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The City refused to extend the permits when asked. The City then issued a <br />citation for the consequence of its refusal. The City wrote that issued <br />permits would resolve enforcement. The remedy is to reinstate what the <br />City refused to extend, not to fine Respondents for the City’s own <br />decision. <br />Beyond the $10,650.67 in permit and plan-check fees paid in January <br />2023, Respondents have spent over $6,000 on engineering, plus thousands <br />more on plan revisions, surveys, and structural reports. They have retained <br />four attorneys over seven years (Lim 2019; Bronitsky 2020; Dolinger <br />2023, since deceased; Norm Matteoni 2026). They have done what the <br />City asked, again and again. The City has been the obstacle. <br />6. Response to the May 4 Staff Report <br />The City’s staff report for this hearing, prepared by Code Enforcement <br />Officer Amaranta Sandoval and approved by Community Development <br />Director Jeff Schwob and City Manager Patrick Heisinger, advances three <br />propositions: (1) RWC § 9.40 and CBC § 105.1 require a permit before <br />construction; (2) Permit ADU22-0064 expired on October 22, 2025 “due <br />to inactivity”; and (3) the unpermitted garage addition therefore remains. <br />Three responses follow. <br />A. The “inactivity” claim is contradicted by the City’s own writing. <br />On September 19, 2025, Respondents formally invoked California <br />Building Code § 105.5 in writing (Exhibit VV). On September 23, 2025, <br />Permit Technician Heather Spooner replied to Respondents in writing: <br />“your permits are still active and you have until 10/22/2025 to resubmit <br />the corrections” (Exhibit BB). On September 29, 2025, Respondents <br />made a second written request, this time to Code Enforcement, for <br />abeyance and extension under § 105.5 (Exhibit WW). On October 20, <br />2025, Respondents filed a formal appeal to the entire City Council group, <br />the Mayor, the City Attorney’s office, and the City Clerk. Each of these <br />communications preceded the October 22, 2025 date the staff report <br />identifies as the expiration. The “inactivity” framing is incompatible with <br />the City’s own contemporaneous record: Respondents were continuously <br />6.A. - Page 28 of 64 <br />30