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8.A <br /> Page 53 <br /> work, are available and able to prepare for this Appeal Hearing. Collectively, these individuals have <br /> worked with relevant subject matter, I am sure, for at least 40 - 50 years. In stark contrast, I do not have <br /> any such expertise or experience, nor the time or resources to engage those who do on such a <br /> compressed timetable. As I explained last evening: <br /> o I do not have any knowledge or experience in matters relating to construction or architecture, and ' <br /> must literally start from the beginning to enable myself to provide a well-reasoned basis for our <br /> Appeal Hearing. Perhaps even inore significantly, my Roldex is bereft of any contacts in these <br /> fields, so I have been and continue to be on rny own re finding the experts who can assist us -- <br /> and whose schedules permit them to assist us within the currently allotted time frame. I can <br /> assure the Council that I started reaching out to identify and contact people I thought inight be <br /> able to assist us in preparing for this Appeal Hearing (e.g., architects, urban planners, arborists <br /> who have demonstrated a concern for our issues) the very day Ms. Vonderlinden informed me of <br /> the Hearing date. I have had some success locating and getting in touch with such individuals; <br /> but, candidly, we do not have any realistic prospect of them generaring materials useful to the <br /> Council to make a fair determination based on fact and on Redwood City's Guiding Principles <br /> (as so eloquently and repeatedly expressed by your own goodselves last evening with reference <br /> to the Stanford in Redwood City Project) in time for the cunrently scheduled November 22nd <br /> Hearing. <br /> o I am a self-employed, one-man consulting firm. I have no staff to assist me in my research and <br /> preparation. Moreover, when I am working on preparing for this Hearing, I am not able to work <br /> to provide an income to support my family. Being able to reduce the need to engage in intense <br /> research, and being permitted to spread my preparations over a longer period would enable me to <br /> more successfully keep all these balls in the air. <br /> o The Holiday Season is upon us, and I can report to you that at least one of the experts who is <br /> necessary for the proper preparation for our Appeal Hearing will be visiting her family the entire <br /> week of November 22nd, preceded and followed by pre-existing commitments through the <br /> truncated work weeks in November and December. She said she would only be ahle to start <br /> reviewing our case in early to mid January. Others have also made reference to their currently <br /> full schedules for the remainder of this month and for December. <br /> o While conducting this Hearing on November 22nd would clearly disadvantage us, there is no <br /> obvious disadvantage to Mr. Carroll if the matter is put over, since Paragraph 23 of his NOA <br /> clearly states "No site work such as grading and/or excavation shall take place during the winter <br /> months, unless prior approval is obtained froin the City." From what I know about the soil <br /> conditions on our adjoining hillside properties, it seems to me imprudent for the City to permit <br /> Mr. Carroll to start his project until the winter is over. In fact, in Paragraph 22 of the NOA, for <br /> example, the City expressly states concern about "stormwater detention" on the site. As it is, <br /> both of our adjoining backyards are prone to flooding and pooling; if construction were to start <br /> this winter, there would certainly be a much greater risk of erosion, soil slippage, and resultant <br /> damage to our property and to that of our neighbors. Since continuing the Hearing date to next <br /> year apparently will not slow down the construction project, I believe there is no reasonable basis <br /> for denying us a continuance. <br /> o Finally, with respect to equity and fair play, no one in the City administration was able to <br /> provide us with any fact in support of conducting the Hearing on November 22nd -- except for <br /> stating that Mr. Carroll "wished to have the Hearing immediately." Consequently, as Ms. <br /> Thompson said last evening, "We split the difference." (I requested 120 days when I f led my <br /> appeal, knowing full well the magnitude of the task ahead of ine.) If I may respectfully observe, <br /> King Solomon rejected the idea of "splitting the difference" because he knew that "solution" <br /> would kill the infant! In our case, "splitting the difference" will almost certain kill any realistic <br /> opportunity we have to prepare adequately for the Hearing. Moreover, Solomon actually did a <br /> factual inquiry regarding the claims and circumstances of the two mothers before rendering his <br /> decision -- something that seems to have been regrettably absent in our case. <br /> z <br />