December 21, 2023
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Mr. Rudy Monroy
City of Downey - Code Enforcement Division
lst Floor Downey City Hal
11111 Brookshire Avenue
Downey, CA 90241
RE:Administrative Citations #CE11759 and #CE1160 – Ojos Locos Sports Cantina Dear Mr. Monroy:
Pursuant to our conversation on December 14th, I am General Counsel for Ojos Locos Sports Cantina. Going forward, please direct any and all future correspondence concerning our establishment to my attention at the address listed below. Refrain from contacting any of our local staff, management, or business owners.
Our office is in receipt of the two recent administrative citations issued to the Ojos Locos located at 8350 Firestone Blvd, Downey, CA 90241. It should be noted that these citations are for the same violation but resulted in double billing because there are two company officers. We request that going forward any violation only be sent to one officer, Michael Morales. This double billing resulted in FOUR THOUSAND DOLLARS being paid to the City through the required appeal process.
If you are not already aware, the City of Downey’s Municipal Code D.M.C. 4996(a)(1) is both unenforceable and unlawful. The legal precedent (“ Edge v. City of Everetf' \ relied upon when D.M.C.4996(a)(1) was implemented has since been declared unconstitutional. The United States District Court Western District of Washington at Seattle held that the Dress Code Ordinance violates the Equal Protection Clause of the U.S. Constitution. The City of Everett later paid $500,000 to settle this claim. We are requesting that the city not target and discriminate against the female gender that we hire as Chicas, immediately refund all fees paid, and revoke said ordinance.
A copy of the Court of Appeals Opinion is attached for convenient reference. Hopefully your office is able to reasonably address the irrational and unlawful actions taken by Code Enforcement.
Thank you,
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Dawn Diaz
General Counsel
Ojos Locos Sports Cantina
6010 W. SPRING CREEK PARKWAY, SUITE 321, PLANO, TEXAS 75024 1 504-577-9764 1 [email protected]
CC:Roger Bradley,
Downey City Manager
John Funk,
City Attorney
Lisa Kolieb
Akerman LLP
Rich Hicks
Michael Morales
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