1 From: Arthur Hodge <[email protected]>
Sent: Monday, September 7, 2026 1:13 PM
To: Patrick Martinez <[email protected]>; Bernie Hatz <[email protected]>; Lena D.
Wade <[email protected]>
Cc: Mercy Hand <[email protected]>; John Schneider <[email protected]>; Claudio Hand <[email protected]>; Marianne Man J. D. LL. M. in Tax <[email protected]> Subject: Purest USA LLC
Please be advised that my representation of Purest USA, LLC has terminated and Purest is presently in the process of transitioning to new regulatory counsel.
In light of that transition, Purest respectfully requests that the City postpone or continue the September 8, 2026 determination so that incoming counsel has a reasonable opportunity to obtain and review the file, administrative record, prior proceedings, and other relevant materials before the City takes final action.
Purest also requests a rehearing of the July 22, 2026 matter. The client did not understand until after the July 22 proceeding that it would be a mini-trial at which the merits would effectively be determined. As a result, the client was unprepared and did not understand that it could present witnesses, cross-examine witnesses, and otherwise fully present its case in such manner.
Consequently, material evidence and issues relevant to Purest’s position were not presented or adequately addressed at the hearing.
Purest therefore respectfully requests a rehearing so that incoming counsel has a reasonable opportunity to review the administrative record, prepare the matter, and ensure that Purest has a meaningful opportunity to present its position before a final determination is made.
Purest expressly does not waive or abandon any rights, claims, defenses, objections, arguments, administrative remedies, rehearing or reconsideration rights, appeal rights, rights to judicial review, or any other procedural or substantive rights or remedies arising from the July 22 proceeding, the proposed September 8 determination, or the underlying regulatory matter. Purest expressly reserves all such rights and remedies, including all rights concerning the administrative record and all applicable deadlines or limitations periods.
Given the transition of counsel and the imminent September 8 date, Purest respectfully requests that no final determination be issued until incoming counsel has had a reasonable opportunity to review the matter and address the City.
Please confirm receipt of this request by "reply all" and please take notice that I will not be responding to any further communications concerning this matter.
Thank you,
Arthur D. Hodge
Former Regulatory Counsel for Purest USA, LLC
Arthur D. Hodge, Esq.
ARTHUR D. HODGE, A Professional Law Corporation
701 Palomar Airport Road, Suite 300
Carlsbad, CA 92011
Tel.: (760) 814-7398 Fax: (877) 847-3690
Email: [email protected]
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