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8.A <br /> Page 119 <br /> Appeal of Issuance of Architectural Pernut Page 11 of 13 <br /> 448 Saint Francis St. <br /> Project No. AP-2010-9 <br /> California and the United States by unreasonably authorizing the construction of a rear <br /> deck that invades the privacy of the Appellants. <br /> Offer of Proof with Respect to Equal Protection and Due Process Rights of Appellants <br /> 1. Appellants would have identified one or more architects, urban planners, legal <br /> authorities, and/or neighbors who would have testified orally or in writing that the City's <br /> treatment of neighbor/neighborhood inputs and concerns with respect to the Stanford In <br /> Redwood City Project ("Project") and Appellants' situation is starkly unequal and in <br /> violation of Appellants' due process rights. <br /> a. Appellants would have cited specific statements inade by the City presenters <br /> and by the City Council in transcripts from the November 8, 2010 City Council <br /> Meeting to demonstrate that the Planning Deparkment and the City Council accord <br /> far more importance to the inputs and concerns of neighbors in the Project area <br /> than they do to the inputs and concems of neighbors on St. Francis Street. <br /> b. Appellants would have demonstrated that the Planning Depurtment was fully <br /> aware that four of the five neighbors adjoining or across from Applicants' <br /> proposed house strenuously objected during the review process at meetings, in <br /> phone calls, in writing, and in person to the Applicants' proposed treatment of the <br /> Tree, the Roof, and the Deck. <br /> c. Appellants would have further demonstrated that the Planning Department, <br /> fi•om its senior management to the planner and zoning administrator responsible <br /> for reviewing Applicants' proposal, ignored these inputs and conceins, and, in <br /> practical fact, "rubber-stamped" Applicants' proposals. <br /> i. Appellants will acknowledge that Jill Ekas, Planning Department Head, will <br /> maintain that the Planning Departrnent did not "rubber stamp" Applicants' <br /> applicarion, but required numerous changes in Applicants' plans; however, <br /> Appellants will show that the Planning Department did, in fact, accept <br /> Applicants' proposals as proposed with respect to the three architectural <br />