The April 20 Production With an April 23 Service Oath

Case 23-009185 | Card 50 | 4880 T Street, Sacramento CA 95819

The April 2026 case-file production carries a PDF CreationDate of April 20, 2026 at 1:46:33 PM PDT A; the requester's April 24, 2026 record-integrity notice separately recorded the same creation minute and the "Microsoft Print to PDF" producer R.26-1549, with the production-format baseline handled in Card 47. The final pages of that same file contain a "Proof of Service by Certified Mail CCP.1013a CCP.2015.5" signed by Desere Williams A635-A636. The proof states that, on 04/23/2026, she served the "Notice of Hearing - Housing & Dangerous Buildings Costs Packet" for the June 10, 2026 HCAAB cost-recovery hearing tied to invoice CDDCHC24459 Card 11, and declares under penalty of perjury that the declaration was executed in Sacramento on 04/23/2026.

That date sequence is the defect. CCP.1013a makes the mailing or deposit date part of a proof of service by mail, and CCP.2015.5 supplies the under-penalty-of-perjury declaration form. The City's own notes recorded on April 17 that the hearing packet "will be sent" by certified mail on 04.23.2026 M040. On the produced record, a file created April 20 already contained a signed proof stating that service and execution occurred April 23.

IN PLAIN TERMS

The City produced a case file whose metadata says the file was created on April 20. Inside that file is a signed proof of service saying the hearing packet was served, and the declaration executed, on April 23. A further record could reconcile the two dates: the City could show the file was assembled later, that the proof was added after April 20, or that the metadata does not mean what the produced file appears to say. Without that kind of record, the production contains an April 23 oath inside an April 20 file.

RECORD CHAIN

  1. The file's creation date. The April production's PDF metadata reads: CreationDate April 20, 2026 1:46:33 PM PDT, ModDate April 20, 2026 5:57:50 PM PDT, Producer "Microsoft: Print To PDF," Author Melanie Haage A. The same creation minute was separately recorded in the requester's April 24 notice posted to the portal R.26-1549. The April production's format, metadata baseline, and provenance are documented at Card 47.
  2. The declaration's own dates. The final two pages of the April file are a Proof of Service by Certified Mail, invoking CCP.1013a and CCP.2015.5, hand-signed by Desere Williams. The proof recites service "On 04/23/2026 … Notice of Hearing - Housing & Dangerous Buildings Costs Packet" and states that it was "executed … on 04/23/2026" A635-A636. Page 636 duplicates page 635; the same declaration appears twice.
  3. What the packet was for. The City's note log records the chain M040: on 04/17/2026 Desere Williams entered that the City scheduled the June 10, 2026 HCAAB hearing on invoice CDDCHC24459 ($410.40) and that "A Notice of Hearing packet will be sent by certified mail on 04.23.2026." On 04/28/2026 the same log records: "Received signed certified green card for the 06/10/2026 HCAAB hearing packet. Signature unknown dated 04/24/2026." As of the April 20 production date, the April 23 mailing was an event the City had described only in the future tense. The fee-ledger context for invoice CDDCHC24459 is at Card 11.
  4. The date gap. The proof of service invokes CCP.1013a and CCP.2015.5. It states that both the service and the execution occurred on April 23, 2026 A635-A636 — three days after the creation date in the file's own metadata A.
  5. Separate portal notice. The requester's April 24, 2026 notice posted to the portal R.26-1549 separately records the production creation as "Microsoft Print to PDF on April 20, 2026, at 1:46:33 PM" — matching the file's own metadata A — and demands a stay of the June 10, 2026 hearing. That notice and the City's non-response to it are documented at Card 49.

FULL CIRCLE

The City may argue: The Proof of Service was prepared in advance for a scheduled mailing; staff routinely pre-generate service declarations for a planned certified-mail date; the April 20 production simply captured a form already in the system, so the date difference is a workflow artifact, not a defect.

The produced page, however, is not presented as merely a blank future-mailing template; A635-A636 states that service and execution occurred on April 23, 2026, under the proof-of-service and declaration framework of CCP.1013a and CCP.2015.5. The case notes describe the same April 23 mailing as a future event as of April 17 M040, and the April production's metadata places the file's creation on April 20 A.

An export log, custodian declaration, or corrected metadata showing that the April production was assembled on or after April 23, 2026 would answer the date gap. The production's format and metadata baseline are treated in Card 47, the unanswered April 24 integrity notice in Card 49, and the closed-production completeness baseline in Card 4. This card's finding is narrower: without such a record, the file produced with an April 20 creation date contains a proof of service sworn as executed on April 23. That is a production-integrity and foundation problem in the record the City produced.

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