PATTERSON & O’NEILL, PC
235 Montgomery Street, Suite 950
San Francisco, CA 94104
Telephone: (415) 907-9110
Facsimile: (415) 907-7704
www.pattersononeill.com
VIA EMAIL AND U.S. MAIL
Before the city council of the city of Palo Alto
Mahealani Ah Yun, City Clerk
Office of the City Clerk: City Hall, 7th Floor
250 Hamilton Avenue
Palo Alto, CA 94301
Re: Appeal of Notice and Order to Demolish/Deconstruct and Remove Buildings Buildings Located at 531 Stanford Avenue
Dear Ms. Ah Yun:
This appeal is submitted pursuant to PAMC § 16.40.080 on behalf of Stanford Orion, the property manager and owner’s representative, that is subject to the attached Notice and Order.
This appeal protests the following specific orders and actions, for the following reasons:
1) The Notice and Order was not properly served. The City mailed the Notice and Order to the building at 531 Stanford Avenue, which the City knows is vacant, fenced, and inaccessible building. The City did not properly serve the Notice and Order to the building owners, or their known representatives, as required by PAMC § 16.40.060.
2) The buildings at 531 Stanford do not meet the requirements for the City to order demolition. The building has already been vacated. Building can only be ordered demolished if the building is fifty percent damaged, decayed or deteriorated from its replacement value. The Notice and Order cites a number of “violations” that are inaccurate, immaterial, grossly overstated, or which have already been addressed.
Further, these violations are only relevant to issues of habitability and do not establish that the building has been fifty percent damaged, decayed or deteriorated from its replacement value.
3) The Notice and Order requires the submittal of a deconstruction permit and prohibits demolition of the building. The City Code on deconstruction, PAMC § 5.24.080 clearly exempts any building that has been determined to be dangerous, structurally unsafe or otherwise hazardous to human life that is required to be abated by demolition from all Docusign Envelope ID: 4D932618-C4F7-492A-BE9F-3666ECB0E493 deconstruction requirements. Thus, the City’s demand for deconstruction is unlawful, unauthorized, and must be set aside.
4) The Notice and Order requires complete removal by May 18, 2026. This timeframe is unreasonable, including because 1) this requires removal during the wet season, which can cause delays, increases costs, and can create dangerous condition; 2) essential public health and safety equipment is located on the building and there is currently no plan in place to address this equipment; and 3) the City has delayed approval of a post-approval plan and a vacant property with no active use will continue to be a magnet for nuisance activities.
The reasons for this appeal are further elaborated in the attached response to the Notice and Order.
Very truly yours,
PATTERSON & O’NEILL, PC
_______________________________
Brian O’Neill
STANFORD ORION
_______________________________
Sophia Huang
531 Stanford Avenue
Palo Alto, CA 94306
Docusign Envelope ID: 4D932618-C4F7-492A-BE9F-3666ECB0E493
VERIFICATION
I, Sophia Huang, declare as follows:
I am the appellant in this matter and am authorized to verify as to the truth of the matters stated in the appeal. I have read the foregoing appeal and know its contents. The matters stated in the appeal are true of my own knowledge from having been a representative of the owner’s of 531 Stanford for many years. I declare the foregoing matters are true and correct.
Executed on November 13, 2025 ________________________ Sophia Huang
Docusign Envelope ID: 4D932618-C4F7-492A-BE9F-3666ECB0E493