United States Bankruptcy Court Central District of California Riverside Division

Case 6:12-bk-28006-MJ
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S TRADLING Y OCCA C ARLSON & R AUTH
LAWYERS S AN T A M O N IC A
PAUL R. GLASSMAN (State Bar No. 76536) LAURA L. BUCHANAN (State Bar No. 156261) KATHLEEN D. DeVANEY (State Bar No. 156444) STRADLING YOCCA CARLSON & RAUTH A Professional Corporation 100 Wilshire Blvd., Suite 440 Santa Monica, CA 90401 Telephone: (424) 214-7000 Facsimile: (424) 214-7010 E-mail: [email protected] [email protected] [email protected] JAMES F. PENMAN (State Bar No. 91761) OFFICE OF THE CITY ATTORNEY 300 N. D STREET, Sixth Floor San Bernardino, CA 92418 Telephone: (909) 384-5355 Facsimile: (909) 384-5238 E-mail: [email protected] Attorneys for Debtor City of San Bernardino UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA RIVERSIDE DIVISION In re: CITY OF SAN BERNARDINO, CALIFORNIA, Debtor. Case No. 6:12-bk-28006-MJ Chapter 9 CITY OF SAN BERNARDINO'S STATUS CONFERENCE STATEMENT Date: November 5, 2012 Time: 10:00 a.m. Place: Courtroom 301 3420 Twelfth Street Riverside, CA 92501
STATUS CONFERENCE STATEMENT

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The City of San Bernardino, California (the City) submits this Status Conference Statement to advise the Court of the Citys progress toward fiscal stability and propose a path for an efficient resolution of the objections filed to its eligibility for chapter 9 relief. I. THE CITYS PROGRESS TOWARD FISCAL STABILITY. When the City filed its voluntary petition on August 1 (Petition Date), the City faced a dire cash flow crisis and was insolvent due, in part, to a cash deficit of $18.9 million in its General Fund as of July 31, and a preliminarily projected $45.8 million budget deficit for its current fiscal year.1 On August 31, the City timely filed its pleadings and evidence in support of its eligibility to be a chapter 9 debtor.2 While the City has made expenditure reductions that substantially reduce its staggering $45.8 million budget deficit, the City still faces a severe cash flow crisis and structural budget imbalance. Absent chapter 9 protection, the City would be unable to pay its employees, go into uncontrolled default of its obligations for critical City assets such as police cars, fire trucks, and refuse trucks, and could not provide basic essential services to ensure the health, safety and welfare of its citizens. A. The Common Councils Approval Of Its Pre-Pendency Plan.
City staff and the Citys consultants, Urban Futures, Inc. (UFI), developed a PrePendency Plan to serve as an initial first step toward cutting expenditures and balancing the Citys current fiscal year budget.3 The Pre-Pendency Plan4 was presented to the Common Council for consideration on August 30. After spirited and extensive discussions and debates, on September 17 and October 1, the Common Council approved the majority of cuts, revenue offsets and adjusted net transfers in/out recommended in the Pre-Pendency Plan. As a result, approximately $29.78 million of the projected current fiscal year $45.8 million budget deficit has been eliminated, leaving a remaining projected budget deficit of approximately $16.03 million for the current fiscal year.
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The Citys current fiscal year began on July 1, 2012 and ends on June 30, 2013. See, Docket Nos. 124, 125, 126, 127, 128, 129, 130, and 131. 3 Shortly after the Citys Common Council authorized the filing of a chapter 9 petition and a week prior to the Petition Date, the City adopted a Fiscal Emergency Operating Plan that served as an operating budget through September which allowed the City to maintain sufficient cash flow to pay its employees and provide basic services. 4 The Pre-Pendency Plan is a budget for the Citys operations until a Pendency Plan is finalized and approved.
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Unfortunately, during the month-long process of obtaining Common Council approval of the Pre-Pendency Plan, the Citys General Fund deficit continued to increase and the City was forced to defer payment of certain post-petition obligations, including the Citys portion of retirement contributions to CalPERS and certain trade debt as reflected in the Citys Cash Flow Position reports, in order to pay its employees and other obligations necessary to provide basic services to its citizens. The City is now implementing the Pre-Pendency Plan. B. The Citys Progress Toward A Pendency Plan.
City staff and UFI are diligently working to formulate a Pendency Plan, the next step toward restoring fiscal stability.5 The Pendency Plan will propose a plan to achieve a balanced budget for the Citys current fiscal year, make progress toward reducing the Citys enormous General Fund cash deficit6 and serve as an important step toward developing the plan of adjustment of the Citys debts. City staff intends to present the Pendency Plan to the Common Council for consideration on November 19, 2012, or as soon thereafter as possible. It is anticipated that as the Pre-Pendency Plan is implemented and once the Common Council approves the Pendency Plan, the Citys cash flow crisis will improve. As a practical and realistic matter, it is not an easy task to make the massive cuts that the City must make to correct its structural budget imbalance. The City started from an extraordinarily deep financial hole, and it is making every effort to solve its fiscal problems in a prudent manner. If approved in its entirety, the Pendency Plan will balance the Citys current fiscal year budget and allow the City to operate until a long-term plan of adjustment can be negotiated with the Citys creditors.
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The City believes it is important to clarify a point of confusion made evident by CalPERS objection. In the Citys pleadings filed in support of its eligibility for chapter 9 relief, the City makes references to its Pendency Plan and represented that the Pendency Plan was being developed. Given the magnitude of the Citys deep financial hole, City staff determined that making the radical cuts necessary to balance the Citys current fiscal year budget all at one time was impractical and would seriously compromise City operations and services. Thus, the City decided on a multi-phase process to make severe cuts over a period of time by first presenting a Pre-Pendency Plan for the initial expenditure reductions followed by a Pendency Plan proposing additional measures necessary to balance the Citys budget and mitigate the cash flow crisis. Due to the close timing of the deadline to file the Citys eligibility pleadings and finalizing the Pre-Pendency Plan, the City was unable to make the terminology clear that references to the Pendency Plan in its eligibility pleadings should be construed as references to the Pre-Pendency Plan and Pendency Plan. 6 As of October 8, 2012, the Citys General Fund had a negative cash balance of over $17.1 million.

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C.
The Status Of The Citys Efforts To Negotiate With Its Labor Groups.
As of late October, the City's negotiating team had met with all seven of the Citys bargaining units which consist of the following: General Employees Unit, Mid-Management Unit, Management/Confidential Unit, Police Safety, Police Management, Fire Safety, and Fire Management. The Fire Safety bargaining unit, which is represented by the San Bernardino City Professional Firefighters Local 891 (SBCPF), and the City will be entering into a stipulation to participate in a confidential mediation of disputes. During the initial meeting with each bargaining unit, the City's chief negotiator presented an overview of bargaining issues, including economic issues that will help mitigate the City's current cash flow problems. II. THE CITYS SUCCESS IN RESOLVING DISCOVERY ISSUES AND EFFORTS TO AVOID OBJECTIONS TO ITS ELIGIBILITY FOR CHAPTER 9 RELIEF. The City and most all of its major creditors worked together successfully to avoid costly litigation of two discovery motions and several joinders in those motions. The City entered into stipulations for the voluntary production of documents with its bond insurers, indenture trustees, the San Bernardino Police Officers Association (SBPOA), the SBCPF, and the San Bernardino Public Employees Association (SBPEA). Pursuant to the stipulations, the City voluntarily produced over 15,000 pages of documents. After review of the documents and discussions with the Citys bankruptcy counsel, almost all of the Citys major creditors decided not to object to the Citys eligibility to be a chapter 9 debtor. III. THE OBJECTIONS FILED TO THE CITYS ELIGIBILITY AND THE CITYS PROPOSAL TO ADJUDICATE ITS ELIGIBILITY FOR CHAPTER 9 RELIEF IN AN EFFICIENT AND COST EFFECTIVE MANNER. Despite ample and compelling evidence of the Citys eligibility for chapter 9 relief, the SBPEA7 and CalPERS8 filed objections (the Objections).9 In this section, the City provides the Court with a brief overview of the Objections because the City believes that many of the
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See, Docket Nos. 203, 204, 205 and 206. See, Docket Nos. 207, 207-1, 207-2, 207-3 and 207-4. 9 As discussed below, eight other objections from five different individuals and one corporation were also filed but state no cognizable grounds to the Citys eligibility for chapter 9 relief.

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issues raised in the Objections can be narrowed prior to engaging in the costly discovery process and a trial on eligibility. In so doing, the City does not intend to address all the issues raised in the Objections or engage in legal arguments on the merits of the Objections. Instead, the Citys goal is to identify issues that it believes can be narrowed as a matter of law and explain the basis for its proposal for an orderly process to address the Objections. The City also responds to the issues raised by CalPERS that go beyond objections to the Citys eligibility. A. CalPERS Preliminary Objection And Extraneous Requests For Affirmative Relief. CalPERS characterizes its objection as a preliminary objection and states that the goal of CalPERS is not to start a costly battle over eligibility but rather to defer any disputes about eligibility until the City has produced credible projections which could form the basis of a feasible plan.10 Before presenting an overview of CalPERS objection to the Citys eligibility, the City first addresses CalPERS improper requests for extraneous affirmative relief. First, CalPERS requests that the Court set a date by which the City must file a plan of adjustment under section 941.11 The City submits that this request is procedurally improper and must be brought by way of a noticed motion. Even if CalPERS had filed a motion seeking such relief, the City believes that it is premature to set a deadline for the City to file its plan of adjustment and that the City has demonstrated its diligence and progress toward financial stability by preparing a Fiscal Emergency Operating Plan prior to the Petition Date, obtaining Common Council approval of the Pre-Pendency Plan and working toward a Pendency Plan that it intends to present to the Common Council for consideration in the next several weeks. Second, CalPERS states that it reserves the right to later object on other grounds after conducting proper discovery and obtaining a clear picture of the Citys finances and the events that lead to the Citys filing.12 This is entirely inconsistent with CalPERS stated goal of avoiding a costly battle over the Citys eligibility, and CalPERS has no such right to reserve. The Courts Order Directing And Approving Form Of Notice And Setting Deadline For Filing
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See, CalPERS Objection at p. 1, lns. 10-12. See, CalPERS Objection at p. 12, lns. 20-28 and p. 13, lns. 1-6. 12 See, CalPERS Objection at p. 13, lns. 20-22.

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Objections To The City Of San Bernardino, Californias Petition (Objection Deadline Order)13 unambiguously established the deadline to file and serve all objections to eligibility as 5:00 p.m. on October 24, 2012.14 Just like the Citys other creditors, CalPERS had sufficient time and opportunity to seek limited discovery and review the documents the City voluntarily produced. The Courts deadline for filing eligibility objections has passed and neither CalPERS nor any other creditor should be permitted to file additional objections on any grounds. CalPERS assertion that despite its previous promises, the City has failed to provide interested parties with reliable financial information is not correct. CalPERS had time and opportunity to file a motion seeking limited discovery pursuant to the Courts Objection Deadline Order. Even after CalPERS chose not do so, the City offered to make available to CalPERS the over 15,000 pages of documents it produced to other creditors, but CalPERS did not avail itself of the opportunity to review them prior to filing its objection.15 Furthermore, CalPERS claim that it only recently learned that, contrary to the PrePendency Plan, the City has failed to make certain required payments to CalPERS16 is not credible. As CalPERS has acknowledged, [s]ince the Petition Date, the City has made certain cash flow reports available to the public though its website17 and those reports clearly state that the City has deferred payments to CalPERS due to the Citys dire liquidity crisis.18 The Citys Pre-Pendency Plan does not indicate that the City would continue to make payments to CalPERS.19 The Pre-Pendency Plan was a proposed short-term budget20 and did not constitute a
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See, Docket No. 111 entered on August 24, 2012. In fact, CalPERS Objection was untimely and filed after the deadline. If CalPERS believed it needed more time to file an objection, it could have sought relief from the Court prior to expiration of the deadline. 15 In early October, the Citys counsel sent CalPERS counsel the same stipulation entered into by the Citys other major creditors regarding the voluntary production of documents. CalPERS never signed the stipulation or advised the City that it was unacceptable. The City produced many documents containing detailed and reliable financial information respecting the Citys fiscal situation. Only after filing its objection did CalPERS counsel provide comments on the Citys proposed stipulation. 16 See, CalPERS Objection at p. 5, lns. 2-3. 17 See, CalPERS Objection at p. 5, lns. 7-8. 18 See, Exs. B and C to CalPERS Objection [Docket Nos. 207-2 and 207-3]. 19 See, Ex. A to CalPERS Objection [Docket No. 207-1]. 20 The Citys Pre-Pendency Plan showed that the City would be operating at a deficit as the proposed expenditures exceeded projected revenues.
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promise or representation that payments would not be deferred, and the Citys Cash Flow reports refute CalPERS position.21 Without addressing the merits, CalPERS objects to the Citys eligibility on two grounds: (1) the City cannot demonstrate a desire to effect a plan to adjust its debts because the City has not yet filed its Pendency Plan; and (2) the petition was not filed in good faith because the City has not filed a Pendency Plan in an effort to adjust its debts in a manner that is feasible and potentially confirmable under chapter 9 or demonstrated that it has negotiated with its creditors pre-petition or post-petition. While the City believes that the steps the City has taken are sufficient evidence of its desire to effect a plan to adjust its debts and that applicable law does not mandate that the City file a Pendency Plan or engage in negotiations with its creditors at any specific time period, City staff intend to present the Pendency Plan to the Common Council within a matter of weeks which may alleviate CalPERS concerns and resolve CalPERS Objection. As such, the City believes that its proposal set forth below to set a further status conference in approximately 45 days is consistent with CalPERS stated goal of avoiding a costly battle over eligibility and deferring any dispute about eligibility. B. The SBPEA Objection.
Despite efforts by the Citys bankruptcy counsel, the SBPEAs counsel was unable to engage in any meaningful dialogue with the City toward avoiding an objection to eligibility. To the extent that the City can decipher the SBPEAs arguments, the City believes that the SBPEA objects to the Citys eligibility on three grounds: (1) the City did not comply with AB 506 because a municipality may not fail or refuse to engage in the neutral evaluation process if knows [sic] that bankruptcy is a real possibility 60 days prior to filing a petition and the Citys declaration of fiscal emergency22 could have been avoided; (2) the City did not meet its burden of proof to show insolvency; and (3) the City did not file the petition in good faith. The City
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In addition, presumably CalPERS has a system in place for monitoring the status of payments by participants of the employers share of obligations due to CalPERS. 22 The SBPEA alleges that the City orchestrated its dire fiscal crisis for years to avoid AB 506s neutral evaluation process. This defies common sense because if, as the SBPEA contends, the City had known for years of the magnitude and dire nature of its cash flow crisis, staggering General Fund cash deficit and growing structural budget imbalance and avoiding the AB 506 neutral evaluation process had been the Citys goal, the City simply would have filed its petition before January 9, 2012, the effective date of AB 506.

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believes that it can significantly narrow the legal issues in the SBPEAs objection because the arguments are based on a misinterpretation of the statutory requirements of AB 506,23 and inapplicable and incorrect legal tests for insolvency and good faith. To the extent that the SBPEAs objection was filed because it believes that the City has unfairly treated its union members, the Citys request to set a further status conference may help mollify these concerns so that the City can make progress in its negotiations with its labor groups and talks with other creditors. C. Miscellaneous Defective Objections That Do Not State Cognizable Grounds Challenging The Citys Eligibility For Chapter 9 Relief. Eight other objections were filed by five individuals24 and one corporation.25 None of these objections state any cognizable grounds challenging the Citys eligibility for chapter 9. IV. CONCLUSION The City believes that there is good cause for the Court to set a further status conference in approximately 45 days to allow the City and the objecting parties to file additional legal briefs. This will also afford the Citys Common Council the opportunity to consider and approve the Pendency Plan which may help satisfy CalPERS concerns respecting the Citys desire and ability to effect a plan of adjustment of its debts. It will also save the City (and other parties) tens of thousands of dollars in potentially avoidable attorneys fees and costs taking discovery on issues that may be eliminated as a matter of law or otherwise resolved. To facilitate that goal, the City also requests that the Court order a stay of any discovery until further order of the Court to avoid the expense of discovery on issues that may be eliminated.
AB 506 is codified in California Government Code sections 53760 through 53760.7. Altheia Taylor filed three separate objections that do not state cognizable grounds challenging the Citys eligibility. See, Docket Nos. 194, 195 and 208. Barrye R. Hanson claims that he is a former employee and filed a letter stating that he objected to any reduction in his pension. See, Docket No. 165. Arthur Eads Jr. claims that he is a retiree and filed a letter stating that he objects to losing any of his retirement benefits. See, Docket No. 188. James A. Edwards, an inmate at Calipatria State Prison, filed an objection on grounds that are unclear but certainly not cognizable. James Crawford filed an objection asserting a claim for approximately $1,200 for damage to a vehicle caused by a traffic accident with a City vehicle. See, Docket No. 209. Susan Millslagle, who states that she is a former employee who asserted workers compensation claims against the City, also faxed a letter of protest to the Citys counsel, a copy of which will be provided to the Court. 25 Manta Management Corporation, Inc. filed an objection but it does not state grounds for any challenge to the Citys eligibility for chapter 9 relief. See, Docket No. 145. The City will propose a manner for addressing this objection at a further status conference.
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For these reasons, the City requests that the Court enter an order: (1) setting a further status conference on December 21, 2012 at 10:00 a.m.; (2) prohibiting any discovery pursuant to the Federal Rules of Bankruptcy Procedure until further order of this Court; and (3) establishing a briefing schedule26 for the purpose of narrowing the legal issues raised in the Objections challenging the Citys eligibility and scope of discovery as follows: the City must file and serve its opening brief on or before November 30, 2012; and CalPERS and the SBPEA must file and serve any response to the Citys opening brief on or before December 14, 2012. Dated: November 2, 2012 STRADLING YOCCA CARLSON & RAUTH A Professional Corporation By: /s/ Paul R. Glassman Paul R. Glassman Attorneys for City of San Bernardino, Debtor
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This proposed schedule has been communicated to counsel for the SBPEA and counsel for CalPERS.

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PROOF OF SERVICE OF DOCUMENT

I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is: 100 Wilshire Blvd., Suite 440, Santa Monica, CA 90401. A true and correct copy of the foregoing document entitled: CITY OF SAN BERNARDINO'S STATUS CONFERENCE STATEMENT will be served or was served (a) on the judge in chambers in the form and manner required by LBR 50052(d); and (b) in the manner stated below: 1. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Pursuant to controlling General Orders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On November 2, 2012, I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined that the following persons are on the Electronic Mail Notice List to receive NEF transmission at the email addresses stated below: Jerrold Abeles [email protected], [email protected] Franklin C Adams [email protected], [email protected];[email protected];[email protected] Joseph M Adams [email protected] Andrew K Alper [email protected], [email protected];[email protected] Thomas V Askounis [email protected] Anthony Bisconti [email protected] Jeffrey E Bjork [email protected] Sarah C Boone [email protected], [email protected] J Scott Bovitz [email protected] Jeffrey W Broker [email protected] Deana M Brown [email protected] Michael J Bujold [email protected] Christopher H Conti [email protected], [email protected] Christina M Craige [email protected] Alex Darcy [email protected] Susan S Davis [email protected] Robert H Dewberry [email protected] Todd J Dressel [email protected], [email protected] Chrysta L Elliott [email protected], [email protected] Scott Ewing [email protected], [email protected] Paul R. Glassman [email protected] David M Goodrich [email protected], [email protected] Everett L Green [email protected] Chad V Haes [email protected], [email protected] James A Hayes [email protected] M Jonathan Hayes [email protected], [email protected];[email protected];[email protected] D Edward Hays [email protected], [email protected] Eric M Heller [email protected] Bonnie M Holcomb [email protected] Whitman L Holt [email protected] Michelle C Hribar [email protected] Steven J Katzman [email protected] Jane Kespradit [email protected], [email protected] Mette H Kurth [email protected] Michael B Lubic [email protected], [email protected] Richard A Marshack [email protected], [email protected];[email protected]
This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California. June 2012
F 9013-3.1.PROOF.SERVICE
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Gregory A Martin [email protected] David J Mccarty [email protected], [email protected] Reed M Mercado [email protected] Aron M Oliner [email protected] Scott H Olson [email protected] Dean G Rallis [email protected] Christopher O Rivas [email protected] Kenneth N Russak [email protected], [email protected];[email protected] Gregory M Salvato [email protected], [email protected] Mark C Schnitzer [email protected], [email protected] Benjamin Seigel [email protected], [email protected] Diane S Shaw [email protected] Jason D Strabo [email protected], [email protected] Matthew J Troy [email protected] United States Trustee (RS) [email protected] Anne A Uyeda [email protected] Annie Verdries [email protected] Brian D Wesley [email protected] Kirsten A Roe Worley [email protected], [email protected]
Service information continued on attached page 2. SERVED BY UNITED STATES MAIL: On November 2, 2012, I served the following persons and/or entities at the last known addresses in this bankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail, first class, postage prepaid, and addressed as follows. Listing the judge here constitutes a declaration that mailing to the judge will be completed no later than 24 hours after the document is filed. Service information continued on attached page 3. SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL, FACSIMILE TRANSMISSION OR EMAIL (state method for each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on November 2, 2012, I served the following persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing to such service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declaration that personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document is filed. Honorable Meredith A. Jury (Personal delivery) U.S. Bankruptcy Court 3420 Twelfth Street, Suite 325 / Courtroom 301 Riverside, CA 92501-3819 Manta Management Corporation, Inc. (Overnight delivery) c/o ROGER JON DIAMOND 2115 Main Street Santa Monica, CA 90405 Althea Taylor (Overnight delivery) PO Box 30082 San Bernardino, CA 92413
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Arthur Brandon Eads Jr. (Overnight delivery) PO Box 390957 Anza, CA 92539 Barrye R. Hanson (Overnight delivery) 8987 Cielito Street Alta Loma, CA 91701 James Edwards (Overnight delivery) P.O. BOX 5002 Calipatria, CA 92233 Susan Millslagle (Overnight delivery) 10045 Jonathan Ave. Cherry Valley, CA 92223 Service information continued on attached page I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct.
November 2, 2012
Date
Christine Pesis
Printed Name
/s/ Christine Pesis

Signature
Attachment to Proof of Service

2. SERVED BY UNITED STATES MAIL: Defendant Jose Munoz 780 West Trenton Street San Bernardino, CA 92405 Defendant Michael Malcom Wade CDCR# AB7405 c/o Pleasant Valley State Prison P.O. Box 8500 Coalinga, CA 93210 Counsel to Defendant Jose Munoz Neil S. Steiner, Esq. Steiner & Libo, Professional Corporation 433 N Camden Dr Suite 730 Beverly Hills, CA 90210-4411 Counsel to Defendant Michael Wade Dale K Galipo, Esq. Law Offices of Dale K Galipo 21800 Burbank Boulevard Suite 310 Woodland Hills, CA 91367
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Everett L Green Office of the US Trustee 3685 Main St Ste 300 Riverside, CA 92501
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Case 6:12-bk-28006-MJ

STATUS CONFERENCE STATEMENT

-1STATUS CONFERENCE STATEMENT

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-3STATUS CONFERENCE STATEMENT

-4STATUS CONFERENCE STATEMENT

-5STATUS CONFERENCE STATEMENT

-6STATUS CONFERENCE STATEMENT

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PROOF OF SERVICE OF DOCUMENT

/s/ Christine Pesis

Attachment to Proof of Service

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