Item 3.1 - Reso Confirming and Auth. Recovery of Costs to Abate Public Nuisances; 16943 Valle Verde and 12805 Beeler CreekG`,�.1 OF oWgY
City of Poway
�E �v COUNCIL AGENDA REPORT
C�"IN THE Dov
DATE: January 15, 2019
TO: Honorable Mayor and Members of the City Council
FROM: Alan Fenstermacher, City Attorney
CONTACT: Alan Fenstermacher, City Attorney
afenstermacher@poway.org
APPROVED
■
APPROVED AS AMENDED ❑
(SEE MINUTES)
DENIED
❑
REMOVED
❑
CONTINUED
RESOLUTION NO. 1
11.03
SUBJECT: Resolutions confirming and authorizing recovery of costs incurred to abate
public nuisances at 16943 Valle Verde Road and 12805 Beeler Creek Trail
Summary:
Following extensive efforts to achieve voluntarily compliance, the City Council declared that
conditions at both 16943 Valle Verde Road and 12805 Beeler Creek Trail constituted public
nuisances based on violations of the Poway Municfipal Code ("PMC"), and authorized the City
Attorney's Office to obtain abatement warrants and abate the nuisances. After providing the
property owners with additional time to voluntarily comply with the PMC, the City sought and
secured a warrant to enter and abate each property. In accordance with the authority granted by
said warrants, the City utilized third party contractors to abate the nuisances. State law and the
PMC entitle the City to recover its abatement costs, including attorneys' fees and costs. This
action requests that the City Council confirm those costs (Attachments C & D) and authorize
recovery from the property owners, including placing the amounts owed on the property tax rolls,
if the confirmed costs go unpaid.
Recommended Action:
It is recommended that the City Council adopt the proposed Resolutions (Attachments A & B)
confirming the costs incurred abating public nuisances, ordering payment, and authorizing
recovery of the same, including placement of any uncollected costs on the property tax rolls.
Discussion:
16943 Valle Verde Road
The City has received Code Enforcement complaints concerning this property dating back to
2012, with limited compliance. Relevant to this specific action, in February 2017, a new code
enforcement case was opened based on violations relating to the dilapidated fence and
accumulation of construction materials in public view. The City issued the property owner two
Notices of Violation, a Notice and Order to Abate, and four Administrative Citations between
February 2017 and August 2017 in an effort to address these issues.
On February 27, 2018, the City Attorney's Office sent the owner a Notice of Violation citing the
outstanding violations, demanding that the owner timely correct the violations, and providing the
owner a notice to appear before the Poway City Council at the April 3, 2018 City Council meeting
where the City Council would consider whether to declare the property a public nuisance.
1 of 39 January 15, 2019, Item #,L
Public Nuisance Hearing — Confirming Abatement Costs
January 15, 2019
Page 2
At a public hearing on April 3, 2018, the City Council considered all of the evidence and found
that the conditions on the property constitute a public nuisance, and authorized abatement of the
violations by removing all the trash, junk, miscellaneous debris, dilapidated fencing, inoperable
vehicles, and encroachments. The agenda report submitted to the City Council stated that staff
would return to the City Council to confirm the costs and then lien the property for the same, which
is the purpose of this action. The property owner did not appear at this public hearing.
The abatement warrant was issued in June 2018, and the abatement work was performed by the
City's contractor on June 28, 2018, which cost the City $1,630 (Attachment C, pp. 3-6).
The City also incurred legal expenses and associated court costs throughout this process, which
total $3,639.58 (Attachment C, pp. 7-15).
12805 Beeler Creek Trail
Commencing in 2013, the City began receiving complaints regarding a shed and tarp fence in the
floodway on the property. Upon inspection in June 2013, the City concluded that both a fence
and a shed had been placed within the floodway located on the property in violation of PMC
§16.88.060. The City sent several Notices of Violation to the property owner regarding the fence
and shed encroachments. On January 9, 2015, the City sent the owner a Notice and Order to
Abate regarding the shed and fence, and when compliance was not achieved, the City continued
its administrative effort to gain compliance by issuing the property owner a number of
Administrative Citations. The City has engaged in consistent and continuous efforts to achieve
voluntary compliance since that time, but the tarp fence was not removed until June 2018, after
the City obtained an inspection and abatement warrant, as discussed below.
In September 2014, the City received another complaint regarding the property. The complainant
claimed that the garage and workshop on the property had been converted to habitable space
and was being rented out to individuals as living quarters. The City sent a courtesy notice and
then subsequent Notices of Violation to the property owner requesting inspection of the garage
and workshop area. In July 2015, City staff sent the owner a letter regarding options to legalize
the conversion of the garage and workshop to habitable space. In March 2016, the property
owner met with staff regarding the garage and workshop conversion. City staff informed her that
the garage conversion required permits and that no kitchen would be allowed.
In November 2016, the owner submitted plans to the Building Department to legalize the garage
and workshop conversion to a guest house. The City approved the plans with certain conditions,
including a condition that required the owner to get approval from the Department of
Environmental Health Services (DEHS) for use of the septic system. DEHS determined that the
conversion would require that the property owner's septic system be expanded to accommodate
the additional habitable space. City staff contacted DEHS to determine whether any exception to
the requirement existed. Ultimately, DEHS determined that it would not grant an exception to this
requirement. No further action was taken by the owner, and the City's plan check application for
the garage and workshop conversion expired on November 29, 2017.
On February 27, 2018, the City Attorney's Office sent a letter to the property owner that identified
the PMC violations and provided the property owner an opportunity to abate the aforementioned
violations. The letter also provided the property owner a notice to appear before the Poway City
Council on April 3, 2018 for a hearing to consider whether the property constitutes a public
2 of 39 January 15, 2019, Item # 3.1
Public Nuisance Hearing — Confirming Abatement Costs
January 15, 2019
Page 3
nuisance. The property owner and her daughter both appeared at the public hearing and objected
to the proposed declaration of a public nuisance. However, the property owner refused to
voluntarily allow City staff onsite to inspect the property to determine if the tarp fence or
unpermitted habitable space had been brought into compliance.
At a public hearing on April 3, 2018, the City Council considered all of the evidence, including the
property owner's objections, and found that the conditions on the property constitute a public
nuisance, and authorized abatement of the floodway encroachment and inspection of the garage
and workshop. In particular, in addition to removing the tarp fence, the City Council required that
an interior garage wall be removed, the overhead garage door be operable, and that the stove be
removed and that all of this should be completed within 30 days.
Upon City application, in June 2018, the Court issued an inspection and abatement warrant.
When City staff and its contractor executed the inspection warrant on June 28, 2018, the City
discovered that the tarp fence, garage and workshop had all been brought into compliance. The
property owner never notified the City of these changes, nor did the owner allow the City to inspect
the property without executing the inspection and abatement warrant. As a result, the City
incurred $270 in costs from the abatement contractor's time, which the property owner could have
easily avoided (Attachment D, pp. 4-6).
Further, because compliance was not achieved until the day the inspection warrant was executed,
the City also incurred legal expenses and associated costs throughout the process, which total
$4,229.37 (Attachment D, pp. 7-16).
It should be noted that City staff has spent a considerable amount of time and effort on both of
the foregoing cases over many years, yet the City is not seeking to recover the significant costs
associated with that time. The proposed recovery is a fraction of the "real" costs incurred to bring
these two properties into compliance with the PMC.
Environmental Review:
This item is not a "Project" pursuant to the California Environmental Quality Act (CEQA) and is
therefore not subject to CEQA review.
Fiscal Impact:
Approval of the resolutions will result in the recovery of abatement costs already expended by the
City. Failure to adopt the Resolutions will result in the City being unable to recover the incurred
costs.
Public Notification:
Public notice was published in the Poway News Chieftain on January 3, 2019, and a copy of this
report was both sent by certified mail, return receipt requested, to each respective property
owner, and physically posted at both subject properties.
3 of 39 January 15, 2019, Item # 3.1
Public Nuisance Hearing — Confirming Abatement Costs
January 15, 2019
Page 4
Attachments:
A. Resolution (16943 Valle Verde Road)
B. Resolution (12805 Beeler Creek Trail)
C. Invoices and Executed Inspection and Abatement Warrant for 16943 Valle Verde Road
D. Invoices and Executed Inspection and Abatement Warrant for 12805 Beeler Creek Trail
Reviewed/Approved By:
Wendy Kaserman
Assistant City Manager
4 of 39
Reviewed By:
1/"'" Ut:
Approved By:
,,5V Y , A/l
Alan Fentermacher Tina M. White
City Attorney City Manager
January 15, 2019, Item #3.1
RESOLUTION NO. 19-
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
POWAY, CALIFORNIA, CONFIRMING ABATEMENT COSTS
AND AUTHORIZING RECOVERY (APN 273-171-05-00)
WHEREAS, on April 3, 2018, the City Council of the City of Poway ("City Council") declared
a public nuisance at 16943 Valle Verde Road, Poway, California ("Property"), and directed City staff
and the City Attorney's office to take all steps necessary to abate said nuisance, including obtaining
and executing an inspection and abatement warrant;
WHEREAS, inspection and abatement warrants were obtained and executed for the
Property, and the public nuisances thereon were abated;
WHEREAS, on January 15, 2019, the City Council held a public hearing to confirm the costs
incurred in the abatement of the foregoing public nuisances at the Property in compliance with all
applicable provisions of law; and
WHEREAS, the owner(s) of the Property was notified of the January 15, 2019 public hearing
in the manner required by law.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Poway as follows:
The City Council confirms that the City of Poway incurred a total of $5,269.58 in
costs to abate a public nuisance at the Property, located at 16943 Valle Verde Road,
which the City Council hereby finds is reasonable in amount, and further finds that
such costs were necessary in order to abate the public nuisance.
City staff and the City Attorney's office are hereby authorized to take all steps to
recover and collect the foregoing costs from the owner(s) of the Property, including
placement of these amounts as special assessment on the appropriate property tax
rolls, pursuant to Poway Municipal Code ("PMC") section 16.68.040 or any other
applicable provision of law, if not voluntarily paid.
3. All interested parties are hereby notified that judicial review, if desired, shall be
sought within the 90 -day time limit set forth in Code of Civil Procedure section
1094.6.
PASSED, ADOPTED AND APPROVED by the City Council of the City of Poway at a regular
meeting this 15th day of January 2019.
Steve Vaus, Mayor
ATTEST:
A. Kay Vinson, Interim City Clerk
5 of 39 ATTACHMENT A January 15, 2019, Item #3.
Resolution No. 19 -
Page 2
STATE OF CALIFORNIA )
) SS
COUNTY OF SAN DIEGO )
I, A. Kay Vinson, Interim City Clerk, of the City of Poway, do hereby certify under penalty of
perjury that the foregoing Resolution No. 19-*** was duly adopted bythe City Council at a meeting of
said City Council held on the 15th day of January 2019, and that it was so adopted by the following
vote:
AYES:
NOES:
ABSENT:
DISQUALIFIED:
A. Kay Vinson, Interim City Clerk
City of Poway
6 of 39 January 15, 2019, Item #3.1
RESOLUTION NO. 19-
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
POWAY, CALIFORNIA, CONFIRMING ABATEMENT COSTS
AND AUTHORIZING RECOVERY (APN 316-070-34-00)
WHEREAS, on April 3, 2018, the City Council of the City of Poway ("City Council") declared
a public nuisance at 12805 Beeler Creek Trail, Poway, California ("Property'), and directed City staff
and the City Attorney's office to take all steps necessary to abate said nuisance, including obtaining
and executing an inspection and abatement warrant;
WHEREAS, inspection and abatement warrants were obtained and executed for the
Property, and the public nuisances thereon were abated;
WHEREAS, on January 15, 2019, the City Council held a public hearing to confirm the costs
incurred in its efforts to abate of the foregoing public nuisances at the Property, including the
execution of an inspection warrant, in compliance with all applicable provisions of law; and
WHEREAS, the owner(s) of the Property were notified of the January 15, 2019 public
hearing in the manner required by law.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Poway as follows:
The City Council confirms that the City of Poway incurred a total of $4,499.37 in
costs to abate a public nuisance at the Property, located at 12805 Beeler Creek
Trail, which the City Council hereby finds is reasonable in amount, and further finds
that such costs were necessary in order to abate the public nuisance.
2. City staff and the City Attorney's office are hereby authorized to take all steps to
recover and collect the foregoing costs from the property owners, including
placement of these amounts as special assessment on the appropriate property tax
rolls, pursuant to Poway Municipal Code ("PMC") section 16.68.040 or any other
applicable provision of law, if not voluntarily paid.
3. All interested parties are hereby notified that judicial review, if desired, shall be
sought within the 90 -day time limit set forth in Code of Civil Procedure section
1094.6.
PASSED, ADOPTED AND APPROVED by the City Council of the City of Poway at a regular
meeting this 15th day of January 2019.
Steve Vaus, Mayor
ATTEST:
A. Kay Vinson, Interim City Clerk
7 of 39 ATTACHMENT B January 15, 2019, Item #3•j
Resolution No. 19 -
Page 2
STATE OF CALIFORNIA )
)SS
COUNTY OF SAN DIEGO )
I, A. Kay Vinson, Interim City Clerk, of the City of Poway, do hereby certify under penalty of
perjury that the foregoing Resolution No. 19-*** was duly adopted by the City Council at a meeting of
said City Council held on the 15th day of January 2019, and that it was so adopted by the following
vote:
AYES:
NOES:
ABSENT:
DISQUALIFIED:
A. Kay Vinson, Interim City Clerk
City of Poway
8 of 39 January 15, 2019, Item # 3.1
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Rutan 8 Tucker, LLP
ellonw.l 1319
2UTAN & TUCKER, LLP
Man B. Fenstermacher (State Bar No. 278171)
ifenstermachc,r@rutan.com
,4oam Duzman (State Bar No. 213 689)
rduzman@rutan,com
i 11 Anton Boulevard, Suite 1400
2osta Mesa, California 92626-1931
Telephone: 714-641-5100
Facsimile: 714-546-9035
Attorneys for the CITY OF POWAY
F I L E
elul0 ni lukuler eautl
JUN 21 2018
Exempt Prom Filing Fee Pursuant to
Government Code section 6103
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF S to 4`t A h�Go 4
CITY OF POWAY,
Plaintiff,
vs.
ZAMBUS FAMILY TRUST,
Defendant.
Dept
Case No. 37 -2018 -00030792 -CU -PT -CTL
INSPECTION WARRANT
THE PEOPLE OF THE STATE OF CALIFORNIA: To any employee of the City of Poway, any
other law enforcement agency including the San Diego Sheriff's Department, and any authorized
contractor or agent of the City of Poway (collectively, the "City"):
You are hereby commanded to enter the exterior of the property described as 16943 Valle
Verde Rd., in the City of Poway, County of San Diego, State of California, 92064, Assessor's
Parcel Number 273-171-0500 ("Property") and inspect and abate the nuisance conditions thereon
6s authorized herein. The owner of the Property is the Zambus Family Trust 01-03-92 (the
"Owner").
Proof, by affidavit, was made this day before me, by Poway Director of Development
Services Robert Manis that there is just and reasonable cause for believing that there are
conditions on the Property that constitute violations of the Poway Municipal Code, Said affidavit
is incorporated here in full.
�aRaa
,-�9; Item #25121012782.0015^ ----AT et rA
I Pursuant to this warrant, the City is so authorized to:
2 a. Access the exterior of the Property;
3 b. Remove and dispose of any all debris, trash, and refuse;
4 c, Remove and dispose of the dilapidated fence;
5 d. Use the assistance of the San Diego Sheriff's Department in order to keep the peace
6 during the inspection and abatement of the violations of the Poway Municipal
7 Code;
8 e. Videotape and/or photograph and take any report of any and all of the
9 aforementioned activities; and
10 f. All City-incurred fees and costs not paid by the property owner associated with the
I I abatement will be part of the costs of abatement that will be presented to the City
12 Council for confinnation of costs, and an eventual Nuisance Abatement Lien or
13 Special Assessment against the Property in accordance with applicable law.
14 You and each of you, are hereby commanded and authorized in the daytime, between the
15 hours of 8:00 a.m. and 6:00 p.m,, to enter the Property's exterior for those reasons set forth herein.
16 This warrant may be executed without prior notice.
17 This Abatement Warrant authorizes the presence of one or more peace officers to
18 accompany the execution of this Abatement Warrant in order to keep the peace during the
19 inspection authorized by this Abatement Warrant, This Abatement Warrant also authorizes
20 reasonable force, including the use of a locksmith and/or the cutting or breaking of any locks
21 restricting access to the Property,
22 This Abatement Warrant shall be effective for a period of fourteen (14) days from the date
23 of issuance specified below,
24 IT IS SO ORDERED:
25
26
27 Dated:J
/ Judge of the Superior Cov Eddie C. sturgeou
28 of the State of California
Rulan 8 TUcWer, LLP
ormmi0I5F39 sizroiazsz-oois 2 9, Item# 3.1
„,-,0,1,9. INSPR(Tl(1N W A R R ANT
PLEASE REMIT CHECK PAYMENT TO:
2950 Kurtz Street, San Diego, CA, 92110 NRC Environmental Services, Inc.
Phone: 619.235-3320,Fax:619-232-4093 P.O Box 749929
Los Angeles, CA 90074-9929
Customer:
PLEASE REMIT ACH PAYMENT TO:
®
NRC Environmental Services, Inc.
Bank of America Merrill Lynch
Transportation and Disposal of Non -Hazardous Solid Waste
ABA 0210 0032 2
NRC Job M
A/C# 483043542964
THANK YOU FOR YOUR BUSINESS
A/C Name: NRC Environmental Services, Inc.
PLEASE REMIT CHECK PAYMENT TO:
2950 Kurtz Street, San Diego, CA, 92110 NRC Environmental Services, Inc.
Phone: 619.235-3320,Fax:619-232-4093 P.O Box 749929
Los Angeles, CA 90074-9929
Customer:
CITY OF POWAY
Invoice M
679000
Transportation and Disposal of Non -Hazardous Solid Waste
13325 Civic Center Dr
NRC Job M
127889
THANK YOU FOR YOUR BUSINESS
INVOICE SUBTOTAL 1,630.00
SALES TAX 0.00
INVOICE TOTAL 1,630.00
Customer PO#:
POWAY, CA, 92064
Reference M
Invoice Date:
17-JUL-18
Contact:
MANIS, BOB
Job Description:
Unpermitted Construction Removal
Phone:
858-668-4601
Fax:
E -Mail:
bmanis@poway.org
Terms:
30 NET
Job Location:
16943 Valle Verde Road
Job Date (s):
6/28/18
POWAY, CA, 92064
Progress Billing:
No
Final Billing:
Yes
Descri tion See Attached Details
EXTENDED PRICE
Residential Non -Permitted Abatement Crew
1,080.00
Transportation and Disposal of Non -Hazardous Solid Waste
550.00
THANK YOU FOR YOUR BUSINESS
INVOICE SUBTOTAL 1,630.00
SALES TAX 0.00
INVOICE TOTAL 1,630.00
Currency: USD
OR CCB #89527
WA CCB #NRCENS963CR
FED ID #: 91.1572532
A 1.5% per month finance charge will be assessed for all past due invoices to include the flat late fee amount.
11 of 39 January 15, 2019, Item 3.1
M Am AV
bP c
JOB NO 127889
Others
INVOICE DETAILS SHEET
INVOICE NO 679000 Page No 2/2
Date
Name/Items
Description
Billing Code
UOM
Oty
Rate
Amount
28 -JUN -18
Residential
1,080.00
Non -Permitted
Abatement Crew
28 -JUN -18
Transportation and
550.00
Disposal of
Non -Hazardous Solid
Waste
Sub Total 1,630.00
Grand Total 1,630.00
12 of 39 January 15, 2019, Item # 3.1
A x Dally Work Report of
City Of Poway
Date: Thursday, June 28, 2018
re'nivoi 16943 Valle Verde Rd, Poway, CA 92064
Pro)en Number: 127889
Project Out.: 3325 SAN DIEGO, CAL FORMA
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13 of 39 January 15, 2019, Item #3.1
SYCAMORE LANDFILL
8514 MAST BLVD
SANTEE, CA 92071
c)-
018350 - NRC ENVIRONMENTAL SERVICES
3500 Sunrise Hwy. Ste 200, Building 200
Great River, NY 11739
Contract: COMMERCIAL -GATE -0
GROSS 13,380 Scale In
TARE 12,480 Scale Out
NET 900
Tracking Qty: 0.00
Qty Unit Description
0.45 TN MSW
Origin: POWAY 1000
Y9 Ticket #:1581435
Weighmaster: IN - ribblal OUT - calixch
In: June 28, 2018 11:32 am
Out: June 28, 2018 11:57 am
Vehicle: C
Ref:
BOL:
INBOUND
INVOICE
Rate Extension
Tax
Total
Paid
Change
Total
Signature:
14 of 39 January 15, 2019, Item # 3. l
TAXPAYERS ACCOUNT
NO 95.0519027
Poway, City of
Attn: Wendy Kaserman
Assistant City Manager
13325 Civic Center Drive
Poway, CA 92064
RUTAN & TUCKER, LLP
ATTORNEYS AT LAW
A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS
RE: Poway v. Zambus Family Trust
611 ANTON BOULEVARD SUITE 1400
POST OFFICE BOX 1950
COSTA MESA, CALIFORNIA 92628-1950
(714)641-5100
Invoice No.
Account No.
Billing Atty.
Date
Page
803109
012782-0015
John Ramirez
March 16, 2018
1
FOR PROFESSIONAL SERVICES RENDERED THROUGH FEBRUARY 28. 2018
02/22/18 Noam I. Duzman 0.20
02/28/18 Daniel Huizar (0) 0.20
02/28/18 Noam I. Duzman 0.60
Total Hours 1.00
Total Professional Services
Total Current Fees
Prior Balance Due
Total Balance Due
$196.00
$196.00
$0.00
$196.00
Additional disbursements may have been paid or incurred on your behalf and are not reflected in this statement.
An additional statement covering such disbursements will be furnished to you.
The abbreviation (PA), (LC), (LSS), (DC) or (0) following an individual's name denotes paralegal, law clerk,
15 of 39 litigation support specialist, document clerk, or other paraprofessilAuary 15, 2019, Item # 3.1
TAXPAYERS ACCOUNT
RUTAN & TUCKER, LLP
03/19/18
NO 95-3519027
ATTORNEYS AT LAW
Noam I. Duzman
03/21/18
A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS
611 ANTON BOULEVARD SUITE 1400
POST OFFICE BOX 1950
COSTA MESA, CALIFORNIA 92628-1950
(714)641-5100
Poway, City of
Invoice No.
806166
Attn: Wendy Kaserman
Account No.
012782-0015
Assistant City Manager
Billing Atty.
John Ramirez
13325 Civic Center Drive
Date
April 23, 2018
Poway, CA 92064
Page
1
RE: Poway v. Zambus Family Trust
FOR PROFESSIONAL SERVICES RENDERED THROUGH MARCH 31, 2018
03/06/18 Noam I. Duzman
03/14/18 Alan Fenstermacher
03/14/18 Noam I. Duzman
03/19/18
Alan Fenstermacher
03/19/18
Noam I. Duzman
03/20/18
Noam I. Duzman
03/21/18
Alan Fenstermacher
03/21/18
03/22/18
03/22/18
16 of 39
Noam I. Duzman
Alan Fenstermacher
0.20
0.20
0.30
0.40
1.10
0.20
0.20
1.20
0.10
Noam I. Duzman 0.50
Additional disbursements may have been paid or incurred on your behalf and are not reflected in this statement.
An additional statement covering such disbursements will be furnished to you.
The abbreviation (PA), (LC), (LSS), (DC) or (0) following an individual's name denotes paralegal, law clerk,
litigation support specialist, document clerk, or other paraprofessignanuary 15, 2019, Item # 3 .
RUTAN & TUCKER, LLP
ATTORNEYS AT LAW
Poway, City of April 23, 2018
Poway v. Zambus Family Trust Invoice No. 806166
012782-0015 Page No. 2
Total Hours 4.40
Total Professional Services $990.00
DISBURSEMENTS AND COSTS ADVANCED
Miscellaneous 10.00
Total Disbursements $10.00
Total Current Fees and Costs $1,000.00
Previous Balance Due 196.00
Payments and Adjustments (196.00)
Prior Balance Due $0.00
Total Balance Due $1,000.00
ACCOUNTS RECEIVABLE
0 - 30 DAYS 31- 60 DAYS 61 - 90 DAYS 91 - 180 DAYS OVER 180
$1,000.00 $0.00 $0.00 $0.00 $0.00
Additional disbursements may have been paid or incurred on your behalf and are not reflected in this statement.
An additional statement covering such disbursements will be furnished to you.
The abbreviation (PA), (LC), (LSS), (DC) or (0) following an individual's name denotes paralegal, law clerk,
litigation support specialist, document dark, or other paraprofessional.
17 of 39 January 16, 2019, Item #3.1
TAXPAYERS ACCOUNT
NO 95.0519027
Poway, City of
Attn: Wendy Kaserman
Assistant City Manager
13325 Civic Center Drive
Poway, CA 92064
RUTAN & TUCKER, LLP
ATTORNEYS AT LAW
A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS
RE: Poway v. Zambus Family Trust
611 ANTON BOULEVARD SUITE 1400
POST OFFICE BOX 1950
COSTA MESA, CALIFORNIA 92628-1950
(714)641-5100
Invoice No.
Account No.
Billing Atty.
Date
Page
808148
012782-0015
John Ramirez
May 15, 2018
1
FOR PROFESSIONAL SERVICES RENDERED THROUGH APRIL 30, 2018
04/03/18 Noam I. Duzman 0.90
04/05/18
Noam I.
Duzman
0.10
04/18/18
Noam I.
Duzman
0.10
04/23/18 Noam I. Duzman 0.20
Total Current Fees
Previous Balance Due
Payments and Adjustments
Prior Balance Due
Total Hours 1.30
Total Professional Services
1,000.00
(1,000.00)
$292.50
$292.50
$0.00
Total Balance Due $292.50
Additional disbursements may have been paid or incurred on your behalf and are not reflected in this statement.
An additional statement covering such disbursements will be furnished to you.
The abbreviation (PA), (LC), (LSS), (DC) or (0) following an individual's name denotes paralegal, law clerk,
18 of 39 litigation support specialist, document dark, or other paraprofessipanhuary 15, 2019, Item # 3. I
TAXPAYERS ACCOUNT
NO 96-3519027
Poway, City of
Attn: Wendy Kaserman
Assistant City Manager
13325 Civic Center Drive
Poway, CA 92064
RUTAN & TUCKER, LLP
ATTORNEYS AT LAW
A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS
611 ANTON BOULEVARD SUITE 1400
POST OFFICE BOX 1950
COSTA MESA, CALIFORNIA 9262&1950
(714)641-5100
Invoice No.
810384
Account No.
012782-0015
Billing Atty.
John Ramirez
Date
June 13, 2018
Page
1
RE: Poway v. Zambus Family Trust
FOR PROFESSIONAL SERVICES RENDERED THROUGH MAY 31, 2018
05/03/18 Noam I. Duzman
05/04/18
05/08/18
05/08/18
05/23/18
05/24/18
05/25/18
05/30/18
05/30/18
19 of 39
Noam I. Duzman
Noam I. Duzman
Noam I. Duzman
Noam I. Duzman
Noam I. Duzman
Noam I. Duzman
Alan Fenstermacher
0.20
0.20
0.30
0.10
0.20
0.20
0.40
0.30
Noam I. Duzman 0.80
Additional disbursements may have been paid or incurred on your behalf and are not reflected in this statement.
An additional statement covering such disbursements will be furnished to you.
The abbreviation (PA), (LC), (LSS), (DC) or (0) following an individual's name denotes paralegal, law clerk, 2
litigation support specialist, document clerk, or other paraprofessjnal. Uary 15, 2019, Item # .J.
Poway, City of
Poway v. Zambus Family Trust
012782-0015
RUTAN & TUCKER, LLP
ATTORNEYS AT t -AW
June 13, 2018
Invoice No. 810384
Page No. 2
Total Hours 2.70
Total Professional Services $607.50
Total Current Fees $607.50
Previous Balance Due 292.50
Payments and Adjustments (292.50)
Prior Balance Due $0.00
Total Balance Due $607.50
ACCOUNTS RECEIVABLE
0 - 30 DAYS 31- 60 DAYS 61 - 90 DAYS 91 - 180 DAYS OVER 180
$607.50 $0.00
Additional disbursements may have been paid or incurred on your behalf and are not reflected in this statement.
An additional statement covering such disbursements will be furnished to you.
The abbreviation (PA), (LC), (LSS), (DC) or (0) following an individual's name denotes paralegal, law clerk,
litigation support specialist, document clerk, or other paraprofessional.
20 of 39 January1 S, 2019, Item # 5.1
TAXPAYERS ACCOUNT RUTAN & TUCKER, LLP
NO 95-3519027 ATTORNEYS AT LAW
A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS
611 ANTON BOULEVARD SUITE 1400
POST OFFICE BOX 1950
COSTA MESA, CALIFORNIA 92628-1950
(714)641-5100
Poway, City of
Attn: Wendy Kaserman
Assistant City Manager
13325 Civic Center Drive
Poway, CA 92064
Invoice No.
813246
Account No.
012782-0015
Billing Atty.
John Ramirez
Date
July 16, 2018
Page
1
RE: Poway v. Zambus Family Trust
FOR PROFESSIONAL SERVICES RENDERED THROUGH JUNE 30, 2018
06/11/18 Noam I. Duzman
0.40
06/12/18 Noam I. Duzman 1.40
06/13/18
Noam I.
Duzman
0.10
06/18/18
Noam I.
Duzman
0.40
06/19/18 Noam I. Duzman 0.20
06/21/18 Noam I. Duzman 2.50
06/22/18 Noam I. Duzman 0.50
06/27/18 Noam I. Duzman 0.20
Additional disbursements may have been paid or incurred on your behalf and are not reflected in this statement.
An additional statement covering such disbursements will be furnished to you.
The abbreviation (PA), (LC), fl -SS), (DC) or (0) following an individual's name denotes paralegal, law clerk,
21 of 39 litigation support specialist, document clerk, or other paraprofessignaal. uary15, 2019, Item # 3.
RUTAN & TUCKER, LLP
ATTORNEYS AT t -AW
Poway, City of
Poway v. Zambus Family Trust
012782-0015
DISBURSEMENTS AND COSTS ADVANCED
Duplication
Express Mail
Postage
Total Current Fees and Costs
Previous Balance Due
Payments and Adjustments
Prior Balance Due
Total Balance Due
Total Hours
Total Professional Services
Total Disbursements
ACCOUNTS RECEIVABLE
July 16, 2018
Invoice No. 813246
Page No. 2
5.70
$1,282.50
27.36
96.52
24.70
$148.58
$1,431.08
607.50
(607.50)
$0.00
$1,431.08
Additional disbursements may have been paid or incurred on your behalf and are not reflected in this statement.
An additional statement covering such disbursements will be furnished to you.
The abbreviation (PA), (LC), (LES), (DC) or (0) following an individual's name denotes paralegal, law clerk,
litigation support specialist, document clerk, or other paraprofessional.
22 of 39 January 15, 2019, Item # 3.1
TAXPAYERS ACCOUNT
NO 95-3519027
Poway, City of
Attn: Wendy Kaserman
Assistant City Manager
13325 Civic Center Drive
Poway, CA 92064
RUTAN & TUCKER, LLP
ATTORNEYS AT LAW
A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS
RE: Poway v. Zambus Family Trust
611 ANTON BOULEVARD SUITE 1400
POST OFFICE BOX 1950
COSTA MESA, CALIFORNIA 92628-1950
(714)641-5100
Invoice No.
Account No.
Billing Atty.
Date
Page
816773
012782-0015
John Ramirez
August 24, 2018
1
FOR PROFESSIONAL SERVICES RENDERED THROUGH JULY 31, 2018
07/02/18 Noam I. Duzman 0.50
Total Current Fees
Previous Balance Due
Payments and Adjustments
Prior Balance Due
Total Balance Due
Total Hours 0.50
Total Professional Services
ACCOUNTS RECEIVABLE
1,431.08
(1,431.08)
$112.50
$112.50
$0.00
$112.50
Additional disbursements may have been paid or incurred on your behalf and are not reflected in this statement.
An additional statement covering such disbursements will be furnished to you.
The abbreviation (PA), (LC), (LES), (DC) or (0) following an individual's name denotes paralegal, law clerk,
23 of 39 litigation support specialist, document clerk, or other paraprofessiUA!nuary 15, 2019, Item # 3.1
I RUTAN & TUCKER, LLP
Alan B. Fenstermacher (State Bar No. 278171)
2 afenstermacher rutan.com I L p
Noam Duzman (State Bar No. 213689) 6N�el A, 8900010624
3 nduzman@rutan.com
611 Anton Boulevard, Suite 1400 JUN 212018
4 Costa Mesa, California 92626-1931
Telephone: 714-641-5100 Deputy
5 Facsimile: 714-546-9035
6 Attorneys for the CITY OF POWAY
7 Exempt from Filing Fee Pursuant to
Government Code section 6103
8
9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 FOR THE COUNTY OF SAN DIEGO
11 CITY OF POWAY, Case No. 37.2018.o0030788 -CU -P" -CTL
12 Plaintiff, INSPECTION WARRANT
13 vs.
14 BEVERLY S. THOMAS,
15 Defendant.
16
17 THE PEOPLE OF THE STATE OF CALIFORNIA: To any employee of the City of
18 Poway, any other law enforcement agency including the San Diego Sheriff's Department,
19 and any authorized contractor or agent of the City of Poway (collectively, the "City"):
20 You are hereby commanded to enter the exterior of the Property and the interior of
21 the garage/workshop/storage structure ("Garage") of the property described as 12805
22 Beeler Creek Trail, in the City of Poway, County of San Diego, State of California, 92064,
23 Assessor's Parcel Number 316-070-34 (the 'Property") and inspect and abate the nuisance
24 conditions thereon as authorized herein. The owner of the Property is Beverly S. Thomas
25 (the "Owner").
26 Proof, by affidavit, was made this day before me, by Poway Director of
27 Development Services Robert Manis that there is just and reasonable cause for believing
28 that there are conditions on the Property that constitute violations of the Poway Municipal
0
24 of
2512/012762-0016
ATTACHMENT D
TNSPECT[ON W.
I Code. Said affidavit is incorporated here in full.
2 Pursuant to this warrant, the City is so authorized to:
3 a. Access the exterior of the Property and the interior of the Garage on the
4 Property;
5 b. Remove and haul off the Property any unpermitted item and improvement
6 found in the floodway;
7 c. Enter the interior of the Garage to inspect for any unpermitted improvements
8 and occupancy of the structure;
9 d. Use the assistance of the San Diego Sheriff's Department in order to keep
10 the peace during the inspection and abatement of the violations of the Poway
I 1 Municipal Code;
12 e. Videotape and/or photograph and take any report of any and all of the
13 aforementioned activities; and
14 f. All City-incurred fees and costs not paid by the property owner associated
15 with the abatement will be part of the costs of abatement that will be
16 presented to the City Council for confirmation of costs, and an eventual
17 Nuisance Abatement Lien or Special Assessment against the Property in
18 accordance with applicable law.
19 Therefore, you and each of you, are hereby commanded and authorized in the
20 daytime, between the hours of 8:00 a.m. and 6:00 p.m., to enter the Property's exterior in
21 addition to the interior of the Garage thereon.
22 This warrant may be executed without prior notice.
23 This Abatement Warrant authorizes the presence of one or more peace officers to
24 accompany the execution of this Abatement Warrant in order to keep the peace during the
25 inspection authorized by this Abatement Warrant. This Abatement Warrant also
26 authorizes reasonable force, including the use of a locksmith and/or the cutting or breaking
27 of any locks restricting access to the Property.
28 ///
25 of 39 -2- January 15.2019. Item # 3.1
25121012782-0016INSPECTION WARRANT
nexgnAone IanOemII one
a
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
2_`
2(
2;
2f
26 of
This Abatement Warrant shall be effective for a period of fourteen (14) days from
[he date of issuance specified below.
IT IS SO ORDERED:
Dated: SohQa1S
ie #(o)f the Superror Cou
of the State of California
Eddie C. Sturgeon
-3- Januarv15.2019,Item#3.1
2512/012782-0016 INSPECTION WARRANT
I14 W061 06110119
001 AW�C
v
oi
2950 Kurtz Street, San Diego, CA, 92110
Phone: 619-235-3320, Fax:619-232-4093
Customer: CITY OF POWAY
13325 Civic Center Or
POWAY, CA, 92064
PLEASE REMIT ACH PAYMENT TO:
NRC Environmental Services, Inc.
Bank of America Merrill Lynch
ABA 0210 0032 2
A/C# 483043542964
A/C Name: NRC Environmental Services, Inc.
PLEASE REMIT CHECK PAYMENT TO:
NRC Environmental Services, Inc.
P.O Box 749929
Los Anoeles. CA 90074-9929
Invoice M
NRC Job M
Customer PO#:
Reference #:
Invoice Date: 17-JUL-18 Contact:
Job Description: Unpermitted Construction Removal Phone:
Fax:
E -Mail:
Terms:
Job Location: 12805 BEELER CREEK TRAIL
POWAY, CA, 92064
THANK YOU FOR YOUR BUSINESS
Job Date (s):
679001
127889
MANS, BOB
858-668-4601
bmanis@poway.org
30 NET
Progress Billing: No
Final Billing: Yes
INVOICE SUBTOTAL
SALES TAX
INVOICE TOTAL
OR CCB #89527
WA CCB #NRCENS963CR
FED ID #: 91-1572532
A 1.5% per month finance charge will be assessed for all past due invoices to include the flat late fee amount.
27 of 39 January 15, 2019, Item # 3.1
Mr6
JOB NO 127889
Others
INVOICE DETAILS SHEET
INVOICE NO 679001
Page No 2/2
Date
Namelltem s
Description
Billing Code
UOM
Qty
Rate
Amount
28 -JUN -18
Residential
270.00
Non -Permitted
Abatement Crew
Sub Total 270.00
Grand Total 270.00
28 of 39 January 15, 2019, Item # 3•
C-11": City Of Poway
".am .... L.- 12805 Beeler Creek Trail, Poway, CA 92064
w..a.-maun: Poway Abatement Work
Daily Work Report
Date: Thursday, June 28, 2018
Project Number: 127889
Project 0,.: 3225 SAN DIEGO, CALIFORNIA
Customer PO/Pmj p:
Task Code:
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basam Ir,n—. pw.µre n —Vet
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BIIIIN.
FIELD SUPERVISOR
Fuentes, David
m
LRGS
11:00 13:00
100
❑
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o
TECHNICIAN/HA WOPE
R
Voelker, John
m
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Murillo, Angel
m
LRGS
12:00 13:00
1:00
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$0 1125 0
SUB DISPOSAL
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01581435
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1
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So 3376 m
0
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ane.mFMeTVF
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Customer Representative
.umleeca uollf-,lm --.1.m1m Wr4Cale)axLlla•YnrmnrnCa areaal�Ho1
29 of 39 January15, 2019, Item # 3.1
TAXPAYERS ACCOUNT
RUTAN & TUCKER, LLP
Duzman
NO 953519027
ATTORNEYS AT LAW
Noam I.
Duzman
A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS
611 ANTON BOULEVARD SUITE 1400
POST OFFICE BOX 1950
COSTA MESA, CALIFORNIA 92628-1950
(714)641-5100
Poway, City of
Invoice No.
803110
Attn: Wendy Kaserman
Account No.
012782-0016
Assistant City Manager
Billing Atty.
John Ramirez
13325 Civic Center Drive
Date
March 16, 2018
Poway, CA 92064
Page
1
RE: Poway v. Beverly Thomas
FOR PROFESSIONAL SERVICES RENDERED THROUGH FEBRUARY 28, 2018
02/22/18
Noam I.
Duzman
0.20
02/27/18
Noam I.
Duzman
1.10
Total Current Fees
Prior Balance Due
Total Balance Due
Total Hours 1.30
Total Professional Services
ACCOUNTS RECEIVABLE
0 - 30 DAYS 31- 60 DAYS 61 - 90 DAYS 91 -180 DAYS OVER 180
$292.50 $0.00 $0.00 $0.00 $0.00
$292.50
$292.50
$0.00
$292.50
Additional disbursements may have been paid or incurred on your behalf and are not reflected in this statement.
An additional statement covering such disbursements will be furnished to you.
The abbreviation (PA), (LC), (I -SS), (DC) or (0) following an individual's name denotes paralegal, law clerk,
30 of 39 litigation support specialist, document clerk, or other paraprofessipnanUary 15, 2019, Item # 3.1
TAXPAYERS ACCOUNT RUTAN & TUCKER, LLP
NO 95-3519027 ATTORNEYS AT LAW
A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS
611 ANTON BOULEVARD SUITE 1400
POST OFFICE BOX 1950
COSTA MESA, CALIFORNIA 92626-1950
(714)641-5100
Poway, City of
Attn: Wendy Kaserman
Assistant City Manager
13325 Civic Center Drive
Poway, CA 92064
Invoice No. 806167
Account No. 012782-0016
Billing Atty. John Ramirez
Date April 23, 2018
Page 1
RE: Poway v. Beverly Thomas
FOR PROFESSIONAL SERVICES RENDERED THROUGH MARCH 31, 2018
03/08/18 Noam I. Duzman 0.20
03/14/18 Alan Fenstermacher
03/15/18 Noam I. Duzman
03/16/18 Alan Fenstermacher
0.20
0.20
03/16/18 Noam I. Duzman 1.10
03/19/18 Noam I. Duzman 1.10
03/20/18 Noam I. Duzman 0.70
03/22/18
03/22/18
31 of 39
Alan Fenstermacher
0.40
Noam I. Duzman 0.60
Additional disbursements may have been paid or incurred on your behalf and are not reflected in this statement.
An additional statement covering such disbursements will be furnished to you.
The abbreviation (PA), (LC), (LSS), (DC) or (0) following an individual's name denotes paralegal, law clerk,
litigation support specialist, document clerk, or other paraprofessignafl
aUary 15, 2019, Item # 3• I
Poway, City of
Poway v. Beverly Thomas
012782-0016
Total Current Fees
Previous Balance Due
Payments and Adjustments
Prior Balance Due
Total Balance Due
RUTAN & TUCKER, LLP
ATTORNEYS AT LAW
Total Hours
Total Professional Services
ACCOUNTS RECEIVABLE
April 23, 2018
Invoice No. 806167
Page No. 2
5.40
$1,215.00
$1,215.00
292.50
(292.50)
$0.00
$1,215.00
0 - 30 DAYS 31- 60 DAYS 61 - 90 DAYS 91 - 180 DAYS OVER 180
$1,215.00
00 $0.00
Additional disbursements may have been paid or incurred on your behalf and are not reflected in this statement.
An additional statement covering such disbursements will be furnished to you.
The abbreviation (PA), (LC), (LSS), (DC) or (0) following an individual's name denotes paralegal, law clerk,
litigation support specialist, document clerk, or other paraprofessional.
32 of 39 January 15, 2019, Item # 3.1
TAXPAYERS ACCOUNT RUTAN & TUCKER, LLP
NO 95.3519027 ATTORNEYS AT LAW
A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS
611 ANTON BOULEVARD SUITE 1400
POST OFFICE BOX 1950
COSTA MESA, CALIFORNIA 92628-1950
(714)641-5100
Poway, City of
Attn: Wendy Kaserman
Assistant City Manager
13325 Civic Center Drive
Poway, CA 92064
Invoice No.
808149
Account No.
012782-0016
Billing Atty.
John Ramirez
Date
May 15, 2018
Page
1
RE: Poway v. Beverly Thomas
FOR PROFESSIONAL SERVICES RENDERED THROUGH APRIL 30, 2018
04/02/18 Alan Fenstermacher 0.20
04/02/18 Noam I. Duzman 0.30
04/03/18 Noam I. Duzman 0.90
04/05/18
Noam I.
Duzman
0.20
04/18/18
Noam I.
Duzman
0.10
04/23/18 Noam I. Duzman 0.20
Total Hours 1.90
Total Professional Services
$427.50
Total Current Fees $427.50
Previous Balance Due 1,215.00
Payments and Adjustments (1,215.00)
Additional disbursements may have been paid or incurred on your behalf and are not reflected in this statement.
An additional statement covering such disbursements will be furnished to you.
The abbreviation (PA), (LC), (LSS), (DC) or (0) following an individual's name denotes paralegal, law clerk,
33 of 39 litigation support specialist, document clerk, or other paraprofesla nal. 15, 2019, Item # 3.
Poway, City of
Poway v. Beverly Thomas
012782-0016
Prior Balance Due
Total Balance Due
RUTAN & TUCKER, LLP
ATTORNEYS AT LAW
ACCOUNTS RECEIVABLE
May 15, 2018
Invoice No. 808149
Page No. 2
0 -30 DAYS 31- 60 DAYS 61 - 90 DAYS 91 -180 DAYS OVER 180
$427.50 $0.00 $0.00 $0.00 $0.00
$0.00
$427.50
Additional disbursements may have been paid or incurred on your behalf and are not reflected in this statement.
An additional statement covering such disbursements will be furnished to you.
The abbreviation (PA), (LC), (LSS), (OC) or (0) following an individual's name denotes paralegal, law clerk,
litigation support specialist, document clerk, or other paraprofessional.
34 of 39 January15, 2019, Item # 3.1
TAXPAYERS ACCOUNT RUTAN & TUCKER, LLP
NO 95-3519027 ATTORNEYS AT LAW
A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS
611 ANTON BOULEVARD SUITE 1400
POST OFFICE BOX 1950
COSTA MESA, CALIFORNIA 92628-1950
(714)641-5100
Poway, City of
Attn: Wendy Kaserman
Assistant City Manager
13325 Civic Center Drive
Poway, CA 92064
Invoice No. 810385
Account No. 012782-0016
Billing Atty. John Ramirez
Date June 13, 2018
Page 1
RE: Poway v. Beverly Thomas
FOR PROFESSIONAL SERVICES RENDERED THROUGH MAY 31, 2018
05/04/18 Noam I. Duzman
05/08/18
05/08/18
05/16/18
05/23/18
05/24/18
05/25/18
05/30/18
05/30/18
35 of 39
Noam I. Duzman
Noam I. Duzman
Noam I. Duzman
Noam I. Duzman
Noam I. Duzman
Noam I. Duzman
Alan Fenstermacher
0.20
0.40
0.10
0.20
0.10
0.20
0.40
0.30
Noam I. Duzman 0.90
Additional disbursements may have been paid or incurred on your behalf and are not reflected in this statement.
An additional statement covering such disbursements will be furnished to you.
The abbreviation (PA), (LC), (I -SS), (DC) or (0) following an individual's name denotes paralegal, law clerk,
litigation support specialist, document clerk, or other paraprofessiprla), Uary 15, 2019, Item #3.
RUTAN & TUCKER, LLP
ATTORNEYS AT LAW
Poway, City of
Poway v. Beverly Thomas
012782-0016
June 13, 2018
Invoice No. 810385
Page No. 2
05/31/18 Noam I. Duzman 0.20
Total Hours 3.00
Total Professional Services $675.00
Total Current Fees $675.00
Previous Balance Due 427.50
Payments and Adjustments (427.50)
Prior Balance Due $0.00
Total Balance Due $675.00
ACCOUNTS RECEIVABLE
0 - 30 DAYS 31- 60 DAYS 61 - 90 DAYS 91 - 180 DAYS OVER 180
$675.00 $0.00 $0.00 $0.00 $0.00
Additional disbursements may have been paid or incurred on your behalf and are not reflected in this statement.
An additional statement covering such disbursements will be furnished to you.
The abbreviation (PA), (LC), (LSS), (DC) or (0) fallowing an individual's name denotes paralegal, law clerk,
litigation support specialist, document clerk, or other paraprofessional.
36 of 39 January 15, 2019, Item #I
TAXPAYERS ACCOUNT
RUTAN & TUCKER, LLP
NO 95-3519027
ATTORNEYS AT LAW
A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS
611 ANTON BOULEVARD SUITE 1400
POST OFFICE BOX 1950
COSTA MESA, CALIFORNIA 92628-1950
(714)641-5100
Poway, City of
Invoice No.
813247
Attn: Wendy Kaserman
Account No.
012782-0016
Assistant City Manager
Billing Atty.
John Ramirez
13325 Civic Center Drive
Date
July 16, 2018
Poway, CA 92064
Page
1
RE: Poway v. Beverly Thomas
FOR PROFESSIONAL SERVICES RENDERED THROUGH JUNE 30, 2018
06/07/18 Noam I. Duzman
06/11/18
06/12/18
06/13/18
06/18/18
06/19/18
06/21/18
06/22/18
06/27/18
37 of 39
Noam I. Duzman
Noam I. Duzman
Noam I. Duzman
Noam I. Duzman
Noam I. Duzman
Noam I. Duzman
Noam I. Duzman
0.30
elm
1.40
0.10
0.40
0.20
2.50
0.50
Noam I. Duzman 0.20
Additional disbursements may have been paid or incurred on your behalf and are not reflected in this statement.
An additional statement covering such disbursements will be furnished to you.
The abbreviation (PA), (LC), (LSS), (DC) or (0) following an individual's name denotes paralegal, law clerk,
litigation support specialist, document clerk, or other paraprofessignnal. 15, 2019, Item #..3,'
Poway, City of
Poway v. Beverly Thomas
012782-0016
RUTAN & TUCKER, LLP
ATTORNEYS AT l -AW
July 16, 2018
Invoice No. 813247
Page No. 2
Total Hours 6.00
Total Professional Services $1,350.00
DISBURSEMENTS AND COSTS ADVANCED
Duplication 20.52
Express Mail 25.01
Total Disbursements $45.53
Total Current Fees and Costs $1,395.53
Previous Balance Due 675.00
Payments and Adjustments (675.00)
Prior Balance Due $0.00
Total Balance Due $1,395.53
ACCOUNTS RECEIVABLE
0 - 30 DAYS 31- 60 DAYS 61 - 90 DAYS 91 -180 DAYS OVER 180
$1,395.53 $0.00 $0.00 $0.00 $0.00
Additional disbursements may have been paid or incurred on your behalf and are not reflected in this statement.
An additional statement covering such disbursements will be furnished to you.
The abbreviation (PA), (LC), (LSS), (DC) or (0) following an individual's name denotes paralegal, law clerk,
litigation support specialist, document clerk, or other paraprofessional.
38 of 39 January 15, 2019, Item # 3.1
TAXPAYERS ACCOUNT
NO 95-3519027
Poway, City of
Attn: Wendy Kaserman
Assistant City Manager
13325 Civic Center Drive
Poway, CA 92064
RE: Poway v. Beverly Thomas
RUTAN & TUCKER, LLP
ATTORNEYS AT LAW
A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS
611 ANTON BOULEVARD SUITE 1400
POST OFFICE BOX 1950
COSTA MESA, CALIFORNIA 92628-1950
(714)641-5100
Invoice No.
Account No.
Billing Atty.
Date
Page
816774
012782-0016
John Ramirez
August 24, 2018
1
FOR PROFESSIONAL SERVICES RENDERED THROUGH JULY 31, 2018
07/02/18 Noam I. Duzman
07/03/18 Noam I. Duzman
07/11/18 Noam I. Duzman
DISBURSEMENTS AND COSTS ADVANCED
Express Mail
Total Current Fees and Costs
Previous Balance Due
Payments and Adjustments
Prior Balance Due
0.20
0.10
Total Hours 0.90
Total Professional Services $202.50
21.34
Total Disbursements $21.34
1,395.53
(1,395.53)
$223.84
$0.00
Total Balance Due $223.84
Additional disbursements may have been paid or incurred on your behalf and are not reflected in this statement.
An additional statement covering such disbursements will be furnished to you.
The abbreviation (PA), (LC), (LES), (DC) or (0) fallowing an individual's name denotes paralegal, law clerk,
39 of 39 litigation support specialist, document clerk, or other paraprofessignalluary 15, 2019, Item # 3. i