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8.A <br /> ._ ..... . ._ : �l:��.�;". �; , �: Page 64 <br /> support." (11/12/10 email from Mr. Warsowe to Ms Thompson and members of the City <br /> Council). In denying Appellants a continuance, Mr. Ingram, City Manager, and Ms. <br /> Thompson, City Attorney, were fully aware of the disadvantages they were arbitrarily <br /> imposing on Mr. Warsowe, because they were informed in detail of the impediments <br /> facing him in preparing properly for the Hearing in several emails starting on October 14, <br /> 2010, with the latest one sent and on November 11, 201010 at 1:SSpm. (The time is <br /> significant in that the City took only 17 minutes to deliberate and convey their denial of <br /> Appellants' request, their decision having been sent by Ms. Thompson at 2:12pm that <br /> day. ) <br /> Appellants will be submitting in this Offer of Proof the facts and conclusions supporting <br /> the various elements of our Appeal that we believe we would have demonstrated in our <br /> submissions and in person at the hearing, had we been afforded a fair chance to do so. <br /> The legal basis for this challenge is that the City failed to follow its own architectural <br /> guidelines set forth in Article 45, Section 45.8, Architectural Standards, Standards B., C., <br /> and E., and other provisions of the Redwood City Zoning Code and other ordinances, <br /> rules, regulations, and practices Appellants believe would support Appellants' Appeal <br /> ("Guidelines"), and, where applicable, also failed to follow various State and Federal law <br /> and regulations, as well. <br /> Offer of Proof with Res�ect to Standard E and the Italian Stone Pine ("Tree") <br /> 1. Several different arborists have informally informed Mr. Warsowe that there are a <br /> nuinber of options available to save the Tree from needless destruction, even given the <br /> currently approved plans. Appellants would have been able to demonstrate: <br /> a. That the two co-dominant trunks of the Tree could have been wired together <br /> to provide adequate structural support; and/or <br /> b. The co-dominant trunk over Appellants' property could have been trimmed to <br /> reduce the weight of that trunk; or <br />