CITY COUNCIL AGENDA Page 1 of 3 AUGUST 6, 2024
SPECIAL MEETING
CITY COUNCIL
AGENDA
CITY HALL COUNCIL CHAMBER
78495 Calle Tampico, La Quinta
SPECIAL MEETING
TUESDAY, AUGUST 6, 2024, AT 4:00 P.M.
Members of the public may listen to this meeting by tuning-in live via https://laquinta.cablecast.tv/watch-now?site=1.
CALL TO ORDER
ROLL CALL: Councilmembers: Fitzpatrick, McGarrey, Peña, Sanchez, and Mayor Evans
PUBLIC COMMENT ON MATTERS NOT ON THE AGENDA
At this time, members of the public may address the City Council on any matter not listed on the agenda pursuant to the “Public Comments – Instructions” listed at the end of the agenda.
The City Council values your comments; however, in accordance with State law, no action shall be taken on any item not appearing on the agenda unless it is an emergency item authorized by the Brown Act [Government Code § 54954.2(b)].
CONFIRMATION OF AGENDA
PLEDGE OF ALLEGIANCE
BUSINESS SESSION
PAGE
1. REVIEW TERM SHEET RELATING TO PROPOSED INTERIM AGREEMENT
FOR TRANSFER OF DEVELOPER RIGHTS AND OBLIGATIONS FOR THE
TALUS PROJECT (FORMERLY SILVERROCK RESORT)
5 ADJOURNMENT
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City Council agendas and staff reports
are available on the City’s
web page: www.LaQuintaCA.gov
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CITY COUNCIL AGENDA Page 2 of 3 AUGUST 6, 2024
SPECIAL MEETING
The next regular meeting of the City Council will be held on September 17, 2024, with open session starting at 4:00 p.m. at the City Hall Council Chamber, 78495 Calle Tampico, La Quinta, CA 92253.
DECLARATION OF POSTING
I, Monika Radeva, City Clerk of the City of La Quinta, do hereby declare that the foregoing Agenda for the La Quinta City Council Special meeting was posted on the City’s website, near the entrance to the Council Chamber at 78495 Calle Tampico, and the bulletin board at the La Quinta Cove Post Office at 51321 Avenida Bermudas, on August 5, 2024.
DATED: August 5, 2024
MONIKA RADEVA, City Clerk
City of La Quinta, California
Public Notices
Agenda packet materials are available for public inspection: 1) at the Clerk’s Office at La Quinta City Hall, located at 78495 Calle Tampico, La Quinta, California 92253; and 2) on the City’s website at www.laquintaca.gov/councilagendas, in accordance with the Brown Act [Government Code § 54957.5; AB 2647 (Stats. 2022, Ch. 971)]. The La Quinta City Council Chamber is handicapped accessible. If special equipment is needed for the hearing impaired, please call the City Clerk’s office at (760) 777-7123, 24- hours in advance of the meeting and accommodations will be made. If background material is to be presented to the City Council during a City Council meeting, please be advised that 15 copies of all documents, exhibits, etc., must be supplied to the City Clerk for distribution. It is requested that this takes place prior to the beginning of the meeting.
PUBLIC COMMENTS - INSTRUCTIONS
Members of the public may address the City Council on any matter listed or not listed on the agenda as follows:
WRITTEN PUBLIC COMMENTS can be provided either in-person during the meeting by submitting 15 copies to the City Clerk, it is requested that this takes place prior to the beginning of the meeting; or can be emailed in advance to [email protected], no later than 9:00 a.m., on the day of the meeting. Written public comments will be distributed to Council, made public, and will be incorporated into the public record of the CLICK HERE to Return to Agenda
CITY COUNCIL AGENDA Page 3 of 3 AUGUST 6, 2024
SPECIAL MEETING
meeting, but will not be read during the meeting unless, upon the request of the Mayor, a brief summary of public comments is asked to be reported.
If written public comments are emailed, the email subject line must clearly state “Written Comments” and should include: 1) full name, 2) city of residence, and 3) subject matter.
VERBAL PUBLIC COMMENTS can be provided in-person during the meeting by completing a “Request to Speak” form and submitting it to the City Clerk; it is requested that this takes place prior to the beginning of the meeting. Please limit your comments to three (3) minutes (or approximately 350 words). Members of the public shall be called upon to speak by the Mayor.
In accordance with City Council Resolution No. 2022-027, a one-time additional speaker time donation of three (3) minutes per individual is permitted; please note that the member of the public donating time must: 1) submit this in writing to the City Clerk by completing a “Request to Speak” form noting the name of the person to whom time is being donated to, and 2) be present at the time the speaker provides verbal comments.
Verbal public comments are defined as comments provided in the speakers’ own voice and may not include video or sound recordings of the speaker or of other individuals or entities, unless permitted by the Mayor.
Public speakers may elect to use printed presentation materials to aid their comments; 15 copies of such printed materials shall be provided to the City Clerk to be disseminated to the City Council, made public, and incorporated into the public record of the meeting; it is requested that the printed materials are provided prior to the beginning of the meeting. There shall be no use of Chamber resources and technology to display visual or audible presentations during public comments, unless permitted by the Mayor.
All writings or documents, including but not limited to emails and attachments to emails, submitted to the City regarding any item(s) listed or not listed on this agenda are public records. All information in such writings and documents is subject to disclosure as being in the public domain and subject to search and review by electronic means, including but not limited to the City’s Internet Web site and any other Internet Web-based platform or other Web-based form of communication. All information in such writings and documents similarly is subject to disclosure pursuant to the California Public Records Act [Government Code § 7920.000 et seq.].
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City of La Quinta
CITY COUNCIL SPECIAL MEETING: August 6, 2024
STAFF REPORT
AGENDA TITLE: REVIEW TERM SHEET RELATING TO PROPOSED INTERIM
AGREEMENT FOR TRANSFER OF DEVELOPER RIGHTS AND OBLIGATIONS FOR
THE TALUS PROJECT (FORMERLY SILVERROCK RESORT)
RECOMMENDATION
A. Review Term Sheet relating to proposed Interim Agreement for Transfer of Developer Rights and Obligations for the Talus project (formerly SilverRock Resort); and
B. Authorize the City Manager to negotiate and enter into, on behalf of the City, an Interim Agreement based on the general terms and conditions of the Term Sheet.
EXECUTIVE SUMMARY
The City and SilverRock Development Company, LLC (SDC) entered into a Purchase, Sale, and Development Agreement on November 19, 2014, which was subsequently amended via Amendments 1, 2, 3, 4, and 5, collectively referred to as the PSDA, for the Talus project (formerly SilverRock Resort). Pursuant to letters from the City and SDC, dated July 1 and August 1, 2024, included as Attachment 2, the City declared that SDC is in full breach of the PSDA and that SDC no longer has any rights as “Developer” under the PSDA for failure to timely cure, and inability to ever cure, the Defaults identified in those letters. The Term Sheet and Letter of Intent (Term Sheet), included as Attachment 1, set forth terms and conditions, with details and implementing provisions to be more fully developed and agreed upon in the Interim Agreement for Transfer of Developer Rights and Obligations (Interim Agreement) for the Talus project.
FISCAL IMPACT
None known or expected at this time, as the terms and conditions of the proposed Interim Agreement would not have the City pay for costs associated with SDC’s breach of the PSDA, and would provide for Christopher M. George (CMG) to pay off identified unpaid debts owed by SDC and acquisition costs for the properties currently held by SDC.
BUSINESS SESSION ITEM NO. 1
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BACKGROUND/ANALYSIS
As public records reflect, the City and SDC entered into a PSDA on or about November 19, 2014 (“Original PSDA”), as amended by that certain Amendment No. 1 dated on or about October 29, 2015 (“Amendment No. 1”), that certain Amendment No. 2 dated on or about April 18, 2017 (“Amendment No. 2”), that certain Amendment No. 3 dated on or about November 28, 2018 (“Amendment No. 3”), that certain Amendment No. 4 dated on or about October 12, 2021 (“Amendment No. 4”), and that certain Amendment No. 5 dated on or about November 16, 2023 (“Amendment No. 5” and collectively referred to as the “PSDA”) for the SilverRock Resort Project, renamed Talus project. Under Amendments Nos. 4 and 5, SDC and the City memorialized the then City-approved Revised Capitalization that was presented to the City by SDC.
Pursuant to letters from the City to SDC, dated July 1 and August 1, 2024 (Attachment 2), respectively, the City declared that SDC is in full breach of the PSDA and that SDC no longer has any rights as “Developer” under the PSDA for failure to timely cure, and inability to ever cure, the Defaults identified in those letters.
Furthermore, as explained in the City’s August 1, 2024, letter, the City identified a material misstatement made by SDC (Attachment 3 – August 1, 2024, letter by The Robert Green Company) by promulgating SDC has the authority to determine whether CMG, one of multiple parties to the Memorandum of Understanding and Agreement Relating to Default and Developer Requirements (PSDA) (MOU), dated May 24, 2024, as defined therein, “has no further rights, liabilities, or obligations under the MOU or the PSDA or in connection with the Developer-Held Properties.” To the contrary, as explained by the City, SDC failed to perform under the MOU, willfully took actions to frustrate the ability for CMG and other parties to perform under the MOU, and no longer has any rights as the “Developer” under the PSDA.
In this regard, the City’s Term Sheet (Attachment 1) addressed to CMG, dated August 2, 2024, outlines the efforts by the City to continue with effectuating the transactions that were set forth in the MOU, given the frustration of purpose and bad faith actions taken by SDC.
The Term Sheet outlines the terms and conditions, with details and implementing provisions to be more fully developed and agreed upon in the Interim Agreement, to proceed with having CMG assume and become the “Developer” for the Talus project under the PSDA.
The City, CMG, and other parties to the MOU have expressed interest in moving forward with an Interim Agreement with more specifics to implement the acquisition of properties by CMG and transfer of rights and obligations to CMG, upon acquisition of those properties, as “Developer” under the PSDA. So that the City may enter into the Interim Agreement upon mutual agreement of its final terms by the parties, it is recommended the City Manager is granted the authority to execute the Interim Agreement as long as it is generally consistent with the provisions outlined in the Term Sheet. If the City Manager 6 CLICK HERE to Return to Agenda
is concerned that the Interim Agreement may require further review by the Council because, after negotiations with CMG and other parties, it is not generally consistent with the provisions outlined in the Term Sheet, then the Interim Agreement would be brought to Council for review and comment before the City Manager would enter into the Agreement on behalf of the City.
ALTERNATIVES
Staff does not recommend an alternative.
Prepared and Approved by: Jon McMillen, City Manager
Attachments:
1. August 2, 2024 – Term Sheet and Letter of Intent from City to Christopher M.
George regarding Interim Agreement for Transfer of Developer Rights and Obligations
2. August 1, 2024 – Letter regarding Failure to Cure Notice and Confirmation of Default – Purchase, Sale, and Development Agreement between City and SilverRock Development Company
3. August 1, 2024 – The Robert Green Company – Notice of Termination of MOU and Agreement Relating to Default and Developer Requirements (PSDA), dated May 24, 2024
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August 2, 2024
VIA E-MAIL
Christopher M. George
3160 Crow Canyon Road, Suite 400
San Ramon, California 94583
Email: [email protected]
Re: Term Sheet and Letter of Intent
Interim Agreement for Transfer of Developer Rights and Obligations Dear Mr. George:
As public records reflect, the City of La Quinta (“City”) and SilverRock Development Company, LLC (““SDC”), entered into a Purchase, Sale, and Development Agreement on or about November 19, 2014 (“Original PSDA”), as amended by that certain Amendment No. 1 dated on or about October 29, 2015 (“Amendment No. 1”), that certain Amendment No. 2 dated on or about April 18, 2017 (“Amendment No. 2”), that certain Amendment No. 3 dated on or about November 28, 2018 (“Amendment No. 3”), that certain Amendment No. 4 dated on or about October 12, 2021 (“Amendment No. 4”), and that certain Amendment No. 5 dated on or about November 16, 2023 (“Amendment No. 5” and collectively referred to as the “PSDA”) for the SilverRock Resort Project, renamed Talus project (the “Project”). Under Amendments Nos. 4 and 5, SDC and the City memorialized the then City-approved Revised Capitalization that was presented to the City by SDC.
Pursuant to letters from the City to SDC, dated July 1 and August 1, 2024, respectively, the City declared that SDC is in full breach of the PSDA and that SDC no longer has any rights as “Developer” under the PSDA for failure to timely cure, and inability to ever cure, the Defaults identified in those letters (copies of which are attached for reference).
Furthermore, as explained in the City’s August 1, 2024 letter, the City identified a material misstatement made by SDC by promulgating SDC has the authority to determine whether CMG, one of multiple parties to the MOU (as defined therein) “has no further rights, liabilities, or obligations under the MOU or the PSDA or in connection with the DeveloperHeld Properties.” To the contrary, as explained by the City, SDC failed to perform under the MOU, willfully took actions to frustrate the ability for CMG and other parties to perform under the MOU, and no longer has any rights as the “Developer” under the PSDA.
ATTACHMENT 1 8
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In this regard, the City sends this Term Sheet and Letter of Intent to outline the efforts by the City to continue with effectuating the transactions that were set forth in the MOU, given the frustration of purpose and bad faith actions taken by SDC. Please be reminded that this letter is an outline, albeit delivered to be as informative as possible, and any and all actions described below are and will be subject to final review and approval by the City Council and memorialized in a binding, written agreement (for reference, described as the “Interim Agreement”).
Term Sheet/Statement of Terms
With those provisions, the City sets forth the following terms and conditions (“Term Sheet”), with details and implementing provisions to be more fully developed and agreed upon in the Interim Agreement, to proceed with having CMG assume and become the “Developer” for the Project under the PSDA:
1. Parties to the Interim Agreement are proposed to be same parties as in the MOU, except SDC and the SDC-affiliated entities. Upon mutual agreement of the City and CMG, other parties may be added to the Interim Agreement.
2. If CMG acquires by foreclosure sale the real property covering the secured interest described in the Second Deed of Trust with Cypress Point Holdings (“Cypress”) as named beneficiary, County Recorder Doc. No. 2022-0486431 (“Cypress Deed of Trust”), which real property is referred to in this Term Sheet as the “Core Project Components Property,” and as a result of the foreclosure sale the fee interest in the Core Project Components Property vests with CMG, then the City will approve CMG as the “Developer” for the Project and will accept CMG’s assumption of the rights and obligations under the PSDA for the Core Project Components Property. The City and CMG will then negotiate and amend the PSDA (or enter into another agreement as mutually agreeable to the City and CMG), to memorialize the mutually agreed-upon modifications to the PSDA with CMG proceeding as the “Developer” of the Project, and in connection therewith, the City will want to address the following:
a. The daily reduction in rebates based on TOT receipts for the Luxury and Lifestyle Hotels, as described in Section 6 of Amendment No. 5, will need to have revised the completion dates of the two hotels. New dates will be mutually agreed upon by City and CMG, and these will become the new dates for calculating any reductions. In explanation of this, if the hotels are completed on schedule per a new amendment to the PSDA (for reference, “Amendment No. 6”), then there will be no reductions to the TOT rebate. Currently, the TOT rebate has 90% 9 CLICK HERE to Return to Agenda
available for first 10 years, and 70% for the remaining 5 years, of a total 15- year rebate term.
b. The Schedule of Performance will need to be adjusted based on new schedules provided by the general contractor, with an added contingency for minor delays, and will include force majeure provisions to be approved by City Manager and CMG. This new Schedule of Performance will be incorporated into Amendment No. 6.
c. The Purchase Price for the Future Resort Property (as defined in the PSDA) will be Two Million Five Hundred Thousand Dollars ($2,500,000) as identified in Amendment No. 4, and will not be subject to the “Financial Incentive Reductions” incurred by SDC, as the previous “Developer.”
3. If CMG acquires the Core Project Components Property, then the City will exercise its rights under the PSDA and respective repurchase Option Agreements (County Recorder Doc. Nos. 2018-0464676 and 2018-0464677, and referred to as the “Repurchase Option Agreements”), as applicable for the repurchase of the property constituting the Luxury Branded Residential Project Component (formerly Parcel 1 of Parcel Map No. 37207 and subdivided as Tract Map No. 37730 [Lots 1-29 & Lots A-L], and referred to as the “Luxury Branded Residences Property”) and the undeveloped land consisting of Planning Areas 7, 8, and 9 (Parcels 10, 11, and 12 of Parcel Map 37207, and referred to as the “PA7,8,9 Property”) (collectively, the Luxury Branded Residences Property and the PA7,8,9 Property is referred to as the “Repurchase Options Properties”). The City will assign all of its rights and obligations under the Repurchase Option Agreements to CMG, and CMG will assume all rights and obligations under the Repurchase Option Agreements. The City will also exercise its right under the PSDA to acquire from SDC all “Plans” related to the Project (such as blueprints, drawings, studies, and other work product relating to the construction of the Project). The City will assign to CMG all of its rights acquire the Plans, and CMG will assume all rights and obligations to acquire the Plans.
4. If CMG acquires the Core Project Components Property, then CMG must acquire the fee interest in the Luxury Branded Residences Property either by foreclosure sale or grant deed executed by SDC to CMG through the Repurchase Option Agreement process, and CMG must acquire the fee interest in the PA7,8,9 Property either by foreclosure sale or grant deed executed by SDC to CMG through the Repurchase Option Agreement process.
5. If CMG acquires the Core Project Components Property, then CMG must: (a) pay-off (or assume on restructured terms) all debts owed by SDC to Poppy Bank (“Poppy”), which debt is secured by that certain Deed of Trust with Poppy as named beneficiary (County 10 CLICK HERE to Return to Agenda
Recorder Doc. No. 2021-0628130, and referred to as the “Poppy Deed of Trust”), so that the recorded documents relating to the Poppy foreclosure sale are removed from title; and (b) pay-off all debts owed by SDC to RD Olson Construction, Inc. (“Olson”) and its respective subcontractors, and Granite Construction Company (“Granite”), in the respective amount stipulated or agreed between SDC and such contractor/subcontractor, including all stipulated or agreed interest accrued through payment date, in satisfaction of SDC’s contractual obligations and all mechanic’s liens that have been recorded against the SDC-held properties relating to Olson’s (and Olson’s subcontractors’) and Granite’s completed work and said claims filed in Riverside County Superior Court.
6. If CMG acquires the Core Project Components Property, then CMG must enter into a binding agreement with Montage North America, LLC (“Montage”) to serve as the hotel operator and manager of the Project Components comprised of the Luxury and Lifestyle Branded Hotels, and the Luxury and Lifestyle Branded Residences.
7. If CMG acquires the Core Project Components Property, and if the City exercises its rights under the Repurchase Option Agreements, CMG agrees to deposit into escrow funds that City and CMG determine to be sufficient to cover 100% of the costs to repurchase from SDC the Luxury Branded Residences Property and PA7,8,9 Property.
8. If CMG acquires the Core Project Components Property, and if the City exercises its rights under the Repurchase Option Agreements, then the City agrees that it will continue to prosecute its civil claims against SDC in Riverside County Superior Court, and CMG agrees to join in that litigation as a Co-Plaintiff or Plaintiff in Intervention if necessary or proper to effectuate the statement of terms generally outlined herein and terms and conditions in the Interim Agreement, once executed by the parties thereto.
9. CMG must provide to the City, for review and approval by the City, CMG’s proposed financing and related agreements, pro-formas, and other documents, for the purpose of confirming CMG’s implementation for remediating the partial improvements on the properties held by SDC, and remobilizing and completing the construction of the Core Project Components (as defined in Amendment No. 5, and referred to in the MOU as the “CMG Proposed Plan”), with the first Project Components to be completed being the Permanent Golf Clubhouse and Luxury Hotel (as defined in the PSDA).
10. The City will work to have all necessary recorded documents assigned or replaced, and where necessary, these recorded documents may need to be acknowledged by other secured interests as having priority if they are replaced instead of assigned. 11 In order for the terms of the PSDA (including amendments thereto) to be effective, CMG must have ownership of all property currently owned by SDC (or SDC affiliate). 11 CLICK HERE to Return to Agenda
12. Ultimately, the City Council is required to approve all assignments and amendments to the PSDA or any new agreements as may be required and described above.
One last advisory note: The real property and property descriptions that are referenced in this Term Sheet, and that would be included in the Interim Agreement, shall be construed and interpreted to mean the most-current legal descriptions and boundaries of property currently held by SDC (or SDC affiliate). In explanation of the foregoing, the MOU referenced the “Phase 1A Property,” “Phase 1B Property,” and “City Approved LLAs [Lot Line Adjustments]”), and defined that as the “Developer-Held Properties.” For purposes of this Term Sheet and the Interim Agreement, the properties discussed in this Term Sheet are intended to include all of the “Developer-Held Properties” as defined in the MOU even though different defined terms are used in this Term Sheet for purposes of sequencing the acquisition of all properties by CGM.
Should you have any questions, please contact me at (760) 777-7100. _________________________
Jon McMillen, City Manager
cc: Bill Ihrke, City Attorney (via email)
Michelman & Robinson, LLP
10880 Wilshire Blvd.,19th Floor
Los Angeles, CA 90024
Attn: Edward D. Vaisbort, Esq.
Attn: Eric Rans, Esq.
[email protected]
[email protected]
Abbey, Weitzenberg, Warren
& Emery
100 Stony Point Rd, Ste. 200
Santa Rosa, CA 95401
Attn: Mitchell B. Greenberg,
Esq.
[email protected]
Watt, Tieder, et al., LLP
4 Park Plaza, Suite 1000
Irvine, CA 92614
Attn: David McPherson
Email: [email protected]
Finch, Thornton & Baird, LLP
4747 Executive Drive
San Diego, CA 92121
Attn: Andrea L. Petray
Email: [email protected]
Rodriguez Wright LLP
Attn: Stephen M. Wright, Esq.
Email: [email protected]
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ATTACHMENT 2 13 CLICK HERE to Return to Agenda
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343 Fourth Ave | San Diego, CA 92101 | 760.634.6543
August 1, 2024 (12:01 am) Sent via email, read confirmation requested City of La Quinta
78495 Calle Tampico
La Quinta, CA 92253
Attention: Jon McMillen, City Manager
Email: [email protected]
Poppy Bank
438 First Street
Santa Rosa, CA, 95401
Attn: Ed Gomez Attn: Lisa Mills
Email: [email protected];
[email protected]
Cypress Ascendant Holdings, LLC
12707 High Bluff Dr., Suite 340
San Diego, CA 92130 Attn: Bill Trzos
Email: [email protected]
R.D. Olson Construction
400 Spectrum Center Drive, Suite 1200
Irvine, CA 92618
Attn: William Wilhelm
Email: [email protected]
Granite Construction Corporate
Headquarters
585 W. Beach Street
Watsonville, CA 95076
Attn: Jordy Murray, Deputy Senior
Counsel Email: [email protected]
Montage North America, LLC
3 Ada Parkway, Suite 100
Irvine, CA 92618
Attn: Jason S. Herthel
Email: [email protected]
CMG
3160 Crow Canyon Road, Suite 400
San Ramon, California 94583
Attn: Christopher George
Email: [email protected]
Re: Notice of Termination of MEMORANDUM OF UNDERSTANDING AND AGREEMENT
RELATING TO DEFAULT AND DEVELOPER REQUIREMENTS (PURCHASE, SALE, AND DEVELOPMENT AGREEMENT) (the “ MOU”) dated May 24, 2024
Dear Mr. McMillen and all other parties to the referenced MOU:
I call your attention to Section 4.5 to the MEMORANDUM OF UNDERSTANDING AND
AGREEMENT RELATING TO DEFAULT AND DEVELOPER REQUIREMENTS (PURCHASE, SALE, AND DEVELOPMENT AGREEMENT) (the “ MOU”) dated May 24, 2024, which states, in part:
“CMG shall pay-off all Developer Unpaid Obligations no later than thirty (30) days after July 1, 2024 (i.e., July 31, 2024, and referred to as the ‘Developer Unpaid Obligations Payment Deadline’), unless the creditor and/or beneficiary of an Developer Unpaid Obligation expressly consents to nonpayment of the Developer Unpaid Obligation by delivering written notice, no later than July 15, 2024, to the Parties, that said creditor/beneficiary has voluntarily agreed to an accord and satisfaction for the debt owed and no sale at auction will be pursued by said creditor/beneficiary for payment (in whole or in part) of the Developer Unpaid Obligation...” ATTACHMENT 321 CLICK HERE to Return to Agenda
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August 1, 2024
4 Watt, Tieder, et al., LLP
4 Park Plaza, Suite 1000
Irvine, CA 92614
Attn: David McPherson
Email: [email protected]
Finch, Thornton & Baird, LLP
4747 Executive Drive
San Diego, CA 92121
Attn: Andrea L. Petray
Email: [email protected]
Dentons US, LLP
2398 E. Camelback Road, Suite 850
Phoenix, AZ 85016
Attn: Chair, Global Hotels and Leisure
Email: [email protected]
Rodriguez Wright LLP
Attn: Stephen M. Wright, Esq.
Email: [email protected]
Crosbie Gliner Schiffman et al.
12750 High Bluff Drive, Suite 250
San Diego, California 92130
Attention: Dana Schiffman
Email: [email protected]
Attention: Thomas Crosbie
Email: [email protected]
Caldarelli Hejmanowski Page & Leer
3398 Carmel Mountain Road Suite 250
San Diego, CA 92121
Attention: William Caldarelli, Esq.
Email: [email protected]
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