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*1055267192*

IN THE DISTRICT COURT IN AND FOR TULSA COUNTY

STATE OF OKLAHOMA

Freeman Culver III, )

individually, )
)
)
Plaintiff, )
) CASE NO. CV-2023-00638
vs. ) Judge: Priddy
)
CITY OF TULSA, a political subdivision ) DISTRICT COURTD
of the State of Oklahoma, LORI DECTER ) F rJ L E
WRIGHT, in her capacity as Tulsa City )
Councilor, VANESSA HALL-HARPER, ) MAY 05 2023
in her capacity as Tulsa City Councilor, ) DON NEWBERRY, Court Clerk
LAURA BELLIS WRIGHT, in her capacity ) STATE OF OKLA. TULSA COUNTY
as Tulsa City Councilor, )
)
Defendants. )

APPLICATION FOR LEAVE TO FILE AMENDED PETITION

COMES NOW the Plaintiff, Freeman Culver III, by and through attorneys ofrecord Ronald

E. Durbin, II, and Christina Vaughn of Viridian Legal Services, PLLC, and respectfully requests

this Honorable Court to grant leave to file the amended petition attached hereto as exhibit "A". In

support, the Plaintiff states:

1. The proposed Amended Petition contains additional facts and allegations that have become

more developed since the filing of the original Petition.

2. The proposed Amended Petition is not intended to cause any undue delay or prejudice to

any party in this matter.

3. The Plaintiff notes that pursuant to the Oklahoma Code of Civil Procedure, Title 12,

Section 2015(8), "leave to amend shall be freely given when justice so requires."

4. The petitioner respectfully submits that justice requires that leave to amend be granted in

this case, as the proposed amendments will serve the interests of justice by clarifying the

0
 claims and allegations in the original Petition, and by providing additional information that

will assist the Court in its determination of this matter.

5. The petitioner further submits that the proposed Amended Petition is not intended to unduly

delay the proceedings in this matter, and that any delay caused by the amendment will be

minimal and will not prejudice any party. The petitioner has acted in good faith throughout

this matter and seeks only to ensure that the interests of justice are served.

WHEREFORE, the Plaintiff respectfully requests that this Honorable Court grant leave to file

the Amended Petition, and for such other and further relief as the Court deems just and proper.

Respectfully submitted,

111
Ronald E. Durbin, II, OBA #2
Christina M. Vaughn, OBA#
Viridian Legal Services, PLLC
1602 South Main
Tulsa, OK 74119
918.533.9635
Durbin(c~viridianlegal.com
Christinar(~viridianlegal.com
 CERTIFICATE OF SERVICE

I hereby certify that on the 5th day of May, 2023, a true and correct copy of the forgoing
document was mailed via First Class Mail, postage prepaid, to the following:

Mary Quinn Cooper

McAfee & Taft
Williams Center Tower II
Two W. Second Street, Suite 1100
Tulsa, OK 74103
 IN THE DISTRICT COURT IN AND FOR TULSA COUNTY
STATE OF OKLAHOMA

Freeman Culver III, )

individually, )
)
)
Plaintiff, )
) CASE NO. CV-2023-638
vs. ) Judge: Tracy L. Priddy
)
CITY OF TULSA, a political subdivision )
of the State of Oklahoma, MAYOR G.T. )
BYNUM, in his official capacity as Mayor )
of the City of Tulsa, BLAKE EWING, )
in his capacity as an employee of the City )
of Tulsa, LORI DECTER WRIGHT, in her )
capacity as Tulsa City Councilor, )
VANESSA HALL-HARPER, in her )
capacity as Tulsa City Councilor, )
LAURA BELLIS WRIGHT, in her capacity )
as Tulsa City Councilor, JEANIE CUE, )
In her capacity as Tulsa City Councilor, )
CHRISTIAN )
BENGAL, in his capacity as Tulsa City )
Councilor, )
)
Defendants. )

AMENDED PETITION FOR DECLARATORY JUDGMENT AND

INJUNCTIVE RELIEF

COMES NOW the Plaintiff, Freeman Culver III, by and through attorneys ofrecord Ronald

E. Durbin, II, and Christina Vaughn of Viridian Legal Services, PLLC, and for his AMENDED

causes of action against Defendants, alleges and states as follows:

JURISDICTION AND VENUE

1. Plaintiff, Freeman Culver, is a resident of Tulsa County, State of Oklahoma.

2. The City of Tulsa is a political subdivision of the State of Oklahoma.

3. The City of Tulsa utilizes a City Council in its structure of government, and in doing so,

the City of Tulsa vests the City Council for the City of Tulsa with decision making authority

on behalf of the City of Tulsa.

4. Upon information and belief, the Defendant, Lori Deeter Wright ("Wright"), is a resident

of Tulsa County, State of Oklahoma.

5. Defendant Wright is a public official being a duly elected member of the City Council for

the City of Tulsa.

6. Upon information and belief, the Defendant, Vanessa Hall-Harper ("Hall-Harper"), is a

resident of Tulsa County, State of Oklahoma.

7. Defendant Harper is a public official being a duly elected member of the City Council for

the City of Tulsa.

8. Upon information and belief, the Defendant, Laura Bellis ("Bellis"), is a resident of Tulsa

County, State of Oklahoma.

9. Defendant Bellis is a public official being a duly elected member of the City Council for

the City of Tulsa.

10. Upon information and belief, Defendant Wright is a state actor, employee of the City of

Tulsa, and an agent of Defendant, City of Tulsa, governed by the laws of the State of

Oklahoma, specifically 25 O.S. §§ 301 et seq., and Wright, in the performance of her

official duties, engaged in prohibited conduct under 25 O.S. §§ 301 et seq. in Tulsa County,

State of Oklahoma.

11. Upon information and belief, Bellis is a state actor, employee of the City of Tulsa, and an

agent of Defendant, City of Tulsa, governed by the laws of the State of Oklahoma,

specifically 25 O.S. §§ 301 et seq., and Bellis, in the performance of her official duties,
 engaged in prohibited conduct under 25 O.S. §§ 301 et seq. in Tulsa County, State of

Oklahoma.

12. Upon information and belief, Hall-Harper is a state actor, employee of the City of Tulsa,

and an agent of Defendant, City of Tulsa, governed by the laws of the State of Oklahoma,

specifically 25 O.S. §§ 301 et seq., and Hall-Harper, in the performance of her official

duties, engaged in prohibited conduct under 25 O.S. §§ 301 et seq. in Tulsa County, State

of Oklahoma.

13. The Tulsa City Council constitutes a public body under Oklahoma law. See 25 O.S. §

304(1) (defining Public Body to include, "all boards, bureaus, commissions, agencies,

trusteeships, authorities, councils, committees, public trusts or any entity created by a

public trust .... "). (emphasis added).

14. As a "Public Body," the Tulsa City Council and its members must comply with the

Oklahoma Open Meeting Act. See 25 Okla. Stat.§§ 304 et seq.

15. The actions giving rise to this suit occurred in Tulsa County, State of Oklahoma.

16. The Court has subject matter jurisdiction over the claims alleged herein and may properly

exercise personal jurisdiction over the Defendants.

17. Venue is proper in Tulsa County.

SERIAL MEETINGS

18. Defendants Mayor G.T. Bynum, Blake Ewing, Lori Deeter Wright, Vanessa Hall-Harper,

Laura Bellis Wright, Christian Bengel, Jeanie Cue, and Christian Bengel all regularly

engage in serial meetings to engage in business of the City of Tulsa.

19. That the Defendants identified above engage in serial meetings knowing that they

constitute a violation of the Open Meetings Act because the conversations are about City

of Tulsa business.

20. The Defendant discussed the Gilcrease funding by engaging in a series of text messages

and phone calls amongst and between themselves for purposes of corning to a decision on

a funding request before the Tulsa City Council.

21. The Defendants discussed above regularly discussed variances and other important city

business via serial meetings.

22. Defendants used in person, phone call, and text messages to engage in the serial meetings

and such action violates the Open Meeting Act.

23. The Defendants discussed ARP A and other grant funding by engaging in a series of text

messages and phone calls amongst and between themselves for purposes of corning to a

decision on a funding request before the Tulsa City Council.

24. The Defendants discussed low water damn and other City of Tulsa improvement projects

using serial meetings in violation of the Open Meeting Act.

25. The Defendants discussed regularly discussed permit application, reviews, and other

matters before the Tulsa City Council.

26. Defendant Blake Ewing came to counsel's office and attempted to engage in a serial

meeting with City Councilor Grant Miller regarding this lawsuit.

27. Defendant G.T. Bynum sent Blake Ewing to speak to all Defendant Councilors regarding

this lawsuit in violation of the Open Meetings Act.

28. Defendant G.T. Bynum regularly sends Defendant Blake Ewing to engage in serial

meetings about City of Tulsa business with members of the Tulsa City Council in

violation of the Open Meetings Act.

29. That any act of importance undertaken since the election of Defendant Mayor G.T.

Bynum was done using serial meetings with Defendants in violation of the Open

Meetings Act.

Defendants regularly discussed Mayor Action Items presented to the City Council by

engaging in a series of text messages and phone calls amongst and between the

Defendants for purposes of coming to a decision on a funding request before the Tulsa

City Council.

THE MARCH 22, 2023 TULSA CITY COUNCIL MEETING

30. Plaintiff adopts and incorporates paragraphs 1 through 17 of this Petition as if fully set out

herein.

31. On March 22, 2023, Councilor Grant Miller ("Miller") of the Tulsa City Council called to

order the 10:30 A.M. Urban and Economic Development Committee meeting, a regularly

scheduled and posted public meeting of the Tulsa City Council. See Public Meeting Notice

and Agenda attached hereto as Exhibit "A."

32. The meeting constituted a quorum of the Tulsa City Council.

33. The following Councilors were in attendance at the March 22, 2023 meeting: Vanessa Hall-

Harper, Lori Deeter Wright, Laura Bellis, Jayme Fowler, Phil Lakin, Jeannie Cue, Christa

Patrick, Grant Miller, and Christian Bengel.

34. Agenda item number four (4) of the meeting was a presentation and discussion on the

Citywide Housing Assessment Report which included a representative from Housing

Solutions, Becky Gligo ("Gligo"). See Id.

35. Gligo spoke to the issue of homelessness within the report during the public meeting.

36. During open meetings of the Tulsa City Council, councilors ask questions in tum by raising

their hand to be placed on the list to speak on the agenda item and a list is kept by the

chairperson of the meeting.

37. Councilor Miller asked a question of Gligo related to the above-mentioned report when the

report mentioned homelessness.

38. As Miller asked his question, he observed Defendant Wright roll her eyes, smirk, and pick

up her phone.

39. Councilor Miller observed Defendant Wright typing on her phone keyboard during the

public meeting.

40. Miller observed Defendant Bellis, during the public meeting, pick up her phone, read

something on the phone, look toward Defendant Wright, and smirk.

41. Councilor Miller then observed Defendant Bellis type something on her device's keyboard

during the public meeting.

42. Councilor Miller then observed Defendant Harper pick up her phone, during the public

meeting, look at Defendant Wright and smirk.

43. Defendant Harper then looked at Defendant Bellis and smirked.

44. Upon information and belief, Councilor Miller suspected Defendants were communicating

about his question about allocating ten (10) million dollars to homelessness during the
 public meeting which was related to the topic being discussed as agenda item four (4). See

Id.

45. Immediately after the meeting, Councilor Miller submitted an Open Record Request

pursuant to the Oklahoma Open Records Act. 51 O.S. § 24A.l et seq.

46. Councilor Miller submitted the request to Council Administrator Patrick Boulden

("Boulden").

47. Boulden is an employee of the City of Tulsa and more specifically is an attorney employed

by the City of Tulsa and/or the Tulsa City Council to provide legal advice to the Tulsa City

Council and members of the Tulsa City Council in their official capacity.

48. Boulden is available to any councilor for advice regarding compliance with Oklahoma law

including, but not limited to, the Oklahoma Open Meeting Act.

49. Defendant Councilors possessed access to Boulden for legal advice, and as such, knew and

or should have known that the actions identified herein constitute a violation of the

Oklahoma Open Meeting Act.

50. The City of Tulsa fulfilled Councilor Miller's Open Record Request and provided

Councilor Miller a series of text messages between the Councilor Defendants. See Text

Messages of Councilor Defendants attached hereto as Exhibit "B."

51. The Open Record production contained at least two text messages sent from Defendant

Wright in a group to the Defendants Hall-Harper and Bellis (hereinafter collectively

"Defendant Councilors"). See Id

52. The Open Record production contained one text message sent from Defendant Bellis to

the group containing Defendant Councilors. See Id

53. The Open Record production contained text messages received by Defendant Harper from

the other Defendant Councilors. See Id.

54. The Defendant Councilor messages were all contained within a group message between all

three (3) Defendant Councilors.

55. The time date stamps of the Defendants' text messages reflect that they were sent and

reviewed during the public meeting identified above and in Exhibit "A".

56. The first message from Defendant Wright stated "$1 OM Gilcrease $ for housing". See Id.

57. The second message from Defendant Wright stated "Miller is ridiculous". See Id.

58. The text message from Defendant Bellis stated "RIDICULOUS". See Id.

59. All messages were either sent, observed, or both by all three Defendants.

60. Plaintiff attempted to resolve these violations of the Oklahoma Open Meeting Act with the

City of Tulsa, but they failed to respond as promised leaving Plaintiff no choice but to

initiate this litigation.

61. Councilor Defendants, instead of admitting fault and working towards a resolution, sent a

threat letter to Councilor Miller. See Letter from Laurie Phillips, Counsel for Defendants

Hall-Harper, Wright, and Bellis to Councilor Miller attached hereto as Exhibit "C".

62. Councilor Defendants, instead of admitting fault and working towards a resolution, sent a

threat letter to the undersigned after their threat letter to Councilor Miller failed to have the

chilling effect they hoped on the inquiry into their wrongdoing. See Letter from Laurie

Phillips, Counsel for Defendants Hall-Harper, Wright, and Bellis attached hereto as Exhibit

"D".
63. Upon information and belief, Defendant Councilors retained legal counsel for actions taken

in the course of their individual capacity indicating that their improper and illegal actions

extend into their personal lives as well as their role as members of the Tulsa City Council.

64. In her letter, Phillips falsely claimed Councilor Miller accused Defendant Councilors of

violations of the Open Meeting Act and Phillips threatened frivolous litigation if Miller

continued to engage in public discourse about the subject. See Exhibit "D".

65. Councilor Miller published the threat letter to his public Facebook page.

66. Upon information and belief, this was a strategic letter intended to limit public participation

and discourse around the topic of open and transparent government.

67. Critically, in addition to the violations already known about, Phillips admitted in her letter

that Defendant Councilors regularly text during open meetings in violation of the

Oklahoma Open Meeting Act stating "The practice of text message use has been in effect,

even during regular City Council meetings." See Exhibit "D".

68. Thus, Phillips freely admited her clients regularly and frequently violate the Act.

69. Defendant Councilors' Attorney, Laurie Phillips, made comments to media that her clients'

actions are no big deal and not a violation of the Open Meeting Act.

THE OKLAHOMA OPEN MEETING ACT

70. Plaintiff adopts and incorporates paragraphs 1 through 57 of this Petition as if fully set out

herein.

71. Oklahoma codified the Open Meetings Act, as 25 O.S. §§ 301 et seq.

72. The stated purpose of the Open Meeting Act is to facilitate and encourage an informed

citizenry's understanding of government. 25 OS. § 302.

73. Under the statutory provisions contained in 25 O.S. §§ 301 et seq., any public body, as

defined in § 304(A) as "all boards, bureaus, commissions, agencies, trusteeships,

authorities, councils, committees, public trusts or any entity created by a public trust. .. ",

is required to provide to the public specific times and places, which are convenient to the

public, such that citizens may attend said meetings and be informed of the activities of their

government.

74. To be "informed" under Section 301, the Act requires that citizens be aware of matters

discussed during public meetings. By communicating about matters of public concern

secretively, Defendants violated the Open Meeting Act.

75. In other words, the Oklahoma Open Meeting Act requires public bodies, like the Tulsa City

Council, to conduct meetings in the fresh air that only the sunshine of transparency brings

to the process of governance.

76. The language in 25 O.S. § 303 requires that meetings of public bodies be both convenient

to the public and open to the public. (emphasis added).

77. To be "open" to the public, the public must be able to see and hear all the discourse of all

members of the public body. See 25 O.S. §301 et seq.

78. Pursuant to the Act, a meeting is not open if the public cannot see the members of the

public body during the public meeting. See Id.

79. Pursuant to the Act, a meeting is not open if the public cannot hear the members of the

public body while they discuss agenda items during the public meeting. See Id.

80. The Oklahoma Open Meetings Act, 25 O.S. § 303 specifically requires:

All meetings of such public bodies ... shall be preceded by advance public
notice specifying the time and place of each such meeting to be convened
as well as the subject matter or matters to be considered at such meeting, as
hereinafter provided.
81. Under the Open Meeting Act, "Meeting" means "[t]he conduct of business of a public

body ... " 25 O.S. § 304(2).

82. The Tulsa City Council is a public body under the Open Meetings Act.

83. The City of Tulsa attempted to conduct a meeting under the Act for purposes of conducting

business of the public body.

84. A violation of the Open Meetings Act, "does not require a showing of bad faith, malice,

or wantonness, but, rather, encompasses conscious, purposeful violations oflaw or blatant

or deliberate disregard oflaw by those who know, or should know requirements of the Act

.... " Wilson v. City of Tecumseh, 2008 OK CIV APP 84, 1 13 (bold emphasis added).
85. The Open Meeting Act provides criminal sanctions for violation of its provisions by stating

as follows:

A. Any person or persons willfully violating any of the provisions of this

Act shall be guilty of a misdemeanor and upon conviction shall be
punished by a fine not exceeding Five Hundred Dollars ($500.00) or by
imprisonment in the county jail for a period not exceeding one (1) year
or by both such fine and imprisonment.
25 O.S. § 314(A)

86. Aside from the criminal sanctions addressed above, the Open Meeting Act also authorizes

any person to bring a civil suit seeking declaratory or injunctive relief, or both. See 25

Okla. Stat.§ 314 (B)(l).

87. The Open Meeting Act provides for the recovery of Plaintiffs attorney fees and costs. See

25 Okla. Stat.§ 314 (B)(2).

COUNT 1: DECLARATORY RELIEF- OPEN MEETINGS ACT

88. Plaintiffs adopt and incorporate paragraphs 1 through 75 of this Petition as if fully set out

herein.
89. The City of Tulsa notified the public of its intention to consider the matters on the Agenda

attached hereto as Exhibit "A".

90. The City of Tulsa made no provisions to stream, record, or otherwise broadcast electronic

and/or text message conversations of the Defendant members of the Tulsa City Council

that occurred during the public meeting.

91. Defendants made no effort to capture or broadcast the comments of Defendant Councilors

for public review and for future review by allowing such to be captured by the public.

92. Defendant Councilors each contend, via a public statement from their attorney, that they

did nothing wrong by texting about public business during a public meeting in a secretive

and deceptive manner. See Interview with News 8 Tulsa on _ _ _ available at:

93. The position of Defendant Councilors is contrary to 25 O.S. § 306 which provides that,

"[n]o informal gatherings or any electronic or telephonic communications, except

teleconferences or videoconferences as authorized by Section 307 .1 of this Title, among a

majority of the members of a public body shall be used to decide any action or to take any

vote on any matter."

94. Section 306 applies not just to matters directly being considered but "any action".

95. Without doubt the events of the meeting and the conversations of counselors constitute

actions of the public body.

96. The texts between the Defendant Councilors regarded a matter of City of Tulsa business

and matters presently before the City Council.

97. The text messages occurred during a meeting "among a majority of the members of a public

body .... " Id.

98. This is by far not the only occurrence of these councilors texting about public business

during public meetings shielded from public view.

99. At 10:30 A.M. on Wednesday, November 17, 2021, Councilor Fowler called to order the

Tulsa City Council Urban and Economic Development Committee Meeting. See Agenda

of November 17, 2021 Tulsa City Council attached hereto as Exhibit "E".

100. Agenda Item No. 16 of that meeting states: "Resolution of the City of Tulsa,

Oklahoma, stating its intention to appropriate American Rescue Plan Act (ARPA) funds to

specific programs and projects; providing for additional procedures and conditions of

funding. (Emergency Clause) (Hall-Harper, Cue, Deeter Wright, Lakin). See Id.

101. Present at the meeting were Tulsa City Councilors: Lori Deeter Wright, Kara Joy

McKee, Conny Dodson, Jeannie Cue, Phil Lakin, Jayme Fowler, Mykey Arthrell-Kenezek,

and Christa Patrick.

102. The members present at the meeting constituted a quorum.

103. During that meeting, and specifically during the discussion of ARP A funding,

Defendant Lori Deeter Wright communicated electronically, and it appears that such

communication is with former City Councilor Connie Dodson.

104. The text message communications by Defendant Lori Deeter Wright and former

City Councilor Connie Dodson were caught on camera. See image of Defendant Wright

texting attached hereto as Exhibit "F".

I 05. This was the first of many meetings of the City Council for the City of Tulsa to

consider ARP A allocations, and at each of those meetings, at least one (I) member of the

Tulsa City Council engaged in electronic communications in violation of the Oklahoma

Open Meeting Act.

 106. A review of City of Tulsa TV reveals that, between the three (3) Defendant

Councilors, there are hundreds if not thousands of occurrences of Defendants Hal-Harper,

Wright, and Bellis texting during public meetings.

107. The actions of Defendants Hall-Harper, Wright and Bellis could, and due to their

willful nature likely will, invalidate years of work of the City Council for the City of Tulsa.

Every action taken at any meeting wherein these councilors violated the Open Meeting Act

is per se invalid under Oklahoma law.

108. The text messages by and amongst Defendant Councilors were not done pursuant

to teleconferences authorized by 25 O.S. § 307.1 as required by Section 306 of the Act.

109. Section 307.1 of the Open Meetings Act deals with the issue of conducting

meetings via videoconference as opposed to in person meetings. See Id.

110. The videoconference exception to public meetings provides that a public body,

which the City Council constitutes, may conduct a videoconference if, "each member of

the public body is visible and audible to each other and the public through a video monitor

" See Id.

111. Thus, under Section 307 .1 there are two (2) requirements to meet the standards: 1.

There must be both video and audio, and 2. The video and audio must be visible and audible

to both members of the public body and the public.

112. Section 307.1 is not ambiguous, and without both audio and video available to both groups,

a meeting is not open.

113. Defendants failed to meet both requirements of Section 307 .1 in order to engage in

electronic communications during a public meeting.

114. Defendants failed to meet Section 307 .1 exceptions because they failed to provide

video and audio of those text messages to all other members of the public body. The written

word for purposes of communication of a message to another member of a public body is

the same as the spoken word for purposes of the act, and the text messages were not

provided to other members outside the Defendant group.

115. Further, the Defendant Councilors failed to meet Section 307.1 exceptions because

the text messages were not available during the meeting to the public as required by the

Act. Future availability is irrelevant under Section 307 .1, and the text messages are the

same as audible speech for purposes of the Act. As such, Defendants failure to provide

them to the public during the public meeting of the public body constitutes a failure to

provide audible access.

116. 307.l(C)(S) also requires that, if a public body wants to communicate and meet

electronically, they must ensure that, "Any documents or other materials provided to

members of the public body or shared electronically between members of the public body

during a meeting utilizing teleconferencing or videoconferencing shall also be immediately

available to the public on the website of the public body, if the public body maintains a

website .... "

117. The City of Tulsa maintains a website.

118. The Defendants did not make the text messages of the Defendant Councilors

"immediately available," and providing them in response to an Open Record Request does

not constitute making them immediately available because Section 307.1 contemplates

availability during the meeting.

119. By establishing Defendants did not meet a 307.1 exception to Open Record Act,

which is the only manner in which electronic communication can take place outside the

direct observance of the public in a public forum during a public meeting, Plaintiff

definitively establishes that Defendants violated the Open Meeting Act by engaging in

communication about a matter of public business outside the only exception to the Act

regarding such communication.

120. The Open Meeting Act requires a public body maintain written minutes "which

shall be an official summary of the proceedings showing clearly those members present

and absent .... "

121. By text messaging during meetings, even if those messages are about matters other

than those of public importance, Defendant Councilors are leaving the meeting, even if

momentarily, to attend to other matters on their phone. While breaks happen, as in

restroom breaks, Section 312 of the Act requires that, when a member is not present during

a break from their attention to the meeting, their absence must be reflected in the minutes.

122. The City of Tulsa and Defendant Councilors failed to document when they were

not present at meetings due to engaging in other business utilizing their cellular telephones

and/or laptops during public meetings.

123. Importantly, the Defendants either knew and/or should have known that their

actions constitute a violation because this issue is not one of first impression. The

Oklahoma Attorney General reached a similar conclusion when faced with a question

regarding presence at a meeting. The AG noted,

,-i22 The teleconference exception to the Open Meeting Act also aids in
construing the meaning of presence and absence. "In the interpretation of
statutes, courts do not limit their consideration to a single word or phrase in
isolation to attempt to determine their meaning, but construe together the
 various provisions of relevant legislative enactments to ascertain and give
effect to the legislature's intention and will." McNeill v. City of Tulsa, 953
P.2d 329,332 (Okla. 1998).

124. The AG then further analyzed the intention of the Open Meeting Act and found that

presence requires that, "each member of the public body is visible and audible to each other

and the public." Id. citing 25 O.S.2011, § 307.1.

125. Defendant Councilors during their text messaging were not "visible" to the public,

as their messages were secret.

126. Defendant Councilors during their text messages were not "audible" to the other

members of the Council present which were excluded from the group communication.

127. Defendant Councilors during their text messages were not "audible" to the public

as their messages were secret, despite the fact they admittedly regarded public business.

128. Based on the foregoing, the Defendant Councilors were not "present" at the meeting

when they were text messaging and such communication was not done in accordance with

the Act.

129. As the AG noted, "A member is 'absent' when the member is no longer visible and

audible to the other members and the public. The absence must be reflected in the minutes.

Minutes that report only a commissioner's presence during roll call but do not indicate a

commissioner was absent for portions of the meeting, do not "show clearly those members

present and absent" in compliance with Section 312(A) of the Open Meeting Act. The

same is true in this matter. The Councilors were not Present when communicating via text

messaging during the meeting. Picking up their phones to engage in other matters or

discuss the matters in the room was the same as stepping away to go to the restroom, and

their absence must be noted in the public meeting minutes.

130. The Minutes of the Meeting do not accurately reflect events occurring during a

public meeting or whether members of the City Council were "present" or "not present"

because the minutes fail to reflect when councilors engaged in conversations not open to

the public due to their electronic nature.

131. Defendants failed to account for times Councilors were absent from meetings by

attending to other matters during public meetings, and such failure constitutes a failure to

properly maintain minutes of the public body in violation of 25 O.S. § 312(A).

132. Section 312 of the Act also requires that minutes must reflect "all matters

considered by the public body .... " Id.

133. By communicating via text messaging or other electronic means, Defendants

violated the Open Meeting Act because they failed to record and document "all matters

considered" during the public meeting as matters considered via those methods are shielded

from recordation and never make it into the official minutes required by the Act.

134. The Open Meeting Act further requires that, "C. Any person attending a public

meeting may record the proceeding of said meeting by videotape, audiotape or by any other

method .... " 25 O.S. § 312(C).

13 5. The clear purpose of allowing recordation via video and audio is to allow the public

to capture all that occurs at the public meeting and the events which transpired during said

meeting.

136. By communicating via text messaging, Defendants violated§ 312(C) because they

did not allow the public to record those communications as mandated by the Act.

13 7. By failing to account for text messages, emails, and other electronic

communications of councilors during public meetings, the City of Tulsa and the Defendant
 Councilors failed to disclose "all matters considered" as some matters were clearly

considered secretly and not disclosed to the public.

138. Defendant Councilors via Facebook and their attorney mock their violations of the

Open Meeting Act arguing that their actions were trivial and of no consequence. Because

of that, they argue, their violations could not be willful.

139. Defendants mistakenly believe that willful intent is required to violate the Open

Meeting Act. It is most certainly not required.

140. Even if willful intent was required, like it is when seeking to declare an action taken

in such a meeting invalid, text messaging amongst members of the Tulsa City Council,

during a public meeting, constitutes a "willful violation" of the Open Meeting Act.

141. The Oklahoma Court of Civil Appeals addressed the issue of willfulness, and in

doing so, they provide this Court ample guidance to conclude that the Defendants' actions

were willful. The Court noted that,

Appellees, though, urge us to give no effect to the violations in the case at hand.
They argue that the Open Meeting Act, with its "fitfull and confused history," is
"inflexible" and "unfortunate," and that it was no wonder these school boards,
acting within the Act's first year, found it "unfamiliar and obscure." They argue that
the violations, which they call mere "irregularities," were not "significant" or
"material" and that they substantially complied with the Act. They argue that the
annexation should not be invalidated because, as it turned out, a bare majority of
the voters approved it. And, they argue that the violations were not willful because
they meant no harm and were simply trying, in good faith, to do the right thing for
the schoolchildren.

We find none of these arguments persuasive.

Matter of Order Declaring Annexation Dated June 28, 1978, Issued by Frazier, 1981 OK

CIV APP 57, ~ 16 (emphasis added).

142. The Court further importantly directed that, "Appellees' argument that the

annexation should be allowed to stand because a majority of electors voted for it

 misconceives the purpose of the Sunshine Law. It is not meant to insure that public bodies

follow the dictates of the majority. Rather, as stated in§ 302, it is meant to 'encourage and

facilitate an informed citizenry's understanding of the governmental process and

governmental problems.' Where an action is taken in violation of the Act, it is irrelevant

whether the action was popular or unpopular."

143. Any action by the City of Tulsa and/or the City Council of the City of Tulsa to,

after the fact, "ratify" or otherwise approve prior decisions made in violation of the Act

will not cure the defects, and it most certainly will not "breathe life" into the prior bad acts

of these Defendants. See Id. at, 23.

144. As further noted by Attorney General Opinion, "The goal of the Oklahoma

Legislature in enacting the Open Meeting Act was not simply to prevent or punish

deliberate violations, but to restore sadly sagging public confidence in government, a goal

which is hurt by every noncomplying meeting regardless of whether or not the

noncompliance resulted from evil motives. Matter of Order Declaring Annexation, Etc.,

Okl.App., 637 P.2d 1270 (1981). 1982 OK AG 212,, 11

145. In that opinion, the Attorney General found that, "it is clear that, when members of

a public body meet informally and begin discussing matters affecting the public body,

regardless of whether or not there is any motive to evade the Open Meeting Act, the

discussion falls under the auspices of the Open Meeting Act." Id.

146. Members of the City Council for the City of Tulsa, regularly, and as a matter of

habit and practice, communicate with one another via telephone calls, emails, and text

messages on a near daily basis for the purposes of informally discussing matters impacting

the public body.

14 7. Those conversations are contrary to both the black letter and spirit of the Open

Meeting Act, and constitute a violation of the Open Meeting Act.

148. All matters discussed by any member of the City Council with any other member,

are subject to the Open Meeting Act if such issue impacted the public body.

149. Every conversation had by a member of the Tulsa City Council with another

member of the City Council outside a public meeting, which is about a matter of public

concern, constitutes a violation of the Oklahoma Open Meeting Act.

150. The actions of the Defendant Councilors were done in the course of their roles as

elected members of the City Council for the City of Tulsa and their employment with the

City of Tulsa and with the express direction and consent of the City of Tulsa. As such,

City of Tulsa is jointly and severally liable for all acts of their agents done under color of

law which constitute violation of Oklahoma law.

151. Plaintiff seeks declaratory judgment in accordance with the Open Meetings Act and

12 Okla. Stat. §§ 1651-1657 as the matters addressed herein constitute an actual,justiciable

controversy existing between the parties.

152. Pursuant to the aforementioned facts and allegations, Plaintiff is entitled to a

declaratory judgment determining that the Defendants:

(a) Violated the Oklahoma Open Meeting Act by allowing Councilor

Defendants to electronically communicate and/or text message each

other during public meetings about matters of public concern.

(b) Violated the Oklahoma Open Meeting Act by engaging m

electronic communication and/or text message with members of the

public about matters of public concern during open meetings.

 (c) Violated the Oklahoma Open Meeting Act by failing to accurately

maintain minutes of meetings to reflect when members of the public

body are present or absent from the meeting.

(d) Violated the Oklahoma Open Meeting Act by failing to capture all

matters considered by all members of the public body during an

open meeting because matters considered electronically were not

documented by the Defendant City of Tulsa and/or Defendant

Councilors

(e) Violated the Oklahoma Open Meeting Act by engagmg m

conversations between Defendant Councilors about matters of

public concern outside of public meetings.

(t) Violated the Oklahoma Open Meeting by failing to capture and

broadcast electronic conversations of members of the public body

during the open meeting.

(g) Violated the Oklahoma Open Meetings Act by requiring citizens to

sign in to attend certain meetings of the public body.

153. Pursuant to the aforementioned facts and allegations, Plaintiffs are further entitled

to a declaratory judgment determining that:

(a) all actions at any City Council meeting of the City of Tulsa are invalid

if, during at any point of that public meeting, any member of the Tulsa

City Council communicated by electronic means with any other

member of the City Council about a matter of City of Tulsa business;

 (b) All actions of the Tulsa City Council which were discussed by members

of the Tulsa City Council amongst themselves, outside of a public

meeting, constitute a violation of the Open Meeting Act, and all actions

taken on those matters should be invalidated;

(c) all actions at any City Council meeting of the City of Tulsa are invalid

if, during at any point of that public meeting, any member of the Tulsa

City Council communicated by electronic means with any member of

the public about any matter of City of Tulsa business.

COUNT 2: INJUNCTIVE RELIEF

154. Plaintiffs adopt and incorporate paragraphs 1 through 141 of this Petition as if fully

set out herein.

155. Plaintiff seeks entry of a permanent injunction compelling the Defendants to refrain

from conducting any further public meetings or hearings until the violations of the

Oklahoma Open Meeting Act are addressed.

156. Plaintiff seeks entry of a permanent injunction compelling the Defendants to

comply with the Oklahoma Open Meeting Act.

157. Plaintiff IS SEEKING an emergency temporary injunction so that the citizens of

Oklahoma may enjoy the activities authorized by 25 O.S. §§ 301 et seq. In order to

facilitate the presence of Defendants at said hearing, Plaintiff requests that this Court set

its application for a hearing expeditiously in lieu of Plaintiff presenting this as an

emergency ex-parte application.

158. No adequate remedy at law exists for Plaintiff to remedy the harm done by the

named Defendants by their violation of the Open Meeting Act.

 159. Substantial threat exists that the Plaintiff, and all citizens of Oklahoma, will suffer

permanent and irreparable injury in the absence of the requested injunctive relief. Indeed,

the public has already been previously subjected to said harm by Defendants.

160. The interests of the public are served by the issuance of injunctive relief, as the

injunctions sought would prevent future actions taken by the named Defendants that exceed

their authority and violate the public's right to know and participate in the law-making

process of the State of Oklahoma.

161. Plaintiff is entitled to a permanent injunction ordering the Defendants to: invalidate

all measures, resolutions, votes and other action taken by the City Council for the City of

Tulsa at any meeting or about any subject in which any member of the Tulsa City Council

violated the Oklahoma Open Meeting Act, refrain from initiating any future public

meetings or hearings under the Open Meeting Act without prior approval of the Court,

provide training and staff to their agents and/or employees, specifically members of the

Tulsa City Council, about the Oklahoma Open Meeting Act and Oklahoma Open Record

Act.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays that the Court enter judgment against all Defendants in their

official capacity as follows:

(a) Declaratory Judgment as requested above;

(b) Injunctive relief as requested above;

(c) Award Plaintiffs their costs and attorney's fees incurred herein; and

(d) Such other relief as this Court deems proper under law and equity.
JURY TRIAL DEMANDED
ATTORNEY'S LIEN CLAIMED

Respectfully submitted,

Ronald E. Durbin, II, OBA #22550

Christina M. Vaughn, OBA# 21390
Viridian Legal Services, PLLC
1602 South Main
Tulsa, OK 74119
918.533.9635
[email protected]
[email protected]
 FILED
CITY OF TULSA NOTICE AND AGENDA
STATE OF OKLAHOMA
I03/1712023 J:~-~~ jlTY COUNOL-Urban & Economic Development Committee Meeting
og:~e~~:e 10:30 AM, Wednesday, March 22,2023
One Technology Center, 4th Floor, Roam 411-175 E. 2nd St., Tulsa, OK 74103

CHAIR: MILLER CO-CHAIR: lAKIN, FOWLER, BEWS

Persons who require o spedol oc:commodotlon to portldpote In this meeting should contoc:t
Sec:retory to the Tulsa Oty c:aunc/1 Lori Doring, 1.15 East Sec:ond Street, Fourth Floor, Tulsa,
Oklahoma, 91.8-596-1.990 or via Emo/I: /[email protected], as for In advance os possible
ond preferably at least 48-hours before the date of the meeting. Persons using o TOO may contact
OKLAHOMA RELAY ot l-800-122-0353 ond volc:e coils should be mode to 1.-800-522-8506 to
communlc:ote vfo telephone with hearing telephone users ond vice verso.

1. Call to Order.

2. Ordinance amending the fiscal year 2022-2023 budget ta make supplemental

appropriations of ten thousand dollars ($10,000.00) from grant revenues to be received
from The Hartford within the Publlc Safety & Protection Non-Federal Grants SubFund.
(Tulsa Fire Department Publlc Education Fire Safety Program) (UEO 3/22/23; CC 3/22/23; CC
3/29/23) 23-170-1
suppgrt(n1 Pa,urnentatlon
3. Ordinance amending the fiscal year 2022-2023 budget ta make supplemental
appropriations of eight mllllon, two hundred fifty thousand dollars ($8,250,000.00) from
revenue received from the sale of Stormwater Revenue Bonds within the Tulsa Public:
Fac:llltles Authority (TPFA) 2023 Stormwater Bonds SubFund. (Stormwater Improvements:
lewis Ave. from 41st St. to 1-44, N. Toledo Bridge, 4th St. and Kenosha Ave., Comanche Park,
Hager Creek) (UEO 3/22/23; CC 3/22/23; CC 3/29/23) 23-171•1
Suopgrtlnr Qgcumentatfon
4. Presentation and discussion on the Citywide Housing Assessment Report with the City of
Tulsa's Director of Housing and representatives from Housing Solutions, Development
Strategies, Homebase, PartnerTulsa, the Tulsa Housing Authority, and Downtown Tulsa
Partnership. (Cue, Patrldc. Oec:ter Wright, Lakin) (UEO 3/22/23) 23-177-1
Suppactlor PAcurneotatlgn
5. Semiannual report from and discussion with Johna Easley, Emergency Medical Services
Authority (EMSAI, and Or. Jeffrey Goodloe, Medical Oirec:tor, Office of the Medical Control
Board, or their deslgnees regarding EMSA operations and Medlc:al control Board oversight.
(Lakin) (UEO 3/22/23) 23-163-1
Supportlnr Documentation
6. Adjournment.

I
I

. -

·. . RIDICULOUS
~ ( .' ,
11 :43 AM

OJ

11 :42 AM

11 :42 AM

11 :43 AM
 19:58

X 2023-03-26 Email to Mille...

.
Law Office of
LAURIE PHILLIPS"'
Confirma:ion of Oehvery
AeeeiptN'o.
l-i08 S. Dcm-u
Tulw. OK 71119

918.SH7 .81:KJ0 Offiu

11<;6.H6.o3114 fo,
Morch 26. 2023
?llll"""r"·'"'nn
lpbillip~91Al l'Jl1'1'r.<om

Adam "Gronf' Grant Miller gmillerl 21986<§gmoil.com

1139 S. Canton Ave.
iulso. OK 74112

Ir, Re: Vanessa Hol~Horper. Lori Deeter Wright. and Louro 3e!lis

Deer Mr. Miler:

I represent Vanessa HoU•Harper. Lori Deeter Wright end Louro 8e\lis. individuotly, nol in
rheir capacity as City Councilors. It hos come lo !heir attention that you hove been
threatening to sue them personally. If you file legal action, I om authorized to occapt
service on their beho!!.

My office Is locoteo o'. 1408 S. De1ver A-1e .. Turso. Ok!onomo. If I om net ovoiloble. the
process server may serve my ossistor.t. My assistant is in the of.ice Monday through Friday
from noon until 5:00 p.m.

CEASE & DESIST all communications (social media Or>d olherwiseJ stating that Holl-'iorcer.
Deeter Wright end/or SeI1is hove violated the Open Meelings and/or Open Records Act.
Further, remove oil references in oriy pubac postings of violations. The requested text
message was deilvered. !here hos been no finding of vl:ilotion of either Act. Your
assertions !hot there wos a vio:otion ~ not only ur.trvthfut. tt is also defomclory ond
libelous.

The practice of text message use hos beer. in effect. even during reg-itor City Courca
meeiings. This Is tne first t'me the issue of text messaging hos been brought forward and
apparently: this is the firs: time this hos been a point of contention. Since you ore a
member of the City C01mcu. r suggest that CouncU policies be modernized. Digi;ol
communication Is how tnings ore communicated. There ore many options to ovoid vcur
cor.cems over tcx1 messaging 11) the ru1ure. tor exomple. the Council coufd use Microsoft
Teams. There ore o number of other 1ex• oppticolio:'\S that wculd sollsfy the Open
Meetings and Open Records statutes so that individual members would not hove to tun
over the;, personal devices for scrutiny - even for insignificant communicotions
concerning lhei• opinion of anothe• member of the ovbllc body.

In Re: vanesso Holl-Harper. Leri Decte• Wright. one LaJra Bems

Morch 26, 2023
Page 2

There is no violation of o statute until o CoJrt dete:mines there r:os been a violation. Your
posts on socicr media concerning my clients ore not only in orrect. defomolOfY and
7
libelous; you hove sought to Intimidate using threors of o lawsuit. r suggest tho! you l~k
at both the Open Meetings Act o~d the Open Records Act. _Any findi~gs of a vlolofion
of the act requires "wiUfutness" on the pcriy alleged to hove violated either Act.

tr. addition. You mlghr to<e note that 51 OS§ 24A.9 olows for o pubfic official to keep
oonfidenliol her or his personal notes and personally c,eoted motertols.

Should you bring suit, 1wiU reqvest oltorney fees. , charge $4-.."0 on hour for this type of
wort. 1suggest that you purer.me the OJsiohomo Qoeo Meerlng & Open Records Bool;
from the Oklahoma Pre,s Association.

If yOL hove on oitorr.ey, please odv.se so that I con commun,co•e directly wi!h her or
him.

s:ncere:y,
EXHIBIT

I l
cc: Vanessa rial:-.'icroer
Lori Deeter Wrig ..
'-··-- .
"_, _
 Law Office of
JLAlU[ J~ ][ E ]Pl ]H[ ]( ]L ]L ]( JP>§ PC

Confirmation of Delivery
1408 S. Denver Receipt No.
Tulsa, OK 74 I 19

918.587.8800 Offi"cr
866.436.0304 fi'-~

9 l 8Lawycr.com March 26, 2023

lphillips@9 l8Lawycr.com

Viridian [email protected]
Ronald Durbin, II [email protected]
1602 S. Main St.
Tulsa, OK 74119-4410

In Re: Vanessa Hall-Harper, Lori Deeter Wright, and Laura Bellis

Dear Mr. Durbin:

I represent Vanessa Hall-Harper, Lori Deeter Wright, and Laura Bellis, individually, not as
City Councilors. Ms. Harper did not admit to violating the Open Meetings Act. Your post
on Facebook yesterday that there was admission of violation is incorrect and
defamatory. Your other statements on social media concerning Deeter Wright and Bellis
are likewise incorrect.

CEASE & DESIST: All communications (social media and otherwise) stating that Hall-
Harper, Deeter Wright and/or Bellis have violated the Open Meetings and/or Open
Records Act. Further, remove all references in any public postings of violations. The
requested text message was delivered. There has been no finding of violation of either
Act. Your assertions that there was a violation is not on1y untruthful, it is also defamatory
and libelous.

You are an attorney. As a lawyer. you have a responsibility to:

"[5]A lawyer's conduct should conform to the requirements of the law, both
in professional service to clients and in the lawyer's business and personal
affairs. A lawyer should use the law's procedures only for legitimate
purposes and not to harass or intimidate others. A lawyer should
demonstrate respect for the legal system and for those who serve it,
including judges, other lawyers and public officials. While it is a lawyer's
duty, when necessary, to challenge the rectitude of official action, it is also
a lawyer's duty to uphold legal process. [emphasis added]

[6] As a public citizen, a lawyer should seek improvement of the law, access
to the legal system, the administration of justice and the quality of service
rendered by the legal profession. As a member of a learned profession, a

Constitution of the United States, Amendment I

Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of
speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress ofgrievances.
In Re: Vanessa Hall-Harper, Lori Deeter Wright, and Laura Bellis
March 26, 2023
Page2

lawyer should cultivate knowledge of the law beyond its use for clients.
employ that knowledge in reform of the law and work to strengthen legal
education. In addition, a lawyer should further the public's understanding
of and confidence in the rule of law and the justice system because legal
institutions in a constitutional democracy depend on popular participation
and support to maintain their authority. A lawyer should be mindful of
deficiencies in the administration of justice and of the fact that the poor,
and sometimes persons who are not poor, cannot afford adequate legal
assistance. Therefore, all lawyers should devote professional time or
resources and use civic influence to ensure equal access to our system of
justice for all those who because of ecoromic or social barriers cannot
afford or secure adequate legal counsel. A lawyer should aid the legal
profession in pursuing these objectives and should help the bar regulate
itself in the public interest."

Oklahoma Rules of Professional Conduct, Appendix 3-A. Section preamble.

There is no violation of a statute until a Court determines there has been a violation. Your
posts on social media concerning my clients are not only incorrect, defamatory and
libelous; you have sought to intimidate using threats of a lawsuit. I suggest that you look
at both the Open Meetings Act and the Open Records Act. Any findings of a violation
of the act requires "willfulness" on the party alleged to have violated either Act.

In addition, you might toke note that 51 OS § 24A.9 allows for a public official to keep
confidential her or his personal notes and personally created materials.

Should you bring suit, I will accept service on behalf of Hall-Harper, Deeter Wright and
Bellis. If I am not in the office, my assistant is authorized to accept service. My assistant is
in the office from noon until 5:00 p.m. You should be aware. that if you do file suite. I will
request attorney fees. I charge $450 an hour for this type of work. I suggest that you
purchase the Oklahoma Open Meeting & Open Records Book from the Oklahoma Press
Association.

Sincerely,

~?~
Laurie Phillips

cc: Vanessa Hall-Harper

Lori Deeter Wright
Laura Bellis
Patrick Boulden, Attorney for City of Tulsa
Councilor Crista Patrick, Chair
 ($6,178,882.D1). pravlously ~naed from;..;:...,. ncel...t;,.;.,.h an Olclahoma Homeland
Seaufty Grant Awanl wlthh, tho Oklahoma Department of Transportation Grants F•nd. [UED
'/21; CC 11/17/21; CC lZ/1/21)

3 of 3 ance amandina the llscal year 2021-2022 bud&et ta make 111pplemental -,iprfations of
htlnmd ei&hty-seven thOIISlnd, ~ dollar,, ($387,099.IIO) fnlm die US
Oepanment of Justice ta be ncelved wllhln the JAG Reimbursement Granis Subfund. [UED
11/17/21; CC 11/17/21; CC lZ/1/21)

U. Ordinance amendln1 the fiscal year 2021•2022 budgot ta make 111pplemental approprialfons of
forty lhousand doGzr,, ($40,000.00) from ll"'nt reven•os to be IK<lfved within the Non-Grant
Miscellaneous Spedzl Ra..n.. Fund. [UED 11/17/21; CC 11/17/21;CC lZ/1/21)

14. Rosollltlon requostln& that the lndwi Nations Collna1 of Governments (INCOGJ proeram the
p•rcl,ase of ten (101 electrfc vehicles and ISSOdated ch•'lfna llatlons ta n,place f,ve (SI
psollne-fuelednhiclos ror die Qty otT•lsa AsNc "'"-ment0eparlm81Und live ISi
psollne-f.eled vehicles lorlhe Qty of T•lsa Information ToduloJoay Deportment Into the
Transportatlonl-entPr.,.,amfottheTulsaTl'IIISPOrtltfonMlnqementArea;
requesting that the Oklahoma Transportatfon Commission OIHl<Ul' In the -rammlna. [UEO
11/17/21; CC ll/1/211

15. Resolution n,quostJna that the Indian Nations Ccundl of Gowmments (INCOGI PfOllram the
p•rchaso of twelve (121 electric: vehicles and associated chltllnl stadons to n,place IWelve (121
psollne-lveled vehkles for lhe City of Tulsa Enalnearfnc 5eNlces Department Into the
Transportation lmp,ovement Proeram fat the Twa Transpomtfon M&nqement Area;
requesting that the Oklahoma Transportallon CommlUlon concur In the pt0ttlfflmln11, (UEO
11/17/21; CC ll/1/211

16 R....,luttnn nf t"'-' Oty ol Tulsa. Oklahoma, Slating Its Intention to appropriate Amencan Rescue
Plan Act CARPAi funds to spedflc pqramund profecn; pro.kl'a,1 for additional procedwres and
condillons ol fundlnc- lEmersency Clause) (HaU-Harpar, Cue, Deeter Wrfgh~ uklnl (UED
11/17/21; CC 11/17/211

17. Olscuulonwlthandpn,sentation l t o m - - f r o m theTulsa Rep,1111 Olamborof

Commen:eon cunwnt actlvldos and efforts. ICC 11/17/21)

18. Adjournment.

EXHIBIT
Q cityoftulsa.org - Private
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