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AgdaPkt 2017-09-11 Closed and Joint SA PFA
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AgdaPkt 2017-09-11 Closed and Joint SA PFA
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Last modified
9/21/2017 12:51:50 PM
Creation date
9/7/2017 6:06:39 PM
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Template:
CC Index
CC Index - Document Type
Agenda Packet
Meeting Type
Joint
Agency Type
City Council and Successor Agency and Public Financing Authority
Date
9/11/2017
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TA. - Page 168 <br /> 7/5/2017 <br /> City of Redwood City <br /> Page: 2 <br /> appeal. (City of San Jose P. Superior Court, 42 Cal. 4' 319 (2017)). You should consider this a <br /> Public Records Act Request pursuant to Government Code Section 6250 for inclusion of <br /> these materials in the record on appeal, and the requisite obligation to disclose pursuant to <br /> California Constitution Article I, Section 3, Subsection (b)(1). Appellants' submittals <br /> include,but are not limited to,the following: <br /> 1. Letter from Dave Tanner,Inc.,dated November 1,2016. <br /> 2. Letter from Stewart Painting. <br /> 3. Letter from Powlan Cassidy Law, dated November 1,2016, <br /> 4. Traffic Analysis Review of Proposed Project: Rocketship Charter School, <br /> Redwood City,California,dated March 31,2017,prepared by Prism Engineering. <br /> 5. Letter from Rasmussen Planning,Inc.,dated April 4,2017. <br /> 6. Letter from Dave Tanner,Inc.,dated June 16,2017. <br /> 7. Letter from Prism Engineering,dated June 16,2017. <br /> 8. Letter from Rasmussen Planning,Inc.,dated June 15,2017. <br /> Based on Appellants' submittals and all other evidence in the record before the City Council <br /> on this appeal, the City has not complied with CEQA, nor is there substantial evidence in <br /> the record to sustain the CUP findings required by your Code for the Project. Appellants <br /> reserve the right to submit additional information and analyses, as well as additional legal <br /> authority, in support of their appeal in this matter, particularly rebuttalevidence for any <br /> subsequent submissions from City Staff or Project proponents. Based on the foregoing, <br /> Appellants respectfully request that you uphold the appeal of the Appellants. <br /> Respectfully Submitted, <br /> POWLAN&ASSIDY LAW LLP <br /> By: <br /> 61 Stephen K. Cassidy <br /> Attorneys for Appellants <br /> cc: Dave Tanner <br /> Rebecca Powian <br />
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