110 E. Main Street Los Gatos, CA 95030 ● (408) 354-6832 www.losgatosca.gov
TOWN OF LOS GATOS
COUNCIL AGENDA REPORT
MEETING DATE: 01/21/2025
ITEM NO: 13
ADDENDUM
DATE: January 17, 2025
TO: Mayor and Town Council
FROM: Gabrielle Whelan, Town Attorney
SUBJECT: Conduct a Public Hearing for Appeal of Administrative Citation VL-19-362 (16660 Cypress Way) for Violations of the Los Gatos Town Code Related to Grading and Building and Adopt a Resolution Upholding the Administrative Citation and Imposing Costs According to Proof
REMARKS:
Attachment 25 contains correspondence submitted by appellant, attachment 26 contains public comment, and attachment 27 contains the PowerPoint presentation.
Attachments received with the Staff Report:
1. Aerial View of Subject Property 9/2017
2. Aerial View of Subject Property 5/2018 Showing Grading in Progress
3. Aerial View of Subject Property 8/2018 Showing Completed Paving
4. Aerial View of Subject Property Showing Locations of Structures in Violation
5. Hotpads Internet Posting, Showing Violations
6. Trulia Internet Posting, Showing Violations
7. Realtor.com Internet Posting, Showing Violations
8. Administrative Warning Dated 7/17/2019
9. Administrative Warning (2nd notice) Dated 8/22/2019
10. Application for Grading Permit and Architecture and Site Approval dated 7/9/2021 and Letter of Justification and Project Description Dated 7/8/2021
11. Photos of Town Inspection on 8/24/2021
12. Staff Technical Review Dated 8/24/2021 and 8/25/2021
13. Email from Town Attorney Dated 10/30/2023
14. Updated Letter of Justification Regarding Application Dated 12/13/2023
15. Staff Technical Review Dated 1/31/2024
16. Letter dated 5/22/2024 and Inspection Warrant Dated 5/20/2024
17. Description and Photos of Site Inspection of Subject Property on May 30, 2024 PAGE 2 OF 2
SUBJECT: Public Hearing for Appeal of Administrative Citation VL-19-362 (16660 Cypress Way) for Violations of the Los Gatos Town Code Related to Grading and Building DATE: January 15, 2025
18. Administrative Warning Dated 7/8/2024
19. Administrative Citation Dated 9/16/2024
20. Property Detail Report
21. Administrative Citation Hearing Request Dated 10/14/2024
22. Letter to Town Community Development Department from Attorney Rogers Joseph Dated 10/14/2024
23. Notice of Appeal Hearing
24. Proposed Resolution
Attachment Received with this Addendum:
25. Correspondence Submitted by Appellant
26. Public Comment
27. PowerPoint Presentation
From: Sharon C. Ingram
To: Wendy Wood
Cc: Gabrielle Whelan; Richard M. Harris
Subject: Supplemental Administrative Appeal Statement of Theodore and Lauri Date: Thursday, January 16, 2025 11:16:28 AM
Attachments: 2025-01-16; Ltr Town Council.pdf
[EXTERNAL SENDER]
Dear Town Clerk,
Please find the attached correspondence sent on behalf of Mr. Harris.
Thank you,
Sharon
Sharon C. Ingram
Assistant
Aaron P. Silberman | Dennis C. Callahan | Dean D. Paik | Aaron M. Scolari | Richard M. Harris ROGERS JOSEPH O'DONNELL | a Professional Law Corporation 311 California Street, 10th fl | San Francisco, CA 94104 415.956.2828 main | 415.365.5327 direct | 415.956.6457 fax [email protected] |www.rjo.com
Notice to recipient: This email is meant for only the intended recipient(s) of the transmission and may be privileged by law. If you receive this email in error, please notify us immediately. Do not print, copy, or disseminate it. Please delete the email from your system. Thank you.
ATTACHMENT 25
580954.1
415.956.2828 (t) Robert Dollar Building
415.956.6457 (f) 311 California Street, 10th Flr.
San Francisco CA 94104
202.777.8950 (t) 1500 K Street, NW, Suite 800
202.347.8429 (f) Washington DC 20005
ROGERS JOSEPH O'DONNELL www.rjo.com
January 16, 2025
VIA EMAIL
[email protected]
Town Council
Town of Los Gatos
Town Attorney’s Office
110 E Main Street
Los Gatos, CA 95030
Re: Supplemental Administrative Appeal Statement of Theodore and Lauri Deffenbaugh
Dear Town Clerk:
This supplemental statement is provided in response to the Town’s agenda item provided to the Deffenbaughs on December 13, 2024. It incorporates all of the objections and evidence presented in the Deffenbaughs’ previous statement.
Mr. Deffenbaugh first requests a continuance of 180 days to work to resolve outstanding permitting issues. As I wrote to the Town’s attorney, the engineer required for additional submittals is now re-involved in the project. Exhibit A. Mr. Deffenbaugh’s father-in-law was on hospice during the Summer and the Deffenbaughs were the primary care providers. At the same time, Mr. Deffenbaugh was actively involved in planning his daughter’s wedding which occurred in September 2024. With a sufficient continuance, the Deffenbaughs can resubmit to show how all structures can be permitted without requiring demolition.
Should the Town refuse to continue the hearing, then the Deffenbaughs object to this hearing, which is violating Town ordinances and state law. Not only is the Town estopped from litigating this permit issue (as described in our previous statement) and has failed to establish a procedure as required under the building code, but this hearing violates the Deffenbaugh’s substantive and procedural due process rights. The Deffenbaughs has not been granted the right to subpoena witnesses (such as their neighbor); cross examine and directly confront those who will bring evidence on behalf of the Town; or have adverse witnesses placed under oath. Further, the code under which the Town is proceeding (1.30.040) does not even state the burden of proof the Town will be applying. This is the A Professional Law Corporation
Richard M. Harris
415.365.5306 (d)
[email protected]
ROGERS JOSEPH O'DONNELL www.rjo.com
Town Council
January 16, 2025
580954.1
A Professional Law Corporation
consequence when the Town fails to institute a procedure for a hearing as required by the building code.
Even considering the Town’s evidence, it has not shown that the Deffenbaughs have violated the town codes listed in the citation. The Deffenbaughs have received a violation for of 6.150.010 (R105.1) and a violation of 12.20.010. Even if the Deffenbaughs were found liable, the maximum fine would be $600. This prosecution does not stand up to scrutiny. This citation should be dismissed.
A. The Deffenbaughs Are Not Intending to Complete Unpermitted Work, and Therefore Cannot Be Liable Under the Citation.
The Town claims that the Deffenbaughs are violating R105.1 and 12.20.010 because they have not yet secured permits for 5 structures and for some grading done on the property. But these ordinances prohibit constructing without a permit; they do not require securing permits for previously unpermitted work. On this basis alone the citation should be dismissed.
Under R105.1, a property owner violates the statute if they intend to construct on their property and fail to secure a permit. (“Any owner or owner’s authorized agent who intends to construct, enlarge, alter, repair, move, demolish, or change the occupancy of a building or structure, or to erect, install, enlarge, alter, repair, remove, convert, or replace any electrical, gas, mechanical or plumbing system, the installation of which is regulated by the this code, or to cause any such work to be performed, shall first make application of the building official and obtain the required permit.")(emphasis added). But at best, the Town has shown that there are allegedly unpermitted structures on the Deffenbaugh’s property. It is not a violation of R105 to have unpermitted structures on your property, only to construct without a permit.
12.20.010 is similar. That ordinance proscribes some grading without first obtaining a permit. But the Deffenbaughs are not intending on completing any grading work, and the Town does not claim otherwise; instead, the Town’s evidence is simply that grading work occurred. There is no evidence that the Deffenbaughs are liable under this code section.
B. The Town’s Evidence Does Not Show Violations That Cannot Be Resolved With Permitting After the Lawsuit Is Complete.
Not only are the Deffenbaughs not liable under the listed ordinances, but they are actively involved in getting all of the structures permitted. Contrary to the Town’s position, the buildings do not need to be demolished.
ROGERS JOSEPH O'DONNELL www.rjo.com
Town Council
January 16, 2025
580954.1
A Professional Law Corporation
As discussed below, Mr. Deffenbaugh should be allowed to get each building permitted under the code. For each building, there is no basis for this citation.
1. ADU remodel
The Town claims that this ADU was permitted on 1981, but there are “unpermitted interior improvements.” But the citation is for failing to secure a permit for construction that the owner intends to complete. R105 does not require that a party secure a permit for work already complete.
The Town also claims that “The sleeping room lacked sufficient emergency egress and the bathroom window was not tempered as required in a wet hazard area. The front entrance deck, stairs, and railings were unstable and appeared unsafe. The railings were far below minimum requirement and have openings exceeding a 4” diameter sphere.” But there is no support for this claim: the Town’s notes from its visit show that none of these issues were actually observed at the time of the inspection (see page 2 of attachment 17).
Without some evidence supporting the Town’s claims, Mr. Deffenbaugh cannot respond except to state that any building code related issues were pre-existing at the time the Deffenbaughs’ purchased the property. As such, they cannot be liable under the Town ordinance for failing to secure a permit.
2. Accessory Structure (“Office” or “Shed”)
The Town claims this structure is an “Office,” but the Deffenbaughs are using it as a storage shed. Sheds need not be permitted if they are at or less than 120 square feet.
The Deffenbaughs were obviously trying to build the shed to this specification, and 4 square feet over is a de minimus error that should not lead to thousands of dollars of fines. Contrary to the Town’s position, the shed has no electricity, and an extension cord is used to light the structure when people enter the structure.
The Town also claims that the Shed does not meet required setbacks because it is too close to the property line. But it also admits that there is a current litigation over the location of those property lines and easements associated with them. Given that the finalize location of the rights to the property line are not yet established, the Town should not attempt to enforce them as the Deffenbaughs’ neighbor understands them.
3. Storage Structure behind ADU
The Town claims that the Storage Structure is wired for “electrical and plumbing.” But there is no plumbing or electrical connected to this structure.
Mr. Deffenbaugh used this building to practice with his children how to install electrical and ROGERS JOSEPH O'DONNELL www.rjo.com
Town Council
January 16, 2025
580954.1
A Professional Law Corporation
plumbing work, but nothing was completed, and nothing is connected. This is neither “plumbing” nor “electrical” as defined by the code.
The Town also claims that the Storage Structure does not have required setbacks. Again, this is dependent on the rights of the Deffenbaughs and their neighbors related to the property, and cannot be determined until that case is complete.
4. Garage Structure
Whether this building can be constructed in its current location is dependent on the determination of the Superior Court in the Lawsuit. Once determined, the Deffenbaughs will be able to get the structure permitted as to the foundation and electrical work. Tearing down the structure is not required, and the Town should give Mr. Deffenbaugh the opportunity to permit the structure as soon as the lawsuit regarding the underlying property rights is complete.
C. Any Penalties For Failing to Secure a Permit Are Limited to $600, and an $11,100 Fine is Excessive Under the Town Code, California Constitution and the Excessive Fines Clause.
Even if these code sections proscribed past work completed without a permit, the penalties would be limited to that violation (failing to secure a permit), which only occurred once for each construction site. If the Town is to be believed, at the time of the citation, Mr. Deffenbaugh had 5 structures constructed without permits and one grading violation without a permit. Since all the violations occurred on the same day (September 16, 2024), the maximum penalty allowed would be $600 (one for each violation). There is no continuing violation, as the Deffenbaughs are not continuing to construct without a permit.
Further, this fine is excessive. It fifty times more than the Town brought previously against the Deffenbaughs for the same alleged violations, and is completely disconnected from any wrongdoing by the Deffenbaughs. The fine is unreasonably high and should be reduced or eliminated.
D. The Town Ignores Similar Issues with the Deffenbaughs’ Neighbor, and Fails to Resolve its Own Obligations to the Deffenbaughs’ Property.
Additionally, fairness concerns require the dismissal of this citation. First, as stated in my previous statement, the Town agreed to wait until the lawsuit was complete.
This makes sense because the lawsuit will define the property rights between the neighbors and therefore define whether or not the structures could be permitted successfully. As the Town agreed to delaying any enforcement, it cannot go back on that agreement.
ROGERS JOSEPH O'DONNELL www.rjo.com
Town Council
January 16, 2025
580954.1
A Professional Law Corporation
Further, the Town does not typically enforce these types of permitting concerns. One needs only to look at the Deffenbaughs’ neighbors’ property, where an accessory building is built right up against the property line. Exhibit B. Attached is an report from a civil engineer discussing how the wall is unsafe and must be replaced with a safe structure. Exhibit C. The Deffenbaughs informed the Town no later than December 2019 about the dangers of their neighbor’s retaining wall. Exhibit D. Exhibit C and D show this wall, which has not substantially changed since 2019. It is clearly unsafe construction and threatens the Deffenbaughs’ property. And yet the Town has refused to enforce these same permitting concerns against that neighbor; the only enforcement is against the Deffenbaughs.
In contrast, the Deffenbaughs have been good neighbors to the Town. For example, the Town is responsible for upkeep of slopes and embankments along Cypress Way. Exhibit E. The Town is also responsible for the upkeep of Cypress Way, which is the only road access to the Deffenbaughs’ property. Exhibit F. But the Town has failed to keep up its responsibilities, and the embankment is overgrown and may fail. In 2022, a tree fell along the Town’s easement, which should have been the Town’s responsibility to clean.
Exhibit G. The Deffenbaughs cleared this tree at their own expense when requested by the Town because that is the neighborly thing to do. As still, the Town has failed to properly upkeep the road access to the Deffenbaugh’s property, creating a safety concern.
The Town should hold its end of the bargain. The Town should treat the Deffenbaughs similar to their neighbors. The Town should give the Deffenbaughs the time their need to get the structures permitted, which can only occur after the lawsuit is complete.
It is the fair thing to do.
II. CONCLUSION
This hearing violates California law as the Deffenbaughs are entitled to an established procedure to hear their appeal, an ad hoc process because the current procedure does not follow state law. This hearing further violates due process, as the Deffenbaughs are not entitled to call and cross examine witnesses, and the Deffenbaughs are being treated differently that similarly situated landowners. Prosecuting this matter is in conflict with the agreement the Town previously made. The citation’s listed ordinances are not at issue here, as the Deffenbaughs are not constructing anything. And finally, there are no violations that cannot be solved with the permitting process as soon as the lawsuit is complete and the property rights are known.
ROGERS JOSEPH O'DONNELL www.rjo.com
Town Council
January 16, 2025
580954.1
A Professional Law Corporation
The Deffenbaughs request a dismissal of the citation, or a continuance until the lawsuit is complete. The penalty of the citation cannot be more than $600.
Very truly yours,
Richard M. Harris
Attorney for Theodore and Lauri Deffenbaugh
RMH:nca
Enclosure
cc: Gabrielle Whelan ([email protected])
EXHIBIT A
January 6, 2025
Job No. 21-213
Los Gatos Town Council
Town Hall
110 E. Main St.
Los Gatos, CA 95030
Subject: 16660 Cypress Way - Grading Violation Abatement Architecture and Site Application S-21-024
Dear Town Council Members:
I am writing to address the delays experienced in the Architecture Package S-21-024 project and explain the circumstances that have led to this situation.
Causes of Delay
The primary reasons for the project delay are as follows:
1. Subcontractor Issues: We encountered unforeseen challenges with the documentation of various subcontractors' retaining wall construction details. This has severely impacted our project timeline.
2. Retirement of Key Personnel: Our geotechnical engineer, who played a critical role in the project, unexpectedly retired. This sudden departure created a significant gap in our team. We need a gravity wall specialist who is both a qualified soil & structural engineer.
3. Competing Business Priorities: Other pressing needs within our business temporarily diverted our attention and resources from this project.
Resolution and Path Forward
I want to assure you that we have taken swift action to address these issues:
1. We have identified and implemented solutions to the subcontractor challenges.
2. A replacement for the retired geotechnical engineer has been found and integrated into our team.
3. We have reallocated our resources to ensure this project receives the necessary focus and attention.
Commitment to Completion
With these measures in place, we can refocus our efforts on Architecture Package S-21-024 and continue progressing as we have done with previous projects for the Town. Despite this temporary setback, our team is committed to delivering the high-quality results you expect from us.
Next Steps
We have revised our project timeline and will provide you with an updated schedule in the coming days. We appreciate your understanding and patience during this period. Town staff has been very supportive in detailing the presentation format required for the Planning Commission review.
If you have any questions or require further information, please don't hesitate to contact me.
TS/CIVIL ENGINEERING, INC.
Terence J. Szewczyk, P.E. C35527
Principal Engineer
EXHIBIT B
EXHIBIT C
Sean O’Neill, Esq.
August 18, 2021
Photo 1 – Over view of retaining wall. Note proximity of roof overhang of residential init.
Photo 2 – Top of wall extended 3 boards (3 feet) to support raised parking pad.
Sean O’Neill, Esq.
August 18, 2021
Photo 3 – Dry rot visible on back of lagging. Amount varies by location.
Photo 4 – Excessive deflection of lagging.
Sean O’Neill, Esq.
August 18, 2021
Photo 5 – 8” space between lagging and displaced column.
Photo 6 – Leaning column where cable holding top of column failed.
Sean O’Neill, Esq.
August 18, 2021
Photo 7 – Rusted end of cable where it failed and pulled out of soil. Inadequate bearing of lagging at steel column repair.
Photo 8 – Photo showing various repairs. Paving at parking now exposed as lagging has slid down.
Sean O’Neill, Esq.
August 18, 2021
Photo 9 – Wall failure from degradation of components at right (East) end of wall.
Photo 10 - Wall failure from degradation of components at right (East) end of wall. Excessive deflection of lagging in upper wall is another potential failure mode.
EXHIBIT D
Retaining Wall Concerns
Neighbor Has Unfenced Area Over Rotting Retaining Wall
Held Together With Cables And Rotting Boards
Details Of Sorid State Of Wall
Dry Rot
Dry Rot
Wall hollowed out by
Squirrels
Old Knob and Tube
Indicating 100 Years Old
Car stop: Unanchored tie
Already Collapsed
Cracked pavement,
drains into wall
EXHIBIT E
EXHIBIT F
EXHIBIT G
This Page Intentionally Left Blank
Dear Town Councils,
This is Ivy Chang and Scott Watson: the neighbors of the Mr. and Ms. Deffenbaugh in this case.
Town staff have provided a comprehensive investigation report, and we respectfully request the Town Council adopt a resolution (Attachment 24) upholding the administrative citation and imposing costs according to proof. In support of this, we want to highlight the following:
1. In a letter addressed to me in 2017 before the subject construction, Mr. Deffenbaugh said:
“I talked to a architect, and for all practical purposes, he said that getting anything built on my property was going to be a massive undertaking. I can fill you in on the details, but Los Gatos has clamped down on allow us to do stuff with our houses in the hills.” See Exhibit A.
2. 532 cubic yard earthwork
According to Town Civil Engineer Mike Wise’s calculation, after his onsite visit in 2021. There are 532 cubic yard earthwork for asphalt parking area. See Exhibit B.
According to a picture of 2016 March, there is no such wall in front of main house, see Exhibit C, which was found in Los Gatos Library given the main house is registered as historical house.
Further, per Town Code, it is clearly defined 4’ cut and 3’ fill in HDS&G. The evidence shows it is 14’ fill. Can Councils direct staff to confirm what is the resubmitting plan Town is expecting? Are you enforcing fully comply the Town Code to enforcing to cut down to 3’ fill from 14’ fill? or are you ok with as it and only need to pay fine and add engineering to the 14’ wall?
3. Page 559 summarizes the timeline well. On July 9, 2021, the Deffenbaughs submitted an Application for Development Permits; this consisted of a property survey and a 2 page justification letter which verbally described a scope of work.
Staff Technical Review of Aug 24-25, 2021 response included 18 pages of additional information that Deffenbaughs needed to submit for the Town and Santa Clara County Fire review. Applicant did nothing for over 2 years, finally submitting only reedited letter of justification on Dec 13, 2023. Staff Technical Review of Jan 31, 2024 reiterated the deficiencies in the application. Please ask Town Staff how they plan to enforce Town codes in a timely manner and not allow the Deffenbaughs to delay remediation indefinitely.
ATTACHMENT 26
4. Page 677, states “Code enforcement to send a compliance order to resubmit required documents within 60 days or impose fines”. Can Councils’ ask staff to detail the fines to be imposed, and ask staff how to enforce the resubmittal of a completed plan, so this process does not incur another 2 years delay?
5. Also, while staff is waiting for the plan resubmittal, will Town Councils red flag the unpermitted parking area? If no, why not?
6. Drainage – Mudslide
I witnessed the mudslide on Cypress Way in 2023 and it worsened in March 2024.
The mudslide location appears to be the water runoff from the un-permitted parking area, which likely to have caused the mudslide onto Cypress Way. See Exhibit D.
Can Councils direct the staff to prioritize the investigation of the drainage issue because of public safety concern?
7. Town’s Cost
On Page 598, it only shows staff hourly rate. Can Councils direct staff to confirm who should be paying the hourly rate for Town Attorney and Outside Special Counsel Lance Bayer? If it’s not violator, will the town be paying that, which means the town residence is paying it. Please clarify.
Your fair review on this matter is highly appreciated.
Sincerely
Ivy Chang and Scott Watson
EXHIBIT A
12/4/2019 Gmail - Let Me Know When You Are Around
https://mail.google.com/mail/u/0?ik=4d1b2a54ec&view=pt&search=all&permmsgid=msg-f%3A1566754611178377151&simpl=msg-f%3A1566754611178377151 1/1 Scott Watson <[email protected]>
Let Me Know When You Are Around
TE Deffenbaugh <[email protected]> Sun, May 7, 2017 at 9:13 AM To: Scott Watson <[email protected]>
Scott,
I am still trying to figure out what to do with the property line. I wanted to jot down some brainstorming notes, then maybe we can talk when you have time.
I talked to a architect, and for all practical purposes, he said that getting anything built on my property was going to be a massive undertaking. I can fill you in on the details, but Los Gatos has clamped down on allow us to do stuff with our houses in the hills.
However, I would like an easement for both the road and the shed that is on your property because I want to open the road to my lower property and rebuild the shed.
Los Gatos just passed a weed abatement ordinance which I was reading about (basically they signed up for Santa Clara county version) start here.
Maybe I could trade the easement for keeping your weeds down in the easement area.
Alternatively, I was looking at my property appraisal, which I can send you, and additional land on a house is valued at $100K per acre, but because we can't build, I don't see the value in it! However, if you would rather do this, I would be open to it at about this rate.
However, the easement is really the only thing I would like to take care of now because I would like to get going on the road and the shed.
Ted
WATSON000003
EXHIBIT B
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EXHIBIT C
EXHIBIT D
16660 Cypress Way
Administrative Appeal of Citation
VL-19-362 issued to Theodore
and Lauri Deffenbaugh
Town Council Meeting
January 21, 2025
#1 ATTACHMENT 27
In October 2016, the Deffenbaughs acquired title to the property #2
September 2017 Google Earth image of the
property
#3
May 2018 Google Earth image of the
property
#4
August 2018 Google Earth image of the
property
#5
Approximate location of unpermitted retaining walls, ADU remodel, and accessory buildings
#6
Unpermitted ADU remodel
(Building # 1)
#7
Unpermitted ADU remodel
(Building # 1)
#8
Unpermitted ADU remodel
(Building # 1)
#9
Chapter Title Date
Unpermitted ADU remodel (Building # 1)
#10
Unpermitted ADU remodel
(Building # 1)
#11
Unpermitted 124 sf office
shed (Building # 2)
#12
Unpermitted 197 sf storage
building (Building # 3)
#13
Unpermitted 197 sf storage
building (Building # 3)
#14
Unpermitted 294 sf garage
(Building # 4)
#15
August 24, 2021 Architectural & Site inspection of unpermitted retaining walls and grading #16
August 24, 2021
A&S inspection of unpermitted retaining walls
#17
August 24, 2021 Architectural & Site inspection of unpermitted retaining walls #18
Chapter Title Date
May 30, 2024
Inspection Warrant inspection
#19
Chapter Title Date
May 30, 2024
Inspection Warrant inspection
#20
Chapter Title Date
May 30, 2024
Inspection Warrant inspection
#21
September 13, 2024
Photos prior to citation (Building #2)
#22
September 13, 2024
Photos prior to citation (Building #3)
#23
September 13, 2024
Photos prior to citation (Building #4)
#24
Town Code Section
6.150.010 (R105.1)
Town Code Section
12.20.010
#25
September 16, 2024
Administrative Citation
#26