Agenda — California City City Council, August 25, 2026 (part 3 of 4)

Site Plan Review 25-09
Determination Letter
To,
Marcelo Ariola
VP Real Estate
CoreCivic, Inc.
5501 Virginia Way, Suite 110,
Brentwood, TN 37027
Date: 26 February 2026
Subject: Approval of Site Plan Review (SPR 25-09) at 22844 Virginia Blvd, California City, CA 93505
Dear Marcelo Ariola,
The City of California City (“City”) Planning Department has completed its review of Site Plan Review Application SPR 25-09 for the California City Corrections Facility located at 22844 Virginia Blvd (APN 350-031-02). Based upon review of the City’s entitlement record and associated environmental documents, the following determination is issued.

Background:

The facility located at Virginia Boulevard was originally approved under Conditional Use Permit (CUP) 97-01, adopted via Resolution No. 01-98-1802, for a 2,304-bed “prison facility.” In October 1998, the City granted CUP 98-02 to expand the permitted use by 512 beds.

The facility was inactive for approximately one year. Neither CUP 97-01 nor CUP 98-02 expires due to inactivity. Further, each CUP runs with the land and is valid unless and until revoked after a notice and opportunity to be heard according to applicable law.

On August 22, 2025, the facility applied for Site Plan Review approval “to operate in the same manner it has since it was constructed in 1999.”

CITY HALL
21000 Hacienda Blvd.

California City, CA 93505
______________________________________
760-373-8661
www.californiacity-ca.gov
Marquette Hawkins
MAYOR
Jim Creighton

MAYOR PRO TEM
Della Clark
Ronald Smith

COUNCIL MEMBERS
__________________
Sean Grayson

INTERIM CITY

MANAGER

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Discussion:

Pursuant to California City Municipal Code (“CCMC”) section 9-2.212(b), the Planning Director reviews the proposal to determine whether it satisfies the requirements of this section. Section 9-

2.212(d), further provides that “The site plan shall be approved if application shows the site will be developed in accordance with the requirements of the Municipal Code.” As such, Section 9-

2.212 directs ministerial approval when the proposal demonstrates Municipal Code compliance.

The Planning Department has reviewed the Site Plan Review Application and finds the use is authorized subject to compliance with CUP 97-01 and CUP 98-02. In particular, these permits collectively allow for a total bed count of 2,816.

The facility has satisfied the requirements of the Building & Safety Division and Fire Department.

According to CCMC section 9-2.402, “correction, probation or prison facilities and services” are permitted in the Residential Agricultural (RA) zone with a conditional use permit. The facility’s current operations appear to fall within the scope of the use approved in CUP 97-01 and expanded by CUP 98-02. Therefore, the proposed use is a continuation of the previously entitled use.

CEQA Determination:

The Site Plan Review approval is a ministerial action limited to verification of compliance with objective Municipal Code standards and does not involve the exercise of discretion. Accordingly, this approval is exempt from the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines Section 15268 (Ministerial Projects).

The facility and correctional facility use were previously evaluated in a certified Environmental Impact Report Supplement (SCH No. 97091045) adopted in connection with CUP 97-01 and a Mitigated Negative Declaration adopted in connection with CUP 98-02. This administrative approval implements existing entitlements and does not authorize any expansion or modification of the approved project.

Planning Department Findings:

The facility remains subject to the use category approved under CUP 97-01: Governmental or quasi-governmental correction, probation, or prison facilities and services. Pursuant to CCMC section 9-2.212(d), the application shows the site will be used in accordance with the requirements of the CCMC, and as such “the site plan shall be approved.” This Site Plan Review approval:

1. Implements CUP 97-01 and CUP 98-02 as reflected in the City’s entitlement record;

2. Reflects a maximum occupancy of 2,816 beds;

3. Applies solely to the previously approved 70-acre facility footprint (APN 350-031-02); and

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4. References the previously certified environmental documents and adopted mitigation programs associated with CUP 97-01 and CUP 98-02.

5. Affirms that the operator maintains ongoing compliance with all applicable mitigation measures contained in both adopted programs. The City reserves the right to conduct inspections and request documentation necessary to verify continued compliance.

Failure to comply with the conditions of CUP 97-01 or CUP 98-02 the adopted mitigation programs may result in enforcement action, including potential revocation proceedings in accordance with the CCMC and California law.

Any proposal to expand the development area, increase bed capacity beyond 2,816 beds, or materially modify the approved use shall require amendment to the applicable Conditional Use Permit(s) and compliance with CEQA.

This letter constitutes the Planning Department’s formal approval of SPR 25-09 consistent with the above-referenced entitlements and environmental determinations. _____________________
Sincerely,
Anu Doravari
Planning Director
Planning Division
Community Development
City of California City

California City, CA: Decision of City Manager Appeal of Business License Issuance July 9, 2026

CITY HALL
21000 Hacienda Blvd.

California City, CA 93505
______________________________________
760-373-8661
www.californiacity-ca.gov
Marquette Hawkins
MAYOR
Jim Creighton

MAYOR PRO TEM
Della Clark
Ronald Smith

COUNCIL MEMBERS
__________________
Sean Grayson

CITY MANAGER
July 9, 2026
DELIVERED VIA U.S. MAIL & ELECTRONIC MAIL:
[email protected]; [email protected]; [email protected] Jehan Laner & Grisel Ruiz Daniel P. Struck
Dignity Not Detention Coalition Struck Love Acedo, PLC
268 Bush Street, #3933 3100 West Ray Road, Suite 300
San Francisco, CA 94104 Chandler, AZ 85226
RE: Decision of City Manager Regarding Dignity Not Detention Coalition’s Appeal of California City’s February 26, 2026, Issuance of a Business License to CoreCivic, Inc.

Dear Ms. Laner, Ms. Ruiz, and Mr. Struck:

On July 7, 2026, at 3:30 p.m. P.S.T. an administrative appeal hearing was held in the above referenced matter using the online platform Zoom and in person at California City’s City Hall, City Council Chambers located at 21000 Hacienda Blvd., California City, CA 93505. The administrative appeal hearing was conducted pursuant to the authority and process provided under California City Municipal Code (“CCMC”) Chapter 4 (Appeals and Review). City Clerk John Paul Maier appeared on behalf of the City of California City (“City”).

Jehan Laner and Grisel Ruize, as legal counsel, appeared on behalf of the Appellant and Daniel P. Struck, as legal counsel, appeared on behalf of the Applicant. Pursuant to CCMC Section 1-4.09(b), the City Manager served as the hearing officer.

After reviewing all of the evidence submitted by the City, the Appellant, and the Applicant prior to and at the administrative appeal hearing as well as the Appellant’s supplemental briefing, and based upon a preponderance of that evidence, this hearing officer upholds the City Clerk’s February 26, 2026 issuance of a Business License to CoreCivic, Inc., and denies Appellant’s appeal.

Scope of Hearing Officer’s Review at Administrative Appeal Hearing Pursuant to CCMC Section 1-4.04(d), at the administrative appeal hearing, the hearing officer was charged with conducting a de novo hearing based upon the following evidence:
(1) Any relevant evidence, including staff reports, etc., submitted at the time of the prior decision and at the appeal hearing; and
California City, CA: Decision of City Manager Appeal of Business License Issuance July 9, 2026 (2) Findings, if any, and decision of the person or body whose decision is being appealed, but the person or body hearing the matter shall not be bound by the findings and decisions of the original decision being appealed.

Burden of Proof at the Administrative Appeal Hearing
Under CCMC Section 1-4.04(e), because the appeal involved the issuance of a Business License the Appellant had the burden of proof to support the overturning of the prior decision.

Hearing Officer’s Decision
Based upon a preponderance of the evidence, the Appellant failed to show that the City Clerk erred or did not comply with the requirements of the CCMC when s/he issued a Business License to CoreCivic, Inc. on February 26, 2026. Thus, the appeal filed by the Appellant is denied and the issuance of the Business License is upheld.

Right of Appeal
This decision may be appealed by any affected person within seven (7) days of the hearing officer’s decision pursuant to CCMC Sections 1-4.04(a), 1-4.05(b) and 1-4.09(c).

Respectfully Submitted,
Sean Grayson
City Manager
City of California City

NOTICE OF PUBLIC HEARING

CITY OF CALIFORNIA CITY

CITY COUNCIL
MATTER: Appeal of City Manager Decision to the City Council PROJECT/REVIEW: Business License for CoreCivic Inc.

APPLICANT/FACILITY: California City Correctional Facility / CoreCivic Inc.

LOCATION: 22844 Virginia Boulevard, California City, CA 93505; APN:350-031-28-2 NOTICE IS HEREBY GIVEN pursuant to California City’s California Municipal Code Chapter 4. Sec. 1-

4.08 that the City Council of the City of California City will consider an appeal of the City Manager’s Decision dated July 7, 2026, determination approving the issuance of a Business License for the California City Correctional Facility located at 22844 Virginia Boulevard, California City, CA 93505 (APN 350-031-28- 2). Jehan Laner, on behalf of Immigrant Legal Resource Center and Dignity Not Detention Coalition, appealed the City Manager’s decision to uphold the City Clerk’s issuance of a business license to CoreCivic Inc. Following deliberate consideration of the matter, the City Council may uphold, modify, reverse, or remand the City Manager determination.

HEARING SCHEDULE & VENUE
Hearing Date: Tuesday, August 25, 2026
Hearing Time: 5:00 p.m. Pacific Standard Time, or as soon thereafter as this matter may be heard Location: City Council Chambers, 21000 Hacienda Boulevard, California City, CA 93505

REMOTE DIGITAL PARTICIPATION
Zoom Video Link: https://us06web.zoom.us/j/82424125440
Webinar ID: 824 2412 5440
+1 669 444 9171 US
+1 253 205 0468 US

SUBMISSION OF WRITTEN MATERIALS
Interested parties may submit written comments, letters, or supplemental evidence prior to the hearing via mail or email to: Mail: City of California City Clerk, 21000 Hacienda Boulevard, California City, CA 93505 or Email: [email protected]
To ensure adequate time for review and inclusion in the official hearing record, written submissions are strongly encouraged to be received at least twenty-four (24) hours prior to the hearing. While materials presented live at the hearing will be accepted, the Planning Commission reserves the right to continue the hearing to a subsequent date if additional time is required to evaluate late-submitted documentation.

This notice is posted, published, and distributed in strict accordance with applicable California Brown Act requirements and municipal procedures. Questions / Public Inquiry may be submitted to: City Clerk at [email protected] or (760) 338-1377.

August 19, 2026
Via email
City Council
City of California City
21000 Hacienda Boulevard
California City, CA 93505
Cc: City Clerk
Motion for Continuance of August 25, 2026 Appeal Hearing for CoreCivic Inc.’s Site Plan Review and Business License for the California City Correctional Facility

1. Appellants respectfully move the City Council to continue the August 25, 2026 hearing date for the appeal of the Planning Commission’s decision to sustain the grant of the SPR Minor Permit (SPR 25-09), and the City Manager’s decision to sustain the grant the of the Business License for CoreCivic Inc. for the reasons stated below.

2. The City Clerk set this City Council hearing for the Appeal of the Planning Commission’s decision to sustain the grant of the SPR Minor Permit (SPR 25-09), and the City Manager’s decision to sustain the grant the of the Business License to CoreCivic Inc. on August 25, 2026 at 5:00pm.

3. On August 6, 2026, the City Clerk asked to confirm appellants’ availability for August 25, 2026, and stated he could explore additional hearing dates. On that same date, appellants informed the City Clerk that due to urgent medical issues neither Ms. Ruiz or Ms. Laner could attend the August 25, 2026 date, and requested that the City Clerk schedule the hearing to a date after September 18, 2026 to allow appellants to appear in person.

4. Due to appellants’ correspondence with the City Clerk, appellants reasonably expected that the hearing date remained under discussion. On August 14, 2026, appellants received electronic notice that the hearing date was scheduled for August 25, 2026.

5. Appellants now respectfully move the City Council to continue this hearing to another date. Based on the upcoming City Council meeting dates provided by the City Clerk, appellants believe the following dates would work to hold this hearing, and respectfully request that the City Council consider a continuance of the appeal to one of these dates:
a. September 22, 2026
b. October 13, 2026
c. October 27, 2026 (less preferred).

6. Appellants respectfully request and move for this continuance for the reasons stated below.

7. First, appellants incorporate the previous reason for requesting a different date due to unforeseen medical issues.

8. Second, because appellants were under the impression that the City Clerk could accommodate a request for a different date, appellants only received official electronic notice on August 14, 2026. This is only 7 business days before the hearing. The City Code requires at least 10 days’ notice and does not specify whether those are calendar or business days. See California City Municipal (CCM) Code Sec. 1-4.04 (requiring at least 10 days’ notice for an appeal before a body which conducts regularly scheduled meetings). The August 25th hearing date does not provide 10 business days’ notice.

9. Third, even if the City interprets the code as only requiring 10 calendar days’ notice before an appeal hearing, the City Code does require that hearing notice be given in “the same manner as any required notice for the hearing at which the decision subject to the appeal or review was made.” CCM Code Sec. 1-4.08 (emphasis added).

10. In this case, the Planning Commission and City Manager hearings for the SPR Minor Permit and Business License were held on July 7, 2026, and appellants received official electronic notice on June 18, 2026, which is 19 calendar days (13 business days) before the hearings. Therefore, the shortened notice provided for the August 25, 2026 hearing does not satisfy Section 1-4.08’s requirement that notice be given in the “same manner” as notice for the underlying hearings being appealed.

11. Appellants' request is limited and reasonable. Appellants do not seek an indefinite continuance, but request that the hearing be continued to one of three identified, regularly scheduled City Council meetings. The earliest proposed date, September 22, is only four weeks after the currently scheduled hearing. A brief continuance would allow Appellants to appear in person and permit additional public notice and participation without materially delaying the City's consideration of the appeals.

12. Finally, a brief continuance would promote meaningful public notice, transparency, and participation in the City’s decision-making process. These appeals concern the permitting and licensing of the California City Detention Facility, a matter of significant public interest. The permit and business license at issue relate to one of the largest detention centers in the United States, likely to operate for at least fifteen years or more, with significant and long-term impact on city infrastructure including on roads, water, and emergency services. Providing only 7 business days’ notice between official notice and the hearing limits the ability of California City residents and other interested members of the public to learn of the hearing, review the relevant materials, arrange their schedules and other obligations, and prepare meaningful public comment. Sufficient public notice, transparency, and civic engagements are basic tenants of democracy. A continuance to one of the regularly scheduled City Council meetings identified above would provide additional time for public participation while causing only a brief delay in consideration of the appeals. Appellants are unaware of any statutory or other deadline requiring the Council to hear these appeals on August 25, 2026. Particularly where Appellants themselves are unable to attend on August 25 because of unforeseen medical circumstances that they communicated to the City before the hearing was set, the interests of fairness, transparency, and meaningful public participation favor a brief continuance.

Respectfully submitted,
Jehan Laner
Managing Attorney
Immigrant Legal Resource Center
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COUNCIL AGENDA ITEM
August 25, 2026
TO: Honorable Mayor and Members of the City Council
FROM: Anu Doravari, Planning Director
SUBJECT: Appeal of Planning Commission Decision - Site Plan Review No. SPR 25-09 PROJECT: California City Correctional Facility, 22844 Virginia Boulevard, APN 350-031-02 APPLICANT: CoreCivic, Inc.

APPELLANT: Immigrant Legal Resource Center / Dignity Not Detention Coalition

RECOMMENDATION
Staff recommends that the City Council:

1. Receive the staff report, public testimony, and the record materials submitted for the appeal;

2. Find that the Council’s action on the appeal does not approve new construction, expansion of the approved facility footprint, an increase in bed capacity beyond the existing entitlement record, or a new or modified conditional use; and

3. Adopt the attached draft resolution denying the July 9, 2026, appeal and upholding the Planning Commission’s July 7, 2026 decision sustaining SPR 25-09, as clarified by the findings and scope limitations in the resolution.

DECISION BEFORE THE COUNCIL
Under CCMC Sections 1-4.04 and 1-4.09(d), the Council hears the appeal de novo from the Planning Commission. Because the appealed decision granted an approval, the appellant bears the burden under CCMC Section 1-4.04(e) to support overturning the prior decision. Under CCMC Section 9-2.212(d), a site plan shall be approved if the application shows the site will be developed in accordance with the requirements of the Municipal Code. If the application demonstrates conformance, approval is mandatory, and neither the Planning Director, nor the Planning Commission, nor the Council has discretion to withhold it. The question is whether the appeal establishes a Planning or zoning basis to overturn SPR 25-09 for the existing facility.

THE APPEAL CHALLENGES:

1. Use: civil immigration detention is not an allowed O/RA use under CUP 97-01 and therefore requires a new CUP or separate code-interpretation process.

2. Site plan: SPR 25-09 should not have been approved because a newly prepared site-plan drawing was not submitted with the 2025 application.

3. 1998 expansion record: the Attorney General argues that the 1998 expansion amendment was tied to additional construction and cannot be used to support the existing facility configuration.

CITY RECORD - HOW STAFF GOT HERE

DATE CITY RECORD
JAN. 1998 CUP 97-01 approved the correctional facility at 22844 Virginia Boulevard.

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DATE CITY RECORD
NOV.-DEC. 1998 CCA applied to amend CUP 97-01 for an expansion. Planning Commission Resolution No. 11-98-02 states that the applicant sought to “expand the permitted use by 512 beds.” On
December 1, the City Council approved the amendment to CUP 97-01 and the related environmental findings.

OCT. 2009 The City Council adopted the Final General Plan 2009-2028. At page 5-15, the City identifies the same O/RA facility as a privately owned prison housing federal detainees awaiting deportation.

SEPT. 2010 The City Council approved the federal detention-services IGSA and the related CCA agreement. The City Manager advised Council that authorized agencies could include ICE and BOP. 2014 A City land-use review documented the facility’s then-existing operating configuration. The State Fire Marshal later issued a Certificate of Occupancy for the entire facility as I-3 institutional occupancy.
2025-2026 SPR 25-09 concerned the existing physical plant and proposed no new construction or replacement site layout. The Planning Director approved SPR 25-09 on February 26, 2026; the
Planning Commission denied the appeal on July 7, 2026.

STAFF ANALYSIS

1. Existing use / claimed need for a new CUP
CCMC Section 9-2.402(p) allows governmental or quasi-governmental correction, probation, or prison facilities and services in the RA District with a conditional use permit. CUP 97-01 is the site-specific CUP for this prison facility. Planning determined that the federal detention operation described in SPR 25-09 remains within the existing correctional/prison-facility use authorized by CUP 97-01. SPR 25-09 is a Minor Site Plan Review for an existing building, business, and ownership. SPR 25-09 did not create a new landuse category or approve new development.

The City’s own later record is consistent with that treatment. The Council-adopted 2009 General Plan identifies this same O/RA facility as a prison housing federal detainees awaiting deportation, and the 2010 Council record documents City approval of federal detention services that could include ICE and BOP.

Staff relies on those City records as historical land-use context, not as amendments to CUP 97-01 or the zoning code.

2. Site-plan record
CCMC Section 9-2.212 requires site-plan information as part of the administrative review. SPR 25-09 involved an existing facility and proposed no physical site change. It proposed no new construction, no ground disturbance, no expansion of the approved footprint, and no change to the site layout. Planning reviewed the application together with historical site-layout and entitlement materials maintained in the NB 2

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City project record because the application proposed no change to the physical site layout. The historical record includes the 1998 CUP-amendment application, which expressly refers to an attached site plan, and a 2017 conceptual site plan that labels and depicts the existing approximately 70-acre facility. SPR 25-09 did not approve a new site layout or construction plan.

3. 1998 expansion record / existing configuration
The original CUP approved the facility in 1998. Later that year, the City approved an amendment to CUP 97-01 for a 512-bed expansion. These CUPs run with the land. The associated Initial Study describes a specific housing-unit/support-building expansion. The Attorney General argues that the later amendment cannot be used to establish additional capacity within the buildings that exist today.

That historical construction question does not need to be resolved broadly to decide this SPR. The operative 2025 business plan describes the facility as it exists today, and SPR 25-09 requested no construction, grading, additional detention housing, or expansion of the developed footprint. Staff therefore recommends that Council decide only whether the administrative SPR for the existing facility should stand, without independently authorizing any unbuilt portion of the 1998 expansion or any additional physical capacity.

4. Approval was mandatory
Section 9-2.212 commits site plan review to the Planning Director. Subsection (d) then removes the discretion the appeal assumes exists: the site plan “shall” be approved if the application shows the site will be developed in accordance with the requirements of the Municipal Code.

On this record, Section 9-2.212(d) required approval.

BURDEN OF PROOF
Under Section 1-4.04(e), because this appeal challenges an approval that issued, Appellant bears the burden of proof and must support overturning the prior decision by a preponderance of the evidence. The Council need not find affirmatively that the Planning Director was right. Appellant must show the Planning Director was wrong: that the application failed to demonstrate Municipal Code conformance on February 26, 2026.

THE GROUNDS FOR APPEAL DO NOT SHOW THAT THE APPROVAL WAS WRONG Appellant contends the Municipal Code does not expressly allow civil immigration detention, so the use is unclassified and unentitled.

The premise fails on the text. Section 9-2.402 speaks in broad categorical terms: governmental or quasigovernmental correction, probation, or prison facilities and services. A secure detention facility operated under contract with federal agencies sits comfortably inside those categories, as it has since the facility’s first contract with the U.S. Marshals Service. The legal status of the persons detained (criminal inmates or civil detainees) changes nothing about the facility’s function, form, footprint, or impacts. The building is the same building and its purpose-built nature means it can only function in one way; the operation is the operation the CUPs studied and approved.

The premise also fails on the record. CUP 97-01 and CUP 98-02 authorized this use at this site nearly 30 years ago, after public hearings and full CEQA review. Those permits run with the land and remain valid absent revocation. SPR 25-09 did not classify a use. It implemented an existing entitlement.

Appellant also argues that any ambiguity about whether the Code covers civil detention had to be resolved through the City’s code-interpretation procedure before SPR 25-09 could issue. Section 9-2.103 supplies a procedure for resolving genuine ambiguity about uses the Code does not address. It is not a mandatory process for uses the Municipal Code does address and the City has already permitted. There is no ambiguity to resolve. And a third party cannot compel this process and suspend ministerial approval.

CORRESPONDENCE RECEIVED
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Two documents arrived shortly before the hearing. Both are attached and are part of the record for this item. Each addresses this appeal and the companion SPR 25-09 appeal together.

Counsel for Appellants submitted a ‘motion’ to continue the August 25, 2026 hearing on both appeals to September 22, October 13, or October 27, 2026. The motion states that medical issues prevent counsel from personally appearing on August 25, and argues that the electronic notice given on August 14, 2026 does not satisfy CCMC Section 1-4.04 or the requirement in Section 1-4.08 that notice be given in the same manner as notice for the hearing below. The motion asks the Council to set a continued date.

Counsel for CoreCivic also submitted a combined response opposing both appeals, with nine exhibits, including declarations from CoreCivic personnel and the City Planner, the 2025 application submissions and business plan, and the July 2, 2026 general warranty deed conveying the facility to the United States.

CoreCivic argues that neither Appellant is an affected person entitled to appeal under CCMC Sections 1-

4.02(a) and 1-4.04(a); that federal ownership and the Supremacy Clause bar the relief the appeals seek; and that each of the six grounds fails on the merits. Staff’s recommendation rests on the grounds set out in this report. It does not depend on CoreCivic’s standing arguments, and staff takes no position on them here.

CEQA
Planning treated SPR 25-09 as a ministerial administrative approval under CEQA Guidelines Section 15268. The SPR applied objective City standards to an existing facility and authorized no new construction, grading, expanded developed footprint, additional detention housing, or replacement site layout. The prior environmental documents remain part of the historical entitlement record; SPR 25-09 did not amend those physical projects.

CONCLUSION AND RECOMMENDED MOTION
The City’s record shows an existing correctional facility approved by CUP in 1998, a later expansion amendment, a Council-adopted 2009 General Plan documenting federal detainees awaiting deportation at the same O/RA prison facility, and a 2010 Council-approved federal detention arrangement that could include ICE and BOP. SPR 25-09 did not create a new facility, change the site layout, or approve physical expansion. Staff recommends denial of the appeal.

Recommended motion: I move to adopt Resolution No. 26-0825 denying the appeal and upholding the Planning Commission’s July 7, 2026 decision sustaining SPR 25-09, subject to the scope limitations stated in the resolution.

ATTACHMENTS

1. Draft City Council Resolution No. 26-0825.

2. Appeal Record: February 27, 2026 DNDC Appeal to the Planning Commission; July 7, 2026 Planning Commission Staff Report and final meeting minutes; and July 9, 2026 City Council Appeal.

3.SPR 25-09 Planning Director Determination dated February 26, 2026.

4. Controlling Entitlement Record: CUP 97-01, CUP Amendment 98-02, and December 1, 1998 City Council action on the amendment.

5. City Historical Land-Use Record: Final General Plan 2009-2028 (adoption page and p. 5-15), September 21, 2010 City Council minutes, and 2017 historical site-layout drawing.

6. June 15, 2026 California Attorney General comment letter (letter only; duplicate exhibits omitted).

7. Appellants’ Motion for Continuance of August 25, 2026 Appeal Hearing, dated August 19, 2026 NB 2

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8. CoreCivic, Inc. combined response in opposition to the applications for appeal, dated August 20, 2026, with Exhibits 1 through 9
NB 2

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ATTACHMENT 1
DRAFT RESOLUTION NO. 26-0825

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CALIFORNIA CITY DENYING THE APPEAL OF THE PLANNING COMMISSION DECISION UPHOLDING SITE PLAN REVIEW NO. SPR 25-09 FOR THE CALIFORNIA CITY CORRECTIONAL FACILITY AT 22844 VIRGINIA BOULEVARD WHEREAS, the California City Correctional Facility at 22844 Virginia Boulevard is an existing correctional facility located on property zoned O/RA and subject to Conditional Use Permit No. 97-01, approved in January 1998 for a prison facility; and
WHEREAS, in 1998 Corrections Corporation of America applied to amend CUP 97-01 for an expansion, and the City subsequently approved that amendment and its related environmental findings; and WHEREAS, the City Council adopted the Final General Plan 2009-2028 on October 6, 2009, which identifies the same O/RA facility as a privately owned prison housing federal detainees awaiting deportation, and on September 21, 2010 the Council approved federal detention-service agreements after being advised that authorized federal users could include ICE and BOP; and WHEREAS, the City’s later land-use record and the operative SPR 25-09 business plan describe the existing physical and operational configuration of the facility; and WHEREAS, on August 22, 2025, CoreCivic, Inc. submitted SPR 25-09 using the City’s Minor Site Plan Review application for an existing building/business/ownership, and the application did not request new construction, grading, additional detention housing, expansion of the developed facility footprint, or a replacement site layout; and
WHEREAS, on February 26, 2026, the Planning Director approved SPR 25-09 as a ministerial administrative review of the existing facility; and
WHEREAS, the Planning Commission denied an appeal of SPR 25-09 on July 7, 2026, and the Immigrant Legal Resource Center and Dignity Not Detention Coalition filed a further appeal to the City Council on July 9, 2026; and
WHEREAS, pursuant to CCMC Sections 1-4.04 and 1-4.09(d), the City Council considered the appeal de novo, and under CCMC Section 1-4.04(e) the appellant bears the burden to support overturning the prior approval.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF CALIFORNIA CITY DOES HEREBY RESOLVE AS FOLLOWS:

SECTION 1. RECITALS AND RECORD.

The foregoing recitals are true and correct and are incorporated into this Resolution. The Council’s decision is based on the administrative record before it, including the staff report and attachments for this appeal.

SECTION 2. SCOPE OF COUNCIL ACTION.

This Resolution concerns only the appeal of SPR 25-09 and the existing approximately 70-acre correctional facility. It does not approve new construction, grading, additional detention housing, expansion of the developed facility footprint, a replacement site layout, or a new or modified conditional use. Nothing in this Resolution independently authorizes additional physical capacity or construction.

SECTION 3. FINDINGS ON THE APPEAL.

A. Existing land use. Council determines that the federal detention operation described in SPR 25-09 remains within the existing correctional/prison-facility use authorized by CUP 97-01 and does not require a new CUP on the record before the Council. The Council-adopted 2009 General Plan and the 2010 Council-approved federal detention arrangement document the City’s historical treatment of federal detention at this same facility. This Resolution does not create a new zoning category.

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B. Site-plan record. SPR 25-09 proposed no physical site change. Planning reviewed the existing facility using historical site-layout and entitlement materials in the City project record. The appeal does not establish a basis to overturn the administrative SPR solely because a newly prepared site-layout drawing was not submitted where no physical layout change was proposed. This finding does not approve a new site layout or construction plan.

C. 1998 expansion record. The City record includes CUP 97-01 and the later 1998 expansion amendment. The associated Initial Study describes a specific housing-unit/support-building expansion. SPR 25-09 concerns the facility as it exists today and requests no new construction or expansion. The Council therefore need not determine the full numerical capacity authorized by the combined 1998 approvals or whether any unbuilt portion of the 1998 expansion is physically present. This Resolution does not independently authorize additional physical capacity or construction.

D. Burden on appeal. Considering the record as a whole, the appellant has not met the burden under CCMC Section 1-4.04(e) to establish a Planning or zoning basis to overturn SPR 25-09 within the limited scope stated in this Resolution.

SECTION 4. CEQA.

SPR 25-09 is a ministerial administrative approval exempt from the California Environmental Quality Act pursuant to CEQA Guidelines Section 15268. The action applies objective City standards to an existing facility and does not authorize new construction, grading, expansion of the developed footprint, additional detention housing, or a replacement site layout.

SECTION 5. DECISION.

The City Council denies the July 9, 2026 appeal and upholds the Planning Commission’s July 7, 2026 decision sustaining SPR 25-09, as clarified by the express scope limitations and findings stated in this Resolution. The Council does not independently authorize additional physical capacity, construction, or an unbuilt portion of the 1998 expansion.

SECTION 6. EFFECTIVE DATE AND NOTICE.

This Resolution shall take effect immediately upon adoption. The City Clerk is directed to provide notice of the Council’s decision in accordance with applicable City procedures.

PASSED, APPROVED AND ADOPTED this 25th day of August 2026, by the following vote:

AYES: ________________________________________________
NOES: ________________________________________________
ABSENT: ________________________________________________ ABSTAIN: ________________________________________________ __________________________________
Marquette Hawkins, Mayor
ATTEST:
__________________________________
City Clerk
APPROVED AS TO FORM:
__________________________________
City Attorney
February 27, 2026
U.S. mail and electronic transmittal
City of California City
City Hall
21000 Hacienda Blvd.

California City, CA 93505
To Mayor Hawkins, Members of the City Council, Members of the Planning Commission, Interim City Manager Grayson, City Attorney Ponto, and City Clerk, On behalf of the Dignity Not Detention Coalition, I write to appeal the decision by California City to approve a business license, site plan review, and all related approvals to CoreCivic, Inc. for the operation of the California City Detention Facility, 22844 Virginia Blvd., California City, CA. This appeal is brought pursuant to sections 1-4.04, 1-4.05, and 9-2.212(b) of the California City Municipal Code (CCMC). The grounds for appeal are outlined below. • The Business License, Site Plan Review, and all related approvals are not in conformance with the City’s zoning for the facility. See CCMC § 9-2.803(a). • The facility’s zoning does not on its face allow civil immigration detention facilities.

CCMC §§ 9-2.401, 9-2.402. Under the Municipal Code, any uses not expressly allowed within a zoning district are prohibited. CCMC § 9-2.102(b). • Even if the facility’s zoning district could allow civil immigration detention as a use similar to a “prison”, whether it in fact does is ambiguous. The Municipal Code mandates that the Planning Commission and City Council resolve any ambiguities in interpreting the Code to allow uses not expressly permitted. CCMC § 9-2.103. The Council must make such determination before any Business License, Site Plan Review, or other permit for the facility may issue.
• Even if civil immigration detention is conditionally allowed in the facility’s zoning district, then the converted facility still requires a Conditional Use Permit, including notice, public hearings, and public right of appeal. CCMC §§ 9-2.2501, 1-4.02(a). • The City is prohibited from issuing a business license to CoreCivic because CoreCivic has been violating the Code by operating the facility without a license. The Code states that the City “shall” revoke or suspend a license if the licensee is violating the provisions of the business license chapter, which also includes the requirement that a business cannot operate without a license. CCMC §§ 1-3.01(a)(1), 9-2.2803(b), 9-2.2804(c), 3-

2.3.201.
• Similarly, the Code provides that a license “shall be” suspended, cancelled, or revoked if the licensee has “[f]ailed to observe . . . the laws of the State” or has “[w]illfully or knowingly permitted violations of . . . the laws of the State.” CCMC § 3-2.3.208(c)(4), (6). As set forth in the federal lawsuit pending against the federal government regarding conditions at the facility, CoreCivic has engaged in and knowingly facilitated numerous, egregious violations of state and federal law. See Gomez Ruiz v. ICE, Case No. 3:25-cv09757 (N.D. Cal.; filed Nov. 12, 2025). Because these violations would require the City to automatically suspend or terminate any existing business license, they should preclude the City from issuing CoreCivic a business license for the facility in the first instance.

A check for the $381.00 appeal fee, pursuant to the City’s current fee schedule, has been mailed to the City Clerk. Please provide notice of any appeal hearing once the date and time are set.

CCMC § 1-4.08. If this appeal will be decided without a hearing, please provide the date of the anticipated decision and immediate notice of the appeal body’s determination so that we may exercise any further appeal rights to which we are entitled by law.

Sincerely,
Jehan Laner
Senior Staff Attorney
Immigrant Legal Resource Center
cc: Brandon Sanchez
2031489.2

PLANNING COMMISSION
Staff Report
July 07, 2026
TO: Honorable Chair and Members of the Planning Commission FROM: Anu Doravari, Planning Director
SUBJECT: Appeal of Planning Director Approval of Site Plan Review No. SPR 25-09 for the California City Correctional Facility, 22844 Virginia Boulevard, APN 350-031-02
APPLICANT: CoreCivic, Inc.

APPELLANT: Dignity Not Detention Coalition
REQUEST: Consider the appeal and determine whether to uphold the Planning Director's February 26, 2026 approval of SPR 25-09 as issued.

RECOMMENDATION
Staff recommends that the Planning Commission:

1. Receive the staff report, public testimony, and record materials submitted for the appeal;

2. Find that the appellant failed to meet the required burden of proof to overturn the Planning Director’s approval of SPR 25-09 and find that the Planning Commission’s action on the appeal does not approve new construction, expansion, an increase in bed capacity beyond the existing entitlement record, or a new or modified conditional use; and

3. Adopt Resolution No. PC 2026-07-07 denying the appeal and upholding the Planning Director’s February 26, 2026 approval of SPR 25-09 as issued.

Recommended motion: I move to adopt Resolution No. PC 2026-07-07 denying the appeal and upholding the Planning Director’s February 26, 2026 approval of SPR 25-09 as issued.

EXECUTIVE SUMMARY
SPR 25-09 concerns the California City Correctional Facility at 22844 Virginia Boulevard. The application was submitted on the City’s Minor Site Plan Review application form for an existing building/business/ownership and is dated August 22, 2025. The operative business plan submitted with the application describes the facility as owned and operated by CoreCivic, Inc., opened in 1999, and expected to operate in the same manner it has since construction.

CoreCivic SPR 25-09 Appeal
The Planning Director issued a determination letter on February 26, 2026, approving SPR 25-09. The determination was based on the City’s existing entitlement record— including Conditional Use Permit (CUP) 97-01, CUP 98-02, and the CEQA Transmittal Addendum No. 1 2014.pdf—the associated environmental record, application materials, and applicable Municipal Code provisions. The determination letter states that the approval implements CUP 97-01 and CUP 98-02, reflects a maximum vested entitlement capacity of 2,816 beds, applies to the previously approved 70-acre facility footprint, and does not authorize any expansion or modification of the approved project.

Dignity Not Detention Coalition initiated its appeal of the Site Plan Review approval on February 27, 2026. This staff report addresses the Site Plan Review appeal before the Planning Commission under standard California land-use frameworks. Business licensing and contract matters are administered through separate City procedures and are outside the purview of this land-use evaluation.

Based on the complete administrative and environmental record, staff recommends that the Planning Commission deny the appeal and uphold the February 26, 2026, SPR 25- 09 approval as issued.

APPLICATION MATERIALS AND REVIEW BACKGROUND
SPR 25-09 was submitted as a Minor Site Plan Review application for an existing building/business/ownership. The application materials did not request new construction, expansion of the approved facility footprint, ground disturbance, or changes to the approved site layout. No new site plan was submitted for SPR 25-09.

Staff reviewed the application based on the existing entitlement record, City records on file, the operative business plan, and applicable Municipal Code requirements.

The operative business plan describes the California City Correctional Facility as a 2,560-bed facility with an approximately 522,363 square foot physical plant. The Planning Director’s determination letter identifies the entitlement record as CUP 97-01 for 2,304 beds and CUP 98-02 for an additional 512 beds, for a total authorized entitlement capacity of 2,816 beds. Because the applied-for operational capacity of 2,560 beds remains well below the maximum authorized capacity, SPR 25-09 did not approve any expansion or increase beyond the historical entitlement record.

The determination letter also states that the facility satisfied all objective requirements of the Building & Safety Division and Fire Department.

CoreCivic SPR 25-09 Appeal

ENTITLEMENT RECORD
Approval /
Record Summary Relevance to SPR 25-09
CUP 97-01 / PC
Resolution No.
01-98-1802
Approved a conditional use
permit for a 2,304-bed
prison facility on
approximately 70 acres and
adopted a Mitigation
Monitoring Program.

Establishes the original
conditional use entitlement
and identifies site plan review,
utility connection, and
Municipal Code compliance
obligations.

CUP 97-01 / CC
Resolution No.
01-98-1801
Certified the Final EIR
Supplement / CEQA
findings for the 2,304-bed
prison project and
approved the project
following Planning
Commission action.

Establishes the City Council
approval and prior CEQA
record for the original facility.

CUP 98-02 /
Resolution No.
11-98-02
Approved modification of
CUP 97-01 for a 512-bed
expansion and affirmed
CUP 97-01 except as
provided in that resolution.

Supports the determination
that the combined entitlement
record reflects a maximum
authorized capacity of 2,816
beds.

CEQA
Transmittal
Addendum No.
1 2014.pdf
Documented and filed a
CEQA Notice of
Determination (NOD) on
June 9, 2014, for a 256-bed
internal repurposing of the
facility structure.

Formally establishes that the
environmental impacts of a
2,560-bed operational
configuration within the
existing facility footprint have
been fully evaluated, cleared,
and mitigated.

Prior CEQA
documents and
adopted
mitigation
programs
The facility and correctional
use were evaluated
through the EIR
Supplement (CUP 97-01),
the MND (CUP 98-02), and
Addendum No. 1 (2014).

Existing adopted mitigation
programs remain enforceable
according to their own terms.

SPR 25-09 did not alter
or adopt new mitigation
measures.

MUNICIPAL CODE FRAMEWORK
CoreCivic SPR 25-09 Appeal
• CCMC Section 9-2.212 (Site Plan Review): applications are filed with the Planning Director. The Planning Director reviews the proposal to determine whether it satisfies the requirements of the section. The section explicitly mandates that the site plan shall be approved if the application shows the site conforms to existing Municipal Code requirements.
• CCMC Section 9-2.402 (RA District Conditional Uses): "Governmental or quasi-governmental correction, probation or prison facilities and services" may be permitted in the RA District with a conditional use permit. • CCMC Section 9-2.103 (Code Interpretation): Establishes guidelines for interpreting general code language. SPR 25-09 was reviewed under the existing entitlement record and the listed RA conditional-use category; it was not processed as a new citywide code interpretation or a new conditional use permit.

SCOPE OF THE APPEAL BEFORE THE PLANNING COMMISSION
The item before the Planning Commission is the appeal of the Planning Director’s approval of SPR 25-09 under CCMC Section 9-2.212.

Under California zoning law, when a local code utilizes mandatory phrasing such as "shall be approved," the review is strictly ministerial (non-discretionary) once objective conformity is demonstrated. CCMC Section 9-2.212(d) explicitly removes discretionary authority from the Planning Director, stating that the “site plan shall be approved if application shows the site will be developed in accordance with the requirements of the Municipal Code.”
The Planning Commission’s review is strictly limited to whether the application demonstrates conformance with the Municipal Code per CCMC Section 9-2.212(d). This appeal hearing is not a revocation proceeding for CUP 97-01 or CUP 98-02, nor is it a public hearing for a new conditional use permit. Under California's vested rights doctrine, long-standing entitlements cannot be retroactively extinguished or readjudicated through a ministerial site plan compliance check.

PROCEDURE OF THE APPEAL
The appeal hearing before the Planning Commission is considered de novo under CCMC Section 1-4.04(d). This means that the Planning Commission is not bound by the decision of the Planning Director. The appeal hearing shall be based on the following evidence:
(1) Any relevant evidence, including staff reports, etc., submitted at the time of the prior decision and at the appeal hearing; and
(2) Findings, if any, and decision of the Planning Director, but the Planning Commission shall not be bound by the findings and decisions of the original decision being appealed.

BURDEN OF PROOF AT THE APPEAL HEARING
CoreCivic SPR 25-09 Appeal
Under CCMC Section 1-4.04(e), the appellant, Dignity Not Detention Coalition, has the burden of proof to support the overturning of the Planning Director’s decision on SPR 25-09.

MINOR SPR PROCESSING AND DIRECTOR HEARING
SPR 25-09 was properly submitted on the City’s Minor Site Plan Review application form because it applies strictly to an existing building with no physical modifications.

The application did not propose new construction, new ground disturbance, expansion of the approved facility footprint, or modifications to the existing site layout.

While the Planning Department utilizes Director Hearings for projects involving active discretionary reviews or major site design alterations, CCMC Section 9-2.212 does not require a formal public hearing for an administrative verification of an existing, approved structure.

NO NEW SPR CONDITIONS
SPR 25-09 did not impose new discretionary Planning conditions, did not adopt new mitigation measures, and did not modify CUP 97-01 or CUP 98-02. The approval simply recognizes that the facility remains bound by its existing entitlement record, previously adopted environmental documents, and active mitigation programs. Any compliance review or enforcement related to those existing obligations remains completely separate from this limited SPR approval.

APPEAL ISSUES AND STAFF REVIEW
Appeal Issue Staff Land Use Review
Zoning / Use
Classification
CCMC Section 9-2.402 explicitly identifies “[g]overnmental or quasi-governmental correction, probation or prison facilities and services” as a conditional use in the RA District. The existing entitlement record includes CUP 97-01 and CUP 98-

02. Under standard California planning practices, land-use classifications track the physical characteristics, structural demands, and impacts of a facility (e.g., Institutional Group I3 occupancy), not the specific demographics or civil/criminal status of the occupants. The facility remains a secured correction/detention facility and falls squarely within the broad categorical language of the CCMC and the existing CUPs.

Civil Immigration
Detention /
The appellant asserts that civil immigration detention
represents a separate use category requiring a new CUP.

However, the City has historically interpreted this land-use CoreCivic SPR 25-09 Appeal
Appeal Issue Staff Land Use Review
"Change of Use"
Argument
classification to encompass federal civil detainees, notably during the facility's operations under the 2010–2013
Intergovernmental Service Agreement (IGSA). Furthermore, the certified CEQA Transmittal Addendum No. 1 2014.pdf
explicitly cleared the "repurposing" of internal bed
configurations up to 2,560 beds within the existing structure.

Shifting the supervising agency contract between state and federal authorities does not alter the physical land-use footprint or generate distinct zoning impacts.

New Conditional
Use Permit
Requirement
Because SPR 25-09 requested no new construction, zero
ground disturbance, and no increase in bed capacity beyond the established 2,816-bed entitlement, no triggers for a new or modified CUP have occurred. Any future proposal to
physically expand the development footprint or exceed the 2,816-bed limit would legally require a separate discretionary CUP amendment and subsequent CEQA review.

CEQA
Compliance
Under California Public Resources Code § 21080(b)(1)
CEQA Guidelines Section 15268, and CCMC Section 2-

6.303(b)(2), ministerial actions are entirely exempt from CEQA. Because the Planning Director was legally mandated by CCMC Section 9-2.212(d) to approve the site plan upon demonstration of code conformity, the action involves no discretionary balancing of environmental options.

Furthermore, the physical facility and its 2,560-bed
operational ceiling were already fully analyzed under the certified EIR Supplement (CUP 97-01), the MND (CUP 98-
02), and CEQA Transmittal Addendum No. 1 2014.pdf.

FINDINGS SUPPORTING RECOMMENDED ACTION

1. SPR 25-09 was submitted as a Minor Site Plan Review application for an existing building/business/ownership and is dated August 22, 2025.

2. The City’s Site Plan Review process ensures that development of an approved use conforms to Municipal Code standards for site design, infrastructure, and improvements.

3. The application materials did not request new construction, expansion of the approved facility footprint, ground disturbance, or modification to the approved site layout.

CoreCivic SPR 25-09 Appeal

4. The operative business plan states that the facility opened in 1999, is owned and operated by CoreCivic, and is expected to operate in the same physical manner it has since it was constructed.

5. CUP 97-01 approved a 2,304-bed prison facility on approximately 70 acres at the project site.

6. CUP 98-02 approved a 512-bed expansion and affirmed CUP 97-01, establishing a combined entitlement capacity of 2,816 beds.

7. The facility's operational configuration of 2,560 beds was explicitly evaluated and cleared under CEQA Transmittal Addendum No. 1 2014.pdf, which concluded that internal bed repurposing within the existing structure generates no new significant environmental impacts.

8. CUP 97-01 and CUP 98-02 run with the land and remain valid, active entitlements absent a formal, separate revocation proceeding.

9. CCMC Section 9-2.402 allows governmental or quasi-governmental correction, probation, or prison facilities and services in the RA District with a conditional use permit.

10.The Planning Director’s approval of SPR 25-09 did not impose new discretionary conditions, adopt new mitigation measures, or modify the underlying vested CUPs.

11.Because SPR 25-09 demonstrated compliance with objective Municipal Code requirements, approval was mandatory under the ministerial command of CCMC Section 9-2.212(d).

12.The appeal materials do not identify an objective basis under CCMC Section 9-

2.212 to set aside the February 26, 2026, SPR 25-09 approval.

ATTACHMENTS

1. Planning Commission Resolution No. PC 2026-07-07

2. Combined Administrative Record for SPR 25-09 Appeal
The combined record can include:
• Planning Director Determination Letter
• Appeal Letter
• SPR Application Materials
• Business Plan / Operational Information
• CUP 97-01 Record
• CUP 98-02 Record
• Prior CEQA Documents
• 2014 CEQA Addendum / NOD Materials
• Building, Fire, and Occupancy Materials
• DOJ Correspondence
• Prior agenda/hearing materials
• Record exhibits
CoreCivic SPR 25-09 Appeal
ATTACHMENT 1:

PLANNING COMMISSION RESOLUTION NO. PC 2026-07-07

A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF CALIFORNIA

CITY DENYING THE APPEAL FILED BY THE DIGNITY NOT DETENTION COALITION AND UPHOLDING THE PLANNING DIRECTOR'S FEBRUARY 26, 2026 APPROVAL OF SITE PLAN REVIEW NO. SPR 25-09 AS ISSUED FOR THE CALIFORNIA CITY CORRECTIONAL FACILITY LOCATED AT 22844 VIRGINIA BOULEVARD, APN 350-031-02
WHEREAS, CoreCivic, Inc. submitted Site Plan Review No. SPR 25-09 for the California City Correctional Facility located at 22844 Virginia Boulevard, APN 350-031- 02; and
WHEREAS, SPR 25-09 was submitted on the City's Minor Site Plan Review application form for an existing building/business/ownership and is dated August 22, 2025; and WHEREAS, the operative business plan describes the facility as owned and operated by CoreCivic, opened in 1999, and expected to operate inside the same physical plant footprint since construction; and
WHEREAS, the project site is subject to Conditional Use Permit No. 97-01, approved for a 2,304-bed facility, and Conditional Use Permit No. 98-02, approved for an additional 512 beds, representing a total authorized capacity of 2,816 beds; and WHEREAS, the proposed operational scale of 2,560 beds was formally evaluated, cleared, and certified under CEQA Transmittal Addendum No. 1 2014.pdf, with a Notice of Determination properly filed with the Kern County Clerk on June 9, 2014; and WHEREAS, the Planning Director issued a determination letter dated February 26, 2026, finding that SPR 25-09 satisfies all objective Municipal Code requirements; and WHEREAS, the Dignity Not Detention Coalition submitted an appeal dated February 27, 2026; and
WHEREAS, the Planning Commission considered the staff report, the appeal materials, the entitlement record, the prior CEQA record, applicable Municipal Code provisions, and public testimony at a regular meeting.

NOW, THEREFORE, THE PLANNING COMMISSION OF THE CITY OF CALIFORNIA CITY DOES HEREBY RESOLVE AS FOLLOWS:

SECTION 1. RECITALS. The foregoing recitals are true and correct and are incorporated herein by this reference.

CoreCivic SPR 25-09 Appeal
SECTION 2. SCOPE OF ACTION. The action before the Planning Commission is strictly limited to the appeal of the Planning Director's approval of SPR 25-09 under CCMC Section 9-2.212. This Resolution does not authorize or approve new construction, physical expansion of the facility footprint, an increase in bed capacity beyond the existing entitlement record, or a new or modified conditional use.

SECTION 3. CEQA FINDINGS. The Planning Commission hereby affirms that SPR 25- 09 is exempt from the California Environmental Quality Act pursuant to CEQA Guidelines Section 15268 (Ministerial Projects). The approval is a non-discretionary action limited to the verification of compliance with objective Municipal Code standards.

The Commission further finds that the environmental impacts of the 2,560-bed configuration within the existing structural footprint were fully analyzed and mitigated under CEQA Transmittal Addendum No. 1 2014.pdf, and no triggers for a subsequent or supplemental EIR exist under CEQA Guidelines Section 15262.

SECTION 4. LAND USE FINDINGS.

1. SPR 25-09 applies strictly to an existing building/business/ownership and is dated August 22, 2025.

2. The application materials requested zero new construction, zero ground disturbance, and no expansion of the approved facility footprint.

3. CUP 97-01 and CUP 98-02 establish a combined, valid land-use entitlement capacity of 2,816 beds on the project site, which runs with the land and remains unrevoked.

4. CCMC Section 9-2.402 explicitly permits “governmental or quasi-governmental correction, probation or prison facilities and services” in the RA District via a CUP. The physical land-use impacts of the facility are consistent across federal and state operational contracts, and the current use falls squarely within this approved zoning category.

5. Under CCMC Section 9-2.212(d), site plan approval is mandatory if the application demonstrates conformance with existing code standards. Because the application satisfies all objective Planning, Building, and Fire standards, the Planning Director possessed no discretionary authority to deny the application.

The appeal record provides no objective legal or land-use basis under the CCMC to set aside the approval.

SECTION 5. DECISION. The Planning Commission hereby denies the appeal filed by the Dignity Not Detention Coalition and upholds the Planning Director's February 26, 2026, approval of SPR 25-09 as issued.

SECTION 6. EFFECTIVE DATE. This Resolution shall become effective immediately upon adoption.

PASSED, APPROVED, AND ADOPTED by the Planning Commission of the City of California City at a regular meeting held on July 7, 2026, by the following vote:

CoreCivic SPR 25-09 Appeal
ATTEST:
____________________________________
Planning Secretary/City Clerk

STATE OF CALIFORNIA )
COUNTY OF KERN ) ss.

CITY OF CALIFORNIA CITY )
I, ____________________________, City Clerk of the City of California City, do hereby certify that the foregoing Resolution was duly adopted by the Planning Commission at a regular meeting held on July 7, 2026, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:
____________________________________
City Clerk

CITY OF CALIFORNIA CITY

PLANNING COMMISSION MEETING MINUTES
July 7, 2026

CALL TO ORDER
Chair Brottlund called the meeting to order at 6:02 p.m.

PLEDGE OF ALLEGIANCE AND INVOCATION
Pledge of Allegiance led by Chair Brottlund; invocation by Pastor Rob Troutman.

ROLL CALL

Present: Chair Brottlund; Commissioner Cantrell; Commissioner Coleman; Commissioner Perez.

Commissioner Perez was sworn in.

MOTION CARRIED 4-0 TO APPOINT COMMISSIONER COLEMAN AS VICE CHAIR.

MOTION CARRIED 3-1 TO ESTABLISH A TWO-MINUTE PUBLIC COMMENT LIMIT (BROTTLUND, COLEMAN, PEREZ - YES; CANTRELL - NO).

ADOPT THE AGENDA
MOTION CARRIED 4-0 TO ADOPT THE AGENDA.

DISCLOSURE OF SITE VISITS AND EX-PARTE CONTACTS
Commissioners Brottlund, Perez and Cantrell reported no site visits. Vice Chair Coleman disclosed visiting the exterior of the subject site.

PUBLIC BUSINESS FROM THE FLOOR
Public comment was received. No action taken.

CONSENT CALENDAR
None.

PUBLIC HEARING
PH 1. Appeal of Planning Director Approval of Site Plan Review No. SPR 25-09 - California City Correctional Facility, 22844 Virginia Boulevard, APN 350-031-02
MOTION TO CONTINUE THE HEARING FOR 30 DAYS FAILED ON A 2-2 VOTE (CANTRELL, COLEMAN - YES; BROTTLUND, PEREZ - NO).

Staff Report: Planning Director Anu Doravari presented the item and recommended denial of the appeal and adoption of Resolution PC 2026-07-07.

The Commission received presentations from the appellant and applicant. Written and oral public comments were received.

Vice Chair Coleman was absent for the final action.

MOTION CARRIED 2-1 TO ADOPT RESOLUTION PC 2026-07-07, DENY THE APPEAL, AND UPHOLD THE PLANNING DIRECTOR'S APPROVAL OF SPR 25-09 (BROTTLUND, PEREZ - YES; CANTRELL - NO; COLEMAN - ABSENT).

DEPARTMENT REPORT
None.

COMMISSIONER COMMENTS
No action taken.

ADJOURNMENT
MOTION CARRIED 3-0 TO ADJOURN (BROTTLUND, CANTRELL, PEREZ - YES; COLEMAN - ABSENT).

Page 1 of 3 ends

Background:

On August 22, 2025, the facility applied for Site Plan Review approval “to operate in the same manner it has since it was constructed in 1999.”

CITY HALL
21000 Hacienda Blvd.

California City, CA 93505
______________________________________
760-373-8661
www.californiacity-ca.gov
Marquette Hawkins
MAYOR
Jim Creighton

MAYOR PRO TEM
Della Clark
Ronald Smith

COUNCIL MEMBERS
__________________
Sean Grayson

INTERIM CITY

MANAGER

Page 2 of 3 ends

Discussion:

Pursuant to California City Municipal Code (“CCMC”) section 9-2.212(b), the Planning Director reviews the proposal to determine whether it satisfies the requirements of this section. Section 9-

2.212(d), further provides that “The site plan shall be approved if application shows the site will be developed in accordance with the requirements of the Municipal Code.” As such, Section 9-

2.212 directs ministerial approval when the proposal demonstrates Municipal Code compliance.

The facility has satisfied the requirements of the Building & Safety Division and Fire Department.

CEQA Determination:

Planning Department Findings:

1. Implements CUP 97-01 and CUP 98-02 as reflected in the City’s entitlement record;

2. Reflects a maximum occupancy of 2,816 beds;

3. Applies solely to the previously approved 70-acre facility footprint (APN 350-031-02); and

Page 3 of 3 ends

4. References the previously certified environmental documents and adopted mitigation programs associated with CUP 97-01 and CUP 98-02.

CITY OF CALIFORNIA CITY
FINAL

GENERAL PLAN
2009-2028
Adopted by City Council
October 6, 2009
Resolution# 10-09-2359
SCH# 1992062069
City of California City
21000 Hacienda Boulevard
California City, CA 93505-2293
(760) 373-8661

ORIBI L
A RESOLUTION Of THE CITY COUNCIL
Of THE CITY Of CALIFORNIA CITY
ADOPTING GENERAL PLAN UPDATE 2009-2028
BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF CALIFORNIA CITY as follows:

1. Purposeand Scope.

This Resolution adopts the Generai Plan for 2009-2028.

2. Findings.

The City Council finds, determines and declares:
(a) The General Plan amendments described herein ("subject amendment'') will benefit the City, its residents and property;
(b) The subject amendment is otherwise consistent with the remainder of the General Plan and zoning regulations;
(c) The subject amendment will not be accompanied by any significant, adverse environmental impacts; and
(d) The subject amendment was considered as a duly noticed public meeting by the Planning Commission and by the City Council.

3. Amendment.

The General Plan for 2009-2028 is hereby amended as set forth on Exhibit "A", attached hereto and hereby incorporated by this reference.

AYES: Smith, Strong, Lessenevitch, Edmiston, A ams
NOES: None
ABSENT: None
ABSTAIN: None
CC\Reso\PH 1
XX:. PE:O"o:. TIH 1

4. Citywide California City General Plan, Environmental Impact Report, incorporated by reference, (SCH #1992062069), General Plan Update 2012.

5. Villages Specific Plan, incorporated by reference, The Villages of California City Supplemental Environmental Impact Report, April 1993 (SCH #1992072089) amending the 2028 City of California City Redevelopment Plan and Project Area Environmental Impact Report (SCH #1987110918), known as the first amendment. Documents are on file in the California City Planning Dept., 21000 Hacienda Blvd., California City. The Villages Specific Plan, approved in April 1993 is 500 acres located in the central core of California City with access to infrastructure for recreational, residential, government, medical, and regional commercial development. Bound on the north by North Loop Boulevard, on the east by Randsburg-Mojave/California City Boulevard, on the South by South Loop Boulevard and on the west by Hacienda Boulevard.

6. Corrections Corporation of America (CCA) at 22844 Virginia Boulevard, California City, California, incorporated by reference, Environmental Impact Report (SCH #1993082030 and SEIR 1997091045) . Documents are on file in the California City Planning Dept., 21000 Hacienda Blvd., California City. California City has within its jurisdictional boundaries a minimum security, privately owned and operated prison by Corrections Corporation of America (CCA) at 22844 Virginia Boulevard, California City, California. The California City Correctional Facility houses over 2,300 Federal detainees awaiting deportation. The overall site is 320 acres and zoned open space/residential agricultural (O/RA), of which there is a 105-acre footprint that incorporates the existing 70-acre facility and an additional 35 acres for future expansion. This 105-acre footprint has received all of its environmental approvals.

7. Annexation/Detachment #5, incorporated by reference 2002Final Environmental Impact Report Redevelopment Area Expansion, Detachment, Annexation and Automotive Test Course Project, Volume III, October 4, 2002, (SCH #2002041025). This report incorporates Clarifications and Revisions to the Draft EIR, Comment Letters on the Draft EIR, and Responses to Comments. The final EIR (which consists of Volume I: Draft EIR dated July 17, 2002; Volume II: Technical Appendices to the Draft EIR dated July 17, 2002; Environmental Findings of Fact and Statement of Overriding Considerations for the Redevelopment Area Expansion, Detachment, Annexation and Automotive Test Course Project dated October 4, 2002; Mitigation Monitoring Program for the Redevelopment Area Expansion, Detachment, Annexation and Automotive Test Course Project dated October 2, 2002; Environmental Assessment/Habitat Conservation for issuance of an Endangered Species Section 10(A)1(B) Permit /2081 Permit for the Incidental Take of the Desert Tortoise and Mojave Ground Squirrel dated July 2, 2002; Initial Study: Annexation, Detachment, Sphere of Influence Amendment, Redevelopment Area Expansion, General Plan Update Including the Housing Element), and Automotive Test Course Project dated April 4, 2002. Documents are on file in the California City Planning Dept., 21000 Hacienda Blvd., California City. The existing sphere of influence includes the previous annexation (Annexation #5) of approximately 17,993 acres or 28.1 square miles in the southeast portion of the City and detachment of 18,676 acres or 29.1 square miles generally in the northeastern and eastern portion of the City, approved in 2003 by the Local Agency Formation Commission (LAFCO). In addition, in 2003 approximately 5.04 square miles was acquired by Hyundai Proving Grounds and Technical Center for the purpose of providing additional desert tortoise habitat in order to mitigate potential impacts to the desert tortoise and its habitat, as a result of the construction and on-going operation of the Hyundai Proving Grounds and Technical Center. This mitigation area is located to the north of the General Plan Planning Area, in the vicinity of the Desert Tortoise Research Natural Area. The privately owned and operated Hyundai Proving Grounds and Technical Center is zoned Light Industrial and Research (M1).

8. California City Motocross Track, incorporated by reference, (SCH #2003081099). Documents are on file in the California City Planning Dept., 21000 Hacienda Blvd., California City. Cal City 5-15
1 REGULAR MEETING
CITY OF CALIFORNIA CITY
CITY COUNCIL
Tuesday September 21, 2010
Council Chambers, 21000 Hacienda Blvd.

MINUTES
CALL TO ORDER
Mayor Adams called the meeting to order at 5:38 pm
Following the Pledge of Allegiance the city clerk called the roll:

PRESENT: Councilmembers Smith, Strong, Lessenevitch, Edmiston Mayor Adams
ABSENT: None
ADOPTION OF AGENDA
Mayor Adams announced that there were two addendums to the Agenda; CC6 and CC7. Also, that these items will be heard and acted on first under New Business.

Motion by Councilmember Lessenevitch, second by Councilmember Strong to adopt the agenda with the addendums and the order in which they will be heard. Motion carried.

PRESENTATIONS
Patrick Welling outlined his proposed Eagle Scout Project STAFF ANNOUNCEMENTS/REPORTS
Public Works Director Bevins provided an update on the CCB resurface project including that the grinds will be used on the cemetery parking lot.

He also reported that the Mendiburu project; 96 th to Hacienda will start on 9/30/10 and will be closed while the tortoise fence is installed. Project to last approximately 22 days.

CIVIC / COMMUNITY ORGANIZATION ANNOUNCEMENTS
Helen Dennis, Community Club “Meet the Candidates” 10/7 and 10/14, CCMS at 6pm. Also as Chairman of the Parks and Recreation Commission she announced there is a shorter revised survey available for the public to fill out regarding the parks.

Shirley Heathman Cancer Assistance Walk to be held 10/23/10 at Central Park. Registration is at 7:30 am
MaryAnn Leblanc, EDC 5 th Thursday Dinner 9/30/10 at Senior Center Kim Collins, Citizens Advisory Committee Next meeting 9/24/10 5:30 City Hall
2 PUBLIC BUSINESS FROM THE FLOOR
Public comment was received from Pat Bohannon, Buford Land and Kim Collins
CONSENT CALENDAR / PUBLIC COMMENT
CC 1. City check registers dated through 9/15/10
CC 2. Approve minutes of meeting dated 9/07/10
Motion by Councilmember Lessenevitch, second by Councilmember Strong, to approve the consent calendar. Roll call vote as follows:

AYES: Smith, Strong, Lessenevitch, Edmiston, Adams
NAYS:  None
ABSTAIN: Smith Ck #82529
ABSENT:  None
NEW BUSINESS
NB 6. Intergovernmental Service Agreement (IGSA)
NB 7. Corrections Corporation of America (CCA)
City Manager Weil reported that NB 6 and NB7 go hand in hand.  First is the agreement between the City and the Office of the Federal Detention Trustee to house US Marshall detainees. This gives the City the opportunity to sign contracts with the federal government and then CCA becomes our subcontractor.

He outlined the details of the agreements and how the City is in no way can be held responsible for the actual running of the prison. Staff is requesting permission for the City Manager to sign both agreements. Mr. Weil further explained that the IGSA agreement also opens up the opportunity to receive inmates from other authorized agencies, such as ICE and BOP. This will allow our prison to fill back up to capacity and reinstate a huge portion of the jobs that were lost. Further positive action resulting from these agreements will be the new revenue stream that will be created to the City through CCA. The City will receive .50 per day, per inmate. Staff is recommending these funds be put into a reserve fund.

Jeb Beasley, representing CCA, was present from the Tennessee corporate office to answer any questions. Both council and public received clarification on their concerns and to their questions.

Motion by Mayor Pro Tem Edmiston, second by Councilmember Strong to allow the City Manager to sign and approve the Intergovernmental Service Agreement,. Roll call vote as follows:

AYES: Smith, Strong, Lessenevitch, Edmiston, Adams
NAYS: None
ABSTAIN: None
ABSENT: None
3 Motion by Mayor Pro Tem Edmiston, second by Councilmember Strong to allow the City Manager to sign and approve the agreement with Corrections Corporation of America. Roll call vote as follows:

AYES: Smith, Strong, Lessenevitch, Edmiston, Adams
NAYS: Nonce
ABSTAIN: None
ABSENT: None
Mayor Adams reported that the City has been working on securing an agreement since it was announced that CCA contract had been cancelled. He thanked Congressman Kevin McCarthy for stepping up to help the City.

NB1. Special Tax Commission Ordinance
City Attorney Lemieux reported that it was asked to prepare this ordinance amending the municipal code to establish am over site commission to ensure that the special tax proceeds will be spent for specific purposes i.e. infrastructure replacement . (Pending the massage of Measure E in November). He outlined the proposed ordinance.

City Manager Weil added that this is to ensure oversight by future councils and that the proceeds of the tax could not be used for operating expenses.

Mayor Pro Tem Edmiston noted that he is concerned about Sec 22.905 regarding compensation. Staff agrees that this should be an unpaid position. It has always been that way in the past, regarding the Citizens Advisory Committee.

Councilmember Smith expressed his concerns regarding design cost of the water system as referred to in Sec 22.907
Motion by Mayor Pro Tem Edmiston, second by Councilmember Strong to give First Reading, by Title only, with Further Reading waived of “AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF CALIFORNIA CITY AMENDING THE CALIFORNIA CITY MUNICIPAL CODE BY
ESTABLISHING THE SPECIAL TAX COMMISSION” deleting section 2

2.905. Roll call vote as follows:

AYES: Smith, Strong, Lessenevitch, Edmiston, Adams
NAYS:  None
ABSTAIN:  None
ABSENT:  None
4 NB 2. Scout Island Plans and Specifications
Public Works director Bevins reported that is June 2010 staff received an email from the Committee Chairman of California City Boy Scout Troop 413, requesting improvements to the existing Scout Hut. During the review of the situation it was recommended by citizens Rhonda and Alan Vasquez that the former Sports Arena property would be an ideal location for future Scout related activities. A rough design was prepared by staff. It was then reviewed by both Councils for the Boy Scouts of America and the Girl Scouts of Greater Los Angeles, with changes made per their suggestions.

Staff has determined that funding in the amount of $70,000 was firmly available from the current year budget for the purchase of materials.

Additional funding would come from donations and fund raising. The project is planned to be constructed by volunteer labor and landscaped by the Scouts. Two architects who attended the review process were approached to provide bids on the creation of construction plans for the Scout Lodge. Both are presented for review.

Staff is recommending that the council adopt Scout Island project and to award the design for the Bob Parker scout Lodge to Mountain View Studios for $1000 per their submission.

Helen Dennis, Chairman of the Parks & Recreation Commission, voiced her support for this project and urged the council to approve.

Motion by Mayor Pro Tem Edmiston, second by Councilmember Strong to approve. Roll call vote as follows:

AYES: Smith, Strong, Lessenevitch, Edmiston, Adams
NAYS:  None
ABSTAIN:  None
ABSENT:  None
NB 3. Municipal Code Review Title 6
City Attorney Lemieux explained this is the continuation of the review of the Municipal Code. He explained that on this large Title 6 he has mostly done clean up with the exception of a few area. He proceeded to review the proposed changes, stopping and discussing areas of concern noted by Mayor Pro Tem Edmiston and Councilmember Smith.

After lengthy review it is the consensus of the council to have staff make discussed revisions and bring back a new draft for further review. 5 NB 4. Scout Island Drive and Aspen Avenue Extension
Public Works Director Bevins reported that the Redevelopment Agency has previously allocated $100,000 for the construction of a new road for the Cerro Coso Community College / Best Western access road. Keeping with current county 911 policy, existing alignment names will be used, where a current alignment exists. Survey work and staking needs to be completed to provide water to the proposed hotel and college site across CCB, before those streets are resurfaced. Mr. Bevins provided a map designating the proposed alignments for the two streets. Staff recommends that the council adopt the proposed alignment for Scout Island Drive and Aspen Avenue Extension and request that deeded easements and final road maps be prepared and recorded. Funding, in the amount of $10,000, would come from Street Improvement.

No council or public comments noted.

Motion by Councilmember Smith, second by Mayor Pro Tem Edmiston to approve the proposed alignment. Roll call vote as follows:

AYES: Smith, Strong, Lessenevitch, Edmiston, Adams
NAYS:  None
ABSTAIN:  None
ABSENT:  None
NB 5. CCB Resurface Project Change Order
Public Works Director Bevins reported that the City has entered into a construction contract with Bowman Construction to resurface CCB at various locations. The current project does not include plans to construct a deceleration lane along CCB in the Scout Island Drive area. The plan was originally submitted by WRA Engineering for the Ellison project. WRA has released the design and survey information to the City for its use. Bowman requires a change order in the amount not to exceed $79, 331.52. The proposal affects the southern edge of the City right of way from the west end of the ARRA project, west to the Tierra del Sol golf course.

Staff recommends that the council authorize the deceleration lane change order to the CCB Resurface contract with Bowman Construction. Funding source would be Street Improvements.

Public comments were addressed.

Motion by Mayor Pro Tem Edmiston, second by Councilmember Lessenevitch to approve the change order with Bowman Construction.

Roll call vote as follows:

AYES: Smith, Strong, Lessenevitch, Edmiston, Adams
NAYS:  None
6 ABSTAIN:  None
ABSENT:  None
COUNCIL AGENDA
Councilmember Smith See attached written report
Mayor Pro Tem Edmiston Thanks to Mayor Adams and City Manager Weil for they successful efforts on acquiring the contract with CCA Mayor Adams Updates from the recent attendance to the League of Cities Annual Conference; electric car requirements, new technology in pipes and “Healthy Eating” Program

ADJOURNMENT
Motion by Mayor Pro Tem Edmiston, second by Councilmember Smith to adjourn at 7:18 pm. Motion carried.

Respectfully submitted by,
Denise Hilliker, City Clerk
APPROVED BY CITY COUNCIL ON __________________________
Correctional Development Facility at California City (CDFCC) Conceptual Site Plan
D:\Projects\3CRC\010100\GRAPHICS\NOP\Ex_site_plan_BW_20171218.ai CDFCC Site Boundary Rob Bonta
Attorney General
1300 I STREET, SUITE 125
P.O. BOX 944255
SACRAMENTO, CA 95814
Public: (916) 445-9555
Telephone: (916) 210-6642
E-Mail: [email protected]
SENT VIA EMAIL AND CERTIFIED U.S. MAIL
June 15, 2026
Sean Grayson, City Manager & Hearing Officer
David Brottlund, Planning Commission Chair
City of California City
21000 Hacienda Boulevard
California City, CA 93505
[email protected]
[email protected]
RE: Comments on Appeals of California City’s Issuance of Entitlements for CoreCivic, Inc.’s Immigrant Detention Operations at the California City Correctional Facility Dear City Manager Grayson and Planning Commission Chair Brottlund:

The California Attorney General’s Bureau of Environmental Justice respectfully submits these comments regarding the appeals of California City’s approval of CoreCivic, Inc.’s (“CoreCivic”) applications for a business license and a site plan for its current use of the California City Correctional Facility (“Facility”), a former prison located on approximately 70 acres of land at 22844 Virginia Boulevard, California City, for immigrant detention operations.

We submit these comments to City Manager Grayson in his capacity as the hearing officer for the business license appeal and to the Planning Commission in its role as the hearing body for the site plan appeal, pursuant to California City Municipal Code sections 1-4.09, subsection (a), and 9-2.212, subsection (b).1
As explained further below, the City Manager and Planning Commission (individually and collectively referred to herein as “City”) should not approve CoreCivic’s business license and site plan review applications because doing so would violate the City’s duties under its Municipal Code for several reasons. First, as a preliminary matter, pursuant to section 3-.2.3.203, subdivision (b), the City may not approve a business license or site plan application that fails to include information or materials required by the Municipal Code or that contains material misrepresentations. Based on records provided to our office by the City and publicly available information, it appears that CoreCivic did not provide the City with proof of compliance with workers’ compensation laws or a site plan with its applications, as required by the Municipal Code, and CoreCivic’s applications obscure the nature of its immigrant detention operations at 1 All references in this letter to statutory provisions are to the California City Municipal Code, unless otherwise stated.

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the Facility. Second, pursuant to section 3-2.3.211, the City may not issue a business license unless the proposed use conforms to the zoning regulations. Here, CoreCivic’s use of the Facility as an immigrant detention center violates the City’s zoning regulations and the existing conditional use permit for the Facility because immigrant detention is not permitted within the zone district or pursuant to the conditional use permit. Further, the existing conditional use permit for the Facility allows up to 2,304 beds at the Facility, not the 2,816 beds which the City has purported are authorized.2
As adopted by the City Council, the Municipal Code Zoning Chapter “preserves, protects and promotes the public health, safety, peace, comfort, convenience, prosperity, and general welfare.”3 The City’s adherence to its own Municipal Code, which the Municipal Code mandates, is essential to achieving these objectives.
4 This principle applies to the City’s actions
to process entitlement applications for proposed business operations and land uses. 5 The
necessity of the City’s correct application of its Municipal Code requirements to CoreCivic’s business license and site plan applications is magnified by the serious public health and safety failures that courts and our office have documented at the Facility and in other immigrant detention facilities operated by CoreCivic.

For these reasons, we urge the City to deny CoreCivic’s site plan and business license applications.

I. CoreCivic’s Immigrant Detention Operations at the Facility On August 27, 2025, without obtaining a business license or any other entitlement required by the Municipal Code, and more than a year after the closure of the former prison operations at the Facility, CoreCivic began to receive immigrants who had been detained by the federal government at the site.
6 In a press release, CoreCivic announced that it would hold immigrant detainees at the “2,560-bed California City Immigration Processing Center” pursuant to a contract with the U.S. Immigrations and Customs Enforcement (“ICE”).7 News reports estimate, based on statements by the City’s Mayor, that the Facility held 500 detainees within 2 Ex. I (Res. No. 01-98-1802), p. 1. 3 § 9-2.101.
4 §§ 1-3.01, 1-3.03, subd. (a)(1), 9-2.2803.
5 §§ 9-2.2803, subd. (a), 3-2.3.214.
6 Elliott, State Removes All Inmates from Cal. City Prison, Remaining Staff Working to Close Facility, Tehachapi News (Nov. 18, 2023), https://www.tehachapinews.com/news/state-removesall-inmates-from-cal-city-prison-remaining-staff-working-to-close-facility/article_f6920d7c864e-11ee-88b2-3f4bee2c5642.html. 7 CoreCivic, CoreCivic Announces New Contract Awards at California City Immigration Processing Center and Midwest Regional Reception Center (Sept. 29, 2025), https://ir.corecivic.com/news-releases/news-release-details/corecivic-announces-new-contractawards-california-city.

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just two weeks of its opening as an immigration detention center.8 By January 2026, the detained population at the Facility had ballooned to over 1,400 people.9 Since CoreCivic began to receive detainees at the Facility in 2025, inhumane conditions of confinement have been repeatedly documented by detainees, non-profit organizations, and government entities, including the California Department of Justice. In September 2025, Disability Rights California conducted a monitoring visit of the Facility and concluded that ICE and CoreCivic were subjecting people with disabilities to abuse and neglect by failing to provide access to critical medical and mental health care and failing to address disability-related requests in a timely manner, in addition to other critical shortcomings.10 In November 2025, seven detainees filed a class action lawsuit against ICE and the Department of Homeland Security (“DHS”) alleging that detainees at the Facility have been deprived of access to basic medical care, disability accommodations, and access to their lawyers and loved ones, in violation of their rights under the U.S. Constitution.
11,12 The lawsuit further alleges that detainees have been subjected to crumbling and unhygienic infrastructure conditions in the Facility, including clogged toilets and showers, foul smelling and discolored tap water, raw sewage, mold, insects, leaks, and flooding, as well as inadequate clothing, excessive solitary confinement and threats of force, and a lack of privacy in bathing and toilet facilities. 13 On February 10, 2026, the United
States District Court for the Northern District of California issued a preliminary injunction 8 Montalvo, ICE awards $130M contract to run Kern County facility amid deportation crackdown, FresnoBee (Oct. 22, 2025),
https://www.fresnobee.com/news/local/article312344657.html. 9 Fry, California’s Newest ICE Center Has 1,400 Detainees - What Adam Schiff and Alex Padilla Saw There, CalMatters (Jan. 20, 2026), https://calmatters.org/justice/2026/01/californiacity-ice-detention-senators/. 10 Disability Rights California, Newly Opened California City ICE Detention Facility:

Dangerous for Disabled People (Nov. 3, 2025),
https://www.disabilityrightsca.org/reports/california-city-ice-processing-center-a-dangerousexpansion-of-immigration-detention-in; see also Montalvo, Immigrants Protest Solitary Confinement - Abuse at CA’s Largest ICE Detention Center, FresnoBee (Oct. 22, 2025) (describing inhumane conditions and treatment reported by detainees at the Facility and detainees’ sit-ins and refusal to eat in protest),
https://www.fresnobee.com/news/california/article312180017.html. 11 Gomez-Ruiz, et al v. ICE, et al. (N.D.Cal. Nov. 12, 2025, No. 3:25-cv-09757), ECF No. 1 (“Gomez-Ruiz Complaint”), ¶ 1.
12 In a lawsuit filed against CoreCivic and the City by the Dignity Not Detention Coalition and a John Doe detainee in September 2025, the petitioners have also alleged that detainees have been subjected to invasive body searches, a lack of privacy in bathing and toilet facilities, cold water showers, inconsistent electricity, and inadequate hygiene and cleaning supplies and have been denied consistent recreational time outside of their cells and access to medicine. (Supp. Dec. of John Doe In Support of Ex Parte App. for Temp. Rest. Order and Order to Show Cause, ¶¶ 4, 7-

12.)
13 Gomez-Ruiz Complaint, supra, ¶¶ 38, 40 76, 114.

June 15, 2026

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ordering the federal government to provide detainees with adequate access to medical care, attorneys, appropriate clothing, and recreation spaces. 14 The California Department of Justice, through an on-site inspection and interviews with detainees conducted by our Civil Rights Enforcement Section on November 20 and 21, 2025, pursuant to the Attorney General’s authority under Assembly Bill 103 (2017), has also identified extensive violations of the ICE standards that apply to the Facility. Our office documented these findings in a report published this year entitled “Immigration Detention in California, A Review of Conditions of Confinement.” The Department’s findings on violations at the Facility include the premature opening of the Facility without adequate staffing, crisis-level understaffing for healthcare, denial of access to outside medical specialists, exposure of detainees to extremely cold temperatures, the infiltration of rainwater and plumbing leaks into detainees’ living quarters, reports of inadequate food quantities to meet nutritional needs, excessively long lockdowns, and reports of a failure to provide detainees with recreational time, among other problems. 15 The inhumane conditions of confinement at the Facility highlight the urgent need for government at all levels, including local jurisdictions, to faithfully exercise their respective oversight responsibilities over CoreCivic’s immigrant detention operations in accordance with the applicable laws.

II. CoreCivic’s Applications Are Inaccurate and Incomplete Based on documents provided to our office by the City and publicly available information, it is our office’s understanding that the present appeals are based on the City’s approval of the business license and site plan review applications and corresponding business plan submitted to the City by CoreCivic on August 25, 2025, and attached hereto respectively as Exhibits A, B, and C. Concerningly, the applications obscure the true nature of CoreCivic’s current operations as an immigrant detention facility, thereby preventing the City from correctly processing the applications. Further, CoreCivic’s business license and site plan applications to operate the Facility appear to lack material information that is required by the Municipal Code for the City to process and make a decision on the applications. The City must not approve 14 Gomez-Ruiz, et al v. ICE, et al. (N.D.Cal. Nov. 12, 2025, No. 3:25-cv-09757), ECF No. 72 (Order Granting in Part Plaintiffs’ Motions for Preliminary Injunction and Class Cert., p. 1.) 15 Our office’s findings from its inspection of the Facility and other detention facilities in the state are detailed in a report issued on May 15, 2026, entitled “Immigration Detention in California, A Review of Conditions of Confinement.” The report is available at https://oag.ca.gov/system/files/media/immigration-detention-2026.pdf. In January 2026, California State Senators Adam Schiff and Alex Padilla toured the Facility and described reports from detainees of foul odors emanating from the drinking water and encountering mold in their food and water. Mejia and Vives, U.S. Senators Tour California City ICE Facility, Decry Conditions and Inadequate Medical Care, Los Angeles Times (Jan. 21, 2026), https://www.latimes.com/california/story/2026-01-20/u-s-senators-tour-california-city-detentioncenter-decry-conditions-inadequate-medical-care.

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CoreCivic’s business license and site plan based on applications containing incomplete and misleading information.

The Municipal Code sets forth specific, mandatory requirements for the contents of business license and site plan applications submitted to the City. Business license applications must identify the “name and business of the applicant,” the “nature of the business,” proof of compliance with workers’ compensation laws, and other specified information.16 The applicant must verify the application under oath.
17 Further, the City must revoke or suspend a business
license if a licensee violates the Municipal Code’s business license provisions, including because the licensee operated its business in an unlawful manner or misrepresented information to obtain a business license.
18 Likewise, site plan review applications must meet certain criteria, including by providing a plan with specified information relating to the site’s layout and development.19 The City is required to enforce the Municipal Code’s business license and site plan requirements.20
CoreCivic’s August 2025 business license and site plan applications cannot be approved since they fail to disclose CoreCivic’s immigrant detention operations at the Facility.

Correspondence between the City and CoreCivic shows that CoreCivic withdrew the business license and site plan applications it originally submitted in July 2025, which accurately described CoreCivic’s operations at the Facility as immigration processing and detention subject to a contract with ICE, and replaced it with new versions in August 2025 that omit any reference to immigrant detention and ICE’s involvement.
21 Instead, the August 2025 application materials
describe the Facility generically as a “Detention Facility/Prison” and state that CoreCivic “will be operating…under a contract with the United States Marshals Service.”22 City records indicate that CoreCivic revised its business license and site plan applications in response to the City’s determination that CoreCivic’s proposed use of immigrant detention at the Facility would trigger Senate Bill 29 (2017)—a determination which CoreCivic disputed. 23 Without an accurate and
complete description of CoreCivic’s intended use of the Facility in CoreCivic’s business license 16 § 3-.2.3.203, subd. (b).
17 § 3-2.3.203, subd. (d).
18 § 3-2.3.208, subds. (a), (c).
19 § 9-2.212.
20 § 3-2.3.214; see §§ 1-3.01, subd. (a)(1); 1-3.03 (prohibiting the aiding or abetting of omissions that are unlawful under the Municipal Code).
21 Exs. A-C, D (CoreCivic July 2025 Business License Application), E (CoreCivic July 2025 Site Plan Review Application), F (CoreCivic July 2025 Business Plan), G (Malloy Aug. 14, 2025 Email); H (Carter Aug. 8, 2025 Letter).
22 Exs. A-C. 23See Exs. D-F. Senate Bill 29 (2017) prohibits a city, county, or other public agency from approving a deed, instrument, or other conveyance of land or issuing a permit for civil immigration proceedings without first providing at least 180-days advanced notice and soliciting public comments at a minimum of two public hearings. (Ch. 494, Stats. 2017, § 2.) June 15, 2026

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and site plan applications, the City cannot accurately determine whether CoreCivic’s operations conform to zoning regulations, which is a required step to issue a business license or site plan. 24 CoreCivic’s August 2025 business license and site plan applications also do not appear to include all of the information required by the Municipal Code, and thus cannot be approved by the City as submitted. First, we have not identified any documents indicating that CoreCivic provided the City with proof of its compliance with workers’ compensation laws with its business license application.
25 Compliance with the Municipal Code’s requirement to provide proof of compliance with workers’ compensation laws is especially important in light of both critical understaffing identified at CoreCivic detention facilities, which have contributed to worker injuries, and the lawsuits alleging CoreCivic’s use of forced labor practices.26 Second, it does not appear that CoreCivic submitted an actual site plan, as required, with its site plan review application.
27 It is important that CoreCivic provide a site plan, because a site plan provides the City with information about the Facility’s physical layout and its compatibility with Building and Fire Code standards.

III. CoreCivic’s Operations at the Facility Do Not Conform to the City’s Zoning Regulations
The City’s Municipal Code prohibits the issuance of a business license “unless the place of business and the purposes and methods of conducting such business conform to health, fire, and zoning regulations.”28 Similarly, the Municipal Code does not allow the City to approve a site plan where the application does not show that the site “will be developed in accordance” with the Code’s requirements.29 Here, the City may not issue CoreCivic a business license or site plan for its current immigrant detention operations, because CoreCivic’s current operations do not conform to the zoning regulations contained in Title 9 of the Municipal Code for several reasons. First, immigrant detention is not a permitted use, either by right or by conditional use 24 §§ 3-2.3.208, subds. (a), (c), 3-2.3.211, subd. (d), 3-2.3.214, 9-2.212, subd. (d). 25 § 3-2.3.203, subd. (b).
26 See Meza, Protected Whistleblowers’ Disclosures Regarding Gross Waste and Unlawful Contract Performance at the Torrance County Detention Facility, Government Accountability Project (Feb. 18, 2025), p. 2, https://whistleblower.org/wp-content/uploads/2025/02/02-18-2025- Whistleblower-Letter-to-Congress-and-Oversight-re-Torrance.pdf; Office of the Insp. Gen., U.S.

Dep’t. of Jus., Audit of the U.S. Marshals Service Contract No. DJJoDT7C0002 with CoreCivic, Inc., to Operate the Leavenworth Detention Center, Leavenworth, Kansas (Apr. 2017), https://oig.justice.gov/sites/default/files/reports/a1722.pdf; Wilhen Hill Barrientos, et al., v.

CoreCivic, Inc., Dist. Ct. Ga. Middle, Apr. 17, 2026, No. 4:18cv70 (resulting in settlement requiring CoreCivic to notify detainees of their labor rights and provide confidential benefits to petitioners, according to a statement issued by petitioners’ counsel, https://www.splcenter.org/presscenter/settlement-forced-labor-case-against-private-prisoncompany-operating-immigration/). 27 § 9-2.212, subd. (c)(4). 28 § 3-2.3.211, subd. (d).
29 §§ 1-3.03, 9-2.212, subd. (b), 9-2.2803 (stating that a permit or license issued in conflict with the zoning regulations is null and void).

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permit, within the zone district that applies to the Facility. Second, CoreCivic’s immigrant detention operations are not authorized by the existing conditional use permit that applies to the Facility (Conditional Use Permit (“CUP”) No. 97-01), which allows only prison operations and not immigrant detention. Finally, CoreCivic is authorized to operate only up to 2,304 beds at the Facility under CUP No. 97-01, far below the 2,560-bed capacity which CoreCivic’s application attributes to the Facility as well as the 2,816 beds which the City determined are allowed when it approved CoreCivic’s site plan application.

A. Immigrant Detention is Not a Permitted Use Within the Open Space / Residential Agricultural Zone District
22844 Virginia Boulevard, the property on which the Facility is located, is zoned for Open Space (“O”) / Residential Agricultural (“RA”).
30 Immigrant detention is not an allowed use
within this zone district,
31 and uses not authorized in the RA / O zone district are prohibited by the zoning regulations.
32 Yet, CoreCivic is using the Facility for immigrant processing and detention—a fact prominently displayed on a sign at the Facility entry stating “CoreCivic Immigration Processing Center” and documented in our office’s report issued this year following its inspection of the Facility.
33 Accordingly, CoreCivic’s use of the Facility does not conform to the zoning regulations.

Further, immigrant detention is not covered by the one functionally comparable use category that is allowed by a conditional use permit in the O / RA zone district— “[g]overnmental or quasi-governmental correction, probation or prison facilities and services.”34 The plain meaning of “correction, probation, and prison facilities” does not include immigrant detention facilities.35 While correction, probation, and prison facilities are all facilities used to hold or provide services to people charged with a crime, immigration enforcement and detention is generally premised on a civil law violation.
36 In addition, the Municipal Code assigns
30 See Kern County Interactive Zoning Map, https://www.californiacityca.gov/CC/index.php/54-your-city-government/243-interactive-zoning-map. 31 §§ 9-2.102, 2.401, 2.402, 2.2801. 32 See §§ 9-2.102 (stating that the Zoning Regulations control the uses of land under the City’s jurisdiction), 9-2.401 (listing the uses permitted in the RA zone district), 9-2.402 (listing the uses that “may be” permitted with a conditional use permit in the RA zone district); see also Blankenship v. Allstate Ins. Co. (2010) 186 Cal.App.4th 87, 94 (a legislative body’s “omission of a term in a list of terms indicates that (it) did not intend to include the term.”). 33 Elliott, Private Prison in California City may reopen for immigration processing, Bakersfield Californian (Jun. 19, 2025), https://www.bakersfield.com/news/private-prison-in-california-citymay-reopen-for-immigration-processing/article_0a138bb1-1d92-4f6a-a612-59c93d28e4f4.html; Cal. Dep’t. of Just., Immig. Det. in Cal., A Review of Cond. of Confin. (2026), p. 13. 34 § 9-2.402, subd. (p).
35 J. Arthur Properties, II, LLC v. City of San Jose (2018) 21 Cal.App.5th 480, 486 (local government laws are interpreted consistent with the general rules of statutory interpretation, starting with the plain language of the enactment).
36 See Civ. Code, § 1670.9, subd. (h); Mayorkas, Guidelines for Enforcement of Civil Immigration Law, DHS (Sept. 30, 2021), https://www.corecivic.com/private-detention; see also June 15, 2026

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undefined terms the meanings ascribed to them by state law and courts, and California statute and court decisions clearly distinguish between “prisons” and immigrant detention facilities as separate use types.
37 Despite the prohibition on immigrant detention use at the Facility under the regulations applicable to the O / RA zone district, it appears from City records that it permissively allowed immigrant detention use to occur at certain points in the Facility’s history. The City’s failure to require CoreCivic to adhere to the Zoning Regulations’ prohibition on immigrant detention uses in the O / RA zone district does not render CoreCivic’s present use of the site lawful.38 B. CUP No. 97-01 Allows Only Prison Use at the Site, Not Immigrant Detention
As discussed above, immigrant detention is not an allowed use, either by right or by a conditional use permit, in the zone district that applies to the Facility. However, even if immigration processing and detention were a type of “correction, probation, or prison facilit[y]” that could be allowed under a conditional use permit in the City, immigration processing and detention is not allowed under CUP No. 97-01. The California City Council issued CUP No. 97- 01 in 1998 to authorize the construction and operation of a “2,304 bed prison facility” on approximately 70-acres of the 320-acre parcel at Virginia Boulevard.39 The existing Facility at 22844 Virginia Boulevard was constructed the next year and then began operating as a prison.

By its terms, CUP No. 97-01 allows only a “prison facility.”40 The permit application materials and environmental review prepared for CUP No. 97-01 also make clear that the intended use of the site was for correctional, not civil detention, purposes.41 Nothing in CUP No. 97-01 or in the CoreCivic, A Limited But Important Role in America’s Immigration System (describing CoreCivic’s immigrant detention facilities as “designed to care specifically for civil detainees), https://www.corecivic.com/private-detention. 37 § 1-2.08; see, e.g., Gov. Code, § 27491.56, subd. (f) (identifying correctional and immigrant detention facilities as distinct facility types for purposes of forensic accountability requirements for the determination of the cause of in-custody deaths); Cal. Att’y for Crim. Just. v. Newsom, et al (2020) 2020 Cal.LEXIS 3220 (addressing state authorities’ responsibilities to protect the health and safety of inmates subject to transfer between state prison and federal immigrant detention facilities); see also Zadvydas v. Davis (2001) 553 U.S. 678, 699. 38 See Hansen Bros. Enter. v. Bd. of Sup. (1996) 12 Cal.4th 533, 564 (local government lacks power to waive or consent to violation of the zoning law); Fontana v. Atkinson (1963) 212 Cal.App.2d 499, 509 (no vested right to violate a city ordinance may be acquired by continued violations, and city failure to enforce a zoning ordinance does not estop a city from subsequently enforcing it).
39 Ex. I, p. 1; Ex. J (Mit. Mon. Prog. CCA Prison at Cal. City, State Clearinghouse No. 97091045), p. 2.
40 Ex. I.
41 See IT Corp. v. County of Imperial (1983) 35 Cal.3d 63, 74 (holding that the Superior Court reasonably found from the permit application and other documents generated during the permit issuance process that a conditional use permit was limited in scope); Env. Impact Report Suppl., CCA Prison at Cal. City, Oct. 1997 (CUP No. 97-01) (describing the facility objectives as June 15, 2026

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application materials indicate that CoreCivic or the City intended or anticipated the Facility would be used for non-correctional purposes, including for immigrant detention. Therefore, CUP No. 97-01 does not authorize CoreCivic’s current use of the Facility.

C. A Maximum of 2,304 Beds is Authorized in the Facility Under CUP No. 97-01
CUP No. 97-01’s terms are similarly limiting when it comes to the specific number of beds permitted at the Facility.
42 The application for CUP No. 97-01 confirms the intention for the Facility to operate a maximum of 2,304 beds.43 The Mitigation and Monitoring Program prepared for CUP No. 97-01 was explicit that the Facility would “only accommodate 2,304 inmates, the intended capacity of the prison.”44
Despite CUP No. 97-01’s clear 2,304-bed cap on the existing Facility’s capacity, the City Planning Director’s determination letter for its review of CoreCivic’s site plan application finds that 2,816 beds are allowed. To reach this conclusion, the letter adds the number of beds authorized by CUP No. 97-01 to the number of beds authorized by CUP No. 98-02. However, CUP No. 98-02’s terms are inapplicable to the existing Facility. CUP No. 98-02 and its associated application materials authorized the construction of an additional 512-bed prison facility on approximately 1.5 acres, but this construction never occurred. 45 These materials make
it clear that the 512-bed expansion authorized by CUP No. 98-02 was designed to occur in an entirely new building and facility located near, but outside of, the structures previously approved by CUP No. 97-01.46 Therefore, the 512 beds authorized by CUP No. 98-02 were allowed only within the additional facility authorized by that permit—which were never built—and were not transferable to the existing Facility.

In pending litigation brought by the Dignity Not Detention Coalition against the City and CoreCivic, CoreCivic has attempted to characterize CUP No. 98-02 as allowing an additional 512 beds, beyond the 2,304 authorized by CUP No. 97-01, within the existing Facility. 47 In
serving the “inmate incarceration needs of government correctional agencies,” and referring to facility staff as “correctional officers”), pp. 1-2, 3-1. 42 Ex. I, p. 1; Ex. K (Cal. City Planning Dep’t., App. for Conditional Use Permit, Case No. 97- 01), p. 4-5. 43 Ex. K, pp. 4-5.
44 Ex. J, p. 2, underline added.
45 Ex. L (Res. No. 11-98-02), pp. 1-2 (allowing for a 512-bed expansion in additional buildings connected to wet and dry utilities); Ex. M (Cal. City Planning Dep’t., App. for Conditional Use Permit—Amendment, Case No. CUP-A 98-02), p. 5; Ex. N (Initial Study, Eval. of Env. Impacts, City of. Cal. City, Proposed 512-Bed Expansion of CCA), p. 2; Dignity Not Detention Coalition, et al v. City of California City (DNDC v. Cal. City) (2025), Cal.E.D. (Case 1:25-cv-01292, ECF No. 18 (CoreCivic’s Resp. to Pet. Ex Parte App. for Temp. Rest. Order, Ex. p. 2, ¶¶ 12-14 (citing Ex. 1 [Ariola Decl., Att. D (Stewart, Mem. to File, Nov. 15, 2001]). 46 Ex. J, p. 2. 47 DNDC v. Cal. City (2025), supra, ECF No. 18 (CoreCivic’s Resp. to Pet. Ex Parte App. for Temp. Rest. Order, p. 2, ¶¶ 12-14 (citing Ex. 1 [Ariola Decl., Att. D].) June 15, 2026

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support of this characterization, CoreCivic points to a memorandum-to-file dated November 15, 2001, and purportedly signed by the then-City Manager stating that CUP No. 98-02 would expire on November 30, 2001 and purporting to approve the 512-bed expansion authorized by CUP No. 98-02 within the existing Facility.48 But this memorandum is not persuasive for several reasons.

First, the nearly quarter-century old memorandum is not on letterhead, rendering its authenticity uncertain. Second, as evidence of the City Manager’s authority to grant the change to CUP No. 98-02’s terms, the memorandum cites to several Municipal Code sections which have since been repealed and which the City has indicated to our office cannot be located. Without verification of the contents of those repealed Municipal Code sections, the memorandum does not establish that it constitutes a legally valid modification to CUP No. 98-02.

Similarly, a letter by another City Manager dated May 27, 2014, which CoreCivic points to as evidence of its authorization to operate up to 2,560 beds at the Facility, is also unconvincing. That letter states that the “Planning Department has completed a review of the land use permitting associated with” the California City Correctional Facility, and the letter serves as notification that the Facility is “authorized and fully permitted to operate 2,560 beds.”49 However, the letter provides no support for this statement. As discussed above, continued violations of a local law do not create a vested right to continue to violate the law. 50 IV. Conclusion
In conclusion, we urge the City to deny CoreCivic’s business license and site plan applications, as required by the Municipal Code. In addition, in light of the significant public interest in this matter, we encourage the City to take steps to facilitate public participation in the appeals process, including by providing public notice of the date and time of the appeal hearings on its website at least ten days before the hearing; inviting and considering written comments; and allowing the public to provide verbal comments at both the business license and site plan hearings. If you would like to meet to discuss our concerns, please do not hesitate to let us know. Thank you for considering our comments.

Sincerely,

ASHLEY WERNER
Deputy Attorney General
Bureau of Environmental Justice
For ROB BONTA
California Attorney General
48 Id.
49 Id. at p. 3, ¶¶ 12-13 [citing Ex. 1 (Ariola Decl., Att. F [Weil, May 27, 2014])]. 50 Fontana v. Atkinson, supra, 212 Cal.App.2d 499, 509; Pettitt v. City of Fresno (1973) 34 Cal.App.3d. 813, 822-23 (holding that estoppel will not be invoked against a government agency where it would defeat the effective operation of a policy adopted to protect the public, such as zoning laws, which involve a vital public interest).

June 15, 2026

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cc: Gesele Marsh, Planning Commission Vice Chair
Salena Coleman, Commissioner
Ralph Cantrell, Commissioner
John Paul Maier, Deputy City Manager/City Clerk
Brandon Sanchez, Esq., Burke, Williams & Sorensen, LLP
August 19, 2026
Via email
City Council
City of California City
21000 Hacienda Boulevard
California City, CA 93505
Cc: City Clerk
Motion for Continuance of August 25, 2026 Appeal Hearing for CoreCivic Inc.’s Site Plan Review and Business License for the California City Correctional Facility

6. Appellants respectfully request and move for this continuance for the reasons stated below.

7. First, appellants incorporate the previous reason for requesting a different date due to unforeseen medical issues.

Respectfully submitted,
Jehan Laner
Managing Attorney
Immigrant Legal Resource Center
August 20, 2026
VIA FEDEX and EMAIL
City of California City
City Hall
21000 Hacienda Blvd.

California City, CA 93505
Dear Mayor Marquette E. Hawkins, Mayor Pro Tem Jim Creighton, and City Council Members Ronald Smith, Della Clark, and Shawn Bradley:

CoreCivic, Inc. files this combined response to and opposes the July 9, 2026 and July 10, 2026 applications for appeal filed on behalf of the Dignity Not Detention (“DND”) Coalition and the Immigration Legal Resource Center (“ILRC”). The applications for appeal request the City Council to review: (1) the Planning Commission’s decision to adopt Resolution No. PC 2026-07- 07 denying the DND Coalition’s prior application for appeal of the City Planner’s approval of CoreCivic’s Site Plan Review (“SPR”) Minor; and (2) the City Manager’s decision denying the DND Coalition’s prior appeal of the City Clerk’s issuance of CoreCivic’s Business License. These applications for appeal should be denied because the Planning Commission’s and City Manager’s decisions are both correct. Neither the DND Coalition nor the ILRC has standing to appeal under the Municipal Code, and their grounds for the appeal are based on false and misleading information.

I. Relevant Background.

CoreCivic, previously known as Corrections Corporation of America, owns and operates detention facilities in partnership with federal, state, and municipal governments/agencies across the country. For the past thirty years, CoreCivic has been a member in good standing with the community, conducted business in the City, paid property and other taxes, contributed to the City’s economy, and employed many of its residents.1
1 The City recognized that the Facility was a “primary economic driver in the community” due to its “large, stable source” of “high-wage employment” when it was previously open. (See https://www.californiacity-ca.gov/CC/images/ stories/2017-04-07-California-City-Economic-Assessment--SWOT---FINAL.pdf (PDF at 1, 3 and 6).) Under the contract with ICE, CoreCivic now pays prevailing wages at the Facility that far exceed the state minimum wage. For example, Detention Officers, the most common entry-level position at the Facility, are paid $50.04 per hour. (https://sam.gov/wage-determination/2015-5603/28). The Facility currently employs nearly 450 individuals.

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The DND Coalition is not a legal entity, much less a member of the California City community. Rather, it is a collection of social and political advocacy groups that oppose the federal government’s current immigration policies.

The ILRC is a member of the DND Coalition and also not a member of the California City community. Rather, it is a national nonprofit organization founded and headquartered in the City and County of San Francisco. It provides training and education to legal professionals on immigration law and engages in advocacy for immigration rights across the country. The DND Coalition and the ILRC’s applications to appeal to the City Council are pretexts to advance their political goals and social agenda to oppose federal immigration detention operations.

A. CoreCivic’s Facility.

In 1997, CoreCivic submitted a proposal to construct a facility at 22844 Virginia Boulevard, consisting of 2,304 general population beds, a 256-bed segregation unit, and a 4-bed medical unit. (Ex. 1, Verhulst Declaration, ¶ 7; Ex. 2, Malloy Declaration, ¶ 4.) CoreCivic’s application for a conditional use permit for the facility did not designate a particular detention population. At a noticed public hearing on January 15, 1998, the California City Planning Commission recommended granting Conditional Use Permit (“CUP”) 97-01 for the proposed facility, known as the California City Correctional Facility (“the Facility”). (Ex. 3, Ariola Declaration, ¶ 11.) The City Council granted CUP 97-01 on January 20, 1998, and in June 1998, CoreCivic purchased the 320-acre site, a vacant terrain surrounded by natural desert. (Id., ¶¶ 11, 14.) Construction began in 1998. (Id., ¶ 16.) During construction, CoreCivic applied to amend CUP 97-01 to construct two additional 256-bed housing units at the site. (Id., ¶ 17.) On December 1, 1998, the City granted CUP Amendment 98-02, which expanded the site’s permitted use by 512 general population beds. (Id. and Attachment D at Page 48, 50–51 and 57 of 161.) On November 15, 2001, the City Manager/Planning Director clarified that the Amendment extension was “granted indefinitely.” (Ex. 3, ¶ 17 and Attachment D at Page 45 of 161.) Neither CUP 97-01 nor CUP Amendment 98-02 has been revoked, rescinded, or canceled. (Ex. 3, ¶ 19.) CoreCivic operated the Facility as a federal detention center from 2000 to 2013. (Ex. 1, ¶¶ 11–14; Ex. 3, ¶ 18.) From 2000 to 2010, CoreCivic housed criminal aliens in the custody of the Bureau of Prisons (“BOP”) through a direct contract with BOP. (Ex. 1, ¶¶ 10–12; Ex. 3, ¶ 18.) From 2010 to 2013, CoreCivic housed detainees in the custody of the United States Marshals Service (“USMS”) and immigration detainees in the custody of United States Immigration and Customs Enforcement (“ICE”) through an Intergovernmental Services Agreement (“IGSA”) with the City. (Ex. 1, ¶¶ 13–14.) During that period, there were more than 9,500 ICE detainees at the Facility. (Id.) In 2013, CoreCivic leased the Facility to the California Department of Corrections and Rehabilitation (“CDCR”) to house California inmates.2 (Ex. 1, ¶ 15; Ex. 3, ¶ 22.) In 2014, the City confirmed that a land-use review had been completed and authorized and permitted the use of 2,560 beds at the Facility. (Ex. 3, ¶ 23 and Attachment G at Page 97 of 161.) CDCR made full use 2 On May 27, 2014, the City confirmed that CDCR was “authorized and fully permitted to operate 2,560 beds” at the Facility. (Ex. 3, ¶ 23 and Attachment G at Page 97 of 161.) August 20, 2026

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of the available space and regularly housed more than 2,304 inmates at the Facility during the lease. (Ex. 1, ¶ 16.)
After CDCR’s lease expired in 2024, CoreCivic did not close the Facility or discontinue its use as an Institutional Group I-3 facility. (Ex. 3, ¶ 29.) To the contrary, CoreCivic continued to staff the Facility with operations and maintenance employees while it identified and explored opportunities to enter into a new contract. (Id., ¶ 30.) In April 2025, CoreCivic entered a new contract with ICE to operate the Facility once again as a federal detention facility. (Ex. 1, ¶ 20.) In August 2025, ICE informed CoreCivic that it would begin delivering detainees to the Facility; the first group of detainees arrived on August 27, 2025. (Id., ¶ 21.) In September 2025, ICE formalized a contract for up to 2,560 beds, which expires on August 31, 2027. (Id., ¶ 21.) The USMS is an authorized and active user of the Facility as well.

The Facility houses ICE detainees, who are classified as High/Mod-High or Low/Mod-Low. Most detainees classified as High/Mod-High have criminal convictions (and/or a documented history of predatory behavior), the majority of which were in the United States. The Facility also houses USMS male pretrial criminal detainees.

On July 2, 2026, the United States Department of Homeland Security (“DHS”) purchased the Facility from CoreCivic. (Ex. 8, Declaration of Warden Chestnut, ¶ 27; Ex. 9, General Warranty Deed.) The Facility has since been owned by the federal government, and CoreCivic has continued performing immigration detention operations at ICE’s direction and on its behalf, as well as federal pretrial detention operations at the USMS’s direction.

B. CoreCivic’s Applications for a SPR Minor and a Business License.

On July 22, 2025, CoreCivic applied for an SPR Minor and a Business License. (Ex. 3, ¶¶ 39–40 and Attachment O at Page 117–131 of 161.) It submitted the SPR Minor application at the City Planner’s instruction. (Ex. 3, ¶¶ 36–39 and Attachment O at Page 117 of 161.) An SPR Major application was not required because CoreCivic did not plan any structural modifications to the Facility, and it merely sought to use the Facility for immigration detention as it had previously done in partnership with the City. (Ex. 3, ¶ 37.) That application was supplemented with a business plan for the operation of the Facility on August 11, 2025. (Ex. 4, Aug. 11, 2025 Business Plan Submission.) The City provided public notice that it was considering CoreCivic’s application no later than August 12, 2025.

CoreCivic also submitted a second SPR Minor and Business License application on August 25, 2025, in response to interest by the USMS to place detainees at the Facility. (Ex. 5, Aug. 25, 2025 2d SPR Minor & Biz License Submission.) That application was clarified on September 15, 2025. (Ex. 6, Sept. 15, 2025 2d SPR Minor Clarification.) At the time of these submissions, the City was aware and even received public comments from the floor at numerous meetings relating to ICE’s desire to use the facility.

The City provided advance notice and held the first hearing on both of CoreCivic’s applications before the City Council on October 28, 2025. The City also provided advance notice, which was reported in local media, and held a second public hearing on CoreCivic’s applications August 20, 2026

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before the Planning Commission on December 16, 2025. After holding two noticed public hearings under the procedures set forth in California Civil Code § 1670.9 (“SB 29”), the City Planner approved the SPR Minor, and the City Clerk issued CoreCivic’s Business License on February 26, 2026.

C. The DND Coalition’s Prior Applications for Appeal.

On February 27, 2026, an application for appeal challenging the City Planner’s approval of the SPR Minor and the City Clerk’s issuance of the Business License was filed on behalf of only the DND Coalition. On July 7, 2026, the Planning Commission held a public meeting and adopted Resolution No. PC 2026-07-07, denying the DND Coalition’s application for appeal and upholding the City Planner’s February 26, 2026 approval of the SPR Minor. On July 7, 2026, the City Manager heard arguments on the DND Coalition’s application for appeal and issued a decision on July 8, 2026, denying that application and upholding the City Clerk’s issuance of the Business License.

II. The Applications for Appeal Should Be Denied Because the Federal Government Owns the Facility and CoreCivic Performs Operations on ICE’s Behalf.

The applications for appeal should be denied because the relief they request is unconstitutional. Under the guise of enforcing the City’s permitting and licensing regulations, the DND Coalition and ILRC lobby the City to revoke the historically authorized use of the Facility for immigration detention under CUP 97-01 and CUP Amendment 98-02 (the “Conditional Use Permits”), revoke the Business License, and shut down the Facility until CoreCivic has complied with their incorrect interpretations of the Municipal Code. The applications for appeal, however, omit the crucial fact that shows this cannot be done because the United States now owns the Facility. (Ex. 8, ¶ 27 and Ex. 9.) Thus, the City may not impose its permitting and licensing requirements to interfere with and/or override the federal government’s decision to use the Facility for its immigration detention operations. This includes interfering with ICE’s decision to hire CoreCivic to perform immigration detention services at the Facility by shutting it down until the City is satisfied that its permitting and licensing requirements have been met. This is because the Supremacy Clause prohibits the City from exercising any veto power over the federal government, such as by regulating or discriminating against it and its contractors without Congress’s express consent.3
3 See Goodyear Atomic Corp. v. Miller, 486 U.S. 174, 176 (1988) (“[A] federally owned facility performing a federal function is shielded from direct state regulation, even though the federal function is carried out by a private contractor, unless Congress clearly authorizes such regulation.”); Leslie Miller, Inc. v. Arkansas, 352 U.S. 187, 188–90 (1956) (invalidating fine against contractor for commencing work without obtaining a state license as preempted by federal law because subjecting the contractor to state licensing requirements would effectively grant the state licensing board a “virtual power of review” over the federal government’s power to select its contractor and schedule construction); Geo Grp., Inc. v. Newsom, 50 F.4th 745, 754–58 (9th Cir. 2022) (explaining California may not impose licensing requirements to deny a particular federal contractor the right to perform federal work, much less impose regulations that would effectively override the federal government’s decision to use private detention operatorsin the state); United States v. King County, 122 F.4th 740, 756–57 (9th Cir. 2024) (invalidating executive order that directed county officials to ensure that future leases prohibit servicing ICE charter flights at a county airfield); Gartrell Const. Inc. v. Aubry, 940 F.2d 437, 438–41 (9th Cir. 1991) (holding California authorities were preempted from imposing fines on a private August 20, 2026

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The applications for appeal also fail to inform the City of another important fact. The DND Coalition’s members, including the ILRC, have been advocating for the California Legislature to pass SB 1367, a bill that would prohibit cities and counties from approving a new land use authorizing construction of a detention facility, or a change of use permitting an existing building to be used as a detention facility. See https://sjud.senate.ca.gov/system/files/2026-06/ab-2465- ortega-sjud-analysis.pdf. Thus, in opposing federal immigration detention operations, their plan is nuclear. They not only seek to shut down the Facility, but also to categorically prohibit the City in the future from authorizing the new use or change of use for any detention facility operated by a private entity on behalf of any government entity, whether for civil, criminal, or administrative purposes. Any argument that the applications for appeal merely seek CoreCivic’s compliance with the Municipal Code to obtain a new conditional use permit or business license is simply a ruse under this plan.

III. The DND Coalition and the ILRC Cannot Appeal the Approved SPR Minor or Issued Business License.

The Municipal Code permits only an “affected person” to file an application for appeal.

CCMC § 1-4.04(a). It defines an “affected person” as a “person … who has an interest in the matter at issue or whose health, safety, or welfare may be affected by the decision.” CCMC § 1-4.02(a).

A “person” is defined as “any natural person,” a “firm, company, corporation, partnership, association,” or a public entity. CCMC § 1-4.02(f); CCMC § 1-2.07(k).

The DND Coalition may not appeal because it is not a “natural person,” a “firm, company, corporation, partnership, association,” or a public entity. Nor is it otherwise registered under California law as any other type of incorporated or unincorporated association. See Cal. Corp. Code § 12585 (requiring nonprofit associations that receive government grants or charitable funding to register). Rather, the DND Coalition is merely a label, assigned to a belief that several social and political advocacy groups hold. It has no office or any officers. It does not own property, operate a business, or reside in the City of California. Nor does it pay City taxes. CoreCivic raised these objections in its response to the DND Coalition’s prior application for appeal, but the DND Coalition does not dispute them here. Thus, the DND Coalition concedes that it is not “person,” let alone an “affected person.”
Realizing the defect in the DND Coalition’s appeal, the ILRC attempts to add itself as an appellant for the first time in these appeals. But this tactic fails for two reasons. First, the ILRC’s applications to appeal are untimely because the City Planner’s approval of the SPR Minor and the City Clerk’s issuance of the Business License both occurred six months ago, on February 26, 2026.

Because the February 27, 2026 application for appeal was filed on behalf of only the DND Coalition, the ILRC’s applications to appeal are untimely. See CCMC § 1-4.05(a) (requiring application for appeal to be filed “within seven (7) days” from the decision subject to appeal). contractor for not obtaining a state license to perform work exclusively for the federal government); California Attorney General Opinion No. 85-102, 68 Cal. Op. Att’y Gen. 310 (1985) (“The United States Postal Service need not comply with county zoning regulations in constructing a post office on land owned or leased by the United States.”); see also Hillsborough County v. Automated Med. Lab’ys, Inc., 471 U.S. 707, 713 (1985) (analyzing the constitutionality of local ordinances the same way as state laws).

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Second, the ILRC’s application for appeal also fails to provide any information that shows it is an “affected person.” Like the DND Coalition, the ILRC does not assert that it has an office, owns property, operates a business, or resides in the City, or that it pays City taxes. To the contrary, public records show that the ILRC’s office and headquarters are located in San Francisco. See https://rct.doj.ca.gov/Verification/Web/Details.aspx?result=6f54a3aa-2187-4f1f-a674-e4a102702 6c8.
4 The failure to provide any information to establish the ILRC’s interests is fatal to its appeal because the Municipal Code requires that any “application shall contain sufficient information to identify the party, its interest in the matter, and the reasons for requesting an appeal.” CCMC § 1-4.04(a) (emphasis added). And the Municipal Code mandates that “any decision becomes final for all purposes when it is made” unless the decision was “appealed … in the time and manner provided,” CCMC § 1-4.10.

The City should deny the applications for appeal filed by the DND Coalition and the ILRC for these reasons alone.5
IV. The Applications’ Grounds for Appeal Lack Merit.

Although the DND Coalition and the ILRC have requested the City Council to review the Planning Commission’s decision to uphold the approved SPR Minor and the City Manager’s decision to uphold issuance of the Business License, their applications fail to identify any error in those decisions. Thus, they fail to meet their burden of proof under the Municipal Code “to support overturning of the prior decision[s].” CCMC 1-4.04(e). Instead, they merely copy and paste the same six grounds that the DND Coalition unsuccessfully argued in its prior application for appeal.

Nonetheless, all six grounds for appeal are based on the same false factual and legal premise that the Zoning Regulations do not permit CoreCivic’s use of the Facility as an immigration detention facility under the existing Conditional Use Permits.
4 In a July 7, 2026 letter to City Manager Grayson in support of the DND Coalition’s prior appeal, the Managing Attorney for the ILRC, Jehan Laner, argued she was an “affected person” because she “serves the inside of immigration detention centers.” These appeals, however, were not filed on her behalf. Although Ms. Laner asserts that she provides services “inside immigration detention centers,” the ILRC’s website belies any claim that the ILRC provides services to detainees in the Facility. See https://www.ilrc.org/community-resources (“For over 40 years, we have impacted the field of immigration law with a three-pronged approach – capacity building, policy advocacy, and civic engagement.

Because this work is generally focused around teaching, interpreting, and changing law to empower legal practitioners, we do not directly represent clients at the ILRC, nor do we provide individual legal consultations.”); https://www.ilrc.org/about-us(“The ILRC trains attorneys, paralegals, and community-based advocates who work with immigrants around the country. We inform the media, elected officials, and public to shape effective and just immigration policy and law. Our staff works with grassroots immigrant organizations to promote civic engagement and social change.”); https://www.ilrc.org/what-we-do (“We Help Immigration Law Professionals and Advocates Expand Their Expertise.” “We Educate and Train Immigrant Communities to Advocate for Themselves.” “We Shape Immigration Law and Policy.”).
5 The applications for appeal cite CCMC § 9-2.212(b), but that section is irrelevant because it applies only to the approval of CoreCivic’s SPR for construction of the Facility in 1998, not the SPR Minor for use of the Facility as an immigration detention center. Moreover, CCMC § 9-2.212(b) allows only an “interested party” to file an appeal. The DND Coalition and the ILRC may not file an application for appeal because they are not interested parties for all the reasons above. Further, CCMC § 9-2.212(b) provides that the Planning Director’s decision “shall be final unless appealed to the Planning Commission by any interested party prior to the issuance of any building permit for the party.” (Emphasis added). Thus, even assuming that this section applied to the SPR Minor approval, it is final and cannot be appealed because the DND Coalition’s prior applications and these applications for appeal were filed after February 26, 2026.

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First, the applications for appeal assert that the approval of the SPR Minor and the issuance of the Business License do not conform with CCMC § 9-2.803(a). But CCMC § 9-2.803(a) is irrelevant because it sets a minimum lot area (80,000 square feet) for sites and structures in an R4 district (One-Family Residential District Estate). The Facility is located in an RA (Residential/Agricultural) district, not an R4 district. (Ex. 7, City Planner Doravari Declaration, ¶

4.) Nonetheless, the Facility satisfies this minimum lot area requirement because the lot (parcel num. 350-031-28-2) is 61.19 acres, which is 2,665,436.4 sq. ft. (Ex. 3, Attachment M at Page 110 of 161.)
Second, the applications for appeal assert that CCMC § 9-2.102(b) prohibits the use of the Facility as an immigration detention facility because CCMC §§ 9-2.401 and 9-2.402 do not permit that use. This argument is also wrong.

CCMC § 9-2.102(b) provides only that “[n]o structure shall be erected or altered or used Except as provided in this Chapter.” CoreCivic has not erected or altered any structure, and its use of the Facility for immigration detention is a permitted use. Although CCMC § 9-2.401 permits certain uses, CCMC § 9-2.402 permits other uses with a “conditional use permit.” Among these uses is “[g]overnment or quasi-government correction, probation or prison facilities and services.” CCMC § 9-2.402(p). CoreCivic’s use of the Facility for immigration detention services and USMS detention services is thus permitted under CCMC § 9-2.402(p) as a conditional use. This is consistent with the Facility’s historical use as well as the City’s own interpretation of the Zoning Regulations.

The California City Final General Plan 2009-2028, adopted by the City Council in 2009, expressly recognizes that the “Facility houses over 2,300 Federal detainees awaiting deportation.” (https://www.californiacity-ca.gov/CC/index.php/planning/final-general-plan-2009-2028/downloa d, at page 5-15.) Between 2000 and 2010, the Facility housed criminal aliens in the custody of BOP who were subject to removal at the completion of their sentences. (Ex. 1, ¶¶ 10–12.) And between 2010 and 2013, the Facility housed more than 9,500 civil immigration detainees in the custody of ICE. (Id., ¶ 14.) Indeed, those immigration detention services were performed pursuant to an IGSA between the City and ICE. (Ex. 1, ¶¶ 13–14; Ex. 7, ¶ 8 and Exhibit B at 2 and 4 of 22.) The City did not require CoreCivic to obtain a new CUP for any of these populations, nor has it ever found that CoreCivic needs a new one.6
The City’s interpretation is also consistent with the interpretations of both Kern County and the State. The Kern County Assessor classifies the Facility with a use code of “1716 – Detention Facility/Prison.” (Ex. 3, ¶ 32 and Attachment M at Page 110–111 of 161.) And the Certificates of 6 See Anderson First Coal. v. City of Anderson, 130 Cal. App. 4th 1173, 1193, 30 Cal. Rptr. 3d 738, 754 (2005) (holding city’s “interpretation of its own general plan” and its “view of the meaning and scope of its own [zoning] ordinance is entitled to great weight unless it is clearly erroneous or unauthorized.”) (alteration in original and citation omitted).

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Occupancy issued to the Facility by the State Fire Marshal list the occupancy classification as Institutional Group I-3. (Ex. 3, ¶ 25.)
Moreover, the California Building Code, which CCMC § 8-1.01 adopts as the Municipal Code for Building and Safety, defines Institutional Group I-3 occupancy to “include buildings or portions of buildings and structures that are inhabited by more than five persons who are under restraint or security.” Cal. Building Code § 308.4. The Building Code further provides that Institutional Group I-3 “shall include, but not be limited to the following: Correctional Centers … Detention centers … Jails … Prisons … Temporary holding facility.” Id. (emphasis added.) Further, the Conditional Use Permits have not expired. The City has never taken any action to revoke the Conditional Use Permits, which run with the land unless they expire or are revoked.

See CCMC § 9-2502(a). CCMC § 9-2.2502(c) further provides that the City must provide due process, which includes notice of revocation and a revocation hearing, before revoking any conditional use permit. These requirements are consistent with the City’s constitutional due process obligations, which prohibit it from depriving any person “of life, liberty, or property, without due process of law.” U.S. Const. amend. XIV, § 1. If the City were to now attempt to revoke the Conditional Use Permits without complying with these procedural requirements, the City would be in violation of not only its own regulations but also CoreCivic’s constitutional rights.

The fact that the Facility’s use for immigration detention is and has always been permitted as a conditional use at the site is also consistent with the City Planner’s conclusions after she investigated this matter and before she approved the SPR Minor:

After the Facility’s reopening in 2025, the City undertook a multistep review to determine what, if any, local approvals were required and whether any such approvals would trigger the notice-andhearing procedures in SB 29. This was a time-consuming process.

The City searched physical archives and digital repositories across Planning, Building, Fire, and the City Clerk for historical records.

The City gathered information from the operator regarding current operations and conducted inspections. Planning compared current operations against historical approvals located during the records search. Staff identified which, if any, administrative approvals (e.g., site plan review) could apply and whether issuing them would be covered by SB 29.
[T]he City’s investigation revealed the following. In January 1998, the City approved CUP 97-01 for a 2,304-bed ‘prison facility’ on approximately 70 acres of the 320-acre Property. In October 1998, the City approved CUP 98-02 expanding the permitted capacity by 512 beds. Neither CUP limits the entitlement to criminal custody or to a particular inmate/detainee population.

Based on my review of the CUP terms, the records on file, and my understanding of current operations, the Facility’s ongoing operations remain within the scope of CUP 97-01 and CUP 98-02 August 20, 2026

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and within the RA-district allowance for ‘correction, probation, or prison facilities and services.’ The CCMC does not define ‘prison.’ In ordinary usage a prison is a ‘place of confinement,’ and immigration detention is a place of confinement of the same kind.

This present determination is also consistent with past practice. In 2010, the City entered Intergovernmental Agreement ODT-10-0002 with the operator for federal detainee housing, including immigration detainees. That use occurred under the 1998 CUPs. So immigrant detention has historically been determined by the City to be a “prison facility” use conditionally permitted under the 1998 CUPs.
(Ex. 7, ¶¶ 5–8 and Exhibits A and B.)
Third, the applications for appeal assert that CCMC § 9-2.103 requires the City Council to resolve any ambiguity as to whether the Facility’s use for immigration detention is in fact permitted before the SPR Minor and the Business License may be approved. This argument is also wrong because there is no ambiguity for the City Council to resolve. To the extent one may have existed in the past, the City resolved it years ago by allowing CoreCivic to use and continue using the Facility for immigration detention. The City itself entered into an IGSA with ICE for the same use under the Conditional Use Permits in 2010. (Ex. 1, ¶¶ 13–14; Ex. 7, ¶ 8 and Exhibit B at 2 and 4 of 22.)
Fourth, the applications for appeal assert that, even if the Zoning Regulations permit the Facility’s use for immigration detention services, CoreCivic must follow the procedures under CCMC § 9-2.2501 to obtain a new CUP because it has somehow “converted” the Facility into an immigration detention facility. This argument improperly assumes that CoreCivic has exceeded the scope of the Conditional Use Permits by using the Facility for immigration detention. As explained in detail above, that assumption is false.

Fifth, the applications for appeal assert that CCMC §§ 9-2.2803(b) and 9-2.2804(c) are enforcement provisions that require the City to revoke or suspend a business license if the licensee is operating without a business license. This argument is wrong for several reasons.

These enforcement provisions do not authorize the City to revoke or suspend CoreCivic’s Business License. Instead, they are Zoning Regulations that authorize City employees to enter and inspect the premises (but not a building unless the owner consents) “affected by this chapter,” see CCMC § 9-2.2803(b), and the City to file a lawsuit to enjoin a land use “contrary to this chapter,” see CCMC § 9-2.2804(c).

Moreover, the “chapter” these sections refer to is the Zoning Regulations Chapter under “Title 9, Land Use and Development, Chapter 2 – Zoning.” They are thus irrelevant to the City Clerk’s issuance of CoreCivic’s Business License, which is governed by the Business Licenses August 20, 2026

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Chapter under “Title 3, Finance, Chapter 2, Revenue, Article 3, Fees and Charges, Division 2, Business Licenses.”7
Nonetheless, CoreCivic is not in violation of the Zoning Regulations because both its historical and current use of the Facility for ICE immigration detention and USMS detention services is permitted with the Conditional Use Permits. If the City Council were to suddenly disallow that permitted use, CoreCivic’s continued use of the Facility for that same purpose would still be deemed a “lawful nonconforming use” under CCMC § 9-2.2802(a). That section expressly provides that “a use of property existing after April 4, 1966, which was permitted by the then current zoning regulations of the City, but which was subsequently prohibited by the zoning regulations, is a lawful nonconforming use.” Id.

The applications for appeal also incorrectly cite to CCMC § 3-2.3.201, which prohibits the operation of a business “without having first obtained a license as provided in this Chapter,” or “after the date of such suspension or revocation without having again procured a license.” That section does not apply because CoreCivic had a business license to operate a detention facility.

Although it expired, CoreCivic’s business license was never suspended or revoked.

Nevertheless, these enforcement provisions of the Business Licenses Chapter do not permit the DND Coalition or the ILRC to file an appeal to suspend or revoke the City Clerk’s grant of the Business License. CCMC § 3-2.3.214 authorizes the City Clerk to examine a business premises and demand to see a business license, and to file a complaint if the Clerk finds a violation of the Business Licenses Chapter (not the Zoning Regulations).

CCMC § 3-2.3.208 also allows the City Clerk to suspend or revoke a license, but it requires the City Clerk to provide written notice of a suspension or revocation and permits the licensee to file an appeal to the City Manager. CCMC § 3-2.3.208(a) and (b). If the licensee files an appeal, the City Manager must then conduct a hearing to determine whether the licensee willfully or knowingly violated the Municipal “Code or laws of the State” or failed to follow their provisions.

See CCMC § 3-2.3.208(c)(4) and (6).

These enforcement sections do not apply here because the City Clerk did not suspend or revoke CoreCivic’s Business License, and CoreCivic—the licensee—is not filing any such appeal.

Nothing in these sections permits the DND Coalition or the ILRC—neither of whom is the licensee—to file an appeal, even if the City Clerk suspended or revoked CoreCivic’s Business License, much less to file an appeal of the City Clerk’s issuance of the Business License. These enforcement provisions further prove that the DND Coalition and the ILRC have no right to appeal to advance their abstract sociopolitical goal of ending federal immigration detention. Such concerns should be addressed with the federal government. They have no place in a neutral administrative hearing under the Municipal Code. The City Council should not inject itself into that political issue under the guise of a business-license appeal.
7 The applications for appeal also cite CCMC § 1-3.01, which is a general provision that prohibits any violation of the Municipal Code. But the penalties for a Municipal Code violation do not include revocation or suspension of a Business License. CCMC § 1-3.01(b).

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Sixth, the applications for appeal misleadingly suggest that a judge in a pending federal lawsuit, Gomez Ruiz v. ICE, No. 3:25-cv-09757 (N.D. Cal.), “set forth” “egregious violations of state and federal law” at the Facility which, the application contends, “would require the City to automatically suspend or terminate any existing business license” and “should preclude the City from issuing CoreCivic a business license for the facility in the first instance.” Once again, the application misrepresents both the facts and the law.

As noted above, the enforcement provisions of the Business License Chapter authorize only the licensee to appeal the City Clerk’s suspension or revocation of a license, and only upon notice and a hearing where the City Manager may uphold the suspension or revocation if he or she finds the CoreCivic actually “committed” a violation of the Municipal “Code or laws of the State.” CCMC § 3-2.3.208(a), (c)(4) and (6). Moreover, the City Council cannot suspend or revoke the Business License because the Municipal Code authorizes only the City Manager to make that determination, and the City Manager did not find any violations of the Municipal Code or state law.

CCMC § 3-2.3.208(c). The federal cases and comments that these applications for appeal cite for alleged violations of state and federal law do not change the analysis or otherwise support a finding that CoreCivic willfully or knowingly engaged in violations of the Municipal Code or state law.

The Gomez Ruiz case does not allege that CoreCivic violated either the Municipal Code or the laws of the State. Rather, that case involves allegations that United States agencies and officials violated federal law by allegedly failing to provide constitutional conditions of confinement, legal access, and disability accommodations to detainees at the Facility. Nor has the judge found that CoreCivic committed any violation of any law, municipal, state, or federal. The allegations in the Gomez Ruiz case are thus completely irrelevant to the City Planner’s approval of the SPR Minor and the City Clerk’s issuance of CoreCivic’s Business License.8 The applications for appeal also improperly cite allegations in the Office of Attorney General’s June 15, 2026 Comment Letter (“OAG comment”) and “past public comments.” The OAG comment, however, simply parrots the same unfounded allegations about Facility conditions in Gomez to assert constitutional violations, not state law violations. The OAG comment in turn cites a California Department of Justice (“DOJ”) report that alleges only that the DOJ observed during a Facility visit that the conditions did not conform to ICE’s detention standards. 9 The DOJ
8 In the July 7, 2026 letter, Jehan Lenar cited three federal habeas cases to misleadingly suggest that those federal courts found “the Facility’s substandard conditions, constitutional violations, or both.” CoreCivic was not a defendant in any of those cases. Nor did the courts find constitutional violations stemming from substandard conditions of care at the Facility. In all three cases, the court addressed procedural due process claims based on prolonged detention periods, finding no violation in two of the cases. See Carias Valenzuela v. Warden, No. 1:26-CV-01249 DJC SCR, 2026 WL 901337, at *5 (E.D. Cal. Apr. 2, 2026) (denying habeas petition based on procedural due process claim of prolonged detention period without a bond hearing); Chantha v. Warden, No. 1:26-CV-01052-DJC-SCR, 2026 WL 925995, at *7 (E.D. Cal. Apr. 6, 2026) (denying habeas petition based on alleged facility conditions but granting bond hearing for procedural due process claim of prolonged detention period without a bond hearing); Rivas Campos v. Chestnut, No. 1:26-CV-01330 DJC SCR, 2026 WL 1816190, at *12 (E.D. Cal. June 24, 2026) (finding alleged “conditions do not strongly factor towards a due process violation,” but granting habeas petition based on procedural due process claim of prolonged detention period). 9 Observations made during a pastoral visit two weeks after the DOJ’s visit contradicted the DOJ report’s allegations that the Facility conditions fell below ICE standards. See Kayla Canas, Bishop Joseph Brennan Visits ICE Detention Center, Leads Mass Amid Prior Scrutiny, Mohave Desert News (Feb. 27, 2026), https://www.desertnews.com/ August 20, 2026

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report did not allege, much less find, that CoreCivic committed any violations of federal or state law.10 Indeed, nothing in the OAG comment establishes violations of federal or state law. 11 And
although the applications for appeal fail to identify any particular “past public comment,” such opinions and commentary from the general public—the majority of whom do not reside in California City and lack any property or local interest in this matter—do not prove CoreCivic committed any violations of state or federal law, much less the Municipal Code.

Significantly, the applications for appeal fail mention another lawsuit pending in federal court where the DND Coalition (and the ILRC as a coalition member) has sued the City and CoreCivic based on allegations that the City violated the Municipal Code by approving the Facility’s use for immigration detention and state law by not following the notice and hearing process applicable to building permits under SB 29 before issuing CoreCivic’s Business License.

See Dignity Not Detention Coalition, et al. v. City of California City, et al., No. 1:25-cv-01292 JLT CDB (E.D. Cal.). Although the City Planner’s approval of CoreCivic’s SPR Minor and the City Clerk’s issuance of the Business License were not subject to SB 29, the City voluntarily complied with that statute out of an abundance of caution in defending against the DND Coalition’s lawsuit.

Because the City’s approvals of CoreCivic’s SPR Minor and issuance of the Business License after complying with SB 29 moots those claims, the DND Coalition and the ILRC are improperly using these applications for appeal to avoid their dismissal. The City should not reward their litigation tactic to use these applications for appeal as a pretext to save the DND Coalition’s claims against the City and CoreCivic in that federal lawsuit.
news/article_6bd751cf-7750-4f85-ad0e-11bbbcf40cd5.html (reporting that two weeks after the DOJ visit, Bishop Brennan and parish leaders visited the Facility and “observed ‘absolute cleanliness’ and did not witness ‘awful conditions.’”); Steve Virgen, Fresno bishop leads Mass, prays with detainee at California City Detention Center, Eyewitness News (Feb. 16, 2026), https://kmph.com/news/local/fresno-bishop-leads-mass-prays-with-detainees-atcalifornia-city-detention-center (Bishop “Brennan said that if there were any awful conditions at the facility, he did not see them.”); Chandler Marquez, What California faith leaders saw inside a divisive immigration facility, The Fresno Bee (Feb. 20, 2026), https://www.fresnobee.com/opinion/readers-opinion/article314749157.html (“The areas of the facility we were permitted to see were clean and orderly. Nothing we witnessed in those spaces caused alarm among our delegation, and staff members remained professional to everyone throughout our visit.”). 10 The DOJ report admits that the Facility “was used to house … ICE detainees from 2010 2013.” https://oag.ca.gov/system/files/media/immigration-detention-2026.pdf (PDF at Page 145). 11 Although these applications for appeal do not rely on them, allegations in the OAG comment that CoreCivic violated the Municipal Code are also false. CoreCivic did not conceal the nature of business on its license application. While CoreCivic initially sought a business license and SPR Minor for an immigration detention facility, those applications were amended in August 2025, when CoreCivic learned the USMS also wished to use available space at the Facility for federal pretrial detainees and corrected them for accuracy. Nor did CoreCivic provide an incomplete application.

The Business License Application form provided by the City Clerk in accordance with CCMC Sec. 3-2.3.203(c) was fully completed, and CoreCivic signed the application certifying under penalty of perjury that the information required on the form is true and correct, that it agreed to the terms of the City’s business license requirements, and that it has complied with relevant state and county business license requirements, which include compliance with state workers’ compensation laws. Likewise, the SPR Minor application was accompanied by documents the Planning Department requested because many documents, including a Site Plan, had been previously submitted and there were no changes to the site. Further, the OAG’s criticism that certain historic documents may not be authentic because they were not printed on letterhead or cannot provide copies of prior and subsequently repealed versions of the Municipal Code are unavailing. The OAG does not dispute the City Planner’s testimony or any of the other records that conclusively prove the City issued approval on May 27, 2014 to use 2,560 beds at the Facility (Ex. 3, ¶ 23 and Attachment J).

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V. Conclusion.

For the above reasons, the DND Coalition and the ILRC have no right to file these applications for appeal, and their reasons for the appeals are misleadingly based on false facts and misapplication of the law. The Planning Commission’s and the City Manager’s decisions are correct. CoreCivic respectfully requests that the City Council deny the applications for appeal and uphold: (1) the Planning Commission’s adoption of Resolution No. PC 2026-07-07 denying the DND Coalition’s prior appeal of the City Planner’s approval of CoreCivic’s SPR Minor; and (2) the City Manager’s decision denying the DND Coalition’s prior appeal of the City Clerk’s issuance of CoreCivic’s Business License.

Sincerely,
Daniel P. Struck
DPS/KLN/eap
cc: Brandon A. Sanchez (via email only)
Enclosures: As stated
EXHIBIT 1
EXHIBIT 1
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DECLARATION OF JOHN MALLOY CASE NO. 1:25-CV-01292-KES-CDB

STRUCK LOVE ACEDO, PLC
Daniel P. Struck, Bar #012377
Dana M. Keene, Bar #324993
Shannon L. Knorr, Bar #300399
3100 West Ray Road, Suite 300
Chandler, Arizona 85226
Tel.: (480) 420-1600
Fax: (480) 420-1695
[email protected] [email protected]
[email protected]
Nicholas H. Rasmussen, Bar #285736
Nancy Flores-Castaneda, Bar #357148
McCORMICK, BARSTOW, SHEPPARD,

WAYTE & SMITH, LLP
7647 North Fresno Street
Fresno, CA 93720
Tel: (559) 433-1300
Fax: (559) 433-2300
[email protected]
[email protected]
Attorneys for Respondent-Defendant
CoreCivic, Inc.

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA
Dignity Not Detention Coalition and

JOHN DOE,
Petitioners and Plaintiffs,
v.

City of California City and CoreCivic,
Inc.,
Respondents and Defendants. _________________________________ __
CORECIVIC, INC.,
Real Party in Interest.

Case No. 1:25-cv-01292-KES-CDB

DECLARATION OF JOHN MALLOY
U.S. District Judge: Kirk E. Sherriff
U.S. Magistrate Judge: Christopher D. Baker
I, John Malloy, state the following based upon my personal knowledge.

1. I am over the age of 18 and am competent to testify to the matters set forth in this Declaration.

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DECLARATION OF JOHN MALLOY CASE NO. 1:25-CV-01292-KES-CDB

2. I have been employed by CoreCivic1 since November 2008, when I was hired as Senior Director, Partnership Development with responsibility for managing CoreCivic’s relationships with the states of California, Arizona and Oklahoma, relating to each of those states’ respective correctional services agreements with CoreCivic. For the past seven years, I have held the position of Managing Director, Government Relations with a primary focus on CoreCivic’s relationships with its local governmental partners.

3. The facts set forth are based on my personal knowledge and/or information and knowledge gained in my capacity as a corporate representative of CoreCivic, including information obtained through discussions with other CoreCivic employees and my review of CoreCivic’s corporate records.

4. The California City Correctional Facility (“the facility”) is located at 22844 Virginia Boulevard, California City.2

5. CoreCivic constructed the facility in the late 1990s and began operating it in 2000 under a contract with the Federal Bureau of Prisons.

6. In September 2010, the City of California City entered into a 15-year Intergovernmental Service Agreement (“IGSA”) with the United States Department of Justice, Office of the Federal Detention Trustee to provide an estimated 2,532 federal beds for use by the United States Marshals Service, Bureau of Prisoners, and Immigration and Customs Enforcement, with CoreCivic to be the service provider for those agencies at the facility. Attachment A is a true and correct copy of IGSA ODT-10-0002, which is maintained as a business record of CoreCivic, and reflects the estimated total number of federal beds on page 1.

7. Due to the opening of other facilities and declining population levels at the facility, as well as an acute need by the State of California to reduce overcrowding in its 1 Prior to November 2016, CoreCivic was known as Corrections Corporation of America.
2 The facility has also been variously known at times as the California City Correctional Center, the California City Immigration Processing Center, and the California City Detention Facility.

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DECLARATION OF JOHN MALLOY CASE NO. 1:25-CV-01292-KES-CDB facilities, in 2013, the OFDT authorized CoreCivic to pursue the leasing of the entire facility to the California Department of Rehabilitation and Corrections (“CDCR”).

8. In 2013, CoreCivic entered into a Lease Agreement with CDCR for the use of the 2,560-bed facility. That lease agreement was subsequently extended several times until it terminated in 2024.

9. Although the facility was not used for federal detention between December 2013 and April 2024, neither the City of California City nor the United States cancelled Agreement ODT-10-0002, and it remained in effect until it terminated in September 2025.

10. Once CoreCivic entered into a letter agreement with ICE in April 2025 and began planning to fully restaff the facility to comply with ICE’s requirements, I began to have communications with various City representatives relating to the contract.

11. In early June 2025, City Manager Christopher Lopez requested that we provide tours of the facility for the Mayor, City Council, and various members of the City’s Management Team, which I facilitated on June 17, 2025.

12. At the end of July 2025, I was provided an email from then Director of Public Safety, Justin Vincent, in which he was complimentary of the fire life safety inspection he and Deputy Fire Marshal Hightower conducted. Dr. Vincent noted that there were “just three areas” which needed to be addressed prior to “his final inspection and sign-off for the facility.” Those issues were limited to: 1) installing “704 placards” which indicate to first responders the location of potentially hazardous materials; 2) placement of keys which first responders may use to access the secure perimeter of the facility in the Knox box; and 3) ensuring that City of California City fire and police department radio communications are possible throughout all locations of the facility. Attachment B is a true and correct copy of my email forwarding Dr. Vincent’s report to City Manager Lopez on July 29, 2025, and is a business record of CoreCivic.

13. On July 29, 2025, I received a memorandum from City Manager Lopez regarding the California City Fire Department Inspection. Attachment C is a true and correct copy of this memorandum. In it, the issues raised by the City are limited to the radio issues Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 4 of 82 1 2
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DECLARATION OF JOHN MALLOY CASE NO. 1:25-CV-01292-KES-CDB of which I was aware, as well as financial concerns of the City related to potentially increased demand for police, fire, and EMS response due to any calls for service to the facility.

14. At Dr. Vincent’s suggestion, CoreCivic engaged with the City’s recommended contractor, Roger Goodman, to address the radio communications issue. He conducted tests with the City’s fire department radios on July 30, 2025 and noted that “the signal is very strong inside the facility.” Mr. Goodman confirmed that radio communications were also available with Kern County Communications on existing channels. As a temporary solution, he recommended that first responders change to Kern County channel 5 until a bi-directional amplifier was installed at the facility. Attachment D is a true and correct copy of my July 31, 2025 email to City Manager Lopez forwarding the results of the radio test and is a business record of CoreCivic.

15. In response to follow-up correspondence from the City Manager, Dr. Vincent sent another message on July 31, 2025 noting that once the temporary solution of changing channels in response to public safety call for service at the facility was confirmed to be effective for all fire, police, and ambulance services, he would approve that resolution for 90 days, with the requirement that a permanent solution be provided so that first responders do not have to switch radio channels at the prison when responding to a call for service in the future. He concluded that “the only item from our safety inspection still pending is the communications issue” but directed CoreCivic to remove staff from the facility until the temporary solutions had been confirmed effective for all first responders. Attachment E is a true and correct copy of the email thread containing Dr. Vincent’s email response to the City Manager, on which I was copied, as well as my reply, and is a business record of CoreCivic.

16. That same day, I replied that CoreCivic has had productive conversations regarding the need for full dispatch capabilities and expected work to be completed in the very near future. See Attachment E.

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DECLARATION OF JOHN MALLOY CASE NO. 1:25-CV-01292-KES-CDB

17. To effect the temporary radio communications solution, CoreCivic purchased a repeater trailer to boost the radio signal at the facility to Kern County dispatch. On August 5, 2025, I provided notification that permission had been obtained from Kern County for use of the repeater and provided the license authorization to the City Attorney, City Manager, and Dr. Vincent. Attachment F is a true and correct copy of the City Attorney’s confirmation of receipt of my message and is a business record of CoreCivic.

18. The temporary radio solution was tested, and on August 7, 2025, I received confirmation from Deputy Fire Marshal Hightower that the temporary radio system was now working, along with Fire Clearance, and was instructed to “contact city hall to obtain your business license.” Attachment G is a true and correct copy of the email and attachment I received, which is a business record of CoreCivic.

19. On August 7, 2025, I, along with other CoreCivic personnel, had a meeting at the facility with Acting Director of Public Safety, Lt. Hayes, who confirmed he had verified the radio system was fully functional, but stated there were a few outstanding items for CoreCivic to address relating to potential financial impacts to the City should emergency services be required at the facility. Attachment H is a true and correct copy of Lt. Hayes’ email, which accurately reflects our conversations on that day and is a business record of CoreCivic.

20. On August 8, 2025, CoreCivic provided a complete response to the concerns raised in City Manager Lopez’s July 29th memorandum. In particular, Daren Swenson, CoreCivic’s Senior Vice President and Chief Corrections Officer, confirmed that the radio communications solutions were underway and acknowledged the City’s financial concerns.

Mr. Swenson confirmed, based upon CoreCivic’s considerable experience managing multiple populations for various governmental partners, that the likely need for police response to calls for service is expected to be considerably lower for the ICE population than for prior populations at the facility. Moreover, he noted that since the facility’s construction in 1999, there has never been a single instance requiring the California City Fire Department to respond to a call for service at the facility. Finally, Mr. Swenson Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 6 of 82 1 2
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DECLARATION OF JOHN MALLOY CASE NO. 1:25-CV-01292-KES-CDB explained that the facility’s robust medical unit should reduce the need for emergency medical services, but that CoreCivic has contracted with an ambulance service for any emergency medical transports. Mr. Swenson also confirmed CoreCivic’s willingness to reimburse the City for any costs related to emergency responses at the facility, whether by police, fire, or EMS. Attachment I is a true and correct copy of this letter, which is a business record of CoreCivic.

21. In addition, on August 8, 2025, CoreCivic’s General Counsel, Cole Carter, sent separate correspondence, confirming that CoreCivic would reimburse actual costs incurred by the City for emergency response, indemnify and defend the City, and provide insurance coverage for the City to avoid placing any unnecessary strain on the City’s and its agencies’ valuable responses. Attachment J is a true and correct copy of this letter, which is business record of CoreCivic.

22. On August 13–14, 2025, I was copied on and exchanged multiple emails with the City’s Consultant Planner, Anu Doravari, who noted that she was “coordinating with all City departments to ensure compliance,” requested that CoreCivic submit an application for a sign permit, and asked for a copy of CoreCivic’s response to City Manager Lopez’s July 29, 2025 memorandum. Attachment K is a true and correct copy of that email thread, which included my reply providing the requested documents, and is a business record of CoreCivic.

23. Later on August 14, 2024, I was surprised to receive correspondence from Ms. Doravari stating that she believed SB 29 was applicable to the facility, SB 29 required a Site Plan Review independent of the existing valid Conditional Use Permit for the facility, and that no permit or final project approval would be executed or issued by the City before February 1, 2026. Attachment L is a true and correct copy of this email and is a business record of CoreCivic.

24. Notwithstanding Ms. Doravari’s representation that no permit would be approved, executed, or issued before February 1, 2026, a few hours later, the City Building Department transmitted the completed sign permit documents and payment receipt.

Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 7 of 82 1 2
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DECLARATION OF JOHN MALLOY CASE NO. 1:25-CV-01292-KES-CDB Attachment M is a true and correct copy of the email and attachments received by CoreCivic personnel on August 14, 2025, and is a business record of CoreCivic.

25. I made several requests to City Officials for an explanation as to why a new Site Plan Review is required for the facility when CoreCivic is not making any substantive alterations to the property or its use. Since 1999, CoreCivic has maintained the facility and operated it in conjunction with its government partners, including the United States (to house BOP inmates), the City of California City (to house ICE and USMS detainees), and the State of California (to house CDCR inmates). During each of those prior transitions, the City did not request or require any Site Plan Review, despite changes in the identity of the government entity whose inmates or detainees were housed at the facility.

I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT.

Executed on October 27, 2025.

John Malloy
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 8 of 82

ATTACHMENT A

ATTACHMENT A
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 9 of 82

Page 1 of 21 ends

I
I
4, DUNS Number
159734151

1. Agreement Number 3, Facility Code(s)
ODT-10-0002
I

5. Issuing Federal Agency
U.S. Department of Justice
Office of the Federal Detention Trustee
4601 M. Fairfax Drive, Suite 910
Arlington, Virginia 20530

7. Appropriation Data
I

2. Effective Date
See Block 19.

6. Local Government
California City
21000 Hacienda Ave
California City, California 93505
TAX ID# 62-1806755

8. Local Contact Person
Tom Weil, City Manager

9. Tel: (760) 373-7170
Fax: (760) 373-7532
Ernail: citymqr@ca!iforniacity.com mu

13. Optional Guardlfransportation Services:
[XI Medical Services
U.S. Courthouse

15. Local Government Certification
To the best of my knowledge and belief,
information submitted in support of this
agreement is true and correct, this document
has been duly authorized by the governing of
the Depastmen t or Agency and the Department
or Agency will comply wjth all pro visions set
forth herein.

14. Guard Hour Rate: $53.03
Mlleage shall be reimbursed by the Federal Government at the GSA Federal Travel Regulation Mileage Rate.

16. Signature of Person Authorized to Sign (Local)
vw
Signature
Tom Weil
Name
City Manager, California City o?/z///~
Title Date
Services

10. This agreement is for the housing,
safekeeping, and subsistence of federal
prisoners, in accordance with content set forth
herein.
17,Prisoner and
Detainee Type
Authorized
@ Adult Male
Adult Female
Juvenile Male
Juvenile Female
ICE Detainees

11. Male: 2,276 Female: 256
(Estimated Federal 8eds)
' 12.

See Page #I8

18. Other Authorized 1 19. Signature on Authorized to Sign (Federal) Agency User -
BOP ~J!h~.~>~d Signature -
ICE Scott P. Sterrner
Name
Assistant Trustee for Procurement, OFDT 23 10
Title
" I
Date
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 10 of 82 Detention Services . Operational Contract . California City September 17, 2010
A . 1 Rac kground ........................................................................................................................... 3 A.2 Services Required ................................................................................................................. 3 A.2.1 Standard Receiving and Discharge of PrisonerslDetainees .......................................... 4 A.2.2 Records Management .................................................................................................... 5 A.2.3 Indemnification ............................................................................................................. 5 A.2.4 Transportation ............................................................................................................... 5 A.2.5 Medical Services ........................................................................................................... 7 A.2.5a Prisoner Rape Elimination Act (PW) ........................ .... ................................. 8 A.2.6 Contacts and Incident Reporting ................................................................................... 8 A.2.7 Detainee Work Program ........................................................................................... 9 A.3 Quality Control Management ............................................................................................. 10 A.4 Quality Assurance .............................................................................................................. 10 A.4.1 Inspection Clause ........................................................................................................ 11 A.5 Performance Reviews ....................................... .,. ....................*.......*..*.......................... -12 A.6 Performance Ratings ........................................................................................................ 12 A.7 Performance Matrix ............................................................................................................ 13 A.8 Contact for Agreement Administration .............................................................................. 17 . * A.9 Financial Provls~ons ........................................................................................................... 17 A.9.1 Service Contract Act .............................. ..... ........................................................... 17 A.9.2 Price Schedule ............................................................................................................. 18 A.9.3 InvoiceandPayment ................................................................................................. 18 A . 1 0 Modification and Disputes ............................................................................................ 19 A . 1 1 Termination ..................................................................................................................... 19 A . 12 Litigation ........................................................................................................................ -20 Prisoner Rape Elimination Act Reporting Information ............................................................... 21

Page 2 of 21 ends

Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 11 of 82 Detention Services - Operational Contract - California City September 17, 2010
A.1 Background
Federal detention is a large component of criminal and immigration case processing by the U.S. Marshals Service (USMS) and, U.S. Immigration and Customs Enforcement (ICE), Department of Homeland Security (DHS). Law enforcement initiatives and increases in illegal immigration to the United States have created a complex detention program that the Department of Justice (DOJ) must effectively manage with available detention resources or acquire additional resources to meet increasing demands.

In response to the increasing concern regarding federal detention, the OEce of the Federal Detention Trustee (OFDT) was established by a Congressional directive to exercise all power and fi~nctions authorized by law relating to the detention of federal prisoners and illegal aliens. Accordingly, OFDT leads the development of DOJ detention policy and manages federal detention resources to maximize available detention space.

Currently, non-federal detention bed space for federal detainees and prisoners is acquired through Intergovernmental Agreements (EGAs), where a daily rate is paid to state and Focal governments, and facility-specific contracts with private service providers. The Department of Justice Appropriations Act for 2001 (Public Law 106-553) is designed to allow for the use of non-traditional contract vehicles when acquiring detention and other related services. This authority states:
"Sec. 119 - Nofwithstandiprgany olherprovision of law, including seclion d(d) of the Sewice Conpact Act of 1965 (41 US.C. 353(d)), the Attorney General hereafter may enter into contracts and other agreements, of any reasonable duration, for detention or incarceration space or facilities, including related services, on any reasonaGle basis. " In an effort to operate in the most effective way and receive the maximum benefit of Section 1 1 9 to meet the Government's current and future goals, and acquire additional resources, OFDT desires to award an Agreement to California City for detention services at the California City Correctional Center.

A-2 Services Required
California City will provide, by the terms and conditions identified in this agreement, all necessary personnel, equipment, materials, supplies, and services for the management of comprehensive detention services, which includc, hut are not limited to, security, medical services, food service, safety, and sanitation. Additionally, the facility shall have sound proof rooms to accommodate video conferencing that permit prisoners and their attorneys to communicate in a secure manner which preserve the confidentiality of the attarneyclient relationship.

These comprehensive detention services shall provide for the safe, secure, and humane confinement for male and female population principally consisting of prisoners or Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 12 of 82 Detention Services - Operational Contract - California City September 17, 2010
detainees charged with federal offenses' and detained while awaiting trial or sentencing.

Services are to be provided at the California City.

Performance shall be in accordance with the most current editions of the Federal Performance-Based Detention Standards (FPBDS), Performance-Based Detention Standards for Adult Local Detention FaciIities (ALDF), and Standards Supplement.

California City shall maintain American Correctional Association (ACA) and Joint Comission on Accreditation of Healthcare Organizations (JCAHO) accreditation throughout the life of the agreement.

All services and programs shall comply with this Performance Work Statement (PWS); the U.S. Constitution; all applicable federal, state, and local laws and regulations; applicable Presidential Executive Orders (E.O.); all applicable case law; and Court:

Orders and Consent Decrees. Should a conflict exist between any of the aforementioned standards, the most stringent shall apply. When a conflict exists and a conclusion cannot bc made as to which standard is mare stringent, the Contracting Officer (CO) shall determine the appropriate standard. California City shall comply with DOJ and/or USMS regulation, Congressional mandate, federal law or E.O. and all existing CaIifornia City polices.

California City will:

Provide a means for verification of their ACA and JCAHO accreditation.

Operate in full and complete compliance of the Federal Performance-Based Detention Standards as defined. Those standards are available at http:/lwww. justice.gov/ofdtlmajor-activities.hm
Operate in full complete compliance with California Iaws and regulations. a California City will ensure that all employees and contractors comply with their policies regarding employment suitability and background clearances and that any violations of California City Standards of Conduct are investigated and adjudicated appropriately and promptly.

A.2.1 Standard Receiving and Discharge of PrisonerslXletainees California City agrees to accept federal detainees only upon presentation by a law enforcement officer of the Federal Government with proper agency credentials and shall not relocate a federal detainee from one facility under its control to another without the permission of the Federal Government.

California City shall only release federa1 prisonersJdetainees only to law enforcement officcrs of the Federal Government agency initially committing the detainee (i.e., DEA, ICE, etc.) or to a Deputy United States Marshat (USM). Those detainees who are Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 13 of 82 Detention Services - Operational Contract - California City September 17, 2010
remanded to custody by a USM may only be released to a USM or an agent specified by the USM of the Judicial District.

Federal prisoners detainees sought for a state or local court proceeding must be acquired through a Writ of Habeas Corpus or the Interstate Agreement on Detainers and then only with the concurrence of the Federal Government.

A.2,2 Records Management
AIE records related to agreement performance should be retained in a retrievable format for the duration of the agreement. Except as otherwise expressly provided in this PWS, California City shall, upon completion or termination of the resulting agreement, transmit to the Government any records related to performance of the agreement.

A.2.3 Indemnification
California City shall protect, defend, indemnify, save, and hold hmless the United States Government, the DOJ and its employees or agents, from and against any and all claims, demands, expenses, causes of action, judgments and liability arising out of, or in connection with, any negligent acts or omissions of California City, its agents, subcontractors, employees, assignees, or any one for whom California City may be responsibIe. California City shall also be liable for my and all costs, expenses, and attorneys' fees incurred as a result of any such claim, demand, and cause of action, judgment or liability, including those costs, expenses, and attorneys' fees incurred by the United States Government, the DOJ and its employees or agents. California City's liability shall not be limited by any provision or limits of insurance set forth in the resulting agreement.

In awarding this agreement, the Government does not assume any liability to third parties, nor will the Government reimburse California City for its liabilities to third parties, with respect to loss due to death, bodily injury, or damage to property resulting in any way from the performance of the agreement or any subagreement under this agreement.

California City shall be responsible for all litigation, including the cost of litigation brought against it, its employees or agents for alleged acts or omissions. The CO shall be notified in writing of all litigation pertaining to this agreement and be provided copies of any pleadings filed or said litigation within five (5) working days of receipt of service.

California City shall cooperate with government I egal staff andlor the United States Attorney regarding any requests pertaining to federal or State litigation.

A.2.4 Transportation
California City is responsible for the movernentltransportation of prisoners designated to the institution as requested in writing by the USMS as specified below. Examples of Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 14 of 82 Detention Services - Operational Contract - California City September 17, 2010
circumstances requiring prisoner rnovernent/transportation include, but are not limited to:
outside medical care; transfer or movement tolfrom other Government facilities; and airlift sites. California City's transportation procedures shall ensure staff and prisoner security and safety. California City shall utilize restraint equipment identical to the USMS when one-hone equipment exchange is required (e.g., airlifts).

Transportation and escort guard services will be performed by at least two (23 armed qualified detention or correctiena1 officer personnel under applicable policies, procedures, and practices. California City agrees to augment such practices as may be requested by the USMS to enhance specific requirement for security, prisoner monitoring, visitation, and contraband control.

California City shall establish procedures for the disposition of prisonerldetainee propertylfunds upon final transfer from the facility. California City shall establish procedures to allow prisonerldetainee one set of clothes that helshe is wearing at time of final transfer from the facility. California City shall ensure that prisonerldetainee transport clothing provided is properly fitted, climatically suitable, durable and presentable. These procedures shall be approved in writing by the USMS.

Specific services, California City agrees, upon request of the USMS in whose custody a prisoner is held, to provide:
1) Transportation and escort guard services for federal prisoners housed at their facility to and from a medical facility for outpatient care {wiflzita per40 y rate); 2) Transportation and stationary guard services for federal prisoners admitted to a medical facility (outside per-day rate; paid on a per-hour basis for Guard Service) ;
3) Transportation and escort guard services for federal prisonersldetainees housed at the facility are transported to and from the San Diego Courthouse four times a week fwitiz in per-day rate);
4) And, the Justice Prisoner and Alien Transportation (JPATS) airlift site in Victorville, CA (outside perday mle: on a gerclrour hnsis for Gunrd Service);
5) Transportation and escort guard services for federal prisoners once a week from the California City Correctional Center to the Nevada Southern Detention Center in Pahrump, Nevada (wit11 irz per-day mfe) .
-- Page 6 of21
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 15 of 82 Detention Services - Operational Contract - California City September 17, 2010
A.2.5 Medical Services
Provide suMjcient on-site medical coverage to accompIish the deliverables listed beIow while containing costs, with an understanding that California City Correctional Center's proximity to other California facilities allows the medical provider to provide certain coverage, care and relief using staff from nearby institutions.

Specifically, the goal is to provide these services on-site:

Initial (intake) mcdical screening of new admissions including administration and reading of PPD tests.

Health appraisals ('physicals) within the 14 day requirement aRer intake. 24 hour/ 7 day basic care to respond to emergent situations and distribute medications.

Sick call Monday through Friday days.

Chronic care clinics when needed,
California City is financially responsible for all medical treatment provided to federal detainees within the facility, California City shall provide either through its shff or contractors the full range of medical care required within the facility including dental care, mental health care, pharmaceuticals, and record keeping, as necessary to meet the standards of the JCAHO. California City shall not be responsible for the cost of necessary outside medical care or treatment. The USMS shall be responsible for the cost of necessary outside medical care or treatment.

In the event of an emergency, California City shall proceed immediately with necessary medical treatment. In such event, California City shall notify the USMS Contracting Officer" Technical Representative (COTR) immediately regarding the nature of the federal detainee's illness or injury and type of treatment provided.

The facility shall have in place an adequate infectious disease control program, which includes testing all prisoners at the facility for Tuberculosis (TB) as soon as possible upon intake (not to exceed 14 days) and read within 72 hours. TB testing shall be accomplished in accordance with the latest Center for Disease Control (CDC) Guidelines and the results documented on the federa1 detainee's medical record. California City shall immediately notify the USMS of any cases of suspected or active TB so that any scheduled transports or production can be delayed until a physician verifies the federal detainee's TB status. (Refer to USMS Directive: 9.4 Prisoner Health- Prisoner Airborne Pathogen Control)
When a federal detainee is being transferred andor released from thc facility, he will be provided with seven (7) days of prescription medication which will be dispensed from the detention facility. When possible, generic medications should be prescribed. Medical records must travel with the federal detainee.

Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 16 of 82 Detention Services - Operational Contract - California City September 17, 2010
If the records are maintained at a medical contractor's facility, it is the detention facility's responsibility to obtain them before a federal detainee is moved.

A.2.5a Prisoner Rape Elimination Act (PREA)
The facility is required to post the Prisoner Rape Elimination Act (PEA) brochurelbulletin in each housing unit of the facility. A11 prisoners or detainees have a right to be safe and free from sexuaI harassment ad sexual assaults, The facility shall include the PREA information in their handbooks and orientations at the California City {Refer to Attachment: Prisoner Rape EIimination Act Infomati on).

A.2.6 Contacts and Incident Reporting
Policy and procedures shall be developed which ensure a positive relationship is maintained with all levels of the federal judiciary. California City's procedures shall ensure a tracking system is established which mandates that all judicial inquiries and program recommendations are responded to in a timely and accurate manner. All judicial inquiries and California City responses, specifically related to a detainee, shall be made part of the detainee's file.

California City shall notify the COTR (with copy to the CO) when a member of the United States Congress or the media requests information or requests to visit the facility.

California City shall coordinate all public information related issues with the COTR. A11 press statements and releases shall be cleared, in advance, with the COTR.

California City, their employees, agents, or sub-contractors shall not release any information regarding the facility population, security level, personal identifiers, or medical issues to anyone outside the USMS without express permission of the CO, COTR, or their designee. Any inquiries regarding any inmate or other matter related to the contract shall immediately be referred to the USMS. California City shall immediately notify the USMS of any incident where they beIieve information was released by their employee, agent, or sub-contractor related to a USMS' matter.

California City shall ensure employees agree to use appropriate disclaimers cIearly stating the employees' opinions do not necessarily reflect the position of the DOJ in any public presentations they make or articles they write that relate to any aspect of contract performance or the facility operations.

California City shall immediately report all criminal activity related to the performance of this contract to the USMS, who shall contact the appropriate law enforcement investigative agency. California City shall immediately report all serious incidents to the COTR. Serious incidents include, but are not limited to the following: activation of disturbance control tearn(s); disturbances (including gang activities, group demonstrations, sexual assaultlabuse, food boycotts, work strikes, work place violence, civil disturbancedprotests); staff uses of force, assaults on staffldetainees resulting in Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 17 of 82 Detention Services - Operational Contract - California City September 17, 2010
injuries that require medical attention (does not include routine medical evaluation after the incident); fires; full or partial lockdown of the facility; escape; any security breaches; weapons discharge; suicide attempts; deaths; hunger strikes; adverse incidents that attract unusual interest or significant publicity; adverse weather; fence damagc; power outages; bomb threats; signiiicant environmental problems that impact the facility operations; transportation accidents if a detainee is in the vehicle.

California City shall provide a safe, secure, and humane environment for alleged victims of sexual assaults and detainees undergoing mental health treatment for sexual assault.

The Government may investigate any incident pertaining to performance of this contract.

California City shall cooperate with the Government on a11 such investigations.

A.2.7 Detainee Work Program
Detainee labor shall be used in accordance with the detainee work plan developed by California City and approved by the USMS. The detainee work plan must be voIuntary, and may include work or program assignments for industrial, maintenance, custodial, service or other jobs. The USMS detainees may not be required to work. USMS detainees may volunteer to work within the secure confines of the contract facility if they sign a waivcr of their right not to work. USMS detainees with suicidal tendencies, attempted escapes or escape history, violent history, gang affiliations or with retainers for pending chargcs with other local, state or federal agencies will not be considered for the volunteer program. USMS detainees me not permitted to act as Trustees and they may not work in positions that permit unsupervised contact with segregated prisoners or detainees of the opposite sex. USMS detainees are restricted from operating equipment that may expose the prisoners to grave bodily harm or any work assignment requiring security risk items and controlled tools which could be uscd to facilitate an escape or used as a weapon that could endanger staff, citizens or other inmates. WSMS detainees will not have access to prisoner or employee records. In addition, the State will ensure that detainees who volunteer to work are denied access to prescription medications.

USMS detainees must obtain required medical clearances before working in the food selvice areas. The detainee work program shall not conflict with any other requirements of the contract and must comply with all applicable laws and regulations. Detainees shall not be used to perform the responsibilities or duties of m empIoyee of California City.

Appropriate safetylprotective clothing and equipment shall be provided to detainee workers as appropriate. Detainees shall not be assigned work that is considered hazardous or dangerous. This includes, but is not limited to, areas or assignments requiring great heights, extreme temperatures, use of toxic substances and unusual physical demands.

Volunteer prisonerjdetainee workers can be paid the identical rates of pay as other California City inmates.

USMS prisoneddetainees shall he rcquired to participate in normal housekeeping duties which help ensure the cleanliness of their housing area. Increases and reductions in Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 18 of 82 Detention Services - Operational Contract - California City September 17, 2010
privileges may be used as incentives to ensure that USMS' detainees keep their living arcas clean (FPBDS Services and Programs Section - G.3 & G.4.).

A.3 Quality Control Management
California City is responsible for management and quaIity control actions necessary to meet the quality standards set forth in this agreement. In compliance with the FAR Clause 52,246-4, Inspection of Services-Fixed Price, California City must provide a Quality Control Plan (QCP) to the CO no later than 60 days after award.

The plan must include:
1) A description of the methods to be used for identifying and preventing defects in the quality of service performed;
2) A description of the records to be kept to document inspections and corrective or preventive actions taken;
3) Records of inspection that must be kept and made available to the Contracting Officer, when requested, through the agreement performance period and for the period after agreement completion until finaI settlement of any claims under this agreement.

A.4 Quality Assurance
The Government quality assurance (QA) is comprised of the various functions, including inspection, performed by the Government to determine whether a provider has fulfilTed its agreement obligations pertaining to quality. The Government's QA program is not a substitute for quality control by the provider.

Each phase of the services rendered under this agreement is subject to Government inspection both during California City's operations and afier completion of the tasks.

When California City is advised of any unsatisfactory condition(s), California City shaIl submit a written report to the CO addressing correctivelpseventive actions taken. The COTR may check California City's performance and document any non-compliance, but only the CO may take formal action against California City for unsatisfactory performance.

The COTR will be designated subsequent ta agreement award and a delegation of COTR duties and authority will be furnished to California City. The Government may reduce California City's invoice or otherwise withhold payment for any individual item of nonconforming service observed as specified in Contractor's Failure to Perfom Required Services. The Government may apply various inspection and extrapolation techniques to determine the quality of service and the total payment due.

Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 19 of 82 Detention Services - Operational Contract - California City September 17, 2Qi0
A.4.1 Inspection Clause
Failure to Perform Required Services
The rights of the Government and remedies described in this section are in addition to all other rights and remedies set forth in this solicitation. Specifically, the Government reserves its rights under the Inspection of Services and Termination clauses. Any reductions in the contractor's invoice shall reflect the contract" reduced vaIue resulting from the contractor's failure to perform required services. The contractor shall not be relieved of full performance of the services hereunder and may be terminated for default based upon inadequate performance of services, even if a reduction was previously taken for any inadequate performance.

This agreement incorporates FAR clause 52.246-4 Inspection of Services-Fixed-Price:
(a) Definition. "Services," as used in this cIause, includes services performed, workmanship, and material furnished or utilized in the performance of services. (b) The Contractor shall provide and maintain an inspection system acceptable to the Government covering the services under this contract. Complete records of all inspection work performed by the Contractor shall be maintained and made available to the Government during contract performance and for as Iong afterwards as the contract requires.
(c) The Government has the right to inspect and test all services called for by the contract, to the extent practicable at all times and places during the term of the contract.

The Government shall perform inspections ad tests in a manner that will not unduly delay thc work.
(d) If the Government performs inspections or tests on the premises of the Contractor or a subcontractor, the Contractor shall furnish, and shall require subcontractors to furnish, at no increase in contract price, all reasonable facilities and assistance for the safe and convenient performance of these duties.
(el If any of the services do not conform to contract requirements, the Government may require the Contractor to perform the services again in conformity with contract requirements, at no increase in contract amount. When thc defects in services cannot be corrected by re-perfomance, the Government may-
(1 $ Require the Contractor to take necessary action to ensure that future performance conforms to contract requirements; and
(2) Reduce the contract price to reflect the reduced value of the services performed. - Page 11 of 21 ,- P
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 20 of 82 Detention Services - Operational Contract - California City September 17, 2010
(0 If the Contractor fails to promptly perform the services again or to take the necessary action to ensure hse performance in conformity with contract requirements, the Government may-
(1) By contract or otherwise, perform the services and charge to the Contractor any cost incurred by the Government that is directly related to the performance of such service; or
(23 Terminate the contract for default.
(End of clause)
A.5 Performance Reviews
In accordance with the Federal Acquisition Regulations (FAR), subpart 37.601 Performance-based Acquisition, the Govemment must have a method of assessing contractor performance against performance standards. Further, the agreement provides procedures for seductions to the price of a fixed-price agreement when services are not performed or do not meet agreement requirements. This Performance Summary establishes the performance level required by the Government to meet the agreement requirements.

The following methods of surveillance may be used in the assessments of agreement performance:

A) Svstcrnatic: These reviews will be scheduled inspections focusing on a specific discipline. Assessments may be performed by Government monitors or by other parties designated by the Government.

B) Ad-Hoc: These reviews will be conducted as a resuIt of special interests arising from routine monitoring of the contractor's quality control system an unusual occurrence pertaining to the agreement or other Govemment concerns.

A.6 Performance Ratings
The service requirements are divided into various disciplines, each of which ha5 a number of key functions. Successful performance of a key function is essential for successhl performance of the related disciptine. Each discipline comprises a specific percentage of the overall agreement requirement. Reductions in agreement price will be based on these percentages applied to the averall monthIy invoice.

At the conclusion of any review, a report will be written and an adjectival rating of contractor performance within each discipline will be assigned. The following rating system will be used:
--- Page 12 of 21 P - -
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 21 of 82 Detention Services - Operational Contract - California City September 17, 2010
Excellent: The program conforms to the FPRDS in an exceptional manner and conformance is maintained with exceptional internal controls. Policies and procedures for achieving the program standards are documented and adequate for the mission of the facility; the policies and procedures are communicated to staff; the policies and procedures are fully implemented; and the desired outcome is achieved. Level of performance in the aggregate exceeds the minimum performance standard by substantial margin; deficiencies are nonexistent or extremely minor.

Good: The program conforms to the FPBDS in an acceptable manner. Internal conlrols limit procedural deficiencies. The facility mare tl~an accomplishes the requirements of program standards. Level of performance in the aggregate meets the performance standard: deficiencies are minor and offset by outstanding elements of performance within the review guideline.

Acceptable: The program is meeting the requirements of the FPBDS. There are no breakdowns that would keep the program from continuing to accomplish the mission of the facility. Level of performance in the aggregate meets thc performance standards; deficiencies are minor and there are no outstanding elements of performance present within the review guideline. -- Deficient: The program is unable to meet the requirements of one or more of the FPBDS. Internal controls are weak, resulting in serious deficiencies in one or more areas. Thc level of performance in the aggregate faits to meet the perfomance standards: deficiencies are pervasive.

At-Risk: Operation of the program is impaired to the point that the facility is unable to accomplish Its mission. The program is unabIe to meet the requirements of the FPBDS and is unlikely to meet those requirements in the foreseeable future without substantial corrective action. The level of performance in the aggregate fails to meet the performance standards: def ciencies require immediate corrective actions.

A.7 Performance Matrix
This Performance Matrix serves to communicate what the Government intends to qualitatively inspect. The matrix identifies:

A. Each service requirement and the key functions essentiaI to successful perfomance of each agreement requirement;
B. Define the minimum performance rating acceptable for each agreement requirement; and
-- Page 13 of 21
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 22 of 82 Detention Services - Operational Contract - California City September 17, 2010
C. Specify the maximum percentage of total agreement value attributable to each agreement requirement.

Oh~ective - Addresses policy development and monitoring; internal quality control; maintenance of detainee recorcls, funds, and property; admission and orientation procedures; detainee release; and accommodsttions for the disabled.

Securitv and Control
Objective - Addresses the issuance of policies and procedures to staff; appropriate use of force; maintenance of'daily incident logs; emergency readiness; and detainee accountability and discipline.

Value: 20%
Minimum Successful Performance Rating: Acceptable

Page 14 of 21 ends

Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 23 of 82 Detention Services - Operational Contract - California City September 17, 2010
Food Service
Objective - Address basic sanitation procedures and the adequacy of meals provided to detainees. 1 Sarlitatron Kecpire~ncnts - - - . . - -
tlnsurc Meals we V;lricd - -- . I Special 13icts
Staff and Detainee Communication
Ohjective - Address opportunities for detainees to communicate with staff; detainee grievance procedures; and the prevision of diversity training.

I value: 5% I
(tl:.1) CK.12) _ Sl;~l'i'C>ctrtinec C:rlrnmu~licntion . - -- -LY Tnining -- -~ E.3)(K13 Dctainee Grievances
Safe@ and Sanitation
Ilhjectivc - Addrcsscs the adequacy of fire safety programs; the co~~tml of dangerous materials andlor hazards; air quality, noise levels, and sanitation of the facility; and the cleanliness of clothing and bedding.

I Value: 5% I

Page 15 of 21 ends

Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 24 of 82 Detention Services - Operational Contract - California City September 17, 2010
exercise opportunities; access to lcgal materials and legal representation; access to a telephone; visitation privileges; and the handling of detainee mail and correspondence. the adequacy of procedures to respond to allegations of staff misconduct.

Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 25 of 82 Detention Services - Operational Contract - California City September 17, 2010
A.8 Contact for Agreement Administration
California City shall designate a person to serve as the agreement administrator for the requirement. The agreement administrator is responsible for overall compliance with agreement terms and conditions. California City designation of representatives to handle certain finctions under this agreement does not relieve the agreement admirlistrator of responsibility for agreement compliance.

A.9 Financial Provisions
Name
Title
Address
Zip Code
Telephone
FAX
E-Mail
Address
A.9.1 Service Contract Act
Tom Wei?
California City City Manager
2 1000 Hacienda Avenue
California City, California
93505
(760) 373-7 170
(760) 373-7532
citymgr~califom~acit~~com
This Agreement incorporates the following clause by rekrence, with the same force and effect as if it was given in full text. Upon request, the full text will be made available.

The full text of this provision may be accessed electronicaEly at this address:
www.arnet.gov.

Federal Acquisition Regulation Clause(s):

52.222-4 1 Service Contract Act of 1 965, as Amended (July 2005)

52.222-42 Statement of Equivalent Rates for Federal Hires (May 1989)

52.222-43 Fair Labor Standards Act and the Service Contract Act - Price Adjustment (Multiyear and Option Contracts) (May 1989)
The current Statc of California City, California wage rates shall be the prevailing wages unless notified by the Federal Government.

Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 26 of 82 Detention Services - Operat~onal Contract - California City September 17, 2010
A.9.2 Price Schedule
The Federal Government will use various price analysis techniques and procedures to ensure the per-diem rate established by this Agreement is considered a fair and reasonabIe price. Examples of such techniques include, but are not limited to, the following:

1. Comparison of the requested per-diem rate with the: independent govement estimate for detention services, otherwise known has the Core Rate;

2. Comparison with per-diem rates at other state or local faciIities of similar size and economic conditions;

3. Comparison of previously proposed prices and previous Federal Government and commercial contract prices with current proposed prices for the same or similar items;

4. Evaluation of the provided jail operating expense information; The firm-fixed per-diem rate for services is $77.50, and shall not be subject to adjustment on the basis of California City actual cost experience in providing the service. The perdiem rate shall be fixed for a period from the effective date of the Agreement forward for 36 months. The per-diem rate covers the support af one federal detainee per "federal detainee day", which shall include the day of arrival, but not the day of departure.

After 36 months, if a rate adjustment is desired, the Local Government shall submit a request through the Electronic Intergovernmental Agreements area of the Detention Services Network (DSNetwork). All information pertaining to the jail on DSNetwork will be required before a new per-diem rate can be considered.

A.9.3 Invoice and Payment
California City shall prepare and submit for certification and payment, original and separate invoices each month to the USMS Southern District of California. To constitute a proper monthly invoice, the name and address of the facility, the name of each federal detainee, his specific dates of confinement, the total days to be paid, the appropriate per diem rate, and the total amount billed (total days multiplied by the rate per day) shall be listed, along with the name, title, complete address and telephone number of the official responsible for invoice preparation. The invoice shall be submitted to the COTR at the address listed below must include:

Name and address of California City;
Invoice date and number;
Agreement number;
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 27 of 82 Detention Services - Operational Contract - California City September 17, 2010
Description, quantity, unit of measure, unit price and extended price of the services provided;
'Terms of any discount for prompt payment offered;
Name and address of official to whom payment is to be sent; a Name, title, and phone number of person to notify in event of defective invoice; and a Taxpayer Identification Number; and
Electronic funds transfer banking information in accordance with PAR 52.232-33, Payment by Electronic Funds TransferCCentzrtl Contractor Registration.

The invoice shall be sent to:

USMS Southern District of California
Address: Edward J. Schwartz Courthouse
U.S. District Court
Southern District of CA
940 Front Street
San Diego, CA 92101-8900
The Government will make payments to California City on a monthly basis, promptly pursuant to the Prompt Payment Act after receipt of an appropriate invoice.

A 0 Modification and Disputes
Either party may initiate a request for modification to this Agreement in writing. All modifications negotiated will be effective only upon written approval of both parties.

Disputes, questions, or concerns pertaining to this Agreement will be resolved between appropriate officials of each party. Both the parties agree that they will use their best efforts lo resolve the dispute in an informal fashion through consultation and communication, or other forms of non-binding alternative dispute resolution mutually acceptable to the parties.

A 1 Termination
This Agreement shall terminate after fifteen (15) caIendar years or by either party upon one-hundred and eighty days (1 80) advanced written notice to the ether party. Within 180 days of the giving, or receipt, of such notice the USMS shall retake custody of all prisoners(s) transferred to the California City under this Agreement. The City of California City agrees to consult with the USMS and OFDT at least 90-days prior to any action(s) to terminate to allow sufficient time to prepare for loss and replacement of services.

Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 28 of 82 Detention Services - Operational Contract - California City September 17, 2010
A.12 Litigation
The Federal Government shall be notified, in writing, of a11 litigation pertaining to this Agreement and provided copies of any pleadings filed or said litigation within 5 working days of the filing.

The Local Government shall cooperate with the Federal Government Iegal staff andlor the United States Attorney regarding any requests pertaining to Fcderal Government or Local Government litigation.

Page 20 of 21 ends

Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 29 of 82 Prisoner Rape Elimination Acf
SEXUAL ASSAULT A\VARENESS
Tlus document is requested to be posted in each
Housing Unit Bulletin Board at aIl Contract
Detention Fadties. This document may be used
and adapted by Intergoremmental Semice
-1greement Pro\-iders.
\YhiIe detained by the Depnrtment ofJustrce.

Unitcd Sratcs Sfarshats Service, you have a right to
be safe and free from sexual harassment and
sexual assaults.

Definitions
A. Detainee-on-Detainee Sexual
Abuse/Assault
One or more detainees engaging in or
attempting to engage in a sexu~l act with
another detainee or the use of threats,
intimidation, inappropriate touching or
other actions and/or communications by0 one
or more detainees aimed at coercing and/or
pressuring another detainee to engage in a
sen~al act.

B. Staff-on-Detainee Sexual Abuse /Assault
Staff member engaging in, or attempting to
engage in a sexual act with any detainee or the
intentional touch~ng of a detainee's genitaha,
nrlus, groin, breast, inner thigh, or buttocks with - the intent to abuse, humiliare, harass, degrade, arouse, or grati$ the sexual desires of any
person. Sexual abuse/assault of detainees
by staff or othcr detainees is an
inappropriate use of pan-er and is
prohibited bx~ DOJ policy and the law.

C. Staff Sexual Misconduct is:

Sexual behavior between a staff member and
detainee which can include, bur is not limited to
indecent, profane or abusive language or
gesmes and inappropriate visual surveillance of
detainees.

Prohibited Acts
h dctaincc, xvl~o engages in inappropriate sexual
behavior with or directs ~t at others, can be
charged with the follon.ing Prohbited Acts under
the Detamee Disciplinan- Policy.

Using Abusive or Obscene Language
w Sexual Assault
Making a Sexual Proposal
E Indecent Exposure
Engaging in Sex Act
Detention as a Safe Environment
\Y~hile you fire detained, no one has the right to
pressure you to engage in sexual acts or engage in
unwanted sexual behavior regardless of your age,
size, race, or ethniclty. Regardless of your sexual
orientation, you have the right to be safe from
unwanted sexual advances and acts.

ConfidentiaLitv
Information concerning the identity of a detainee
victim reporting a sexual assault, and thc facts of
the report itself, shd be limited to those who
have the need to !mow in order to make decisions
concerning the detainee-\-ic tim's welfare and for
lam enforcement h~vescigative put-poses.
medical staff, supervisors or Deputy U.S.

Marshals. Staff members keep the reported
information confidential and o+ discuss iv with
the appropriate officials on a need to know basis.

If ?ou are not comfortable reporting the assault to
staff, you have other options:
r Write a letter reporting the sc~ual misconduct
to the person in charge or the United States
Pvfarshal. To ensure confidentialin., use speck1
(Legal) mail procedures.

File an Emergenq Detainee Grievance - If
you decide Tour complaint is too sensiuve to
file -with the Officer in Charge, you can file
your Grievance kectly with the F~eld O fhcc
Director. You can get the forms from your
housing unit officer, or a Eadty supemisor.

Write to the Office of Inspector General
(OIG], wl~ich investigates allegations of staff
misconduct. Tbe address is: Office of
Inspector General, U.S. Department of
Justice, 9 50 Pennsylvania Ave. Room 4706,
Washington, DC. 20530
Call, at no expense to you, the Office of
Inspector General (OIG). The phone number
is 1-800-869-4499.

Tndividuals who sexually abuse or assauIt
detainees can only be disciplined or
prosecuted if the abuse is reported.
h publication of the Office of the
Federal Detention Trustee
Washington, DC
Published Febmq 2008
Re~ort A11 Assaults!
If YOU become a victim of a sexual assault, you
should report it immediately to any staff person
you trust, to include housing officers, chaplains,

Page 21 ends

Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 30 of 82

ATTACHMENT B

ATTACHMENT B
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 31 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 32 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 33 of 82

ATTACHMENT C

ATTACHMENT C
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 34 of 82 To: John Molloy, CoreCivic
From: Christopher Lopez, City Manager, City of California City Date: July 29, 2025
Re: California City Fire Department Inspection of 22844Virgina Blvd. on July 22, 2025 As you know, I am the City Manager for the City of California City (City). This letter is being sent as the City has substantial concerns related to the re-opening of the facility at 22844 Virginia Blvd. As detailed further below, the facility does not comply with applicable codes and the operation of the facility does or will pose a serious and imminent threat to the health and safety of the community of California City, City’s emergency personnel, future detainees, those employed at the facility and visitors.

Unless and until CoreCivic can demonstrate that it complies with all applicable codes and can operate in a manner that is safe for the community of California City, the City’s emergency personnel and those employed or detained at the facility, the facility cannot legally operate in the City.

The City’s concerns related to the operation of facility include:

1. Emergency Communications Operations are insufficient (described in detail below regarding the Fire Code).

2. Increased demand upon the City in responding to Penal Code violations or other violations and investigation demands that will require a California City Police Department (CCPD) response.

3. Increase demand upon the City in responding to fires at the facility by the California City Fire Department (CCFD).

4. Increase demand upon other emergency personnel, including paramedics/ambulances, in responding to medical emergencies.

Fire Code Requirements:

As you are aware, on July 22, 2025, CCFD conducted an inspection, including a radio test, at the CoreCivic facility. As you are further aware, there is a substantial number of individuals

CITY HALL
21000 Hacienda Blvd.

California City, CA 93505
______________________________________
760-373-8661
www.californiacity-ca.gov
Marquette Hawkins
MAYOR
Michael Hurles
Ronald Smith

COUNCIL MEMBERS
__________________
Christopher Lopez

CITY MANAGER
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 35 of 82 expected to be present at the facility. This factor was considered while CCFD conducted the fire life safety inspection.

During the inspection some serious concerns were identified by CCFD. And, while the Director of Public Safety hoped that CoreCivic could address the issues with a one hundred and twenty (120) day extension, it has been determined that is not possible due to the significant threats to the general public’s health and safety, those who are or will be present at the facility including detainees, CoreCivic’s employees, contractors, visitors and first responders.

It should be noted, after the inspection, the City conducted further research, deliberation, and analysis of the hazards and it has been determined that risks to the public’s health and safety are of such significance that the City cannot permit or otherwise allow for the operation of the facility at this time and in its current condition.

By way of background, the City of California City has adopted the California State Fire Code (see California City Municipal Code (CCMC) section 4-1.101 adopting the State Fire Code as adopted by the California Building Standards Commission). With the facility being privately owned and located within the City limits, the California City Fire Department is the authority having jurisdiction for fire life safety and enforcement of Chapter 11 of the Fire Code. Chapter 11 governs Construction Requirements for Existing Buildings which addresses the issue of twoway emergency response communications for existing buildings. More specifically, Fire Code section 1103.2 addresses emergency responder communications capability in the existing facility as follows:
1103.2 Emergency responder communications enhancement in existing buildings.

Existing buildings other than Group R-3 that do not have approved in-building emergency response communications enhancement for emergency responders in the building based on existing coverage levels of the public safety communication systems, shall be equipped with such coverage according to one of the following:

1. Where an existing wired communication system cannot be repaired or is being replaced, or where not approved in accordance with Section 510.1, Exception 1.

2. Within a time frame established by the adopting authority.

Exception: Where it is determined by the fire code official that the in-building emergency responder communications enhancement system is not needed.

According to the City’s Director of Public Safety, pursuant to the Building and Fire Code, this large building is classified as an I-3 occupancy. Further, the Director of Public Safety has determined (as further detailed below) that based on the existing coverage levels of the public safety communications system, the facility does not have an approved in-building emergency responder communications enhancement system in the building. That is, based on the determination of the Director of Public Safety, the current emergency communications system at the facility is not sufficient to meet the emergency communication needs of the facility, first responders or the City.

During the July 22, 2025 inspection, the Director of Public Safety conducted a basic radio test utilizing a fire department portable radio in multiple locations throughout the facility and determined that the building construction did not conform to this section of the Fire Code.

Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 36 of 82 Specifically, the rooms that house the building’s fire panel, the mechanics shop which houses multiple flammable and combustible liquids, multiple IT server rooms, and multiple cells did not have an ability to transmit radio signals to first responders in an emergency as required by the Fire Code.

With an inability to communicate, emergency responders would not be able to radio transmit a “mayday” or “firefighter down” call from multiple critical locations in the facility, nor would law enforcement officers be capable of calling for backup in an emergency. Studies have consistently demonstrated a strong link between communication failures and firefighter fatalities.

Research by the National Institute for Occupational Safety and Health (NIOSH) and the National Fire Protection Association (NFPA) highlights how ineffective communication on the fireground can contribute to line-of-duty deaths.

As such, CoreCivic must demonstrate the emergency communications at the facility meet the requirements of the Fire Code and Director of Public Safety and that CoreCivic has taken all steps necessary to ensure the public’s safety, the safety of emergency responders and all those who are or will be present at the facility.

Conclusion:

Based upon the information available at this time, the City has determined that the facility is not safe to and cannot be operated in the City. More specifically, the California City Fire Department has determined that the facility should not be occupied and utilized for business purposes, until such time that the facility has an approved in-building emergency responder communications enhancement system in the building (that is, fire, police, sheriff, and ambulance radio transmissions will need to be fully operational and capable throughout the entire facility).

The City’s main priority is to ensure the safety of both the public, first responders and those present at the facility. As such, at this time, the City is requesting that CoreCivic and its employees, contractors, staff, and others vacate the premises until such time that the Director of Public Safety has inspected and approved the improvements needed to ensure the safety of personnel during a potential emergency response.

Please note, any additional code violations, safety concerns or other issues may be later communicated to CoreCivic as information becomes available and further inspections are conducted including any inspections necessary related to CoreCivic’s expected application for a business license.

For further questions, comments, or concerns regarding this letter, please feel free to reach out to Justin Vincent, Director of Public Safety.

Respectfully,
Christopher Lopez
City Manager
City of California City
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 37 of 82

ATTACHMENT D

ATTACHMENT D
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 38 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 39 of 82

ATTACHMENT E

ATTACHMENT E
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 40 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 41 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 42 of 82

ATTACHMENT F

ATTACHMENT F
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 43 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 44 of 82 Reference Copy
Conditions:

Pursuant to §309(h) of the Communications Act of 1934, as amended, 47 U.S.C. §309(h), this license is subject to the following conditions: This license shall not vest in the licensee any right to operate the station nor any right in the use of the frequencies designated in the license beyond the term thereof nor in any other manner than authorized herein. Neither the license nor the right granted thereunder shall be assigned or otherwise transferred in violation of the Communications Act of 1934, as amended. See 47 U.S.C. § 310(d). This license is subject in terms to the right of use or control conferred by §706 of the Communications Act of 1934, as amended. See 47 U.S.C. §606.

Page 1 of 3 ends

LICENSEE:

ATTN: RADIO LICENSE GROUP

KERN, COUNTY OF
2601 PANORAMA DR., BLDG. A
BAKERSFIELD, CA 93306-1013

KERN, COUNTY OF

STATION TECHNICAL SPECIFICATIONS
Grant Date
08-01-2025
Effective Date
08-01-2025
Expiration Date
11-01-2025
Print Date
08-02-2025
FCC Registration Number (FRN): 0004514535
Public Safety and Homeland Security Bureau

RADIO STATION AUTHORIZATION
Federal Communications Commission
46PWAP75026489

Radio Service
Regulatory Status
PW - Public Safety Pool, Conventional
PMRS
Frequency Coordination Number
Call Sign
WSJJ774
File Number
0011669211
Fixed Location Address or Mobile Area of Operation
Loc. 1 Area of operation
Operating within a 5.0 km radius around 35-09-10.8 N, 117-51-31.8 W, CALIFORNIA CITY, KERN county, CA
Loc
No.

Frequencies
(MHz)
Sta.

Cls.

No.

Units
No.

Pagers
Emission
Designator
Output
Power
(watts)
ERP
(watts)
Ant.

Ht./Tp
meters
Ant.

AAT
meters
Construct
Deadline
Date
Ant
No.

Antennas
000154.75500000 FB2T 1 11K2F1D
11K2F1E
11K2F3E
8K10F1D
8K10F1E
11 100.000 120.000
000460.20000000 FB2T 1 11K2F1D
11K2F1E
11K2F3E
8K10F1D
8K10F1E
11 100.000 100.000

REFERENCE COPY
This is not an official FCC license. It is a record of public information contained in the FCC's licensing database on the date that this reference copy was generated. In cases where FCC rules require the presentation, posting, or display of an FCC license, this document may not be used in place of an official FCC license.

FCC 601-ULSHS1
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 45 of 82 Reference Copy

Page 2 of 3 ends

Loc
No.

Frequencies
(MHz)
Sta.

Cls.

No.

Units
No.

Pagers
Emission
Designator
Output
Power
(watts)
ERP
(watts)
Ant.

Ht./Tp
meters
Ant.

AAT
meters
Construct
Deadline
Date
Ant
No.

Antennas
000453.75000000 FB2T 1 11K2F1D
11K2F1E
11K2F3E
8K10F1D
8K10F1E
11 90.000 200.000
000151.10000000 FB2T 1 11K2F1D
11K2F1E
11K2F3E
8K10F1D
8K10F1E
11 100.000 150.000
Control Points
Control Pt. No. 1
Address: 22844 VIRGINIA BLVD
City: CALIFORNIA CITY County: KERN State: CA Telephone Number: (760)246-7600 Associated Call Signs
WSL679, KCI548
<NA>
Waivers/Conditions:

Special Temporary Authority is authorized on a secondary non-interference basis.

Antenna structures for land, base and fixed stations authorized for operation at temporary unspecified locations may be erected without specific prior approval of the Commission where such antenna structures do not exceed a height of 60.96 meters (200 feet) above ground level; provided that the overall height of such antennas more than 6.10 meters (20 feet) above ground, including their supporting structures (whether natural formation or man-made), do not exceed any of the slope ratios set forth in Section 17.7(b). Any antenna to be erected in excess of the foregoing limitations requires prior Commission approval. Licensees seeking such approval should file application for modification of license. In addition, notification to the Federal Aviation Administration is required whenever the antenna will exceed 60.96 meters (200 feet) above the ground and whenever notification is otherwise required by Section 17.7 of the Commission's Rules. Such notification should be given by filing FAA Form 7460-1, Notice of Proposed Construction or Alteration, in duplicate, with the nearest office of the Federal Aviation Administration, which form is available from that office.

Licensee Name: KERN, COUNTY OF
Call Sign: WSJJ774 File Number: 0011669211 Print Date: 08-02-2025 FCC 601-ULSHS1
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 46 of 82 Reference Copy

Page 3 of 3 ends

This Special Temporary Authorization may be terminated at the Bureau's discretion, without a hearing, if conditions warrant.

Under no circumstances may the facility(ies) authorized herein become a hazard to air navigation or violate the terms of an international agreement or treaty. If an application for permanent authority is on file with the Commission, this action is taken without prejudice to that application. Post and/or retain a copy of this authorization as required by the Commission's Rules.

Licensee Name: KERN, COUNTY OF
Call Sign: WSJJ774 File Number: 0011669211 Print Date: 08-02-2025 FCC 601-ULSHS1
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 47 of 82

ATTACHMENT G

ATTACHMENT G
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 48 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 49 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 50 of 82

ATTACHMENT H

ATTACHMENT H
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 51 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 52 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 53 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 54 of 82

ATTACHMENT I

ATTACHMENT I
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 55 of 82 Daren Swenson
Senior Vice President and Chief Corrections Officer
5501 Virginia Way, Suite 110, Brentwood, Tennessee 37027, Phone: 615-263-3000, Fax: 615-615-208-1126, www.corecivic.com August 8, 2025

VIA EMAIL
Christopher Lopez, City Manager
[email protected]
City of California City
21000 Hacienda Boulevard
California City, CA 93505

RE: California City, CA July 29, 2025, Memorandum
Dear Mr. Lopez,
CoreCivic appreciates the opportunity to address the issues outlined in the city’s July 29th memo that stems from the city’s fire inspection conducted on July 22, 2025. That letter addressed 4 main concerns:
one related to radio communication issues inside the facility and three items that are interrelated, specifically the potential of increased demand on the Police Department and the Fire Department as well as other emergency personnel like paramedics and ambulance services.

On the radio communication issue, we have worked collaboratively with Roger Goodman with 661 Communications on both a temporary and permanent fix which has already been approved by the city.

We very much appreciate the collaboration that occurred to solve this issue, and we concur that having effective radio communication at the facility is imperative to a safe and secure facility operation.

We also understand the issues raised about the potential impact the facility's operation could have on the limited resources within California City. CoreCivic has partnered with the U.S. Immigration and Customs Enforcement (ICE) since 1983, and we have a long track record of success managing detainees for the federal government. In fact, the company currently houses over 13,000 non-citizens across 18 facilities nationwide. This vast experience has allowed us to implement policies and procedures that significantly reduce the need for local law enforcement and emergency response at our facilities housing ICE detainees. These policies and procedures are further explained in our numbered responses at the end of this letter.

While we are confident that the need for local police, fire and emergency services will be low, we understand that when those calls do take place, they result in costs. Because of this, we commit to fully reimburse the city for any costs incurred responding to any incident at the facility. Furthermore, we will fully indemnify and hold harmless the city of California City against any claims, suits or judgements that arise as a result of the activation and operation of the facility. Further details on cost reimbursement and indemnification have been included in a separate correspondence from our General Counsel, Cole Carter.

Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 56 of 82 C. Lopez, City Manager
August 8, 2025

Page 2 of 4 ends

5501 Virginia Way, Suite 110, Brentwood, Tennessee 37027, Phone: 615-263-3000, Fax: 615-208-1126, www.corecivic.com

1. Emergency Communications Operations are insufficient (described in detail below regarding the Fire Code).

We appreciate the city approving the plan to provide appropriate Emergency Communications Operations as referenced in the email from Shannon Hayes August 7, 2025.

2. Increased demands upon the city in response to Penal code violations or other violations and investigation demands that will require California City Police Department (CCPD) response.

Immigration and Customs Enforcement (ICE) detention is a civil process, not a criminal one, and is used to ensure individuals appear for immigration hearings and asylum proceedings or to facilitate their removal from the United States. ICE detainees are measurably less demanding on investigative resources than inmates serving criminal sentences.

Albeit rare, the most common demand for investigative resources involves requests to investigate allegations of sexual assault. The CoreCivic 14-2-DHS Sexual Abuse Prevention and Response in Immigration Detention Facilities policy provides CoreCivic operated facilities with procedures for complying with the Prison Rape Elimination Act (PREA) of 2003, Department of Homeland Security (DHS) Standards to Prevent Detect and Respond to Sexual Abuse and Assault in Confinement Facilities (79 Fed. Reg. 13100 March 7, 2014), and the Immigration and Customs Enforcement (ICE) 2025 National Detention Standards.

In accordance with the aforementioned statutes, policies, and standards, any allegations of sexual abuse that may constitute criminal conduct must be promptly reported to a law enforcement agency authorized to conduct such investigations. CoreCivic endeavors to establish a written Memorandum of Understanding (MOU) with an external investigating agency, delineating the respective roles and responsibilities of both the facility and the investigative entity in conducting sexual abuse investigations.

The capacity of law enforcement agencies to investigate these incidents is dependent on their available resources.

Criminal investigative referrals remain relatively infrequent. For instance, CoreCivic's Otay Mesa Detention Center (OMDC) in San Diego, CA, averages approximately two investigative requests per month related to PREA allegations. It is important to note that the OMDC population comprises a significant number of U.S. Marshals Service inmates. By contrast, the California City ICE Processing Center (CCIPC) will exclusively house ICE detainees.

If CCPD responds to investigate these allegations, such requests are expected to be uncommon and would depend on available resources. In the event that CCPD does not have the resources to investigate, CoreCivic staff work with ICE staff to conduct an administrative investigation.

Should internal disturbances occur, CCIPC would not request assistance from CCPD. CCIPC would deploy its Critical Incident Response Team (CIRT), whose members are trained to manage such events.

For major incidents, the Special Operation Response Team (SORT) — comprised of 38 specially trained staff from Nevada Southern Detention Center and Otay Mesa Detention Center—can respond within four hours.

Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 57 of 82 C. Lopez, City Manager
August 8, 2025

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5501 Virginia Way, Suite 110, Brentwood, Tennessee 37027, Phone: 615-263-3000, Fax: 615-615-208-1126, www.corecivic.com Public Safety Director Vincent of California City expressed concerns regarding the California City Police Department's (CCPD) ability to respond effectively to potential protests. California’s Law Enforcement Mutual Aid System is designed to support local agencies in maintaining order during emergencies— including incidents of civil unrest—as well as other extraordinary events or catastrophic disasters. As an integral part of the Standardized Emergency Management System (SEMS), the Mutual Aid System operates across four organizational levels: cities, counties, regions, and the State.

Fundamentally, the system facilitates mutual assistance among neighboring law enforcement agencies within an operational area. When an incident exceeds the resources available at the county level, regional agencies provide the necessary support. If regional resources remain insufficient, the Regional Coordinator will contact the Cal OES Law Enforcement Branch to coordinate further resource allocation.

3. Increased demands upon the city in responding to fires at the facility by the California City Fire Department (CCFD).

CoreCivic's California City facility, built in 1999, is equipped with fire detection and suppression systems.

On July 21, 2025, Kristy Hightower of the CCFD completed a fire inspection on CCIPC and fire clearance was granted.

Since CoreCivic has operated the facility, there have been no recorded incidents requiring CCFD to respond to a fire at the site. While we do not anticipate any increased demands on CCFD, CoreCivic is committed to reimbursing the city for any costs related to any emergency response at the facility.

Additionally, we do conduct emergency response drills with first responders and local law enforcement to streamline emergency response services and strengthen community partnerships.

4. Increased demands by other personnel, including paramedics/ambulances, in responding to medical emergencies.

CCIPC has a robust medical unit that is staffed by Physicians, Psychiatrists, Nurse Practitioners, Dentists, RNs, and LPNs, all providing medical care inside of the facility, which greatly reduces the need to transport detainees by ambulance outside for medical care. This medical unit is staffed 24 hours a day, seven days a week, with a physician on call 24 hours a day. Once operational, the facility will be accredited by the National Commission on Correctional Health Care (NCCHC), which is an independent, non-profit organization that provides oversight of correctional facilities across the country, both public and private. NCCHC accreditation requires health service standards and includes audits to ensure compliance. In total, the facility will have over 70 medical personnel providing health care services to the population on a daily basis.

We have coordinated with Hall Ambulance to provide medical transportation in the event a detainee needs to be transported outside of the facility for medical care. CoreCivic transportation staff accompany all outside ambulance transports, providing security detail for any hospital stay. All ambulance transport costs, as well as the costs of providing security, are paid by CoreCivic. There will be no cost to Hall ambulance or the city for any emergency service calls.

Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 58 of 82 C. Lopez, City Manager
August 8, 2025

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5501 Virginia Way, Suite 110, Brentwood, Tennessee 37027, Phone: 615-263-3000, Fax: 615-615-208-1126, www.corecivic.com In closing, we very much appreciate the opportunity to address the concerns raised in your July 29th letter and we trust our response here has alleviated those concerns. Should you have any further questions or wish to discuss them further, please do not hesitate to reach out to me or my team. We are proud of our longstanding partnership with the city and we look forward to continued collaboration in the years to come.

Sincerely,
Daren Swenson
Senior Vice President and Chief Corrections Officer
cc: Victor Ponto, City Attorney
California City, CA
Lieutenant Shannon Hayes, Acting Director of Public Safety California City, CA
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 59 of 82

ATTACHMENT J

ATTACHMENT J
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 60 of 82 August 8, 2025
Christopher Lopez, City Manager
City of California City
21000 Hacienda Blvd
California City, CA 93505
Subject: Public Safety and Emergency Response
Dear Sir:

On behalf of CoreCivic, I am writing to present our firm commitment to ensuring that the activation and operation of the California City Immigration Processing Center (the “Facility”) will not place unnecessary strain on the valuable resources of California City and its agencies. We recognize the importance of a cooperative relationship with the City and wish to set forth the following offers of indemnification, defense, cost reimbursement, and insurance coverage:

Indemnification and Defense
CoreCivic offers to indemnify, defend, and hold harmless the City of California City, as well as its officers and employees, from any liability and all claims, suits, judgments, and damages to the extent such claims, suits, judgments, or damages arise as a result of CoreCivic's acts and/or omissions in the activation, or operation of the Facility.

Reimbursement of Public Safety Costs
To further support the City, CoreCivic offers that, in the event of an incident at the Facility involving (i) a death from other than natural causes, (ii) a loss of control affecting a housing, recreational, medical, or general activity area, or (iii) the serious bodily injury of a member of the public, and to the extent such an incident requires the response of City public safety personnel for safety or emergency services, CoreCivic will reimburse the actual costs incurred by the City due to such response.

Insurance Provisions
CoreCivic also offers to name the City, together with its agents, employees, and representatives, as an additional insured on its general liability policy. A copy of the declaration page of the policy evidencing this coverage will be provided to the City for your records and assurance.

We trust these commitments address any concerns regarding the Facility’s impact on City resources and stand as a testament to CoreCivic’s dedication to responsible partnership. Should you require any clarification or wish to discuss these provisions further, please do not hesitate to contact us.

Thank you for your attention and collaboration.

Sincerely,
Cole Carter, CAO and General Counsel
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 61 of 82

ATTACHMENT K

ATTACHMENT K
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 62 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 63 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 64 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 65 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 66 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 67 of 82

ATTACHMENT L

ATTACHMENT L
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 68 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 69 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 70 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 71 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 72 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 73 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 74 of 82

ATTACHMENT M

ATTACHMENT M
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 75 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 76 of 82 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 77 of 82 California City Building Dept.
21000 Hacienda Blvd.

California City, Calif. 93505
(760) 338-1498
C - Sign Permit Permit Number: 21381
Applicant Approval Date: 08/14/2025
Name: Core Civic LLC Phone: 817-917-8501
Address: 5501 Virginia Way #110
Brentwood, TN 37027
Parcel
Parcel Number: 350 031 02 Zoning:

Address: 22844 Virginia Blvd
California City, Ca 93505
Addition: S13T32R38 Block: Lot(s): S13T32R38
Legal Description: 350-031-02
Section/Township/Range:

Owner
Name: Phone:

Address:
,
Contractor
Contractor Type: Sign
Name: Bennu Enterprises Phone: 615-522-4588
Address: 1116 Fowler St
Old Hickory, TN 37138
Fees and Receipts
Application Fee
Code
3 319
$46.00
Bldg Stand Spec Rev Fund
Code
6 614
$1.00
Min Permit Fee
Code
3 319
$56.00
Fee Description
Total Fees: $103.00
Description
Structure Use: Start Date:

Purpose:

Sign Permit (After the Fact)
installed new vinyl wrap on
existing sign structure for
Core Civic. No other
changes to sign made.

End Date:

Construction Value: $2800.00
Floor Areas Commercial Buildings
8/14/25, 5:18 PM iworq.net/iworq/0_Pages/popupEditLetterPrint.php?sid=D7XRFNFXGCMFMHZJ1FG8MKHZMG602&id=26792170&letterlinkid=307… https://www.iworq.net/iworq/0_Pages/popupEditLetterPrint.php?sid=D7XRFNFXGCMFMHZJ1FG8MKHZMG602&id=26792170&letterlinkid=30790109… 1/3 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 78 of 82 Living Space: Building 1:

Basement/Storage: Building 2:

Garage: Accessory 1:

Decks: Accessory 2:

Porches: Other:

Other: Total:

Total Area:

Structure Area: Site Area: Percentage of Site:

Conditions
Date: Status: Code:

Condition Description:

Condition Comments:

LICENSED CONTRACTORS DECLARATION: I hereby affirm under penalty of perjury that I am licensed under provisions of Chapter (commencing with Section 7000) of Division 3 of the Business and Professions Code, and my license is in full force and effect.

Class: Lic. #: Date: Contractor:

WORKER'S COMPENSATION DECLARATION: I hereby affirm that I have a certificate of consent to selfinsure, or a certificate of Worker's Compensation Insurance, or a certified copy thereof (Sec. 3800, I.A.B.O.) Policy#: Company: Exp: Applicant:

CERTIFICATE OF EXEMPTION FROM WORKER'S COMPENSATION INSURANCE: (This section performance of the work for which this permit is issued, I shall not employ any person in any manner so as to become subject to the Worker's Compensation Laws of California.

Date: Applicant:

NOTICE TO APPLICANT: If, after making this Certificate of Exemption, you should become subject to the Worker's Compensation provisions of the Labor Code, you must forthwith comply with such provisions or this permit shall be deemed revoked.
_______ I, as owner of the property, or my employees with wages as their sole compensation, will do the work, and the structure is not intended or offered for sale (Sec. 7044, Business & Professions Code: The Contractor's License Law does not apply to an owner of property who builds or improves thereon, and who does such work himself or through his own employees, provided that if such improvement is sold within one year of completion, the owner-builder will have the burden of proving that he did not build or improve for the purpose of sale).
_______ I, as of the property, am exclusively contracting with licensed contractors to construct the project (Sec. 7044, Business & Professions Code)
_______ I am exempt under Sec.______________, Business & Professions Code, for this reason:

Date: Owner:

I certify that I have read this application and state that the information is correct. I agree to comply with all City Ordinances and State Laws regulating construction. I certify that in the performance of this work for which this permit is issued, I shall not employ any person in violation of the Labor Code of California relating to Workman's Compensation. This permit becomes null and void if work is not commenced within 180 days from date of issuance.

Signature of Applicant or Agent: Date:
8/14/25, 5:18 PM iworq.net/iworq/0_Pages/popupEditLetterPrint.php?sid=D7XRFNFXGCMFMHZJ1FG8MKHZMG602&id=26792170&letterlinkid=307… https://www.iworq.net/iworq/0_Pages/popupEditLetterPrint.php?sid=D7XRFNFXGCMFMHZJ1FG8MKHZMG602&id=26792170&letterlinkid=30790109… 2/3 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 79 of 82 8/14/25, 5:18 PM iworq.net/iworq/0_Pages/popupEditLetterPrint.php?sid=D7XRFNFXGCMFMHZJ1FG8MKHZMG602&id=26792170&letterlinkid=307… https://www.iworq.net/iworq/0_Pages/popupEditLetterPrint.php?sid=D7XRFNFXGCMFMHZJ1FG8MKHZMG602&id=26792170&letterlinkid=30790109… 3/3 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 80 of 82 City of California City
21000 Hacienda Blvd
California City CA 93505 (760) 373-8661
Receipt No: 9.000003207 Aug 14, 2025
350-031-02/Core Civic
Permits/Fees - Building Permits 46.00
10-3221 Building Permits
Permits/Fees - Building Permits 56.00
10-3221 Building Permits
Total: 102.00
Misc Revenue - Revolving State Fund 1.00
10-02082 Special Revolving State Fund
Total: 1.00
Credit Card Check No: mc 103.00
Payor: 350-031-02/Core Civic
Total Applied: 103.00
Change Tendered: .00
Duplicate Copy
08/14/2025 5:12 PM
Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 81 of 82 Required Inspections Appr'd Date
Set Backs / Land Survey
Underground Plumbing
Footing and Slab
Foundation / Block Walls
Framing Roof Sheathing
Framing Rough (Walls/Shear Panels)
Ventilation Attic/Floor
Rough Electrical
UFER for Electrical Service
Gas Pressure Test
Rough Mechanical
Rough Plumbing
Seepage Pit/Leach Field/Special Trench
Septic Tank
Sewer Line
Drainage / Rain Gutters
Insulation
Lathing
Drywall Nailing
Sewer Compaction
Progress
Fireplace and Stoves
Framing Floor
Masonry and Concrete Walls
Underground Electrical
HVAC
Fire Bucket
Fire Rough
Fire Sprinkler System
Temporary Electrical
Elevation Certification
Asphalt Patch
Concrete Approach with Flow Line
CF1R
CF2R
CF3R
Other
Other
Other

INSPECTION RECORD

POST THIS CARD AT JOBSITE
California City

BUILDING DEPARTMENT
N
O
T
I
C
E

POST THIS CARD IN A SAFE, CONSPICUOUS
PLACE ON JOB. GIVE 48-HOUR NOTICE TO

BUILDING DEPARTMENT WHEN READY FOR
INSPECTION. CALL (760) 338-8387. GIVE A

GOOD PHONE NUMBER, PERMIT NUMBER,
AND WORK TO BE INSPECTED. PLANS SHALL

BE ON JOB SITE OR INSPECTION CANNOT BE
MADE.

P
R
O
J
E
C
T
Address 22844 Virginia Blvd
Owner Core Civic LLC
Phone 817-917-8501
Permit Type C - Sign Permit
Description Sign Permit (After the Fact) installed
new vinyl wrap on existing sign
structure for Core Civic. No other
changes to sign made.

Contractor Bennu Enterprises
Lot S13T32R38 Tract
Permit # 21381 Date 08/14/2025
F
I
N
A
L

DO NOT REQUEST FINAL INSPECTION UNLESS ALL
WORK HAS BEEN COMPLETED Appr'd Date
Building
Smoke Detectors/ CO2 Sensors
Energy Code
Mechanical
Plumbing
Roofing Certification
Grading
Flood Zone
Right of Way Improvements
Solar System
Electrical
Service Panel
Elevation Certificate
Fire
Backflow Certification
Backflow Cert I.D.

Insulation Certificate
Comments:

RECEIPTS MUST BE

SUBMITTED TO BUILDING DEPARTMENT
WITHIN 90 DAYS OR BEFORE PROJECT IS
FINALED (WHICHEVER COMES FIRST.)
**MPU's MUST CONTACT EDISON FOR DISCONNECT**

CERTIFICATE OF OCCUPANCY
DATE:
8/14/25, 5:18 PM iworq.net/iworq/0_Pages/popupEditLetterPrint.php?sid=D7XRFNFXGCMFMHZJ1FG8MKHZMG602&id=26792170&letterlinkid=307… https://www.iworq.net/iworq/0_Pages/popupEditLetterPrint.php?sid=D7XRFNFXGCMFMHZJ1FG8MKHZMG602&id=26792170&letterlinkid=30790106… 1/1 Case 1:25-cv-01292-KES-CDB Document 18-3 Filed 10/27/25 Page 82 of 82 EXHIBIT 3
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DECLARATION OF MARCELO ARIOLA CASE NO. 1:25-CV-01292-KES-CDB

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA
Dignity Not Detention Coalition and

JOHN DOE,
Petitioners and Plaintiffs,
v.

City of California City and CoreCivic,
Inc.,
Respondents and Defendants. _________________________________ __
CORECIVIC, INC.,
Real Party in Interest.

Case No. 1:25-cv-01292-KES-CDB

DECLARATION OF MARCELO
ARIOLA
U.S. District Judge: Kirk E. Sherriff
U.S. Magistrate Judge: Christopher D. Baker

I, Marcelo Ariola, state the following based upon my personal knowledge.

1. I am over the age of 18 and am competent to testify to the matters set forth in this Declaration.

2. I have been employed by CoreCivic1 since April 2007, when I was hired as Senior Director of Site Acquisition. I became Managing Director of Project Development in 2012. As Managing Director of Project Development, I was responsible for leading a team which provided financial analysis, land development oversight, due diligence, 1 Until November 2016, CoreCivic was known as Corrections Corporation of America (“CCA”).

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DECLARATION OF MARCELO ARIOLA CASE NO. 1:25-CV-01292-KES-CDB entitlements, operational systems improvements, and pre-construction services (including planning and ensuring zoning compliance), as well as fostering governmental relations for all projects. In January 2025, I assumed my current position of Vice President, Real Estate.

In that new role, I continue to discharge my prior responsibilities relating to Project Development but also assumed responsibility of oversight and management of facility maintenance at all CoreCivic-owned facilities.

3. The facts set forth are based on my personal knowledge and/or information obtained in my capacity as a corporate representative of CoreCivic, including information obtained through discussions with other CoreCivic employees and my review of CoreCivic’s corporate records.

4. The CoreCivic facility (“the facility”) is located at 22844 Virginia Boulevard, California City. It is at the terminus of Virgina Boulevard and south of Twenty Mule Team Parkway.

5. In 1993, the then California Department of Corrections (“CDCR”) commenced an Environmental Impact Report (“EIR”) (State Clearinghouse Number 93082030) evaluating the environmental effects resulting from construction and operation of a CDCR prison facility on one of two properties located in California City, which included the current site of the facility. Specifically, the CDCR Final EIR addressed a new 2,200-bed prison or up to a 4,400-bed prison complex, and an associated wastewater treatment facility on an adjacent 160-acre parcel.

6. While that report was completed and certified by CDCR in August 1994, due to funding constraints, CDCR chose not to proceed with development of a prison facility in California City.

7. In 1997, CoreCivic’s predecessor, CCA, proposed the construction and operation of a medium security facility in California City, which would occupy approximately 70 acres of a site approximately five miles from downtown California City.

The proposal specified that the facility would have 2,304 general population beds, and Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 3 of 161 1 2
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DECLARATION OF MARCELO ARIOLA CASE NO. 1:25-CV-01292-KES-CDB consistent with federal facility requirements, also include an additional 260 beds over design capacity, for special uses including Restrictive Housing and medical housing.

8. Pursuant to the California Environmental uality Act (“CEA”) guidelines (Section 15163), the City of California City, as lead agency, elected to prepare a supplement to the CDCR Environmental Impact Report and incorporated the original report.

9. The City of California City issued a Notice of Preparation for an EIR Supplement on September 11, 1997. The Draft EIR was completed and circulated for review beginning on October 24, 1997, and comments were prepared and included in the Final EIR Supplement in January 1998 (State Clearinghouse Number 97091045).

10. On January 20, 1998, the City Council of City of California City adopted Resolution No. 01-98-1801, Making Certain Environmental Findings and Adopting a Statement of Overriding Considerations in Connection with the Corrections Corporation of America Prison. Attachment A is a true and correct copy of that resolution, which is maintained as a business record of CoreCivic.

11. As noted in Attachment A, the most significant environmental impacts tend to arise during the construction phase of the facility, rather than during the operations of a completed facility.

12. At a duly noticed public hearing on January 15, 1998, the City of California City Planning Commission recommended granting Conditional Use Permit (“CUP”) 97-01 for the proposed facility. The City Council granted CUP 97-01 on January 20, 1998.

Attachment B is a true and correct copy of Resolution No. 01-98-1902, A Resolution of the City Council Granting Conditional Use Permit 97-01 Prison Facility, which is maintained as a business record of CoreCivic.

13. CUP 97-01 contained a provision stating that it expired twelve months from January 20, 1998 (the date of the City Council’s Approval) if the prison facility operation was not commenced and diligently pursued.

14. In June 1998, CoreCivic diligently pursued the prison facility operation by acquiring the 320-acre site originally contemplated by CDCR and considered by the City.

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DECLARATION OF MARCELO ARIOLA CASE NO. 1:25-CV-01292-KES-CDB Attachment C is a true and correct copy of the Deed for the property, which is maintained as a business record of CoreCivic.

15. Following the acquisition of the property by CoreCivic, the site was subdivided into three parcels. Parcel 1 is approximately 70 acres at the northwest corner of the property and is the site of the facility. Parcel 2 is approximately 35 acres and is directly south of Parcel 1. Parcel 3 is comprised of approximately 215 acres to the east and south of Parcel 1.

16. Completing the requirement to commence and diligently pursue facility operation, construction of the facility began later in 1998.

17. Based upon the final configuration of the site when construction began, in 1998 CoreCivic applied to the City of California City to amend CUP 97-01 and construct two additional 256-bed housing units on the site. A Mitigation Monitoring Plan was approved and adopted by the City on December 1, 1998, and CUP Amendment 98-02 approving the 512-bed expansion of the facility was issued that same date. After an initial extension, in November 2001 the City extended the time for CUP Amendment 98-02 “indefinitely.” Attachment D is a true and correct copy of records relating to the issuance and extension of CUP Amendment 98-02, which are maintained as business records of CoreCivic.

18. Construction of the facility was completed, and in 2000 CoreCivic began to receive Federal Bureau of Prisons inmates at the facility.

19. At no point did the City of California City ever revoke, rescind, or cancel either CUP 97-01 or CUP Amendment 98-02.

20. In 2006, CoreCivic submitted a proposal to the City for construction of a second 2,200-bed facility on the southern 35-acre parcel. The December 2009 Addendum to the Final Subsequent Environmental Impact Report, noted that this proposed second 2,200-bed facility would not have significant operational impacts relating to traffic, air quality, noise, or other factors required for consideration under the California Environmental uality Act. Attachment E is a true and correct copy of the December 2009 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 5 of 161 1 2
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DECLARATION OF MARCELO ARIOLA CASE NO. 1:25-CV-01292-KES-CDB Addendum to the Final Subsequent EIR, which is maintained as a business record of CoreCivic.

21. On December 22, 2009, the City of California City Planning Commission approved CUP 09-04 for the construction and operation of a 2,200-bed facility on that parcel. Attachment F is a true and correct copy of the City of California City Planning Commission Resolution No. 12-09-2990PC to Approve Conditional Use Permit 09-04, which is maintained as a business record of CoreCivic, and does not contain any expiration date.

22. In December 2013, CDCR entered into a lease agreement for the facility. The lease agreement permitted CDCR to utilize up to 2,560 beds at the facility but required CDCR to request permission from CoreCivic if they were to have more than 2,560 inmates assigned to the facility.

23. On May 27, 2014, the City Manager for California City confirmed to both CDCR and CoreCivic that a land use review had been completed and provided authorization and full permitting for use of 2,560 beds at the facility. Attachment G is a true and correct copy of the May 27, 2014 letter from City Manager Tom Weil and is maintained as a business record of CoreCivic.

24. As part of the CDCR lease agreement, significant upgrades related to ADA compliance were made to the facility in two phases. Attachment H is a true and correct copy of the Certificate of Occupancy issued by the Office of the State Fire Marshal for Phase 1 on May 29, 2014, which is maintained as a business record of CoreCivic.

Attachment I is a true and correct copy of the Certificate of Occupancy issued by the Office of the State Fire Marshal for Phase 2 on December 11, 2014, which is maintained as a business record of CoreCivic.

25. Notably, the Office of the State Fire Marshal noted on the Certificates of Occupancy that the occupancy classification of the facility under CCR Title 24 (2013 Edition) was “I-3.” “I-3” is an Occupancy Classification under the California Building Code, formerly known as Institutional Group 3, which includes “buildings or portions of Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 6 of 161 1 2
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DECLARATION OF MARCELO ARIOLA CASE NO. 1:25-CV-01292-KES-CDB buildings and structures that are inhabited by one or more persons who are under restraint or security andare generally incapable of self-preservation due to security measures not under the occupants’ control which includes persons restrained.” The California Building Code notes that this group “shall include, G the following: Correctional Centers Detention centers Jails Prisons Temporary holding facility.” See Attachment J, 2022 California Building Code, Title 24, Part 2, Section 308.4 (emphasis added).

26. On August 18, 2014, the Office of the State Fire Marshal completed and issued its Final Inspection Report and grant of occupancy for the ADA renovations.

Attachment K is a true and correct copy of that Inspection Report, which is maintained as a business record of CoreCivic.

27. In 2016, at the request of CDCR, construction of three additional structures for use as administrative office space outside of the secure southern perimeter of the facility began. Those spaces were completed, and the California City Building Department issued a Certificate of Occupancy for the administrative buildings on January 31, 2017.

Attachment L is a true and correct copy of the Certificate of Occupancy for the administrative structures, which is maintained as a business record of CoreCivic.

28. Beginning in 2017, CoreCivic began to explore proposed development of the eastern 215-acre parcel to construct two 1,512-bed correctional centers. An application for CUP 20-02 was opened with the City, and the notice of Availability of a Draft Environmental Impact Report (State Clearinghouse No. 2017121069) was issued by the City on May 21, 2021. However, because this separate project was placed on “pause” by CoreCivic, CUP 20-02 has not been approved and remains pending.

29. Despite the expiration of the lease of the existing facility to CDCR in 2024, CoreCivic never “shuttered” the facility or discontinued its use as an Institutional Group I3 facility.

30. CoreCivic has consistently utilized and maintained its property for use as an Institutional Group I-3 facility since its completion. It has no intent, and never had any Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 7 of 161 1 2
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DECLARATION OF MARCELO ARIOLA CASE NO. 1:25-CV-01292-KES-CDB intent, to discontinue or abandon the property or to change the use or occupancy classification of the facility.

31. CoreCivic has always employed individuals to provide nearly around-theclock operations and maintenance at the property, seven days a week.

32. Attachment M is a true and correct copy of the Kern County Assessor Record’s Property Detail Report for the facility, which is available at:
https://www.kerncounty.com/government/departments/assessorrecorder/property/assessor-property-search. Of note, the Assessor assigned the facility Use Code 1716 – Detention Facility/Prison.

33. Specifically, while continuing to proactively market the facility, CoreCivic applied to the City of California City and was issued Plumbing Permit No. 21170 on January 7, 2025 for waterline repairs. Similarly, the City issued permit number 20989 on January 15, 2025 for repairs to the facility roof.

34. In addition, the City issued Plumbing Permit No. 21309 on May 14, 2025 to remodel a handicapped shower stall for ADA compliance.

35. Each of those three permits expires one year from the date of issue. The permitted work has been completed for all three permits, and the only outstanding item is the final inspection by the City. None of these permits is a major or significant repair or renovation which requires the issuance of a new Certificate of Occupancy, as confirmed to me by the Building Department on August 14, 2025. Attachment N is a true and correct copy of an email I received from the City of California City Building Department on August 14, 2025 confirming that these permits do not require a new Certificate of Occupancy.

36. On July 14, 2025, I became aware that the City was requiring CoreCivic to submit a Site Plan Review Application Form for the facility.

37. Because there has been no change in use and the Institutional Group I-3 Occupancy Classification of the facility has never changed, there is no need to undertake a Site Plan Review. A Site Plan Review is usually required for a different use which requires Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 8 of 161 1 2
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DECLARATION OF MARCELO ARIOLA CASE NO. 1:25-CV-01292-KES-CDB a change in the Occupancy Classification, such as reuse of a warehouse space into a restaurant.

38. I had numerous telephone calls with Joe Barragan, the City’s Public Works Director, regarding the City’s request that CoreCivic submit a Site Plan Review. He agreed that the City had most of the documents already and noted that CoreCivic was only required to make minimal additional submissions, consisting mainly of ADA Compliance certificates and studies. He represented that this was simply a ministerial review, which would be quickly completed after the fees were paid.

39. As specified by Mr. Barragan, CoreCivic submitted the Site Plan Review Minor application, which I signed on July 22, 2025, along with a letter from me regarding the ADA requirements, a Disabled Accessibility Certification completed after the renovations requested by CDCR in 2014, and some other potentially relevant documents.

Attachment O is a true and correct copy of that submission, which is a business record of CoreCivic.

40. On July 23, 2025, CoreCivic received confirmation that it had paid the City’s 250.00 fee for the Site Plan Review. Attachment P is a true and correct copy of that email confirmation and attached receipt, which are business records of CoreCivic.

41. On the morning of July 24, 2025, I participated in a meeting involving former Public Safety Director Justin Vincent, who had raised some concerns relating to emergency radio communications observed during his inspection of the facility on July 21, 2025.

Specifically, Director Vincent reported that a portable fire department radio did not receive an adequate signal in a few of the locations he tested throughout the facility.

42. At Director Vincent’s suggestion, CoreCivic engaged the City’s radio consultant to obtain and install a mobile repeater trailer to extend the radio signal range.

43. On July 24, 2025, I received confirmation from the City that the ADA Certification we submitted was sufficient and CoreCivic was not required to remit payment for a building inspection. Attachment is a true and correct copy of that email communication and is a business record of CoreCivic.

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DECLARATION OF MARCELO ARIOLA CASE NO. 1:25-CV-01292-KES-CDB

44. A few hours later, I received a second email communication from Public Works Director Barragan, stating that only the fire inspection remained to be completed before CoreCivic’s business license would issue. Attachment R is a true and correct copy of that email communication and is a business record of CoreCivic.

45. On August 7, 2025, CoreCivic received confirmation from Deputy Fire Marshal Hightower that the temporary radio system, which included the repeater trailer acquired by CoreCivic at a cost of more than 75,000, had been tested and approved. Ms.

Hightower further instructed that CoreCivic would have 90 days to install a permanent solution to boost radio signals in the facility.

46. CoreCivic engaged Berk-Tel Communications to install an Emergency Responder Radio System in the facility. Plans were submitted to Deputy Fire Marshal Hightower on August 19, 2025, and after submission of a permit to the Fire Department and payment of a 1,000 plan review fee, the permit was issued by the Fire Department. The City also stated that an additional commercial electrical permit would be required for the installation of the permanent system. Attachment S is a true and correct copy of an email thread I was copied on during the period from August 19–21, 2025 regarding the permitting for the permanent radio solution and is a business record of CoreCivic.

47. Eventually, the commercial electrical permit was issued, and the permanent radio solution was installed with final testing scheduled for Tuesday, October 14, 2025.

Attachment T is a true and correct copy of the email thread I was copied on during the period from August 19 to October 8, 2025, confirming the schedule for the inspection and testing and is a business record of CoreCivic.

48. The City Fire Department, in conjunction with Kern County Communications, confirmed that the permanent radio Emergency Responder Radio System, which CoreCivic installed at a cost of nearly 700,000, was fully operational on October 14, 2025.

49. The facility at issue was, and has been at all times, constructed and operated pursuant to CUP 97-01 and CUP Amendment 98-02, for an Occupancy Classification Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 10 of 161 1 2
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DECLARATION OF MARCELO ARIOLA CASE NO. 1:25-CV-01292-KES-CDB Institutional Group I-3 facility. While the identity of the government partner utilizing the facility has changed several times since 2000, from a zoning and permitting standpoint, the classification and use of the 70-acre site at issue have not changed.

50. Aside from the permitted ADA upgrades requested by CDCR which were completed in 2014 and the construction of additional administrative office space outside of the secure perimeter of the facility, but still on the 70-acre site, CoreCivic has not undertaken any major renovations or modifications of the facility requiring further amendment of the CUP, which remains valid and effective for an Occupancy Classification Institutional Group I-3 facility.

51. CoreCivic has also obtained CUP 09-04 for construction of a separate 2,200- bed facility on the southern 35-acre site, which is separate and distinct from the facility at issue in this lawsuit, and also has a pending CUP 20-02 for construction of a separate and distinct 3,324-bed correctional complex on the eastern 215-acre site. Neither of these permits or applications, however, are relevant to the facility currently being utilized by Immigration and Customs Enforcement.

52. Although no CEA study is required to continue using the existing facility for its intended use, the fact that two additional proposed facilities with a combined capacity of 5,500-beds have been studied extensively on the site with no findings of significant adverse environmental impact further demonstrates that the continued use of the existing facility, merely by a different government partner, will not have any significant adverse environmental impact.

I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT.

Executed on October 25, 2025.

Marcelo Ariola
Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 11 of 161

ATTACHMENT A

ATTACHMENT A
Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 12 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 13 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 14 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 15 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 16 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 17 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 18 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 19 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 20 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 21 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 22 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 23 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 24 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 25 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 26 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 27 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 28 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 29 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 30 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 31 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 32 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 33 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 34 of 161 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 35 of 161

ATTACHMENT B

ATTACHMENT B
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ATTACHMENT C

ATTACHMENT C
Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 40 of 161 I -
Recording Requested by:
~ommonbealth~~and Title Company
WHEN RECORDED MAIL TO:

Corrections Corporation of America
Attn: Ken Avant
102 Woodmont
Nashville. TN 37205
I THIS SPACE FOR RECORDER'S IIS\;
GRANT DEED The undersi ed Grantor s) declaree) that the w~~I~~TARY TRANSFER TAX Is: $ *N co111tt~ $ city
Computed on the consideration or \ahre of property conveyed; OR APN: 350-031-02 - Computed on the consideration or vube or encumbrances ESCROW NO: 48665156 remaining at time of sale.

FOR A VALUABLE CONSIDERATION, receipt of which is hereby acknowledged, Moohay A. k, a married woman as to an undivided 113 interest, @ ela H. Ahn Mouradian, a married woman, who acquired titl~ as =\wela H. Ahn, a single woman as to an undivfded 1/3 interest and Channing C. Ahn, a slngla mah, as ea an undivided 1/3 interest
hereby GRANT(S) to CORRECTIONS CORPORATION OF AMERICA, A TENNESSEE CORPORATION all the real property situated in the City of California City, County of Kern, State of California. as:

The North 112 of Section 13, Township 32 South, Range 38 East, Mount Diablo Meridian.

EXCEPT 112 of all oil, gas and other minerals contained within the property above described, whether now known to exist or hereafter discovered and together with the right to produce, mine, extract and remove oil, gas, and other minerals upon, from and through said property but unless grantee, its successors or assigns shall give written consem to the drilling of wells upon the surface of said land, all of the foregoing rights shall be exercised only by the drilling of wells or conducting operations into and through said property at depths below 100 feet from locations on adjacent or neighboring lands in Such manner as not to disturb the surface (or the first 100 feet of the subsurface) of said property or any improvements located upon the surface thereof as reserved in deed recorded April 25, 1960 in Book 325 1, Page 639 of records of said County.

THIS DEED IS BEING SIGNED IN COUNTERPART.

Dated: June 5, 1998
Moohay A. Choe

COUNTY OF
personally known to me or proved to me on this basis of satisfactory evidence to be the person@ whose name(+ Channing is1a.w subscribed to the within instrument and acknowledged to me that hels4wAhey executed the same in hislheFkkeir authorized capacity(ias), and that by hislheFkkerr
signature@) on the instrument the personh), or the entity upon behalf of which the person@) acted, executed the
instrument.

MAIL TAX STATEMENTS TO ADDRESS ABOVE (This area for official notarial seal) Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 41 of 161 Reccrding Requested by:

Cornrnon&ealth Land Title Company
WHEN RECORDED MAIL TO:

Corrections Corporation of America
Attn: Ken Avant
102 Woodmont
Nashville, TN 37205
THIS SPACE FOR RECORDER'S USE ONLY:

GRANT DEED
APN: 350-031-02
ESCROW NO: 486651JG
The undersimed Grantore) declare(s) that the DOCUMENTARY TRANSFER . . . ~ TAXIS:$ i,812.80 County $ City
- Computed on the consideration or value of property conveyed; OR - Computed on the consideration or value less or encumbrances remaining at time of sale.

FOR A VALUABLE CONSIDERATION, receipt of which is hereby acknowledged, Moohay A. Choe, a married woman as to an undivided 113 interest, Angela H. Ahn Mouradian, a married woman, who acquired title as Angela H. Ahn, a single woman as to an undivided 113 interest and Channing C. Ahn, a single man, as to an undivided 3 intere
hereby GRANT& to CORR~~TIONS C.ORPORATION OF AMERICA, A TENNESSEE CORPORATION all the real property situated in the City of California City, County of Kern, State of California, described as:

The North 112 of Section 13, Township 32 South, Range 38 East, Mount Diablo Meridian.

EXCEPT 112 of all oil, gas and other minerals contained within the property above described, whether now known to exist or hereafter discovered and together with the right to produce, mine, extract and remove oil, gas, and other minerals upon, from and through said property but unless grantee, its successors or assigns shall give written consent to the drilling of wells upon the surface of said land, all of the foregoing rights shall be exercised only by the drilling of wells or conducting operations into and through said property at depths below 100 feet from locations on adjacent or neighboring lands in such manner as not to disturb the surface (or the first 100 feet of the subsurface) of said property or any improvements located upon the surface thereof as reserved in deed recorded April 25, 1960 in Book 3251, Page 639 of records of said County.

THIS DEED IS BEING SIGNED IN COUNTERPART.

I
Dated: luneg 1998
M A SG ~chu54te.~ ss 1 Moohay A. Choe
STATE OF 1
COUNTY OF =TE!klk
before m-fl LV finme
/ hgela H. Ahn Mouradian
Ahn hl\bd&tdi
or proved to me on this basis of
satisfactory evidence to be the person(s) whose name(s) Channing C. Ahn isle~esubscribed to the within instrument and acknowledged to me that k4lshe/hy executed the same in kie/her/tbk
authorized capacity(ies), and that by ~Iherl~
signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the
instrument.

WITNESS my hand and official seal.
(This area for official notarial seal)
Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 42 of 161 - 2
"ecwding Reqyted by:
~omrnonbedth Land Title Company
WHEN RECORDED MAIL TO:

Corrections Corporation of America
Attn: Ken Avant
102 Woodmont
Nashville, TN 37205
1 I James lap I es . nsscssu, .\--- --
I Kern County C 'cial Records Pages : 3 . --
DOCUMENT #:0198081113
Fees. . . . 13.00
Taxes ... 1812.80
a8198881113a Other. . . TOTAL
PAID.. 1825.80
/ THIS SPACE FOR RECORDER'S USE ONLY: Stat. Types: 1
GRANT DEED The undersigned Grantor(s) declare(s) that the DOCUMENTARY TRANSFER City
e of property conveyed; OR
APN: 350-031-02 Computed on the consideration or value less or encumbrances ESCROW NO: 486651JG -
remaining at time of sale.

FOR A VALUABLE CONSIDERATION, receipt of which is hereby acknowledged, Moohay A. Choe, a married woman as to an undivided 113 interest, Angela H. Ahn Mouradian, a married woman, who acquired title as Angela H.; Ahn, a single woman as to an undivided 113 interest and Channing C. Ahn, a single man, as to an undivided 113 interest
hereby GRANT(S) to CORRECTIONS CORPORATION OF AMERICA, A TENNESSEE CORPORATION all the real property situated in the City of California City, County of Kern, State of California, described as:

The North 112 of Section 13, Township 32 South, Range 38 East, Mount Diablo Meridian.

EXCEPT 112 of all oil, gas and other minerals contained within the property above described, whether now known to exist or hereafter discovered and together with the right to produce, mine, extract and remove oil, gas, and other minerals upon, from and through said property but unless grantee, its successors or assigns shall give written consent to the drilling of wells upon the surface of said land, all of the foregoing rights shall be exercised only by the drilling of wells or conducting operations into and through said property at depths below 100 feet from locations on adjacent or neighboring lands in such manner as not to disturb the surface (or the first 100 feet of the subsurface) of said property or any improvements located upon the surface thereof as reserved in deed recorded April 25, 1960 in Book 325 1, Page 639 of records of said County.

THIS DEED IS BEING SIGNED IN COUNTERPART.

Dated: June 5, 1998
Moohay A. Choe 2
personally appeared HAY A C lr u e Ipersonally known to me or satisfactory evidence to be Channing C. Ahn
within instrument and acknowledged
to e that &5/she/t'hp executed the same in l&/her/t!)&r authorized capacitym, and that by fi@lher/t!~f&T
on the instrument the person- or the entity
of which the person(wcted, executed the
instrument.
.. .
..

MAIL TAX STATEMENTS 'P6 AIlDRESS ABOVE (This area for official notarial seal) Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 43 of 161

ATTACHMENT D

ATTACHMENT D
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ATTACHMENT E

ATTACHMENT E
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ATTACHMENT F

ATTACHMENT F
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ATTACHMENT G

ATTACHMENT G
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ATTACHMENT H

ATTACHMENT H
Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 98 of 161

DEPARTMENT OF FORESTRY AND FIRE PROTECTION
Office of the State Fire Marshal
Fire & Life Safety Division

CERTIFICATE OF OCCUPANCY
This Certificate of Occupancy is issued pursuant to the requirements of the California Building Code Section 111 Inspections required by the California Building Code have been completed and it has been determined that the below referenced facility conforms to the Codes and Standards adopted by the State Fire Marshal. Final approval is hereby granted and the facility may be occupied for the intended use as stated herein.

Facility: CCA- California City Correctional Facility
Address: 22844 Virginia Blvd. California City, Ca.

CA State Fire Marshal File #: 02-15-44-0020
Occupancy Classification: I-3 (Under CCR Title 24 2013 Edition) Project No. or Name: ADA Phase 1 Upgrades (S.S., Dayrooms & Cells) Name and Title of Approving Official: George D. Mavrikis, Deputy State Fire Marshal

Signature: Date: May 29, 2014
This certificate is valid until one of the following conditions occur: 1) change in the use of the building which would place it in a different occupancy classification, 2) the building becomes vacant for a period in excess of 180 days, or 3) this certificate is otherwise revoked under provisions of the Code.

This Certificate Shall Be Filed on Location
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ATTACHMENT I

ATTACHMENT I
Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 100 of 161

DEPARTMENT OF FORESTRY AND FIRE PROTECTION
Office of the State Fire Marshal
Fire & Life Safety Division

Facility: CCA- California City Correctional Facility
Address: 22844 Virginia Blvd. California City, Ca.

CA State Fire Marshal File #: 02-15-44-0020
Occupancy Classification: I-3 (Under CCR Title 24 2013 Edition) Project No. or Name: ADA Phase 2 Upgrades (Entire Facility) Name and Title of Approving Official: George D. Mavrikis, Deputy State Fire Marshal III Specialist

Signature: Date: December 11, 2014
This certificate is valid until one of the following conditions occur: 1) change in the use of the building which would place it in a different occupancy classification, 2) the building becomes vacant for a period in excess of 180 days, or 3) this certificate is otherwise revoked under provisions of the Code.

This Certificate Shall Be Filed on Location
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ATTACHMENT J

ATTACHMENT J
Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 102 of 161 2022 California Building Code, Title 24, Part 2 (Volumes 1 & 2) with July 2024 Supple
CHAPTER 3 OCCUPANCY CLASSIFICATION AND USE
308.4 Institutional Group I-3.

Institutional Group I-3 occupancy shall include buildings or portions of buildings and structures that are inhabited by one or more persons who are under restraint or security. A Group I-3 facility is occupied by persons who are generally incapable of self-preservation due to security measures not under the occupants’ control which includes persons restrained. This group shall include, but not be limited to, the following:

Correctional centers
Correctional hospitals
Correctional nursing facilities
Correctional mental health facilities
Correctional treatment centers
Courthouse holding facility
Detention centers
Detention treatment room
Jails
Juvenile halls
Prerelease centers
Prisons
Reformatories
Secure interview rooms
Temporary holding facility
Buildings of Group I-3 shall be classified as one of the occupancy conditions specified in Sections 308.4.1 through 308.5.8 and shall comply with Section 408.
308.4.1 Condition 1.

This occupancy condition shall include buildings in which free movement is allowed from sleeping areas, and other spaces where access or occupancy is permitted, to the exterior via means of egress without restraint. A Condition 1 facility is permitted to be constructed as Group R.
308.4.2 Condition 2.

This occupancy condition shall include buildings in which free movement is allowed from sleeping areas and any other occupied smoke compartment to one or more other smoke compartments. Egress to the exterior is impeded by locked exits.
308.4.3 Condition 3.

This occupancy condition shall include buildings in which free movement is allowed within individual smoke compartments, such as within a residential unit composed of individual sleeping units and group activity spaces, where egress is impeded by remote-controlled release of means of egress from such a smoke compartment to another smoke compartment.
308.4.4 Condition 4.

This occupancy condition shall include buildings in which free movement is restricted from an occupied space. Remotecontrolled release is provided to permit movement from sleeping units, activity spaces and other occupied areas within the smoke compartment to other smoke compartments.
308.4.5 Condition 5.

This occupancy condition shall include buildings in which free movement is restricted from an occupied space. Staffcontrolled manual release is provided to permit movement from sleeping units, activity spaces and other occupied areas within the smoke compartment to other smoke compartments. 308.4.6 Condition 6.

This occupancy condition shall include buildings containing only one temporary holding facility with six or fewer persons Copyright © 2025 International Code Council, Inc., or its licensors (ALL RIGHTS RESERVED).

Accessed by Michael Giardina on 10/17/2025 pursuant to License Agreement with ICC. No further reproduction or distribution authorized. Any Unauthorized reproduction or distribution is a violation of the federal copyright, and subject to civil and criminal penalties thereunder.

PDF from: http://codes.iccsafe.org/content/CABC2022P4/chapter-3-occupancy-classification-anduse#CABC2022P4_Ch03_Sec308.4 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 103 of 161 under restraint or security where the building is protected throughout with a monitored automatic sprinkler system installed in accordance with Section 903.3.1.1 and where the temporary holding facility is protected throughout with an automatic fire alarm system with notification appliances. A Condition 6 building shall be permitted to be classified as a Group B occupancy.
308.4.7 Condition 7.

This occupancy condition shall include buildings containing only one temporary holding facility with nine or less persons under restraint or security where limited to the first or second story, provided the building complies with Section 408.1.2.6. A Condition 7 building shall be permitted to be classified as a Group B occupancy. 308.4.8 Condition 8.

This occupancy condition shall include buildings containing not more than four secure interview rooms located within the same fire area where not more than six occupants under restraint are located in the same fire area. A Condition 8 building shall be is permitted to be classified as a Group B occupancy, provided the requirements in Section 408.1.2.7 are met.
308.4.9 Condition 9.

This occupancy condition shall include buildings where the use of the building is for correctional medical care or correctional mental health care.

PDF from: http://codes.iccsafe.org/content/CABC2022P4/chapter-3-occupancy-classification-anduse#CABC2022P4_Ch03_Sec308.4 Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 104 of 161

ATTACHMENT K

ATTACHMENT K
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ATTACHMENT L

ATTACHMENT L
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ATTACHMENT M

ATTACHMENT M
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ATTACHMENT N

ATTACHMENT N
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ATTACHMENT O

ATTACHMENT O
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ARTICLES OF AMENDMENT
OF

CORRECTIONS CORPORATION OF AMERICA
The undersigned, being duly authorized to execute and file these Articles of Amendment of Corrections Corporation of America, a Maryland corporation (the "Corporation"), hereby certifies to the State Department of Assessments and Taxation of the State of Maryland that:

FIRST: The Corporation desires to amend its charter as currently in effect.

SECOND: The charter is hereby amended by deleting Article FIRST in its entirety and inserting the following in place thereof:

FIRST: The name of the corporation (which is hereinafter called the "Corporation") is:

CoreCivic, Inc.

THIRD: The foregoing amendment was unanimously approved by the entire board of directors and the amendment is limited to a change expressly authorized by § 2-605 of the Maryland General Corporation Law to be made without action by the stockholders.

FOURTH: The undersigned President acknowledges these Articles of Amendment to be the corporate act of the Corporation and, as to all matters or facts required to be verified under oath, the undersigned President acknowledges that, to the best of his knowledge, information and belief, those matters and facts are true in all material respects and that this statement is made under the penalties for peijury.

IN WITNESS WHEREOF, the Corporation has caused these Articles of Amendment to be signed in its name and on its behalf by its President on this 9th day of November 2016.

KITEST:

Secretary

CORRECTIONS CORPORATION OF

AMERICA
LT
Damon T. Hininger
President and Chief Executive Officer
CUST ID:0003482065 STATE OF MARYLAND
WORK ORDER:0004698642 -
DqTE: 11-09-2016 1047 cui ,'ttfvthat thisisatrueandcompletecopy4fth P!1T. PPID:$1,172.00 oniikinthisjb. DATED:_ (i !6
t1)hI'AkTMENT O ASESMENTS AN1 TA(ATlON:
, Custodian
aiiip replaces our previo ceruticanon system. Effective: 6I9 /
Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 125 of 161

CORPORATE CHARTER APPROVAL SHEET
** EXPEDITED SERVICE ** ** KEEP WITH DOCUMENT **
DOCUMENT CODE Oj 4 BUSINESS CODE
III UIU II IIU IIII IllI VJ IIH III IIJ III ffl JI1 Jill! llJ III 1000362009853062 Close Stock Nonstock
PA. Religious
Merging (Transferor)
Surviving (Transferee)

FEES REMITTED
Base Fee: / iO
Org. & Cap. Fee:

Expedite Fee:

Penalty:

State Recordation Tax:

State Transfer Tax:

I Certified Copies
CopyFee:

Certificates
Certificate of Status Fee: 0
Personal Property Filings:

Mail Processing Fee:

Other:
, () (_
Credit Card Cheák . Cash
Documents on Checks
Approved By: / L
Keyed By:

COMMENT(S): -1_a d'o )W d,t4j4 iQ I4- ce
ID D05095757 ACK 1000362009853062
PAGES: 0002
CORECIVIC, INC.
11/09/2016 AT 10:05 A WO 0004698642
New Name -'ta."tc 2.7LC_
ÜJ
hange of Name MADE
Change of Principal Office
Change of Resident Agent
Change of Resident Agent Address
Resignation of Resident Agent
Designation of Reident Agent
and Resident Agent's Address
Change of Business Code
Adoption of Assumed Name
Other Change(s)
Code D T7
Attention:
- ______-

THE CORPORATION TRUST INCORPORATED
351 U CAMDEN ST
BALTIMORE MD 21201-7912
CUST ID: 0003482065
WORK ORDER: 0004698642
DATE:11-09-2016 10:47 PM
ANT. PAID:$1,172.00
Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 126 of 161 Business License Application
City of California City
21000 Hacienda Blvd
California City, CA 93505
[email protected]
License # ____________________
ƉƉƌoǀeĚ ďǇ __________________
WƌoĐesseĚ ďǇ__________________
Processed On _________________
760-373-7140
Name of Business
Business Address
Business Phone #
Nature of Business
Business
Owner(s) NĂŵe
Mailing
Address
Email
Address
Have you had a license for this business in the past?
Do you own or rent the spaĐe KǁŶ ZeŶƚ ;If rent, building owner/landlord Yes No
WŚoŶe NƵŵďeƌ
tŝůů ƚŚe ďƵsŝŶess ŚĂǀe ŶŶƵĂů 'ƌoss /ŶĐoŵe oĨ ΨϭϬ͘ϬϬϬ oƌ ŵoƌe͍ Business Emergency Contact͗ Name
C License #
(Required for Alcohol & Liquor Sales)
Expiration Date
State/County Licensing Information:
^eůůeƌΖs Weƌŵŝƚ #
Health Certificate #
(Required for Food Services – attach copy)
ŽŶƚƌĂĐƚŽƌƐ:

State License #
State License Type
(Required for ContractorsͿ
ŽŵŵĞƌĐŝĂůƵƐŝŶĞƐƐΘ&ŝƌĞ>ŝĨĞ^ĂĨĞƚǇ/ŶƐƉĞĐƚŝŽŶĨŽƌ>ŽĐĂůƵƐŝŶĞƐƐĞƐ:
/ŶsƉeĐƚŝoŶ ZeƋƵŝƌeĚ ŶŶƵĂůůǇ
Yes No
WůĂŶŶeĚ ƵsŝŶess
eŐŝŶ Ăƚe
Date
See the California City Master Fee Schedule on our website. Click here for cost of fees.

By signing below, I certify under penalty of perjury that the foregoing information is true and correct. I agree to all of the terms of the City of California City business license requirements. I comply with the relevant state and county license requirements for my business and am aware that the City of California City business license does not cover state and county license requirements for my business.

Signature Ăƚe
WƌŝŶƚeĚ NĂŵe
Case 1:25-cv-01292-KES-CDB Document 18-1 Filed 10/27/25 Page 127 of 161 CoreCivic, Inc. California City Immigration
Processing Center
CoreCivic Inc.
22844 Virginia Blvd
California City, CA 93504-0590
PO Box 2511
California City, CA 93504
760-338-6670 [email protected]
Detention Center
Christopher Chestnut 229-315-7861
212481920-00005
93505/RE11/EH-FDA-2
07/21/2025
07/22/2025
Christopher Chestnut

Page 1 of 4 ends

California City City CouncilAugust 25, 2026

California City City Council
August 25, 2026