OLVERA STREET LEASE NEGOTIATIONS Jeffer Mangels JMBM Butler & MitchellLLP------
Paul Hamilton 3 Park Plaza, Suite 1100 Direct: (949) 623-7235 Irvine, California 92614-2592 Fax: (310) 712-8552 (949) 623-7200 (949) 623-7202 Fax [email protected] www.jmbm.com Ref: 71153-0001
April24, 2011
Via Hand Delivery Via Email: [email protected] Honorable Members of the Budget and Gerry Miller Finance and Arts, Parks, Health and Aging Chief Legislative Analyst Committees City of Los Angeles City Hall City Hall 200 N. Spring St. 200 N. Spring St. Los Angeles, CA 90012 Los Angeles, CA 90012
Via Email: migueL santana@lacity. org Via Email: [email protected] Miguel Santana Ana Cubas , Chief Administrative Officer Chief of Staff to the Honorable Jose Huizar City ofLos Angeles 14th District Councilmember City Hall City Hall 200 N. Spring St. 200 N. Spring St. Los Angeles, CA 900J 2 Los Angeles, CA 90012
Via Email: [email protected] Robert L. Andrade General Manager El Pueblo De Los Angeles Historical Monument
Re: El Pueblo De Los Angeles Historical Monument Concession Agreement. April21, 2011 Report; Council File No. 11-0449; Assignment No. 11-04-0381
Dear Councilmembers, Mssrs. Miller, Santana and Andrade, Ms. Cubas:
The writer and my law firm, represents the Olvera Street Merchants Association ("OSMA"). OSMA represents 4 7 Olvera Street Merchants who are the lessees of 60 premises on Olvera Street.
OSMA has received the detailed April21, 2011 Joint CLA/CAO/Department Report ("April 21, 2011 Reportu) to the Joint Committees and make the comments that follow.
A Limited Liability Law Partnership Including Professional Corporations I Los Angeles ,. San Francisco ,. Orange County 7755353vl Honorable Councilmembers; Gerry Miller; Miguel Santana; Ana Cubas; Robert L Andrade April 24, 2011 Page 2
I. Expression of Appreciation
OSMA is very appreciative of the efforts made by the City and its representatives and particularly, Council member Huizar and the tireless efforts of his Chief of Staff, Ana Cubas, in bringing the Concession Agreement to this eve of closure.
OSMA is also very appreciative of the extraordinary and tireless efforts of Judge Dennis Choate, as mediator, to long ago bring the parties near to closure, of Concession Agreement Terms that he stated were reasonable to the City and the Olvera Street Merchants represented by OSMA.
Taking into account the CLA, CAO, and Department recommendation, OSMA and the City are very close to consensual agreement on the economic and other terms of the proffered March 18, 2011 Concession Agreement. With OSMA's requested concessions approved, it is done. In OSMA's view, the facts compel these requested adjustments, are addressed below.
II. The Olv:~ra Street Merchants are Entitled; They are not Month to Month Tenants
Since 1980, the State, the Electorate of the City, and the City Council have recognized the need to protect the Olvera Street Merchants and their commitment to El Pueblo, and their years of benefits provided to the City:
• In 1980, the State General Plan recognized the Olvera Street Merchants as "a unique and important human resource," thus giving the Olvera Street Merchants legally protected status which cannot be denied by City action.
• In 1992, the City Electorate, with unanimous City Council support, passed Proposition H, recognizing then 60, now 81 years of benefits given by the Olvera Street Merchants to the City by commanding the City "protect the Olvera Street Merchants and the Mexican marketplace theme while recognizing the [Olvera Street] Merchants' continued commitment and involvement. They have become the essential link to the preservation of this [EI Pueblo] historic landmark." And the City electorate mandated that long term leases be given to the Olvera Street Merchants without competitive bidding, thus assuring that no future action by the City could lawfully deny the Olvera Street Merchants a long term lease without competitive bidding to the Olvera Street Merchants.
"' In 1999, in implementation ofProposition H, the City Charter was amended to require the City "to negotiate long term concession agreements with the Olvera Street Merchants without any arbitrary or artificial limit as to their duration to be determined on what is negotiated as being fair and :reasonable in light of all the other terms and conditions negotiated in the contracts."
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® In 1999, the City Council, by unanimous vote, further implemented the mandates of Proposition Hand the Charter Amendment by directing the Department to enter into Concession Agreements with the Olvera Street Merchants on certain minimum terms.
III. Olvera Street Medium to Large Stores Must Have Further Rent Relief
As presented by to April 24, 2011 OSMA letter filed with this letter, 6 medium to large size stores will not likely survive the increased rent and CAM fee due to the present economy, if further rent adjustments are not made. The new rent/CAM fee represents a minimum of a 190% increase to as much as 294% increase in the tirst year of the lease, depending on the Merchant, - with greater increases over the next 4 years. Moreover, the new rent and CAM fee are estimated to be between 17% and 40% of the 2010 gross revenues of such Merchants. By any measure, these are not economically sustainable rents, and, accordingly, as mandated by the City Charter, 11 these rents/CAM are not "fair and reasonable . Any real estate professional will confirm this.
OSMA takes issue with certain related findings in the April 21, 2011 Report, determining that the combined effect of new rent and CAM and payment of6 months ofback rent and 2 11 months of security deposits are "fair and reasonable , the facts are:
1. Unanticipated December 201 0 rains during Las Posadas and New Year week and unanticipated extraordinarily slow first quarter 2011 significantly reduced revenues.
2. Of the 158 days from the time the first City Term Sheet was proposed to the City proposed March 18, 2011 Concession Agreement, the City consumed 115 days in drafting the new Term Sheets and Concession Agreements and OSMA spent 43 days. OSMA Merchants should not be penalized for this delay.
3. The August 2009 Riggs Report is 18 months old. No updating has occurred, although OSMA has repeatedly asked for an updated report. Comparable rents have dropped significantly from August 2009 to the present, with vacancies for long periods. The 20-30% 1 discount from April I, 20 I 0 rent mentioned on page 2 CRent' ) of the April 2 I, 20 II Report is not reflective oftrue present market rates; which are 35 to 50% below the August 2009 rents. OSMA's well respected MAI Appraiser, Ron Buss ofBuss Shelger, will confirm this fact through testimony, as certain of the Merchants at the April25, 2011 Hearing will also establish these facts.
IV. There is No 11 Gift of Public Funds" Issue
OSMA and the City Attorney agree that there should be no 11 gift of public funds" implicated. And none are, in fact, implicated here. The City Attorney's contention that agreeing to a rental amount that is anything other than "fair market value" is illegal as violating the California Constitution and other laws prohibiting a public gift is flawed because:
]efferMangels JMBM lButler & Mltcheiii.U' 7755353vl Honorable Councilmembers; Gerry Miller; Miguel Santana; Ana Cubas; Robert L Andrade April 24, 2011 Page 4
• The Constitutional ban on public gifts do not apply to Charter cities like Los Angeles and there is no other applicable authority to support the illegality of the rental amounts proposed by the merchants;
• The applicable law simply requires that a governmental entity obtain adequate consideration for leases; it does not require "fair market value;" and
e The enactment of Proposition H by the City Electorate and other laws and the elimination of competitive bidding for the Olvera Street leases provides a sufficient public benefit to negate the applicability of the public gift prohibition.
The City Attorney offers Allen v. Hussey (1950) 101 Cal.App.2d 457, as the key case supporting its position. Allen, however, is inapposite. There, the court found that a lease between defendant and the County of Los Angeles regarding an airport constituted an improper gift because the proposed rent amounted to one dollar a year and was to remain unchanged for 34 years and possibly 69 years through the exercise of an option. Allen, supra, 101 Cal.App.2d at 473(emphasis added). Thus, the Allen court found that because defendant provided no , consideration whatsoever for the subject lease, it was an improper gift of public funds under the State Constitution. !d. at 473-474. Those are not the facts here.
1. First, Olvera Street is City owned property, not County owned, and thus the public gift ban of the State· Constitution does not apply to the City of Los Angeles.
2. Unlike the County in Allen, the Olvera Street merchants here provide the City with more than adequate consideration for their leased premises. Over the first 5 year term of the Concession Agreement, the Merchants will pay over $7 Million in rent and over $1 Million in CAM tees. Such payments can hardly be compared to the $1 per year in Allen wherein absolutely no consideration was provided, and a "public gift" was found.
Moreover, assuming, arguendo, that the Constitutional requirement regarding public gifts did apply to City owned property, the law only requires that adequate consideration be provided in exchange, and not fair market value. 1 In Winkelman v. City (ifTiburon (1973) 32 Cal.App.3d 834, 844 ("it is established that in order for a transfer to avoid being classified as a gift, the consideration given in exchange must be "adequate," so as to evidence a bona fide contract The consideration cannot be merely "nominal." The law, however, does not require a weighing of the quantum of benefit received by a promisor or of the detriment suffered by a promisee where the consideration is plainly substantial. Therefore, appelJants' content1on that the transfer must be for the fair market value is not supported by any authority that is cited in their brief.")
1 And even assuming arguendo that fair market rent is required, the Buss Report sets forth the applicable market rent, noL the Riggs Report.
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Finally, as the City Attorney's other cited case recognizes (People v. City C?fLong Beach ( 1959) 51 Cal.2d 875), where the public obtains a benefit in exchange for governmental property, the public gift law is not violated. Here, the foregoing makes evident the public benefit provided by the Olvera Street Merchants to the City and confirms their entitlement to be excepted from the public gift rule:
V. Start Date and Back Rent
The April 21, 2011 Report seeks to justify the Back Rent date of November 1, 2010 based on a November Term Sheet Agreement between the City Attorney and OSMA and that 115 days of City delay in bringing closure to the Concession Agreement Terms are not the City's responsibility.
OSMA disagrees with these characterizations of the facts as set out below:
1. November 1, 2010 Agreement.
It is true that OSMA and the City Attorney agreed in November 2010 to a November 1, 2010 rent start date. This is not the end of the story; this agreement must be put in context.
At that time, it was contemp\ated that final agreement on all key terms would be concluded in November 2010 and a final Concession Agreement would be executed in November 2010. That didn't happen. The record reflects that from late November 2010 through March 18, 2011, the delay in producing a Concession Agreement incorporating the agreements reached in November and December 2010 through early March 2011 is generally laid at the doorstep of the City. In that time period, OSMA made repeated written and oral requests to the City that an updated Concession Agreement be delivered for review and comment- none was delivered until March 18, 2011; a period of over 115 days.
The economic facts then known to OSMA also dramatically changed. The late December 2010 heavy rains wiped out significant expected December revenues. In the first quarter 2011, there was also a substantial further reduction in revenues. These economic facts disabled the Merchants realizing the funds to pay these Back Rents and Security Deposit.
VI. El Pueblo Ec9nomic Issues are not Solely Revenues; Cost of Administration is an Issue
El Pueblo generates $4.2 Million in reported present revenues with a reported $5 Million in expenditures. As reported previously by the CAO in his yearly budget analysis, $1.5 Million in yearly administration expenses of the Department is unjustified and not sustainable, particularly given the level of(non) services provided to El Pueblo. This must be changed ifEl Pueblo is to be on sound and solvent financial footing. Attempting to overcome this operating
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cost extravagance by 200% plus rent/CAM increases in these recessionary times is, respectfully, wrong.
VII. Retail/Office/Storage Space Determination/Rental Rate Adjustment
Essential to certain Merchants signing the Concession Agreement is Merchant/City Agreement on type of space (reta11/office/storage) on the premises and rental rate thereof The premises affected are: W-OlB (La Luz Del Dia); W-03 (Olvera Street Candle Shop); W-07 (a) and (b) (Bazaar de Mexico); W-10 (Casa California); and W-17 (La Golondrina).
On April 18, 2011, the Department responded to OSMA's request for its determination of the above issues. In net, the Department determined that aU space inside the premises wall is retail space unless there are executed agreements for storage space. The affected Merchants disagree with the Department's square footage and space use allocations.
The affected Merchants retained architect Bruce Arita, AIA, of Thornton Tomasetti, an architectural firm, who are experts in these matters. Mr. Arita will provide a comprehensive , report establishing that the Depmtment's April 18, 2011 facts, and conclusions thereon, are not supported. Mr. Arita will give testimony demonstrating that the space used, for years, by the affected merchants is unqualifiedly unfit for retail use nor has it been used as retail space - the details of which are set out in his report, and such space is not code or ADA compliant for retail use.
The affected merchants request that: (a) the Committees adopt Mr. Arita's report; or alternatively (b) the Department and Commission be directed to withhold any implementation of its April 18, 2011 findings and recommendations until it has considered and rendered a detailed response to the Thornton Tomasetti report; and (c) no action is taken to finalize the Concession Agreement until these matters are concluded.
VIII. Mi Rosa (E-14)
Rent is charged at $5.50 per square foot. Mi Rosa challenged this determination. Mi Rosa contends that its measurable retail square footage is greater than 960 square feet with no less than 150 square feet as storage and the retail space market rent is no more than $3.00 per square foot.
Mr. Buss will give testimony and provide a report establishing that the Mi Rosa space should be measured by comparable retail space at 800-1000 square feet citing many premises at a rental rate of$2.50-$3.00 per square foot.
Mr. Arita will testify that a portion of the space is storage and could not be sued as retail. No Concession Agreement will be signed by Mi Rosa until this issue is satisfactorily resolved.
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OSMA will supplement this presentation at the April25, 2011 Joint Committee Hearing.
Respectfully Submitted,
PAUL HAMIL TON of Jeffer Mangels Butler & Mitchell LLP
PH:dpc cc: Vivien Bonzo, President, OSMA ([email protected]) Gerry Hertzberg, Office of Gloria Molina, Chairman, Board Supervisors: County of Los Angeles ([email protected])
jeffer Mangels JMBM lButler & Mit<: hell '" 7755353vl To: Honorable Members of the los Angeles City Council Fr: Olvera Street Merchants' Association
April 25, 2011
SU: Outstanding Olvera Street Lease Negotiation Issues
Dear Council members,
The following is a summary of the outstanding lease issues and requests of the Olvera Street Merchant Association. We seek resolution of these issues as soon as possible in order that an agreed upon lease may be executed. We are available to meet at your convenience and request this audience as soon as possible. We will be contacting your office this week to schedule an appointment.
Sincerely yours, Vivien C. Bonzo Olvera Street Merchants' Association
Olvera Street large Stores Destined for failure in City's Rent Plan
1. Olverita's Village, Unit W-24 will pay a 250°/o increase in combined rents and fees over current rental rates under the City's proposal. Olverita's current rent and CAM will increase from $2325 to $5026 or $60,300 annually in combined new rent and related fees for the first year of the lease. This increase is not sustainable and will place at risk the continuation of this business.
Background Last year, Olveritas Village gross sales declined 30°/o due to school cuts of Mexican ballet folklorico affecting costuming for student groups, restaurant uniform business die-off and declining book and CD sales. Olverita's Village special niche of Mexican costumes, Spanish language books and music is continuing to fall under recessionary pressure. The owner works seven 7 days a week and has cut vital staff and other supportive practices to try to contend with the loss of sales. All tenants on Olvera Street were impacted by Dec and Jan rains, undermining anticipated holiday revenues.
2. Casa Bernal, Unit W-23 is being assessed a 258% increase over current rents. This business increases from $2391 to $6167 or $74,000 per year upon lease signing. This increase is unachievable and will place at risk the economic solvency of the business.
Background casa Bernal will sustain the fourth highest combined rate increase on Olvera Street. In 2010, Casa Bernal missed the hardship {10°/o profitability) threshold by 1°/o --at current rental rates. Gross sales would need to increase by over $240K at a 50% retail mark up, in order to maintain the current level of diminishing profitability. New rent and added fees as proposed are financially unsustainable. 3. Casa California, Unit W-10, will sustain the second highest Olvera Street rate increase of 302°/o increase. The business currently pays a rate of $1679 monthly that will increase to $5070 or $60,800 annually at the City's proposed rate. Given declining sales/ this business will be unable to sustain itself at the new rates.
Background In 2010, the owner cut back on her $30K annual salary to mitigate a year-over- year drop in sales. The owner has exhausted personal savings to remain in business. Her husband is housebound with a major illness. This owner has had to pay a home health care worker along with part time help at the store to manage time needed as caregiver to her disabled husband.
El Pueblo increased Casa California's square footage by some 600 square feet when it completed its revised measurements. This tenant has a sizeable storage space in her shop being assessed at the prime retail rate. The storage area is not handicap accessible and has been in use as storage for over 50 years. El Pueblo is unwilling to recognize storage space at the appropriate rate. Current rent and fees will render this business a candidate for bankruptcy and eviction.
4. Bazaar de Mexico, Unit W-7 is in line for a dramatic 233°/o increase. Bazaar's rates go from $2113 to $4925 or $59,100 annually in increased rents and fees in year one. This rate of rent and fees is likewise unachievable.
Background Bazaar de Mexico has reported sales declines over the past two years of 35% as a result of the recession. These declining sales have impacted bottom line profits which will be severely undercut if the City,s proposed hundreds-fold increase is implemented.
5. Olvera Street candle Shop is assessed a 280°/o increase. Their cost will go from $1141 to $3200 year one or $38,400 annually in increased rents and fees upon lease signing. This rate of increase will require half of the store owners to go without any pay for one full year.
Background · 100% owner operated by 4 sisters who took home little more than $13K each last year with no rent increase. Their personal income is supplemented by their spouses. Candle Shop sales have declined a total of 50°/o since 2006. The City's proposed rent increase will place all owners at below poverty level salary rates. This business will be on the path to closure if City rates, as prescribed, are implemented.
6. Reynati's, Unit W-2, is the final large store example at 3270/o increase (the largest increase of all the large shops) from $1346 to $4402/1st yr or $52,800 annual increases for year one of the lease.
2 Background Reynatdo Verduzco signed the 19991ease (in 1999) and retained his copy. The City Attorney signed the lease but some signatures were not obtained by the Ei Pueblo Administration and are still missing. The City Attorney has not responded to OSMA's request to honor this lease. There is a second business owner, Rafael Caballero, with two puestos that also hold copies of the 1999, City Attorney signed lease. OSMA wishes to have both tenants recognized as proper 19991easeholders. In either case, Reynati's rent and fees are unsustainable given the street-wide decline in sales.
All the large store rent increases should be viewed against the context of the last twelve year CPI increase of 37%1 during the same period. There is a substantial amount of City created storage space that is not "retail use" code compliant Adjustments to proposed City rates must reflect storage as opposed to a retail use and pricing.
ProQer Measurements and Correct Rates for Olvera Stress Businesses
For the past several months, OSMA has sought adjustments in the measurements, use and rental pricing of several Olvera Street businesses. In a recent letter to Robert Andrade, OSMA provided examples of businesses that have incorrect and inappropriate rental rates. Mr. Andrade responded with a letter confirming that all six business measurements he investigated were different than what was reflected in the Riggs and Riggs 2009 Rent Study.
To promptly resolve the issue, OSMA contracted a licensed professional to provide accurate square footage measurements and a statement as to the types of use permissible under current City codes. It was confirmed that many of the businesses that contain storage space, are being improperly charged at retail prices, because, in most cases, they will not conform to City building and safety or fire code requirements for such use.
OSMA Request OSMA requests that City Council accept the professionally certified measurements and appropriate use classifications for each business involved and adjust the rental rates accordingly.
Disproportionate Impact of CAM and Back Rents on Large Retailers
Common Area Maintenance Fee Increase The CAM (common area maintenance fee) will increase 400°/o and is charged according to square footage. Larger retailers receive substantial rate increases as a result of the new CAM rate. The new rate was characterized as non-negotiable in the mediation process and thus had to agree upon by OSMA.
City CAM Cost Analysis shows fees of $50 to change light bulbs and $100 to pick up a dead bird. Private sector CAM rates in neighboring counties ranged between $0.16- $0.22 psf in 2010, while El Pueblo's rate is $0.36 psf. No other tenants pay CAM at El Pueblo except Olvera Street merchants. Commercial vacancies within El Pueblo further lessen the number of CAM contributors overall.
3 Back Rent Assessments and Security Deposits Back rents are being assessed from November 1, 2010- present. November, 2010 back rents were agreed to by OSMA based on a dosing date of December 2010, but further City delays ensued over the holidays. The Lease Term Sheet authored by the City Attorney first appeared on October 10 2010. The City Attorney final Concession Agreement is dated March 18, 2011. During that time, there were 2 Term Sheet revisions and 1 Concession Agreement revision. The City Attorney took 115 days to make revisions; OSMA took 43 days to make its revisions. OSMA is financially penalized for delays that it had no control over.
Back rents are being assessed for 6 months, plus 2 months in security deposits, increased base rent and the significant increase in CAM fees. In aggregate, these combined rates puts at risk of evictions all of our large retailers.
Two month security deposits for tenants who have continuously occupied the space over the past 60-80 years are unnecessary. Alleged potential damages to the space have never occurred. City Charter entitled tenants will occupy the facilities for the next forty years; however, the imposition of these numerous additional fees, in aggregate, will likely prevent their anticipated longevity.
Casa de Sousa was evicted for rent default in 2009 and both shops are still vacant. Meloni Tanzini died 2 yeas ago and his two shops are still vacant. Evictions and vacancies have cost El Pueblo considerable lost revenue and yet evictions are inevitable at City prescribed rates for all of the Olvera Street large stores. Large stores keep detailed financial records and offer exclusively Mexican-themed merchandise for the public's enjoyment.
OSMA Request Elimination of November 2010 to present Back Rents; Commencement date and agreed upon rate increases to be provided simultaneous with the execution of lease.
80 Hour Minimum "On Premises.. Owner Partici(g!!tion
The requirement for specific hourly and on-premise owner participation, introduced unilaterally by the City Attorney on March 19, 2011, violates the Term Sheet agreement authored by the City Attorney in November 2010. This last minute provision was never agreed to or discussed with OSMA.
Merchants will pay increased rental and CAM rates, maintain businesses according to all lease requirements, but are now becoming quasi City employees working the number of hours and in a manner dictated to us by the legal branch of the City. This new provision is not in any other Olvera Street tenant leases and is likely not included in other off-site City leases. Illness, family emergencies/obligations, other business undertakings, extended and justifiable time-off are not excusable in this restrictive provision. Failure to abide by this requirement is considered a breach of contract. The ClA report does not include any comment on this new City Attorney proposal.
4 OSMA Request Strike all references to any hourly and business related requirements and replace with: 11The majority owner will provide suitable personal attention and participation in managing the concession".
Use of Olvera Street Name
Olvera Street Merchants Association (OSMA) and Olvera Street Merchants' Association Foundation (OSMAF) are both active organization that require use of the name Olvera Street. City Attorney proposes to restrict this use. OSMA's use of this name predates City ownership of El Pueblo Monument dating back to 1957. Each of these non-profit organizations have provided decades of pro-bono service to Olvera Street's cultural life and utilizes non-profit 501 © (3) status to raise additional revenue for Olvera Street's cultural events. OSMA and OSMAF have used the name Olvera Street since 1957 and 2005, respectively, without objection by the Oty resulting in protected common law use.
OSMA Request Instruct El Pueblo to provide an exemption for OSMA and OSMAF for use of the name Olvera Street to continue its cultural non-profit endeavors.
cc: Honorable Members of the Los Angeles City Council Chairman, Los Angeles County Board of Supervisors Honorable Mayor Villaraigosa Gerry Miller, Los Angeles CLA Miguel Santana, Los Angeles CAO
5 Olvera Street President's day weekend 2010 I Olvera Street President's day weekend 2010 Olvera Street Fountain at E-15. In this state for three weeks in October 2010 E Pueblode LosAngeles tree base alongMain Street, 2010 _ Pueb o de Los Angeles 6 of September Mexican Independence day Plaza 'osk below stage restrooms, 20 0.
El Poe lo · torical1\Jionument's Cinco de ayoCelebr tion2010
El PuebloHistor·cal Monument's Cinco de MayoCelebration 2010 YEARLY FIGURES
I A B c D E F I G I H Shop Shop Current Rent Current vs. Year 1 Year2 Year 3 I Hardship"" I i No. Sq. Ft. * i CAM& Tax Gross Sales vs Gross vs Gross vs Gross I vs Gross I l W-03 1,482 I $17,645.00 10.78% I 25.88% 31.44% 37.00% 28.85% ! W-07 2,209 $30,683.00 15.49% I 30.08% 33.71% 37.34% 34.64% I W-10 2,381 $24,101.00 15.12% 40.64% 50.22% 59.80% 46.37% W-23 3,898 $36,878.00 9.88% 22.01% 26.05% 30.08% I 23.82%
! 19.31% W-24 3,059 $33,995.00 8.59% 16.78% I 21.85% 17.21% I I I E-14 ** 886 $15,901.00 I 6.51% 11.22% 12.78% I 14.33% 11.07% I E-14 *** 886 $15,901.00 6.51% 13.40% 17.14% 20.87% 15.41% I oo 50% off Riggs Study * Per El Pueblo Footage ** at $3.00/sq ft rate ***at $5.00/sq ft rate