Sonny R. Santa Ines
Mayor
Victor A. Sanchez
Mayor Pro Tem
Ray Dunton
Council Member
Dan Koops
Council Member
Wendi Morse
Council Member
1 December 19, 2025
VIA E-MAIL, U.S. MAIL & CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Berenice Cristerna
Authorized Representative
Dynasty Alliance Grow Inc.
8832 Ramona Street
Bellflower, CA 90706
Email: [email protected]
Re: Document dated December 18, 2025
Denial of Cannabis Business Permit Renewal
Ms. Cristerna:
This letter responds to your “Formal Notice of Appeal” document dated December 18, 2025, regarding the City Council’s decision on the cannabis business permit associated with 8832 Ramona Street. Thank you for your communication.
The action you describe in your document is a final decision of the City Council on renewal of a discretionary cannabis business permit, not a conditional use permit revocation or other appealable land use entitlement. Under the City’s procedures, there is no further administrative appeal within the City from the Council’s decision on this cannabis business permit renewal.
There will be no additional consideration of Dynasty Alliance’s permit by the City Council.
To the extent you wish to challenge the City Council’s final administrative decision, your remedy is to seek judicial review by filing a petition for writ of administrative mandamus in the Superior Court pursuant to Code of Civil Procedure § 1094.5, within any applicable limitations period. You should consult with legal counsel promptly regarding any deadlines and procedural requirements associated with such action.
Cannabis business permits issued by the City are discretionary authorizations that do not create any vested right to renewal or to future permits. The City Council retains full discretion whether to grant, deny, or decline to renew such permits. There is no legal requirement that the Council renew a cannabis business permit or issue one in the first instance.
The City Council agenda item at issue concerned renewal of the cannabis business permit and related requests, not revocation of any conditional use permit. Any discussion of CUP violations
Sonny R. Santa Ines
Mayor
Victor A. Sanchez
Mayor Pro Tem
Ray Dunton
Council Member
Dan Koops
Council Member
Wendi Morse
Council Member
2 or cannabis tax delinquency occurred in that context as part of the Council’s evaluation of whether to renew the cannabis business permit. You were provided adequate (and repeated) notice regarding the meeting date. Additionally, you were free to send a representative for your company.
Your correspondence indicates that your client may seek judicial remedies and damages from the City. Any claim for damages must be submitted to the City in accordance with the Government Claims Act (Government Code § 900, et seq.). Such claims must be filed with the City Clerk’s office. Should your company pursue legal action against the City for damages, this office will recover defense costs, including attorney’s fees, pursuant to Code of Civil Procedure § 1038.
Persons operating commercial cannabis facilities within the City without a valid cannabis business permit engage in unlawful activity. The penalties for operating an unlicensed cannabis facility are set forth in the Bellflower Municipal Code.
Cannabis business permits are highly regulated and discretionary permits. The City Council’s authority to issue (or renew) some, all, or no such permits is well established; it has extremely broad discretion to make its decisions. As you were informed, the cannabis business permit for 8832 Ramona Street will terminate and be of no further force and effect after December 31, 2025. Any cannabis-related commercial operations at that address after that date, without a valid City cannabis business permit, constitutes unpermitted activity and will result in civil and criminal enforcement by the City and/or other agencies to the full extent allowed by law.
Nothing in this letter alters or waives any of the City’s rights, remedies, or enforcement authority, all of which are expressly reserved.
Very truly yours,
Karl H. Berger
City Attorney
FORMAL NOTICE OF APPEAL
Applicant: Dynasty Alliance Grow Inc.
Address: 8832 Ramona Street, Bellflower CA 90706
Phone: 562-455-7981
Email: [email protected]
Re: Appeal of denial of Cannabis License Renewal; Denial of Request for Continuance; Alleged CUP Violation and Cannabis Tax Delinquency
Agenda Item: Cannabis License Renewal -Request for Continuance —Agenda Item To: City Clerk / City Council (as applicable)
City of Bellflower, California
NOTICE IS HEREBY GIVEN That Dynasty Alliance Group Inc. ("Applicant") hereby appeals the City's decision denying its cannabis license renewal and denying its request for a continuance, where the stated basis for denial includes alleged violation of the Conditional Use Permit ("CUP") exceeding one year in duration, alleged cannabis tax delinquency.
Grounds for Appeal
1. Denial of Due Process and Meaningful Opportunity to Be Heard: The Applicant was prevented from appearing and responding to the City's allegations due to documented medical emergency that city members had been notify of. Denial of a reasonable continuance deprived the Applicant of the opportunity to present evidence, explain mitigating circumtances, and demonstrate ongoing or substantial compliance.
2. Abuse of Discretion in Denying Continuance: The City failed to reasonably exercise discretion by refusing a short continuance despite extraordinary circumstances, where no prejudice to the City was identified and the alleged violation are fact -intensive and require evidentiary review.
3. Failure to Consider Corrective Actions and Good -Faith compliance Efforts: The Applicant has undertaken corrective measures related to CUP conditions and has been addressing cannabis tax obligations in good faith. Processing in the Applicant's absence resulted in the City failing to consider relevant evidence, payment history, cure efforts, and proportional remedies short of denial.
4. Arbitrary and Disproportionate Enforcement: Denial of renewal based in alleged long- standing CUP violations and tax delinquency, without allowing the Applicant to present defenses, timelines, or cure plans, constitutes arbitrary and capricious action particularly where lesser remedies (conditional renewal, compliance schedule, or continued hearing) were available.
5. Lack of Nexus Between Non -Appearance and Ultimate Denial: To the extent denial was influenced by non-appearance, such reliance is improper where the absence was involuntary and promptly communicated.
Relief Requested
• Acceptance of this appeal as timely filed.
• A full administrative appeal hearing before the City Council or designate hearing officer; • Opportunity to present evidence regarding CUP compliance status, corrective actions, and cannabis tax payment or cure arrangements;
• Reversal of the denial and reinstatement of the license, or alternatively, remand for a continued hearing with conditions reasonable related to compliance.
File this: "1+ 1 OVti 1a is/25-
By:
Authorized Representative, Dynasty Alliance Group Inc.