On 09/16/2025, in the City’s own voices on the property’s own audio, the Principal Building Inspector told the owner’s contractor the City did not want a permit pulled on the rear workshop — with the inspector of record present and jointly measuring the structure at the permit-exempt threshold — while the same-day walkthrough set a 30-day permit deadline and the City never named the permit category in any served or amended Notice and Order.
A city can’t quietly change what it is demanding in an open enforcement case; if it wants to add a new requirement, it has to put it in an amended written order and serve it. SCC §8.100.720 SCC §8.96.130 HSC §17980(c)(1) Here, a city building inspector and his supervisor walked the property with the owner’s contractor and, on the property owner’s own recording, told them the city did not want a permit pulled on a small backyard workshop, that the city had already told them to go ahead and do the electrical work without one, and that the structure was small enough that the inspector said “I don’t care about it.” M036 On the same walk, the supervisor pointed at a roof beam and said it was going to fall and “hopefully he’s not under it,” but added that all the city does is point it out. The same walkthrough also set a 30-day deadline to “obtain the building permit” but named no permit category. M036 Weeks later, by phone, the city specified a “minimal permit” — and even then said “most issues are no longer there.” The original 2023 order it is enforcing M124 M125 never named a permit category and was never amended to add one. R.25-3549 R.26-1965
Bottom line: on the property the city said in its own voices it did not want a permit pulled and had already allowed work to start; only later, by phone, did it specify a permit it had never named in any served or amended order — the document that should carry the enforceable scope.On 09/16/2025, Principal Building Inspector Bo Cosley and inspector of record Paul Lovato walked 4880 T Street with the owner’s licensed contractor Arthur Popov and the property representative. M036 On the property’s own audio that morning, Cosley told the contractor that pulling a permit on the rear workshop is something the City does not want (“Or, get a permit. We don’t want that”), that the City had already let prior work proceed (“I said go ahead and start the work and do it”), that stripped of its electrical and plumbing the structure “is probably gonna be 120, so I don’t care about it,” and that a roof member “is going to fall… [h]opefully he’s not under it… [a]ll we can do is point it out.” The same walkthrough set a 30-day deadline to “obtain the building permit” but named no permit category. M036
The served 04/12/2023 Notice and Order named no permit category — only the generic B59 “Permits Required” code on the Correction List. M124 M125 The representative’s three written demands for specifics drew no permit category in writing. Card 7 For thirty months, administrative penalty orders citing the SCC §1.28.010 SCC §1.28.010 catch-all accrued. M025–M034 Then the City’s own voices on tape contradicted themselves in four distinct ways — and the off-record phone specification that followed never produced an amended order to carry the new position onto the served record. SCC §8.100.720 SCC §8.96.130 HSC §17980(c)(1)
The served Notice and Order and Correction List cited only the B59 “Permits Required” code under SCC §8.100.190; the representative’s three written demands for specifics drew no permit category in writing. Card 7 Lovato’s 04/11/2023 internal log named “failure to obtain an HDB permit” M024 — a characterization never carried to the served record. Across the following thirty months, administrative penalty orders cited the SCC §1.28.010 D3(c2ii) catch-all rather than entering a permit-required finding for any specific work item. M025–M034 Card 12
With the licensed contractor and property representative present, on the property’s own recording, the City’s own officers stated:
The four statements above do not appear anywhere in Lovato’s 09/16/2025 case note, which records only the walkthrough, a correction notice given to the contractor, and the 30-day permit window. M036
In October 2025, attorney Saakian relayed the City’s position after a phone call: “[o]nce the violations are reported, a permit is needed… I understand that most issues are no longer there… coordinate the minimal permit” (10/16/2025). Seven days later Lovato added a pre-installation inspection requirement and a siding-style condition through the same channel, M036 neither of which appears in any served order. The scope language that eventually reached the City’s permit list classified the work as a routine “Residential Housing-Minor / Plans not required” permit. Card 31 Card 32
From 04/12/2023 to the present the City issued, served, and posted nothing that amended the order to state the permit-triggering condition it began asserting on 10/16/2025. The amended-or-supplemental-notice requirement under SCC §8.100.720 and SCC §8.96.130 was never met. The later permit track lives outside the procedural envelope of the order it is being enforced under. R.25-3549 R.26-1549
Thirty months of formal silence on any permit requirement, M124 M125 M025–M034 during which administrative penalty orders accrued. Card 12 Card 13 Then, on the property and in the City’s own voices, the Principal Building Inspector said the City did not want a permit pulled, both inspectors jointly put the structure right at the 120-sq-ft permit-exempt threshold, said the City had already let the electrical work proceed without one, and said the structure was going to fall while disclaiming City responsibility for it. M036 Weeks later, by phone through the owner’s attorney, the City specified a “minimal permit” the same-day order had never named in any category — and never issued an amended order to carry the new position onto the served record. R.25-3549 R.26-1965
Generic catch-all language is exactly what the Housing Code specificity requirement and HSC §17980(c)(1) are written to prevent. SCC §8.100.720 HSC §17980(c)(1) The City’s own conduct for thirty months treated the order as not identifying a specific permit-triggering item: no inspection report, no penalty order, and no written communication entered a permit-required finding for any specific item between 04/12/2023 and 10/15/2025. The on-tape statements and the off-record specification are the City’s own. On that record, the served order stated neither the danger the inspectors described on tape nor any permit category, even after the City began naming a “minimal permit” by phone. Card 3 Card 28 Card 31 Card 32 Card 47