220216 1235 Re_ 30-day extension of time_REDACTED
*** EXTERNAL SENDER ***
Fred,
The unnecessary listening tour on district elections is now complete. In my view, it
accomplished nothing, and just raised the visibility of the conflicts within the Cypress City
Council -- most recently in an OC Register article.
Cypress has a council meeting on Feb. 28. It needs to adopt a resolution at that meeting
and adopt a district map by the end of May. I think you know the consequences if it fails to
do so.
-Kevin
On Monday, December 6, 2021, 03:10:14 PM PST, Fred Galante
<fgalante@awattorneys.com> wrote:
Hi Kevin,
I am back from vacation and wanted to confirm the discussion we had on our November 11,
2021 call. I explained that the Cypress Council is still evaluating your September 17, 2021
letter and that the timing to gain all relevant information to understand the nature of your
allegations has proved difficult in light of the general unavailability of demographic
consultants due to the ongoing redistricting process required by statute at this time. I also
asked if you and your clients were willing to allow the City to defer any decision on
responding to your Sept. 17 letter until after the Nov. 2022 Cypress City Council election so
that we could ascertain if your allegations had support in light of the outcome of that
election.
You said your client would not agree to extend the timelines to allow another at-large
election to proceed for City Council in Cypress. I then asked if Cypress could nevertheless
have additional time to respond to your letter before it has to initiate the process to convert
to by-district elections. At that point, you graciously agreed to allow Cypress more time and
would not raise any issue of a lack of timeliness in responding to the letter; provided
Cypress took timely action to convert its at-large elections to by-district elections by
complying with the deadlines set by the County Registrar’s Office. We appreciate your
courtesy. We estimate the time to initiate that process to be April or early May, 2022.
Nevertheless, I will let you know what the Council decides and understand your explanation
that you may proceed to court if the Council does not initiate the action to convert to by-
district elections in time for the Nov. 2022 election to proceed as a by-district election.
Please let me know if you have any questions or disagree with the confirmation I provided.
Thank you. You may reach me anytime on my cell at (714)606-2728.
Fred Galante | Equity Partner
Aleshire & Wynder, LLP | 18881 Von Karman Ave., Suite 1700, Irvine, CA 92612
Tel: (949) 223-1170 | Dir: (949) 250-5410 | Fax: (949) 223-1180 |
fgalante@awattorneys.com | awattorneys.com
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From: Kevin Shenkman <shenkman@sbcglobal.net>
Sent: Tuesday, October 26, 2021 11:59 AM
To: Fred Galante <fgalante@awattorneys.com>
Subject: Re: 30-day extension of time
*** EXTERNAL SENDER ***
Fred,
Thank you for the call and email.
As I mentioned, retaining Jonathan Katz is a recipe for disaster for Cypress. Below are
links to a couple cases criticizing his opinions, most recently and relevantly is the court's
rejection of Katz's opinions concerning racially polarized voting in Luna v Kern County. Dr.
Katz knows statistics, but he doesn't have a clue about voting rights and elections, as
demonstrated by his opinions in the two cases below.
Better choices include David Ely, J. Morgan Kousser, Paul Mitchell, Karin MacDonald, and
Matt Barreto. For the sake of full disclosure, we have worked extensively with Ely and
Kousser, and Kousser's opinions have consistently been adopted over Katz's conflicting
opinions, including in Luna v Kern County. If you are looking for the most economical
solution out of this group, it is probably Paul Mitchell -- much less expensive than Katz, and,
unlike Katz, he has experience drawing districts. His email is
paul@redistrictingpartners.com.
Borders et al. v. King County et al. | Seattle Weekly
Borders et al. v. King County et al. | Seattle Weekly
A transcript of the decision by Chelan County Superior Court Judge John
Bridges, June 6, 2005.
Luna v. Cnty. of Kern, 291 F. Supp. 3d 1088 | Casetext Search + Citator
On Tuesday, October 26, 2021, 10:00:38 AM PDT, Fred Galante
<fgalante@awattorneys.com> wrote:
Hi Kevin,
This confirms our discussion this morning regarding your September 17, 2021 letter to the
City of Cypress. As I explained, I am City Attorney of Cypress. In response to my request,
you agreed to provide Cypress with a 30 day extension of time to respond to the September
17 letter before you would consider pursuing any judicial relief. As such, Cypress now has
until December 6, 2021 rather than the November 7, 2021 deadline outlined in your letter to
advise your office as to whether Cypress intends to pursue a voluntary change to its current
at-large voting system. Thank you for your professional courtesy and recognition that
securing the services of demographers has proved very challenging, especially in light of
the burdens on their services posed by AB 849.
Should you wish to discuss further, feel free to respond to this email or contact me on my
cell phone at (714)606-2728.
Fred Galante | Equity Partner
Aleshire & Wynder, LLP | 18881 Von Karman Ave., Suite 1700, Irvine, CA 92612
Tel: (949) 223-1170 | Dir: (949) 250-5410 | Fax: (949) 223-1180 |
fgalante@awattorneys.com | awattorneys.com
This email and any files transmitted with it may contain privileged or otherwise confidential information. If
you are not the intended recipient, or believe that you may have received this communication in error,
please advise the sender via email and delete the email you received.