No Written Standard for Non-Owner Contacts
The City answered the owner's representative for two and a half years and then told him it deals only with the owner or the owner's representative. On 04/04/2023 the inspector logged his first email — "Jackie is CC'd on this email" [M024] — and "replied back" [M024] the same day; that month he answered him five more times (Card 6 and Card 9: the requests for the basis, and the pictures never sent). On 08/21/2025, after the person at the door "wanted to cancel the inspection" [M035], the inspector logged: "About 30 minutes later I received a call from the property owners rep (Karin) who stated we could go ahead and enter the property and perform the inspection" [M035], and went back in on that call. On 09/02/2025 the representative emailed the Principal Building Inspector, who forwarded it at 2:29 PM asking "Paul, who is this person? How is he involved?" [E3]; fourteen minutes later the inspector replied: "The City of Sacramento deals directly with the owner of the property, or the owners representative. The last few times we met onsite, the owners representative is also attached to the email. Any concerns you have with the property, please reach out to the owner of the property." [E3] On 09/11/2025 he logged that email as one "from property owners handyman" [M036]. Fourteen days after the reply, on 09/16/2025, the City "met with a contractor and a representative of the property owner" [M036], recorded that "the handyman had taken care of some of the violations" [M036] — the word the 08/21/2025 entry uses for the person working in the backyard, not for the representative: "wanted repairs to be made by a contractor and not the handyman" [M035] — and gave the representative of the owner "30 days to obtain the building permit" [M036].
The email the City answered had offered the thing its rule names: "I will bring you a signed letter from Jackie authorizing you to communicate with me directly regarding this case" [E3]. The reply does not answer that offer. The file the City produced under Request 26-1965 (closed as complete [R.26-1965.1]) holds no later reply to it, no authorization from the owner for the 08/21/2025 caller or for anyone else, no completed Form CDD-0204 — the City's own Agent-for-Owner Authorization — and no entry saying how the City confirmed that the caller spoke for the owner (Card 27: the compliance question in that same email, never answered; Card 30: the records behind the representative's contacts that the file does not hold; Card 28 and Card 29: the 09/02/2025 thread).
On what record did the City confirm that the 08/21/2025 caller [M035] spoke for the owner, and on what record did it decide that the person who had written for the owner since April 2023, with the owner copied [M024], did not [E3] — when the file the City produced under Request 26-1965 in May 2026 [R.26-1965.1] holds no authorization from the owner for either?
IN PLAIN TERMS
The City answered the owner's representative from his first email in April 2023 [M024], which copied the owner. In August 2025 an inspector took a call from "the property owners rep (Karin)" [M035] and acted on it. In September 2025 he told the representative the City deals with the owner or the owner's representative [E3] and that the representative was already on the email; he logged him as the "property owners handyman" [M036]. The offer of a signed letter from the owner went unanswered. Two weeks later the City gave "a representative of the property owner" [M036] thirty days. The file it produced in May 2026 holds no owner authorization for anyone. The question for the City: on what record did you confirm the August caller spoke for the owner, and on what record did you decide the man who wrote for her since 2023 did not?
RECORD CHAIN
- April 4, 2023 — the City answers the representative at first contact, owner copied. The 04/04/2023 case entry records "Good morning, My name is Chris Foley and Jacqueline Baritell has informed me you had stopped by [M024]," and "Jackie is CC'd on this email" [M024]; the inspector "replied back" [M024] to him the same day.
- August 21, 2025 — a phone call and a first name stand in for the owner's word. The inspector's 08/21/2025 entry records that the person at the door "wanted to cancel the inspection" [M035], that he told her the City "would move forward with an inspection warrant" [M035], and then: "About 30 minutes later I received a call from the property owners rep (Karin) who stated we could go ahead and enter the property and perform the inspection [M035]." The entry records a call and a first name. It does not record who the caller was to the owner, how the inspector knew it, or any authorization; the same entry uses "the care taker for the owner" [M035] and "the handyman" [M035] for the person working in the backyard. The file the City produced under Request 26-1965 holds no owner authorization for the caller.
- September 2, 2025 — the forward asks who he is; the rule follows fourteen minutes later. The representative emailed the Principal Building Inspector at 10:40 AM, writing that the official had "just came by and delivered the new Notice and Order packet" [E3] and offering, "I will bring you a signed letter from Jackie authorizing you to communicate with me directly regarding this case" [E3]; at 2:29 PM the Principal Building Inspector forwarded it to the inspector and a second City official asking "Paul, who is this person? How is he involved?" [E3]; at 2:43 PM the inspector replied to all of them and to two non-City addresses: "The City of Sacramento deals directly with the owner of the property, or the owners representative. The last few times we met onsite, the owners representative is also attached to the email." [E3] The reply names no one and answers neither the offer nor the question "If Jackie’s consent must come first, please just confirm that and we’ll bring it immediately" [E3] (Jackie is the property owner). The same thread is carried in Card 28, Card 29, and Card 27.
- September 11, 2025 — logged nine days later as "property owners handyman". The inspector's 09/11/2025 case entry recorded the 09/02/2025 email as one "from property owners handyman [M036]," copied its text, and copied his own reply: "I replied back to the email stating: Chris, Thank you for reaching out to the city of Sacramento with your concerns of the property at 4880 T street." [M036] The entry adds nothing to the 09/02/2025 reply — no name for the representative it says was "attached to the email" [M036], no request for the offered letter.
- September 16, 2025 — fourteen days after the reply, a representative of the owner is given thirty days, without a form. The inspector "met with a contractor and a representative of the property owner [M036]," gave the contractor "a correction notice, that included pictures [M036]," handed him "my business card [M036]," recorded that "the handyman had taken care of some of the violations" [M036] — the 08/21/2025 word for the person working in the backyard, not the 09/11/2025 label for the representative — and wrote, "I let the representative of the owner know I would give them 30 days to obtain the building permit [M036]." The entry names no one and records no authorization asked of anyone.
- May 22, 2026 — the file produced under Request 26-1965: no authorization for anyone, no entry of how the caller was confirmed. No entry, email, or notice in the file the City produced under Request 26-1965 and closed as complete [R.26-1965.1] shows any staff member asking the representative, the 08/21/2025 caller, the owner, or the contractor for an authorization, holding an owner-signed Form CDD-0204, Agent-for-Owner Authorization for any of them, or recording how the 08/21/2025 caller was confirmed as the owner's representative. This is a negative search across the May case file, checked against the City's own form; search terms are listed in the citations below.
FULL CIRCLE
The City's first available answer is that the owner's representative was the person the owner herself put forward: on 08/21/2025 the inspector logged "a call from the property owners rep (Karin)" [M035] and acted on it, and the 09/02/2025 reply went to that representative too — "the owners representative is also attached to the email" [E3].
The 08/21/2025 entry records a phone call and a first name; it does not record who confirmed that the caller spoke for the owner, or how, and the reply says "attached to the email" without a name. The same file shows the owner copied on the representative's first email in April 2023 [M024] and the City answering him from that day. The email the reply answered offered "a signed letter from Jackie authorizing you to communicate with me directly" [E3]; the reply skipped it. The City's own Agent-for-Owner Authorization form is the instrument it prints for recording that a non-owner acts for the owner; the file the City produced under Request 26-1965 holds none for the caller, the representative, or anyone.
The City's second available answer is that no ordinance or form requires a written designation for code-enforcement correspondence, and that CDD-0204 is a permit-application form.
Then the thirty-day permit window of 09/16/2025 [M036] — a permit matter — was given to a non-owner without it; and if no writing is required, the City applied its rule to one non-owner and not to another on no page that says why.
What would defeat this card is a page in the file the City produced under Request 26-1965 that records how the 08/21/2025 caller was confirmed as the owner's representative, or an owner's authorization for anyone — a completed Form CDD-0204, a signed letter, or a staff entry recording the decision. The file, closed with "All responsive records have been provided." [R.26-1965.1], holds none. Card 4 is the completeness baseline (what the file the City produced means, and does not mean).
APPLICABLE LAW
The City's stated rule and the City's own printed form are what the record here is measured against: the produced file shows no written standard, form requirement, policy entry, or documented threshold determining which non-owner contacts the City would recognize, redirect, or relabel.
- CITY.CDD0204.AgentAuthorization: City of Sacramento Form CDD-0204, Agent-for-Owner Authorization — a permit-specific form used when a non-owner executes a permit application or owner-builder permit paperwork, and the City's printed instrument for recording non-owner authority on a permit. The Case File the City closed as complete contains no completed version of that form for any contact in this case, and no produced staff directive extending it to ordinary code-enforcement communications. The production-completeness implication is handled through the related anchor cards Card 4 Card 46.
SOURCE CITATIONS USED BY THIS CARD
- M024 — May production p.24; 04/04/2023 case entries quoting the representative's first contact ("Jackie is CC'd on this email") and Paul Lovato's same-day reply.
- M035 — May production p.35; 08/21/2025 Paul Lovato entry: the care taker cancels, "a call from the property owners rep (Karin)", the backyard inspection, "the care taker for the owner" and "the handyman".
- M036 — May production p.36; 09/11/2025 "property owners handyman" entry logging the 09/02/2025 email and reply; 09/16/2025 contractor/representative meeting and 30-day permit window.
- E3 — CPRA 25-4711 produced email thread of 09/02/2025: the representative's 10:40 AM email to Bo Cosley, Cosley's 2:29 PM forward to Paul Lovato and Douglas Pierson asking "Paul, who is this person? How is he involved?", and Paul Lovato's 2:43 PM reply. Public provenance: https://cityofsacramentoca.nextrequest.com/requests/25-4711.
- R.25-4711 — NextRequest 25-4711 provenance for E3
- R.26-1965 — NextRequest portal record for the May 2026 case-file production; the full May Case File negative search for an owner-signed authorization form, a staff request that one be submitted, or an entry recording how the 08/21/2025 caller was confirmed. Search terms: "authorization," "authorized," "agent," "owner authorization," "representative," "rep," "handyman," "care taker," "consent," "CDD-0204"; none located.
- R.26-1965.1 — portal and notification capture for Request 26-1965; the City's closure reason, verbatim: "All responsive records have been provided."
- CITY.CDD0204.AgentAuthorization — City of Sacramento Form CDD-0204, Agent-for-Owner Authorization; official URL https://www.cityofsacramento.gov/content/dam/portal/cdd/Building/Forms/CDD-0204_Agent-for-Owner-Authorization-Form.pdf
CARD REFERENCES
- Card 6 — The Unsupported Internal Issuance Reasons: the April 2023 exchange the City logged and answered.
- Card 9 — The Missing Photograph Disclosure: the April 2023 replies that never sent the pictures.
- Card 27 — The Unanswered Void-and-Fee Question: the compliance question in the 09/02/2025 email.
- Card 28 — the same 09/02/2025 email thread.
- Card 29 — the same thread and the representative-role framing.
- Card 30 — The Missing Representative Records: the records behind the representative's contacts that the file does not hold.
- Card 4 — Fourteen Written CPRA Completeness Determinations: the production-completeness baseline.