HomeMy WebLinkAbout20250321_Conflict Waiver_Brownstien repping SLO Creek LLC
Christopher R. Guillen
Attorney at Law
805.882.1452 direct
cguillen@bhfs.com
www.bhfs.com
Brownstein Hyatt Farber Schreck, LLP
805.963.7000 main
1021 Anacapa Street, 2nd Floor
Santa Barbara, California 93101
March 20, 2025
City of San Luis Obispo
Attn: Christine Dietrick, City Attorney
990 Palm Street
San Luis Obispo, CA 93401
RE: Waiver of Conflict of Interest - Consultation, Disclosure, Informed Consent
Dear Ms. Dietrick:
This letter requests a waiver from the City of San Luis Obispo (the “City”) with regard to a potential
conflict of interest involving Brownstein Hyatt Farber Schreck, LLP’s (“Brownstein”) representation of
SLO Creek LLC (“SLO Creek”), as described below.
As you know, Brownstein has, for many years, represented the City in a variety of legal and water
rights and water supply matters (collectively, the “City Matters”). SLO Creek desires to engage us as
counsel in connection with land use advise for an infill development located at 300 Higuera Street in
San Luis Obispo, which includes assisting SLO Creek with obtaining permits from the City (the “Land
Use Matter”). The Land Use Matter is not related to our work for the City. However, our
representation of SLO Creek in the Land Use Matter while we represent the City in other unrelated
matters arguably constitutes a conflict of interest under the applicable Rules of Professional Conduct.
Under the Rules of Professional Conduct, we may not represent a client in a manner that is adverse to
another client unless both clients agree to the proposed representation after being adequately
informed, in writing, of the relevant circumstances and the material, reasonably foreseeable ways that
the conflict could have adverse effects on their interests.
The City should consider whether there is any material risk that Brownstein will be less zealous or
eager on its behalf due to Brownstein’s representation of SLO Creek in the Land Use Matter, or
whether the professional judgment of Brownstein attorneys working on the City’s matters could be
affected by the interests of SLO Creek. We do not believe that there is a material risk of any of the
foregoing in our concurrent but separate representation of SLO Creek in the Land Use Matter and the
City in unrelated matters.
While we represent SLO Creek in the Land Use Matter, all attorneys representing the City in the City
Matters will be denied access to all files, attorney work product, and materials concerning the Land
Use Matter and will not represent SLO Creek in any manner.
City of San Luis Obispo Conflict Waiver
March 20, 2025
Page 2
There is also a possibility that a dispute or litigation could develop between SLO Creek and the City
regarding the Land Use Matter. In the event of a dispute or litigation between SLO Creek and the City
related to the Land Use Matter, Brownstein will not represent SLO Creek and further, SLO Creek
consents to our continuing to act for the City in any manner whatsoever, including in negotiation or
litigation against SLO Creek related to the Land Use Matter. SLO Creek will obtain other legal counsel
and waives any right to contest Brownstein’s continued representation of the City or to seek
disqualification or recusal of Brownstein from its representation of the City, even if Brownstein is
representing the City in matters that are adverse to SLO Creek. However, the City agrees the City will
not seek for us to withdraw from representing SLO Creek in unrelated matters.
If you have any questions or concerns about the circumstances described herein, please contact me.
We recommend that the City seek independent counsel regarding the effect of this letter. If the City
determines, based on the advice of its independent counsel or otherwise, that our representation as
described herein will be detrimental to its interests, the City should not consent to it.
If the City wishes to consent to this waiver after such review as you believe appropriate, please sign a
copy of it in the space provided and return it to the undersigned. Your execution of this letter will
confirm that we have provided you with adequate information and explanation about the material
risks of our proposed representation.
Sincerely,
Christopher R. Guillen
READ AND AGREED TO THIS _____ DAY OF ___________, 2025.
CITY OF SAN LUIS OBISPO
By: _________________________
Its: _________________________ City Attorney
March21st