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wall are in good condition, the CMU wall can remain.” Respondents <br />commissioned a stamped engineering report from Hogan Land <br />Services at a cost of $6,141.25. The report concluded both that the <br />wall was in good condition and that demolition of the wall would <br />damage the City’s own adjacent concrete-lined drainage channel. <br />Respondents specifically asked the City for a written assumption of <br />liability for any creek damage caused by City-ordered demolition. The <br />City did not provide one. The agreement was repudiated by <br />Christian Craig on April 23, 2024 (Exhibit EE), who rejected the <br />stamped report and demanded additional unspecified analysis. Audio <br />recording and full 877-line transcript of the January 30, 2024 meeting <br />exist and are in the record (Exhibit JJ). <br />Jeff Schwob, Community Development Director. On July 22, 2024, <br />Mr. Schwob wrote: “I confirmed with our Building Official that a <br />building permit would not be required for the new fence installation <br />atop a shortened (<3-foot high) CMU base if the new wall/fence <br />combination remains under 7 feet in height.” On October 25, 2024, <br />Schwob reconfirmed: “I believe this is the agreement we reached.” <br />The agreement was repudiated. First internally: Christian Craig, <br />Assistant Engineer, admitted in writing on May 1, 2025 that he had <br />walked the Schwob agreement back internally earlier in the year — “I <br />reaffirmed this [contrary position] with Jeff in January when the <br />resubmission was received” — and that he was “following the <br />instruction of my supervisors and the public works department.” Then <br />publicly to Respondents: on June 6, 2025, Mr. Schwob personally <br />telephoned Respondent Stephen Burns and stated that the agreement <br />was “off,” that the City had a “new City Engineer,” and that “the <br />agreement we came to no longer stands.” Tanisha Werner had just <br />been appointed Engineering and Transportation Director / City <br />Engineer in early June 2025, days before Mr. Schwob’s call. James <br />O’Connell, who had been Acting City Engineer through August 2025, <br />was subsequently let go; his City email began returning a “no longer <br />with the City” auto-reply on September 29, 2025. <br />6.A. - Page 24 of 64 <br />26