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City and County of San Francisco Board of Appeals . London Breed Julie Rosenberg ‘Mayor Executive Director i w October 15, 2019 Joseph Duffy, Senior Building Inspector Department of Building Inspection 1660 Mission Street, 3rd Floor San Francisco, CA 94103 Appeal No.: 19-116 Appeal Title: Six Dogs LLC vs. DBI Subject Property: 3426-3432 22nd Street Determination or Permit Type: Building Permits Determination or Permit Nos.: 2018/07/12/4400, 2018/07/23/5200, 2018/08/01/6151, 2018/11/21/6573, 2018/11/21/6577, 2018/11/21/6578, 2018/11/21/6579, 2018/11/21/6580, 2018/12/24/9088 Dear Joseph Duffy: This is to notify you that an appeal has been filed with this office protesting the REVOCATION of the above-referenced permits. Pursuant to Article |, §8 of the San Francisco Business & Tax Regulations Code, the permits will remain SUSPENDED until the Board of Appeals decides this matter and releases a notice of decision and order. ‘We are enclosing a copy of the Preliminary Statement of Appeal for your information The hearing regarding this matter has been scheduled for November 13, 2019, at 5:00 p.m., City Hall, Room 416, One Dr. Carlton B. Goodlett Place. Ifyou have any further questions, you may call this office at (415) 575-6880. Sincerely, BOARD STAFF ce: Six Dogs LLC, Appellant(s) clo Scott Emblidge, Attorney for Appellant(s) Moscone Emblidge & Otis LLP 220 Montgomery Street #2100 ‘San Francisco, CA 94104 1650 Mission Street, Suite 308 » San Francisco, CA 94103 Phone: 418-575-6880 « Fax: 415.575.6805 - Emall: boardofappeals@sfaov.or wunw sfgov orgiboa BOARD OF APPEALS Se Date Filed: OCT 15 2019 CITY & COUNTY OF SAN FRANCISCO appear ¢ [4-1] BOARD OF APPEALS ERELIMINARY, STATEMENT OF APPEAL jogs jereby appeal the following departmental action: Termit No: porioritaieaso, 2048/07123/5200, 2018/08/04/6184, 2018/11/2116573, 2018/11/2116877, 2018/1 1/21/6578, 2018/1 1/21/6579, 2018/11/21/6580, 2018/12/24/9088 by the Department of Building Inspection which was issued or became effective on: September 30, 2019, to: Six Dogs LLC , for the property located at: 3426-3432 22 nd Street, BRIEFING SCHEDUL The Appellant may, but is not required to, submit a one page (double-spaced) supplementary statement with this Preliminary Statement of Appeal. No exhibits or other submissions are allowed at this time, Appellant's Brief is due on or before: October 24, 2019, (no later than three Thursdays prior to the hearing date), up to 12 pages in length, double-spaced, with unlimited exhibits, with eleven (11) copies delivered to the Board office by 4:30 p.m., and with additional copies delivered to the other parties\the same day. In addition, an electronic copy should be emailed to: boardofappeals@sfaov ora if possible. ‘ Vv Respondent's and Other Parties’ Briefs are due on or before: November 7, 2019, (no later than one Thursday prior to hearing date), up to 12 pages in length, doubled-spaced, with unlimited exhibits, with eleven (11) copies delivered to the Board office by 4:30 p.m., and with additional copies delivered to the other parties the same day. In addition, an electronic copy should be emailed to: if possible. Only photographs and drawings may be submitted by the parties at the hearing. Hearing Date: Wednesday, November 13, 2019, 5:00 p.m., City Hall, Room 416, One Dr. Carlton B. Goodlett Place. All parties to this appeal must adhere to the briefing schedule above, however if the hearing date is changed, the briefing schedule MAY also be changed. Written notice will be provided of any change to the briefing schedule. In order to have their documents sent to the Board members prior to hearing, members of the public should submit eleven (11) copies of all documents of support/opposition no later than one Thursday prior to hearing date by 4:30 p.m. Please note that names and contact information included in submittals from members of the public will become part of the public record. Submittals from members of the public may be made anonymously. Please note that in addition to the parties briefs, any materials that the Board receives relevant to this appeal, including letters of support/opposition from members of the public, are distributed to Board members prior to hearing All such materials are available for inspection at the Board's office. You may also request a copy of the packet of materials that are provided to Board members at a cost of 10 cents per page, per S.F. Admin. Code Ch, 67.28. If you have any questions please call the Board of Appeals at 415-575-6880 The reasons for this appeal are as follows: see altached Signature: Print Name: SUMMARY OF REASON‘ AND WHAT ACTION IS BEL OR GROUNDS FOR APPEAL REQUESTED OF THE BOARD Six Dogs LLC appeals the revocations of each of the following permits relating to 3426-3432 22nd Street (Block/Lot: 3618/015) as stated in the, September 30, 2019 letter from Mauricio Hemandez, Chief Building Inspector: 20180712400, 201007235200, 201808016151, 201811216573, 201811216577, 201811216578, 201811216579, 201811216580 and 201812249088. Among other reasons, these appeals are based on the fact that no lawful Justification exists for revocation of any of these permits, DBI has never used the remedy of permit revocation for minor violations like those alleged in this case, and the actions of Mr. Hernandez and others at DBI were and are motivated by their desire to retaliate against members of Six Dogs LLC who have spoken out against perceived corruption and unlawful favoritism by employees of the Department of Building Inspection. Six Dogs LLC requests that the Board of Appeals direct DBI to (1) rescind the revocations of each of these permits, (2) reinstate each of these permits and rescind all stop work orders so that this project can be completed, and (3) rescind any penalties, reassessments or fines arising out of the revocation letter or associated Notices of Violations. BOARD OF APPEALS OCT 15 2019 aprca ¢_(Ac IL City and County of San Francisco Department of Building Inspection September 30th, 2019 Six Dogs Luc 340 Lorton Ave STE 202 Burlingame CA To whom it may concern, London Breed, Mayor Tom C. Hui, $.E., C.B.0., Director BOARD OF APPEALS OCT 15 2019 Appeal #_A-Il(p Building Permit Application No 201807124400, 70807238200,20 1808016151,201811216573, 201811216877 2018 §1216578,201811216579.201811216580,201812240068, Block / Lot: 3618/015 REVOCATION OF PERMIT Property Address: 3426-3432 22" 5 4 Cugeuant to Section 106A 4.5 ofthe San Francisco Building Code, he Director of Building Inspection may information sefene, 4 Dulling permit whenever the permit has been iseued iors basis of incorrect information supplied or m violation of any ordinance or regulation oy ees Provision of the Building Cocie Nine total permits were issued to remodel the four unit Puilding, repaic fear stairs, front facade and soft story plans far ets towever. a site vist has revealed that work exceeded the: Scope of tie approved permits and Plans for the above reference work contain inaccurate informatie tite is documented in Notice of Violation Aumber 201987211 (attached). 3559881, Building Permit Application No's 20180712400, 201807235200,201808016151,201811216873 201811216573, 201811216577, 201811216578, 201611216579, 2018112165808 201812240088 are here by Revoked. Froud You have any further questions regarding this matter, contact Building inspector Mauricio Hemandez at (415) 875-8831 of at Mauricio Very truly yours, Tom C. Hui S.E.,C.8.0 Director é afsellq frauricio Hemandez Chief Building Inspector ec: Tom C. Hui S.E., €.8.0., Director Edward Sweeney, Oeputy Director Wiliam Walsh BID File Attachment P\ Revocation of Permitzore 2426.3432 22% st Building inspection Di 4660 Mission Street~ San Francis ision 0 CA 94103 Office (418) 558.6570 - FAX (416) 558-6261 - www City & County of San Francisco BOARD OF APPEALS CONTACT INFORMATION FOR PARTIES Appeal No(s): 1D OF APPEALS APPELLANT(S) OCT 15 2019 ' y Name: Sak Deas LLC appeal #_[ Phone Number: Fax Number: Email Address: Mailing Address: 390 / 47 ton Ave Burlingame CA Street City ‘State Zip Names of Other Appellants: Agent for Appellant Name: “Dechecal Holl Phone Number: 1 5 364-4 3> y Fax Number: Email Address: _4. hersh@ ee na. cow Malling Address: 220 WNontaodmen, shSvite zlgo SF CA 74104 ‘Street ity State Zip od Scott Em bli dae, Mos coue Cob [rel ge8 Ot 226 Montgomery st, Suite 2108 SECH guyict OTHER PARTY (PERMIT HOLDER, VARIANCE HOLDER, ETC.) © bldg © @ mosco ne: lw, ; ow Name Phone Number: Fax Number: Email Address: Mailing Address: Street City State Zip Names of Other Parties: Agent for Other Party Name: Z Phone Number: Fax Number: Email Address: _[Os-eph , du Ast-gov.dd Mailing Address: Keled Missi S1- Grd EL. SE, CA ‘Street City State Zip AN/03 41850 Mission Street, Suite 304 Phone: 415-875-6880 « Fax: 415-575-688 Francisco, CA 94103, al