Mr Bender Reply To Gilda Cordova Statement & Complaint

In a recent interview with a Local Lompoc resident, and through a formal Request for Information, numerous complaints* were found against council member Ms. Cordova. LompocToday conducted an interview that was triggered by a lack of response from the city.
*It should be noted, no formal complaints were found against any other sitting council member.


Below is the formal response from Mr. Bender provided to the LompocToday outlet:

My name is Martin Bender. I am a local Lompoc citizen and have lived here off and on since 2001. I served our country as both an enlisted military member and later as a military officer. I have a juris doctorate and have worked for both private practice law firms and for the County of Santa Barbara Superior Court. I am raising four children here in our community that range from high school to elementary to toddler. I have not and have no intention of holding any public office but I do believe in the integrity, transparency, and accountability of our elected officials.

In early February I wrote and delivered a letter to the Lompoc City Attorney’s office regarding a concern pertaining to the residence of District 1 city council member Gilda Cordova. Three weeks passed with no response from the city attorney’s office despite numerous phone calls for follow-up. Frustrated with the lack of response I made my concerns public via Facebook. I was later interviewed and provided the same information which was later published on Lompoc Today. Interestingly enough within 24 hours of going public with my concerns the city attorney finally responded to my letter.

The basis of my concerns regarding Ms. Cordova’s address were as follows:

  • Cordova filed a Statement of Information with the Office of the Secretary of State for the State of California. The form asks for the “street address of principal office of corporation” for which Ms. Cordova stated was “2863 Lewis Drive, Lompoc CA 93436”. The form then asks for the address for the “agent for proof of process” for which Ms. Cordova indicated was “2863 Lewis Drive, Lompoc CA 93436.” According to Legalzoom©, an agent’s duties include “have someone available at that address to receive service of process for the business” and goes on to state “someone must be at the designated agent’s address during regular business hours.” Because Ms. Cordova listed a residential address (that does not have an associated business license that I could locate) I believed it to be evidence that Ms. Cordova lived at this address. If, as Ms. Cordova claims, it is merely an investment property, it’s unclear how she could ensure that someone would be present at that address during the company’s business hours. In any event, it raised a legitimate question as to Ms. Cordova’s residence, as the address was located outside of the city limits, and under Lompoc city ordinance no. 1643(17) section 2.06.02(B)(ii) “termination of residency in a district by a seated Council Member shall create an immediate vacancy for that City Council district…” If she had in fact moved and resided at the residence then she could not serve on city council.


  • A Santa Barbara county property records search indicated that the address 2863 Lewis Drive, Lompoc CA 93436 was receiving a “homeowners property tax exemption” of $7,000. According to the county “the exemption is available to an eligible owner of a dwelling which is occupied as the owner’s principle place of residence…” This appeared to demonstrate that Ms. Cordova had indicated to the county that the residence was her principle place of residence. If that were true then either a) she was indeed living outside of the city limits or 2) had improperly taken a tax exemption on the property. That was the information publicly available and created a prima facie case that Ms. Cordova indeed lived at the address on Lewis Drive. To Ms. Cordova’s credit, she later contacted and published an email from the Santa Barbara County Clerk-Recorder-Assessor that stated that the home owner’s exemption was displayed on the property because the previous owners in 2022 had taken it and that it would not apply to the property as of the date of sale in May of 2022. While Ms. Cordova was able to get clarification on this issue, it doesn’t change the fact that the information as it was available to the public when my initial complaint was made, would lead a reasonable person to question whether or not the address was the principle residence of Ms. Cordova. Some have since claimed that this serves as proof that Ms. Cordova does not reside at the residence, it does no such thing, it only establishes that she’s not taking a tax credit for doing so. That said, this particular piece of evidence of Ms. Cordova’s principle place of residency is no longer at issue thanks to Ms. Cordova’s effort to produce clarification on the issue.


  • Several residents and neighbors who live on Lewis Drive came forward and stated that they had firsthand knowledge that Ms. Cordova did in fact reside at 2863 Lewis Drive. I did verify the addresses of the neighbors who made statements regarding Ms. Cordova living there and there was no reason to believe that these neighbors were not being truthful.


While none of the evidence, as it existed at the time of my initial complaint, is conclusive of Ms. Cordova’s primary residence, it raised substantial questions that deserved answers. The city attorney responded that it was not the responsibility of the city attorney or city staff to investigate the residency of a city council member when challenged and that if I believed she was residing outside the city limits that I could personally take legal action against her. This seems odd to me that at face value there was prima facie evidence of a violation of a city ordinance by a sitting city council member and that the city attorney refused to investigate it. I am forwarding my complaint to the state Attorney General’s office for clarification on who has responsibility to investigate these types of claims and whether or not it is in fact the responsibility of private citizens to bring legal action against members of city council for potential violations of city ordinances.

For her part Ms. Cordova has made several posts and videos on her campaign social media page regarding the issues I raised. According to Ms. Cordova’s own words the “allegations broke [her] heart.” Ms. Cordova states in her video that she is not a politician and yet Ms. Cordova is in fact a politician which is defined as “a person who is professionally involved in politics, especially as a holder of or a candidate of an elected office.” Ms. Cordova tells us that we have her word she doesn’t reside outside the city limits and that my complaint is outright untrue. Ms. Cordova goes on to state that:

“Being questioned by a select few because they do not believe that I could or should own an investment property aside from my primary residence concerns me and tells me that there is a greater issue of social equality within our community. This too breaks my heart. This is an attempt by a group of individuals that wont’ stop until they remove me from council seat representing district seat number one,. They seek their own agenda and the interest of a select few, not the majority of our residents.”

Ms. Cordova then asks that residents “consider the source of these allegations, consider the motives, and consider the means which these individuals have engaged in social media or any platform where they share their personal opinions and beliefs which they have labeled as fact. Anyone that comes to you with words of hostility, mean spirited words that incite anger, confusion, or hatred is not someone that is someone looking out for the best interest of the majority.” Ms. Cordova finishes by stating that she is considering all of her legal options at this time.

There are many issues with this position that Ms. Cordova has taken. First, the citizens of Lompoc should absolutely consider the source of the allegations. The facts are that I do not know Ms. Cordova, I have no business interests related to Ms. Cordova, her corporations, or the city in general. I am merely a concerned citizen who raised concerns with the city attorney’s office to investigate. Ms. Cordova claims I raised these allegations as “fact” when I did no such thing. My letter to the city attorney, which has been previously published multiple times, begins with “potential violation” and “if proven true” clearly indicating that my allegations were just that, allegations. Even in my analysis of the evidence that I submitted to the city attorney I stated that “Ms. Cordova appears to have terminated her residency…” and requested that the city attorney’s office investigate the matter. In an article on Noozhawk, editor Janene Scully quoted Ms. Cordova as stating that these allegations arise from a disbelief that a “Latino middle-aged, hardworking woman” could own more than one property.  I find it entirely disingenuous of the council woman to bring race or gender into this as neither have any bearing on my decision to raise the issues that I did and it’s a weak attempt to incite anger, confusion, and hatred, the very things that Ms. Cordova states “is not someone looking out for the best interests of the majority.”

Contrary to Ms. Cordova’s stance that she is not a politician, she is in fact a politician in every sense of the word and as such is subject to increased scrutiny by the public. The fact that Ms. Cordova states that she’s considering her legal options in this matter demonstrates a gross misunderstanding of the law, the first amendment, and of her position as an elected official. If Ms. Cordova believes she is above being questioned simply because we should take her word, then she entered into the wrong profession. While I commend Ms. Cordova for getting clarification from the county on the residence in question not receiving a tax credit, her approach to threaten legal action and to discredit my motives should concern every citizen of Lompoc. If Ms. Cordova does in fact live with her mother in district one, as she claims in her video, then she should have no reason to be concerned about my allegations. I would be the first person to admit that the allegations were false if evidence is produced to demonstrate that. My goal is not to remove Ms. Cordova, my goal is to ensure that our elected officials are not above reproach and that they are in fact complying with state, county, and local laws. As a public figure Ms. Cordova has no legitimate legal basis to bring any legal actions against myself, or anyone else, for raising concerns relating to her position on city council. This is implied by her own attorney in an email response he wrote to her in which he states, “your problem is a little more extreme than for most people because you are a public figure.”

In any event, the issue of her residency is left unresolved for now. The city attorney’s office refuses to investigate it and Ms. Cordova asks that we just take her word for it. It would be up to the citizens of Lompoc to be vigilant of the issue and if more evidence is produced then hopefully the city will take action.

I will also add that in my research of Ms. Cordova’s purchase of 2863 Lewis Drive, Lompoc CA I became aware that the home sold for $650,000 according to public records, when the home was valued at nearly $1,000,000 or more (anyone can verify this with a google search). Further research indicated that the home was sold to Ms. Cordova from the Patels (Patel Atul Kumar Prabhubhai, Patel Minaxi Atul, Patel Atul & Minaxi Family Trust). The Patels are members of the board of directors that Ms. Cordova is the president of for Visit Lompoc, LLC (dba Explore Lompoc) which I understand has a 10 year contract with the city of Lompoc that’s potentially worth millions of dollars and is overseen by the city council. The same city council that Ms. Cordova sits on. Whether or not this is a conflict of interest in and of itself is unclear, but the main issue that arises is that it appears the Patels gave a gift of approximately $350,000 to Ms. Cordova ($1,000,000 value – $650,000 sales price) as a city council member that they do business with, in potential violation of state law as elected representatives cannot receive gifts over a certain value ($520 in 2022). It’s also unclear how deep this potential conflict runs as Ms. Cordova on her Statement of Economic Interests (California Form 700) states that she received $100,000 to $1,000,000 from Legend Hospitality Inc. for management and consulting Inc. It’s my understanding (I may be wrong) that Legend Hospitality benefits from the contract between Visit Lompoc, LLC and the city of Lompoc. Ms. Cordova also indicates on her 2021 Form 700 that she has a Limited Partnership with Lompoc Land Holdings, LLC worth a value of $10,001 to $1,000,000. Public documents show that Gilda Cordova and Suraj Patel are officers of Lompoc Land Holdings, and filings for the LLC with the state are signed by Atul Patel. According to the Form 700 Atul Patel also gave Ms. Cordova a personal loan of $10,001 – $100,000 in 2020. It’s an extremely tangled web of LLC’s, city contracts, gifts, and potential conflicts of interests that is beyond the scope of my current information. As such, I did request that the city attorney investigate it and he responded that he would look into it as this was the first time he had heard such allegations. I am also going to be forwarding the information to the California State Attorney General’s office to review as it appears that several state laws may have been violated. To be clear, I do not know whether any of this amounts to a violation of any city, county, state, or federal laws but there appears to be some transactions, especially gifts, that may. Ultimately it is up to the city attorney and the state Attorney General’s office to investigate and possibly for the courts to decide. If there’s no violations then great, but as I’ve stated before, I whole heartedly believe in our elected officials being transparent and accountable to the citizens that elected them and so should every citizen of Lompoc.

In the words of Benjamin Franklin, “it is the first responsibility of every citizen to question authority.”