Kate Colin, Mayor • Maribeth Bushey, Vice Mayor • Eli Hill, Councilmember • Rachel Kertz, Councilmember • Maika Llorens Gulati, Councilmember DATE: November 3, 2025
TO: Lindsay Lara, City Clerk
FROM: Rob Epstein, City Attorney
Andrea Visveshwara, Chief Assistant City Attorney
SUBJECT: November 3, 2025 Closed Session Agenda
For Item 2.a on the Closed Session Agenda, please find the attached correspondence to publish with the agenda. In a subsequent conversation between the City’s legal counsel and the potential plaintiff, the City’s legal counsel understands the last sentence in the potential plaintiff’s email to be a threat of litigation. Information that is subject to the attorney client privilege or attorney work product doctrine has been redacted.
MEMORANDUM
From: Scott Emblidge
To: Andrea Visveshwara: Katherine Kasameyer
Subject:
Date:
FW: CV0006338 Record Update, Depositions, and Settlement Proposal Friday, October 24, 2025 8:08:46 AM
Attachments:
Andrea and Katherine,
Scott
From: Mark Allen >
Sent: Thursday, October 23, 2025 4:53 PM
To: Scott Emblidge <[email protected]>
Cc: Gianna Geil <[email protected]>
Subject: CV0006338 Record Update, Depositions, and Settlement Proposal Hi Scott,
Following the October 14 order, I' m filing a reconsideration motion for CV0006338 by 5:00 PM PDT, October 24, 2025, with new October 21 photos showing escalated Andersen Drive degradation. I propose updating our stipulation to include limited depositions by November 10, 2025, on 2046 exemption/impacts (e.g., Stefanski, Colin) to facilitate merits preparation. The City's November 15 record preparation is noted; please confirm it will include Police, Fire, and Healt h data per§ 21167.6(b)(2), especially regarding Merrydale and camp displacements.
Attached are updated non-conformed copies of the stipulation and [proposed] order; conformed versions will follow filing. Please confirm by 5:00 PM, October 24, 2025, or suggest a call (available October 23 evening or October 24 morning).
I intend to appeal CV0005691 (notice by December 9, 2025). The City's planned Merrydale purchase without CEQA review risks injunction; happy to consider mediation of both cases by November 15, 2025, to resolve efficient ly and avoid depositions/record disputes.
Regards,
Mark Allen
In Pro Per
Attachments:
1. Updated Stipulation Re Administrative Record Access, Rolling Production, and Depositions (CV0006338)
2. [Proposed] Order Approving Updated Stipulation