Edward

FACTS

The following facts are taken from the complaint, declarations, and other evidence submitted on the special motion to strike.

1. Edward, Headlands, and the Beach Access Litigation

Plaintiff Sanford Edward is a real estate developer and a managing member of Headlands Reserve, LLC (Headlands). Edward and Headlands are known in Dana Point (the City) for developing The Strand at Headlands (The Strand), an oceanfront community of multimillion dollar homes sited at one of the last undeveloped coastal promontories in Southern California.

In 2009, in accordance with a City ordinance, Headlands installed pedestrian gates at The Strand to limit public beach access through the development during certain hours. The installation of the gates spawned years of litigation against the City.

During the course of that beach access litigation, the City regularly

submitted its bills for attorney fees to Headlands for reimbursement pursuant to indemnity agreements between Headlands and the City. In August 2015, however, Headlands stopped reimbursing the City for its legal fees. 2. The City’s 2016 Complaint Against Edward for Fraud

The City ultimately settled the beach access litigation in…