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two months earlier. The report’s conclusions are unambiguous and adverse <br />to the City’s demolition position. <br />Significance. The Hogan Report is the dispositive technical record. Two <br />findings cannot be ignored: (1) the wall is in excellent condition <br />(satisfying the O’Connell/Craig test for the wall to remain); and (2) <br />demolishing the wall would damage the City’s own concrete-lined <br />drainage channel. Demolishing the wall is what the City has been pressing <br />for since 2018. The Report establishes that compliance with that demand <br />would create the very harm the City exists to prevent. Respondents asked <br />the City in writing for a written assumption of liability before any City- <br />ordered demolition; the City did not respond. A licensed, stamped <br />engineer’s opinion on infrastructure-adjacent risk should not be <br />unilaterally rejected by an Assistant Engineer without articulating a basis. <br />Findings on the wall and creek channel: - No physical damage to the <br />channel. - The CMU wall is in excellent condition. - The wall is <br />structurally stronger with the eave roof attached than without. - <br />Demolition of the wall would damage the City’s concrete-lined drainage <br />channel. <br />Exhibit F — Hogan Retracement Survey <br />December 6, 2023, Thomas Reeder, P.L.S. #9565 (stamped and <br />signed); Monica Wingett, assisting <br />Issue. The seven-year dispute between Respondents and the City has been <br />driven in significant part by a contested factual question: where do <br />Respondents’ property lines run, and where exactly is the recorded storm <br />drainage easement located on the parcel? The City’s position has shifted <br />across iterations. Respondents commissioned a stamped retracement <br />survey from Hogan Land Services to establish the boundaries definitively. <br />6.A. - Page 47 of 64 <br />49