and swimming facilities, and to construct member/guest bungalows, an access road, and loft units atop the new tennis clubhouse.

In my testimony, I raised concerns regarding health and safety risks and the significant negative impact on member experience and retention during a prolonged construction project within an active operating tennis/pickleball and fitness operation. also shared my direct experience from another private club where similar guest bungalow facilities proved to be both a financial and operational failure. Member utilization was low, occupancy rates were insufficient to cover operating costs, and the units were ultimately sold.

I am writing to expand upon those concerns and to respectfully urge the City Council to broaden the record in three key areas before making a final decision on this project.

Membership involvement in the planning process. On March 16 Huntington Club members received an email from Club Management requiring approval of updated 2026 Rules and Regulations by April 30, 2026effective March 16, the day before the March 17 City Council hearing. These communications state that approval is needed by April 30 to maintain active membership status and club privileges (Exhibit A).

Importantly, the updated Rules and Regulations, Section 1.3b (Exhibit B), explicitly states that, as a non-equity and non-participatory club, members have no rights or standing with regard to Club operations or capital project decisions. This section cites that " The Owner and Club Management have the right to make any and all the facilities unavailable for use for some period of time, due to construction of improvements, health and safety concerns, repairs, government order or other reasons in their sole discretion, and Members shall not receive any abatement of dues during such periods of unavailability".

A March 16 communication to members, (Exhibit C) lists the specific changes to the Rules & Regulations; but, makes no disclosure whatsoever about the proposed project or the significant impact on membership health and safety, facility availability and reduced amenities over a long and complicated infill construction project.

When viewed in context of the proposed project, these provisions take on far greater significance and raise serious concerns regarding transparency and member awareness.

Bungalow/Loft Management- Questions raised at the March 17 hearing regarding the operational responsibility for the proposed bungalow and loft components of the project remain unresolved. A February 7, 2026 communication (Exhibit D), from Club Management to members makes clear that:
• Club Management does not endorse the land owner's assertions regarding the economic viability of the bungalow/access road and loft components of the project. • Club Management has no financial interest in, nor obligation to operate, the bungalow/loft components of the project.
• Club Management states their primary focus has been to compel the property owner to fulfill a long-standing contractual obligation to rebuild the pool and upgrade fitness facilities, obligations that do not include bungalows and lofts.

During a long and disruptive period of construction, Club Management will bear the burden of operating the tennis/pickleball and fitness facilities. A situation presenting members with construction safety risk, periods of extended facility closure and significantly reduced Club amenities. Membership attrition would be the likely response with a commensurate negative impact on operating margins. Thus, the lack of any formal input from the Club Operator in this process, particularly the bungalow/loft elements, is concerning and warrants further review.

In summary, because club members have no formal standing in decisions regarding Club operations or capital investment, we must look to the City Council to ensure that all relevant impacts are fully evaluated. These include:
• Health and safety risks associated with extended construction in an active recreational setting
• The financial viability and member benefit of the proposed bungalow and loft components of the project
• The absence of a clearly defined operational plan during a multi-year " infill " construction project
For these reasons, I believe the record underpinning a decision on this project needs to be expanded and the City Council should direct the Owner and Club Manager to develop plans and analysis covering the following areas.

1. Construction Phasing and Safety Plan
A detailed plan outlining construction sequencing, safety protocols, and measures to protect members, guests, and surrounding residents. This should include clear timelines for facility closures and the extent of reduced access to club amenities.

2. Bungalow/Loft Member Demand and Financial Viability Analysis An independent assessment of member demand for guest bungalows/lofts, supported by a formal economic assessment of their financial viability taking into consideration occupancy expectations (member survey), operating costs and projected economic benefit to the City.

3. Operational Continuity Plan
A comprehensive plan developed jointly by ownership and Club Management detailing how tennis, pickleball, and fitness operations will be maintained during construction. This should include mitigation strategies for reduced amenities, anticipated membership attrition, and potential financial impacts, including dues increases.

This is a significant project with long-term implications for the Huntington Beach community.

Granting a continuance of at least 60 days to allow for the construct of a more complete record will better position the City Council to make a fully informed decision on this project that best serves the interests of all stakeholders.

Respectfully,
Tom McDaniel
Member of the Huntington Club & Huntington Beach Resident

EXHIBIT A

CAMAAADERTE
The Huntington Club (Camaraderie Clubs) has sent you the file "THC Rules & Regulations 2026" for your review and signature.

REVIEW & COMPLETE
Dear The Huntington Club Member, We have updated the Rules & Regulations and Membership Guidelines at The Huntington Club to reflect our most current policies and offerings. These updates are designed to provide greater clarity, improve the member experience, and ensure our policies align with the evoiving needs of our community.

Please review and sign the updated 2026 Rules & Regulations and Club Guidelines using the secure Sertifi tink above. Your signature is required by Aprif 30, 2026 to maintain your active membership and club privileges. We appreciate your attention to these updates and your continued commitment to our club community. Thank you for your prompt attention to this matter.

Alternatively to review and sign you may copy and paste the following URL in your browser: https://www.sertifi.com/CamaraderieClubs/t ashx?su=X1Dy/Xig6nlezpm7 If you have any questions related to documents or wish to contact The Huntington Club, please email at. [email protected]

LAUDIID

ARTICLE I

DEFINITIONS AND APPLICATION

1.1 THE CLUB; THE OWNER; THE LANDLORD
The "Club" refers to the facilities provided at The Huntington Club located at 6501 Palm Ave., Huntington Beach, California 92648. The "Owner" refers to The Huntington Club, LLC. The "Landlord" refers to the owner of the real estate at the Club.

1.2 CLUB MANAGEMENT; MANAGER
"Club Management" refers to The Camaraderie Clubs Management, LLC, which manages the Club and its successors in interest. "Manager" refers to the General Manager of the Club. Club Management has authority over the affairs of the Club.

1.3 MEMBERSHIP
(a) A "Membership" is the contractual privilege by which designated persons enter onto the Club for the exclusive purpose of using and enjoying the available facilities at the times and in the manner set forth in these Rules and Regulations. A "Member" is the person obligated for the payment of all fees, dues, fines and charges.

Members agree to be bound by these Rules and Regulations as presently enacted or hereafter amended. Amendments to the Rules and Regulations shall be made available by Club Management upon request.
(b) The Club is not an equity club. Membership is non-equity and non- participatory. Membership does not imply any right or privilege to participate in or to administer the Club business policies and does not create any vested or proprietary right of any kind in land, the Club, Club Management or the assets of Club Management or the Club. Membership does not create any presumption that the facilities or services that are now or hereafter available will continue to be available. The Owner and Club Management have the right to make any or all facilities unavailable for use for some period of time, due to construction of improvements, health and safety concerns, repairs, governmental order or other reasons in their sole discretion, and Members shall not receive any abatement of dues during such periods of full or partial unavailability.

Membership privileges should not be viewed as an investment and no person obtaining membership privileges should expect to derive any economic benefits from membership in the Club. These Rules and Regulations, Application for Membership, Club Guidelines and other membership documents have not been reviewed nor endorsed by any federal or state authority.
2 - EXHIBIT C

THE HUNTINGTON CLUB
Monday, March 16, 2026
Dear Membership,
We are reaching out to inform you that the Rules & Regulations, Membership Guidelines, and 2026 dues rate at The Huntington Club have been updated to reflect our current policies and offerings. These updates are designed to provide greater clarity, enhance the member experience, and ensure our policies align with the evolving needs of our community.

Shortly, you will receive an email from our signature collection platform, Sertifi, prompting you to review and electronically sign the updated 2026 Rules & Regulations and Club Guidelines. Your signature is required by April 30th, 2026.

The main highlights of these updates include:

Membership Privileges Update:
• Fitness Center Access for All Memberships - Added for those who previously did not have this benefit (Social and Pickleball)
Reminder:
• Golf locker rooms that are located in the main Clubhouse are designated for Golf Memberships only.
• Performance Center locker rooms are designated for Athletic and Pickleball Memberships. Social Memberships do not have access to any locker rooms.

Dependents + Minors:
• Dependent Age Increase: Eligibility for dependents extended from age 21 to age 25 • Minors under the age of fourteen (14) years entering the Club must be accompanied and supervised by an adult member at all times, except wher oroperly qualified and enrolled in any junior golf or tennis program, or otherwise approved by Manager in its sole discretion. (previously under age 10) • Certified dependents (18+) may host up to one (1) guest at any one time, with the Dues + Payments:
• Payment Method Requirement: New members must enroll in both ACH (automatic bank draft) and maintain a credit card on file
• Late Payment Policy:
• 1 day past due - Charging privileges suspended + $25 or 10% fee, whichever greater
• 20 days past due - Membership suspended and may be revoked Dress Code:
• Golf: Respectful golf attire is required on all golf course and practice facility areas. • Men's tank tops are not permitted. Swimwear of any kind is not allowed, and appropriate footwear must be worn at all times. Members are responsible for ensuring that their dependents and guests follow these guidelines. • Athletic: Tennis or Pickleball attire, shoes required • General: Members are encouraged to use good judgment with regard to their attire and grooming for each occasion at the Club. Respectful golf attire or business casual is expected in all Club areas unless otherwise noted. Attire and grooming shall not be offensive to other Members or their guests. Sports uniforms are not permitted in the Dining Room.
• Members are responsible for seeing that their guests conform to the dress code. 2026 Dues Rates Effective April 1st, 2026:

Dues
All-in (Golf) 1,995.00
C-Suite (Corporate) 1,995.00
Corporate (TM) 1,200.00
Beginner's Luck 1(18-39) 1,550.00
Beginner's Luck 2(40-42) 1,650.00
Beginner's Luck 3(43-44) 1,750.00
Beginner's Luck 35 (18-35) 1,550.00
Beginner's Luck 39 (18-39) 1,650.00
Corner Bet (Limited) 1,550.00
Athletic - Family 495.00
Athletic - Single Ş 425.00
Pickleball - Couple 375.00
Pickleball - Single 250.00
Poolside (Social Pool) 250.00
Dining Club (Social) $ 140.00
Heros $ 85.00
Tennis Add On $ 125.00
Please watch for the Sertifi email and plan to review and sign by the deadline of April 30th. If you do not receive the Sertifi email or if you have any questions about the process, please reach out, and we will assist you.

We appreciate your attention to these updates and your continued commitment to our Club.

Sincerely,
Joe Saikali
General Manager
-

THE HUNTINGTON CLUB
Saturday, February 7, 2026
Dear Members of The Huntington Club,
It has been two weeks since Golf Realty Fund and Johnathon Baily held a town hall meeting at the Huntington Club to discuss the New Performance Center Building, new pool, and bungalow project. Over the past two weeks, we have noticed some confusion regarding the relationship between the tenant of THC (Camaraderie Clubs) and the landlord/property owner (Golf Realty Fund). To clarify, Camaraderie Clubs pays rent to Golf Realty Fund through a triple net lease. This lease outlines obligations for capital expenditures for both the tenant and the property owner. So far, Camaraderie Clubs has met and exceeded its capital obligations. However, as the property owner mentioned in the planning commission meeting on January 27th, they have yet to fulfill their obligations. In the past six years since the lease was signed, Golf Realty Fund is still in the process of obtaining the necessary approvals for the project.

In addition, Camaraderie clubs would like to clarify the following misconceptions we have heard from the members.

1.Johnathon Bally represents Golf Reality Trust and is not affiliated with Camaraderie Clubs or involved in our operational decisions regarding THC. We want to make it very clear: WE DO NOT ENDORSE HIS STATEMENT MADE DURING THE TOWN HALL MEETING, where he said, "WE ARE COMFORTABLE AND CONFIDENT IN THE

ECONOMICS, AND YOU GUYS ARE FREE TO SPEAK WITH YOUR WALLETS AND SAY, 'HEY, NO, THIS CLUB ISN'T FOR US; WE WILL LEAVE." Jonathon Baily and Golf Realty Trust do not have the authority to make such statements to you, our valued customers, and members of THC. As made evident by the recent survey, we value member feedback and will use that feedback to frame our capital investment and operational opportunities. We deeply value your membership and thank you for choosing to be a part of our Club.

2. Currently, Camaraderie Clubs has no financial interest or contractual obligation to manage the bungalows and loft apartments proposed by Golf Realty Fund. Camaraderie Clubs has been steadfast in its efforts to compel the landlord to honor its obligations to construct a new swimming pool and upgrade the fitness facilities over the past 6 years.

The ownership of The Huntington Club is dedicated to the ongoing improvement of the Club and its facilities, aiming to preserve and enhance the experience enjoyed by its members.

We will always advocate for the interests of the Club and its members with conviction and respect. Please direct any questions about the project to Golf Realty Fund as they will be best equipped to answer questions about their project.

Sincerely,
Travis Brasher - Managing Partner, Camaraderie Clubs
Joe Saikali - General Manager
6501 Palm Ave. Huntinaton Beach. CA 92648 714.536.8866
From: Tom McDaniel
To: [email protected]
Subject: Request For Continuance- Huntington Club Project-Additional Information Date: Thursday, April 16, 2026 8:27:43 AM
You don't often get email from [email protected]. Learn why this is important Dear Mayor Casey McKeon:

I am supplementing my email of April 2, 2026 with the following information addressing Golf Realty Fund's performance on a project of similar characteristics to the Huntington Club Project.

Background
-Golf Realty Fund is an owner operator of the Newport Beach Tennis Club. -On Mach 20202 he Nepoi Both i por Beap tend to encompassing the demolition and removal of 17 of the Clubs 24 tennis courts, construction of a 27 room boutique hotel, the construction of 5 residential units (Ordinance No.2012-3, DA2008-001- Tennis Club Redevelopment)
- Subsequent to approval the project faced a number of challenges from members, other constituencies and the finance-ability of the project.
- On September 13, 2022, the project had not advanced and the Newport Beach City Council approved a 10 year extension to the development agreement (Development Agreement No.

DA2008-01)
I visited the Newport Beach Tennis Club last week and confirmed that there has been no movement toward developing the project. The fact that 14 years after the initial approval, Golf Realty Fund has not been able to advance the project warrants further review by the City Council. The Huntington Club Project is a significant financial undertaking. I have seen nothing in the record as to how Golf Realty Fund plans to finance, not only the bungalow/loft component of the project, but the other elements of the project - demolish and rebuild the tennis clubhouse and fitness facilities as well a the construction of a new swimming pool.

Adding financing assurances from Golf Realty Fund to the list of concerns warranting further review in my April 2 email supports the City Council granting a continuance of at least 60 days on this project. Additionally, given the contractual issues between the Golf Realty Fund and Camaraderie Clubs regarding this project, it feels like a situation where the project should be remanded back to both entities to develop a Club enhancement project that satisfies the interests of the land owner, the club operator and provides club members the standing to participate in the process.

Please let me know if you would like to discuss any of the points I have put forward in this email.

Respectfully,
Tom McDaniel
Member of the Huntington Club & Huntington Beach Resident From: Julie Ann Crandall
To: [email protected]
Subject: Agenda Item 26-280 Appeal of Planning Commission's Action on Conditional Use Permit Date: Thursday, April 16, 2026 9:43:18 AM
Attachments:
2026.04.10 Letter to HBCC (ETNAL).pdf
You don't often get email from [email protected]. Learn why this is important Dear Members of City Council,
The attached letter is submitted regarding Item 26-280 and is requested to be included in the City's public records, posted on the City's website, and announced at the City Council meeting.

Julie Crandall
Paralegal

EPG BLAW

ENENSTEIN PHAM GLASS

GUTENPLAN & BOLLING LLP

ENENSTEIN PHAM GLASS GUTENPLAN & BOLLING LLP
3200 Bristol St.

Costa Mesa, CA 92626
Phone: (657) 383-4511
Email: [email protected]
www.epggblaw.com
This email and any attachments contain information from the law firm of ENENSTEIN PHAM GLASS & RABBAT LLP, which may be confidential and/or privileged. The information is intended to be for the use of the individual or entity named on this email. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this email is prohibited. If you receive this emait in error, please notify us by reply emait immediately so that we can arrange for the retrieval of the original documents at no cost to you.

EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
Jesse K. Bolling
Managing Partner
[email protected]
April 10, 2026

SENT VIA EMAIL
Huntington Beach City Council
2000 Main Street
Huntington Beach, CA 92648
Email: City. [email protected]
Re: April 21, 2026 Hearing re The Huntington Club Remodel and Bungalows Dear Mayor and Members of the City Council,
I submit this letter in two capacities: (1) as pro bono counsel to appellants Cheryl Gates, Susan Ridgeway, and Douglas Scott Warren; and (2) as a current member of The Huntington Club with a direct interest in the continued availability and character of its facilities. I am an active golf and tennis member of the Club, and my family and I regularly participate in its athletic programs.

To summarize, Golf Realty Fund has a reported contractual obligation of approximately $10 million to $15 million to complete improvements at the Club. In structuring that arrangement, Golf Realty Fund retained control over the buildout, positioning itself to convert that obligation into an additional revenue stream through hotel-like lodging for "members and their guests." At the most recent hearing, Golf Realty Fund implied that it does not need that additional revenue to fund the renovations; it simply seeks an additional revenue stream from the property.

Standing alone, that economic choice would not necessarily be problematic. The problem is the particular plan Golf Realty Fund has chosen to pursue. As proposed, it introduces serious safety risks for Club members and their families. Members and their children move constantly through this area circulating among the courts, the pool, the fitness center, and food service locations often in unpredictable patterns that are inherent to an active recreational environment.

The proposed design forces those same children to cross an internal roadway serving both lodging-related traffic and everyday member vehicle traffic, as members will naturally use that area for convenient parking in the more than thirty new parking spaces located directly adjacent to the tennis and pickleball courts. The plan therefore concentrates vehicle traffic in the exact space where children and families are moving on foot.

This creates a direct and foreseeable conflict between vehicles and pedestrians. That risk is compounded by the nature of the proposed use, which will introduce guest traffic, ride-share Page |1
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
activity, deliveries, and the potential for alcohol-related driving into the same space where children are playing and moving freely. The foreseeable result is not minor or theoretical—it is the risk of serious injury in a setting that has always functioned as a protected recreational environment. Up until now, Golf Realty Fund has asked the Council to allow that plan to proceed without the benefit of a comprehensive safety study, ostensibly because its contractual deadline to complete these improvements will expire in early May 2026.

That private timing pressure is no substitute for a complete and reliable public record, particularly where the safety of Huntington Beach families who use what many regard as the City's crown jewel is at stake. More time is needed to determine whether this design can be made safe. Without that work, approval would expose Golf Realty Fund, its tenant, and the City of Huntington Beach to substantial liability if a member—or worse, a child—is injured.

In good faith discussions between the Appellants and Golf Realty Fund, the concept of a comprehensive safety study has been raised. Golf Realty Fund appears amenable to conducting such a study, but there remains a critical procedural issue. It is my understanding that Golf Realty Fund prefers that the safety study be imposed along with approval of the plan. We respectfully submit that this approach is improper under the circumstances and should be rejected.

The Council should instead retain jurisdiction over this matter and require completion of the safety study before any approval is granted. The Appellants' ability to advocate on behalf of the Club's membership is tied to this appeal. As a non-equity club, members do not control the property; their voice is exercised through this process and through the Council's oversight. If the project is approved subject to later study, that voice is effectively extinguished, and future decisions regarding safety, design, and implementation will be left to private entities whose interests may not align with those of the citizens most directly affected.

Moreover, the Council cannot make the required findings in support of approval without first establishing, based on substantial evidence, that the project can be operated safely. Nor may the Council defer that determination to a future study, as doing so would leave a critical component of the approval unsupported by the administrative record at the time of decision. Where material safety concerns remain unresolved, approval would be premature because the record would not contain substantial evidence sufficient to support the findings required for a Conditional Use Permit.

Based on the foregoing, we respectfully request that the Council continue this hearing for at least 60 days so that the proposed plan can be more fully evaluated, particularly in light of the serious safety concerns created by placing a roadway with significant parking capacity in the middle of the Club's tennis and pickleball facilities. The Council should direct Golf Realty Fund to conduct a comprehensive safety study by an independent consultant approved by the Council Page |2
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
and Appellants. Once completed, that study should be circulated for review and comment, and only then should the Council determine whether the project, as proposed, is safe enough for approval.

1. The factual background demonstrates no evaluation of safety concerns amid contractual time pressure and a breakdown between owner and operator.

The factual statements set forth in this letter are based on a combination of publicly available materials and information obtained through discussions with individuals represented to have knowledge of the operations, agreements, and history of the Club. Except where expressly supported by cited documents or witnessed by me or my clients, these statements are provided on an informational basis only. I therefore do not present these statements as adjudicated fact, but rather as contextual background to assist the Council in understanding the circumstances surrounding the proposed project.
• The entity operating the Club, Camaraderie Clubs, is led by Travis Brasher, who previously served as a golf professional at the Club when it operated under its former name, Seacliff Country Club. Mr. Brasher founded the Travis Mathew apparel brand, which was later sold, and has since returned, now as the tenant overseeing operations at the Club, rebranding it as The Huntington Club.
• Prior to the COVID-19 pandemic, Camaraderie Clubs entered into a long-term lease agreement-reported to be approximately 30 years in duration —with the property owner, Golf Realty Fund, under which it operates the Club.
• As part of that long-term lease arrangement, both Camaraderie Clubs and Golf Realty Fund are understood to have contemplated and committed to significant capital improvements to the Club's infrastructure in recognition of the age and condition of the existing facilities.
• Camaraderie Clubs has invested substantial capital into the Club, reported to be in the range of approximately $8 million to $10 million.
• Golf Realty Fund, as property owner, is likewise understood to have committed to a significant capital contribution toward redevelopment of the property, reported to be in the range of approximately $10 million to $15 million, none of which has yet been deployed. The lease or related agreements reportedly include a deadline for completion of those improvements in early May 2026. Based on that reported deadline, Golf Realty Fund appears to be under substantial time pressure to obtain approvals and move the project forward.

Page |3
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
• The proposed project includes demolition and replacement of fitness and swimming facilities, as well as the addition of new structures, including bungalow units, loft-style accommodations, and related site improvements. More specifically, the project includes (i) conversion or construction of second-floor space within a proposed fitness facility into loft-style accommodations and (ii) construction of detached bungalow-style units on the property. The project would also eliminate three lit tennis courts used for nighttime play and divide the tennis and pickleball facilities with a large internal road serving the bungalow component, including more than thirty parking spaces located within that internal circulation area.
• Golf Realty Fund also submitted an alternative concept involving the addition of a third story to the fitness facility without including the bungalow lodging component.

According to information provided by a City employee, that submission was marked "Incomplete" because it did not contain sufficient detail to determine whether it complied with applicable height limitations. Even if that proposal ultimately raised height- compliance issues, the City retains discretion to evaluate whether such limitations could be addressed or modified through appropriate planning mechanisms. A plan without an internal roadway through the recreational core, therefore, is theoretically possible. • At a presentation by Golf Realty Fund to Club members on Friday, January 23, 2026, at which Camaraderie Clubs was absent, a representative of Golf Realty Fund told members that revenue from the bungalow component was necessary to fund reconstruction of the pool and fitness improvements. Golf Realty Fund has also provided the City with aggressive revenue projections for these rental units, particularly in light of the competition from multiple high-end beachfront hotels in the area. In subsequent representations to the City Council, however, Golf Realty Fund indicated that it has sufficient financial resources to build and maintain the proposed improvements even if those revenue projections were not realized. Those two positions are difficult to reconcile and bear directly on whether the bungalow component is truly necessary or instead an added revenue stream being pursued despite the costs it imposes. • I received a written communication distributed by Camaraderie Clubs to Club members dated February 7, 2026 (Exhibit A). In that communication, Camaraderie Clubs expressly states that it "has no financial interest or contractual obligation to manage the bungalows and loft apartments proposed by Golf Realty Fund." • The same communication also alludes to the statements made by Golf Realty Fund during its town hall meeting with Club members concerning the proposed project. At that meeting, Golf Realty Fund stated that members were "free to speak with [their] wallets" in response to the proposed changes.

Page |4
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
• The February 7, 2026 communication further clarifies that Camaraderie Clubs does not endorse that statement and distinguishes its operational role from that of the property owner with respect to the proposed development.
• It is anticipated that, if the contemplated redevelopment obligations are not satisfied within the early May 2026 timeframe, a dispute between landlord and tenant may arise, otentially resulting in litigation. his
he entaily shu tine landior ahi penant, hich, fruel no prospective ext regarding. • In negotiations among the parties, there has been a general refusal to have all sides sit down together to resolve their issues. Golf Realty Fund has asserted that Camaraderie Clubs contractually agreed to limit or waive its ability to object to certain aspects of the redevelopment plan, including the bungalow component. I have learned nothing that contradicts that assertion. At the town hall meeting, Golf Realty Fund flashed a specific portion of the lease when making that point to members, but I was not provided with a sufficient opportunity to review that provision in full. Further, Appellants' suggestion that a thorough dialogue among all the affected parties would be the best course toward resolution has been dismissed.

2. Golf Realty Fund proposes an unsafe conflict zone within the Club's recreational core that introduces high-traffic areas into the center of club facilities visited daily by families.

The plans submitted to the City do not merely remodel a private club. They change the way this entire recreational area would function on a daily basis. Instead of keeping vehicular circulation at the perimeter, the proposed design pulls vehicle movement into the same part of the site where members and their families naturally move back and forth between the tennis courts, the pickleball courts, the bungalow area, the food truck location, and the pool and fitness complex.

That matters because this part of the Club is not a static space. It is one of the most active family areas on the property. During a recent tennis tournament, I watched my own three children-ages 8, 6, and 3-consistently move among the courts, the fitness center, the pool, and the food truck area. Children were running back and forth for smoothies, food, and breaks between matches. Parents and members were doing the same thing. That pattern of movement is not unusual; it is exactly how this area of the Club is actually used.

The City would never design one of its own recreational spaces this way. In publicly used Huntington Beach recreation areas, vehicular circulation is kept at the edges, while the interior is reserved for fields, courts, trails, playgrounds, and gathering space. That is not accidental. It

Page 15 ends

EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
reflects a basic safety judgment: where children and families are moving freely, cars should not be routed through the middle of the activity zone.

Huntington
Contral Park Library Hontington Beach CONTEN PARK.

Parking Central Park/Secret Garden
Vehicular Access
& Parking Parking
HBSC Recreatioras
Parking

CENTRAL PARK
• BASEBALL/SOFTBALL FIELDS West
Talten doe

TURF FIELOS CENTRAL PARK
Gold Secret Carder
ARENA FIELD Recreation

GRASS FIELDS
tATTING CAGES

SNACK BAR / BATHROOMS

PLAY GROUND
CARDEN

HESC OFFICE
Vehicular Access
& Parking
Huntington Beach park design consistently places vehicular circulation at the perimeter, while interior space is reserved for active recreation. This separation reflects a fundamental safety principle: where children and families are moving freely, vehicles are kept out of the activity zone.

The project plans submitted here do the opposite. They create a conflict zone where ordinary member movement intersects with internal vehicular circulation serving both lodging- related traffic and everyday member parking activity. The internal road does not simply pass near the courts it rums directly through the recreational area and includes more than thirty parking spaces that will attract regular member use. The issue is not whether a careful adult can look both ways and cross. The issue is whether an active tennis and pickleball environment- used by children, teens, and families should be redesigned to require exactly that kind of vigilance in the first place.

The risk is particularly acute at the pickleball courts. Under the current layout, the pickleball courts sit adjacent to one another, and weekly ladder events regularly utilize all eight pickleball couts (four in each court bank). During those events, players continuously rotate between the two courts based on wins and losses. Under the proposed plan, the internal road would run between the two courts that are currently adjacent, meaning that players participating

Page 16 ends

EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
in these events would be required to cross the roadway repeatedly throughout play. That repeated crossing pattern-by adults focused on competition and movement, not vehicle traffic-creates an additional, foreseeable point of conflict between pedestrians and vehicles.

The submitted plan itself shows that the natural path of travel from the heart of the tennis and pickleball courts to the food truck and pool cuts directly across the internal drive and circulation area tied to the bungalow component. In the real world, children do not stop at neat crossing points and wait for vehicles. They run where they have always run. Members move where they have always moved. The danger is therefore not speculative. It is foreseeable on the face of the design.

FOOD TRJCK
(NCT A PART)
LAKE

NAYACAVA
RANCHC

VALENCI

CASA NEW FITNESS /

PALMERO LOFT BUILDING
ole Conflict Zone

ESTIVIS ACKLEBALL 'PARKING STALLS
Proposed site plan showing the internal roadway and parking area ("Conflict Zone") bisecting the Chib's primary tennis and pickleball facilities, where regular pedestrian movement— particularly by children and players rotating between courts—intersects directly with vehicular traffic.

The economic justification for introducing this risk has also shifted. At Golf Realty Fund's presentation on Friday, January 23, 2026, members were told that bungalow revenue was necessary to fund the pool and fitness improvements. Later, Golf Realty Fund represented to the Council that it has sufficient finds to build and maintain those improvements even if the Page |7
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Jesse K. Bolling
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[email protected]
aggressive revenue projections tied to the bungalow and loft component do not materialize. By Golf Realty Fund's own later account, it does not need this additional revenue stream to construct and maintain the facilities. If that is true, then the question for the Council is not whether more revenue would be desirable. The question is whether this added safety risk is worth the cost. It is not.

The concern becomes even more serious because Camaraderie Clubs has already stated that it will not manage the lodging facilities. That means a third party will do so. A third-party lodging operation brings with it its own traffic patterns: guest arrivals and departures, deliveries, rideshare traffic, off-site food runs, and trips for alcohol and other services that are not necessarily integrated with Club operations, including when dining facilities are closed eg Mondays). These risks are compounded by the fact that members themselves will use the same internal circulation area for parking and access to the tennis and pickleball facilities, further increasing vehicle volume in the same environment where children and members are walking and running between athletic and pool facilities. And in each and every one of these scenarios, the Council should assume alcohol will be consumed.

The timing of this application only heightens the concern. Golf Realty Fund appears to be trying to push this project through because it is running out of time under its own contractual obligations, which may expose it to financial consequences. But a private deadline is not a legal basis to shortcut public safety review. The fact that the owner may feel urgency is a reason for the Council to slow down, not a reason to approve an incomplete and under-analyzed design.

A comprehensive, independent safety study must be completed. At a minimum, that study should evaluate pedestrian circulation, child movement patterns, vehicle conflict points, visibility and sightlines, construction-phase hazards, and the operational risks associated with the bungalow and loft component. Without that work, approval would be premature.

The City would never route an internal lodging-access road through one of its own active recreational spaces without rigorous safety analysis. It should not permit that result here simply because the project is privately proposed. The stakes are high. If a child is struck by a vehicle in a conflict zone the plans themselves create, the resulting liability exposure would be extraordinary. As a trial lawyer, I view the owner, the operator, and the City as the approving authority as obvious defendants in that scenario, and the exposure could exceed $100 million in a catastrophic injury case. That outcome is not worth a minor, unnecessary revenue stream. And it can only even be argued to be worth the risk if a comprehensive safety study is done first.

Page |8
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3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]

3. The proposed plan will have additional adverse effects on the Club's tennis program and daily operations, and if the back courts are not lit, tennis will wither at the Club.

Beyond the serious safety concerns addressed above, the proposed project would also materially impair the Club's tennis and pickleball program and its broader day-to-day operations.

First, the project threatens the viability of nighttime tennis at the Club. As the proposed plan makes clear, the six back courts at the far western end of the property become critically important if three existing lit courts are removed. If those back courts cannot be lit, the Club will effectively go from seven lit courts to only four. That reduction would fundamentally alter the Club's evening tennis program and, in practical terms, could cause tennis at the Club to wither.

Most notably, it would jeopardize some of the Club's some of the most popular organized evening events, including Men's Night and Ladies' Night, where large groups of players participate in round-robin doubles. The junior program, which goes until 7:00 p.m. PST, would also be jeopardized. For many members, those events are the core of the Club's tennis culture and one of the principal reasons they remain active members.

Any loss of courts must be tethered to the back courts being capable of lawful nighttime use. At present, however, the problem is that the prior conditional use permit associated with those courts reportedly does not allow lighting because of their proximity to neighboring homes. (Exhibit B.) Golf Realty Fund appears to be exploring technological solutions to reduce light spill, but the practical reality remains the same: nearby homeowners would be looking at illuminated courts on a nightly basis. That issue should not be ignored or deferred. It should be confronted directly now because, without a realistic and enforceable solution, the project substantially diminishes the Club's ability to function as a tennis facility.

Second, the elimination of three tennis courts will materially affect daytime operations as well. The Club's tennis program is not limited to casual drop-in use. It supports numerous teams, private lessons, daily junior programs, clinics, and organized member play throughout the week.

While no club can honestly claim that every court is full at every hour of every day, that is not the standard. The relevant question is whether the reduction in court inventory will impair operations during the hours that matter most. It plainly will. Peak usage periods will be squeezed.

Team practices and matches will be harder to schedule. Private instruction and junior programming will face greater competition for court time. The junior program in particular is a meaningful asset to the Club, run by a strong professional staff and designed to develop high- level young players. Orange County has already produced elite junior talent, and there is no reason that program should be diminished by a redevelopment plan that prioritizes lodging over courts.

Page | 9
EPG-BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
Third, Golf Realty Fund has represented that the courts will remain open during construction. On the present record, however, it is difficult to see how that can occur in a safe and functional way. The project already proposes to remove courts, insert internal circulation, and carry out major construction immediately adjacent to active recreational use. If the road and bungalow components were eliminated, there would at least be a greater possibility of preserving meaningful tennis operations during construction. But under the current design, the notion that children can safely attend junior camp, that coaches can conduct lessons, and that teams can play normally while roads are being paved and heavy construction is underway has not been substantiated. The Council should not simply assume that normal Club operations can continue through a prolonged and invasive construction process without a detailed, credible operational plan.

Taken together, these impacts are not secondary or incidental. They go to the heart of what The Huntington Club is and how it functions. This is not merely a question of replacing old facilities with new ones. It is a question of whether the Club's tennis community, junior development program, and nighttime member culture will survive the project in anything like their present form. On the current record, there is substantial reason to doubt that they will.

4. The City's Zoning Code does not allow people to sleep overnight in recreational space.

The Council's discretion under the Conditional Use Permit process is not unlimited. A CUP is not a blank check to authorize any use the City wishes to allow based on generalized notions of "good cause." Under the Huntington Beach Zoning Code, a CUP may be granted only where the Council can make the required findings, including that the proposed use is consistent with the General Plan and all applicable requirements of the Municipal Code. Most importantly, the Council must be able to find that the proposed use will comply with the provisions of the base district and other applicable provisions of the Zoning Code. If those findings cannot be made, denial is required.

That requirement has procedural consequences here. The Council must be able to support each required finding with substantial evidence in the administrative record at the time of approval. Where material issues such as whether the project can be operated safely-remain unresolved, the Council cannot defer that determination to a future study. Absent substantial evidence demonstrating that the project can be operated safely, the Council cannot make the findings necessary to approve the Conditional Use Permit.

That is the core issue here. The subject property is in the OS-PR district. Huntington Beach's zoning regulations provide that uses not listed in a district's land use controls are prohibited. In OS-PR, "Park & Recreation Facilities" may be allowed with a CUP, and certain Page | 10
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Jesse K. Bolling
Managing Partner
[email protected]
ancillary uses may be permitted in limited form, but the Code does not separately list general lodging or visitor accommodations as an authorized OS-PR use. From a legal perspective, the threshold question, therefore, is not whether the bungalow and loft component may be desirable or financially beneficial. The threshold question is whether that lodging component is actually an authorized use in OS-PR at all.

The City's own use-classification scheme sharpens that issue. Huntington Beach distinguishes between "Clubs and Lodges," on the one hand, and "Visitor Accommodations," on the other. "Clubs and Lodges" are recreational or social facilities primarily for members or guests. "Visitor Accommodations" are separately defined lodging uses, including hotels, motels, and similar short-term occupancy arrangements. The Code thus does not treat private club use and overnight lodging use as interchangeable. They are different use categories. That distinction matters here because the proposed bungalow and loft component appears, in substance, to function as a lodging use rather than merely as part of the Club's traditional recreational operations.

Accordingly, if the City's position is that the bungalow and loft component constitutes a lodging or visitor-accommodation use, then the Council should identify precisely where that use is permitted or conditionally permitted in OS-PR. If the City's position is instead that the lodging component is merely accessory or incidental to the recreational use, then the Council should explain how overnight accommodations are truly subordinate to, and customarily associated with, the principal recreational use of the site, rather than a separate revenue-generating use added to the property. Either way, the Council must still make the finding that the project complies with the base district. A CUP does not eliminate that requirement.

There is a further problem. The Huntington Beach Code contemplates that, if a proposed use cannot be clearly classified within an existing use category, the answer is not simply to approve it by CUP anyway. Rather, the Code assigns use-classification decisions to the Director and, where no existing classification clearly applies, the proper remedy is a change to the zoning text. In other words, the City may not use the CUP process to create a new hybrid use that the Code does not presently authorize.

For that reason, the Council should require a clear answer to a simple question before acting: what, exactly, is the legal use classification for the proposed bungalows and lofts, and where is that use authorized in OS-PR? And critically, the Council must also be able to determine based on substantial evidence—-that the project, as designed, can be operated safely before any approval is granted. Unless and until those questions are answered in a manner that allows the Council to make the required findings, approval of the lodging component would be legally vulnerable and premature.

Page |11
7 EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
Costa Mesa, CA 92626
ENENSTEIN PHAM GLASS (714) 292-0262
GUTENPLAN & BOLLING LLP epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]

5. There is no justifiable basis to move forward with the proposed plan unless and until, at a minimum, a comprehensive safety study is conducted.

For all of these reasons, there is no justifiable basis for the Council to move forward with the proposed plan unless and until a comprehensive safety study is completed. Without that study, the Council lacks substantial evidence necessary to determine that the project can be operated safely and therefore cannot make the findings required for approval of the Conditional Use Permit.

We therefore respectfully request that the Council continue this matter for at least 60 days so that the proposed project can be evaluated on a more complete and reliable record.

Respectfully Submitted,

ENENSTEIN PHAM GLASS GUTENPLAN & BOLLING, LLP
By:

Jesse K. Bolling, Esq.

Cc:

Casey McKeon, Mayor: [email protected]
: Butch Twining, Mayor Pro Tem: Butch. Twining @surfeity-b.org Gracey Van Der Mark, Councilmember: Gracey. [email protected] • Pat Burns, Councilmember: [email protected]
• Don Kennedy, Councilmember: [email protected] • Chad Williams, Councilmember; Chad. [email protected] • Andrew Gruel, Councilmember: [email protected] Page | 12

EXHIBIT A
Julie Ann Crandall
From: The Huntington Club <[email protected]>
Sent: Saturday, February 7, 2026 8:11 AM
To: Jesse Bolling
Subject: Camaraderie Clubs Clarification ~ Townhall Meeting Saturday, February 7, 2026
Dear Members of The Huntington Club,
It has been two weeks since Golf Realty Fund and Johnathon Baily held a town hall meeting at the Huntington Club to discuss the New Performance Center Building, new pool, and bungalow project. Over the past two weeks, we have noticed some confusion regarding the relationship between the tenant of THC (Camaraderie Clubs) and the landlord/property owner (Golf Realty Fund). To clarify, Camaraderie Clubs pays rent to Golf Realty Fund through a triple net lease. This lease outlines obligations for capital expenditures for both the tenant and the property owner. So far, Camaraderie Clubs has met and exceeded its capital obligations. However, as the property owner mentioned in the planning commission meeting on January 27th, they have yet to fulfill their obligations. In the past six years since the lease was signed, Golf Realty Fund is still in the process of obtaining the necessary approvals for the project.

In addition, Camaraderie clubs would like to clarify the following misconceptions we have heard from the members.

1.Johnathon Baily represents Golf Reality Trust and is not affiliated with Camaraderie Clubs or involved in our operational decisions regarding THC. We want to make it very clear: WE DO NOT ENDORSE HIS STATEMENT MADE DURING THE TOWN HALL MEETING, where he said, "WE ARE COMFORTABLE AND CONFIDENT IN THE

ECONOMICS, AND YOU GUYS ARE FREE TO SPEAK WITH YOUR WALLETS AND SAY, 'HEY, NO, THIS CLUB ISN'T FOR US; WE WILL LEAVE. Jonathon Baily and Golf Realty Trust do not have the authority to make such statements to you, our valued customers, and members of THC. As made evident by the recent survey, we value member feedback and will use that feedback to frame our capital investment and operational opportunities. We deeply value your membership and thank you for choosing to be a part of our Club.

2. Currently, Camaraderie Clubs has no financial interest or contractual obligation to manage the bungalows and loft apartments proposed by Golf Realty Fund. Camaraderie Clubs has been steadfast in its efforts to compel the landlord to honor its obligations to construct a new swimming pool and upgrade the fitness facilities over the past 6 years.

The ownership of The Huntington Club is dedicated to the ongoing improvement of the Club and its facilities, aiming to preserve and enhance the experience enjoyed by its members.

We will always advocate for the interests of the Club and its members with conviction and respect. Please direct any questions about the project to Golf Realty Fund as they will be best equipped to answer questions about their project.

Sincerely,
Travis Brasher - Managing Partner, Camaraderie Clubs
Joe Saikali - General Manager
6501 Palm Ave. Huntington Beach, CA 92648 714.536.8866
This message was sent to Jesse Bolling <[email protected]> by Huntington Club Click here to unsubscribe from further communications
2 Huntington Beach Planning Commission
P.O. BOX 190 • CALIFORNIA 92648
August 6, 1985
Huntington Beach Company
2110 Main Street
Huntington Beach, CA 92648
SUBJECT: CONDITIONAL USE PERMIT NO. 85-25/COASTAL DEVELOPMENT PERMIT NO. 85-19/NEGATIVE DECLARATION NO. 185-26
REQUEST: To permit construction
of 6 tennis courts.

LOCATION: East side of palm Ave.
approximately 300 ft.
south of Cherryhill Ave:

FINDINGS FOR APPROVAL CONDITIONAL USE PERMIT NO. 85-25:

1. The proposed six tennis courts are compatible with surrounding land uses and in conformance with the General Plan policies because the facility will become an integral part of the existing Seacliff Country Club.

2. The proposed cennis courts will not be detrimental to the generrl health, welfare, safety and convenience of persons residing or working in the neighborhood because the, facility will lave hours of operation limited to the daytime.

3. The location, site layout, and design of the proposed development does properly adapt the structure to streets, driveways and other uses in a harmonious manner.

FINDINGS FOR APPROVAL COASTAL DEVELOPMENT PERMIT NO. 85-2:

1. for 6 tennis courts is consistent with the City
Coastal Zone suffix as well as other provisions of the
Huntington Beach Ordinance Code applicable to the property; and the plans, policies, reguirements and standards
of the City's Coastal Land Use Plan.

2. The proposed development can be provided with infrastructure in a manner that is consistent with the Coastal Land Use Plan.

3. The proposed development conforms with the public access and public recreation policies of Chapter 3 of the California Coastal Act.

CONDITIONS OF APPROVAL CONDITIONAL USE PERMIT NO. 85-25:

1. The site plan dated May 22, 1985 shall be the approved layout.

2. Prior to issuance of building permits, the applicant shall submit a landscape and irrigation plan to the Department of Development Services and Department of Public Works for review and approval.

3. The tennis courts hours of operation shall be limited to daytime hours. No artificial lighting shall be permitted.

4. A copy of the tennis club membership/entry requirements shall be submitted to the Department of Development Services to assure the membership/use is limited to country club members.

5. All building spoils, such a unused lumber, wire, pipe and surplus or unusable materials, shall be disposed of at an off-site facility equipped to handle them.

I hereby certify that Conditional Use Permit No. 85-25, Coastal Development Permit No. 85-19 and Negative Declaration No. 85-26 was approved by the Planning Commission of the City of Huntington Beach on August 5, 1985 by the foregoing citations and conditions.

Sincerely,
Iloena Wilt/fir
James W. Palin
Secretary
Planning commission
JWP: 1p
(3037đ(3)
From: shari engel
To: [email protected]
Subject: FORMAL FILING: Supplemental Communication for Items 26-324 and 27 (Meeting Date: April 21, 2026) Date: Thursday, April 16, 2026 10:57:02 AM
Attachments: <W1.png
KW2.png
TW1.png
You don't often get email from [email protected]. Learn why this is important Dear City Clerk, City Attorney, and City Manager,
I am writing to formally place on the public record for the April 21, 2026, City Council meeting my objection to the ongoing procurement process involving Wolffhaus (File 26-324 / RFP #140902).

The administrative record for this project contains a pattern of "last-minute" justifications that suggest a coordinated effort to bypass city and federal guardrails to ensure a predetermined outcome for a specific vendor.

1. Misuse of Federal Office and Illegal Endorsement (Item 26-324) The city's "technical justification" for this vendor relies on a letter from Kristin Walker, who explicitly identifies himself as the Reliability Technology Branch Chief at the Aviation and Missile Command at Redstone Arsenal, Alabama. By utilizing his Department of Defense (DoD) title and 25 years of federal experience to endorse a private enterprise, Mr. Walker has committed a prima facie violation of 5 C.F.R. § 2635.702. The city cannot legally accept a bid predicated on a violation of federal ethics laws.

2. Coordinated Administrative Irregularities and Cleanup Public record disclosures indicate a frantic effort to bypass city business requirements. The Wolffhaus business license application was received on April 6, 2026—the same afternoon the Walker letter arrived-yet was backdated to February 1st. Furthermore, the use of an automotive tire shop address (17011 Beach Blvd) as the headquarters for a $720,000 media audit should have triggered an immediate due diligence stop. Instead, it appears the city is willing to do whatever it takes to justify hiring a shell entity.

3. Objection to Political Interference via Ad-hoc Committee (Item 27) I formally object to the proposal in Item 27 to create a City Council Ad-hoc Committee to review RFP proposals. Given the documented federal ethics violations and licensing irregularities, the vetting process must remain with non-partisan, professional City Staff. Allowing a political committee to "hand-pick" a vendor whose entry into this process is already ethically compromised would constitute a gross failure of the city's procurement integrity.

Formal Demand: I demand that the Kristin Walker letter be struck from the record and that any vendor utilizing illegal federal endorsements or irregular licensing be disqualified. If the city persists in utilizing these compromised documents to justify a $720,000 expenditure, I will proceed with a formal referral to the Department of Defense Office of Inspector General (OIG) and the Command Counsel at Redstone Arsenal.

Respectfully,
Shari Engel, Resident, Huntington Beach
From: Robin Brunner
To: [email protected]
Subject: Fwd: THC BUNGALOW PROJECT
Saturday, April 18, 2026 3:03:50 PM
Date:

Attachments: 2026.04.10 Letter to HBCC (FINAL),pdf
You don't often get email from [email protected]. Learn why this is important Begin forwarded message:

From: Robin Brunner <[email protected]>
Date: April 18, 2026 at 2:00:16 PM PDT
To: City. [email protected]
Subjeet: THC BUNGALOW PROJECT
Dear City Council,
I'm a longtime member of the Huntington Club (23 years) and a neighbor that owns a house behind the back tennis courts for 28 years. I share the beliefs and concerns in the attached letter.

We walk over to enjoy the club and are alarmed at the possible future placement lecision for children and adults alike. There must be another way to make thi of a road dividing the club in half. I can't imagine who thought that was a safe safer for the community and keep the relaxed club flow that is there now.

I'm also concerned about the talk of lighting the back courts. We paid millions of dollars for a home with the assurance these courts could never be lit. We enjoy countless evenings outside relaxing in peace and fear there's a possibility of that being taken from us. I understand there is new technology of how courts can be lit with minimal light pollution. However, it's not only the lights that become an issue with playing after dark. Loud noises including screaming, swearing and loud music is a regular occurrence during daytime play and during night time play on current lit courts. It's easy to witness by stopping by the club any given evening to hear. It's one thing when it's closer to the club, but when our home is 6 feet from the courts it becomes very disruptive.

One last concern regarding the bungalows. We've attended all the council meetings and heard all the talk of who is allowed to use these bungalows... I have not heard if weddings booked at the club will be able to use them. Weddings are a big money maker for the club and could see them selling the bungalows as a package for the bride to get ready and wedding party to stay and/or have parties.

Has this been discussed? What would stop the club from charging an extra amount to book weddings (i.e. bungalow package) to make these people temporary members as a loop hole to allow them access to the bungalows. As a neighbor living close to these, I'm very concerned over the noise and security of our neighborhood as well.

Thanks for taking the time to read my concerns and thank you for keeping our city a wonderful and safe place to live.

Robin Brunner
6312 Turnberry Cir HB
714.756.0943
EPG-BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partne
[email protected]
April 10, 2026

SENT VIA EMAIL
Huntington Beach City Council
2000 Main Street
Huntington Beach, CA 92648
Email: [email protected]
Re: April 21, 2026 Hearing re The Huntington Club Remodel and Bungalows Dear Mayor and Members of the City Council,
I submit this letter in two capacities: (1) as pro bono counsel to appellants Cheryl Gates, Susan Ridgeway, and Douglas Scott Warren; and (2) as a current member of The Huntington Club with a direct interest in the continued availability and character of its facilities. I am an active golf and tennis member of the Club, and my family and I regularly participate in its athletic programs.

To summarize, Golf Realty Fund has a reported contractual obligation of approximately $10 million to $15 million to complete improvements at the Club. In structuring that arrangement, Golf Realty Fund retained control over the buildout, positioning itself to convert that obligation into an additional revenue stream through hotel-like lodging for "members and their guests." At the most recent hearing, Golf Realty Fund implied that it does not need that additional revenue to fund the renovations; it simply seeks an additional revenue stream from the property.

Standing alone, that economic choice would not necessarily be problematic. The problem is the particular plan Golf Realty Fund has chosen to pursue. As proposed, it introduces serious safety risks for Club members and their families. Members and their children move constantly through this area circulating among the courts, the pool, the fitness center, and food service locations often in unpredictable patterns that are inherent to an active recreational environment.

The proposed design forces those same children to cross an internal roadway serving both lodging-related traffic and everyday member vehicle traffic, as members will naturally use that area for convenient parking in the more than thirty new parking spaces located directly adjacent to the tennis and pickleball courts. The plan therefore concentrates vehicle traffic in the exact space where children and families are moving on foot.

This creates a direct and foreseeable conflict between vehicles and pedestrians. That risk is compounded by the nature of the proposed use, which will introduce guest traffic, ride-share Page |1
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Costa Mesa, CA 92626
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GUTENPLAN & BOLLING LLP
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
activity, deliveries, and the potential for alcohol-related driving into the same space where children are playing and moving freely. The foreseeable result is not minor or theoretical—it is the risk of serious injury in a setting that has always functioned as a protected recreational environment. Up until now, Golf Realty Fund has asked the Council to allow that plan to proceed without the benefit of a comprehensive safety study, ostensibly because its contractual deadline to complete these improvements will expire in early May 2026.

That private timing pressure is no substitute for a complete and reliable public record, particularly where the safety of Huntington Beach families who use what many regard as the City's crown jewel is at stake. More time is needed to determine whether this design can be made safe. Without that work, approval would expose Golf Realty Fund, its tenant, and the City of Huntington Beach to substantial liability if a member—or worse, a childis injured.

In good faith discussions between the Appellants and Golf Realty Fund, the concept of a comprehensive safety study has been raised. Golf Realty Fund appears amenable to conducting such a study, but there remains a critical procedural issue. It is my understanding that Golf Realty Fund prefers that the safety study be imposed along with approval of the plan. We respectfully submit that this approach is improper under the circumstances and should be rejected.

The Council should instead retain jurisdiction over this matter and require completion of the safety study before any approval is granted. The Appellants' ability to advocate on behalf of the Club's membership is tied to this appeal. As a non-equity club, members do not control the property; their voice is exercised through this process and through the Council's oversight. If the project is approved subject to later study, that voice is effectively extinguished, and future decisions regarding safety, design, and implementation will be left to private entities whose interests may not align with those of the citizens most directly affected.

Moreover, the Council cannot make the required findings in support of approval without first establishing, based on substantial evidence, that the project can be operated safely. Nor may the Council defer that determination to a future study, as doing so would leave a critical component of the approval unsupported by the administrative record at the time of decision. Where material safety concerns remain unresolved, approval would be premature because the record would not contain substantial evidence sufficient to support the findings required for a Conditional Use Permit.

Based on the foregoing, we respectfully request that the Council continue this hearing for at least 60 days so that the proposed plan can be more fully evaluated, particularly in light of the serious safety concerns created by placing a roadway with significant parking capacity in the middle of the Club's tennis and pickleball facilities. The Council should direct Golf Realty Fund to conduct a comprehensive safety study by an independent consultant approved by the Council Page |2
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
and Appellants. Once completed, that study should be circulated for review and comment, and only then should the Council determine whether the project, as proposed, is safe enough for approval.

1. The factual background demonstrates no evaluation of safety concerns amid contractual time pressure and a breakdown between owner and operator.

The factual statements set forth in this letter are based on a combination of publicly available materials and information obtained through discussions with individuals represented to have knowledge of the operations, agreements, and history of the Club. Except where expressly supported by cited documents or witnessed by me or my clients, these statements are provided on an informational basis only. I therefore do not present these statements as adjudicated fact, but rather as contextual background to assist the Council in understanding the circumstances surrounding the proposed project.
• The entity operating the Club, Camaraderie Clubs, is led by Travis Brasher, who previously served as a golf professional at the Club when it operated under its former name, Seacliff Country Club. Mr. Brasher founded the Travis Mathew apparel brand, which was later sold, and has since returned, now as the tenant overseeing operations at the Club, rebranding it as The Huntington Club.
• Prior to the COVID-19 pandemic, Camaraderie Clubs entered into a long-term lease agreement-reported to be approximately 30 years in duration with the property owner, Golf Realty Fund, under which it operates the Club.
• As part of that long-term lease arrangement, both Camaraderie Clubs and Golf Realty Fund are understood to have contemplated and committed to significant capital improvements to the Club's infrastructure in recognition of the age and condition of the existing facilities.
• Camaraderie Clubs has invested substantial capital into the Club, reported to be in the range of approximately $8 million to $10 million.
• Golf Realty Fund, as property owner, is likewise understood to have committed to a significant capital contribution toward redevelopment of the property, reported to be in the range of approximately $10 million to $15 million, none of which has yet been deployed. The lease or related agreements reportedly include a deadline for completion of those improvements in early May 2026. Based on that reported deadline, Golf Realty Fund appears to be under substantial time pressure to obtain approvals and move the project forward.

Page | 3
EPG BLAW Orange County Office
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GUTENPLAN & BOLLING LLP (714) 292-0262
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Jesse K. Bolling
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[email protected]
• The proposed project includes demolition and replacement of fitness and swimming facilities, as well as the addition of new structures, including bungalow units, loft-style accommodations, and related site improvements. More specifically, the project includes (i) conversion or construction of second-floor space within a proposed fitness facility into loft-style accommodations and (ii) construction of detached bungalow-style units on the property. The project would also eliminate three lit tennis courts used for nighttime play and divide the tennis and pickleball facilities with a large internal road serving the bungalow component, including more than thirty parking spaces located within that internal circulation area.
• Golf Realty Fund also submitted an alternative concept involving the addition of a third story to the fitness facility without including the bungalow lodging component.

According to information provided by a City employee, that submission was marked "Incomplete" because it did not contain sufficient detail to determine whether it complied with applicable height limitations. Even if that proposal ultimately raised height- compliance issues, the City retains discretion to evaluate whether such limitations could be addressed or modified through appropriate planning mechanisms. A plan without an internal roadway through the recreational core, therefore, is theoretically possible. • At a presentation by Golf Realty Fund to Club members on Friday, January 23, 2026, at which Camaraderie Clubs was absent, a representative of Golf Realty Fund told members that revenue from the bungalow component was necessary to fund reconstruction of the pool and fitness improvements. Golf Realty Fund has also provided the City with aggressive revenue projections for these rental units, particularly in light of the competition from multiple high-end beachfront hotels in the area. In subsequent representations to the City Council, however, Golf Realty Fund indicated that it has sufficient financial resources to build and maintain the proposed improvements even if those revenue projections were not realized. Those two positions are difficult to reconcile and bear directly on whether the bungalow component is truly necessary or instead an added revenue stream being pursued despite the costs it imposes. • I received a written communication distributed by Camaraderie Clubs to Club members dated February 7, 2026 (Exhibit A). In that communication, Camaraderie Clubs expressly states that it "has no financial interest or contractual obligation to manage the bungalows and loft apartments proposed by Golf Realty Fund." • The same communication also alludes to the statements made by Golf Realty Fund during its town hall meeting with Club members concerning the proposed project. At that meeting, Golf Realty Fund stated that members were "free to speak with [their] wallets" in response to the proposed changes.

Page 14 ends

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GUTENPLAN & BOLLING LLP
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Jesse K. Bolling
Managing Partner
[email protected]
• The February 7, 2026 communication further clarifies that Camaraderie Clubs does not endorse that statement and distinguishes its operational role from that of the property owner with respect to the proposed development.
• It is anticipated that, if the contemplated redevelopment obligations are not satisfied within the early May 2026 timeframe, a dispute between landlord and tenant may arise, potentially resulting in litigation. This point is noted solely to provide context regarding the relationship between landlord and tenant, which, from my perspective, is troubling. • In negotiations among the parties, there has been a general refusal to have all sides sit down together to resolve their issues. Golf Realty Fund has asserted that Camaraderie Clubs contractually agreed to limit or waive its ability to object to certain aspects of the redevelopment plan, including the bungalow component. I have learned nothing that contradicts that assertion. At the town hall meeting, Golf Realty Fund flashed a specific portion of the lease when making that point to members, but I was not provided with a sufficient opportunity to review that provision in full. Further, Appellants' suggestion that a thorough dialogue among all the affected parties would be the best course toward resolution has been dismissed.

2. Golf Realty Fund proposes an unsafe conflict zone within the Club's recreational core that introduces high-traffic areas into the center of club facilities visited daily by families.

The plans submitted to the City do not merely remodel a private club. They change the way this entire recreational area would function on a daily basis. Instead of keeping vehicular circulation at the perimeter, the proposed design pulls vehicle movement into the same part of the site where members and their families naturally move back and forth between the tennis courts, the pickleball courts, the bungalow area, the food truck location, and the pool and fitness complex.

That matters because this part of the Club is not a static space. It is one of the most active family areas on the property. During a recent tennis tournament, I watched my own three children-ages 8, 6, and 3-consistently move among the courts, the fitness center, the pool, and the food truck area. Children were running back and forth for smoothies, food, and breaks between matches. Parents and members were doing the same thing. That pattern of movement is not unusual; it is exactly how this area of the Club is actually used.

The City would never design one of its own recreational spaces this way. In publicly used Huntington Beach recreation areas, vehicular circulation is kept at the edges, while the interior is reserved for fields, courts, trails, playgrounds, and gathering space. That is not accidental. It Page | 5
EPG BLAW Orange County Office
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Costa Mesa, CA 92626
ENENSTEIN PHAM GLASS (714) 292-0262
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Jesse K. Balling
Managing Partner
[email protected]
reflects a basic safety judgment: where children and families are moving freely, cars should not be routed through the middle of the activity zone.

Huntington
2, 1- CENTRAL PARK
tantington Beak East
Contral Park Library entral Park/Secret Garder
Parking
Vehicular Access HOSC
Recreation
& Parking Parking
Recreations
HBSC
Parking

CENTRAL PARK
West
• BASEBALL/SOFTBALL FIELDS Taiter Ace
Tasert Aud
TURF FIELDS Secret Carder
Gold ARENA FIELD Recreation

GRASS FIELDS

BATTING CAGES
• SNACK BAR / RATHROOMS
reation FLAY GROUND
• HESC OFFICE
Vehicular Access
Humtington Beach park desigı consistently places velicular circulation at the perimeter; while Parking interior space is reserved for active recreation. This separation reflects a fimdamental safety principle: where children and families are moving freely, vehicles are kept out of the activity zone.

The project plans submitted here do the opposite. They create a conflict zone where ordinary member movement intersects with internal vehicular circulation serving both lodging- related traffic and everyday member parking activity. The internal road does not simply pass near the courts—it runs directly through the recreational area and includes more than thirty parking spaces that will attract regular member use. The issue is not whether a careful adult can look both ways and cross. The issue is whether an active tennis and pickleball environment- used by children, teens, and families should be redesigned to require exactly that kind of vigilance in the first place.

The risk is particularly acute at the pickleball courts. Under the current layout, the pickleball courts sit adjacent to one another, and weekly ladder events regularly utilize all eight pickleball courts (four in each court bank). During those events, players continuously rotate between the two courts based on wins and losses. Under the proposed plan, the internal road would run between the two courts that are currently adjacent, meaning that players participating Page |6
EPG BLAW Orange County Office
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ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
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[email protected]
in these events would be required to cross the roadway repeatedly throughout play. That repeated crossing pattern-by adults focused on competition and movement, not vehicle traffic-creates an additional, foreseeable point of conflict between pedestrians and vehicles.

The submitted plan itself shows that the natural path of travel from the heart of the tennis and pickleball courts to the food truck and pool cuts directly across the internal drive and circulation area tied to the bungalow component. In the real world, children do not stop at neat crossing points and wait for vehicles. They run where they have always run. Members move where they have always moved. The danger is therefore not speculative. It is foreseeable on the face of the design.

FOOD TRUCK
(NCT A PART)
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*(0.3 . OF

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PICKLEBALL 8 PARKING STALIS
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150
Proposed site plan showing the internal roadway and parking area ("Conflict Zone") bisecting the Club's primary tennis and pickleball facilities, where regular pedestrian movement— particularly by children and players rotating between courts—intersects directly with vehicular traffic.

The economic justification for introducing this risk has also shifted. At Golf Realty Fund's presentation on Friday, January 23, 2026, members were told that bungalow revenue was necessary to fund the pool and fitness improvements. Later, Golf Realty Fund represented to the Council that it has sufficient funds to build and maintain those improvements even if the

Page 17 ends

EPG-B LAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
aggressive revenue projections tied to the bungalow and loft component do not materialize. By Golf Realty Fund's own later account, it does not need this additional revenue stream to construct and maintain the facilities. If that is true, then the question for the Council is not whether more revenue would be desirable. The question is whether this added safety risk is worth the cost. It is not.

The concern becomes even more serious because Camaraderie Clubs has already stated that it will not manage the lodging facilities. That means a third party will do so. A third-party lodging operation brings with it its own traffic patterns: guest arrivals and departures, deliveries, rideshare traffic, off-site food runs, and trips for alcohol and other services that are not necessarily integrated with Club operations, including when dining facilities are closed (eg.

Mondays). These risks are compounded by the fact that members themselves will use the same internal circulation area for parking and access to the tennis and pickleball facilities, further increasing vehicle volume in the same environment where children and members are walking and running between athletic and pool facilities. And in each and every one of these scenarios, the Council should assume alcohol will be consumed.

The timing of this application only heightens the concern. Golf Realty Fund appears to be trying to push this project through because it is running out of time under its own contractual obligations, which may expose it to financial consequences. But a private deadline is not a legal basis to shortcut public safety review. The fact that the owner may feel urgency is a reason for the Council to slow down, not a reason to approve an incomplete and under-analyzed design.

A comprehensive, independent safety study must be completed. At a minimum, that study should evaluate pedestrian circulation, child movement patterns, vehicle conflict points, visibility and sightlines, construction-phase hazards, and the operational risks associated with the bungalow and loft component. Without that work, approval would be premature.

The City would never route an internal lodging-access road through one of its own active recreational spaces without rigorous safety analysis. It should not permit that result here simply because the project is privately proposed. The stakes are high. If a child is struck by a vehicle in a conflict zone the plans themselves create, the resulting liability exposure would be extraordinary. As a trial lawyer, I view the owner, the operator, and the City as the approving authority as obvious defendants in that scenario, and the exposure could exceed $100 million in a catastrophic injury case. That outcome is not worth a minor, unnecessary revenue stream. And it can only even be argued to be worth the risk if a comprehensive safety study is done first.

Page 18 ends

EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]

3. The proposed plan will have additional adverse effects on the Club's tennis program and daily operations, and if the back courts are not lit, tennis will wither at the Club.

Beyond the serious safety concerns addressed above, the proposed project would also materially impair the Club's tennis and pickleball program and its broader day-to-day operations.

First, the project threatens the viability of nighttime tennis at the Club. As the proposed plan makes clear, the six back courts at the far western end of the property become critically important if three existing lit courts are removed. If those back courts cannot be lit, the Club will effectively go from seven lit courts to only four. That reduction would fundamentally alter the Club's evening tennis program and, in practical terms, could cause tennis at the Club to wither.

Most notably, it would jeopardize some of the Club's some of the most popular organized evening events, including Men's Night and Ladies' Night, where large groups of players participate in round-robin doubles. The junior program, which goes until 7:00 p.m. PST, would also be jeopardized. For many members, those events are the core of the Club's tennis culture and one of the principal reasons they remain active members.

Any loss of courts must be tethered to the back courts being capable of lawful nighttime use. At present, however, the problem is that the prior conditional use permit associated with those courts reportedly does not allow lighting because of their proximity to neighboring homes. (Exhibit B.) Golf Realty Fund appears to be exploring technological solutions to reduce light spill, but the practical reality remains the same: nearby homeowners would be looking at illuminated courts on a nightly basis. That issue should not be ignored or deferred. It should be confronted directly now because, without a realistic and enforceable solution, the project substantially diminishes the Club's ability to function as a tennis facility.

Second, the elimination of three tennis courts will materially affect daytime operations as well. The Club's tennis program is not limited to casual drop-in use. It supports numerous teams, private lessons, daily junior programs, clinics, and organized member play throughout the week.

While no club can honestly claim that every court is full at every hour of every day, that is not the standard. The relevant question is whether the reduction in court inventory will impair operations during the hours that matter most. It plainly will. Peak usage periods will be squeezed.

Team practices and matches will be harder to schedule. Private instruction and junior programming will face greater competition for court time. The junior program in particular is a meaningful asset to the Club, run by a strong professional staff and designed to develop high- level young players. Orange County has already produced elite junior talent, and there is no reason that program should be diminished by a redevelopment plan that prioritizes lodging over courts.

Page 19 ends

EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
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Jesse K. Bolling
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[email protected]
Third, Golf Realty Fund has represented that the courts will remain open during construction. On the present record, however, it is difficult to see how that can occur in a safe and functional way. The project already proposes to remove courts, insert internal circulation, and carry out major construction immediately adjacent to active recreational use. If the road and bungalow components were eliminated, there would at least be a greater possibility of preserving meaningful tennis operations during construction. But under the current design, the notion that children can safely attend junior camp, that coaches can conduct lessons, and that teams can play normally while roads are being paved and heavy construction is underway has not been substantiated. The Council should not simply assume that normal Club operations can continue through a prolonged and invasive construction process without a detailed, credible operational plan.

Taken together, these impacts are not secondary or incidental. They go to the heart of what The Huntington Club is and how it functions. This is not merely a question of replacing old facilities with new ones. It is a question of whether the Club's tennis community, junior development program, and nighttime member culture will survive the project in anything like their present form. On the current record, there is substantial reason to doubt that they will.

4. The City's Zoning Code does not allow people to sleep overnight in recreational space.

The Council's discretion under the Conditional Use Permit process is not unlimited. A CUP is not a blank check to authorize any use the City wishes to allow based on generalized notions of "good cause." Under the Huntington Beach Zoning Code, a CUP may be granted only where the Council can make the required findings, including that the proposed use is consistent with the General Plan and all applicable requirements of the Municipal Code. Most importantly, the Council must be able to find that the proposed use will comply with the provisions of the base district and other applicable provisions of the Zoning Code. If those findings cannot be made, denial is required
That requirement has procedural consequences here. The Council must be able to support each required finding with substantial evidence in the administrative record at the time of approval. Where material issues such as whether the project can be operated safely-remain unresolved, the Council cannot defer that determination to a future study. Absent substantial evidence demonstrating that the project can be operated safely, the Council cannot make the findings necessary to approve the Conditional Use Permit.

That is the core issue here. The subject property is in the OS-PR district. Huntington Beach's zoning regulations provide that uses not listed in a district's land use controls are prohibited. In OS-PR, "Park & Recreation Facilities" may be allowed with a CUP, and certain Page | 10
EPG BLAW Orange County Office
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ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
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Jesse K. Bolling
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ancillary uses may be permitted in limited form, but the Code does not separately list general lodging or visitor accommodations as an authorized OS-PR use. From a legal perspective, the threshold question, therefore, is not whether the bungalow and loft component may be desirable or financially beneficial. The threshold question is whether that lodging component is actually an authorized use in OS-PR at all.

The City's own use-classification scheme sharpens that issue. Huntington Beach distinguishes between "Clubs and Lodges," on the one hand, and "Visitor Accommodations," on the other. "Clubs and Lodges" are recreational or social facilities primarily for members or guests. "Visitor Accommodations" are separately defined lodging uses, including hotels, motels, and similar short-term occupancy arrangements. The Code thus does not treat private club use and overnight lodging use as interchangeable. They are different use categories. That distinction matters here because the proposed bungalow and loft component appears, in substance, to function as a lodging use rather than merely as part of the Club's traditional recreational operations.

Accordingly, if the City's position is that the bungalow and loft component constitutes a lodging or visitor-accommodation use, then the Council should identify precisely where that use is permitted or conditionally permitted in OS-PR. If the City's position is instead that the lodging component is merely accessory or incidental to the recreational use, then the Council should explain how overnight accommodations are truly subordinate to, and customarily associated with, the principal recreational use of the site, rather than a separate revenue-generating use added to the property. Either way, the Council must still make the finding that the project complies with the base district. A CUP does not eliminate that requirement.

There is a further problem. The Huntington Beach Code contemplates that, if a proposed use cannot be clearly classified within an existing use category, the answer is not simply to approve it by CUP anyway. Rather, the Code assigns use-classification decisions to the Director and, where no existing classification clearly applies, the proper remedy is a change to the zoning text. In other words, the City may not use the CUP process to create a new hybrid use that the Code does not presently authorize.

For that reason, the Council should require a clear answer to a simple question before acting: what, exactly, is the legal use classification for the proposed bungalows and lofts, and where is that use authorized in OS-PR? And critically, the Council must also be able to determine-based on substantial evidence-that the project, as designed, can be operated safely before any approval is granted. Unless and until those questions are answered in a manner that allows the Council to make the required findings, approval of the lodging component would be legally vulnerable and premature.

Page |11
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
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Jesse K. Bolling
Managing Partner
[email protected]

5. There is no justifiable basis to move forward with the proposed plan unless and until, at a minimum, a comprehensive safety study is conducted.

For all of these reasons, there is no justifiable basis for the Council to move forward with the proposed plan unless and until a comprehensive safety study is completed. Without that study, the Council lacks substantial evidence necessary to determine that the project can be operated safely and therefore cannot make the findings required for approval of the Conditional Use Permit.

We therefore respectfully request that the Council continue this matter for at least 60 days so that the proposed project can be evaluated on a more complete and reliable record.

Respectfully Submitted,

ENENSTEIN PHAM GLASS GUTENPLAN & BOLLING, LLP
By:

Jesse K. Bolling, Esq.

Cc:
• Casey McKeon, Mayor: [email protected]
• Butch Twining, Mayor Pro Tem: [email protected] • Gracey Van Der Mark, Councilmember: Gracey. [email protected] • Pat Burns, Councilmember: [email protected]
• Don Kennedy, Councilmember: [email protected] • Chad Williams, Councilmember; Chad. [email protected] • Andrew Gruel, Councilmember: [email protected] Page | 12

EXHIBIT A
Julie Ann Crandall
From: The Huntington Club <[email protected]>
Sent: Saturday, February 7, 2026 8:11 AM
To: Jesse Bolling
Subject: Camaraderie Clubs Clarification ~ Townhall Meeting Saturday, February 7, 2026
Dear Members of The Huntington Club,
It has been two weeks since Golf Realty Fund and Johnathon Baily held a town hall meeting at the Huntington Club to discuss the New Performance Center Building, new pool, and bungalow project. Over the past two weeks, we have noticed some confusion regarding the relationship between the tenant of THC (Camaraderie Clubs) and the landlord/property owner (Golf Realty Fund). To clarify, Camaraderie Clubs pays rent to Golf Realty Fund through a triple net lease. This lease outlines obligations for capital expenditures for both the tenant and the property owner. So far, Camaraderie Clubs has met and exceeded its capital obligations. However, as the property owner mentioned in the planning commission meeting on January 27th, they have yet to fulfill their obligations. In the past six years since the lease was signed, Golf Realty Fund is still in the process of obtaining the necessary approvals for the project.

In addition, Camaraderie clubs would like to clarify the following misconceptions we have heard from the members.

1.Johnathon Baily represents Golf Reality Trust and is not affiliated with Camaraderie Clubs or involved in our operational decisions regarding THC. We want to make it very clear: WE DO NOT ENDORSE HIS STATEMENT MADE DURING THE TOWN HALL MEETING, where he said, "WE ARE COMFORTABLE AND CONFIDENT IN THE

ECONOMICS, AND YOU GUYS ARE FREE TO SPEAK WITH YOUR WALLETS AND SAY, 'HEY, NO, THIS CLUB ISN'T FOR US; WE WILL LEAVE." Jonathon Baily and Golf Realty Trust do not have the authority to make such statements to you, our valued customers, and members of THC. As made evident by the recent survey, we value member feedback and will use that feedback to frame our capital investment and operational opportunities. We deeply value your membership and thank you for choosing to be a part of our Club.

2. Currently, Camaraderie Clubs has no financial interest or contractual obligation to manage the bungalows and loft apartments proposed by Golf Realty Fund. Camaraderie Clubs has been steadfast in its efforts to compel the landlord to honor its obligations to construct a new swimming pool and upgrade the fitness facilities over the past 6 years.

The ownership of The Huntington Club is dedicated to the ongoing improvement of the Club and its facilities, aiming to preserve and enhance the experience enjoyed by its members.
1 We will always advocate for the interests of the Club and its members with conviction and respect. Please direct any questions about the project to Golf Realty Fund as they will be best equipped to answer questions about their project.

Sincerely,
Travis Brasher - Managing Partner, Camaraderie Clubs
Joe Saikali - General Manager
6501 Palm Ave. Huntington Beach, CA 92648 714.536.8866
This message was sent to Jesse Bolling <jbolling1 [email protected]> by Huntington Club Click here to unsubscribe from further communications
2 Huntington Beach Planning Commission
P.O. BOX 190 CALIFORNIA 92648
August 6, 1985
Huntington Beach Company
2110 Main Street
Huntington Beach, CA 92648
SUBJECT: CONDITIONAL USE PERMIT NO. 85-25/COASTAL DEVELOPMENT PERMIT NO. 85-19/NEGATIVE DECLARATION NO.:385-26
REQUEST: To termit construction
of 6 tennis courts.

LOCATION: East side of Palm Ave.
approximately 300 ft.
south of Cherryhill Ave.

FINDINGS FOR APPROVAL CONDITIONAL USE PERMIT NO. 85-25:

1. The proposed six tennis courts are compatible with surrounding land uses and in conformance with the General Plan policies because the facility will become an integral part of the existing Seacliff Country club.
•

2. The proposed tennis courts will not be detrimental to the generrl health, welfare, safety and convenience of persons residing or working in the neighborhood because the, facility will have hours of operation limited to the daytime:

3. The iocation, site layout, and design of the proposed development does properly adapt the structure to streets, driveways and other uses in a harmonious manner,
FINDINGS FOR APPROVAL COASTAL DEVELOPMENT PERMIT NO. 85-2:
•1. The proposal for 6 tennis courts is consistent with the City Coastal Zone suffix as well as other provisions of the
Huntington Beach Ordinance Code applicable to the property; and conforts with the plans, policies, reguirements and standards of the City's Coastal Land Use Plan.

2. The proposed development can be provided with infrastructure in a manner that is consistent with the Coastal Land Use Plan.

3. The proposed development conforms with the public access and public recreation policies of Chapter 3 of the california Coastal Act.

CONDITIONS OF APPROVAL CONDITIONAL USE PERMIT NO. 85-25:

1. The site plan dated May 22, 1985 shall be the approved layout.

2. Prior to issuance of building permits, the applicant shall submit a landscape and irrigation plan to the Department of Development Services and Department of Public Works for review and approval.

3. The tennis courts hours of operation shall be limited to daytime hours. No artificial lighting shall be permitted.

4. A copy of the tennis club membership/entry requirements shall be submitted to the Department of Development Services to assure the membership/use is limited to country club members.

5. All building spoils, such a unused lumber, wire, pipe and surplus or unusable materials, shall be disposed of at an off-site facility equipped to handle them.

I hereby certify that Conditional Use Permit No. 85-25, Coastal Development Permit No. 85-19 and Negative Declaration No. 85-26 approved by the Planning Commission of the City of Huntington Beach on August 5, 1985 by the foregoing citations and conditions.

Sincerely,
Elena With / fir
James W. Palin
Secretary
Planning Commission
JWP: 1p
(3037đ(3)
From: Barnes, Lisa Lane
To: [email protected]
Fw: Immediate Attention Requested - April 21, 2026 Hearing: Huntington Club Remodel and Bungalows Subject:

Date: Monday, April 20, 2026 10:47:37 AM
Attachments: The Huntington Club Remodel and Bungalows (Revised).pdf Outlook-Logo Desc
Outiook-a1puot0x.png
Outlook-txgr3id1.png
Qutlook-somuygzx.png
Outlook-rspvibaw.png
Lisa Lane Barnes
Elected City Clerk
Office: (714) 536-5405
[email protected]
BO

CITY OF HUNTINGTON BEACH
2000 Main Street, Huntington Beach, CA 92648
For passport information and
appointments please visit:

Passport Services Website
From: Katie Liang <[email protected]>
Sent: Friday, April 17, 2026 3:30 PM
To: McKeon, Casey <[email protected]>; Twining, Butch <[email protected]>; Van Der Mark, Gracey < Gracey. VanDerMark@surfcity- hb.org>; Burns, Pat <[email protected]>; Kennedy, Don <Don.Kennedy@surfcity- hb.org>; Williams, Chad <Chad. [email protected]>; Gruel, Andrew <[email protected]>; Barnes, Lisa Lane <[email protected]> Cc: Wes Babi <[email protected]>
Subject: Immediate Attention Requested - April 21, 2026 Hearing: Huntington Club Remodel and Bungalows
You don't often get email from [email protected]. Learn why this is important
Dear Mayor and Members of the City Council,
On behalf of the Boards of Directors of the Seacliff on the Greens Community Association and the Estate Series of Seacliff Homeowners Association, I am writing to request your immediate attention regarding the proposed Huntington Club Remodel and Bungalows project, scheduled for consideration at the April 21, 2026 City Council hearing.

Attached for your review is a formal letter from the Boards outlining our significant concerns with the proposed development. These concerns include, but are not limited to, drainage impacts, noise and lighting issues, and the need to revisit and renegotiate existing agreements to ensure they align with current standards and fairly protect the neighboring Seacliff on the Greens community.

We respectfully request that approval of the project be postponed until these matters can be thoroughly evaluated and addressed in collaboration with the affected community.

Thank you for your time and consideration. We appreciate your attention to this important issue and your commitment to thoughtful and responsible development within the City of Huntington Beach.

Sincerely,
Katie Liang
Community Manager
26840 Aliso Viejo Parkway Suite 100 Aliso Viejo, CA 92656 Customer Care: (800) 232-7517
p. 949 313 8502
seabreezemgmt.com|

SEABREEZE

MANAGEMENT COMPANY
seabreezemgmt.com in fy d
Huntington Beach City Council
2000 Main Street
Huntington Beach, CA 92648
Email: [email protected]
Re: April 21, 2026 Hearing RE: The Huntington Club Remodel and Bungalows Dear Mayor and Members of the City Council,
The Seacliff on the Greens Community board as well as the Estate of Seacliff on The Greens Community board have significant concerns regarding the proposed development.

Please postpone the approval of the development project so the neighboring community of Seacliff On the Greens is able to have their concerns addressed.

1. Analysis of impact and necessary upgrades to the existing drainage system along the golf course maintained by Seacliff on the Greens community association to make sure it up to date with current standards.

2. Noise study to ensure bungalows don't cause a nuance. Homeowners previously stopped the event space that was constructed on a tennis court to be turned into bungalows.

3. Lights study. The country club had 2 courts lit against the existing lighting agreement to not light the back courts. The association will not allow the back courts to be lit.

4. Renegotiation of current drainage and landscaping agreements with Seacliff on the Greens. The CPI index is not a fair measure to account for rising prices so we will require a percentage share based on the initial costs.

5. The original Drainage Agreement should be nullified if the Huntington Clubs development project is detrimental to the SeaCliff on the Greens community.

Thank you for your attention to this matter.

Best Regards,
Board of Directors of
Seacliff on the Greens Community Association and
The Estate Series of Seacliff Homeowners Association
c/o Seabreeze Management Company

BAY AREA

COACHELLA VALLEY

INLAND EMPIRE

LAS VEGAS

LOS ANGELES

ORANGE COUNTY
REND

CORPORATE OFFICE

SAN DIEGO
26840 Aliso Viejo Parkway | Suite 100 | Aliso Viejo, CA 92656 | p 800.232.7517 | f 949.855.6678 SEATTLE

SEABREEZE

MANAGEMENT COMPANY
CORPORATE OFFICE: 26840 Aliso Viejo Parkway | Suite 100 | Aliso Viejo, CA 92656 | p 800.232.7517 | f 949.855.6678 From: Levin, Shannon
To: Villasenor, Jennifer
Subject: FW: Letter on behalf of Appellants for April 21, 2026 Hearing re The Huntington Club Remodel and Bungalows Date: Monday, April 13, 2026 10:46:39 AM
Attachments: image001.png
2026.04.10 Letter to HBCC (FINAL).pdf
FYI
From: Julie Ann Crandall <[email protected]>
Sent: Friday, April 10, 2026 3:00 PM
To: CITY COUNCIL (INCL. CMO STAFF) <[email protected]> Subject: Letter on behalf of Appellants for April 21, 2026 Hearing re The Huntington Club Remodel and Bungalows
Some people who received this message don't often get email from [email protected]. Learn why this is important
Dear Huntington Beach City Council Members,
Please see attached correspondence from Jesse Bolling, Esq., who represents Appellants Cheryl Gates, Scott Warren, and Susan Ridgway in the above-referenced matter. Do not hesitate to reach out if you have any questions.

Julie Crandall
Paralegal to Jesse Bolling

ENENSTEIN PHAM GLASS GUTENPLAN & BOLLING LLP
3200 Bristol St.

Costa Mesa, CA 92626
Phone: (657) 383-4511
Email: [email protected]
www.epggblaw.com
This email and any attachments contain information from the law firm of ENENSTEIN PHAM GLASS & RABBAT LLP, which may be confidential and/or privileged. The information is intended to be for the use of the individual or entity named on this email. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this email is prohibited. If you receive this email in error, please notify us by reply email immediately so that we can arrange for the retrieval of the original documents at no cost to you.

From: Levin, Shannon
To: Villasenor, Jennifer
Subject: FW: Proposed Huntington Club Remodel
Date: Monday, April 13, 2026 10:59:37 AM
Attachments: 2026.04.10 Letter to HBCC (EINAL).pdf
-----Original Message-----
From: [email protected] <[email protected]> Sent: Sunday, April 12, 2026 6:31 PM
To: CITY COUNCIL (INCL. CMO STAFF) < [email protected]>; McKeon, Casey <[email protected]>; Twining, Butch < [email protected]>; Van Der Mark, Gracey <Gracey. [email protected]>; Burns, Pat <[email protected]>; Kennedy, Don <[email protected]
Cc: Williams, Chad <Chad. [email protected]>; Gruel, Andrew <[email protected]> Subject: Proposed Huntington Club Remodel
[Some people who received this message don't often get email from [email protected]. Learn why this is important at https://aka.ms/LearnAboutSenderIdentification] Dear Councilmembers, Mayor, and Mayor Pro Tem:

By now you must have received numerous emails with the attached letter which includes historical information that would be beneficial prior to a final decision regarding the proposed Huntington Club remodel. If you haven't already, I urge you to read it. This letter points out key safety issues, which have been my main concern since discussions began about this proposed project. I remember making the comment, "With a street running directly through the club courts, it is not a matter of someone potentially being injured or killed, but when". My husband directly asked a representative of the applicant, Jonathon why there should be a need for parking in front of the bungalows. His response was that this was a city requirement. A more viable solution for all parties would be to maintain the original design with the bungalows instead as penthouse units on the new tennis clubhouse.

Raising the building one story does not impact any of the parties. The original penthouse design appeases the interests of the current tennis/pickleball members, the landlord, the residences opposed to lights and residences whose current golf course views will be diminished by the proposed bungalows. Regarding the additional parking required by city ordinance, this can also be reevaluated to mitigate the heightened liability exposure to the landlord, tenant, and city. The new lodging units are not likely to maintain 100% occupancy on a regular basis; therefore, the need for additional parking is quite minimal. Many of the guests are not likely to have more than one vehicle, and the availability of ride share reduces the need even further. It is clear that the liability exposure to all interested parties should warrant more scrutiny and alternative plan solutions.

Regards,
Kelly Kelleher Casares
Kelleher/Casares Equipment, LLC
9901 Paramount Blvd. Ste. 140
Downey, CA 90240
(562)422-1257 X1
(562)857-4481 cell
[email protected]

CONFIDENTIAL & PROPRIETARY INFORMATION
This message is intended for the exclusive use of the addressee(s) and may contain information that is CONFIDENTIAL, PRIVILEGED and/or PROPRIETARY. If you are not the intended recipients), you are hereby notified that any disclosure, copying, dissemination or other use of this communication is prohibited. If you have received this communication in error, please delete/erase all copies of this message and its attachments and notify us immediately.
-----Original Message-----
From: Kelly Kelleher <[email protected]>
Sent: Sunday, April 12, 2026 5:32 PM
To: Kelly Kelleher <[email protected]>
Subject: 2026.04.10 Letter to HBCC (FINAL).pdf
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
Costa Mesa, CA 92626
ENENSTEIN PHAM GLASS (714) 292-0262

GUTENPLAN & BOLLING LLP
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
April 10, 2026

SENT VIA EMAIL
Huntington Beach City Council
2000 Main Street
Huntington Beach, CA 92648
Email: [email protected]
Re: April 21, 2026 Hearing re The Huntington Club Remodel and Bungalows Dear Mayor and Members of the City Council,
I submit this letter in two capacities: (1) as pro bono counsel to appellants Cheryl Gates, Susan Ridgeway, and Douglas Scott Warren; and (2) as a current member of The Huntington Club with a direct interest in the continued availability and character of its facilities. I am an active golf and tennis member of the Club, and my family and I regularly participate in its athletic programs.

To summarize, Golf Realty Fund has a reported contractual obligation of approximately $10 million to $15 million to complete improvements at the Club. In structuring that arrangement, Golf Realty Fund retained control over the buildout, positioning itself to convert that obligation into an additional revenue stream through hotel-like lodging for "members and their guests." At the most recent hearing, Golf Realty Fund implied that it does not need that additional revenue to fund the renovations; it simply seeks an additional revenue stream from the property.

Standing alone, that economic choice would not necessarily be problematic. The problem is the particular plan Golf Realty Fund has chosen to pursue. As proposed, it introduces serious safety risks for Club members and their families. Members and their children move constantly through this area circulating among the courts, the pool, the fitness center, and food service locationsoften in unpredictable patterns that are inherent to an active recreational environment.

The proposed design forces those same children to cross an internal roadway serving both lodging-related traffic and everyday member vehicle traffic, as members will naturally use that area for convenient parking in the more than thirty new parking spaces located directly adjacent to the tennis and pickleball courts. The plan therefore concentrates vehicle traffic in the exact space where children and families are moving on foot.

This creates a direct and foreseeable conflict between vehicles and pedestrians. That risk is compounded by the nature of the proposed use, which will introduce guest traffic, ride-share Page |1
EPG-BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
activity, deliveries, and the potential for alcohol-related driving into the same space where children are playing and moving freely. The foreseeable result is not minor or theoretical—it is the risk of serious injury in a setting that has always functioned as a protected recreational environment. Up until now, Golf Realty Fund has asked the Council to allow that plan to proceed without the benefit of a comprehensive safety study, ostensibly because its contractual deadline to complete these improvements will expire in early May 2026.

That private timing pressure is no substitute for a complete and reliable public record, particularly where the safety of Huntington Beach families who use what many regard as the City's crown jewel is at stake. More time is needed to determine whether this design can be made safe. Without that work, approval would expose Golf Realty Fund, its tenant, and the City of Huntington Beach to substantial liability if a member or worse, a child—is injured.

In good faith discussions between the Appellants and Golf Realty Fund, the concept of a comprehensive safety study has been raised. Golf Realty Fund appears amenable to conducting such a study, but there remains a critical procedural issue. It is my understanding that Golf Realty Fund prefers that the safety study be imposed along with approval of the plan. We respectfully submit that this approach is improper under the circumstances and should be rejected.

The Council should instead retain jurisdiction over this matter and require completion of the safety study before any approval is granted. The Appellants' ability to advocate on behalf of the Club's membership is tied to this appeal. As a non-equity club, members do not control the property; their voice is exercised through this process and through the Council's oversight. If the project is approved subject to later study, that voice is effectively extinguished, and future decisions regarding safety, design, and implementation will be left to private entities whose interests may not align with those of the citizens most directly affected.

Moreover, the Council cannot make the required findings in support of approval without first establishing, based on substantial evidence, that the project can be operated safely. Nor may the Council defer that determination to a future study, as doing so would leave a critical component of the approval unsupported by the administrative record at the time of decision. Where material safety concerns remain unresolved, approval would be premature because the record would not contain substantial evidence sufficient to support the findings required for a Conditional Use Permit.

Based on the foregoing, we respectfully request that the Council continue this hearing for at least 60 days so that the proposed plan can be more fully evaluated, particularly in light of the serious safety concerns created by placing a roadway with significant parking capacity in the middle of the Club's tennis and pickleball facilities. The Council should direct Golf Realty Fund to conduct a comprehensive safety study by an independent consultant approved by the Council

Page 12 ends

EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
and Appellants. Once completed, that study should be circulated for review and comment, and only then should the Council determine whether the project, as proposed, is safe enough for approval.

1. The factual background demonstrates no evaluation of safety concerns amid contractual time pressure and a breakdown between owner and operator.

The factual statements set forth in this letter are based on a combination of publicly available materials and information obtained through discussions with individuals represented to have knowledge of the operations, agreements, and history of the Club. Except where expressly supported by cited documents or witnessed by me or my clients, these statements are provided on an informational basis only. I therefore do not present these statements as adjudicated fact, but rather as contextual background to assist the Council in understanding the circumstances surrounding the proposed project.
• The entity operating the Club, Camaraderie Clubs, is led by Travis Brasher, who previously served as a golf professional at the Club when it operated under its former name, Seacliff Country Club. Mr. Brasher founded the Travis Mathew apparel brand, which was later sold, and has since returned, now as the tenant overseeing operations at the Club, rebranding it as The Huntington Club.
• Prior to the COVID-19 pandemic, Camaraderie Clubs entered into a long-term lease agreement-reported to be approximately 30 years in duration —with the property owner, Golf Realty Fund, under which it operates the Club.
• As part of that long-term lease arrangement, both Camaraderie Clubs and Golf Realty Fund are understood to have contemplated and committed to significant capital improvements to the Club's infrastructure in recognition of the age and condition of the existing facilities.
• Camaraderie Clubs has invested substantial capital into the Club, reported to be in the range of approximately $8 million to $10 million.
• Golf Realty Fund, as property owner, is likewise understood to have committed to a significant capital contribution toward redevelopment of the property, reported to be in the range of approximately $10 million to $15 million, none of which has yet been deployed. The lease or related agreements reportedly include a deadline for completion of those improvements in early May 2026. Based on that reported deadline, Golf Realty Fund appears to be under substantial time pressure to obtain approvals and move the project forward
Page | 3
EPG-BLAW Orange County Office
3200 Bristol Street, Suite 400
Costa Mesa, CA 92626

ENENSTEIN PHAM GLASS
(714) 292-0262

GUTENPLAN & BOLLING LLP
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
• The proposed project includes demolition and replacement of fitness and swimming facilities, as well as the addition of new structures, including bungalow units, loft-style accommodations, and related site improvements. More specifically, the project includes (i) conversion or construction of second-floor space within a proposed fitness facility into loft-style accommodations and (i) construction of detached bungalow-style units on the property. The project would also eliminate three lit tennis courts used for nighttime play and divide the tennis and pickleball facilities with a large internal road serving the bungalow component, including more than thirty parking spaces located within that internal circulation area.
• Golf Realty Fund also submitted an alternative concept involving the addition of a third story to the fitness facility without including the bungalow lodging component.

According to information provided by a City employee, that submission was marked "Incomplete" because it did not contain sufficient detail to determine whether it complied with applicable height limitations. Even if that proposal ultimately raised height- compliance issues, the City retains discretion to evaluate whether such limitations could be addressed or modified through appropriate planning mechanisms. A plan without an internal roadway through the recreational core, therefore, is theoretically possible. • At a presentation by Golf Realty Fund to Club members on Friday, January 23, 2026, at which Camaraderie Clubs was absent, a representative of Golf Realty Fund told members that revenue from the bungalow component was necessary to fund reconstruction of the pool and fitness improvements. Golf Realty Fund has also provided the City with aggressive revenue projections for these rental units, particularly in light of the competition from multiple high-end beachfront hotels in the area. In subsequent representations to the City Council, however, Golf Realty Fund indicated that it has sufficient financial resources to build and maintain the proposed improvements even if those revenue projections were not realized. Those two positions are difficult to reconcile and bear directly on whether the bungalow component is truly necessary or instead an added revenue stream being pursued despite the costs it imposes. • I received a written communication distributed by Camaraderie Clubs to Club members dated February 7, 2026 (Exhibit A). In that communication, Camaraderie Clubs expressly states that it "has no financial interest or contractual obligation to manage the bungalows and loft apartments proposed by Golf Realty Fund." • The same communication also alludes to the statements made by Golf Realty Fund during its town hall meeting with Club members concerning the proposed project. At that meeting, Golf Realty Fund stated that members were "free to speak with [their] wallets" in response to the proposed changes.

Page | 4
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
• The February 7, 2026 communication further clarifies that Camaraderie Clubs does not endorse that statement and distinguishes its operational role from that of the property owner with respect to the proposed development.
• It is anticipated that, if the contemplated redevelopment obligations are not satisfied within the early May 2026 timeframe, a dispute between landlord and tenant may arise, potentially resulting in litigation. This point is noted solely to provide context regarding the relationship between landlord and tenant, which, from my perspective, is troubling. • In negotiations among the parties, there has been a general refusal to have all sides sit down together to resolve their issues. Golf Realty Fund has asserted that Camaraderie Clubs contractually agreed to limit or waive its ability to object to certain aspects of the redevelopment plan, including the bungalow component. I have learned nothing that contradicts that assertion. At the town hall meeting, Golf Realty Fund flashed a specific portion of the lease when making that point to members, but I was not provided with a sufficient opportunity to review that provision in full. Further, Appellants' suggestion that a thorough dialogue among all the affected parties would be the best course toward resolution has been dismissed.

2. Golf Realty Fund proposes an unsafe conflict zone within the Club's recreational core that introduces high-traffic areas into the center of club facilities visited daily by families.

The plans submitted to the City do not merely remodel a private club. They change the way this entire recreational area would function on a daily basis. Instead of keeping vehicular circulation at the perimeter, the proposed design pulls vehicle movement into the same part of the site where members and their families naturally move back and forth between the tennis courts, the pickleball courts, the bungalow area, the food truck location, and the pool and fitness complex.

That matters because this part of the Club is not a static space. It is one of the most active family areas on the property. During a recent tennis tournament, I watched my own three children-ages 8, 6, and 3-consistently move among the courts, the fitness center, the pool, and the food truck area. Children were running back and forth for smoothies, food, and breaks between matches. Parents and members were doing the same thing. That pattern of movement is not unusual; it is exactly how this area of the Club is actually used.

The City would never design one of its own recreational spaces this way. In publicly used Huntington Beach recreation areas, vehicular circulation is kept at the edges, while the interior is reserved for fields, courts, trails, playgrounds, and gathering space. That is not accidental. It Page | 5
EPG-BLAW Orange County Office
3200 Bristol Street, Suite 400
Costa Mesa, CA 92626

ENENSTEIN PHAM GLASS
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
reflects a basic safety judgment: where children and families are moving freely, cars should not be routed through the middle of the activity zone.

Huntington
Huntington Beach CENTRAL PARK
Contral Park Library East
Parking Central Park/Secret Carden
te speare 20901
Vehicular Access HOSC
& Parking Parking
HBSC N Recreationa
Payking

CENTRAL PARK
→ BASESALL/SOFTBALL FIELDS
Central Pas Co Taltent And

TURF FIELDS CEATRAL PARK
Secret Carden
GOld ) ARENA FIELD Recreation
→ GRASS FIELDS

CATTING CAGES

SNACK BAR / RATHROOMS

PLAY GROUND

HESC OFFICE
Vehicular Access
& Parking
Huntington Beach park design consistently places vehicular circulation at the perimeter, while interior space is reserved for active recreation. This separation reflects a fundamental safety principle: where children and families are moving freely, vehicles are kept out of the activity zone.

The project plans submitted here do the opposite. They create a conflict zone where ordinary member movement intersects with internal vehicular circulation serving both lodging- related traffic and everyday member parking activity. The internal road does not simply pass near the courtsit runs directly through the recreational area and includes more than thirty parking spaces that will attract regular member use. The issue is not whether a careful adult can look both ways and cross. The issue is whether an active tennis and pickleball environment- used by children, teens, and families should be redesigned to require exactly that kind of vigilance in the first place.

The risk is particularly acute at the pickleball courts. Under the current layout, the pickleball couts sit adjacent to one another, and weekly ladder events regularly utilize all eight pickleball courts (four in each court bank). During those events, players continuously rotate between the two courts based on wins and losses. Under the proposed plan, the internal road would run between the two courts that are currently adjacent, meaning that players participating Page |6
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
Costa Mesa, CA: 92626

ENENSTEIN PHAM GLASS
GUTENPLAN & BOLLING LLP (714) 292-0262
epegblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
in these events would be required to cross the roadway repeatedly throughout play. That repeated crossing pattern—by adults focused on competition and movement, not vehicle traffic-creates an additional, foreseeable point of conflict between pedestrians and vehicles.

The submitted plan itself shows that the natural path of travel from the heart of the tennis and pickleball courts to the food truck and pool cuts directly across the internal drive and circulation area tied to the bungalow component. In the real world, children do not stop at neat crossing points and wait for vehicles. They run where they have always run. Members move where they have always moved. The danger is therefore not speculative. It is foreseeable on the face of the design.

FOOD TRJCK
(NCT A PART)
LAKE

NAYACAVA
RANCHO

VALENCIA

CACA NEW FITNESS /
2(0.5" 6. PALMERO LOFT BUILLING
AR
Conflict Zone

ACYLEBALL
Proposed site plan showing the internal roadway and parking area ("Conflict Zone") bisecting the Chib's primary tennis and pickleball facilities, where regular pedestrian movement- particularly by children and players rotating between courts—intersects directly with vehicular traffic.

The economic justification for introducing this risk has also shifted. At Golf Realty Fund's presentation on Friday, January 23, 2026, members were told that bungalow revenue was necessary to fund the pool and fitness improvements. Later, Golf Realty Fund represented to the Council that it has sufficient funds to build and maintain those improvements even if the Page |7
7 EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
aggressive revenue projections tied to the bungalow and loft component do not materialize. By Golf Realty Fund's own later account, it does not need this additional revenue stream to construct and maintain the facilities. If that is true, then the question for the Council is not whether more revenue would be desirable. The question is whether this added safety risk is worth the cost. It is not.

The concern becomes even more serious because Camaraderie Clubs has already stated that it will not manage the lodging facilities. That means a third party will do so. A third-party lodging operation brings with it its own traffic patterns: guest arrivals and departures, deliveries, rideshare traffic, off-site food runs, and trips for alcohol and other services that are not necessarily integrated with Club operations, including when dining facilities are closed (e.g Mondays). These risks are compounded by the fact that members themselves will use the same internal circulation area for parking and access to the tennis and pickleball facilities, further increasing vehicle volume in the same environment where children and members are walking and running between athletic and pool facilities. And in each and every one of these scenarios, the Council should assume alcohol will be consumed.

The timing of this application only heightens the concern. Golf Realty Fund appears to be trying to push this project through because it is running out of time under its own contractual obligations, which may expose it to financial consequences. But a private deadline is not a legal basis to shortcut public safety review. The fact that the owner may feel urgency is a reason for the Council to slow down, not a reason to approve an incomplete and under-analyzed design.

A comprehensive, independent safety study must be completed. At a minimum, that study should evaluate pedestrian circulation, child movement patterns, vehicle conflict points, visibility and sightlines, construction-phase hazards, and the operational risks associated with the bungalow and loft component. Without that work, approval would be premature.

The City would never route an internal lodging-access road through one of its own active recreational spaces without rigorous safety analysis. It should not permit that result here simply because the project is privately proposed. The stakes are high. If a child is struck by a vehicle in a conflict zone the plans themselves create, the resulting liability exposure would be extraordinary. As a trial lawyer, I view the owner, the operator, and the City as the approving authority as obvious defendants in that scenario, and the exposure could exceed $100 million in a catastrophic injury case. That outcome is not worth a minor, unnecessary revenue stream. And it can only even be argued to be worth the risk if a comprehensive safety study is done first.

Page | 8
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]

3. The proposed plan will have additional adverse effects on the Club's tennis program and daily operations, and if the back courts are not lit, tennis will wither at the Club.

Beyond the serious safety concerns addressed above, the proposed project would also materially impair the Club's tennis and pickleball program and its broader day-to-day operations.

First, the project threatens the viability of nighttime tennis at the Club. As the proposed plan makes clear, the six back courts at the far western end of the property become critically important if three existing lit courts are removed. If those back courts cannot be lit, the Club will effectively go from seven lit courts to only four. That reduction would fundamentally alter the Club's evening tennis program and, in practical terms, could cause tennis at the Club to wither.

Most notably, it would jeopardize some of the Club's some of the most popular organized evening events, including Men's Night and Ladies' Night, where large groups of players participate in round-robin doubles. The junior program, which goes until 7:00 p.m. PST, would also be jeopardized. For many members, those events are the core of the Club's tennis culture and one of the principal reasons they remain active members.

Any loss of courts must be tethered to the back courts being capable of lawful nighttime use. At present, however, the problem is that the prior conditional use permit associated with those courts reportedly does not allow lighting because of their proximity to neighboring homes. (Exhibit B.) Golf Realty Fund appears to be exploring technological solutions to reduce light spill, but the practical reality remains the same: nearby homeowners would be looking at illuminated courts on a nightly basis. That issue should not be ignored or deferred. It should be confronted directly now because, without a realistic and enforceable solution, the project substantially diminishes the Club's ability to function as a tennis facility.

Second, the elimination of three tennis courts will materially affect daytime operations as well. The Club's tennis program is not limited to casual drop-in use. It supports numerous teams, private lessons, daily junior programs, clinics, and organized member play throughout the week.

While no club can honestly claim that every court is full at every hour of every day, that is not the standard. The relevant question is whether the reduction in court inventory will impair operations during the hours that matter most. It plainly will. Peak usage periods will be squeezed.

Team practices and matches will be harder to schedule. Private instruction and junior programming will face greater competition for court time. The junior program in particular is a meaningful asset to the Club, run by a strong professional staff and designed to develop high- level young players. Orange County has already produced elite junior talent, and there is no reason that program should be diminished by a redevelopment plan that prioritizes lodging over courts.

Page | 9
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
Third, Golf Realty Fund has represented that the courts will remain open during construction. On the present record, however, it is difficult to see how that can occur in a safe and functional way. The project already proposes to remove courts, insert internal circulation, and carry out major construction immediately adjacent to active recreational use. If the road and bungalow components were eliminated, there would at least be a greater possibility of preserving meaningful tennis operations during construction. But under the current design, the notion that children can safely attend junior camp, that coaches can conduct lessons, and that teams can play normally while roads are being paved and heavy construction is underway has not been substantiated. The Council should not simply assume that normal Club operations can continue through a prolonged and invasive construction process without a detailed, credible operational plan.

Taken together, these impacts are not secondary or incidental. They go to the heart of what The Huntington Club is and how it functions. This is not merely a question of replacing old facilities with new ones. It is a question of whether the Club's tennis community, junior development program, and nighttime member culture will survive the project in anything like their present form. On the current record, there is substantial reason to doubt that they will.

4. The City's Zoning Code does not allow people to sleep overnight in recreational space.

The Council's discretion under the Conditional Use Permit process is not unlimited. A CUP is not a blank check to authorize any use the City wishes to allow based on generalized notions of "good cause." Under the Huntington Beach Zoning Code, a CUP may be granted only where the Council can make the required findings, including that the proposed use is consistent with the General Plan and all applicable requirements of the Municipal Code. Most importantly, the Council must be able to find that the proposed use will comply with the provisions of the base district and other applicable provisions of the Zoning Code. If those findings cannot be made, denial is required.

That requirement has procedural consequences here. The Council must be able to support each required finding with substantial evidence in the administrative record at the time of approval. Where material issues- such as whether the project can be operated safely-remain unresolved, the Council cannot defer that determination to a future study. Absent substantial evidence demonstrating that the project can be operated safely, the Council cannot make the findings necessary to approve the Conditional Use Permit.

That is the core issue here. The subject property is in the OS-PR district. Huntington Beach's zoning regulations provide that uses not listed in a district's land use controls are prohibited. In OS-PR, "Park & Recreation Facilities" may be allowed with a CUP, and certain Page | 10
EPG-BLAW Orange County Office
3200 Bristol Street, Suite 400
Costa Mesa, CA 92626

ENENSTEIN PHAM GLASS
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
ancillary uses may be permitted in limited form, but the Code does not separately list general lodging or visitor accommodations as an authorized OS-PR use. From a legal perspective, the threshold question, therefore, is not whether the bungalow and loft component may be desirable or financially beneficial. The threshold question is whether that lodging component is actually an authorized use in OS-PR at all.

The City's own use-classification scheme sharpens that issue. Huntington Beach distinguishes between "Clubs and Lodges," on the one hand, and "Visitor Accommodations," on the other. "Clubs and Lodges" are recreational or social facilities primarily for members or guests. "Visitor Accommodations" are separately defined lodging uses, including hotels, motels, and similar short-term occupancy arrangements. The Code thus does not treat private club use and overnight lodging use as interchangeable. They are different use categories. That distinction matters here because the proposed bungalow and loft component appears, in substance, to function as a lodging use rather than merely as part of the Club's traditional recreational operations.

Accordingly, if the City's position is that the bungalow and loft component constitutes a lodging or visitor-accommodation use, then the Council should identify precisely where that use is permitted or conditionally permitted in OS-PR. If the City's position is instead that the lodging component is merely accessory or incidental to the recreational use, then the Council should explain how overnight accommodations are truly subordinate to, and customarily associated with, the principal recreational use of the site, rather than a separate revenue-generating use added to the property. Either way, the Council must still make the finding that the project complies with the base district. A CUP does not eliminate that requirement.

There is a further problem. The Huntington Beach Code contemplates that, if a proposed use cannot be clearly classified within an existing use category, the answer is not simply to approve it by CUP anyway. Rather, the Code assigns use-classification decisions to the Director and, where no existing classification clearly applies, the proper remedy is a change to the zoning text. In other words, the City may not use the CUP process to create a new hybrid use that the Code does not presently authorize.

For that reason, the Council should require a clear answer to a simple question before acting: what, exactly, is the legal use classification for the proposed bungalows and lofts, and where is that use authorized in OS-PR? And critically, the Council must also be able to determine-based on substantial evidence—that the project, as designed, can be operated safely before any approval is granted. Unless and until those questions are answered in a manner that allows the Council to make the required findings, approval of the lodging component would be legally vulnerable and premature.

Page |11
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]

5. There is no justifiable basis to move forward with the proposed plan unless and until, at a minimum, a comprehensive safety study is conducted.

For all of these reasons, there is no justifiable basis for the Council to move forward with the proposed plan unless and until a comprehensive safety study is completed. Without that study, the Council lacks substantial evidence necessary to determine that the project can be operated safely and therefore cannot make the findings required for approval of the Conditional Use Permit.

We therefore respectfully request that the Council continue this matter for at least 60 days so that the proposed project can be evaluated on a more complete and reliable record.

Respectfully Submitted,

ENENSTEIN PHAM GLASS GUTENPLAN & BOLLING, LLP
By:

Jesse K. Bolling, Esq.

Cc:

Casey McKeon, Mayor: [email protected]
• Butch Twining, Mayor Pro Tem: [email protected] • Gracey Van Der Mark, Councilmember: Gracey. [email protected] • Pat Burns, Councilmember: [email protected]
• Don Kennedy, Councilmember: [email protected] • Chad Williams, Councilmember; Chad. [email protected] • Andrew Gruel, Councilmember: [email protected] Page |12

EXHIBIT A
Julie Ann Crandall
From: The Huntington Club < [email protected]:

Sent: Saturday, February 7, 2026 8:11 AM
To: esse Bolling
Subiect: amaraderie Clubs Clarification ~ Townhall Meetin Saturday, February 7, 2026
Dear Members of The Huntington Club,
It has been two weeks since Golf Realty Fund and Johnathon Baily held a town hall meeting at the Huntington Club to discuss the New Performance Center Building, new pool, and bungalow project. Over the past two weeks, we have noticed some confusion regarding the relationship between the tenant of THC (Camaraderie Clubs) and the landlord/property owner (Golf Realty Fund). To clarify, Camaraderie Clubs pays rent to Golf Realty Fund through a triple net lease. This lease outlines obligations for capital expenditures for both the tenant and the property owner. So far, Camaraderie Clubs has met and exceeded its capital obligations. However, as the property owner mentioned in the planning commission meeting on January 27th, they have yet to fulfill their obligations. In the past six years since the lease was signed, Golf Realty Fund is still in the process of obtaining the necessary approvals for the project.

In addition, Camaraderie clubs would like to clarify the following misconceptions we have heard from the members.

1.Johnathon Baily represents Golf Reality Trust and is not affiliated with Camaraderie Clubs or involved in our operational decisions regarding THC. We want to make it very clear: WE DO NOT ENDORSE HIS STATEMENT MADE DURING THE TOWN HALL MEETING, where he said, "WE ARE COMFORTABLE AND CONFIDENT IN THE

ECONOMICS, AND YOU GUYS ARE FREE TO SPEAK WITH YOUR WALLETS AND SAY, 'HEY, NO, THIS CLUB ISN'T FOR US; WE WILL LEAVE.'" Jonathon Baily and Golf Realty Trust do not have the authority to make such statements to you, our valued customers, and members of THC. As made evident by the recent survey, we value member feedback and will use that feedback to frame our capital investment and operational opportunities. We deeply value your membership and thank you for choosing to be a part of our Club

2. Currently, Camaraderie Clubs has no financial interest or contractual obligation to manage the bungalows and loft apartments proposed by Golf Realty Fund. Camaraderie Clubs has been steadfast in its efforts to compel the landlord to honor its obligations to construct a new swimming pool and upgrade the fitness facilities over the past 6 years.

The ownership of The Huntington Club is dedicated to the ongoing improvement of the Club and its facilities, aiming to preserve and enhance the experience enjoyed by its members.

We will always advocate for the interests of the Club and its members with conviction and respect. Please direct any questions about the project to Golf Realty Fund as they will be best equipped to answer questions about their project.

Sincerely,
Travis Brasher - Managing Partner, Camaraderie Clubs
Joe Saikali - General Manager
6501 Palm Ave. Huntington Beach, CA 92648 714.536.8866
This message was sent to Jesse Bolting <[email protected]> by Huntington Club Click here to unsubscribe from further communications

Huntington Beach Planning Commission
P.O. BOX 190 . CALIFORNIA 92648.

August 6, 1985
Huntington Beach Company
2110 Main Street
Huntington Beach, CA 92648
SUBJECT: CONDITIONAL USE PERMIT NO. 85-25/COASTAL DEVELOPMENT PERMIT NO. 85-19/NEGATIVE DECLARATION NO.::85-26
REQUEST: To permit construction
of 6 tennis courts.

LOCATION: East side of Palm Ave.
approximately 300 ft.
south of Cherryhill Ave:

FINDINGS FOR APPROVAL CONDITIONAL USE PERMIT NO. 85-25:

1. The proposed six tennis courts are compatible with surrounding land uses and in conformance with the General Plan policies because the facility will become an integral part of the existing Seacliff Country Club.

2. The proposed tennis courts will not be detrimental
genere1 health, welfare, safety and convenience of persons residing or working in the neighborhood because the facility will have hours of operation limited to the daytime.

3. The location, site layout, and design of the proposed developmeht does properly adapt the structure to streets, driveways and other uses in a harmonious manner.

FINDINGS FOR APPROVAL COASTAL DEVELOPMENT PERMIT NO. 85-2:

1. The proposal for 6 tennis courts is consistent with the City Zone suffix as well as other provisions of the
Huntington Beach Ordinance Code applicable to the property: and conforms with the plans, policies, reguirements and standards of the City's Coastal Land Use Plan.

2. The proposed development can be provided with infrastructure in a manner that is consistent with the Coastal Land Use Plan.

3. The proposed development conforms with the public access and public recreation policies of Chapter 3 of the California Coastal Act.

CONDITIONS OF APPROVAL CONDITIONAL USE PERMIT NO. 85-25:

1. The site plan dated May 22, 1985 shall be the, approved layout.

2. Prior to issuance of building permits, the applicant shall submit a landscape and irrigation plan to the Department of Development Services and Department of Public Works for review approval.

3. The tennis courts hours of operation shall be limited to daytime hours. No artificial lighting shall be permitted.

4. A copy of the tennis club membership/entry requirements shall be submitted to the Department of Development Services to assure the membership/use is limited to country club members.

5. All building spoils, such a unused lumber, wire, pipe and surplus or unusable materials, shall be disposed of at an off-site facility equipped to handle them.

I hereby certify that Conditional Use Permit No. 85-25, Coastal" Development Permit No. 85-19 and Negative Declaration No. 85-26 was approved by the Planning Commission of the City of Huntington Beach on August 5, 1985 by the foregoing citations and conditions.

Sincerely,
Ilena Witt/ fir
James W. Palin
Secretary
Planning Commission
JWP: 1p
(3037d(3)
From: Levin, Shannon
To: Villasenor, Jennifer
Subject: FW: Safety Concerns over proposed transient accommodations at The Huntington Club Date: Monday, April 13, 2026 11:00:09 AM
Attachments: 2026.04.10 Letter to HBCC (FINAL),pdf
From: Leslie Carter <[email protected]>
Sent: Monday, April 13, 2026 10:56 AM
To: CITY COUNCIL (INCL. CMO STAFF) < [email protected]> Subject: Safety Concerns over proposed transient accommodations at The Huntington Club Some people who received this message don't often get email from [email protected]. Learn why this is important
I am a member at The Huntington Club and I would like to echo the safety concerns highlighted in the attached letter. Adding transient accommodations and a street/parking in the middle of courts where people and children move freely is a recipe for disaster
I would like to see a safety assessment done to see how changes could be made that do noy cause safety issues
Thank you
Leslie Carter
Sent from my iPhone
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
Jesse K. Bolling
Managing Partner
[email protected]
April 10, 2026

SENT VIA EMAIL
Huntington Beach City Council
2000 Main Street
Huntington Beach, CA 92648
Email: City. [email protected]
Re: April 21, 2026 Hearing re The Huntington Club Remodel and Bungalows Dear Mayor and Members of the City Council,
I submit this letter in two capacities: (1) as pro bono counsel to appellants Cheryl Gates, Susan Ridgeway, and Douglas Scott Warren; and (2) as a current member of The Huntington Club with a direct interest in the continued availability and character of its facilities. I am an active golf and tennis member of the Club, and my family and I regularly participate in its athletic programs.

To summarize, Golf Realty Fund has a reported contractual obligation of approximately $10 million to $15 million to complete improvements at the Club. In structuring that arrangement, Golf Realty Fund retained control over the buildout, positioning itself to convert that obligation into an additional revenue stream through hotel-like lodging for "members and their guests." At the most recent hearing, Golf Realty Fund implied that it does not need that additional revenue to fund the renovations; it simply seeks an additional revenue stream from the property.

Standing alone, that economic choice would not necessarily be problematic. The problem is the particular plan Golf Realty Fund has chosen to pursue. As proposed, it introduces serious safety risks for Club members and their families. Members and their children move constantly through this area circulating among the courts, the pool, the fitness center, and food service locations often in unpredictable patterns that are inherent to an active recreational environment.

The proposed design forces those same children to cross an internal roadway serving both lodging-related traffic and everyday member vehicle traffic, as members will naturally use that area for convenient parking in the more than thirty new parking spaces located directly adjacent to the tennis and pickleball courts. The plan therefore concentrates vehicle traffic in the exact space where children and families are moving on foot.

This creates a direct and foreseeable conflict between vehicles and pedestrians. That risk is compounded by the nature of the proposed use, which will introduce guest traffic, ride-share Page | 1
EPG-BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
activity, deliveries, and the potential for alcohol-related driving into the same space where children are playing and moving freely. The foreseeable result is not minor or theoretical— it is the risk of serious injury in a setting that has always functioned as a protected recreational environment. Up until now, Golf Realty Fund has asked the Council to allow that plan to proceed without the benefit of a comprehensive safety study, ostensibly because its contractual deadline to complete these improvements will expire in early May 2026.

That private timing pressure is no substitute for a complete and reliable public record, particularly where the safety of Huntington Beach families who use what many regard as the City's crown jewel is at stake. More time is needed to determine whether this design can be made safe. Without that work, approval would expose Golf Realty Fund, its tenant, and the City of Huntington Beach to substantial liability if a member-or worse, a child is injured.

In good faith discussions between the Appellants and Golf Realty Fund, the concept of a comprehensive safety study has been raised. Golf Realty Fund appears amenable to conducting such a study, but there remains a critical procedural issue. It is my understanding that Golf Realty Fund prefers that the safety study be imposed along with approval of the plan. We respectfully submit that this approach is improper under the circumstances and should be rejected.

The Council should instead retain jurisdiction over this matter and require completion of the safety study before any approval is granted. The Appellants' ability to advocate on behalf of the Club's membership is tied to this appeal. As a non-equity club, members do not control the property; their voice is exercised through this process and through the Council's oversight. If the project is approved subject to later study, that voice is effectively extinguished, and future decisions regarding safety, design, and implementation will be left to private entities whose interests may not align with those of the citizens most directly affected.

Moreover, the Council cannot make the required findings in support of approval without first establishing, based on substantial evidence, that the project can be operated safely. Nor may the Council defer that determination to a future study, as doing so would leave a critical component of the approval unsupported by the administrative record at the time of decision. Where material safety concerns remain unresolved, approval would be premature because the record would not contain substantial evidence sufficient to support the findings required for a Conditional Use Permit.

Based on the foregoing, we respectfully request that the Council continue this hearing for at least 60 days so that the proposed plan can be more fully evaluated, particularly in light of the serious safety concerns created by placing a roadway with significant parking capacity in the middle of the Club's tennis and pickleball facilities. The Council should direct Golf Realty Fund to conduct a comprehensive safety study by an independent consultant approved by the Council Page |2
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
and Appellants. Once completed, that study should be circulated for review and comment, and only then should the Council determine whether the project, as proposed, is safe enough for approval.

1. The factual background demonstrates no evaluation of safety concerns amid contractual time pressure and a breakdown between owner and operator.

The factual statements set forth in this letter are based on a combination of publicly available materials and information obtained through discussions with individuals represented to have knowledge of the operations, agreements, and history of the Club. Except where expressly supported by cited documents or witnessed by me or my clients, these statements are provided on an informational basis only. I therefore do not present these statements as adjudicated fact, but rather as contextual background to assist the Council in understanding the circumstances surrounding the proposed project.
• The entity operating the Club, Camaraderie Clubs, is led by Travis Brasher, who previously served as a golf professional at the Club when it operated under its former name, Seacliff Country Club. Mr. Brasher founded the Travis Mathew apparel brand, which was later sold, and has since returned, now as the tenant overseeing operations at the Club, rebranding it as The Huntington Club.
• Prior to the COVID-19 pandemic, Camaraderie Clubs entered into a long-term lease agreement-reported to be approximately 30 years in duration—with the property owner, Golf Realty Fund, under which it operates the Club.
• As part of that long-term lease arrangement, both Camaraderie Clubs and Golf Realty Fund are understood to have contemplated and committed to significant capital improvements to the Club's infrastructure in recognition of the age and condition of the existing facilities.
• Camaraderie Clubs has invested substantial capital into the Club, reported to be in the range of approximately $8 million to $10 million.
• Golf Realty Fund, as property owner, is likewise understood to have committed to a significant capital contribution toward redevelopment of the property, reported to be in the range of approximately $10 million to $15 million, none of which has yet been deployed. The lease or related agreements reportedly include a deadline for completion of those improvements in early May 2026. Based on that reported deadline, Golf Realty Fund appears to be under substantial time pressure to obtain approvals and move the project forward.

Page |3
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
• The proposed project includes demolition and replacement of fitness and swimming facilities, as well as the addition of new structures, including bungalow units, loft-style accommodations, and related site improvements. More specifically, the project includes (i) conversion or construction of second-floor space within a proposed fitness facility into loft-style accommodations and (ii) construction of detached bungalow-style units on the property. The project would also eliminate three lit tennis courts used for nighttime play and divide the tennis and pickleball facilities with a large internal road serving the bungalow component, including more than thirty parking spaces located within that internal circulation area.
• Golf Realty Fund also submitted an alternative concept involving the addition of a third story to the fitness facility without including the bungalow lodging component.

According to information provided by a City employee, that submission was marked "Incomplete" because it did not contain sufficient detail to determine whether it complied with applicable height limitations. Even if that proposal ultimately raised height- compliance issues, the City retains discretion to evaluate whether such limitations could be addressed or modified through appropriate planning mechanisms. A plan without an internal roadway through the recreational core, therefore, is theoretically possible. • At a presentation by Golf Realty Fund to Club members on Friday, January 23, 2026, at which Camaraderie Clubs was absent, a representative of Golf Realty Fund told members that revenue from the bungalow component was necessary to fund reconstruction of the pool and fitness improvements. Golf Realty Fund has also provided the City with aggressive revenue projections for these rental units, particularly in light of the competition from multiple high-end beachfront hotels in the area. In subsequent representations to the City Council, however, Golf Realty Fund indicated that it has sufficient financial resources to build and maintain the proposed improvements even if those revenue projections were not realized. Those two positions are difficult to reconcile and bear directly on whether the bungalow component is truly necessary or instead an added revenue stream being pursued despite the costs it imposes.

I received a written communication distributed by Camaraderie Clubs to Club members dated February 7, 2026 (Exhibit A). In that communication, Camaraderie Clubs expressly states that it "has no financial interest or contractual obligation to manage the bungalows and loft apartments proposed by Golf Realty Fund." • The same communication also alludes to the statements made by Golf Realty Fund during its town hall meeting with Club members concerning the proposed project. At that meeting, Golf Realty Fund stated that members were "free to speak with [their] wallets" in response to the proposed changes.

Page | 4
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
• The February 7, 2026 communication further clarifies that Camaraderie Clubs does not endorse that statement and distinguishes its operational role from that of the property owner with respect to the proposed development.
• It is anticipated that, if the contemplated redevelopment obligations are not satisfied within the early May 2026 timeframe, a dispute between landlord and tenant may arise, potentially resulting in litigation. This point is noted solely to provide context regarding the relationship between landlord and tenant, which, from my perspective, is troubling. • In negotiations among the parties, there has been a general refusal to have all sides sit down together to resolve their issues. Golf Realty Fund has asserted that Camaraderie Clubs contractually agreed to limit or waive its ability to object to certain aspects of the redevelopment plan, including the bungalow component. I have learned nothing that contradicts that assertion. At the town hall meeting, Golf Realty Fund flashed a specific portion of the lease when making that point to members, but I was not provided with a sufficient opportunity to review that provision in full. Further, Appellants' suggestion that a thorough dialogue among all the affected parties would be the best course toward resolution has been dismissed

2. Golf Realty Fund proposes an unsafe conflict zone within the Club's recreational core that introduces high-traffic areas into the center of club facilities visited daily by families.

The plans submitted to the City do not merely remodel a private club. They change the way this entire recreational area would function on a daily basis. Instead of keeping vehicular circulation at the perimeter, the proposed design pulls vehicle movement into the same part of the site where members and their families naturally move back and forth between the tennis courts, the pickleball courts, the bungalow area, the food truck location, and the pool and fitness complex.

That matters because this part of the Club is not a static space. It is one of the most active family areas on the property. During a recent tennis tournament, I watched my own three children-ages 8, 6, and 3—consistently move among the courts, the fitness center, the pool, and the food truck area. Children were running back and forth for smoothies, food, and breaks between matches. Parents and members were doing the same thing. That pattern of movement is not unusual; it is exactly how this area of the Club is actually used.

The City would never design one of its own recreational spaces this way. In publicly used Huntington Beach recreation areas, vehicular circulation is kept at the edges, while the interior is reserved for fields, courts, trails, playgrounds, and gathering space. That is not accidental. It Page | 5
EPG-BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
reflects a basic safety judgment: where children and families are moving freely, cars should not be routed through the middle of the activity zone
Huntington
Cantral Park Library Huntington Beach 3, 1* CENTRAL PAAK East
Parking Central Park/Secret Carden
Wet and Eat wandEr Collarea? 39 en
...

Vehicular Actess
HOGC
Recreation
& Farking Parking
HBSC Recreations
Parking
42 CENTRAL PARK
• BASEBALL/SOFTBALL FIELDS nard si West
TURF FIELDS Coral Pis O
Gold Secret Carder
ARENA FIELD Recreation
→ GRASS FIELOS

BATTING CAGES

SNACK BAR / RATHROOMS
Tavia Dr

PLAY GROUND
→ HESC OFFICE
Vehicular Access
& Parking
Huntington Beach park design consistently places vehicular circulation at the perimeter, while interior space is reserved for active recreation. This separation reflects a fundamental safety principle: where children and families are moving freely, vehicles are kept out of the activity zone.

The project plans submitted here do the opposite. They create a conflict zone where ordinary member movement intersects with internal vehicular circulation serving both lodging- related traffic and everyday member parking activity. The internal road does not simply pass near the courtsit runs directly through the recreational area and includes more than thirty parking spaces that will attract regular member use. The issue is not whether a careful adult can look both ways and cross. The issue is whether an active tennis and pickleball environment- used by children, teens, and families should be redesigned to require exactly that kind of vigilance in the first place.

The risk is particularly acute at the pickleball courts. Under the current layout, the pickleball courts sit adjacent to one another, and weekly ladder events regularly utilize all eight pickleball courts (four in each court bank). During those events, players continuously rotate between the two courts based on wins and losses. Under the proposed plan, the internal road would run between the two courts that are currently adjacent, meaning that players participating Page |6
EPG-BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
in these events would be required to cross the roadway repeatedly throughout play. That repeated crossing patter-by adults focused on competition and movement, not vehicle traffic-creates an additional, foreseeable point of conflict between pedestrians and vehicles.

The submitted plan itself shows that the natural path of travel from the heart of the tennis and pickleball courts to the food truck and pool cuts directly across the internal drive and circulation area tied to the bungalow component. In the real world, children do not stop at neat crossing points and wait for vehicles. They run where they have always run. Members move where they have always moved. The danger is therefore not speculative. It is foreseeable on the face of the design.

FOOD TRJCK
(NCT A PART)
LAKE

NAYACAVA
RANCHO

VALENCIL

CASA NEW TINES /

PALMERO LOFT BUILLING
:167 No Conflict Zone

ACHLEBALL & PACKING STALLS,
Proposed site plan showing the internal roadway and parking area ("Conflict Zone") bisecting the Club's primary tennis and pickleball facilities, where regular pedestrian movement— particularly by children and players rotating between courts—intersects directly with vehicular traffic.

The economic justification for introducing this risk has also shifted. At Golf Realty Fund's presentation on Friday, January 23, 2026, members were told that bungalow revenue was necessary to fund the pool and fitness improvements. Later, Golf Realty Fund represented to the Council that it has sufficient funds to build and maintain those improvements even if the Page |7
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
aggressive revenue projections tied to the bungalow and loft component do not materialize. By Golf Realty Fund's own later account, it does not need this additional revenue stream to construct and maintain the facilities. If that is true, then the question for the Council is not whether more revenue would be desirable. The question is whether this added safety risk is worth the cost. It is not.

The concern becomes even more serious because Camaraderie Clubs has already stated that it will not manage the lodging facilities. That means a third party will do so. A third-party lodging operation brings with it its own traffic patterns: guest arrivals and departures, deliveries, rideshare traffic, off-site food runs, and trips for alcohol and other services that are not necessarily integrated with Club operations, including when dining facilities are closed (e.g Mondays). These risks are compounded by the fact that members themselves will use the same internal circulation area for parking and access to the tennis and pickleball facilities, further increasing vehicle volume in the same environment where children and members are walking and running between athletic and pool facilities. And in each and every one of these scenarios, the Council should assume alcohol will be consumed.

The timing of this application only heightens the concern. Golf Realty Fund appears to be trying to push this project through because it is running out of time under its own contractual obligations, which may expose it to financial consequences. But a private deadline is not a legal basis to shortcut public safety review. The fact that the owner may feel urgency is a reason for the Council to slow down, not a reason to approve an incomplete and under-analyzed design.

A comprehensive, independent safety study must be completed. At a minimum, that study should evaluate pedestrian circulation, child movement patterns, vehicle conflict points, visibility and sightlines, construction-phase hazards, and the operational risks associated with the bungalow and loft component. Without that work, approval would be premature.

The City would never route an internal lodging-access road through one of its own active recreational spaces without rigorous safety analysis. It should not permit that result here simply because the project is privately proposed. The stakes are high. If a child is struck by a vehicle in a conflict zone the plans themselves create, the resulting liability exposure would be extraordinary. As a trial lawyer, I view the owner, the operator, and the City as the approving authority as obvious defendants in that scenario, and the exposure could exceed $100 million in a catastrophic injury case. That outcome is not worth a minor, unnecessary revenue stream. And it can only even be argued to be worth the risk if a comprehensive safety study is done first.

Page 18 ends

EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]

3. The proposed plan will have additional adverse effects on the Club's tennis program and daily operations, and if the back courts are not lit, tennis will wither at the Club.

Beyond the serious safety concerns addressed above, the proposed project would also materially impair the Club's tennis and pickleball program and its broader day-to-day operations.

First, the project threatens the viability of nighttime tennis at the Club. As the proposed plan makes clear, the six back courts at the far western end of the property become critically important if three existing lit courts are removed. If those back courts cannot be lit, the Club will effectively go from seven lit courts to only four. That reduction would fundamentally alter the Club's evening tennis program and, in practical terms, could cause tennis at the Club to wither.

Most notably, it would jeopardize some of the Club's some of the most popular organized evening events, including Men's Night and Ladies' Night, where large groups of players participate in round-robin doubles. The junior program, which goes until 7:00 p.m. PST, would also be jeopardized. For many members, those events are the core of the Club's tennis culture and one of the principal reasons they remain active members.

Any loss of courts must be tethered to the back courts being capable of lawful nighttime use. At present, however, the problem is that the prior conditional use permit associated with those courts reportedly does not allow lighting because of their proximity to neighboring homes. (Exhibit B.) Golf Realty Fund appears to be exploring technological solutions to reduce light spill, but the practical reality remains the same: nearby homeowners would be looking at illuminated courts on a nightly basis. That issue should not be ignored or deferred. It should be confronted directly now because, without a realistic and enforceable solution, the project substantially diminishes the Club's ability to function as a tennis facility.

Second, the elimination of three tennis courts will materially affect daytime operations as well. The Club's tennis program is not limited to casual drop-in use. It supports numerous teams, private lessons, daily junior programs, clinics, and organized member play throughout the week.

While no club can honestly claim that every court is full at every hour of every day, that is not the standard. The relevant question is whether the reduction in court inventory will impair operations during the hours that matter most. It plainly will. Peak usage periods will be squeezed.

Team practices and matches will be harder to schedule. Private instruction and junior programming will face greater competition for court time. The junior program in particular is a meaningful asset to the Club, run by a strong professional staff and designed to develop high- level young players. Orange County has already produced elite junior talent, and there is no reason that program should be diminished by a redevelopment plan that prioritizes lodging over courts.

Page |9
EPG-BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
Third, Golf Realty Fund has represented that the courts will remain open during construction. On the present record, however, it is difficult to see how that can occur in a safe and functional way. The project already proposes to remove courts, insert internal circulation, and carry out major construction immediately adjacent to active recreational use. If the road and bungalow components were eliminated, there would at least be a greater possibility of preserving meaningful tennis operations during construction. But under the current design, the notion that children can safely attend junior camp, that coaches can conduct lessons, and that teams can play normally while roads are being paved and heavy construction is underway has not been substantiated. The Council should not simply assume that normal Club operations can continue through a prolonged and invasive construction process without a detailed, credible operational plan.

Taken together, these impacts are not secondary or incidental. They go to the heart of what The Huntington Club is and how it functions. This is not merely a question of replacing old facilities with new ones. It is a question of whether the Club's tennis community, junior development program, and nighttime member culture will survive the project in anything like their present form. On the current record, there is substantial reason to doubt that they will.

4. The City's Zoning Code does not allow people to sleep overnight in recreational space.

The Council's discretion under the Conditional Use Permit process is not unlimited. A CUP is not a blank check to authorize any use the City wishes to allow based on generalized notions of "good cause." Under the Huntington Beach Zoning Code, a CUP may be granted only where the Council can make the required findings, including that the proposed use is consistent with the General Plan and all applicable requirements of the Municipal Code. Most importantly, the Council must be able to find that the proposed use will comply with the provisions of the base district and other applicable provisions of the Zoning Code. If those findings cannot be made, denial is required.

That requirement has procedural consequences here. The Council must be able to support each required finding with substantial evidence in the administrative record at the time of approval. Where material issues such as whether the project can be operated safely-remain unresolved, the Council cannot defer that determination to a future study. Absent substantial evidence demonstrating that the project can be operated safely, the Council cannot make the findings necessary to approve the Conditional Use Permit.

That is the core issue here. The subject property is in the OS-PR district. Huntington Beach's zoning regulations provide that uses not listed in a district's land use controls are prohibited. In OS-PR, "Park & Recreation Facilities" may be allowed with a CUP, and certain Page | 10
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
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Jesse K. Bolling
Managing Partner
[email protected]
ancillary uses may be permitted in limited form, but the Code does not separately list general lodging or visitor accommodations as an authorized OS-PR use. From a legal perspective, the threshold question, therefore, is not whether the bungalow and loft component may be desirable or financially beneficial. The threshold question is whether that lodging component is actually an authorized use in OS-PR at all.

The City's own use-classification scheme sharpens that issue. Huntington Beach distinguishes between "Clubs and Lodges," on the one hand, and "Visitor Accommodations," on the other: "Clubs and Lodges" are recreational or social facilities primarily for members or guests. "Visitor Accommodations" are separately defined lodging uses, including hotels, motels, and similar short-term occupancy arrangements. The Code thus does not treat private club use and overnight lodging use as interchangeable. They are different use categories. That distinction matters here because the proposed bungalow and loft component appears, in substance, to function as a lodging use rather than merely as part of the Club's traditional recreational operations.

Accordingly, if the City's position is that the bungalow and loft component constitutes a lodging or visitor-accommodation use, then the Council should identify precisely where that use is permitted or conditionally permitted in OS-PR. If the City's position is instead that the lodging component is merely accessory or incidental to the recreational use, then the Council should explain how overnight accommodations are truly subordinate to, and customarily associated with, the principal recreational use of the site, rather than a separate revenue-generating use added to the property. Either way, the Council must still make the finding that the project complies with the base district. A CUP does not eliminate that requirement.

There is a further problem. The Huntington Beach Code contemplates that, if a proposed use cannot be clearly classified within an existing use category, the answer is not simply to approve it by CUP anyway. Rather, the Code assigns use-classification decisions to the Director and, where no existing classification clearly applies, the proper remedy is a change to the zoning text. In other words, the City may not use the CUP process to create a new hybrid use that the Code does not presently authorize.

For that reason, the Council should require a clear answer to a simple question before acting: what, exactly, is the legal use classification for the proposed bungalows and lofts, and where is that use authorized in OS-PR? And critically, the Council must also be able to determinebased on substantial evidence—that the project, as designed, can be operated safely before any approval is granted. Unless and until those questions are answered in a manner that allows the Council to make the required findings, approval of the lodging component would be legally vulnerable and premature.

Page | 11
Orange County Office
C3 EPG-B LAW
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]

5. There is no justifiable basis to move forward with the proposed plan unless and until, at a minimum, a comprehensive safety study is conducted.

For all of these reasons, there is no justifiable basis for the Council to move forward with the proposed plan unless and until a comprehensive safety study is completed. Without that study, the Council lacks substantial evidence necessary to determine that the project can be operated safely and therefore cannot make the findings required for approval of the Conditional Use Permit.

We therefore respectfully request that the Council continue this matter for at least 60 days so that the proposed project can be evaluated on a more complete and reliable record.

Respectfully Submitted,

ENENSTEIN PHAM GLASS GUTENPLAN & BOLLING, LLP
By:

Jesse K. Bolling, Esq.

Cc:

Casey McKeon, Mayor: [email protected]
• Butch Twining, Mayor Pro Tem: [email protected] • Gracey Van Der Mark, Councilmember: Gracey. [email protected] • Pat Burns, Councilmember: [email protected]
• Don Kennedy, Councilmember: [email protected] Chad Williams, Councilmember; [email protected] Andrew Gruel, Councilmember: Andrew. [email protected] Page | 12

EXHIBIT A
Julie Ann Crandall
From: The Huntington Club < [email protected]> Sent: Saturday, February 7, 2026 8:11 AM
To:

Subject: Jesse Balling Clubs Clarification ~ Townhal Meeting Saturday, February 7, 2026
Dear Members of The Huntington Club
It has been two weeks since Golf Realty Fund and Johnathon Baily held a town hall meeting at the Huntington Club to discuss the New Performance Center Building, new pool, and bungalow project. Over the past two weeks, we have noticed some confusion regarding the relationship between the tenant of THC (Camaraderie Clubs) and the landlord/property owner (Golf Realty Fund). To clarify, Camaraderie Clubs pays rent to Golf Realty Fund through a triple net lease. This lease outlines obligations for capital expenditures for both the tenant and the property owner. So far, Camaraderie Clubs has met and exceeded its capital obligations. However, as the property owner mentioned in the planning commission meeting on January 27th, they have yet to fulfill their obligations. In the past six years since the lease was signed, Golf Realty Fund is still in the process of obtaining the necessary approvals for the project.

In addition, Camaraderie clubs would like to clarify the following misconceptions we have heard from the members.

1. Johnathon Baily represents Golf Reality Trust and is not affiliated with Camaraderie Clubs or involved in our operational decisions regarding THC. We want to make it very clear: WE DO NOT ENDORSE HIS STATEMENT MADE DURING THE TOWN HALL MEETING, where he said, "WE ARE COMFORTABLE AND CONFIDENT IN THE

ECONOMICS, AND YOU GUYS ARE FREE TO SPEAK WITH YOUR WALLETS AND SAY, 'HEY, NO, THIS CLUB ISN'T FOR US; WE WILL LEAVE. Jonathon Baily and Golf Realty Trust do not have the authority to make such statements to you, our valued customers, and members of THC. As made evident by the recent survey, we value member feedback and will use that feedback to frame our capital investment and operational opportunities. We deeply value your membership and thank you for choosing to be a part of our Club.

2.Currently, Camaraderie Clubs has no financial interest or contractual obligation to manage the bungalows and loft apartments proposed by Golf Realty Fund. Camaraderie Clubs has been steadfast in its efforts to compel the landlord to honor its obligations to construct a new swimming pool and upgrade the fitness facilities over the past 6 years.

The ownership of The Huntington Club is dedicated to the ongoing improvement of the Club and its facilities, aiming to preserve and enhance the experience enjoyed by its members.

We will always advocate for the interests of the Club and its members with conviction and respect. Please direct any questions about the project to Golf Realty Fund as they will be best equipped to answer questions about their project.

Sincerely,
Travis Brasher - Managing Partner, Camaraderie Clubs
Joe Saikali - General Manager
6501 Palm Ave. Huntington Beach, CA 92648 714.536.8866
This message was sent to Jesse Bolling <[email protected]> by Huntington Club Click here to unsubscribe from further communications
2 Huntington Beach Planning Commission
P.O. BOX 190 • CALIFORNIA 92648
- r.

August 6, 1985
Huntington Beach Company
2110 Main Street
Huntington Beach, CA 92648
SUBJECT: CONDITIONAL USE PERMIT NO. 85-25/COASTAL DEVELOPMENT PERMIT NO. 85-19/NEGATIVE DECLARATION NO.:385-26
REQUEST: To permit construction
of 6 tennis courts.

LOCATION: East side of Palm Ave.
approximately 300 ft.
south of Cherryhill Ave:

FINDINGS FOR APPROVAL CONDITIONAL USE PERMIT NO. 85-25:

1. The proposed six tennis courts are compatible with surrounding land uses and in conformance with the General Plan policies because the facility will become an integral part of the existing Seacliff Country Club.

2. The proposed tennis courts will not be detrimental to the generrl health, welfare, safety and convenience of persons residing or working in the neighborhood because the, facility will have houzs of operation limited to the daytime:

3. The iocation, site layout, and design of the proposed development does properly adapt the structure to streets, driveways and other uses in a harmonious manner,
FINDINGS FOR APPROVAL COASTAL DEVELOPMENT PERMIT NO. 85-2:

1. The proposal for 6 tennis courts is consistent with the City Zone suffix as well as other provisions of the
Huntington Beach Ordinance Code applicable to the property; and conforms with the plans, policies, reguirements and standards of the City's Coastal Land Use Plan.

2. The proposed development can be provided with infrastructure in a manner that is consistent with the Coastal Land Use Plan.

3. The proposed development conforms with the public access and public recreation policies of Chapter 3 of the californía Coastal Act.

CONDITIONS ÓF APPROVAL CONDITIONAL USE PERMIT NO. 85-25:

1. The™ site plan dated May 22, 1985 shall be the, approved layout.

2. Prior to issuance of building permits, the applicant shall submit a landscape and irrigation plan to the Department of Development Services and Department of Public Works for reyiew and approval.

3. The tennis courts hours of operation shall be limited to daytime hours. No artificial lighting shall be permitted.

4. A copy of the tennis club membership/entry requirements shall be submitted to the Department of Development Services to assure the-membership/use is limited to country club members.

5. All building spoils, such a unused lumber, wire, pipe and surplus or unusable materials, shall be disposed of at an off-site facility equipped to handle them.

I hereby certify that Conditional Use Permit No. 85-25, Coastal" Development Permit No. 85-19 and Negative Declaration No. 85-26 was approved by the Planning Commission of the City of Huntington Beach on August 5, 1985 by the foregoing citations and conditions.

Sincerely,
Ilorena Witt/fir
James W. Palin
Secretary
Planning Commission
JWP: 1p
(3037d (3)
From: Levin, Shannon
To: Villasenor, Jennifer
Subject: FW: Huntington Club Remodel and Bungalows
Date: Tuesday, April 14, 2026 2:52:20 PM
Attachments: 2026.04.10 Letter to HBCC (FINAL).pdf
FYI
From: Mike Michels <[email protected]>
Sent: Tuesday, April 14, 2026 2:28 PM
To: CITY COUNCIL (INCL. CMO STAFF) <[email protected]> Subject: Huntington Club Remodel and Bungalows
Some people who received this message don't often get email from [email protected]. Learn why this is important
Dear Mayor and Council members:

I am writing to express my endorsement of the attached letter on behalf of Huntington Club members and urge you to postpone any decision until sufficient studies are conducted.

My family are members of the Huntington Club and we have resided in Huntington Beach for more than 30 years. A major reason for this is access to a wide variety of recreational and social activities, including tennis membership at the club. In the past, we were able to use the high school courts, which are now locked for understandable prevention of vandalism. The availability of courts in the city has dwindled with the closure of another private club, conversion of courts to pickleball and, in some instances, poor upkeep. We are fortunate to be able to join the Huntington Club, which is the center of our tennis, pickleball and social life.

It may be difficult to feel sympathetic for people who can afford to join a private club, but its presence is one of the many assets that make the city desirable and enhance property values for all.

The club hosts numerous charitable fund-raising events and tournaments, community meetings and provides excellent junior programs, which are open to non-members.

The business merits of providing on-site lodging for members and guests are certainly debatable.

Why would members who live in the area stay in the bungalows? Guests would rather stay at our homes or at the beachfront resorts.

I would like to emphasize several key points of the letter. • In the past, tennis members lost at least three courts due to reconfiguration and conversion for pickleball. The proposal will remove three more lit courts, leaving an insufficient number to host competitive tournaments, courts for teaching pros and evening play after work and school.

The proposed parking area between the pickleball courts makes no sense. As noted, it is a safety hazard and wastes real estate that could be used to retain courts. I believe the property has adequate parking for current members and bungalow guests. • As noted, the zoning code for recreational space does not permit residential or sleeping properties. Quite simply, the 24/7 nature of hotel operation is commercial rather than recreational and does not belong in the middle of residential neighborhoods.

There is no question that the clubhouse, pool and other parts of the property need upgrading, but it seems doubtful that seven rental bungalows will be sufficiently occupied to fund a significant portion of the plan, leaving member dues to pick up any shortfall.

Sincerely,
Mike Michels
6684 Pageant Drive
Huntington Beach
EPG-BLAW Orange County Office
00 Bristol Street, Suite 4
ENENSTEIN PHAM GLASS osta Mesa, CA 9267
GUTENPLAN & BOLLING LLP 714) 292-026
pggblaw.con
Jesse K. Bolling
Managing Partner
[email protected]
April 10, 2026

SENT VIA EMAIL
Huntington Beach City Council
2000 Main Street
Huntington Beach, CA 92648
Email: City. [email protected]
Re: April 21, 2026 Hearing re The Huntington Club Remodel and Bungalows Dear Mayor and Members of the City Council,
I submit this letter in two capacities: (1) as pro bono counsel to appellants Cheryl Gates, Susan Ridgeway, and Douglas Scott Warren; and (2) as a current member of The Huntington Club with a direct interest in the continued availability and character of its facilities. I am an active golf and tennis member of the Club, and my family and I regularly participate in its athletic programs.

To summarize, Golf Realty Fund has a reported contractual obligation of approximately $10 million to $15 million to complete improvements at the Club. In structuring that arrangement, Golf Realty Fund retained control over the buildout, positioning itself to convert that obligation into an additional revenue stream through hotel-like lodging for "members and their guests." At the most recent hearing, Golf Realty Fund implied that it does not need that additional revenue to fund the renovations; it simply seeks an additional revenue stream from the property.

Standing alone, that economic choice would not necessarily be problematic. The problem is the particular plan Golf Realty Fund has chosen to pursue. As proposed, it introduces serious safety risks for Club members and their families. Members and their children move constantly through this area circulating among the courts, the pool, the fitness center, and food service locations often in unpredictable patterns that are inherent to an active recreational environment.

The proposed design forces those same children to cross an internal roadway serving both lodging-related traffic and everyday member vehicle traffic, as members will naturally use that area for convenient parking in the more than thirty new parking spaces located directly adjacent to the tennis and pickleball courts. The plan therefore concentrates vehicle traffic in the exact space where children and families are moving on foot.

This creates a direct and foreseeable conflict between vehicles and pedestrians. That risk is compounded by the nature of the proposed use, which will introduce guest traffic, ride-share Page |1
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
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Jesse K. Bolling
Managing Partner
[email protected]
activity, deliveries, and the potential for alcohol-related driving into the same space where children are playing and moving freely. The foreseeable result is not minor or theoretical —it is the risk of serious injury in a setting that has always functioned as a protected recreational environment. Up until now, Golf Realty Fund has asked the Council to allow that plan to proceed without the benefit of a comprehensive safety study, ostensibly because its contractual deadline to complete these improvements will expire in early May 2026.

That private timing pressure is no substitute for a complete and reliable public record, particularly where the safety of Huntington Beach families who use what many regard as the City's crown jewel is at stake. More time is needed to determine whether this design can be made safe. Without that work, approval would expose Golf Realty Fund, its tenant, and the City of Huntington Beach to substantial liability if a member-or worse, a child—is injured In good faith discussions between the Appellants and Golf Realty Fund, the concept of a comprehensive safety study has been raised. Golf Realty Fund appears amenable to conducting such a study, but there remains a critical procedural issue. It is my understanding that Golf Realty Fund prefers that the safety study be imposed along with approval of the plan. We respectfully submit that this approach is improper under the circumstances and should be rejected.

The Council should instead retain jurisdiction over this matter and require completion of the safety study before any approval is granted. The Appellants' ability to advocate on behalf of the Club's membership is tied to this appeal. As a non-equity club, members do not control the property; their voice is exercised through this process and through the Council's oversight. If the project is approved subject to later study, that voice is effectively extinguished, and future decisions regarding safety, design, and implementation will be left to private entities whose interests may not align with those of the citizens most directly affected.

Moreover, the Council cannot make the required findings in support of approval without first establishing, based on substantial evidence, that the project can be operated safely. Nor may the Council defer that determination to a future study, as doing so would leave a critical component of the approval unsupported by the administrative record at the time of decision. Where material safety concerns remain unresolved, approval would be premature because the record would not contain substantial evidence sufficient to support the findings required for a Conditional Use Permit.

Based on the foregoing, we respectfully request that the Council continue this hearing for at least 60 days so that the proposed plan can be more fully evaluated, particularly in light of the serious safety concerns created by placing a roadway with significant parking capacity in the middle of the Club's tennis and pickleball facilities. The Council should direct Golf Realty Fund to conduct a comprehensive safety study by an independent consultant approved by the Council Page |2
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
Costa Mesa, CA 92626

ENENSTEIN PHAM GLASS
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
and Appellants. Once completed, that study should be circulated for review and comment, and only then should the Council determine whether the project, as proposed, is safe enough for approval.

1. The factual background demonstrates no evaluation of safety concerns amid contractual time pressure and a breakdown between owner and operator.

The factual statements set forth in this letter are based on a combination of publicly available materials and information obtained through discussions with individuals represented to have knowledge of the operations, agreements, and history of the Club. Except where expressly supported by cited documents or witnessed by me or my clients, these statements are provided on an informational basis only. I therefore do not present these statements as adjudicated fact, but rather as contextual background to assist the Council in understanding the circumstances surrounding the proposed project.
• The entity operating the Club, Camaraderie Clubs, is led by Travis Brasher, who previously served as a golf professional at the Club when it operated under its former name, Seacliff Country Club. Mr. Brasher founded the Travis Mathew apparel brand, which was later sold, and has since returned, now as the tenant overseeing operations at the Club, rebranding it as The Huntington Club.
• Prior to the COVID-19 pandemic, Camaraderie Clubs entered into a long-term lease Cole Really Fund, ed ter high it opate 30 cars in duration with the property owner, • As part of that long-term lease arrangement, both Camaraderie Clubs and Golf Realty Fund are understood to have contemplated and committed to significant capital improvements to the Club's infrastructure in recognition of the age and condition of the existing facilities.
• Camaraderie Clubs has invested substantial capital into the Club, reported to be in the range of approximately $8 million to $10 million.
• Golf Realty Fund, as property owner, is likewise understood to have committed to a significant capital contribution toward redevelopment of the property, reported to be in the range of approximately $10 million to $15 million, none of which has yet been deployed. The lease or related agreements reportedly include a deadline for completion of those improvements in early May 2026. Based on that reported deadline, Golf Realty Fund appears to be under substantial time pressure to obtain approvals and move the project forward.

Page 13 ends

EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
• The proposed project includes demolition and replacement of fitness and swimming facilities, as well as the addition of new structures, including bungalow units, loft-style accommodations, and related site improvements. More specifically, the project includes (i) conversion or construction of second-floor space within a proposed fitness facility into loft-style accommodations and (ii) construction of detached bungalow-style units on the property. The project would also eliminate three lit tennis courts used for nighttime play and divide the tennis and pickleball facilities with a large internal road serving the bungalow component, including more than thirty parking spaces located within that internal circulation area.
• Golf Realty Fund also submitted an alternative concept involving the addition of a third story to the fitness facility without including the bungalow lodging component.

According to information provided by a City employee, that submission was marked "Incomplete" because it did not contain sufficient detail to determine whether it complied with applicable height limitations. Even if that proposal ultimately raised height- compliance issues, the City retains discretion to evaluate whether such limitations could be addressed or modified through appropriate planning mechanisms. A plan without an internal roadway through the recreational core, therefore, is theoretically possible. • At a presentation by Golf Realty Fund to Club members on Friday, January 23, 2026, at which Camaraderie Clubs was absent, a representative of Golf Realty Fund told members that revenue from the bungalow component was necessary to fund reconstruction of the pool and fitness improvements. Golf Realty Fund has also provided the City with aggressive revenue projections for these rental units, particularly in light of the competition from multiple high-end beachfront hotels in the area. In subsequent representations to the City Council, however, Golf Realty Fund indicated that it has sufficient financial resources to build and maintain the proposed improvements even if those revenue projections were not realized. Those two positions are difficult to reconcile and bear directly on whether the bungalow component is truly necessary or instead an added revenue stream being pursued despite the costs it imposes. • I received a written communication distributed by Camaraderie Clubs to Club members dated February 7, 2026 (Exhibit A). In that communication, Camaraderie Clubs expressly states that it "has no financial interest or contractual obligation to manage the bungalows and loft apartments proposed by Golf Realty Fund." • The same communication also alludes to the statements made by Golf Realty Fund during its town hall meeting with Club members concerning the proposed project. At that meeting, Golf Realty Fund stated that members were "free to speak with [their] wallets" in response to the proposed changes.

Page | 4
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
• The February 7, 2026 communication further clarifies that Camaraderie Clubs does not endorse that statement and distinguishes its operational role from that of the property owner with respect to the proposed development.
• It is anticipated that, if the contemplated redevelopment obligations are not satisfied within the early May 2026 timeframe, a dispute between landlord and tenant may arise, potentially resulting in litigation. This point is noted solely to provide context regarding the relationship between landlord and tenant, which, from my perspective, is troubling. • In negotiations among the parties, there has been a general refusal to have all sides sit down together to resolve their issues. Golf Realty Fund has asserted that Camaraderie Clubs contractually agreed to limit or waive its ability to object to certain aspects of the redevelopment plan, including the bungalow component. I have learned nothing that contradicts that assertion. At the town hall meeting, Golf Realty Fund flashed a specific portion of the lease when making that point to members, but I was not provided with a sufficient opportunity to review that provision in full. Further, Appellants' suggestion that a thorough dialogue among all the affected parties would be the best course toward resolution has been dismissed.

2. Golf Realty Fund proposes an unsafe conflict zone within the Club's recreational core that introduces high-traffic areas into the center of club facilities visited daily by families.

The plans submitted to the City do not merely remodel a private club. They change the way this entire recreational area would function on a daily basis. Instead of keeping vehicular circulation at the perimeter, the proposed design pulls vehicle movement into the same part of the site where members and their families naturally move back and forth between the tennis courts, the pickleball courts, the bungalow area, the food truck location, and the pool and fitness complex.

That matters because this part of the Club is not a static space. It is one of the most active family areas on the property. During a recent tennis tournament, I watched my own three children-ages 8, 6, and 3—consistently move among the courts, the fitness center, the pool, and the food truck area. Children were running back and forth for smoothies, food, and breaks between matches. Parents and members were doing the same thing. That pattern of movement is not unusual; it is exactly how this area of the Club is actually used.

The City would never design one of its own recreational spaces this way. In publicly used Huntington Beach recreation areas, vehicular circulation is kept at the edges, while the interior is reserved for fields, courts, trails, playgrounds, and gathering space. That is not accidental. It Page | 5
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
reflects a basic safety judgment: where children and families are moving freely, cars should not be routed through the middle of the activity zone.

Huntington
Contral Park Library Hentington Beach CONTA PAN.

Parking Central Park/Secret Carden
base benear Serve
Vehicular Access
HDOC
Parking 43,"
& Farking
HBSC Recreations
Parking

CENTRAL PARK
→ BASEBALL/SOFTBALL FIELDS He a

TURF FIELDS
Gold | ARENA FIELD Recreation
• GRASS FIELDS

BATTING CAGES

SNACK BAR / BATHROOMS

PLAY GROUND
• HESC OFFICE
Vehicular Access
& Parking
Huntington Beach park design consistently places vehicular circulation at the perimeter, while interior space is reserved for active recreation. This separation reflects a fundamental safety principle: where children and families are moving freely, vehicles are kept out of the activity zone.

The project plans submitted here do the opposite. They create a conflict zone where ordinary member movement intersects with internal vehicular circulation serving both lodging- related traffic and everyday member parking activity. The internal road does not simply pass near the courtsit runs directly through the recreational area and includes more than thirty parking spaces that will attract regular member use. The issue is not whether a carefil adult can look both ways and cross. The issue is whether an active tennis and pickleball environment used by children, teens, and families should be redesigned to require exactly that kind of vigilance in the first place.

The risk is particularly acute at the pickleball courts. Under the current layout, the pickleball couts sit adjacent to one another, and weekly ladder events regularly utilize all eight pickleball courts (four in each court bank). During those events, players continuously rotate between the two courts based on wins and losses. Under the proposed plan, the internal road would run between the two courts that are currently adjacent, meaning that players participating Page |6
57 EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
in these events would be required to cross the roadway repeatedly throughout play. That repeated crossing patter—by adults focused on competition and movement, not vehicle traffic-creates an additional, foreseeable point of conflict between pedestrians and vehicles.

The submitted plan itself shows that the natural path of travel from the heart of the tennis and pickleball courts to the food truck and pool cuts directly across the internal drive and circulation area tied to the bungalow component. In the real world, children do not stop at neat crossing points and wait for vehicles. They run where they have always run. Members move where they have always moved. The danger is therefore not speculative. It is foreseeable on the face of the design.

FOOD TRJCK
(NCT A PART)
LAKE

NAYACAVA
165
RANCHO

VALENCIA

CASA NEW FITNESS /

PALMERO LOFT BUILGING
• 167

ACKLEBAL & PARKING SIALIS
Proposed site plan showing the internal roadway and parking area ("Conflict Zone") bisecting the Club's primary tennis and pickleball facilities, where regular pedestrian movement— particularly by children and players rotating between courts—intersects directly with vehicular traffic.

The economic justification for introducing this risk has also shifted. At Golf Realty Fund's presentation on Friday, January 23, 2026, members were told that bungalow revenue was necessary to fund the pool and fitness improvements. Later, Golf Realty Fund represented to the Council that it has sufficient funds to build and maintain those improvements even if the Page |7
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
Costa Mesa, CA 92626

ENENSTEIN PHAM GLASS
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
aggressive revenue projections tied to the bungalow and loft component do not materialize. By Golf Realty Fund's own later account, it does not need this additional revenue stream to construct and maintain the facilities. If that is true, then the question for the Council is not whether more revenue would be desirable. The question is whether this added safety risk is worth the cost. It is not.

The concern becomes even more serious because Camaraderie Clubs has already stated that it will not manage the lodging facilities. That means a third party will do so. A third-party lodging operation brings with it its own traffic patterns: guest arrivals and departures, deliveries, rideshare traffic, off-site food runs, and trips for alcohol and other services that are not necessarily integrated with Club operations, including when dining facilities are closed (e.g Mondays). These risks are compounded by the fact that members themselves will use the same internal circulation area for parking and access to the tennis and pickleball facilities, further increasing vehicle volume in the same environment where children and members are walking and running between athletic and pool facilities. And in each and every one of these scenarios, the Council should assume alcohol will be consumed.

The timing of this application only heightens the concern. Golf Realty Fund appears to be trying to push this project through because it is running out of time under its own contractual obligations, which may expose it to financial consequences. But a private deadline is not a legal basis to shortcut public safety review. The fact that the owner may feel urgency is a reason for the Council to slow down, not a reason to approve an incomplete and under-analyzed design.

A comprehensive, independent safety study must be completed. At a minimum, that study should evaluate pedestrian circulation, child movement patterns, vehicle conflict points, visibility and sightlines, construction-phase hazards, and the operational risks associated with the bungalow and loft component. Without that work, approval would be premature.

The City would never route an internal lodging-access road through one of its own active recreational spaces without rigorous safety analysis. It should not permit that result here simply because the project is privately proposed. The stakes are high. If a child is struck by a vehicle in a conflict zone the plans themselves create, the resulting liability exposure would be extraordinary. As a trial lawyer, I view the owner, the operator, and the City as the approving authority as obvious defendants in that scenario, and the exposure could exceed $100 million in a catastrophic injury case. That outcome is not worth a minor, unnecessary revenue stream. And it can only even be argued to be worth the risk if a comprehensive safety study is done first.

Page 18 ends

EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]

3. The proposed plan will have additional adverse effects on the Club's tennis program and daily operations, and if the back courts are not lit, tennis will wither at the Club.

Beyond the serious safety concerns addressed above, the proposed project would also materially impair the Club's tennis and pickleball program and its broader day-to-day operations.

First, the project threatens the viability of nighttime tennis at the Club. As the proposed plan makes clear, the six back courts at the far western end of the property become critically important if three existing lit courts are removed. If those back courts cannot be lit, the Club will effectively go from seven lit courts to only four. That reduction would fundamentally alter the Club's evening tennis program and, in practical terms, could cause tennis at the Club to wither.

Most notably, it would jeopardize some of the Club's some of the most popular organized evening events, including Men's Night and Ladies' Night, where large groups of players participate in round-robin doubles. The junior program, which goes until 7:00 p.m. PST, would also be jeopardized. For many members, those events are the core of the Club's tennis culture and one of the principal reasons they remain active members.

Any loss of courts must be tethered to the back courts being capable of lawful nighttime use. At present, however, the problem is that the prior conditional use permit associated with those courts reportedly does not allow lighting because of their proximity to neighboring homes. (Exhibit B.) Golf Realty Fund appears to be exploring technological solutions to reduce light spill, but the practical reality remains the same: nearby homeowners would be looking at illuminated courts on a nightly basis. That issue should not be ignored or deferred. It should be confronted directly now because, without a realistic and enforceable solution, the project substantially diminishes the Club's ability to function as a tennis facility.

Second, the elimination of three tennis courts will materially affect daytime operations as well. The Club's tennis program is not limited to casual drop-in use. It supports numerous teams, private lessons, daily junior programs, clinics, and organized member play throughout the week.

While no club can honestly claim that every court is full at every hour of every day, that is not the standard. The relevant question is whether the reduction in court inventory will impair operations during the hours that matter most. It plainly will. Peak usage periods will be squeezed.

Team practices and matches will be harder to schedule. Private instruction and junior programming will face greater competition for court time. The junior program in particular is a meaningful asset to the Club, run by a strong professional staff and designed to develop high- level young players. Orange County has already produced elite junior talent, and there is no reason that program should be diminished by a redevelopment plan that prioritizes lodging over courts.

Page l9
EPG-BLAW Orange County Office
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ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
GUTENPLAN & BOLLING LLP (714) 292-0262
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Jesse K. Bolling
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[email protected]
Third, Golf Realty Fund has represented that the courts will remain open during construction. On the present record, however, it is difficult to see how that can occur in a safe and functional way. The project already proposes to remove courts, insert internal circulation, and carry out major construction immediately adjacent to active recreational use. If the road and bungalow components were eliminated, there would at least be a greater possibility of preserving meaningful tennis operations during construction. But under the current design, the notion that children can safely attend junior camp, that coaches can conduct lessons, and that teams can play normally while roads are being paved and heavy construction is underway has not been substantiated. The Council should not simply assume that normal Club operations can continue through a prolonged and invasive construction process without a detailed, credible operational plan.

Taken together, these impacts are not secondary or incidental. They go to the heart of what The Huntington Club is and how it functions. This is not merely a question of replacing old facilities with new ones. It is a question of whether the Club's tennis community, junior development program, and nighttime member culture will survive the project in anything like their present form. On the current record, there is substantial reason to doubt that they will.

4. The City's Zoning Code does not allow people to sleep overnight in recreational space.

The Council's discretion under the Conditional Use Permit process is not unlimited. A CUP is not a blank check to authorize any use the City wishes to allow based on generalized notions of "good cause." Under the Huntington Beach Zoning Code, a CUP may be granted only where the Council can make the required findings, including that the proposed use is consistent with the General Plan and all applicable requirements of the Municipal Code. Most importantly, the Council must be able to find that the proposed use will comply with the provisions of the base district and other applicable provisions of the Zoning Code. If those findings cannot be made, denial is required.

That requirement has procedural consequences here. The Council must be able to support each required finding with substantial evidence in the administrative record at the time of approval. Where material issues—-such as whether the project can be operated safely—remain unresolved, the Council cannot defer that determination to a future study. Absent substantial evidence demonstrating that the project can be operated safely, the Council cannot make the findings necessary to approve the Conditional Use Permit.

That is the core issue here. The subject property is in the OS-PR district. Huntington Beach's zoning regulations provide that uses not listed in a district's land use controls are prohibited. In OS-PR, "Park & Recreation Facilities" may be allowed with a CUP, and certain Page | 10
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ancillary uses may be permitted in limited form, but the Code does not separately list general lodging or visitor accommodations as an authorized OS-PR use. From a legal perspective, the threshold question, therefore, is not whether the bungalow and loft component may be desirable or financially beneficial. The threshold question is whether that lodging component is actually an authorized use in OS-PR at all.

The City's own use-classification scheme sharpens that issue. Huntington Beach distinguishes between "Clubs and Lodges," on the one hand, and "Visitor Accommodations," on the other. "Clubs and Lodges" are recreational or social facilities primarily for members or guests. "Visitor Accommodations" are separately defined lodging uses, including hotels, motels, and similar short-term occupancy arrangements. The Code thus does not treat private club use and overnight lodging use as interchangeable. They are different use categories. That distinction matters here because the proposed bungalow and loft component appears, in substance, to function as a lodging use rather than merely as part of the Club's traditional recreational operations.

Accordingly, if the City's position is that the bungalow and loft component constitutes a lodging or visitor-accommodation use, then the Council should identify precisely where that use is permitted or conditionally permitted in OS-PR. If the City's position is instead that the lodging component is merely accessory or incidental to the recreational use, then the Council should explain how overnight accommodations are truly subordinate to, and customarily associated with, the principal recreational use of the site, rather than a separate revenue-generating use added to the property. Either way, the Council must still make the finding that the project complies with the base district. A CUP does not eliminate that requirement.

There is a further problem. The Huntington Beach Code contemplates that, if a proposed use cannot be clearly classified within an existing use category, the answer is not simply to approve it by CUP anyway. Rather, the Code assigns use-classification decisions to the Director and, where no existing classification clearly applies, the proper remedy is a change to the zoning text. In other words, the City may not use the CUP process to create a new hybrid use that the Code does not presently authorize.

For that reason, the Council should require a clear answer to a simple question before acting: what, exactly, is the legal use classification for the proposed bungalows and lofts, and where is that use authorized in OS-PR? And critically, the Council must also be able to determine-based on substantial evidence-that the project, as designed, can be operated safely before any approval is granted. Unless and until those questions are answered in a manner that allows the Council to make the required findings, approval of the lodging component would be legally vulnerable and premature.

Page |11
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Costa Mesa, CA 92626
ENENSTEIN PHAM GLASS (714) 292-0262

GUTENPLAN & BOLLING LLP
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Jesse K. Bolling
Managing Partner
[email protected]

5. There is no justifiable basis to move forward with the proposed plan unless and until, at a minimum, a comprehensive safety study is conducted.

For all of these reasons, there is no justifiable basis for the Council to move forward with the proposed plan unless and until a comprehensive safety study is completed. Without that study, the Council lacks substantial evidence necessary to determine that the project can be operated safely and therefore cannot make the findings required for approval of the Conditional Use Permit.

We therefore respectfully request that the Council continue this matter for at least 60 days so that the proposed project can be evaluated on a more complete and reliable record Respectfully Submitted,

ENENSTEIN PHAM GLASS GUTENPLAN & BOLLING, LLP
By:

Jesse K. Bolling, Esq.

Cc:

Casey McKeon, Mayor: [email protected]
• Butch Twining, Mayor Pro Tem: [email protected] Gracey Van Der Mark, Councilmember: Gracey. [email protected] • Pat Burns, Councilmember: [email protected]
• Don Kennedy, Councilmember: [email protected] • Chad Williams, Councilmember; Chad. [email protected] Andrew Gruel, Councilmember: Andrew. [email protected] Page |12

EXHIBIT A
Julie Ann Crandall
The Huntington Club < [email protected]>
Saturday, February 7, 2026 8:11 AM
To: Jesse Bolling
Subiect: Camaraderie Clubs Clarification ~ Townhall Meeting Saturday, February 7, 2026
Dear Members of The Huntington Club,
It has been two weeks since Golf Realty Fund and Johnathon Baily held a town hall meeting at the Huntington Club to discuss the New Performance Center Building, new pool, and bungalow project. Over the past two weeks, we have noticed some confusion regarding the relationship between the tenant of THC (Camaraderie Clubs) and the landlord/property owner (Golf Realty Fund). To clarify, Camaraderie Clubs pays rent to Golf Realty Fund through a triple net lease. This lease outlines obligations for capital expenditures for both the tenant and the property owner. So far, Camaraderie Clubs has met and exceeded its capital obligations. However, as the property owner mentioned in the planning commission meeting on January 27th, they have yet to fulfill their obligations. In the past six years since the lease was signed, Golf Realty Fund is still in the process of obtaining the necessary approvals for the project.

In addition, Camaraderie clubs would like to clarify the following misconceptions we have heard from the members.

1.Johnathon Baily represents Golf Reality Trust and is not affiliated with Camaraderie Clubs or involved in our operational decisions regarding THC. We want to make it very clear: WE DO NOT ENDORSE HIS STATEMENT MADE DURING THE TOWN HALL MEETING, where he said, "WE ARE COMFORTABLE AND CONFIDENT IN THE

ECONOMICS, AND YOU GUYS ARE FREE TO SPEAK WITH YOUR WALLETS AND SAY, 'HEY, NO, THIS CLUB ISN'T FOR US; WE WILL LEAVE."' Jonathon Baily and Golf Realty Trust do not have the authority to make such statements to you, our valued customers, and members of THC. As made evident by the recent survey, we value member feedback and will use that feedback to frame our capital investment and operational opportunities. We deeply value your membership and thank you for choosing to be a part of our Club.

2. Currently, Camaraderie Clubs has no financial interest or contractual obligation to manage the bungalows and loft apartments proposed by Golf Realty Fund. Camaraderie Clubs has been steadfast in its efforts to compel the landlord to honor its obligations to construct a new swimming pool and upgrade the fitness facilities over the past 6 years.

The ownership of The Huntington Club is dedicated to the ongoing improvement of the Club and its facilities, aiming to preserve and enhance the experience enjoyed by its members.
1 We will always advocate for the interests of the Club and its members with conviction and respect. Please direct any questions about the project to Golf Realty Fund as they will be best equipped to answer questions about their project.

Sincerely,
Travis Brasher - Managing Partner, Camaraderie Clubs
Joe Saikali - General Manager
6501 Palm Ave. Huntington Beach, CA 92648 714.536.8866
This message was sent to Jesse Bolling <[email protected]> by Huntington Club Click here to unsubscribe from further communications

Huntington Beach Planning Commission
P.O. BOX 190 . CALIFORNIA 92648
August 6, 1985
Huntington Beach Company
2110 Main Street
Huntington Beach, CA 92648
SUBJECT:: CONDITIONAL USE PERMIT NO. 85-25/COASTAL DEVELOPMENT PERMIT NO. 85-19/NEGATIVE DECLARATION NO.85-26
REQUEST: To germit construction
of 6 tennis courts.

LOCATION: East side of Palm Ave.
approximately 300 ft.
south of Cherryhill Ave.

FINDINGS FOR APPROVAL CONDITIONAL USE PERMIT NO. 85-25:

1. land uses and in conformance with the General Plan policies because the facility will become an integral part of the existing Seacliff Country Club.

2. The proposed tennis courts will not be detrimental to the genetel health, welfare, safety and convenience of persons residing or working in the neighborhood because the facility will have hours of operation limited to the daytime:

3. The iocation, site layout, and design of the proposed development. does properly adapt the structure to streets, driveways and other uses in a harmonious manner.

FINDINGS FOR APPROVAL COASTAL DEVELOPMENT PERMIT NO. 85-2:

1. The proposal for 6 tennis courts is consistent with the City Coastal Zone suffix as well as other provisions of the
Huntington Beach Ordinance code applicable to the property; and conforms with the plans, policies, reguirements and standards of the City's Coastal Land Use Plan.

2. The proposed development can be provided with infrastructure in manner that is consistent with the Coastal Land Use Plan.

3. The proposed development conforms with the public access and public recreation policies of Chapter 3 of the California Coastal Act.

CONDITIONS OF APPROVAL CONDITIONAL USE PERMIT NO. 85-25:

1. The site plan dated May 22, 1985 shall be the, approved layout.

2. Prior to issuance of building permits, the applicant shall submit a landscape and irrigation plan to the Department of Development Services and Department of Public Works for review and approval.

3. The tennis courts hours of operation shall be limited to daytime hours. No artificial lighting shall be permitted.

4. A copy of the tennis club membership/entry requirements shall be submitted to the Department of Development Services to assure the membership/use is limited to country club members.

5. Al1 building spoils, such a unused lumber, wire, pipe and surplus or unusable materials, shall be disposed of at an off-site facility equipped to handle them.

I hereby certify that conditional Use Permit No. 85-25, Coastal Development Permit No. 85-19 and Negative Declaration No. 85-26 was approved by the Planning Commission of the City of Huntington Beach on August 5, '1985 by the foregoing citations and conditions.

Sincerely,
Inena With / fir
James W. Palin
Secretary
Planning Commission
JWP: 1p
(3037đ(3)
From: Levin, Shannon
To: Villasenor, Jennifer
Subject: FW: THC BUNGALOW PROJECT
Date: Monday, April 20, 2026 10:07:23 AM
Attachments: 2026.04.10 Letter to HBCC (EINAL).pdf
From: Robin Brunner <[email protected]>
Sent: Saturday, April 18, 2026 2:00 PM
To: CITY COUNCIL (INCL. CMO STAFF) <[email protected]> Subject: THC BUNGALOW PROJECT
[Some people who received this message don't often get email from [email protected]. Learn why this is important at https://aka.ms/LearnAboutSenderldentification]
Dear City Council,
I'm a longtime member of the Huntington Club (23 years) and a neighbor that owns a house behind the back tennis courts for 28 years. I share the beliefs and concerns in the attached letter.

We walk over to enjoy the club and are alarmed at the possible future placement of a road dividing the club in half. I can't imagine who thought that was a safe decision for children and adults alike. There must be another way to make this safer for the community and keep the relaxed club flow that is there now.

I'm also concerned about the talk of lighting the back courts. We paid millions of dollars for a home with the assurance these courts could never be lit. We enjoy countless evenings outside relaxing in peace and fear there's a possibility of that being taken from us. I understand there is new technology of how courts can be lit with minimal light pollution. However, it's not only the lights that become an issue with playing after dark. Loud noises including screaming, swearing and loud music is a regular occurrence during daytime play and during night time play on current lit courts. It's easy to witness by stopping by the club any given evening to hear.

It's one thing when it's closer to the club, but when our home is 6 feet from the courts it becomes very disruptive.

One last concern regarding the bungalows. We've attended all the council meetings and heard all the talk of who is allowed to use these bungalows... I have not heard if weddings booked at the club will be able to use them. Weddings are a big money maker for the club and could see them selling the bungalows as a package for the bride to get ready and wedding party to stay and/or have parties. Has this been discussed? What would stop the club from charging an extra amount to book weddings (i.e. bungalow package) to make these people temporary members as a loop hole to allow them access to the bungalows. As a neighbor living close to these, I'm very concerned over the noise and security of our neighborhood as well.

Thanks for taking the time to read my concerns and thank you for keeping our city a wonderful and safe place to live.

Robin Brunner
6312 Turnberry Cir HB
714.756.0943
EPG-BLAW Orange County Office
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ENENSTEIN PHAM GLASS (714) 292-0262

GUTENPLAN & BOLLING LLP
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Jesse K. Bolling
Managing Partner
[email protected]
April 10, 2026

SENT VIA EMAIL
Huntington Beach City Council
2000 Main Street
Huntington Beach, CA 92648
Email: [email protected]
Re: April 21, 2026 Hearing re The Huntington Club Remodel and Bungalows Dear Mayor and Members of the City Council,
I submit this letter in two capacities: (1) as pro bono counsel to appellants Cheryl Gates, Susan Ridgeway, and Douglas Scott Warren; and (2) as a current member of The Huntington Club with a direct interest in the continued availability and character of its facilities. I am an active golf and tennis member of the Club, and my family and I regularly participate in its athletic programs.

To summarize, Golf Realty Fund has a reported contractual obligation of approximately $10 million to $15 million to complete improvements at the Club. In structuring that arrangement, Golf Realty Fund retained control over the buildout, positioning itself to convert that obligation into an additional revenue stream through hotel-like lodging for "members and their guests." At the most recent hearing, Golf Realty Fund implied that it does not need that additional revenue to fund the renovations; it simply seeks an additional revenue stream from the property.

Standing alone, that economic choice would not necessarily be problematic. The problem is the particular plan Golf Realty Fund has chosen to pursue. As proposed, it introduces serious safety risks for Club members and their families. Members and their children move constantly through this area circulating among the courts, the pool, the fitness center, and food service locations-often in unpredictable patterns that are inherent to an active recreational environment.

The proposed design forces those same children to cross an internal roadway serving both lodging-related traffic and everyday member vehicle traffic, as members will naturally use that area for convenient parking in the more than thirty new parking spaces located directly adjacent to the tennis and pickleball courts. The plan therefore concentrates vehicle traffic in the exact space where children and families are moving on foot.

This creates a direct and foreseeable conflict between vehicles and pedestrians. That risk is compounded by the nature of the proposed use, which will introduce guest traffic, ride-share Page |1
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ENENSTEIN PHAM GLASS
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activity, deliveries, and the potential for alcohol-related driving into the same space where children are playing and moving freely. The foreseeable result is not minor or theoretical-it is the risk of serious injury in a setting that has always functioned as a protected recreational environment. Up until now, Golf Realty Fund has asked the Council to allow that plan to proceed without the benefit of a comprehensive safety study, ostensibly because its contractual deadline to complete these improvements will expire in early May 2026.

That private timing pressure is no substitute for a complete and reliable public record, particularly where the safety of Huntington Beach families who use what many regard as the City's crown jewel is at stake. More time is needed to determine whether this design can be made safe. Without that work, approval would expose Golf Realty Fund, its tenant, and the City of Huntington Beach to substantial liability if a member—or worse, a child—is injured.

In good faith discussions between the Appellants and Golf Realty Fund, the concept of a comprehensive safety study has been raised. Golf Realty Fund appears amenable to conducting such a study, but there remains a critical procedural issue. It is my understanding that Golf Realty Fund prefers that the safety study be imposed along with approval of the plan. We respectfully submit that this approach is improper under the circumstances and should be rejected.

The Council should instead retain jurisdiction over this matter and require completion of the safety study before any approval is granted. The Appellants' ability to advocate on behalf of the Club's membership is tied to this appeal. As a non-equity club, members do not control the property; their voice is exercised through this process and through the Council's oversight. If the project is approved subject to later study, that voice is effectively extinguished, and future decisions regarding safety, design, and implementation will be left to private entities whose interests may not align with those of the citizens most directly affected Moreover, the Council cannot make the required findings in support of approval without first establishing, based on substantial evidence, that the project can be operated safely. Nor may the Council defer that determination to a future study, as doing so would leave a critical component of the approval unsupported by the administrative record at the time of decision. Where material safety concerns remain unresolved, approval would be premature because the record would not contain substantial evidence sufficient to support the findings required for a Conditional Use Permit.

Based on the foregoing, we respectfully request that the Council continue this hearing for at least 60 days so that the proposed plan can be more fully evaluated, particularly in light of the serious safety concerns created by placing a roadway with significant parking capacity in the middle of the Club's tennis and pickleball facilities. The Council should direct Golf Realty Fund to conduct a comprehensive safety study by an independent consultant approved by the Council Page | 2
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ENENSTEIN PHAM GLASS Costa Mesa, CA 92626
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and Appellants. Once completed, that study should be circulated for review and comment, and only then should the Council determine whether the project, as proposed, is safe enough for approval.

1. The factual background demonstrates no evaluation of safety concerns amid contractual time pressure and a breakdown between owner and operator.

The factual statements set forth in this letter are based on a combination of publicly available materials and information obtained through discussions with individuals represented to have knowledge of the operations, agreements, and history of the Club. Except where expressly supported by cited documents or witnessed by me or my clients, these statements are provided on an informational basis only. I therefore do not present these statements as adjudicated fact, but rather as contextual background to assist the Council in understanding the circumstances surrounding the proposed project.
• The entity operating the Club, Camaraderie Clubs, is led by Travis Brasher, who previously served as a golf professional at the Club when it operated under its former name, Seacliff Country Club. Mr. Brasher founded the Travis Mathew apparel brand, which was later sold, and has since returned, now as the tenant overseeing operations at the Club, rebranding it as The Huntington Club.
• Prior to the COVID-19 pandemic, Camaraderie Clubs entered into a long-term lease agreement-reported to be approximately 30 years in duration—with the property owner, Golf Realty Fund, under which it operates the Club.
• As part of that long-term lease arrangement, both Camaraderie Clubs and Golf Realty Fund are understood to have contemplated and committed to significant capital improvements to the Club's infrastructure in recognition of the age and condition of the existing facilities.
• Camaraderie Clubs has invested substantial capital into the Club, reported to be in the range of approximately $8 million to $10 million.
• Golf Realty Fund, as property owner, is likewise understood to have committed to a significant capital contribution toward redevelopment of the property, reported to be in the range of approximately $10 million to $15 million, none of which has yet been deployed. The lease or related agreements reportedly include a deadline for completion of those improvements in early May 2026. Based on that reported deadline, Golf Realty Fund appears to be under substantial time pressure to obtain approvals and move the project forward.

Page 13 ends

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ENENSTEIN PHAM GLASS
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GUTENPLAN & BOLLING LLP
epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
• The proposed project includes demolition and replacement of fitness and swimming facilities, as well as the addition of new structures, including bungalow units, loft-style accommodations, and related site improvements. More specifically, the project includes (i) conversion or construction of second-floor space within a proposed fitness facility into loft-style accommodations and (ii) construction of detached bungalow-style units on the property. The project would also eliminate three lit tennis courts used for nighttime play and divide the tennis and pickleball facilities with a large internal road serving the bungalow component, including more than thirty parking spaces located within that internal circulation area.
• Golf Realty Fund also submitted an alternative concept involving the addition of a third story to the fitness facility without including the bungalow lodging component.

According to information provided by a City employee, that submission was marked "Incomplete" because it did not contain sufficient detail to determine whether it complied with applicable height limitations. Even if that proposal ultimately raised height- compliance issues, the City retains discretion to evaluate whether such limitations could be addressed or modified through appropriate planning mechanisms. A plan without an internal roadway through the recreational core, therefore, is theoretically possible.

At a presentation by Golf Realty Fund to Club members on Friday, January 23, 2026, at which Camaraderie Clubs was absent, a representative of Golf Realty Fund told members that revenue from the bungalow component was necessary to fund reconstruction of the pool and fitness improvements. Golf Realty Fund has also provided the City with aggressive revenue projections for these rental units, particularly in light of the competition from multiple high-end beachfront hotels in the area. In subsequent representations to the City Council, however, Golf Realty Fund indicated that it has sufficient financial resources to build and maintain the proposed improvements even if those revenue projections were not realized. Those two positions are difficult to reconcile and bear directly on whether the bungalow component is truly necessary or instead an added revenue stream being pursued despite the costs it imposes. • I received a written communication distributed by Camaraderie Clubs to Club members dated February 7, 2026 (Exhibit A). In that communication, Camaraderie Clubs expressly states that it "has no financial interest or contractual obligation to manage the bungalows and loft apartments proposed by Golf Realty Fund." • The same communication also alludes to the statements made by Golf Realty Fund during its town hall meeting with Club members concerning the proposed project. At that meeting, Golf Realty Fund stated that members were "free to speak with [their] wallets" in response to the proposed changes.

Page |4
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Costa Mesa, CA 92626
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Managing Partner
[email protected]
• The February 7, 2026 communication further clarifies that Camaraderie Clubs does not endorse that statement and distinguishes its operational role from that of the property owner with respect to the proposed development.
• It is anticipated that, if the contemplated redevelopment obligations are not satisfied within the early May 2026 timeframe, a dispute between landlord and tenant may arise, potentially resulting in litigation. This point is noted solely to provide context regarding the relationship between landlord and tenant, which, from my perspective, is troubling. • In negotiations among the parties, there has been a general refusal to have all sides sit down together to resolve their issues. Golf Realty Fund has asserted that Camaraderie Clubs contractually agreed to limit or waive its ability to object to certain aspects of the redevelopment plan, including the bungalow component. I have learned nothing that contradicts that assertion. At the town hall meeting, Golf Realty Fund flashed a specific portion of the lease when making that point to members, but I was not provided with a sufficient opportunity to review that provision in full. Further, Appellants' suggestion that a thorough dialogue among all the affected parties would be the best course toward resolution has been dismissed.

2. Golf Realty Fund proposes an unsafe conflict zone within the Club's recreational core that introduces high-traffic areas into the center of club facilities visited daily by families.

The plans submitted to the City do not merely remodel a private club. They change the way this entire recreational area would function on a daily basis. Instead of keeping vehicular circulation at the perimeter, the proposed design pulls vehicle movement into the same part of the site where members and their families naturally move back and forth between the tennis courts, the pickleball courts, the bungalow area, the food truck location, and the pool and fitness complex.

That matters because this part of the Club is not a static space. It is one of the most active family areas on the property. During a recent tennis tournament, I watched my own three children-ages 8, 6, and 3-consistently move among the courts, the fitness center, the pool, and the food truck area. Children were running back and forth for smoothies, food, and breaks between matches. Parents and members were doing the same thing. That pattern of movement is not unusual; it is exactly how this area of the Club is actually used.

The City would never design one of its own recreational spaces this way. In publicly used Huntington Beach recreation areas, vehicular circulation is kept at the edges, while the interior is reserved for fields, courts, trails, playgrounds, and gathering space. That is not accidental. It Page |5
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Jesse K. Bolling
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reflects a basic safety judgment: where children and families are moving freely, cars should not be routed through the middle of the activity zone.

Huntington
Contral Park Library antington Bear
Parking entral Park/Secret Garde
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Vehicular Access HODC
& Parking Parking 43,*
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West
• BASEBALL/SOFTBALL FIELDS
Cereal Pal Dr Faltert Ase

TURF FIELDS
Gold Secret Carder
ARENA FIELD Recreation

GRASS FIELDS

CANO CAGES
) SNACK BAR / BATHROOMS

PLAY GROUND
....
• HESC OFFICE
Vehicular Access
Huntington Beach park design consistently places vehicular circulation at the perimeter, while interior space is reserved for active recreation. This separation reflects a fumdamental safety principle: where children and families are moving freely, vehicles are kept out of the activity cone.

The project plans submitted here do the opposite. They create a conflict zone where ordinary member movement intersects with internal vehicular circulation serving both lodging- related traffic and everyday member parking activity. The internal road does not simply pass near the courts—it runs directly through the recreational area and includes more than thirty look netpays had cross. The issuels wether an a The tens and wheat evil meit can used by children, teens, and families should be redesigned to require exactly that kind of vigilance in the first place.

The risk is particularly acute at the pickleball courts. Under the current layout, the pickleball courts sit adjacent to one another, and weekly ladder events regularly utilize all eight pickleball courts (four in each court bank). During those events, players continuously rotate between the two courts based on wins and losses. Under the proposed plan, the internal road would run between the two courts that are currently adjacent, meaning that players participating

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in these events would be required to cross the roadway repeatedly throughout play. That repeated crossing pattern-by adults focused on competition and movement, not vehicle traffic-creates an additional, foreseeable point of conflict between pedestrians and vehicles.

The submitted plan itself shows that the natural path of travel from the heart of the tennis and pickleball courts to the food truck and pool cuts directly across the internal drive and circulation area tied to the bungalow component. In the real world, children do not stop at neat crossing points and wait for vehicles. They run where they have always run. Members move where they have always moved. The danger is therefore not speculative. It is foreseeable on the face of the design.

FOOD TRUCK
(NCT A PART)
LAKE

HAYACAVA
.165
RANCHO

VALENCIA

NEW FITNESS /
CALA

PALMERO LOFT BUILEING
Conflict Zoue
8 'PARKHO STALIS,
Proposed site plan showing the internal roadway and parking area ("Conflict Zone") bisecting the Chib's primary tennis and pickleball facilities, where regular pedestrian movement— particularly by children and players rotating between courts—intersects directly with vehicular traffic.

The economic justification for introducing this risk has also shifted. At Golf Realty Fund's presentation on Friday, January 23, 2026, members were told that bungalow revenue was necessary to fund the pool and fitness improvements. Later, Golf Realty Fund represented to the Council that it has sufficient funds to build and maintain those improvements even if the Page |7
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aggressive revenue projections tied to the bungalow and loft component do not materialize. By Golf Realty Fund's own later account, it does not need this additional revenue stream to construct and maintain the facilities. If that is true, then the question for the Council is not whether more revenue would be desirable. The question is whether this added safety risk is worth the cost. It is not.

The concern becomes even more serious because Camaraderie Clubs has already stated that it will not manage the lodging facilities. That means a third party will do so. A third-party lodging operation brings with it its own traffic patterns: guest arrivals and departures, deliveries, rideshare traffic, off-site food runs, and trips for alcohol and other services that are not necessarily integrated with Club operations, including when dining facilities are closed (e.g.

Mondays). These risks are compounded by the fact that members themselves will use the same internal circulation area for parking and access to the tennis and pickleball facilities, further increasing vehicle volume in the same environment where children and members are walking and running between athletic and pool facilities. And in each and every one of these scenarios, the Council should assume alcohol will be consumed.

The timing of this application only heightens the concern. Golf Realty Fund appears to be trying to push this project through because it is running out of time under its own contractual obligations, which may expose it to financial consequences. But a private deadline is not a legal basis to shortcut public safety review. The fact that the owner may feel urgency is a reason for the Council to slow down, not a reason to approve an incomplete and under-analyzed design.

A comprehensive, independent safety study must be completed. At a minimum, that study should evaluate pedestrian circulation, child movement patterns, vehicle conflict points, visibility and sightlines, construction-phase hazards, and the operational risks associated with the bungalow and loft component. Without that work, approval would be premature.

The City would never route an internal lodging-access road through one of its own active recreational spaces without rigorous safety analysis. It should not permit that result here simply because the project is privately proposed. The stakes are high. If a child is struck by a vehicle in a conflict zone the plans themselves create, the resulting liability exposure would be extraordinary. As a trial lawyer, I view the owner, the operator, and the City as the approving authority as obvious defendants in that scenario, and the exposure could exceed $100 million in a catastrophic injury case. That outcome is not worth a minor, unnecessary revenue stream. And it can only even be argued to be worth the risk if a comprehensive safety study is done first.

Page | 8
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3. The proposed plan will have additional adverse effects on the Club's tennis program and daily operations, and if the back courts are not lit, tennis will wither at the Club.

Beyond the serious safety concerns addressed above, the proposed project would also materially impair the Club's tennis and pickleball program and its broader day-to-day operations.

First, the project threatens the viability of nighttime tennis at the Club. As the proposed plan makes clear, the six back courts at the far western end of the property become critically important if three existing lit courts are removed. If those back courts cannot be lit, the Club will effectively go from seven lit courts to only four. That reduction would fundamentally alter the Club's evening tennis program and, in practical terms, could cause tennis at the Club to wither.

Most notably, it would jeopardize some of the Club's some of the most popular organized evening events, including Men's Night and Ladies' Night, where large groups of players participate in round-robin doubles. The junior program, which goes until 7:00 p.m. PST, would also be jeopardized. For many members, those events are the core of the Club's tennis culture and one of the principal reasons they remain active members.

Any loss of courts must be tethered to the back courts being capable of lawful nighttime use. At present, however, the problem is that the prior conditional use permit associated with those courts reportedly does not allow lighting because of their proximity to neighboring homes. (Exhibit B.) Golf Realty Fund appears to be exploring technological solutions to reduce light spill, but the practical reality remains the same: nearby homeowners would be looking at illuminated courts on a nightly basis. That issue should not be ignored or deferred. It should be confronted directly now because, without a realistic and enforceable solution, the project substantially diminishes the Club's ability to function as a tennis facility.

Second, the elimination of three tennis courts will materially affect daytime operations as well. The Club's tennis program is not limited to casual drop-in use. It supports numerous teams, private lessons, daily junior programs, clinics, and organized member play throughout the week.

While no club can honestly claim that every court is full at every hour of every day, that is not the standard. The relevant question is whether the reduction in court inventory will impair operations during the hours that matter most. It plainly will. Peak usage periods will be squeezed.

Team practices and matches will be harder to schedule. Private instruction and junior programming will face greater competition for court time. The junior program in particular is a meaningful asset to the Club, run by a strong professional staff and designed to develop high- level young players. Orange County has already produced elite junior talent, and there is no reason that program should be diminished by a redevelopment plan that prioritizes lodging over courts.

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Third, Golf Realty Fund has represented that the courts will remain open during construction. On the present record, however, it is difficult to see how that can occur in a safe and functional way. The project already proposes to remove courts, insert internal circulation, and carry out major construction immediately adjacent to active recreational use. If the road and bungalow components were eliminated, there would at least be a greater possibility of preserving meaningful tennis operations during construction. But under the current design, the notion that children can safely attend junior camp, that coaches can conduct lessons, and that teams can play normally while roads are being paved and heavy construction is underway has not been substantiated. The Council should not simply assume that normal Club operations can continue through a prolonged and invasive construction process without a detailed, credible operational plan.

Taken together, these impacts are not secondary or incidental. They go to the heart of what The Huntington Club is and how it functions. This is not merely a question of replacing old facilities with new ones. It is a question of whether the Club's tennis community, junior development program, and nighttime member culture will survive the project in anything like their present form. On the current record, there is substantial reason to doubt that they will.

4. The City's Zoning Code does not allow people to sleep overnight in recreational space.

The Council's discretion under the Conditional Use Permit process is not unlimited. A CUP is not a blank check to authorize any use the City wishes to allow based on generalized notions of "good cause." Under the Huntington Beach Zoning Code, a CUP may be granted only where the Council can make the required findings, including that the proposed use is consistent with the General Plan and all applicable requirements of the Municipal Code. Most importantly, the Council must be able to find that the proposed use will comply with the provisions of the base district and other applicable provisions of the Zoning Code. If those findings cannot be made, denial is required.

That requirement has procedural consequences here. The Council must be able to support each required finding with substantial evidence in the administrative record at the time of approval. Where material issues such as whether the project can be operated safely-remain unresolved, the Council cannot defer that determination to a future study. Absent substantial evidence demonstrating that the project can be operated safely, the Council cannot make the findings necessary to approve the Conditional Use Permit.

That is the core issue here. The subject property is in the OS-PR district. Huntington Beach's zoning regulations provide that uses not listed in a district's land use controls are prohibited. In OS-PR, "Park & Recreation Facilities" may be allowed with a CUP, and certain Page | 10
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ancillary uses may be permitted in limited form, but the Code does not separately list general lodging or visitor accommodations as an authorized OS-PR use. From a legal perspective, the threshold question, therefore, is not whether the bungalow and loft component may be desirable or financially beneficial. The threshold question is whether that lodging component is actually an authorized use in OS-PR at all.

The City's own use-classification scheme sharpens that issue. Huntington Beach distinguishes between "Clubs and Lodges," on the one hand, and "Visitor Accommodations," on the other. "Clubs and Lodges" are recreational or social facilities primarily for members or guests. "Visitor Accommodations" are separately defined lodging uses, including hotels, motels, and similar short-term occupancy arrangements. The Code thus does not treat private club use and overnight lodging use as interchangeable. They are different use categories. That distinction matters here because the proposed bungalow and loft component appears, in substance, to function as a lodging use rather than merely as part of the Club's traditional recreational operations.

Accordingly, if the City's position is that the bungalow and loft component constitutes a lodging or visitor-accommodation use, then the Council should identify precisely where that use is permitted or conditionally permitted in OS-PR. If the City's position is instead that the lodging component is merely accessory or incidental to the recreational use, then the Council should explain how overnight accommodations are truly subordinate to, and customarily associated with, the principal recreational use of the site, rather than a separate revenue-generating use added to the property. Either way, the Council must still make the finding that the project complies with the base district. A CUP does not eliminate that requirement.

There is a further problem. The Huntington Beach Code contemplates that, if a proposed use cannot be clearly classified within an existing use category, the answer is not simply to approve it by CUP anyway. Rather, the Code assigns use-classification decisions to the Director and, where no existing classification clearly applies, the proper remedy is a change to the zoning text. In other words, the City may not use the CUP process to create a new hybrid use that the Code does not presently authorize.

For that reason, the Council should require a clear answer to a simple question before acting: what, exactly, is the legal use classification for the proposed bungalows and lofts, and where is that use authorized in OS-PR? And critically, the Council must also be able to determine-based on substantial evidence—that the project, as designed, can be operated safely before any approval is granted. Unless and until those questions are answered in a manner that allows the Council to make the required findings, approval of the lodging component would be legally vulnerable and premature.

Page |11
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5. There is no justifiable basis to move forward with the proposed plan unless and until, at a minimum, a comprehensive safety study is conducted.

For all of these reasons, there is no justifiable basis for the Council to move forward with the proposed plan unless and until a comprehensive safety study is completed. Without that study, the Council lacks substantial evidence necessary to determine that the project can be operated sately and therefore cannot make the findings required for approval of the Conditional Use Permit.

We therefore respectfully request that the Council continue this matter for at least 60 days so that the proposed project can be evaluated on a more complete and reliable record.

Respectfully Submitted,

ENENSTEIN PHAM GLASS GUTENPLAN & BOLLING, LLP
By:

Jesse K. Bolling, Esq.

Cc:
• Casey McKeon, Mayor: [email protected]
Butch Twining, Mayor Pro Tem: Butch. [email protected] • Gracey Van Der Mark, Councilmember: Gracey. [email protected] • Pat Burns, Councilmember: [email protected]
• Don Kennedy, Councilmember: [email protected] • Chad Williams, Councilmember; Chad. [email protected] Andrew Gruel, Councilmember: [email protected] Page | 12

EXHIBIT A
Julie Ann Crandall
From The Huntington Club < [email protected]>
ent Saturday, February 7, 2026 8:11 AM
To: Jesse Bolling
Subject: Camaraderie Clubs Clarification ~ Townhall Meeting Saturday, February 7, 2026
ear Members of The Huntington Cl
It has been two weeks since Golf Realty Fund and Johnathon Baily held a town hall meeting at the Huntington Club to discuss the New Performance Center Building, new pool, and bungalow project. Over the past two weeks, we have noticed some confusion regarding the relationship between the tenant of THC (Camaraderie Clubs) and the landlord/property owner (Golf Realty Fund). To clarify, Camaraderie Clubs pays rent to Golf Realty Fund through a triple net lease. This lease outlines obligations for capital expenditures for both the tenant and the property owner. So far, Camaraderie Clubs has met and exceeded its capital obligations. However, as the property owner mentioned in the planning commission meeting on January 27th, they have yet to fulfill their obligations. In the past six years since the lease was signed, Golf Realty Fund is still in the process of obtaining the necessary approvals for the project.

In addition, Camaraderie clubs would like to clarify the following misconceptions we have heard from the members.

1.Johnathon Baily represents Golf Reality Trust and is not affiliated with Camaraderie Clubs or involved in our operational decisions regarding THC. We want to make it very clear: WE DO NOT ENDORSE HIS STATEMENT MADE DURING THE TOWN HALL MEETING, where he said, "WE ARE COMFORTABLE AND CONFIDENT IN THE

ECONOMICS, AND YOU GUYS ARE FREE TO SPEAK WITH YOUR WALLETS AND SAY, 'HEY, NO, THIS CLUB ISN'T FOR US; WE WILL LEAVE." Jonathon Baily and Golf Realty Trust do not have the authority to make such statements to you, our valued customers, and members of THC. As made evident by the recent survey, we value member feedback and will use that feedback to frame our capital investment and operational opportunities. We deeply value your membership and thank you for choosing to be a part of our Club.

2. Currently, Camaraderie Clubs has no financial interest or contractual obligation to manage the bungalows and loft apartments proposed by Golf Realty Fund. Camaraderie Clubs has been steadfast in its efforts to compel the landlord to honor its obligations to construct a new swimming pool and upgrade the fitness facilities over the past 6 years.

The ownership of The Huntington Club is dedicated to the ongoing improvement of the Club and its facilities, aiming to preserve and enhance the experience enjoyed by its members.

We will always advocate for the interests of the Club and its members with conviction and respect. Please direct any questions about the project to Golf Realty Fund as they will be best equipped to answer questions about their project.

Sincerely,
Travis Brasher - Managing Partner, Camaraderie Clubs
Joe Saikali - General Manager
6501 Palm Ave. Huntington Beach, CA 92648 714.536.8866
This message was sent to Jesse Bolling <[email protected]> by Huntington Club Click here to unsubscribe from further communications

Huntington Beach Planning Commission
P.O. BOX 190 . CALIFORNIA 92648
August 6, 1985
Huntington Beach Company
2110 Main Street
Huntington Beach, CA 92648
SUBJECT: CONDITIONAL USE PERMIT NO. 85-25/COASTAL DEVELOPMENT PERMIT NO. 85-19/NEGATIVE DECLARATION NO.::85-26
REQUEST: To germit construction
of 6 tennis courts.

LOCATION: East side of Palm Ave.
approximately 300 ft.
south of Cherryhill Ave.

FINDINGS FOR APPROVAL CONDITIONAL USE PERMIT NO. 85-25:

1. The proposed six tennis courts are compatible with surrounding land uses and in conformance with the General Plan policies because the facility will become an integral part of the existing Seacliff Country Club.

2. The proposed iennis courts will not be detrimental to the genetrl health, welfare, safety and convenience of persons residing or working in the neighborhood because the, facility will lave houzs of operation limited to the daytime.

3. The location, site layout, and design of the proposed development does properly adapt the structure to streets, driveways and other uses in a harmonious manner,
FINDINGS FOR APPROVAL COASTAL DEVELOPMENT PERMIT NO. 85-2:

1. The proposal for 6 tennis courts is consistent with the City Coastal Zone suffix as well as other provisions of the
of the City's Coastal Land Use Plan.

2. The proposed development can be provided with infrastructure in a manner that is consistent with the Coastal Land Use Plan.

3. The proposed development conforms with the public access and public recreation policies of Chapter 3 of the California Coastal Act.

CONDITIONS OF APPROVAL CONDITIONAL USE PERMIT NO. 85-25:

The site plan dated May 22, 1985 shall be the approved layout.

2. Prior to issuance of building permits, the applicant shall submit a landscape and irrigation plan to the Department of Development Services and Department of Public Works for review and approval.

3. The tennis courts hours of operation shall be limited to daytime hours. No artificial lighting shall be permitted.

4. A copy of the tennis club membership/entry requirements shall be submitted to the Department of Development Services to assure the membership/use is limited to country club members.

5. All building spoils, such a unused lumber, wire, pipe and surplus or unusable materials, shall be disposed of at an off-site facility equipped to handle them.

I hereby certify that Conditional Use Permit No. 85-25, Coastal Development Permit No. 85-19 and Negative Declaration No. 85-26 was approved by the Planning Commission of the City of Huntington Beach on August 5, 1985 by the foregoing citations and conditions.

Sincerely,
Ilmena Wilt fir
James W. Palin
Secretary
Planning Conmission
JWP: 1p
(3037d(3)
From: Levin, Shannon
To: Villasenor, Jennifer
Subject: FW: THC plans
Date:

Attachments: 2026.04.10 Letter to HBCC (FINAL).pdf
From: Sharon Pitchford <[email protected]>
Sent: Saturday, April 18, 2026 11:42 AM
To: CITY COUNCIL (INCL. CMO STAFF) <[email protected]> Subject: THC plans
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EPG BLAW Orange County Office
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April 10, 2026

SENT VIA EMAIL
Huntington Beach City Council
2000 Main Street
Huntington Beach, CA 92648
Email: City. [email protected]
Re: April 21, 2026 Hearing re The Huntington Club Remodel and Bungalows Dear Mayor and Members of the City Council,
I submit this letter in two capacities: (1) as pro bono counsel to appellants Cheryl Gates, Susan Ridgeway, and Douglas Scott Warren; and (2) as a current member of The Huntington Club with a direct interest in the continued availability and character of its facilities. I am an active golf and tennis member of the Club, and my family and I regularly participate in its athletic programs.

To summarize, Golf Realty Fund has a reported contractual obligation of approximately $10 million to $15 million to complete improvements at the Club. In structuring that arrangement, Golf Realty Fund retained control over the buildout, positioning itself to convert that obligation into an additional revenue stream through hotel-like lodging for "members and their guests." At the most recent hearing, Golf Realty Fund implied that it does not need that additional revenue to fund the renovations; it simply seeks an additional revenue stream from the property.

Standing alone, that economic choice would not necessarily be problematic. The problem is the particular plan Golf Realty Fund has chosen to pursue. As proposed, it introduces serious safety risks for Club members and their families. Members and their children move constantly through this area circulating among the courts, the pool, the fitness center, and food service locations often in unpredictable patterns that are inherent to an active recreational environment.

The proposed design forces those same children to cross an internal roadway serving both lodging-related traffic and everyday member vehicle traffic, as members will naturally use that area for convenient parking in the more than thirty new parking spaces located directly adjacent to the tennis and pickleball courts. The plan therefore concentrates vehicle traffic in the exact space where children and families are moving on foot.

This creates a direct and foreseeable conflict between vehicles and pedestrians. That risk is compounded by the nature of the proposed use, which will introduce guest traffic, ride-share Page |1
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activity, deliveries, and the potential for alcohol-related driving into the same space where children are playing and moving freely. The foreseeable result is not minor or theoretical-it is the risk of serious injury in a setting that has always functioned as a protected recreational environment. Up until now, Golf Realty Fund has asked the Council to allow that plan to proceed without the benefit of a comprehensive safety study, ostensibly because its contractual deadline to complete these improvements will expire in early May 2026.

That private timing pressure is no substitute for a complete and reliable public record, particularly where the safety of Huntington Beach families who use what many regard as the City's crown jewel is at stake. More time is needed to determine whether this design can be made safe. Without that work, approval would expose Golf Realty Fund, its tenant, and the City of Huntington Beach to substantial liability if a member-or worse, a child—is injured.

In good faith discussions between the Appellants and Golf Realty Fund, the concept of a comprehensive safety study has been raised. Golf Realty Fund appears amenable to conducting such a study, but there remains a critical procedural issue. It is my understanding that Golf Realty Fund prefers that the safety study be imposed along with approval of the plan. We respectfully submit that this approach is improper under the circumstances and should be rejected.

The Council should instead retain jurisdiction over this matter and require completion of the safety study before any approval is granted. The Appellants' ability to advocate on behalf of the Club's membership is tied to this appeal. As a non-equity club, members do not control the property; their voice is exercised through this process and through the Council's oversight. If the project is approved subject to later study, that voice is effectively extinguished, and future decisions regarding safety, design, and implementation will be left to private entities whose interests may not align with those of the citizens most directly affected.

Moreover, the Council cannot make the required findings in support of approval without first establishing, based on substantial evidence, that the project can be operated safely. Nor may the Council defer that determination to a future study, as doing so would leave a critical component of the approval unsupported by the administrative record at the time of decision. Where material safety concerns remain unresolved, approval would be premature because the record would not contain substantial evidence sufficient to support the findings required for a Conditional Use Permit.

Based on the foregoing, we respectfully request that the Council continue this hearing for at least 60 days so that the proposed plan can be more fully evaluated, particularly in light of the serious safety concerns created by placing a roadway with significant parking capacity in the middle of the Club's tennis and pickleball facilities. The Council should direct Golf Realty Fund to conduct a comprehensive safety study by an independent consultant approved by the Council Page |2
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and Appellants. Once completed, that study should be circulated for review and comment, and only then should the Council determine whether the project, as proposed, is safe enough for approval.

1. The factual background demonstrates no evaluation of safety concerns amid contractual time pressure and a breakdown between owner and operator.

The factual statements set forth in this letter are based on a combination of publicly available materials and information obtained through discussions with individuals represented to have knowledge of the operations, agreements, and history of the Club. Except where expressly supported by cited documents or witnessed by me or my clients, these statements are provided on an informational basis only. I therefore do not present these statements as adjudicated fact, but rather as contextual background to assist the Council in understanding the circumstances surrounding the proposed project.
• The entity operating the Club, Camaraderie Clubs, is led by Travis Brasher, who previously served as a golf professional at the Club when it operated under its former name, Seacliff Country Club. Mr. Brasher founded the Travis Mathew apparel brand, which was later sold, and has since returned, now as the tenant overseeing operations at the Club, rebranding it as The Huntington Club.
• Prior to the COVID-19 pandemic, Camaraderie Clubs entered into a long-term lease agreement-reported to be approximately 30 years in duration-with the property owner, Golf Realty Fund, under which it operates the Club.
• As part of that long-term lease arrangement, both Camaraderie Clubs and Golf Realty Fund are understood to have contemplated and committed to significant capital improvements to the Club's infrastructure in recognition of the age and condition of the existing facilities.

Camaraderie Clubs has invested substantial capital into the Club, reported to be in the range of approximately $8 million to $10 million.
• Golf Realty Fund, as property owner, is likewise understood to have committed to a significant capital contribution toward redevelopment of the property, reported to be in the range of approximately $10 million to $15 million, none of which has yet been deployed. The lease or related agreements reportedly include a deadline for completion of those improvements in early May 2026. Based on that reported deadline, Golf Realty Fund appears to be under substantial time pressure to obtain approvals and move the project forward.

Page |3
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• The proposed project includes demolition and replacement of fitness and swimming facilities, as well as the addition of new structures, including bungalow units, loft-style accommodations, and related site improvements. More specifically, the project includes (i) conversion or construction of second-floor space within a proposed fitness facility into loft-style accommodations and (ii) construction of detached bungalow-style units on the property. The project would also eliminate three lit tennis courts used for nighttime play and divide the tennis and pickleball facilities with a large internal road serving the bungalow component, including more than thirty parking spaces located within that internal circulation area.
• Golf Realty Fund also submitted an alternative concept involving the addition of a third story to the fitness facility without including the bungalow lodging component.

According to information provided by a City employee, that submission was marked "Incomplete" because it did not contain sufficient detail to determine whether it complied with applicable height limitations. Even if that proposal ultimately raised height- compliance issues, the City retains discretion to evaluate whether such limitations could be addressed or modified through appropriate planning mechanisms. A plan without an internal roadway through the recreational core, therefore, is theoretically possible. • At a presentation by Golf Realty Fund to Club members on Friday, January 23, 2026, at which Camaraderie Clubs was absent, a representative of Golf Realty Fund told members that revenue from the bungalow component was necessary to fund reconstruction of the pool and fitness improvements. Golf Realty Fund has also provided the City with aggressive revenue projections for these rental units, particularly in light of the competition from multiple high-end beachfront hotels in the area. In subsequent representations to the City Council, however, Golf Realty Fund indicated that it has sufficient financial resources to build and maintain the proposed improvements even if those revenue projections were not realized. Those two positions are difficult to reconcile and bear directly on whether the bungalow component is truly necessary or instead an added revenue stream being pursued despite the costs it imposes. • I received a written communication distributed by Camaraderie Clubs to Club members dated February 7, 2026 (Exhibit A). In that communication, Camaraderie Clubs expressly states that it "has no financial interest or contractual obligation to manage the bungalows and loft apartments proposed by Golf Realty Fund." • The same communication also alludes to the statements made by Golf Realty Fund during its town hall meeting with Club members concerning the proposed project. At that meeting, Golf Realty Fund stated that members were "free to speak with [their] wallets" in response to the proposed changes.

Page | 4
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[email protected]
• The February 7, 2026 communication further clarifies that Camaraderie Clubs does not endorse that statement and distinguishes its operational role from that of the property owner with respect to the proposed development.
• It is anticipated that, if the contemplated redevelopment obligations are not satisfied within the early May 2026 timeframe, a dispute between landlord and tenant may arise, potentially resulting in litigation. This point is noted solely to provide context regarding the relationship between landlord and tenant, which, from my perspective, is troubling. • In negotiations among the parties, there has been a general refusal to have all sides sit down together to resolve their issues. Golf Realty Fund has asserted that Camaraderie Clubs contractually agreed to limit or waive its ability to object to certain aspects of the redevelopment plan, including the bungalow component. I have learned nothing that contradicts that assertion. At the town hall meeting, Golf Realty Fund flashed a specific portion of the lease when making that point to members, but I was not provided with a sufficient opportunity to review that provision in full. Further, Appellants' suggestion that a thorough dialogue among all the affected parties would be the best course toward resolution has been dismissed.

2. Golf Realty Fund proposes an unsafe conflict zone within the Club's recreational core that introduces high-traffic areas into the center of club facilities visited daily by families.

The plans submitted to the City do not merely remodel a private club. They change the way this entire recreational area would function on a daily basis. Instead of keeping vehicular circulation at the perimeter, the proposed design pulls vehicle movement into the same part of the site where members and their families naturally move back and forth between the tennis courts, the pickleball courts, the bungalow area, the food truck location, and the pool and fitness complex.

That matters because this part of the Club is not a static space. It is one of the most active family areas on the property. During a recent tennis tournament, I watched my own three children-ages 8, 6, and 3-consistently move among the courts, the fitness center, the pool, and the food truck area. Children were running back and forth for smoothies, food, and breaks between matches. Parents and members were doing the same thing. That pattern of movement is not unusual; it is exactly how this area of the Club is actually used.

The City would never design one of its own recreational spaces this way. In publicly used Huntington Beach recreation areas, vehicular circulation is kept at the edges, while the interior is reserved for fields, courts, trails, playgrounds, and gathering space. That is not accidental. It Page |5
EPG BLAW Orange County Office
3200 Bristol Street, Suite 400
Costa Mesa, CA 92626
ENENSTEIN PHAM GLASS (714) 292-0262
GUTENPLAN & BOLLING LLP epggblaw.com
Jesse K. Bolling
Managing Partner
[email protected]
reflects a basic safety judgment: where children and families are moving freely, cars should not be routed through the middle of the activity zone.

Huntington
Hantington Beach CONTRAL PATR
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Vehicular Access

43."
& P -king Parking
Recreations
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HBI CENTRAL PARK
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• BASEBALL/SOFTBALL FIELDS Filten Are
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TURF FIELDS Secret Carder
Gold Recreation 119

ARENA FIELD
• GRASS FIELDS

CATTING CAGES
.....
• SNACX BAR / BATHROOMS

PLAY GROUND SEEKER CARDENS
• HESC OFFICE
Vehicular Access
Humtington Beach park design consistently places vehicular circulation at the perimeter; while Parking interior space is reserved for active recreation. This separation reflects a fundamental safety principle: where children and families are moving freely, vehicles are kept out of the activity zone.

The project plans submitted here do the opposite. They create a conflict zone where ordinary member movement intersects with internal vehicular circulation serving both lodging- related traffic and everyday member parking activity. The internal road does not simply pass near the courts it runs directly through the recreational area and includes more than thirty parking spaces that will attract regular member use. The issue is not whether a careful adult can look both ways and cross. The issue is whether an active tennis and pickleball environment— used by children, teens, and families should be redesigned to require exactly that kind of vigilance in the first place.

The risk is particularly acute at the pickleball courts. Under the current layout, the pickleball courts sit adjacent to one another, and weekly ladder events regularly utilize all eight pickleball courts (four in each court bank). During those events, players continuously rotate between the two courts based on wins and losses. Under the proposed plan, the internal road would run between the two courts that are currently adjacent, meaning that players participating

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