The Unserved Walkthrough Statements
On 09/16/2025, Principal Building Inspector Bo Cosley and Paul, the inspector of record, walked 4880 T Street with a contractor and the property representative M036. Property-side audio of that walkthrough, with an owner-verified transcript, records City officers stating a flexible permit sequence, a 120-square-foot workshop condition, and a falling-roof warning; none of those statements appears in any served amended or supplemental Notice and Order in the produced record V4 V4.T. In V4.2, a City speaker confirmed that a permit was still required, but explained that the City had let electrical work start "to some extent" because the hazard was already visible and a permit delay could leave something to burn. In V4.3, Paul discussed the workshop in 120-square-foot terms and said that, if electrical/plumbing were removed, "this is probably under 120, so I don't care about it." In the same sequence, and again in V4.4, Paul described a roof member supported by a small post/block as something that "is going to fall," then said "all we can do is point it out" and that the owners would otherwise be responsible.
The audio is not a concession that no permit was needed; the finding is the gap between the recorded statements and the served record that followed. The same walkthrough set a 30-day deadline to "obtain the building permit" but named no permit category M036. The later October "minimal permit" was relayed through attorney Mark Saakian after he spoke with City inspectors; the contractor then refused to file it and walked off E4 Card 36. Paul later repeated the 120-square-foot / utilities-removal workshop condition in the case notes M037.
The served 04/12/2023 Notice and Order carried only the generic B59 "Permits Required" code M124 M125, a gap developed at Card 6; after later records identified some permit-related work items M035 M544, no served post-walkthrough amended or supplemental order carried the October "minimal permit" scope, the workshop 120-square-foot/utilities condition, or Paul's roof-support statement onto the appealable record V4 V4.T E4 M037.
On the 09/16 audio, the City treated permit sequencing as flexible while an electrical hazard was visible, conditioned the workshop on utilities removal and the 120-square-foot line, and orally flagged a structural danger that does not appear in Paul's same-day note. The October "minimal permit" relay that followed the walkthrough was never entered into a served amended or supplemental order with appeal language attached. SCC.8.100.720, SCC.8.96.130, and HSC.17980.C.1 govern the notice content: HDB and Dangerous Building conditions are to be carried in an inspection-based notice and order that briefly describes the condition and required action, and SCC.8.96.130 expressly governs service/posting of any amended or supplemental notice and order if one is issued.
IN PLAIN TERMS
By September 2025 the City had identified some permit-related work items. The recorded walkthrough then shows City officials treating safety and permits three different ways. Electrical work could start before the permit because waiting might leave a burn hazard. The workshop mattered less if utilities were removed and it stayed around 120 square feet. An official described a roof support as going to fall and said the City could only point that out. The City later relayed a "minimal permit" demand through the owner's attorney, but the produced file does not show an updated served notice carrying that October scope onto the official record.
RECORD CHAIN
- Original-order generic posture, later partial permit entries. The served 04/12/2023 Notice and Order M124 and Correction List M125 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 6. Paul's 04/11/2023 internal case log named "failure to obtain an HDB permit" - a characterization never carried to that served order M024 Card 6. After the 08/21/2025 inspection, the record did identify some permit-related work items: the workshop was to be removed or approved by building-permit inspections M035, and the 09/02/2025 re-issued list stated B45 added square footage was "to be permitted" and P08 added gas line "requires permits" M544.
- 09/16/2025 - three supported safety/permitting statements on the property's own audio. With a contractor and the property representative present, City officers stated the following on the property's recording
V4V4.T:
- Electrical work allowed to start, but permit still required - V4.2 V4.T. A City speaker confirmed a permit was still required, explained that the City "let them do the electrical to some extent" because the hazard was already visible and a permit delay could leave something to burn, said "go ahead and start the work and do it," and stated that the work would still have to go on a permit before it became legal.
- The 120-square-foot / utilities discussion - V4.3 V4.T. Paul discussed the workshop in 120-square-foot terms: "could be very close to 120"; "the electrical and plumbing, if you got rid of it"; "this is probably under 120, so I don't care about it." A later case note repeated the workshop condition as: "Workshop area reduced down to 120 Sq Ft and detached from the garage or removed. All utilities removed from the workshop area" M037.
- The falling-roof statement - V4.3 V4.4 V4.T. Paul said "this is going to fall," "hopefully nobody's underneath it," and "all we can do is point it out"; the follow-on clip identified the support as "this piece of wood right here, holding up that roof" and repeated "I can tell you right now it's going to fall."
The same walkthrough also set a 30-day deadline to "obtain the building permit" but named no permit category M036. None of the three statements appears in Paul'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.
- October 2025 - attorney-routed minimal-permit relay, no later amended order. In October 2025, attorney Saakian relayed the City's position after speaking with City inspectors E4: "[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 Paul added a pre-installation inspection requirement and a siding-style condition through the same channel M036 E4 - neither of which appears in any later served order. The contractor refused to file the "minimal permit" and walked off Card 36. 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 35.
- No later amended or supplemental Notice and Order carrying the October permit scope. The City re-issued the Notice and Order on September 2, 2025 Card 26, but the produced record does not show a served post-walkthrough amendment or supplement stating the permit-triggering condition it began asserting on October 16, 2025. The property representative later identified the amended/supplemental notice problem in writing E6; SCC.8.96.130 expressly requires service and posting of any amended or supplemental Dangerous Buildings notice and order if one is issued, while SCC.8.100.720 and HSC.17980.C.1 tie the HDB/substandard-building process to an inspection-based notice and order describing the condition and required action.
The produced record shows the following on the points at issue:
- The served 04/12/2023 Notice and Order names no permit category - only the generic B59 "Permits Required" code on the Correction List M124 M125 Card 1.
- 09/16/2025 case note, Paul: "we met with a contractor and a representative of the property owner… [w]e had walked all the violations… I would give them 30 days to obtain the building permit" - with no mention of the three on-tape statements above M036.
- 09/16/2025, City officers on the property's audio - three verbatim clips
V4. - Pre-10/16 written records did identify some permit-related items after the 08/21 inspection: the workshop/building-permit-inspection note M035, B45 added square footage "to be permitted," and P08 added gas line "requires permits" M544.
- October 2025 permit specification arrived through the owner's attorney after he spoke with City inspectors: 10/16/2025 "minimal permit" / "most issues are no longer there" relay and 10/23/2025 Paul additions E4.
- No post-walkthrough amended or supplemental Notice and Order carrying the October permit scope, the workshop 120-square-foot/utilities condition, or Paul's roof-support safety statement appears in the produced file M036 M037 Card 26.
FULL CIRCLE
An amended, supplemental, or re-issued Notice and Order, served and posted under City Code procedure SCC.8.100.720 SCC.8.96.130, would be the formal place for the specific permit-triggering finding the City began asserting on 10/16/2025 E4. It would also be the formal place for a record tying the 08/21/2025 and 09/02/2025 written permit-related entries M035 M544 to the later October "minimal permit" scope. The original 04/12/2023 order stated only a generic B59 permit-required code M124 M125; later records identified some permit-related items after the 08/21 inspection M035 M544; then the 09/16 walkthrough audio recorded the three officer statements described above V4 V4.T. The May 2026 case-file production R.26-1965 was closed by the City as "All responsive records have been provided," but no post-walkthrough amended or supplemental order carrying the October permit scope appears in that production. The completeness baseline for the closed productions is set out in Card 4; Card 46 supplies the email-production comparator for the Saakian-relayed October demand E4.
If the 2023 "substandard and/or dangerous" recital rested on a specific safety determination, the later falling-roof, utilities-removal, and 120-square-foot statements did not reach the served record; if it was a generic enforcement label, the served order did not give the owner a concrete condition to correct or appeal M124. The recorded statements and the October specification came from City officers, and the produced file does not show a served amendment carrying either the roof-support danger Paul described or the "minimal permit" scope.
The City may argue: The order's general "all required permits" language covers any later-identified permit-triggering condition without a separate amended order; the 09/16/2025 statements were informal walkthrough comments, not adjudicative findings; and the 10/16/2025 demand applied language already in the served order rather than expanding scope.
On the first point, SCC.8.100.720 requires the notice to describe the conditions found to render the building substandard, and HSC.17980.C.1 ties correction to an inspection and notice determination. The record did contain some pre-10/16 permit-related entries after the 08/21 inspection M035 M544, but no post-walkthrough served amended or supplemental order carries the October "minimal permit" scope, the workshop 120-square-foot/utilities condition, or Paul's roof-support statement. On the informal-comments point, the 09/16/2025 statements were made by City officers, on the property during an official inspection, with a contractor present M036 V4. On the third point, the served record as produced does not contain the October scope.
The record shows a 09/16 walkthrough with three recorded City statements on safety and permitting, followed by an October "minimal permit" relay, and no served post-walkthrough amended or supplemental order carrying either. The defect is a notice-specificity and served-record gap, not a request to rewrite the original order after the fact.
APPLICABLE LAW
- SCC.8.100.720: Housing Code notice content requirement; subsection (A)(2) requires a brief and concise description of the conditions found to render the building substandard.
- SCC.8.96.130: Dangerous Buildings order procedure; subsection (B)(2) requires a brief and concise description of the conditions found to render the building dangerous.
- HSC.17980.C.1: Health and Safety Code section 17980(c)(1), tying substandard-building correction to an inspection and notice determination predicate.
- SCC.8.100.190: Sacramento City Code section 8.100.190, the "Permits Required" provision used for the B59 classification.
- SCC.1.28.010: Administrative penalties framework; the catch-all provision cited in the penalty orders.
SOURCE CITATIONS USED BY THIS CARD
- M024 - Page 24 of
M. Paul 04/11/2023 internal log: "Due to lack of contact from the Owner and failure to obtain an HDB permit I issued the Notice and Order" - a permit characterization never carried to the served record. M025-034- Pages 25-34 ofM. Administrative penalty and activity log entries; all cite the SCC.1.28.010 D3(c2ii) catch-all rather than any permit-required finding.- M035 - Page 35 of
M. 08/21/2025 inspection note stating the workshop is powered by extension cords/added outlets and that everything at the shop is to be removed or approved by inspections from a building permit. - M036 - Page 36 of
M. Paul 09/16/2025 case note: "I arrived onsite on 9/16/25 at 10:00am with PBI Cosley… met with a contractor and a representative of the property owner… walked all the violations… I would give them 30 days to obtain the building permit." No mention of the three on-tape statements recorded by the property. Also carries 10/23/2025 case note with Paul email reproduced verbatim (siding/pre-installation additions). - M037 - Page 37 of
M. Later case note quoting the 12/02/2025 email list, including "Workshop area reduced down to 120 Sq Ft and detached from the garage or removed. All utilities removed from the workshop area." - M124 - Page 124 of
M. Notice and Order to Repair or Demolish, face date 04/12/2023, signed Bo Cosley, Principal Building Inspector. - M125 - Page 125 of
M. Correction List: "Code: B59: 8.100.190 / Description: BUILDING - Permits Required" - generic code only; no permit category named. - M544 - Page 544 of
M. 09/02/2025 re-issued Correction List; includes B45 "Added square footage at detached garage to be permitted" and P08 "Added gas line for dryer in backyard requires permits." V4- Property-side 09/16/2025 walkthrough audio/video family, held locally as clip filesSOURCES/V/V.4.2.mp4,SOURCES/V/V.4.3.mp4, andSOURCES/V/V.4.4.mp4; owner-verified excerpt transcript atSOURCES/V/V.4.T.txt.- V4.T - Owner-verified transcript excerpts for the load-bearing
V4clips,SOURCES/V/V.4.T.txt; local transcript home for V4.2, V4.3, and V4.4, not a City-produced transcript. - V4.2 -
SOURCES/V/V.4.2.mp4; 09/16/2025 property-side clip in which a City speaker says electrical work had been allowed to start to some extent because of a visible hazard, while still requiring the work to go on a permit. - V4.3 -
SOURCES/V/V.4.3.mp4; 09/16/2025 property-side clip with the 120-square-foot/utilities-removal workshop discussion and the first falling-roof / point-it-out statements. - V4.4 -
SOURCES/V/V.4.4.mp4; 09/16/2025 property-side follow-on clip identifying the roof support and repeating that it was going to fall. - E4 -
SOURCES/E/E.4/E.4.pdf; Gmail print of the October 2025 Saakian thread, including the 10/16/2025 "minimal permit" relay after Saakian spoke with City inspectors and the 10/20/2025 contractor walk-off context. - E6 -
SOURCES/E/E.6/E.6.pdf; Gmail print of the 01/06/2026 "violations and case" thread identifying the live case list and the amended/supplemental notice-and-order problem for off-list additions. - R.25-3549 - NextRequest 25-3549 closed-as-complete production; earlier CPRA production for Case 23-009185.
- R.26-1965 R.26-1965.1 R.26-1965.2 - NextRequest 26-1965 closed-as-complete production; provenance for the May 2026 case-file production.
CARD REFERENCES
- Card 1 - The served B59 "Permits Required" placeholder gap; spine card establishing the generic code only on the Correction List.
- Card 6 - HDB-permit internal-versus-served gap; three written demands for specifics refused; never answered in writing.
- Card 15 - Cosley-branded administrative penalty orders on the SCC.1.28.010 catch-all; no permit-required finding in any cycle.
- Card 11 - Total fee ledger accrued against the property on those orders.
- Card 26 - 09/02/2025 re-issued Notice and Order context; confirms the City re-issued the order before the later 09/16 walkthrough and October permit-scope relay.
- Card 35 - Eventual routine "Residential Housing-Minor / Plans not required" permit class; the spine resolution.
- Card 36 - The contractor refused the undefined permit and walked off.
- Card 4 - Record-production-complete baseline; universal disproof anchor.
- Card 46 - Email-bearing completeness exemplar; applies to the Saakian phone-call demand.