The Unreconciled Garage Verification

Case 23-009185 | Card 7 | 4880 T Street, Sacramento CA 95819

The case file the City produced for Case 23-009185 [R.26-1965.2] records one garage-addition verification before the April 2023 Notice and Order, and dates it twice. The Activities log dates it 04/10/2023: "I did verify there is an addition to the detached garage going on... I took pictures of what I saw from where I was standing. A N&O will be requested." [M001] The Notes section of the same file carries that entry word for word under 04/11/2023 [M024]. Five photograph declarations in the same file, each reading "I declare under penalty of perjury under the laws of the State of California that I took the attached photograph" [M110-112], carry "Date Taken: 04/10/2023" [M110-112] and "Taken By: Paul Lovato" [M110-112] — the five frames the Documents inventory dates 04/10/2023 [M013], two of them captioned "View from neighbors lot of work performed" [M013].

Under 04/11/2023 the Notes section holds a second entry: "7:00 am. I arrived to SFR to take photos and update case files... I issued the Notice and Order" [M024]. The Activities log's own 04/11/2023 entry reads, in full, "Any contact from owner? Re-visit site. Add condition? if not, call contact to see if I can gain access to see work Buster prelim sent out 2 weeks ago" [M001]. The inventory lists no photograph dated 04/11/2023 [M013], and no declaration in the produced file carries that date [M110-112]. The order carries the face date 04/12/2023 and recites that the Chief Building Official has caused the building to be inspected and has determined its condition [M124]. The City closed that production under Request 26-1965 with "All responsive records have been provided." [R.26-1965.1]

The file the City produced in May 2026 swears five photographs were taken on 04/10/2023 [M110-112], and its 04/11/2023 note records a 7:00 a.m. arrival at the property "to take photos" [M024] before the order was issued. Where in the file the City produced under Request 26-1965 [R.26-1965.1] is a photograph, a declaration or an inspection record of that 04/11 visit — and which of the two days is the inspection the April 12, 2023 order [M124] recites?

IN PLAIN TERMS

The City's file describes one look at the garage and dates it twice: April 10 in the Activities log [M001], April 11 in the Notes [M024]. Five sworn photograph pages date their pictures April 10 [M110-112], two of them taken from the neighbors' lot [M013]. A second April 11 note says the inspector arrived at 7:00 a.m. to take photographs and issued the Notice and Order [M024]. The file holds no photograph dated April 11 [M013] and no sworn page dated April 11 [M110-112]. The order is dated April 12 [M124] and says the building was inspected. The question for the City: where are the photographs and records from the April 11 visit, and which day was the inspection the order rests on?

RECORD CHAIN

  1. April 7, 2023 — the visit the file scheduled.

    The Notes section's phone-call note of that date records a time set to view the work from the adjoining property: "Monday (4/10/24) at 3:00 pm" [M024].

  2. April 10, 2023 — the entry, the photographs, and the sworn pages.

    The Documents inventory [M013] lists five case photographs dated 04/10/2023: IMG_1372.jpg ("View of detached garage from front of dwelling") [M013], IMG_1373.jpg ("Entry to dwelling") [M013], IMG_1374.jpg ("Card left at site") [M013], IMG_1492 (1).jpg ("View from neighbors lot of work performed") [M013], and IMG_1493.jpg ("View from neighbors lot of work performed") [M013].

    The file carries five photograph declarations for these frames, each reading "I declare under penalty of perjury under the laws of the State of California that I took the attached photograph" [M110-112], with "Date Taken: 04/10/2023" [M110-112] and "Taken By: Paul Lovato" [M110-112]. They are the only photograph declarations of April 2023 in the produced file signed by that inspector; none carries 04/11/2023 [M110-112].

    Three of the captions place the frame at the dwelling; two place it on the adjoining lot. The Activities log entry of the same date [M001] treats the Notice and Order as a step still to come. (Card 8: where these frames fall in a photograph-name sequence that runs through three other City case files.)

  3. April 11, 2023 — the same entry under a second date, and no photograph.

    The Notes section carries two entries under this date: the 04/10 Activities-log entry again [M024], logged as a re-inspection activity note, and the general case note recording the 7:00 a.m. arrival, the photographs, and the issuance.

    The Activities log carries under the same date [M001] an added Accela condition, a cloud request, an online title-report request, and the re-inspection entry that reads in full: "Any contact from owner? Re-visit site. Add condition? if not, call contact to see if I can gain access to see work Buster prelim sent out 2 weeks ago" [M001]. The Buster prelim activity it measures from is dated 03/21/2023 [M001] in the same log; two weeks after it is about April 4, before the visit the log dates 04/10/2023. Read as written on April 4, the entry sits under a date it was not written on; read as written on April 11, it still asks for access to see the work the day after the verification. It does not carry the verification narrative the Notes section dates here.

    The Documents inventory's only two rows dated 04/11/2023 [M013] are merge documents — "HSG - Cloud.htm" [M013] and "HSG - Notice & Order S-DB.htm" [M013]. No photograph of the property carries that date.

  4. April 12, 2023 — the order.

    The Notice and Order carries the face date 04/12/2023 [M124], the day after the note that records issuing it, and the Activities log dates its Notice and Order step to that day [M001]. The Documents inventory [M013] lists the order packet, "no23-009185.pdf" [M013], under 04/12/2023.

    SCC.8.100.720(A)(2) requires the order to contain a brief and concise description of the conditions found to render the building substandard. The order states that those conditions are set forth on the attached list of violations [M124]. The list produced with the case file [M012], opened 03/20/2023, states, "This is not a complete Violation List of building code violations. Neither interior nor exterior has been completely inspected." [M012] (Card 1: the list attached to the order names no structure, no work, no location, and no permit.)

FULL CIRCLE

The City's first available answer is the sworn pages: five photograph declarations carrying "Date Taken: 04/10/2023" [M110-112], one for each of the five inventory rows of that date [M013], with the Notes copy of the entry under 04/11/2023 read as the date the note was created [M024] rather than the date of the visit. Those pages date the April 10 photographs and nothing else. They say nothing about the 7:00 a.m. arrival "to take photos" [M024] the same Notes section dates 04/11/2023; the inventory lists no photograph of that date [M013]; no declaration in the produced file carries 04/11/2023 [M110-112]. A sworn date for one visit is not the record of the other.

The City's second available answer is that the log's 04/11/2023 entry is a checklist written before the visit — its tail, "Buster prelim sent out 2 weeks ago" [M001], counts from the 03/21/2023 Buster prelim activity [M001] — and that "I arrived at SFR to take photos" is the inspector's standing opening line, used again on 06/28/2023: "1:00 pm. I arrived at SFR to take photos, update case files, and send the 1st Level C HSG HDB Monitoring fee" [R.26-1965.2]. Both readings rest on one premise: the dates in the City's log are not the dates of the events under them. Then the produced file does not record when the inspection the order recites [M124] was performed, and the list the order sets those conditions on [M012] states that neither interior nor exterior has been completely inspected. (Card 2: what the produced case file holds, and does not hold, as the inspection predicate for the order.)

What would defeat this card is one page: a photograph, a declaration, an inspection record, or any other page recording the 7:00 a.m. visit of 04/11/2023, or a page stating which of the two visits is the inspection the order recites. The file the City produced under Request 26-1965 [R.26-1965.2], 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).

Request 26-2487 [R.26-2487.5], filed 06/23/2026, asked for "The inspection report(s) underlying the determination recited in the April 12, 2023 Notice and Order" [R.26-2487.5]. It was closed the same day with "All responsive records have been provided." [R.26-2487.5] The three documents released were a case-file extract for 05/17-06/23/2026, a permit inspection history, and a case summary [R.26-2487.5].

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