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Brief in Support of Respondents’ <br />Appeal of Violation 1 <br />Citation No. CE19-0399 (Amended March 24, <br />2026) — RCC § 9.40 <br />Property: 2455 Carson Street, Redwood City, CA 94061 (APN 058-414- <br />220) <br />Respondents: Stephen and Sharon Burns <br />Counsel: Norm Matteoni — norm@matteoni.com <br />Hearing: City Council Special Meeting, Monday, May 4, 2026, 6:00 p.m., <br />Council Chambers <br />Submitted to: Yessika Castro, City Clerk, for inclusion in the Council <br />record <br />Synopsis <br />Respondents are trying to put the garage back the way it was, and the <br />City will not let them. <br />Respondents paid the City $10,650.67 in plan-check and permit fees <br />on January 19, 2023. Forty-one months later, the City has neither <br />issued the permits nor refunded the fees. The work cannot proceed <br />without those permits. The “violation” the City now charges is the <br />consequence of the City’s own delay. <br />6.A. - Page 16 of 64 <br />18