AnswerCal. Super. - 3rd Dist.November 27, 2019S o O o N D 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 KRISTINE MOLLENKOPF, SBN 185914 Kristine.Mollenkopf@lincolnca.gov CITY ATTORNEY’S OFFICE, CITY OF LINCOLN 600 Sixth Street Lincoln, California 95648 Telephone: (916) 434-2400 TINA A. THOMAS, SBN 088796 tthomas@thomaslaw.com CHRISTOPHER J. BUTCHER, SBN 253285 cbutcher@thomaslaw.com THOMAS LAW GROUP 455 Capitol Mall, Suite 801 Sacramento, California 95814 Telephone: (916) 287-9292 Attorneys for Respondent, CITY OF LINCOLN; CITY COUNCIL OF THE CITY OF LINCOLN FILED Superior Court of California County of Placer MAR 24 2020 Jake Chatters tive Officer & Clerk y: O. Lucatuorto, Deputy Exempt from Filing Fees Pursuant to Government Code Section 6013 SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY OF PLACER STOP LINCOLN TWELVE BRIDGES HOTEL, an unincorporated association; Petitioner, Vv. CITY OF LINCOLN Respondents JG LAND & INVESTMENT, LLC., a Limited ) ) ) ) ) CITY OF LINCOLN; CITY COUNCIL OF THE) ) ) ) ) ) Liability Corporation. ) Real Party in Interest. CASE NO. SCV0044111 ANSWER TO VERIFIED PETITION FOR WRIT OF MANDATE [Pub. Resources Code § 21167.8(a)] Hearing Date: TBD Time: TBD ws Dept.: TBD ary Filing Date of Action: November 27, 2019 ANSWER TO VERIFIED PETITION FOR WRIT OF MANDATE S o O o nN DN 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Respondent CITY OF LINCOLN (City) hereby answers the Verified Petition for Writ of Mandate (Petition) filed by Petitioner STOP LINCOLN TWELVE BRIDGES HOTEL (Petitioner) in the above-captioned proceeding. For consistency and ease of reference, certain headings in the Petition are repeated in this answer but should not be construed as an admission or adoption of any part of the Petition. 1. Answering Paragraph 1 of the Petition, the City asserts that the above-captioned proceeding concerns the City’s October 22, 2019 decisions related to the approval of the La Quinta Inns & Suites (Project). Further answering Paragraph 1, the City asserts that the Project approvals, including approval of a Conditional Use Permit and Specific Development Plan and Development Permit, speak for themselves. Further answering Paragraph 1, the City asserts that it complied fully with the California Environmental Quality Act, Public Resources Code section 21000 et seg. (CEQA), City of Lincoln Municipal Code section 18.56.010, and Government Code section 65300 et seq., in approving the Project. The City further contends that Paragraph | contains argument, speculation, and conclusions of law, to which no response is required, and to the extent that a further answer is required, the City denies each and every remaining allegation in Paragraph 1. PARTIES 2. Answering Paragraph 2 of the Petition, the City lacks information and belief sufficient to enable it to admit or deny the allegations relating to the identity, intentions, or activities of the Petitioner and, on that basis, denies each and every allegation in Paragraph 2. 3. Answering Paragraph 3 of the Petition, the City admits that it is a municipal corporation, organized and existing under the laws of the State of California and located within the County of Placer. Further answering Paragraph 3, the City admits that the Project will be located within its jurisdiction. Further answering Paragraph 3, the City admits it is the lead agency for the Project. Further answering Paragraph 3, the City asserts that CEQA speaks for itself, and, therefore, no further response is required. Except as expressly admitted, the City denies each and every remaining allegation in Paragraph 3. 4. Answering Paragraph 4 of the Petition, the City admits that the City Council is a legislative body of the City of Lincoln and the governing body of the City. Further answering 2 ANSWER TO VERIFIED PETITION FOR WRIT OF MANDATE C o O o N D 10 11 12 13 14 15 16 l7 18 19 20 21 22 23 24 25 26 27 28 Paragraph 4, except as expressly admitted, the City asserts Paragraph 4 contains argument, speculation, and conclusions of law, to which no response is required, and to the extent that a further answer is required, the City denies each and every remaining allegation in Paragraph 4. 3. Answering Paragraph 5 of the Petition, the City admits that Real Party in Interest, JG Land & Investment, LLC., is the Project applicant and a limited liability corporation. Further answering Paragraph 5, the City admits that on October 25, 2019 it issued a Notice of Exemption (NOE) for the Project. Further answering Paragraph 5, the NOE speaks for itself, and, therefore, Paragraph 5 requires no further response. Except as expressly admitted, the City denies each and every remaining allegation in Paragraph 5. 6. Answering Paragraph 6 of the Petition, the City lacks information and belief sufficient to enable it to admit or deny allegations relating to the identity, intentions, or activities of the fictitiously named Respondents and Real Parties in Interest Does 1 through 20 and 21 through 40 and, on that basis, denies each and every allegation in Paragraph 6. JURISDICTION AND VENUE 7. Answering Paragraph 7 of the Petition, the City admits that this Court has jurisdiction over the above-captioned proceeding. Further answering Paragraph 7, the City asserts that Code of Civil Procedure sections 1085 and 1094.5, and Public Resources Code sections 21168 and 21168.5 speak for themselves, and, therefore, Paragraph 7 requires no further response. Except as expressly admitted, the City denies each and every remaining allegation in Paragraph 7. 8. Answering Paragraph 8 of the Petition, the City admits that this Court is the proper venue for the above-captioned proceeding. Further answering Paragraph 8, the City asserts that Code of Civil Procedure sections 393, 394, and 395 speak for themselves, and, therefore, Paragraph 8 requires no further response. Except as expressly admitted, the City denies each and every remaining allegation in Paragraph 8. BACKGROUND FACTS A. THE PROJECT AND PROJECT SITE 9. Answering Paragraph 9 of the Petition, the City asserts that the Project description as set 3 ANSWER TO VERIFIED PETITION FOR WRIT OF MANDATE 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 forth in the City’s resolution approving the Project (Resolution No. 2019-242) speaks for itself. To the extent that a further answer is required, the City denies each and every remaining allegation in Paragraph 9. 10... Answering Paragraph 10 of the Petition, the City asserts that the Project description as set forth in the City’s resolution approving the Project (Resolution No. 2019-242) and staff reports, which will be included in the administrative record certified for the above-captioned action, speak for themselves. The City further contends that Paragraph 10 contains argument, speculation, and conclusions of law, to which no response is required, and to the extent that a further answer is required, the City denies each and every remaining allegation in Paragraph 10. B. APPROVAL OF THE PROJECT 11. | Answering Paragraph 11 of the Petition, the City admits the Planning Commission voted to approve Resolution No. 2019-40 approving a Conditional Use Permit and Resolution No. 2019-39 approving the Specific Development Plan and Development Permit for the operation of La Quinta Inns & Suites and determined the Project is exempt from CEQA pursuant to CEQA Guidelines section 15183. Further answering Paragraph 11, the City asserts that the Project approval documents speak for themselves, and, therefore, no further response is required. To the extent that a further answer is required, the City denies each and every remaining allegation in Paragraph 11. 12. Answering Paragraph 12 of the Petition, the City asserts that Petitioner’s appeal of the Planning Commission’s determination to the City Council will be contained in the administrative record and speaks for itself, and, therefore, no further response is required. The City further contends that Paragraph 12 contains argument, speculation, and conclusions of law, to which no response is required, and to the extent that a further answer is required, the City denies each and every remaining allegation in Paragraph 12. 13. Answering Paragraph 13 of the Petition, the City admits that on October 22, 2019 the City Council adopted Resolution No. 2019-242 denying Petitioner’s appeal and upholding the Planning Commission’s Resolution No. 2019-39 and Resolution No. 2019-40, as well as the Planning Commission’s determination that the Project is exempt from environmental review under CEQA 4 ANSWER TO VERIFIED PETITION FOR WRIT OF MANDATE C o O o N D 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Guidelines section 15183. To the extent that a further answer is required, the City denies each and every remaining allegation in Paragraph 13. 14. Answering Paragraph 14 of the Petition, the City admits it filed an NOE with the County Clerk of Placer County on October 25, 2019. EXHAUSTION OF ADMINISTRATIVE REMEDIES AND INADEQUACY OF REMEDY 15. | Answering Paragraph 15 of the Petition, the administrative proceedings will be contained within the administrative record and speak for themselves, and, therefore, Paragraph 15 requires no further response. Further answering Paragraph 15, the City contends that the allegations in Paragraph 15 contain conclusions of law to which no response is required, and to the extent that a further answer is required, the City denies each and every allegation in Paragraph 15. 16. | Answering Paragraph 16 of the Petition, Exhibit A to the Petition speaks for itself, and, therefore, no further response is required. Further answering Paragraph 16, the City contends that the allegations in Paragraph 16 contain conclusions of law to which no response is required, and to the extent that a further answer is required, the City denies each and every allegation in Paragraph 16. 17. Answering Paragraph 17 of the Petition, the City admits Petitioner elected to prepare the administrative record in the above-captioned matter. Further answering Paragraph 17, the City contends that Public Resources Code section 21167.6 speaks for itself. Further answering Paragraph 17, the City admits that the parties entered a stipulation on February 4, 2020, which provided that Petitioner would complete the administrative record consistent with the requirements of the California Rules of Court in time to allow the City to certify and lodge the administrative record by March 5, 2020. To the extent that a further answer is required, except as expressly admitted, the City denies each and every remaining allegation in Paragraph 17. 18. | Answering Paragraph 18 of the Petition, the City contends that the allegations in Paragraph 18 contain argument, speculation, and conclusions of law, to which no response is required, and to the extent a further answer is required, the City denies each and every allegation in Paragraph 18. 19. | Answering Paragraph 19 of the Petition, the City admits that this action was filed with 5 ANSWER TO VERIFIED PETITION FOR WRIT OF MANDATE S o O o N Y D 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 this Court on November 27, 2019, which is less than 35 calendar days from October 25, 2019. Further answering Paragraph 19, the City asserts Paragraph 19 contains argument, speculation, and conclusions of law to which no response is required, and to the extent that a further answer is required, the City denies each and every allegation in Paragraph 19. STANDING 20. | Answering Paragraph 20 of the Petition, the City lacks information and belief sufficient to enable it to admit or deny the allegations relating to the identity, intentions, or activities of the Petitioner and, on that basis, denies each and every allegation in Paragraph 20. Further answering Paragraph 20, the City contends that the allegations in Paragraph 20 contain argument, speculation, and conclusions of law, to which no response is required, and to the extent that a further answer is required, the City denies each and every allegation in Paragraph 20. ARBITRARY AND CAPRICIOUS ACTIONS 21. Answering Paragraph 21 of the Petition, the City contends that the allegations in Paragraph 21 contain argument, speculation, and conclusions of law, to which no response is required, and to the extent a further answer is required, the City denies each and every allegation in Paragraph 21. CAUSES OF ACTION FIRST CAUSE OF ACTION (Abuse of Discretion Violation of CEQA, Public Resources Code, § 21000 et seq.) 22. Answering Paragraph 22 of the Petition, the City incorporates by reference its responses to each and every paragraph set forth above. 23. | Answering Paragraph 23 of the Petition, the City asserts that it fully complied with CEQA in approving the Project. Further answering Paragraph 23, the City contends that Paragraph 23 contains argument, speculation, and conclusions of law, to which no response is required, and to the extent that a further answer is required, the City denies each and every remaining allegation in Paragraph 23. 24. Answering Paragraph 24 of the Petition, the City admits it determined the Project was exempt under CEQA Guidelines section 15183. Further answering Paragraph 24, the City asserts that 6 ANSWER TO VERIFIED PETITION FOR WRIT OF MANDATE 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CEQA Guidelines section 15183 speaks for itself. Further answering Paragraph 24, the City contends that Paragraph 24 contains argument, speculation, and conclusions of law, to which no response is required, and to the extent that a further answer is required, the City denies each and every remaining allegation in Paragraph 24. 25. | Answering Paragraph 25, the City asserts Public Resources Code section 21083.3 and CEQA Guidelines section 15183 speak for themselves. Further answering Paragraph 25, the City contends that Paragraph 25 contains argument, speculation, and conclusions of law, to which no response is required, and to the extent that a further answer is required, the City denies each and every remaining allegation in Paragraph 25. 26. Answering Paragraph 26 of the Petition, the City asserts that the Planning Commission’s Resolution will be included in the administrative record and speaks for itself, and, therefore, no further response is required. Further answering Paragraph 26, the City the contends that Paragraph 26 contains argument, speculation, and conclusions of law, to which no response is required, and to the extent that a further response is required, the City denies each and every allegation in Paragraph 26. 27. | Answering Paragraph 27 of the Petition, the City the contends that the allegations in Paragraph 27 contain argument, speculation, and conclusions of law, to which no response is required, and to the extent further response is required, the City denies each and every allegation in Paragraph 27. 28. | Answering Paragraph 28 of the Petition, the City asserts that CEQA Guidelines section 15183 speaks for itself. Further answering Paragraph 28, the City contends that Paragraph 28 contains argument, speculation, and conclusions of law, to which no response is required, and to the extent that a further answer is required, the City denies each and every remaining allegation in Paragraph 28. 29. | Answering Paragraph 29 of the Petition, the City asserts that Public Resources Code section 21083.3 and CEQA Guidelines section 15183 speak for themselves. Further answering Paragraph 29, the City asserts that the City’s General Plan will be included in the administrative record and speaks for itself, and, therefore, no further response is required. The City further contends that Paragraph 29 contains argument, speculation, and conclusions of law, to which no response is required, and to the extent that a further answer is required, the City denies each and every remaining allegation in Paragraph 29. 7 ANSWER TO VERIFIED PETITION FOR WRIT OF MANDATE C o O o N D 10 11 12 13 14 15 16 17 18 19 20 21 29 23 24 25 26 27 28 30. | Answering Paragraph 30 of the Petition, the City asserts that CEQA Guidelines section 15183 speaks for itself. Further answering Paragraph 30, the City contends that Paragraph 30 contains argument, speculation, and conclusions of law, to which no response is required, and to the extent that a further answer is required, the City denies each and every remaining allegation in Paragraph 30. SECOND CAUSE OF ACTION (Violation of City of Lincoln Municipal Code § 18.56.010; Code of Civil Procedure § 1094.5) 31. | Answering Paragraph 31 of the Petition, the City incorporates by reference its responses to each and every paragraph set forth above. 32. | Answering Paragraph 32 of the Petition, the City asserts that the City’s Municipal Code speaks for itself. Further answering Paragraph 32, the City asserts that it complied fully with its Municipal Code in granting the Conditional Use Permit. 33. | Answering Paragraph 33 of the Petition, the City asserts that it complied fully with its Municipal Code in granting the Conditional Use Permit. The City further contends that the allegations in Paragraph 33 contain argument, speculation, and conclusions of law, to which no response is required, and to the extent a further answer is required, the City denies each and every allegation in Paragraph 33. 34. | Answering Paragraph 34 of the Petition, the City asserts that it complied fully with its Municipal Code in granting the Conditional Use Permit. The City further contends that the allegations in Paragraph 34 contain argument, speculation, and conclusions of law, to which no response is required, and to the extent a further answer is required, the City denies each and every allegation in Paragraph 34. 35. | Answering Paragraph 35 of the Petition, the City asserts that it complied fully with its Municipal Code in granting the Conditional Use Permit. The City further contends that the allegations in Paragraph 35 contain argument, speculation, and conclusions of law, to which no response is required, and to the extent a further answer is required, the City denies each and every allegation in Paragraph 35. 36. | Answering Paragraph 36 of the Petition, the City asserts that it complied fully with its Municipal Code in granting the Conditional Use Permit. The City further contends that the allegations 8 ANSWER TO VERIFIED PETITION FOR WRIT OF MANDATE C o eo N D 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 in Paragraph 36 contain argument, speculation, and conclusions of law, to which no response is required, and to the extent a further answer is required, the City denies each and every allegation in Paragraph 36. 37. | Answering Paragraph 37 of the Petition, the City asserts that it complied fully with its Municipal Code in granting the Conditional Use Permit. The City further contends that the allegations in Paragraph 37 contain argument, speculation, and conclusions of law, to which no response is required, and to the extent a further answer is required, the City denies each and every allegation in Paragraph 37. THIRD CAUSE OF ACTION (Violation of City of General Plan Laws - Government Code §§ 65300 et seq.; Code of Civil Procedure § 1094.5) 38. | Answering Paragraph 38 of the Petition, the City incorporates by reference its responses to each and every paragraph set forth above. 39. | Answering Paragraph 39 of the Petition, the City asserts the State Planning and Zoning Law and associated case law speak for themselves. The City further contends that the allegations in Paragraph 39 contain argument, speculation, and conclusions of law, to which no response is required, and to the extent a further answer is required, the City denies each and every allegation in Paragraph 39. 40. | Answering Paragraph 40, the City asserts that the City complied fully with the State Planning and Zoning Law and that the Project is consistent with the General Plan. Further answering Paragraph 40, the City asserts Paragraph 40 contains argument, speculation, and conclusions of law, to which no response is required, and to the extent a further answer is required, the City denies each and every allegation in Paragraph 40. 41. | Answering Paragraph 41, the City asserts that the City complied fully with the State Planning and Zoning Law and that the Project is consistent with the General Plan. Further answering Paragraph 41, the City asserts Paragraph 41 contains argument, speculation, and conclusions of law, to which no response is required, and to the extent a further answer is required, the City denies each and every allegation in Paragraph 41. 42. Answering Paragraph 42, the City asserts that the City complied fully with the State 9 ANSWER TO VERIFIED PETITION FOR WRIT OF MANDATE C o C O N D 10 ll 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Planning and Zoning Law and that the Project is consistent with the General Plan. Further answering Paragraph 42, the City asserts Paragraph 42 contains argument, speculation, and conclusions of law, to which no response is required, and to the extent a further answer is required, the City denies each and every allegation in Paragraph 42. PETITIONER’S PRAYER FOR RELIEF l(a) Answering Paragraph 1(a) of Petitioner’s Prayer for Relief, the City denies that the Petitioner is entitled to any of the relief it requests, or to any relief whatsoever. 1(b) Answering Paragraph 1(b) of Petitioner’s Prayer for Relief, the City denies that the Petitioner is entitled to any of the relief it requests, or to any relief whatsoever. l(c) Answering Paragraph l(c) of Petitioner’s Prayer for Relief, the City denies that the Petitioner is entitled to any of the relief it requests, or to any relief whatsoever. l(c) Answering the second paragraph labeled Paragraph 1(c) of Petitioner’s Prayer for Relief, the City denies that the Petitioner is entitled to any of the relief it requests, or to any relief whatsoever. 2. Answering Paragraph 2 of Petitioner’s Prayer for Relief, the City denies that the Petitioner is entitled to any of the relief it requests, or to any relief whatsoever. 3. Answering Paragraph 3 of Petitioner’s Prayer for Relief, the City denies that the Petitioner is entitled to any of the relief it requests, or to any relief whatsoever. 4. Answering Paragraph 4 of Petitioner’s Prayer for Relief, the City denies that the Petitioner is entitled to any of the relief it requests, or to any relief whatsoever. 5. Answering Paragraph 5 of Petitioner’s Prayer for Relief, the City denies that the Petitioner is entitled to any of the relief it requests, or to any relief whatsoever. AFFIRMATIVE DEFENSES Without admitting it carries the burden of proof as to any of the causes of action, the City alleges the following separate and independent affirmative defenses: FIRST AFFIRMATIVE DEFENSE As a first, separate affirmative defense, the Petition and each alleged cause of action therein do not state facts sufficient to constitute a cause of action against the City. 10 ANSWER TO VERIFIED PETITION FOR WRIT OF MANDATE 10 11 12 13 14 15 16 17 18 19 20 21 ze 23 24 25 26 27 28 SECOND AFFIRMATIVE DEFENSE As a second, separate affirmative defense, Petitioner lacks standing and capacity to bring or maintain this action. THIRD AFFIRMATIVE DEFENSE As a third, separate affirmative defense, the City alleges that the Petition fails to allege facts sufficient to state a claim for which the Court may grant relief. FOURTH AFFIRMATIVE DEFENSE As a fourth, separate affirmative defense, the Petition and each alleged cause of action therein are barred because Petitioner failed to exhaust administrative remedies as required to maintain the causes of action. FIFTH AFFIRMATIVE DEFENSE As a fifth, separate affirmative defense, Petitioner’s claims set forth in the Petition and each and every alleged cause of action therein are barred by the doctrine of unclean hands. SIXTH AFFIRMATIVE DEFENSE As a sixth, separate affirmative defense, the Petition and each alleged cause of action therein are barred by the doctrine of laches. SEVENTH AFFIRMATIVE DEFENSE As a seventh, separate affirmative defense, Petitioner is estopped to assert the claims and matters set forth in the Petition and each alleged cause of action therein. EIGHTH AFFIRMATIVE DEFENSE As an eighth, separate affirmative defense, Petitioner waived the claims and matters set forth in the Petition and each alleged cause of action therein. NINTH AFFIRMATIVE DEFENSE As a ninth, separate affirmative defense, in all matters alleged in the Petition, the City proceeded in the manner required by law, acted on the basis of substantial evidence, took no arbitrary actions, and committed no prejudicial abuse of discretion. TENTH AFFIRMATIVE DEFENSE As a tenth, separate affirmative defense, the relief sought by Petitioner is not in the public 11 ANSWER TO VERIFIED PETITION FOR WRIT OF MANDATE o O w o N Y D 10 i 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 interest and would not confer a public benefit. ELEVENTH AFFIRMATIVE DEFENSE As an eleventh, separate affirmative defense, Petitioner improperly seeks to control the exercise of the City’s discretion and to compel the exercise of discretion in a particular manner. TWELFTH AFFIRMATIVE DEFENSE As a twelfth, separate affirmative defense, Petitioner has no clear, present, and beneficial right to the relief it seeks. THIRTEENTH AFFIRMATIVE DEFENSE As a thirteenth, separate affirmative defense, Petitioner is not entitled to any relief, insofar as the City complied with all applicable laws in approving the Project, and to the extent any error was made, such error was not prejudicial. FOURTEENTH AFFIRMATIVE DEFENSE As a fourteenth, separate affirmative defense, Petitioner’s claims are not ripe for adjudication. FIFTEENTH AFFIRMATIVE DEFENSE As a fifteenth, separate affirmative defense, Petitioner’s claims, set forth in the Petition and each and every alleged cause of action therein, are barred by the applicable statute of limitations. The City may have other separate, additional defenses of which it is not presently aware and hereby reserves the right to raise such defenses by amendment of this Answer. PRAYER WHEREFORE, the City prays for the following relief: 1. Deny Petitioner’s request for relief in all respects and hold that Petitioner takes nothing by this action; Qs Enter judgment in favor of the City and dismiss the Petition and each cause of action therein; 3. Award the City costs of suit, including reasonable attorneys’ fees, to the extent authorized by law; 4. Grant the City such other relief as the Court deems just and proper. /// 12 ANSWER TO VERIFIED PETITION FOR WRIT OF MANDATE o n N Y DW \o 10 11 12 13 14 15 16 17 18 19 20 21 2 23 24 25 26 27 28 DATED: March 24, 2020 Lit- L CHRISTOPHER J. BUTCHER THOMAS LAW GROUP Attorneys for Respondents CITY OF LINCOLN; CITY COUNCIL OF THE CITY OF LINCOLN 13 ANSWER TO VERIFIED PETITION FOR WRIT OF MANDATE a o n N D D 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Stop the Twelve Bridges Hotel v. City of Lincoln Placer County Superior Court Case No. SCV0044111 PROOF OF SERVICE I] am a resident of the United States, employed in the City and County of Sacramento. My business address is 455 Capitol Mall, Suite 801, Sacramento, California 95814. I am over the age of 18 years and not a party to the above-entitled action. On March 24, 2020, I served the following: ANSWER TO VERIFIED PETITION FOR WRIT OF MANDATE o On the parties in this action by causing a true copy thereof to be placed in a sealed envelope with postage thereon fully prepaid in the designated area for outgoing mail addressed as follows; or oO On the parties in this action by causing a true copy thereof to be delivered via Federal Express to the following person(s) or their representative at the address(es) listed below; or oO On the parties in this action by causing a true copy thereof to be delivered by facsimile machine number (916) 737-5858 to the following person(s) or their representative at the address(es) and facsimile number(s) listed below; or o On the parties in this action by causing a true copy thereof to be hand-delivered to the following person(s) or representative at the address(es) listed below; or X On the parties in this action by causing a true copy thereof to be electronically delivered via the internet to the following person(s) or representative at the address(es) listed below: SEE ATTACHED SERVICE LIST I declare under penalty of perjury that the foregoing is true and correct and that this Proof of Service was executed this 24th day of March 2020, at Sacramento, California. pornos Stephanie Richburg PROOF OF SERVICE n N aD 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Stop the Twelve Bridges Hotel v. City of Lincoln Placer County Superior Court Case No. SCV0044111 SERVICE LIST Donald B. Mooney Attorney for Petitioner: Stop Lincoln Twelve Law Office of Donald B. Mooney Bridges Hotel dbmooney@dcn.org 417 Mace Blvd, Ste. J-334 Davis, CA 95618 Ryan N. Meyer Attorney for Real Party in Interest: JG Land Elguindy Meyer Koegel & Investment, LLC rmeyer@emklawyers.com 2990 Lava Ridge Court, ste. 205 Roseville, CA 95661 PROOF OF SERVICE
