Arcata Ordered To Pay $2.4 Million By End Of Week – December 20, 2012

Thursday, December 20, 2012
In March, 2011, City officlals scrambled to reroute funding out of its doomed Redevelopment Agency in order to save its affordable housing and other projects. Now, says the State of California, that's not legal, and the City has to repay the funds it has spent on housing projects. KLH | Eye

In March, 2011, City officlals scrambled to reroute funding out of its doomed Redevelopment Agency in order to save its affordable housing and other projects. It seemed exciting and innovative at the time, but now, says the State of California, the maneuvers weren’t legal, and the City has to repay the funds it has spent on housing projects. KLH | Eye

Kevin L. Hoover

Eye Editor

ARCATA – Imagine the City of Arcata bankrupt and its top staff, plus the City Council, all in jail.

Those not-impossible consequences could result from a decision made last week by the state’s Department of Finance (DOF). More immediately, the City has to pay an unexpected bill in the millions of dollars.

In a Dec. 15 letter, the DOF has told the City of Arcata that it is exercising its authority to “claw back assets that were inappropriately transferred,” and expects a payment of $2.415 million made to the county auditor by tomorrow, Dec. 21.

The stunning blow stems from the City’s efforts in March, 2011, to salvage the affordable housing projects it had been funding via the Redevelopment Agency. When the cash-strapped State of California dissolved redevelopment agencies and claimed the funds, the City scrambled to transfer and obligate those monies before they could be taken away.

But in its letter to the Successor Agency (which succeeded the defunct Redevelopment Agency, or RDA, and is composed of members of the City Council), the DOF called Arcata out on its fancy maneuvers, saying the City had no legal grounds on which to make the funding transfers.

Stated the letter, “the $1,858,432 transferred during March, 2011 is not allowed.” The letter states that the City’s actions run contrary to the legislation that directed the wind-down in redevelopment, ABx1-26 and AB1484.

The $2.4 million total includes $1,858,432 paid out for the Sandpiper affordable housing project, which is near completion. A smaller portion, $200,000, was spent on the Plaza Point senior housing project.

The unfinished Sandpiper project could grind to a halt because of the snafu. The developer, Resident Owned Parks (ROP), is being asked to repay the City funds it had been given to construct the 16 homes and three apartments there.

Deputy Community Development Director David Loya said the City will make “diligent, good faith efforts” to bill the private entities which received the funds and get the money back.

But, noted Loya several times in his briefing to the Successor Agency last night, recouping the funds could be problematic. “The money is gone. It’s spent,” he said.

Now what?

In a worst-case scenario, the state Board of Equalization could make the City repay the state out of future sales tax increments and property taxes, eliminating Arcata’s tax income and making bankruptcy inevitable.

Or, the state could accept repayments via installments and forego the tax grab. Other possibilities include the City taking legal action against the state, or working with its political allies to have the DOF reverse its ruling.

While all the consequences are unclear, they could include legal action against the City by affected contractors, and even legal prosecution of City staff and elected officials who were involved in redirecting the redevelopment funds.

Meanwhile, though, Arcata is looking at a seven-figure bill. The money is payable to the “taxing entity,” that is, the county auditor, for redistribution to schools, fire districts and others.

Per a vote by the Successor Agency last night, the City will make an immediate payment of $306,927 in unspent funds. It will still owe more than $2 million.

The City has 60 days to recoup the funds it has disbursed to private entities. After that, if it hasn’t repaid the total amount, a 10 percent penalty kicks in.

Ominously, the DOF letter states, “willful failure to return assets that were deemed an unallowable transfer or failure to remit the funds identified above could expose certain individuals to criminal penalties under existing law.”

‘The only choice’

Mayor Shane Brinton defended the City’s actions.

“I think it was the only choice we could make,” he said. “We knew it was a risk.”

He said it is unlikely that anyone will be prosecuted as long as the City is making good-faith efforts to recoup the funds and pay them back.

City Attorney Nancy Diamond said that the City is cooperating with the state by making the initial payment and billing Sandpiper for repayment of funds it has received.

“We’re doing what we have to do under the statutes, and making diligent efforts to recover the money,” she said.

Diamond said that the City is researching its options and will have better information about a course of action in January. That could include court action against the state or the third parties who have received the funds.

She said other municipalities’ efforts to fight the state in court weren’t going very well.

Brinton pointed out that the Oversight Board to the Successor Agency, whose members are representatives of the agencies which would have benefitted from the City surrendering redevelopment funding, nonetheless “unanimously” supported the City in pursuing the affordable housing projects instead.

“These projects were planned prior to the theft of redevelopment,” he said. “I consider the money our money.”

He and Loya noted that the City had already spent significant sum on Sandpiper when it decided in Sept., 2011 to go ahead and complete the project. Failing to do so would have left the City with what Loya called “a beautiful, million-dollar hole in the ground.”

Brinton said he was contacting Assemblymember Wes Chesbro to enlist his support. He also noted that former Assemblymember, Arcata Mayor and City Manager Dan Hauser is on ROP’s board of directors.

The DOF, Brinton suggested, ruled by executive fiat, and might be able to reverse its decison if properly persuaded.

“They could change their mind,” he said. “Hopefully we can cobble together a little group of power players and see what we can do in Sacramento.”

He said the governor and legislature had “acted out of desperation” and against their Democratic principles. Now, with a supermajority in the legislature, he hoped that “maybe there’s a way to bring back redevelopment.”

As far as the threat of criminal penalties for City officials, he  doesn’t think criminalizing City workers over redevelopment funding is a a realistic possibility. He pointed out that the federal government had also suggested that it might prosecute individual employees who administer Arcata’s medical cannabis laws, and didn’t.

Fight or not?

“If there’s any way to continue to fight, I think that’s what needs to happen,” Brinton said last night. He called the turn of events “totally insane” and said the City should pursue “any potential legal recourse.”

Successor Agency Member Susan Ornelas disagreed. She said that with things not going well for other cities who are fighting the state, Arcata should to avert the possibility of penalties accruing.

“I don’t think resisting this is going to be the way to go,” she said. “Unless we have someone else we can appeal to besides the same people who keep telling us the same thing… it’s almost just an insanity to think we’re going to get something different.”

Loya pointed out again that the state is demanding $2.4 million, and “we just don’t have it.”

He said the Sandpiper units are steadily selling, though, and each one purchased for $60,000 will mean another payment the City can make in that amount to help offset the sudden debt.

‘Outrageous’

Speaking on behalf of ROP, Dan Hauser called the DOF decision “outrageous.”

“Some lower-level bureaucrat in the Department of Finance has taken it upon themselves to overturn not only a realistic determination of the law, but the City and the Oversight Board,” Hauser said.

He said ROP can’t give back money it has already spent. “Obviously, there’s no way that ROP or any of the other moderate and low-income housing folks could send money back to the City,”  he said. “That would bankrupt the organization. I guess we just hand over Sandpiper to the state, unfinished?”

Hauser said he’d already been in touch with the offices of Chesbro and Evans. “This is one of those things that we’re going to have to involve our legislators to correct the Department of Finance,” he said, noting that “nothing will happen until after the first of the year.”

Hauser decried “a flat-out misinterpretation of the law” and said that “a low-level bureaucrat wielding all this power is something we may have to take up with the governor.”

Lamenting “the absurdity of the whole thing,” Hauser added, “All we’re trying to do is provide housing for folks. To be slapped down this way is outrageous.”

Early warnings

The startling turn of events wasn’t unforeseen. It just went from bad to worse.

In a “Due Diligence Report” (DDR) dated Nov. 9, the DOF had first ordered the Successor Agency to turn over $1,310,497. This led to a “meet and confer” between City and DOF officials, in which the City pled its case.

But the “final determination” which followed last week overturned the original finding and resulted in an even bigger bill.

“They essentially rejected all of the arguments made by staff,” Loya said.

But so had a former member of the Oversight Board, Arcata architect Kash Boodjeh. He cited a “clear lack” of transparency as one of the reasons he resigned.

In a Nov. 28 letter to the DOF, Boodjeh said the board had been misdirected into making poor choices by its leadership and legal counsel.

He said members of the Oversight Board and its legal counsel repeatedly characterized the law as “confused” for self-serving reasons – to “manipulate the information and prevent what was constantly being referred to as ‘a take’ by the state.”

He said that after reading the law and attending briefings in preparation for his service, “the state deadlines and rules seemed pretty darn clear to me.”

Arcata, like other California cities gouged by the loss of redevelopment, “is not the only one having a hard time letting go of what it considers its own, remaining in denial and creating alternate realities,” Boodjeh said.

He placed the blame squarely on the City. “They have broken the law, knowingly,” he said. “The gaffe is totally ours.”

Boodjeh told the Successor Agency last night that the Oversight Board’s vote last March May to support the City’s use of the funds for housing was not unanimous. Then still a member, he had abstained “due to lack of complete and clear information.”

‘Zapped’

Regardless of the outcome of the DOF/DDR/ROP/Successor Agency/Oversight Board imbroglio, Community Development Director Larry Oetker observed that the traditional manner in which the City has created affordable housing has been completely destroyed.

“We have to look at the entire affordable housing program and how we have done affordable housing,” Oetker said. “It’s just gone. It’s zapped.”

He said that the City is how “in a $2.4 million hole” from which it will have to dig out “before we can even think about doing new projects.”

Calling it a “watershed moment,” Oetker said, “It’s a large-scale, complete revamping of the system that we’ve operated on.”

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58 Responses to “Arcata Ordered To Pay $2.4 Million By End Of Week – December 20, 2012”

  1. Licia Good

    This reminds me of the 10% MediCal reimbursement reduction to providers and how the State of California is trying to make it retroactive to 2011. Can you imagine the nightmare for the doctors, clinics and hospitals that will have to return the funds already paid to them for almost two years besides getting a 27% reduction next year for medicare and medicaid?

    #64771
  2. Licia Walborn Good

    This reminds me of the 10% MediCal reimbursement reduction to providers and how the State of California is trying to make it retroactive to 2011. Can you imagine the nightmare for the doctors, clinics and hospitals that will have to return the funds already paid to them for almost two years besides getting a 27% reduction next year for medicare and medicaid?

    #65460
  3. Sean Mo

    Assuming Sandpiper is 18 units, $1.8 million/18 =$100k per unit cost. Doesn't make much sense to sell the units for $60k. Glad Arcata is going to have to pay for their largesse instead of the rest of the state. Hope Arcata does not sue the states because the court costs ensure that all Californians will lose.

    #64772
  4. Sean Mo

    Assuming Sandpiper is 18 units, $1.8 million/18 =$100k per unit cost. Doesn't make much sense to sell the units for $60k. Glad Arcata is going to have to pay for their largesse instead of the rest of the state. Hope Arcata does not sue the states because the court costs ensure that all Californians will lose.

    #65461
  5. Jim Sousa

    Where's the Chezz' when we need him? Patti Berg? Nobody the clout anymore or what? Willie is still in the game maybe he can put a word in…

    #64773
  6. Jim Sousa

    Where's the Chezz' when we need him? Patti Berg? Nobody the clout anymore or what? Willie is still in the game maybe he can put a word in…

    #65462
  7. Anonymous

    I don't see political maneuvering getting Arcata out of this pickle. The state would have a hard time justifying rescuing one city and not the other cities.

    Also, does it not matter whether the original decision was made in good faith (e.g., an honest misunderstanding)? When Brinton is quoted as saying, 'We knew it was a risk,' that doesn't sound like the decision was made in good faith.

    #64774
  8. Anonymous

    I don't see political maneuvering getting Arcata out of this pickle. The state would have a hard time justifying rescuing one city and not the other cities.

    Also, does it not matter whether the original decision was made in good faith (e.g., an honest misunderstanding)? When Brinton is quoted as saying, 'We knew it was a risk,' that doesn't sound like the decision was made in good faith.

    #65463
  9. yes lets attack small cities but ignore cities like newport beach, costa mesa, carlsbad, del mar, ect They have way more problems than arcata. These other cities can wipe out the deficit that this stupid state has.Sure arcata has tried to get out of this mess but Really! but I guess they are going after the pot growers who are supplying this state's economy.

    #64776
  10. yes lets attack small cities but ignore cities like newport beach, costa mesa, carlsbad, del mar, ect They have way more problems than arcata. These other cities can wipe out the deficit that this stupid state has.Sure arcata has tried to get out of this mess but Really! but I guess they are going after the pot growers who are supplying this state's economy.

    #65464
  11. [...] Arcata Ordered To Pay .4 Million By End Of Week – December 20, 2012 ARCATA – Imagine the City of Arcata bankrupt and its top staff, plus the City Council, all in jail. Those not-impossible consequences could result from a decision made last week by the state's Department of Finance (DOF). More immediately, the City has … Read more on Arcata Eye [...]

    #64778
  12. google Marc Delany and Arcata Eye…. not a surprise.

    #64781
  13. google Marc Delany and Arcata Eye…. not a surprise.

    #65465
  14. Cody Turnbaugh

    Oh. I see. Canibalism (overt and obvious this time). What a great way to save the Golden $tate.

    #64783
  15. Cody Turnbaugh

    Oh. I see. Canibalism (overt and obvious this time). What a great way to save the Golden $tate.

    #65467
  16. Kyle Jensen

    “I think it was the only choice we could make,” he said. “We knew it was a risk.”.
    "They've broken the law, knowingly".

    I think that the ones that made these "risks" need to be punished, not the people or children of Arcata. So since these people irresponsibly spent the states money our children's schools, parks, community areas and other resources that depend on our taxpaying dollars will now be wasted on a 2.4 million dollar bill that comes as a result of bad policy decisions? :(

    #64785
  17. Kyle Jensen

    “I think it was the only choice we could make,” he said. “We knew it was a risk.”.
    "They've broken the law, knowingly".

    I think that the ones that made these "risks" need to be punished, not the people or children of Arcata. So since these people irresponsibly spent the states money our children's schools, parks, community areas and other resources that depend on our taxpaying dollars will now be wasted on a 2.4 million dollar bill that comes as a result of bad policy decisions? :(

    #65468
  18. Kevin Hoover

    What kind of punishment do you have in mind?

    #64786
  19. Kevin Hoover

    What kind of punishment do you have in mind?

    #65478
  20. Anonymous

    $1,858,432 for 16 residential units and 3 apartments?

    That equates to $97,812 per unit.

    And they're selling for $60,000 apiece?

    I work for a living and only had financial access to a 1,300 square foot home with serious foundation problems for $70,000.

    I guess it pays to be poor.

    Bye the way, Shane Brinton as mayor offering his reasoning just proves he never got out of the terrible twos. That money isn't "yours", it's "ours" and you/your City powers that be acted not only irresponsibly, but also illegally.

    #65469
  21. Kyle Ray

    String em' up! Just kidding, to be honest I didn't have a punishment in mind. 2.4 million dollar risks should't be taken in these fragile economic times though.. Especially if they knew that this outcome was a possibility! As it explains in the article Arcata "…made an immediate payment of $306,927 in unspent funds. It will still owe more than $2 million.".. Arcata is looking at a seven-figure bill. The money is payable to the “taxing entity,”" and I think I also read that the city will have to divert resources (money) from important programs and places such as schools, firefighters etc. to make up for this mistake, which I don't think is right.

    #64789
  22. Kyle Jensen

    String em' up! Just kidding, to be honest I didn't have a punishment in mind. 2.4 million dollar risks should't be taken in these fragile economic times though.. Especially if they knew that this outcome was a possibility! As it explains in the article Arcata "…made an immediate payment of $306,927 in unspent funds. It will still owe more than $2 million.".. Arcata is looking at a seven-figure bill. The money is payable to the “taxing entity,”" and I think I also read that the city will have to divert resources (money) from important programs and places such as schools, firefighters etc. to make up for this mistake, which I don't think is right.

    #65479
  23. Kevin Hoover

    Kyle Ray Actually, the one thing we know is that the City WON'T "have to divert resources (money) from important programs and places such as schools, firefighters etc. to make up for this mistake."

    The City doesn't provide any funding for schools and firefighters. Those agencies – the school districts and fire department – are entirely independent of the City of Arcata. In fact, if the state's decision holds, schools and firefighters could very well get the $2.4 million the City spent on the housing projects. It must be repaid to the taxing entity, which could reallocate the funds to the agencies who had representatives on the oversight board – schools and firefighters among them.

    But you are essentially correct in that other City programs could be cut to in order to make up the repayments, as the housing money has been spent. Also, the City could get into its reserves to conjure the repayment funds.

    #64791
  24. Kevin Hoover

    Kyle Ray Actually, the one thing we know is that the City WON'T "have to divert resources (money) from important programs and places such as schools, firefighters etc. to make up for this mistake."

    The City doesn't provide any funding for schools and firefighters. Those agencies – the school districts and fire department – are entirely independent of the City of Arcata. In fact, if the state's decision holds, schools and firefighters could very well get the $2.4 million the City spent on the housing projects. It must be repaid to the taxing entity, which could reallocate the funds to the agencies who had representatives on the oversight board – schools and firefighters among them.

    But you are essentially correct in that other City programs could be cut to in order to make up the repayments, as the housing money has been spent. Also, the City could get into its reserves to conjure the repayment funds.

    #65480
  25. Ian Ray

    Regardless of one's opinion of tax increment financing and redevelopment, it does seem that Arcata moving money around was illegal. The situation appears to be that California cancelled the entire property tax scheme and Arcata refused to go along with that. No amount of "power players" will fix this as Gov. Jerry Brown already signed off on what is the current legal reality. In the best interest of citizens, Arcata could have just accepted that there would be no more TIF the minute it was true instead of trying some creative accounting tricks and hoping everything would work out.

    I do hope everything does work out, but this all seems to me like a "duh" moment where this mess could have been completely avoided.

    #64793
  26. Ian Ray

    Regardless of one's opinion of tax increment financing and redevelopment, it does seem that Arcata moving money around was illegal. The situation appears to be that California cancelled the entire property tax scheme and Arcata refused to go along with that. No amount of "power players" will fix this as Gov. Jerry Brown already signed off on what is the current legal reality. In the best interest of citizens, Arcata could have just accepted that there would be no more TIF the minute it was true instead of trying some creative accounting tricks and hoping everything would work out.

    I do hope everything does work out, but this all seems to me like a "duh" moment where this mess could have been completely avoided.

    #65470
  27. Might get worse before it gets better, Arcata Mobile Home Park was also done at the same time. Don't worry though, Dan Hauser is now a member of ROP.

    #64795
  28. Might get worse before it gets better, Arcata Mobile Home Park was also done at the same time. Don't worry though, Dan Hauser is now a member of ROP.

    #65471
  29. What was suggest many times before, by the CC and others (me, for instance)… Training. Fines to specific programs. Resignation… Better legal representation. Professional requirements of staff… Transparency… Citizen Access… Those things enjoyed by every jurisdiction in CA, except this one, and those others making the front page of the NY Times… Check how often Arcata makes the times in the past few years……. did anyone read the related Arcata Eye story from a member of the oversight entity??? There was a suggestion that the transparency was less than what should have been, and an alternative view on what confusing about state direction…?? "It is difficult to get a man to understand something, when his salary depends upon his not … S. Lewis. The state intended staff reductions too, btw…

    When every committee member, and every commissioner resigns, will the CC start to believe that the current professional management of Arcata is less than that required?

    #64796
  30. What was suggest many times before, by the CC and others (me, for instance)… Training. Fines to specific programs. Resignation… Better legal representation. Professional requirements of staff… Transparency… Citizen Access… Those things enjoyed by every jurisdiction in CA, except this one, and those others making the front page of the NY Times… Check how often Arcata makes the times in the past few years……. did anyone read the related Arcata Eye story from a member of the oversight entity??? There was a suggestion that the transparency was less than what should have been, and an alternative view on what confusing about state direction…?? "It is difficult to get a man to understand something, when his salary depends upon his not … S. Lewis. The state intended staff reductions too, btw…

    When every committee member, and every commissioner resigns, will the CC start to believe that the current professional management of Arcata is less than that required?

    #65481
  31. wait till these people see the file on them all. suprise city of arcata hsu and thee county of humboldt. now comes DR-97-00400.
    pl

    #64797
  32. wait till these people see the file on them all. suprise city of arcata hsu and thee county of humboldt. now comes DR-97-00400.
    pl

    #65472
  33. Sean Mo

    Expect that purchasers of affordable housing will sell at market price.

    #64800
  34. Sean Mo

    Expect that purchasers of affordable housing will sell at market price.

    #65482
  35. Joe Kelley

    You saw this coming. I saw your super happy fun blog that pointed out the unreality of the economics. Sooner or later taxpayers will have to pay for bad decisions of leaders

    #64803
  36. Joe Kelley

    Your premonitions: In one of the biggest OOPS! of the last year, and the final nail in my Resident Owned Parks INC (ROP) and Arcata Mobile Home Park story, I have some final information, as well as some voting information to pass on. It seems that the City of Arcata also agreed that $541 a month for park rent was too much for the space alone, and they never allowed that to be charged. The park rent for space (private owned trailer) was to be $351 a month, but the problem at Arcata Mobile Home Park is that there is a few park owned trailers. ROP took the prices for the trailer and trailer spot rent and made it park wide. Overcharging some people who lived in the park almost $200 a month. The City of Arcata also does share some of the blame, as they allowed ROP to be the only contact and never sent any information to the park people themselves. To date, there has been no improvements to the park, and by most people's accounts there has been a overall lack of upkeep of the park by management and still no paperwork has been sent out to park residents from ROP. No new rules, no old rules, the park floods when it rains, and the management has informed park people that if they have a problem with flooding, to buy a pump and deal with it themselves. Not in writing, because they can't even update the park rules and mail them out like they are legally required too.

    #64806
  37. William Mackintosh

    Welcome to Jerry Brown's Kalifornia.

    He's such a caring, Liberal Guy (NOT)!

    #64808
  38. William Mackintosh

    Welcome to Jerry Brown's Kalifornia.

    He's such a caring, Liberal Guy (NOT)!

    #65473
  39. Way too much money is stolen from the people only to have cities and towns squander it on pet projects which are nothing but pork most times.

    #65474
  40. I just wondered why the 1st pay application I can find in the record (July #4) is for mobilization costs. I'm for AH but it would be great if all those with the ability to do accounting reviewed the project, if you believe what Kash is saying. It is useless to build AH projects that cost MORE than standard… Anyone else look at the file? I am not sure the CC reviewed the actual expenditures or record. They should, rather than ignore what a member (former, resigned in protest) of the oversight committee is trying to bring to everyone's attention. Anyone think Kash is a crackpot?

    #65345
  41. I just wondered why the 1st pay application I can find in the record (July #4) is for mobilization costs. I'm for AH but it would be great if all those with the ability to do accounting reviewed the project, if you believe what Kash is saying. It is useless to build AH projects that cost MORE than standard… Anyone else look at the file? I am not sure the CC reviewed the actual expenditures or record. They should, rather than ignore what a member (former, resigned in protest) of the oversight committee is trying to bring to everyone's attention. Anyone think Kash is a crackpot?

    #65346
  42. I just wondered why the 1st pay application I can find in the record (July #4) is for mobilization costs. I'm for AH but it would be great if all those with the ability to do accounting reviewed the project, if you believe what Kash is saying. It is useless to build AH projects that cost MORE than standard… Anyone else look at the file? I am not sure the CC reviewed the actual expenditures or record. They should, rather than ignore what a member (former, resigned in protest) of the oversight committee is trying to bring to everyone's attention. Anyone think Kash is a crackpot?

    #65347
  43. I just wondered why the 1st pay application I can find in the record (July #4) is for mobilization costs. I'm for AH but it would be great if all those with the ability to do accounting reviewed the project, if you believe what Kash is saying. It is useless to build AH projects that cost MORE than standard… Anyone else look at the file? I am not sure the CC reviewed the actual expenditures or record. They should, rather than ignore what a member (former, resigned in protest) of the oversight committee is trying to bring to everyone's attention. Anyone think Kash is a crackpot?

    #65475
  44. You might also factor in the involvement of former City Manager Dan Hauser (buddy of Councilmembers Wheetley/Stillman and City Manager/ex-APD chief Mendosa) who's suddenly gone into the housing development business…funny how washed up politicians find themselves in these profitable government-connected public-private partnership ventures.

    #65348
  45. You might also factor in the involvement of former City Manager Dan Hauser (buddy of Councilmembers Wheetley/Stillman and City Manager/ex-APD chief Mendosa) who's suddenly gone into the housing development business…funny how washed up politicians find themselves in these profitable government-connected public-private partnership ventures.

    #65483
  46. DR-9700400 coming to the entire humboldt community / stafford slide case / arcata agents under color of law interfered. police holds tapes with political inflammatory local information.SCNN@1995 ALL RIGHTS RESERVED.

    #65349
  47. DR-9700400 coming to the entire humboldt community / stafford slide case / arcata agents under color of law interfered. police holds tapes with political inflammatory local information.SCNN@1995 ALL RIGHTS RESERVED.

    #65476

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