Complaint filled on Valley Vote letterhead

July 24, 1998

Honorable Nora Manella, United States Attorney, Central District of California
312 North Spring Street Los Angeles, CA 90012
Re: Events of July 18 and 19, 1998, at Van Nuys Airport

Dear United States Attorney Manella:

On July 18 and 19, 1998, the City of Los Angeles, through its employees and agents, forcibly barred citizens, including myself, from entering a free public event (the Van Nuys Air Show) on public property at the Van Nuys Airport, thereby denying those citizens their First Amendment right to petition government for redress of grievances and violating federal law.

Dozens of citizens had hoped to collect signatures on a petition to study the feasibility of creating an independent city in the San Fernando Valley. They were met at the gates by security guards, airport staff, and police officers who threatened to arrest them if they even entered this public event on public property. Challenged by citizens, who understood their First Amendment rights, airport personnel stated that the City Attorney's Office had confirmed that no "Valley Cityhood" petitions would be circulated on the property. A number of individuals were denied access to the event simply for wearing a Valley VOTE tee shirt in support of the petition drive.

Over the last several days, airport management and the City Attorney's Office have issued conflicting information and now claim that these events were the result of a "simple misunderstanding." Mayor Richard Riordan has stated that he is "content" with this explanation and sees no need for further investigation. The City Council has asked the City Attorney and the Department of Airports to report on the matter, but City Attorney James Hahn has indicated that his office has no jurisdiction to investigate these events, and in light of the obvious conflict of interest, many doubt that the Department of Airports, or any other City department, will produce anything more than a self-serving report that does nothing to bring the responsible parties to light or hold them accountable.

Accordingly, on behalf of Valley VOTE, myself and the other citizens who suffered this outrageous violation of constitutional rights and federal law, I respectfully request that your office conduct a thorough investigation of these events. Only an independent investigation can vindicate the rights of those affected. We stand ready to cooperate fully with you and your staff and we thank you for your kind attention to this matter.

Sincerely, Steven G. Pearl, Attorney at Law, Encino

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