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Issue. Thirteen days after Hogan delivered the stamped engineering report <br />Mr. Craig himself had specified in writing on February 5, 2024, Mr. Craig <br />rejected the report and demanded what was already in it. <br />Significance. This is the moment the O’Connell agreement was repudiated <br />by the same Engineering staff member who had reduced it to writing. <br />Mr. Craig’s stated objections — “an analysis of the physical condition” <br />and “make sure the document is stamped” — were already addressed on <br />the face of the Hogan report Mr. Craig had in his possession. The rejection <br />set no defined standard for what additional analysis would suffice. This is <br />the textbook signature of a moving-target compliance demand: the <br />standard is whatever the City says it is at the moment the homeowner <br />satisfies the last one. Respondents had no path forward because the City <br />would not specify the path. <br />“We will need an analysis of the physical condition and it must <br />explain how the determination was made. Please make sure the <br />document is stamped also.” <br />(Hogan’s April 10, 2024 report was already stamped by Renfro and <br />analyzed physical condition. Craig did not articulate what additional <br />analysis was required.) <br />Exhibit M — Jeff Schwob (Community Development <br />Director) to Stephen Burns and James Renfro <br />July 22, 2024 <br />Issue. After a year of escalation around the rear CMU wall, the <br />Community Development Director (the senior official over both Building <br />and Planning Divisions) personally issued a written agreement: shorten the <br />CMU wall to under 3 feet, top with a fence under 7 feet total, no separate <br />building permit required for the fence. The agreement was reached after <br />6.A. - Page 49 of 64 <br />51