Taxpayers Watch Settles Suit Against LOCSD

Taxpayers Watch (TW) has settled its 2006 lawsuit with the Los Osos Community Services District (LOCSD), removing a key obstacle to resolving the District’s financial woes, presently knotted in bankruptcy.


In addition to Taxpayers Watch and the LOCSD, parties in the suit include TW officers Gordon Hensley and Joyce Albright, the State Water Resources Control Board (SWRCB), American Alternative Insurance Company (AAIC) and law firm Burke, Williams & Sorenson LLP (BWS). The agreement still has to be approved by the bankruptcy court.

The settlement requires former LOCSD attorneys Burke, Williams & Sorenson to drop payment claims and outstanding invoices against the District in bankruptcy court totaling $812,151.52, and for dismissal of any and all claims by TW against individual LOCSD board members and the District in TW’s Measure B suit and in bankruptcy. Taxpayers Watch has also agreed not to file any further complaints against the acquitted board members to the California Fair Political Practices Commission (FPPC).

The agreement calls for no admission of guilt or liability for any claim or cause of action by any party as a result of the Taxpayer Watch suit, and assigns “no validity or invalidity” to any claims filed by any of the parties. Taxpayers Watch filed its initial suit against the LOCSD in October 2005 and filed FPPC complaints against BWS and the individual board members in July 2009.

Julie Tacker, one of the former LOCSD members targeted by TW, believes “none of these (TW) players would have gotten a thing had the matter gone to trial.  It was the will of the five Directors being sued as individuals, as well at the currently seated LOCSD Board of Directors and more importantly the insurance company ordered by the court to defend us, to stop the bleeding… To that end, it’s (the suit) over. The debt incurred was the LOCSD’s and it was paid by the LOCSD or discharged to bankruptcy.”

Wrote Taxpayers Watch spokesperson Richard LeGros in part of an comment to The Razor, “The TW settlement is of huge benefit of all Los Osos taxpayers, and helps the LOCSD in balancing its books while reducing the LOCSD debt in the US bankruptcy Court… This is a great day for Los Osos as justice has been served.”

Burke, Williams & Sorenson will also pay TW attorney fees totaling $95,000, according the agreement released to local media by LeGros, one of the three recalled LOCSD board members, and provided to him by current LOCSD attorney Jon Seitz at the April 1 LOCSD meeting.

As a result of the settlement, all parties agree to dismiss any claims and counterclaims, and Taxpayers Watch agrees to waive any damage claims against individual board members Chuck Cesena, Lisa Schicker, Julie Tacker, Steve Senet and John Fouche.

According to the settlement, within 10 days of bankruptcy approval, AAIC will pay $348,150 to the SWRCB and $50,000 to TW attorneys, while BWS will pay $95,000 to TW attorneys. Within five days of monies exchanging hands, all suits and cross-suits will be dismissed.

The agreement copy provided by LeGros had not yet been signed by TW’s attorneys.

Taxpayers Watch, comprised of 2005 recalled former District board members and their supporters, filed suit as an organization, although Hensley and Albright also filed separately.

The agreement is not without its political ironies, since the LOCSD has signed the agreement and current board majority members Marshall Ochylski, Maria Kelly and Joe Sparks were all supported for election by Taxpayers Watch.

Taxpayers Watch had accused BWS of advising LOCSD members – some also former members of the Los Osos Technical Task Force (LOTTF) and Concerned Citizens of Los Osos (CCLO) political groups – to settle suits that TW claimed benefitted BWS and LOCSD board members by, in essence, agreeing to settle with themselves for financial gain. Those TW claims against individual board members were dismissed with prejudice in the settlement, which focuses primarily on BWS and the District.

Added Tacker, “The most important message to those in the public who might want to serve as a public official is that one can serve on a board, act as a board and not be sued individually by a vindictive recalled board majority to take our homes, as they desired. The entire matter has been another example of (five) years of wasted District resources and human energy.”

— Ed Ochs

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  • julie

    Aaron and Ed, (check my spelling, k?)

    Thanks for writing such a well researched piece, my only question is for Richard LeGros. When he says “The TW settlement is of huge benefit of all Los Osos taxpayers, and helps the LOCSD in balancing its books while reducing the LOCSD debt in the US bankruptcy Court.”

    I don’t know what he means…

    I see that it is taxpayers who pay for the settlement; it is the same taxpayers who pay insurance premiums and for malpractice insurance which is likely who will pay in BWS’ portion of the settlement. It may be different pockets, but still taxpayers.

    FYI, once AAIC was ordered by a court of law to pay for the case, it didn’t matter who was right or wrong, the judge and all attorneys involved just looked at a source for payment and embraced it like the greedy attorney’s they all are. It was the insurance company who pulled the plug on litigation, apparently not caring one way or another who was right or who was wrong. They just wanted the billing to stop, mediation and settlement were the fastest way to an end.

    **Notice that the 5 Directors are not signatories, the case morphed into TW vs. AAIC.

    It is AAIC insurance company who will pay the settlement amount; NONE of which will go into operating accounts of the LOCSD. — Again I ask, how does the LOCSD benefit?

    The only reprieve for the LOCSD is the BWS claim reduced in bankruptcy, which would have been pennies on the dollar anyway. I question the SWRCB receiving nearly $350K, ahead of other creditors, I have to ask “why?” Why don’t they have to get in line with all the other creditors and wait for the plan of debt adjustment? Maybe the BK judge will wonder about that too.

    When the document is signed by all parties legitimately and approved by the bankruptcy judge; then tell us more about how the settlement benefits to the LOCSD “balancing its books.”

    In the meantime, you are premature and ignorant to declare victory.

    As it says on Page 3, item 2;

    “No Admission: This Agreement does not constitute an admission or acknowledgement by any Part of any liability of the validity or invalidity of any claim or cause of action in the TW Action, the SWRCB Action, the Bankruptcy Action, or the Measure B Action.”

    Premature, hmmmm, just like your premature start on a wastewater project and your premature gray hair. Or better yet, premature donation (remember November 2002, when you donated the first $300 to the Parks and Rec fund? Oh yeah, that was a pledge, not really a donation — you never paid it, you just got credit for starting the fund).

    BTW, where’s that windfall of fines levied against the 5 Directors by the FPPC? Ah, nope, premature to call that too.

    Will you run again this fall? You know there are 3 seats, maybe 4, available. I’m sure Los Osos misses your sleeping through meetings. Oh, I’m sorry, I forgot, you had “eye problems.” Your eyes seem fine, able to spend hours in front of a computer screen, blogging away.

    “Blah, blah, blah” oops, “blah, blah, blah,” wasn’t blogging, that was doodling — during the board meeting when we discussed low income assistance. You were riveted in the conversation and what the public had to say.

    Send out yor press release when the judge has approved the settlement Richard. No one wins here. Only lawyers. You kow what they say about lawyers. Hey, who are you supporting for Supe? Your lawyer candidate or your Geophysicist? Tough choice.

  • http://xx julie

    Aaron and Ed, (check my spelling, k?)

    Thanks for writing such a well researched piece, my only question is for Richard LeGros. When he says “The TW settlement is of huge benefit of all Los Osos taxpayers, and helps the LOCSD in balancing its books while reducing the LOCSD debt in the US bankruptcy Court.”

    I don’t know what he means…

    I see that it is taxpayers who pay for the settlement; it is the same taxpayers who pay insurance premiums and for malpractice insurance which is likely who will pay in BWS’ portion of the settlement. It may be different pockets, but still taxpayers.

    FYI, once AAIC was ordered by a court of law to pay for the case, it didn’t matter who was right or wrong, the judge and all attorneys involved just looked at a source for payment and embraced it like the greedy attorney’s they all are. It was the insurance company who pulled the plug on litigation, apparently not caring one way or another who was right or who was wrong. They just wanted the billing to stop, mediation and settlement were the fastest way to an end.

    **Notice that the 5 Directors are not signatories, the case morphed into TW vs. AAIC.

    It is AAIC insurance company who will pay the settlement amount; NONE of which will go into operating accounts of the LOCSD. — Again I ask, how does the LOCSD benefit?

    The only reprieve for the LOCSD is the BWS claim reduced in bankruptcy, which would have been pennies on the dollar anyway. I question the SWRCB receiving nearly $350K, ahead of other creditors, I have to ask “why?” Why don’t they have to get in line with all the other creditors and wait for the plan of debt adjustment? Maybe the BK judge will wonder about that too.

    When the document is signed by all parties legitimately and approved by the bankruptcy judge; then tell us more about how the settlement benefits to the LOCSD “balancing its books.”

    In the meantime, you are premature and ignorant to declare victory.

    As it says on Page 3, item 2;

    “No Admission: This Agreement does not constitute an admission or acknowledgement by any Part of any liability of the validity or invalidity of any claim or cause of action in the TW Action, the SWRCB Action, the Bankruptcy Action, or the Measure B Action.”

    Premature, hmmmm, just like your premature start on a wastewater project and your premature gray hair. Or better yet, premature donation (remember November 2002, when you donated the first $300 to the Parks and Rec fund? Oh yeah, that was a pledge, not really a donation — you never paid it, you just got credit for starting the fund).

    BTW, where’s that windfall of fines levied against the 5 Directors by the FPPC? Ah, nope, premature to call that too.

    Will you run again this fall? You know there are 3 seats, maybe 4, available. I’m sure Los Osos misses your sleeping through meetings. Oh, I’m sorry, I forgot, you had “eye problems.” Your eyes seem fine, able to spend hours in front of a computer screen, blogging away.

    “Blah, blah, blah” oops, “blah, blah, blah,” wasn’t blogging, that was doodling — during the board meeting when we discussed low income assistance. You were riveted in the conversation and what the public had to say.

    Send out yor press release when the judge has approved the settlement Richard. No one wins here. Only lawyers. You kow what they say about lawyers. Hey, who are you supporting for Supe? Your lawyer candidate or your Geophysicist? Tough choice.

  • David Duggan

    Everyone can claim a victory of sorts just as long as you don’t dis’ the agreement. Yes it’s true the lawyers get the big bucks but isn’t that the way of it. I’m happy to see that a certain ex director has decided to do the right thing instead of keeping on poking a stick into the eye of the community. I have to agree that I don’t see where the taxpayers or the LOCSD as an agency has benifited from these lawsuits or the settlement. But putting to rest the tit for tat filings may go along way in cutting back on the mere rhetoric or at worse the quarrelsome nature of discourse in this community. Oops, I just remembered the County’s project that just happenes to be in LO.

  • David Duggan

    Everyone can claim a victory of sorts just as long as you don’t dis’ the agreement. Yes it’s true the lawyers get the big bucks but isn’t that the way of it. I’m happy to see that a certain ex director has decided to do the right thing instead of keeping on poking a stick into the eye of the community. I have to agree that I don’t see where the taxpayers or the LOCSD as an agency has benifited from these lawsuits or the settlement. But putting to rest the tit for tat filings may go along way in cutting back on the mere rhetoric or at worse the quarrelsome nature of discourse in this community. Oops, I just remembered the County’s project that just happenes to be in LO.

  • Richard LeGros

    Julie,

    I am Laughing Out Loud!
    REALLY LOUD!
    KNEE-SLAPPING, BELLY-ACHING, TEARS-RUNNING-DOWN-MY-FACE LOUD!

    None of the gibberish you wrote is worth responding to.

    Just be thankful, happy and relieved that BW&S and AACI paid the $1,310,000 to prevent you, Lisa, Chuck, Steve, and John from drowning in the legal quagmire created all by your own irresponsible and indefensible actions.

  • Richard LeGros

    Julie,

    I am Laughing Out Loud!
    REALLY LOUD!
    KNEE-SLAPPING, BELLY-ACHING, TEARS-RUNNING-DOWN-MY-FACE LOUD!

    None of the gibberish you wrote is worth responding to.

    Just be thankful, happy and relieved that BW&S and AACI paid the $1,310,000 to prevent you, Lisa, Chuck, Steve, and John from drowning in the legal quagmire created all by your own irresponsible and indefensible actions.

  • julie

    Richard wants to call the actions of our Board “irresponsible and indefensible”, now I’m Laughing Out Loud! REALLY LOUD!
    KNEE-SLAPPING, BELLY-ACHING, TEARS-RUNNING-DOWN-MY-FACE LOUD!

    The definition of irresponsible and indefensible = actions taken by the Board who pound millions into the ground prior to the recall. Or if Richard wants to remain innocent; go back futher to the Board Richard wasn’t on, the Board of Rose, Stan, Pandora, Sylvia and Gordon picking Tri-W in the first place.

    As for who’s paying the settlement, you’ll notice that not one thin dime is coming from John, Chuck, Steve, Lisa or me.

  • http://xx julie

    Richard wants to call the actions of our Board “irresponsible and indefensible”, now I’m Laughing Out Loud! REALLY LOUD!
    KNEE-SLAPPING, BELLY-ACHING, TEARS-RUNNING-DOWN-MY-FACE LOUD!

    The definition of irresponsible and indefensible = actions taken by the Board who pound millions into the ground prior to the recall. Or if Richard wants to remain innocent; go back futher to the Board Richard wasn’t on, the Board of Rose, Stan, Pandora, Sylvia and Gordon picking Tri-W in the first place.

    As for who’s paying the settlement, you’ll notice that not one thin dime is coming from John, Chuck, Steve, Lisa or me.

  • Richard LeGros

    Julie,

    You can thank TW for shielding you, Chuck, Steve, Lisa and John from having to personally pay anything towards the settlement by insisting that all settlement money come exclusively from BW&S and AACI.

    You can thank TW for being merciful by not being interested in ‘vengeance’ as you claim. It is obvious by the very nature and conditions of the settlement that the only intent of the TW lawsuit was to recover as much of the $1,495,000 that the LOCSD’s own audits and financial records show that you and yours illegally misappropriated. If ‘vengeance’ was of any concern to TW we would have been at trial years ago; with TW mercilessly pounding you and yours legally into the ground; and holding you legally responsible for the damage too. Be grateful that such a scenario did not occur.

    Julie, accept the settlement as it benefits you personally, and benefits the entire community of Los Osos too. The time of fighting is over.

    Time to enjoy a peaceful Saturday afternoon.

  • Richard LeGros

    Julie,

    You can thank TW for shielding you, Chuck, Steve, Lisa and John from having to personally pay anything towards the settlement by insisting that all settlement money come exclusively from BW&S and AACI.

    You can thank TW for being merciful by not being interested in ‘vengeance’ as you claim. It is obvious by the very nature and conditions of the settlement that the only intent of the TW lawsuit was to recover as much of the $1,495,000 that the LOCSD’s own audits and financial records show that you and yours illegally misappropriated. If ‘vengeance’ was of any concern to TW we would have been at trial years ago; with TW mercilessly pounding you and yours legally into the ground; and holding you legally responsible for the damage too. Be grateful that such a scenario did not occur.

    Julie, accept the settlement as it benefits you personally, and benefits the entire community of Los Osos too. The time of fighting is over.

    Time to enjoy a peaceful Saturday afternoon.

  • julie

    Dick,

    First you say “None of the gibberish you wrote is worth responding to.” Then you respond anyway.

    Then you say, “You can thank TW for shielding you, Chuck, Steve, Lisa and John from having to personally pay anything towards the settlement by insisting that all settlement money come exclusively from BW&S and AACI.” While I won’t discuss settlement negotiations; you shouldn’t either, I have never heard of such a thing.

    I never used the word “vengeance,” but if the shoe fits wear it!

    Then you go on to say; “accept the settlement as it benefits you personally, and benefits the entire community of Los Osos too. The time of fighting is over.” To that I say, Dick, accept that there will never be a sewer on the Tri-W site as it benefits you personally, and benefits the entire community of Los Osos too. The time of fighting is over.

    And lastly, just a reminder, “No Admission: This Agreement does not constitute an admission or acknowledgement by any Part of any liability of the validity or invalidity of any claim or cause of action in the TW Action, the SWRCB Action, the Bankruptcy Action, or the Measure B Action.” Only you could misunderstand the meaning of this clause within the settlement.

    You use the word “misappropriate” as though we lined our personal pockets with taxpayer funds. The audits clearly show LOCSD debt was paid by LOCSD funds. No Director benefitted from LOCSD funds. Accept that!

  • http://xxx julie

    Dick,

    First you say “None of the gibberish you wrote is worth responding to.” Then you respond anyway.

    Then you say, “You can thank TW for shielding you, Chuck, Steve, Lisa and John from having to personally pay anything towards the settlement by insisting that all settlement money come exclusively from BW&S and AACI.” While I won’t discuss settlement negotiations; you shouldn’t either, I have never heard of such a thing.

    I never used the word “vengeance,” but if the shoe fits wear it!

    Then you go on to say; “accept the settlement as it benefits you personally, and benefits the entire community of Los Osos too. The time of fighting is over.” To that I say, Dick, accept that there will never be a sewer on the Tri-W site as it benefits you personally, and benefits the entire community of Los Osos too. The time of fighting is over.

    And lastly, just a reminder, “No Admission: This Agreement does not constitute an admission or acknowledgement by any Part of any liability of the validity or invalidity of any claim or cause of action in the TW Action, the SWRCB Action, the Bankruptcy Action, or the Measure B Action.” Only you could misunderstand the meaning of this clause within the settlement.

    You use the word “misappropriate” as though we lined our personal pockets with taxpayer funds. The audits clearly show LOCSD debt was paid by LOCSD funds. No Director benefitted from LOCSD funds. Accept that!

  • Richard LeGros

    Julie,

    Accept the settlement.
    The war is over.

  • Richard LeGros

    Julie,

    Accept the settlement.
    The war is over.

  • julie

    Who said I wasn’t?

  • http://xxx julie

    Who said I wasn’t?

  • Richard LeGros

    Ed / Aaron,

    Just an FYI over a few errors in our reporting.

    The Rock posted:
    ‘The agreement is not without its political ironies, since the LOCSD has signed the agreement and current board majority members Marshall Ochylski, Maria Kelly and Joe Sparks were all supported for election by Taxpayers Watch.’

    Correction: Taxpayers Watch has never endorsed any political canidate(s) seeking election to any political office(s).

    The Rock posted:
    ‘The agreement copy provided by LeGros had not yet been signed by all the parties, and it is unclear whether it is the final document awaiting additional signatures or a draft version lacking signatures because it is not the final, approved document.’

    Clarification: The ‘copy’ LeGros provided was obtained from directly from the Los Osos Community Services District; as the district had released at the April 1, 2010 LOCSD Board meeting.
    The ‘copy’ provided is the final settlement agreement accepted by, and has been signed by, all pertinent parties in the settlement agreement.

    The Rock posted:
    ‘Taxpayers Watch filed its initial suit against the LOCSD in October 2006 and filed FPPC complaints against BWS and the individual board members in July 2009.

    Correction: The initial Taxpayers Watch public waste lawsuit was filed in February, 2006 (not October as reported).
    The FPPC, while filed reported, has bsolutely no connection with the causes of action of the public waste lawsuit.
    The lawsuit dealt with violations of Cal Code Sec.526a
    The FPPC complaints dealt with violations regarding improper filings of financial relationships on Form 700 by the elected officials named; and improper form 700 filings by the then distinct council, Julia Biggs of Burke, Williams and Sorenson LLP.

  • Richard LeGros

    Ed / Aaron,

    Just an FYI over a few errors in our reporting.

    The Rock posted:
    ‘The agreement is not without its political ironies, since the LOCSD has signed the agreement and current board majority members Marshall Ochylski, Maria Kelly and Joe Sparks were all supported for election by Taxpayers Watch.’

    Correction: Taxpayers Watch has never endorsed any political canidate(s) seeking election to any political office(s).

    The Rock posted:
    ‘The agreement copy provided by LeGros had not yet been signed by all the parties, and it is unclear whether it is the final document awaiting additional signatures or a draft version lacking signatures because it is not the final, approved document.’

    Clarification: The ‘copy’ LeGros provided was obtained from directly from the Los Osos Community Services District; as the district had released at the April 1, 2010 LOCSD Board meeting.
    The ‘copy’ provided is the final settlement agreement accepted by, and has been signed by, all pertinent parties in the settlement agreement.

    The Rock posted:
    ‘Taxpayers Watch filed its initial suit against the LOCSD in October 2006 and filed FPPC complaints against BWS and the individual board members in July 2009.

    Correction: The initial Taxpayers Watch public waste lawsuit was filed in February, 2006 (not October as reported).
    The FPPC, while filed reported, has bsolutely no connection with the causes of action of the public waste lawsuit.
    The lawsuit dealt with violations of Cal Code Sec.526a
    The FPPC complaints dealt with violations regarding improper filings of financial relationships on Form 700 by the elected officials named; and improper form 700 filings by the then distinct council, Julia Biggs of Burke, Williams and Sorenson LLP.

  • Richard LeGros

    Oops.In the first sentence above I meant ‘YOUR reporting’, not ‘OUR reporting’.

    Have a good Easter!

  • Richard LeGros

    Oops.In the first sentence above I meant ‘YOUR reporting’, not ‘OUR reporting’.

    Have a good Easter!

  • Ed

    Richard,

    Re: Corrections

    You claim: “Taxpayers Watch has never endorsed any political canidate(s) seeking election to any political office(s).”

    Rock Response: Yes it has, in a 2006 mailer endorsing Maria Kelly, Lynette Tornatsky and Joe Sparks for CSD. Besides, the article uses the word “supported” not “endorsed.”

    Your clarification: “The ‘copy’ LeGros provided was obtained directly from the Los Osos Community Services District; as the district had released at the April 1, 2010 LOCSD Board meeting.”

    Response: You stated to The Razor the settlement agreement was released by Jon Seitz, a counsel for the LOCSD, which coincides with your clarification. We are looking further into the release of the agreement.

    Your correction: “The ‘copy’ provided is the final settlement agreement accepted by, and has been signed by, all pertinent parties in the settlement agreement.”

    Rock Response: Only TW’s attorneys have yet to sign the agreement.

    Posted: “‘Taxpayers Watch filed its initial suit against the LOCSD in October 2006 and filed FPPC complaints against BWS and the individual board members in July 2009.”

    Your correction: “The initial Taxpayers Watch public waste lawsuit was filed in February, 2006 (not October as reported). The FPPC, while filed reported, has absolutely no connection with the causes of action of the public waste lawsuit.

    Rock Response: The settlement agreement only refers to the October 2005 Taxpayers Watch filing, which is inconsistent with your correction. The Rock has corrected the typo indicating the filing was October 2006. TW’s FPPC complaint is part of the settlement agreement which is why it is included in the article.

    You claim: “The lawsuit dealt with violations of Cal Code Sec.526a. The FPPC complaints dealt with violations regarding improper filings of financial relationships on Form 700 by the elected officials named; and improper form 700 filings by the then distinct council, Julia Biggs of Burke, Williams and Sorenson LLP.”

    Rock Response: Regarding TW’s FPPC complaint against the “CSD5,” the settlement agreement finds no violations regarding improper filings of financial relationships by the elected officials named.

    We will make any necessary clarifications and typo correction.

  • http://2&FF Ed

    Richard,

    Re: Corrections

    You claim: “Taxpayers Watch has never endorsed any political canidate(s) seeking election to any political office(s).”

    Rock Response: Yes it has, in a 2006 mailer endorsing Maria Kelly, Lynette Tornatsky and Joe Sparks for CSD. Besides, the article uses the word “supported” not “endorsed.”

    Your clarification: “The ‘copy’ LeGros provided was obtained directly from the Los Osos Community Services District; as the district had released at the April 1, 2010 LOCSD Board meeting.”

    Response: You stated to The Razor the settlement agreement was released by Jon Seitz, a counsel for the LOCSD, which coincides with your clarification. We are looking further into the release of the agreement.

    Your correction: “The ‘copy’ provided is the final settlement agreement accepted by, and has been signed by, all pertinent parties in the settlement agreement.”

    Rock Response: Only TW’s attorneys have yet to sign the agreement.

    Posted: “‘Taxpayers Watch filed its initial suit against the LOCSD in October 2006 and filed FPPC complaints against BWS and the individual board members in July 2009.”

    Your correction: “The initial Taxpayers Watch public waste lawsuit was filed in February, 2006 (not October as reported). The FPPC, while filed reported, has absolutely no connection with the causes of action of the public waste lawsuit.

    Rock Response: The settlement agreement only refers to the October 2005 Taxpayers Watch filing, which is inconsistent with your correction. The Rock has corrected the typo indicating the filing was October 2006. TW’s FPPC complaint is part of the settlement agreement which is why it is included in the article.

    You claim: “The lawsuit dealt with violations of Cal Code Sec.526a. The FPPC complaints dealt with violations regarding improper filings of financial relationships on Form 700 by the elected officials named; and improper form 700 filings by the then distinct council, Julia Biggs of Burke, Williams and Sorenson LLP.”

    Rock Response: Regarding TW’s FPPC complaint against the “CSD5,” the settlement agreement finds no violations regarding improper filings of financial relationships by the elected officials named.

    We will make any necessary clarifications and typo correction.