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HomeMy WebLinkAboutItem 1b: Special Use Permit to allow the "626 Night Market" at Santa Anita park.T du(uu 1. 1983 Cow %Unity of 0 STAFF REPORT Development Services Department DATE: October 2, 2012 TO: Honorable Mayor and City Council FROM: Jason Kruckeberg, Assistant City Manager /Development Services Director tlL Jim Kasama, Community Development Administrator By: Lisa L. Flores, Senior Planner I SUBJECT: CONSIDERATION OF A SPECIAL USE PERMIT TO ALLOW THE "626 NIGHT MARKET," AN ASIAN - THEMED FOOD AND RETAIL NIGHT MARKET WITHIN THE INFIELD AREA AT SANTA ANITA PARK AT 285 W. HUNTINGTON DRIVE ON OCTOBER 20 -21, 2012, AND DECEMBER 15-16,2012. Recommended Action: Approve SUMMARY Special Use Permit Application No. SUP 12 -19 was filed by Mr. Jonny Hwang, the organizer of the Asian - themed street food and retail night markets known as the "626 Night Market that were recently held in Pasadena. Mr. Hwang is proposing to bring the "626 Night Market" to Arcadia, and is applying for it to be held in the infield of Santa Anita Park (see the attached aerial map and infield layout) on the weekends of October 20 & 21, and December 15 & 16, 2012. It is recommended that the City Council approve this application, subject to the Conditions of Approval listed in this staff report. BACKGROUND Night -time street markets are a common occurrence in many communities in Asian countries. In smaller towns and villages, they tend to be a "Farmers' Market" type of gathering where local growers and artisans bring their produce and wares for sale. In large cities, they tend to be a semi - permanent street faire with delicacies and entertainment. Mr. Hwang's "626 Night Market" is more the latter. The "626 Night Market" provides Asian businesses an opportunity to showcase themselves. Participants have provided a variety of traditional Asian delicacies, as well as contemporary, Asian - fusion cuisine, retail shopping, and entertainment activities for all ages. The events have been a good promotional opportunity for all types of businesses. SUP 12 -19 — 626 Night Market October 2, 2012 Page 2 of 6 Two "626 Night Market" events were held in Pasadena earlier this year, and both were very popular; and while Asian - themed, they were well attended by the entire community. The first event was held in April of this year, and was located on Oakland Avenue between Colorado Boulevard and Union Street in Pasadena. This being the first such event held by the applicant, the attendance was under - estimated, and the result was overcrowding, and gridlock of the surrounding streets with traffic backed -up to the 210 Freeway. Nevertheless, that event was considered a success by the vendors and attendees. The second event was held in July in front of Pasadena City Hall. The applicant and the City of Pasadena were better able to accommodate the crowd at this event, and it was considered a success by all involved. The applicant, however, wants a larger space that will accommodate more vendors along with more entertainment, and thinks that having the event over a two -day period will be better for the vendors and the attendees. DISCUSSION Arcadia Municipal Code Section 9273.1.20.1 requires City Council review and approval for a special event that will be attended by more than 5,000 people. The applicant is proposing to host the "626 Night Market" (Night Market) event for two weekends; October 20 & 21, and December 15 & 16, 2012 in the infield of Santa Anita Park. The proposal has been reviewed by the Fire, Police, Building Services, Business Licensing, Engineering Services, and the Public Works Services Departments. Also, a meeting was held by City staff with the applicant and representatives of Santa Anita Park to discuss the proposal. The applicant and Santa Anita Park have addressed all of the City's questions and concerns; and, it has been agreed that preparations should be for an attendance of 30,000- 35,000 people each night. The Night Market events will take place entirely in the infield at Santa Anita Park. There will be approximately 170 vendors, six food trucks, a live DJ with a dance floor, and possibly a display of new vehicles by local dealerships — see the attached infield layout. The events will be from 3:00 p.m. to 1:00 a.m. on the Saturdays of the two weekends, and from 3:00 p.m. to 11:00 p.m. on the Sundays. The music by the DJ will end at midnight on Saturdays and at 10:00 p.m. on Sundays. The music system and dance floor are to be arranged so that the music and sound is directed toward the grandstand and away from the residential areas to the north. Alcoholic beverages will not be sold at the Night Market events. There are a total of 18,952 parking spaces for the public at Santa Anita Park: 6,210 parking spaces in the north parking lot (Gate 6), 4,680 parking spaces through Gate 5, and 8,062 parking spaces in the main parking area (Gates 3 & 8). This should be more than enough parking for the Night Market events as well as for any other events that may be held at the same time (e.g., High School Reunions in the Club House facilities). For the October weekend, all of the parking lots will be open, since there will be live racing on those days. Santa Anita Park parking attendants and Arcadia Police Personnel will be directing Night Market attendees to use'the north parking lot (Gate 6). SUP 12 -19 — 626 Night Market October 2, 2012 Page 3 of 6 Having the Night Market attendees concentrated in the north parking lot will better facilitate the exiting of Santa Anita Park in the evening hours. There will be a first -aid station with two Emergency Medical Technicians (EMTs) and an ambulance from Huntington Ambulance. Santa Anita Park will provide 12 security guards and a public address system for emergencies. Arcadia Police Officers will assist with traffic and parking, and also walk the interior grounds of the race track and be available if needed for any incidents. In an emergency, attendees will be directed to exit through the three tunnels or via a 20 -foot wide emergency access lane at the west end of the infield. The Night Market events will be well advertised, including social media ads and blasts (e.g. Facebook and Twitter), local newspaper ads, television and radio commercials, on Santa Anita Park's electronic signs at Gates 5 and 8, and in church bulletins. The event also has a website, www.626nightmarket.com, and it is proposed that a mobile billboard truck be parked at one of the entries on the days of the event — see the attached photo. The following Conditions of Approval are recommended: 1. A permit and inspection is required by the Arcadia Fire Marshal or designee prior to each event, and the applicant shall provide the following at least one week prior to the October and December weekends: A. The locations and specifications of the tents and any other assemblies, including fire extinguishers, generators, and vehicles that are to be provided for each event. And, the tents and all other assemblies are to be available for inspection prior to each event. B. A layout plan showing that facilities used for cooking shall be situated a minimum distance of 20 feet from any tents or canopies, other cooking facilities, and /or Liquefied Petroleum Gas (LPG) storage locations. The layout plan shall include the quantities of, and locations of where Liquefied Petroleum Gas (LPG) is to be used or stored. C. A layout plan that shows a minimum of four exits from the infield, including the clear path -of- travel for a west exit. Exit way- finding signage and adequate lighting for all exit paths shall be provided for the public as specified by the Arcadia Fire Marshal or designee. The signage shall be provided in at least the two languages of English and Chinese. 2. Arcadia Fire Department reserves the right to provide a staffed Rescue Ambulance for the event at the applicant's expense. 3. At no time during the event shall any set -up be on the 20 -foot wide fire lane(s) as designated by the Arcadia Fire Marshal or designee. 4. At the applicant's expense, at least six Police Officers and one Sergeant of the Arcadia Police Department are to be assigned to the events to provide whatever services are deemed necessary by the Arcadia Chief of Police or designee. The SUP 12 -19 — 626 Night Market October 2, 2012 Page 4 of 6 assigned Arcadia Police Officers and Sergeant shall be in charge of traffic monitoring and control during the events. And, based on visual observations and reports by its officers or from other agencies, the Arcadia Police Department shall be able to require that additional personnel be in attendance at the December event at the applicant's expense. 5. No signs are permitted on the City medians or parkways, or any other City property. Any signs or banners to be posted on the subject property that will be visible from a public right -of -way shall be subject to review and approval by the Development Services Director or designee. The mobile billboard truck shall only be visible from the public right -of -way during the days of the events. 6. The vendors and any related independent contractors shall obtain City business licenses as applicable from the City's Business License Office prior to the events, and shall report to the State Board of Equalization that their day -of sales occurred in the City of Arcadia. 7. No perimeter fencing shall be provided around the vendor area(s) except around the generators, and the fencing shall not interfere with any egress routes required by the Arcadia Fire Marshal. 8. All electrical installations, including generators, lighting, and audio equipment shall be done with proper permits, and are subject to approval by the Arcadia Building Official or designee. 9. The portable toilets and water sinks shall not be placed near any catch basins or any other drain inlets. The locations of the portable toilets and water sinks shall be subject to review and approval by the Public Works Services Director or designee. 10. The arrangement and layout for the music, DJ entertainment, and any other amplification equipment shall be subject to the review and approval of the Development Services Director or designee, and the music, DJ entertainment, and any other amplified entertainment shall end by midnight on Saturdays and 10:00 p.m. on Sundays. 11. Noncompliance with the provisions and conditions of approval for SUP 12 -19 shall be grounds for immediate suspension or revocation of any approvals, which could result in the closing and /or cancellation of the events. 12. The applicant shall defend, indemnify, and hold harmless the City of Arcadia and its officers, employees, and agents from and against any claim, action, or proceeding against the City of Arcadia, its officers, employees or agents to attack, set aside, void, or annul any approval or condition of approval of the City of Arcadia concerning this project and /or land use decision, including but not limited to any approval or condition of approval of the City Council, Planning Commission, or City Staff, which action is brought within the time period provided for in Government Code Section 66499.37 or other provision of law applicable to this project or decision. The City shall promptly notify the applicant of any claim, action, or proceeding concerning the project and /or land use decision and the City SUP 12 -19 — 626 Night Market October 2, 2012 Page 5 of 6 shall cooperate fully in the defense of the matter. The City reserves the right, at its own option, to choose its own attorney to represent the City, its officers, employees, and agents in the defense of the matter. Findings Section 9273.1.20.2 of the Arcadia Municipal Code states that a Special Use Permit application is subject to the following four criteria: 1. That the site is adequate in size and shape to accommodate the proposed Special Use or Event. The infield and parking at Santa Anita Park are able to accommodate the proposed Night Market events. 2. That the proposed Special Use or Event will not adversely interfere with existing uses on the subject property, and will not impede or adversely impact pedestrian access ways and /or vehicular circulation patterns. For the weekend in October, the Night Market event will be held in conjunction with the live racing activities, and the arrangement of the Night Market activities will avoid conflicts with the on -site racing activities. There will not be any live racing on the weekend in December. For both of the weekends, all the parking areas will be available. 3. That the proposed Special Use or Event will not result in a significant adverse impact on any adjacent property. Santa Anita Park is a venue that is well- suited for large crowds. The Night Market events will be held in the infield of Santa Anita Park, which is almost 1,000 feet from the nearest residential property. The music system, speakers, dance floor, and any other amplification equipment are to be arranged so that the music and sound is directed away from the nearby residential areas. Santa Anita Park parking attendants and Arcadia Police Personnel will be directing Night Market attendees to use the north parking lot (Gate 6) to better facilitate exiting of Santa Anita Park in the evening hours. 4. That by requiring certain safeguards as conditions of approval, the proposed Special Use or Event will not be detrimental to the public health, safety and welfare. Santa Anita Park has existing facilities that will adequately serve the expected attendance. The vendors will operate in accordance with all applicable health and safety codes. The applicant will provide a first aid station with two Emergency Medical Technicians (EMTs) and an ambulance. Santa Anita Park will provide 12 security guards and a public address system for emergencies. The Arcadia Police Department will also provide officers that will be available to walk the interior grounds of the race track and be available to respond to any incidents. ENVIRONMENTAL ANALYSIS This project is Categorically Exempt from the California Environmental Quality Act (CEQA) under Section 15304(e) of the CEQA Guidelines as a temporary use of land having negligible or no permanent effects on the environment. A Preliminary Exemption Assessment is attached. SUP 12 -19 — 626 Night Market October 2, 2012 Page 6 of 6 PUBLIC NOTICE Public hearing notices of Special Use Permit Application No. SUP 12 -19 were mailed on September 10, 2012, to the owners of those properties that are within 1,000 feet of the subject property, and the notice was published in a local newspaper. Santa Anita Park also sent the attached letter to approximately 800 residents of the Lower Rancho neighborhoods that are adjacent to the racetrack. Attached is an email from Mr. Reed, who resides at 458 Cambridge Drive. FISCAL IMPACT The proposed events will not have a significant fiscal impact on the City's General Fund. The City will be reimbursed for the services it provides (e.g., Police Officers, ambulance, etc.). The vendors will be subject to business licensing, if applicable, and the retail sales will be subject to sales tax. RECOMMENDATION It is recommended that the City Council approve Special Use Permit No. SUP 12 -19, subject to the aforementioned Conditions of Approval. Approved: Dominic Lazzaretto City Manager Attachments: Aerial Map Infield Layout Photo of the Mobile Billboard Truck Preliminary Exemption Assessment Letter by Santa Anita Park Email from Mr. Reed 626 Night Market To be located in the infield area zlef - a � e 1 f -Ga F4 Lz- LM 'Lam� I ■ 3 } i } 1 f - - THIS PAGE INTENTIONALLY BLANK - - CITY OF ARCADIA 240 W. HUNTINGTON DRIVE °,. ARCADIA, CA 91007 PRELIMINARY EXEMPTION ASSESSMENT (Certificate of Determination When Attached to Notice of Exemption) 1. Name or description of project: SUP 12 -19 - 626 Night Market, an Asian themed food and retail night market 2. Project Location — Identify street 285 W. Huntington Drive - Infield Area at Santa Anita Park address and cross streets or attach a map showing project site (preferably a USGS 15' or 7 1/2' topographical map identified by quadrangle name): 3. Entity or person undertaking project: 4. Staff Determination: W B. Other (Private) I (1) Name Jonny Hwang (2) Address 1603 W. Valley Blvd., P.O. Box 3772, Alhambra, CA 91803 The Lead Agency's Staff, having undertaken and completed a preliminary review of this project in accordance with the Lead Agency's "Local Guidelines for Implementing the California Environmental Quality Act (CEQA)" has concluded that this project does not require further environmental assessment because: a. ❑ The proposed action does not constitute a project under CEQA. b. ❑ The project is a Ministerial Project. C. ❑ d. ❑ e. f. ❑ 9. ❑ h. ❑ The project is an Emergency Project. The project constitutes a feasibility or planning study. The project is categorically exempt. Applicable Exemption Class: The project is statutorily exempt. Applicable Exemption: The project is otherwise exempt on the following basis: Section 15304(e) - Minor Alterations to Land The project involves another public agency which constitutes the Lead Agency. Name of Lead Agency: Date: September 5, 2012 Staff: Preliminary Exemption Assessment\2011 FORM "A" 0 - - THIS PAGE INTENTIONALLY BLANK - - September 18, 2012 in Re: 626 Night Market Event — October 20 & 21, 2012 Dear Neighbor: This is to let you know about an event we have requested to hold on our grounds in conjunction with live racing on the afternoon and evening of Saturday, October 20 and Sunday, October 21. The 626 Night Market is a concept that has proven very popular in San Gabriel Valley, having taken place in Pasadena on two separate dates this year. This tinge, the organizer would like to hold the event in the infield at Santa Anita, where the facilities are better suited to the crowds that are anticipated, and the setting far more spectacular! Please review the attached flyer that provides a description of the event. Attendees will be invited to watch a number of live races in the late afternoon, then stay for the 626 Night Market, enjoying cultural street foods and shopping for the various items offered by local vendors. While there will be light entertainment, there will be nothing that will involve excessive noise experienced by our neighbors. The 626 organizers and Santa Anita management have met with the City of Arcadia staff and representatives of the local homeowners' association to anticipate and alleviate any concerns they have. I would be happy to answer any questions you have by phone or email, or you can meet 626 organizer Ionny Hwang at the October 2 city council meeting, during which the event will be discussed. Thank you for your understanding and cooperation. In our efforts to keep Santa Anita Park a viable business leader in the community, we will continue to seek to host special events of which local residents can be proud. Best regards, Pete Siberell Director of Community Service & Special Projects Santa Anita Park 626 -574 -6373 psibereli@santaanita.com Los Angeles Turf Club, Inc. 285W Huntington Drive, RO. Box 60014, Arcadia, CA 91066 -6014 (626) 574 -7223 Fax (626) 446 -9565 - - THIS PAGE INTENTIONALLY BLANK - - 626 Night Market event information Date October 20 & 21, 2012 Time Saturday: 3PM — 1 AM Sunday: 3PM --- 11 PM Location Santa Anita Park infield Website www 6 62 nightmarket.com About Night markets are an icon of Asian societies. Night markets feature delicious street foods, unique shopping experiences, and fun, memorable activities for people of all ages. The 626 Night Market features and supports local, small businesses and entrepreneurs. The 626 Night Market is a cultural, community event for people of all ages and backgrounds. Our goal is to establish the first monthly night market in Southern California. Santa Anita Park Santa Anita Park is a large venue offering 300,000 sq. ft. in the infield and over 15,000 parking spaces. With close access to the 210 freeway and major thoroughfares, traffic and parking will not be an issue. Minimal music will be present at the event. - - THIS PAGE INTENTIONALLY BLANK - - From: Stephen Reed fmailto •swreedCa�rePdbrownlaw.coml Sent:.Wednesday, September 26, 2012 2:50 PM To: Lisa Flores Cc: GKovacic0)fVDLAW.NET; keenarcadia4reatCu�aol.com; harbicht(c�verizon. net; mseQalCa�nksf.com; jwuo218 Qmail com Subject: Request for Special Use Permit -- Infield at Santa Anita Park -- October 20 -21 and December 15 -16 Dear Ms. Flores: I am writing to register my concerns and objections to the application for a proposed Special Use Permit to be considered at the City Council meeting on October 2, 2012. I reside at 458 Cambridge Drive. I have lived there for 37 years. My concerns with the proposed SUP derive from the evolution of the use of Santa Anita Track and its infield over the intervening years. t minclude for them letter in the materials provided each member of the City Council m to consider these comments prior to the public hearing on October 2, 2012. Sound Level. First and foremost among my concerns is the noise that will emanate from the Santa Anita infield during the proposed event. When I moved to Arcadia, Santa Anita Race Track conducted horse racing. I knew that then and purchased my home anyway. The sound from the bugles, the PA announcer, and the cheering fans were part of the environment — something I knew and accepted. Racing was confined to two "meetings" per year; we knew the calendar and could plan on it; and, more importantly, the races occurred in the afternoons — not at night. But years ago, in response to dwindling revenues from pari - mutuel betting, Santa Anita began opening its facilities to other organizations. Well and good. The infield is beautiful; it should be used; and there is nothing improper about the track earning more revenue. Unfortunately, neither the track nor the groups using its facilities or performing there have paid even nominal attention to the Arcadia Sound Ordinance nor demonstrated even a modicum of concern for the sensibilities of their neighbors. Virtually without exception, when an event occurs at the track, the sound system, either of the track or of the user, is turned up to high level. My home is over 300 yards from the infield. Yet I can, on most events, clearly hear the sound coming from the event in the infield inside my home with the doors and windows closed! For years I have tried, without success, to convince the City of Arcadia to enforce its sound ordinance. I have called the Police Department on occasion to complain when a particularly egregious violation of the ordinance was occurring. Nothing happened. I have called the LA Turf Club on numerous occasions. On each such occasion, my complaint was politely received; the person on the other end of the telephone promised to check into the matter; and nothing else happened. I have written to the City requesting that steps be taken to enforce the sound ordinance. However, nothing happened; the sound levels continue to this day to be excessive and invade my home. As recently as Sunday evening, September 16`h, I could still hear sound from the festival going on in the infield despite being inside my home with the doors and windows shut, even after 10 PM. In fairness, I must say that I have this week spoken to Pete Siberell at the track and have received his assurance that the sponsor of the proposed night market event will limit the amplified sound coming from the event. That is positive. However, I am hopeful that you, as the Council, will take the step of making it clear that the Arcadia Sound Ordinance is important; that it means what it says; and that you intend to enforce it. That can be accomplished best by imposing clear conditions on the granting of the Use Permit requiring that the sponsor take affirmative steps to assure that the sound from the event does not exceed the ordinance limits. Now you are considering a Use Permit application that will permit the broadcast of sound until 1:00 AM on Sunday morning! It is outrageous for the applicant even to request that. The track is located in the heart of a residential area of Arcadia. The track infield is not a bar; it is not enclosed; it cannot be made sound proof. Unless severe conditions are placed on the Use Permit, those of us living in the surrounding neighborhood likely will be subject to excessive and unreasonable noise and other environmental intrusion. There are at least three (3) affirmative steps that you, as the representatives of all Arcadians, should take to protect those of us who are neighbors of the track from the nuisance of sound from events at the track. Require that Santa Anita Race Track turn its loudspeakers so that they broadcast only into the infield and the pavilion — not to the North toward our homes. Merely redirecting the speakers would reduce the sound levels somewhat. Require Santa Anita to turn down the level of its speaker system. There is no good reason that I and my neighbors should be able to hear clearly when a veterinarian is summoned to a barn at 6:30 AM. Enforce the ordinance with vigor. Instruct City staff to assure that when amplification systems are set up, they are set such that, when the sound reaches the Northern most border of the track — the fence line dividing the track from private residences — it is no greater than 55dBA prior to IOPM and 50dBA after 10:00 PM — in accordance with the Arcadia Municipal Code, Section 4610.3. In fairness to the citizens of the neighborhoods surrounding the track, the City should enforce existing law. To that means that you will have to do some sound testing, or install meters, to measure the sound coming from the infield. Santa Anita Track should bear at least some of the cost associated with that since the sound emanates from its property, is generated by its own activities or those for which it is being paid. General information about sound levels. A little information readily available on the Internet is useful to gain a perspective on the sound levels coming from events in the infield at Santa Anita. The intensity of sound does not decrease in a linear fashion as you move away; it occurs relative to the square of the distance from the source, which means it decays very fast. This is because the sound power is dispersed in a spherical fashion from its source and is why sounds can seem very loud when you are right next to them but very soft when you move a short distance away. A hand -held blower's decibel level ranges from 60 dB to 75 dB. A push lawnmower may generate decibel levels at 80 decibels. But the point is, from your own personal experience, you know that you cannot hear the sound of a leaf blower operating two streets away from you any more than you can hear the sound of a lawn mower from that distance. Yet, we can hear the sounds from the track infield clearly — sounds that may not law ull exceed 55dBA! 2006 Santa Anita Park Specific Plan EIR. The EIR that Arcadia commissioned in 2006 as part of the Santa Anita Park Specific Plan, expressly addressed noise and sound levels. It noted that, as sound travels over "soft" locations [grass, vegetation, and unpacked earth], it diminishes more rapidly than when traveling over "hard" materials. [Chpt. 4, Section 4.9 -41. The EIR stated that, "[N]oise from stationary or point sources is reduced by about. ..7.5 dBA for every doubling of distance at ... soft locations." Further, according to the EIR, older homes thirty (30) years or older [all of the homes adjacent to the track on the North, will reduce sound levels 20 -25 dBA with widows closed. The Northern fence line of the track is at least 100 yards from the infield. All of that distance is "soft" in that it consists of grassi uncompacted dirt, and trees. According to the EIR, sound leaving the infield should, therefore, be diminished as it travels North. If it is, in fact, diminished, that simply means that it was too loud when it originated in the infield. Per the existing law, the sound leaving the track and crossing into the first tier of homes cannot lawfully exceed 55dBA durine the day. The Code actually says: "It shall be unlawful..." for sound to exceed the levels prescribed by the Code. By the statements of the EIR, then, we learn that when the sound from the infield arrives at homes on Cambridge Drive, it should by reduced at least 15 dBA out of doors — to 40dBA and, monitored from the inside of the homes, it should be further reduced to a maximum of 15 -20 dBA. In Table 4.9 -1 of the EIR, we learn that common noise levels in broadcast /recording studios at 15dBA! So, residents of my street should reasonably expect that while a concert is going on in the infield of Santa Anita Race Track, the sound levels inside our homes should approximate that of a broadcast /recording studio. I assure you that is simply not true! Precedent. The second reason you should reject the application for the SUP is that you will set a bad precedent for future events. If you grant the SUP in this instance, you will undoubtedly be confronted with requests for other special use permits, extending the time, scope, and intensity of the uses. Arcadia takes pride in advertising its residential character — "A Community of Homes." Late night events, even in the infield of Santa Anita Track are inconsistent with that residential character. Arcadia is clearly not a 24 -hour activity community. You should reject efforts to change the fundamental character of the city. Uses such as are requested in this application creep; they always seek to expand what is permissible. Gradually, the restrictions that preserved and protected the community and gave it its character are worn away. You have a chance to prevent that from occurring by rejecting the application as submitted; restricting the outer time limits to 10 PM; and imposing strict sound regulations in line with the existing ordinance. These concerns about sound levels are not merely academic. The issue of the moment is the night market; in a few weeks you will consider the application of Cal Phil for further concerts in the infield next summer. You will receive requests over the next year for other events, all of wich will Thank you for your kind consideration of these concerns. Sincerely yours, Stephen W. Reed Reed & Brown, LLP 35 North Lake Avenue, Ste 960 Pasadena, California 91101 Tel: (626) 449 -4521 Fax: (626) 449 -7453 NOTICE OF CONFIDENTIALITY: This email is covered by the Electronic Communications Privacy Act, 18 U.S.C. Sections 2510 -2521 and is legally privileged. The information contained herein is confidential information from Reed & Brown, LLP and is intended solely for use by the individual or entity named as the recipient of this transmission. If you are not the intended recipient, be aware that any disclosure, copying, distribution or other use of the contents of this transmission is prohibited. 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