1 Mayra Ochiqui
From:Livia Borak Beaudin
Sent:Friday, September 25, 2026 11:25 AM
To:City Clerk
Subject:September 28, 2026 City Council Meeting: Item 12.A.
Attachments:Item 12.A.Bellflower_Abatement_Cost_Appeal_Presentation_Appellant.pptx Follow Up Flag:Flag for follow up
Flag Status:Flagged
Good morning,
Please find aƩached the Power Point presentaƟon for Appellant for Item 12.A for the upcoming City Council mee Ɵng on Monday.
I will appear on behalf of Appellant via Zoom. I am Appellant’s aƩorney.
ConfirmaƟon of receipt would be appreciated.
Thanks,
~Livia
Livia Borak Beaudin (she/her)
Coast Law Group LLP
1140 South Coast Highway 101
Encinitas, California 92024
telephone: 760.942.8505
direct dial: 760-514-0165
“Like music and art, love of nature is a common language that can transcend political or social boundaries.” ― Jimmy Carter
CITY OF BELLFLOWER • CITY COUNCIL HEARING • SEPTEMBER 28, 2026 Appeal of Abatement
Cost Demand
17440–17450 Bellflower Blvd., Bellflower, CA 90706
Three independent grounds require denial or reduction of the City's Demand:
(1) an untimely statement of costs, (2) erroneous double-billing that persists even in the City's Revised Demand, and (3) unsubstantiated attorneys’ fees.
Presented on behalf of 17450 Bellflower Blvd., LLC ("Appellant")Coast Law Group, LLP
OVERVIEW
Three Independent Grounds for Relief
17440–17450 Bellflower Blvd. | Appeal of Abatement Cost Demand 2 01 UNTIMELY DEMAND
BMC § 8.36.180(B)
•The City must serve its cost statement within 20
calendar days of completing abatement.
•The Hearing Officer's Final Order and the City's
own cost records are dated April 15–22, 2026.
•The original Demand was not served until August
24, 2026 — 124 days later.
•The Revised Demand issued even later still, on
September 22, 2026.
02 ERRONEOUS BILLING
Duplicate & Unrelated Charges
•The original Demand double-billed hearing
officer invoices and included charges for
unrelated properties.
•Identified overcharge: $13,800 of the $20,750
claimed hearing officer total.
•The City's Revised Demand corrected some
errors — but still overstates hearing officer costs
by $725.
•The same September 2023 hearing is still billed
twice in the revised figures.
03 UNSUBSTANTIATED FEES
City Attorney Charges Lack
Support
•City Attorney entries list only a name, date,
hours, and rate — never a description of the
work performed or the person’s role.
BACKGROUND
Key Dates in This Matter
03/10/23 Notice of Public Nuisance and Intention to Abate issued 05/23/23 First administrative appeal hearing held
04/15/26 Hearing Officer's Final Order: matter “deemed concluded” 04/22/26 Order mailed; City Attorney's and City Staff's own final cost entries dated 08/19/26 Original Abatement Cost Demand issued — $55,988.66 08/27/26 Appellant files appeal (untimely service; insufficient detail) 08/31/26 Appellant's Addendum identifies $13,800 in duplicate/unrelated charges 09/21/26 City Attorney Emails Appellant with reduction of $4,475 in Hearing Officer Costs.
Appellant Continues to Dispute Double-Billing and Duplicate, Unrelated Hearing Officer Invoices. 09/22/26 City issues Revised Demand Reducing Hearing Officer Costs by an additional $8,600.
Appellant Continues to Dispute Double-Billing
17440–17450 Bellflower Blvd. | Appeal of Abatement Cost Demand 3
GROUND 1
The Demand Is Untimely Under BMC § 8.36.180(B)
“The City shall serve a statement of abatement costs on the responsible persons within 20 calendar days of the City's completion of nuisance abatement actions.”
— BMC § 8.36.180(B)
04/22/26
Completion of abatement actions
(Final Order mailed; City's own cost entries dated)
124 days
Until the original Demand was served — August 24,
2026
(over 6× the 20-day deadline)
153 days
Until the Revised Demand issued — September 22,
2026
(the delay only grew)
• The Order concluded the administrative action and both the City Attorney's and City enforcement staff's cost logs end on April 22, 2026 — the City's own records fix the completion date.
• “Shall” is mandatory language; the 20-day period is not discretionary. • Because the City failed to comply with this procedural requirement, the Demand — original and revised — is untimely and should be denied in its entirety on that basis alone.
17440–17450 Bellflower Blvd. | Appeal of Abatement Cost Demand 4
GROUND 2
The Original Demand Overcharged Appellant by $13,800
AmountHoursNature of ErrorCharge Identified
$1,5506.2 hrsBilled twice in the Demand's exhibitNov. 9, 2023 hearing officer invoice $7252.9 hrsBilled twice in the Demand's exhibitSept. 11, 2023 hearing officer invoice $1,8507.4 hrsFor a different property — 9103–9121 Artesia Blvd.Feb. 14, 2024 hearing officer invoice $8,95035.8 hrsFor an unrelated matter — One Stop Paint Shop, Inc. — billed twiceNov. 15, 2023 hearing officer invoice $20,750
Hearing officer costs claimed
in the original Demand
$13,800
Total overcharge identified
in Appellant's Addendum
$6,950
Correct hearing officer costs
supported by the record
Source: Appellant's Addendum to Appeal of Abatement Costs (Aug. 31, 2026); City's Aug. 19, 2026 Demand, Exhibit A. 17440–17450 Bellflower Blvd. | Appeal of Abatement Cost Demand 5
GROUND 2 — CONTINUED
The Revision Did Not Fix the Double‐Billing
The City's Sept. 22, 2026 Revised Demand reduced hearing officer costs, acknowledging “duplicate and inapplicable invoicing.” But the revised figure still does not match the City's own supporting invoices.
$7,675
Hearing officer total claimed
in the Revised Demand
(30.7 hours)
−$6,950
Total actually supported by the
Revised Demand's own attached
invoices (27.8 hours)
=$725
Unexplained overcharge remaining
— exactly 2.9 hours, the size of the
duplicate Sept. 11, 2023 invoice
• The Revised Demand's summary table still contains both sets of line items for the same September 2023 hearing: the Sept. 11, 2023 invoice's entries and the overlapping September entries carried over from the Nov. 9, 2023 invoice. • Appellant is therefore still being billed twice for a single hearing officer appearance and report. • The City Attorney and City Staff figures were not adjusted at all in the revision — $22,744.30 and $12,494.36, unchanged from the original Demand. 17440–17450 Bellflower Blvd. | Appeal of Abatement Cost Demand 6
GROUND 2 — CONTINUED
The Revision Did Not Fix the Double‐Billing
17440–17450 Bellflower Blvd. | Appeal of Abatement Cost Demand 7
The hearing occurred on 9/7/2023
(not 9/6/2023) as confirmed by the
hearing officer’s own order and
staff enforcement billing records.
GROUND 3
The City Attorney's Fees Are Not Substantiated
“The Demand fails to provide sufficient detail to enable an assessment of reasonableness … the entries do not detail the tasks undertaken and therefore Appellant cannot verify they are related to the nuisance abatement process.” — Appeal of Abatement Costs, Aug. 27, 2026 (Ground B)
$22,744.30
Total City Attorney fees claimed — not one entry
describes the work performed
•Every City Attorney entry lists only a name, date, hours, and rate — never a description of the task performed, unlike the Hearing Officer's invoices. •BMC § 8.36.230 permits recovery only of fees “reasonably required” to achieve abatement; undocumented, unverifiable, and commingled entries cannot meet that standard.
17440–17450 Bellflower Blvd. | Appeal of Abatement Cost Demand 9
GROUND 3 — EVIDENCE
What the City Attorney's Billing Entries Actually Look Like No task or description column exists — every entry lists only a name, date, hours, and rate.
Four different attorneys each bill 0.1 hour the same day — with nothing in the Staff or Hearing Officer logs to explain why.
Source: City's Revised Abatement Cost Demand (Sept. 22, 2026), Exhibit A — City Attorney Costs. 17440–17450 Bellflower Blvd. | Appeal of Abatement Cost Demand 10
SUMMARY
Original vs. Revised vs. Supported Costs
Supported by
the Record
Revised Demand
(Sept. 22, 2026)
Original Demand
(Aug. 19, 2026)Cost Category
Unverified*$22,744.30$22,744.30City Attorney
$12,494.36$12,494.36$12,494.36City Staff
$6,950.00$7,675.00$20,750.00Hearing Officer
$19,444.36$42,913.66$55,988.66TOTAL
*City Attorney and City Staff entries list only name, time, and rate — no task description — so Appellant cannot verify these charges relate to nuisance abatement at this Property.
Bottom line:
Even after the City's own correction, the Demand still overstates recoverable hearing officer costs by at least $725 — and the City Attorney totals remain wholly unverified.
17440–17450 Bellflower Blvd. | Appeal of Abatement Cost Demand 11
REQUESTED RELIEF
Appellant Respectfully Requests
1 Deny the Demand in its entirety
The City failed to comply with the mandatory 20-day service requirement of BMC § 8.36.180(B); the Demand is untimely as a matter of law. 2 In the alternative, reduce the demand to the amount supported by the invoices: $19,444.36 The amount actually supported by the invoices the City itself attached to the Revised Demand — for a total of $19,444.36.
For these reasons, Appellant respectfully requests that the City Council grant the appeal and deny — or, at minimum, substantially reduce — the City's Abatement Cost Demand.