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1. The Property and the Citation <br />The garage and accessory structure at 2455 Carson Street were built circa <br />1951, twenty years before the 1971 storm drainage easement and seventy- <br />four years before the 2025 California Building Code edition now charged. <br />Respondents purchased the property in 2012 and have owned it <br />continuously since. <br />The Amended Citation of March 24, 2026 alleges, as its first violation, <br />that “no building permit is on file for the garage addition, located closest <br />to the creek,” charging RCC § 9.40 referencing California Building Code <br />§ 105. The “garage addition” referenced in the citation consists of work <br />completed February 2, 2018 that extended the existing eave on the side <br />of the original 1951 garage to the existing CMU wall at the rear of the <br />property and enclosed the previously covered storage area with walls <br />on each end. That work is the entire factual basis of Violation 1, and <br />Respondents acknowledge that as completed it required a permit. <br />Respondents filed Permit ADU22-0064 in November 2022 to authorize <br />the corrective demolition of the 2018 work as part of the garage-to-ADU <br />conversion, bringing the property into compliance. (Respondents also filed <br />Permit C22-0027 at the same time for the separate main-house renovation; <br />both permits were paid in full and both have been held in plan check <br />since.) <br />2. The Origin of the 2018 Work and a City <br />Building Inspector’s Advice <br />When Respondents purchased the property in 2012, the area where the <br />2018 work now sits was already covered by a corrugated, shanty-style roof <br />on 2x4 supports running from under the garage eave to the CMU wall at <br />the rear of the property. In 2015, a tree fell and destroyed that pre-existing <br />covered structure. <br />6.A. - Page 20 of 64 <br />22