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ORIGINAL
"
JOHN O. PINKNEY, Bar No. 162586 EXEMPT FROM FILING FEES PURSUANT
LENA D. WADE, Bar No. 258356 TO GOVERNMENT (:qu SECTION
m 6103
SLOVAK BARON EMPEY MURPHY & PINKNEY LLP
s- r.‘
SUPERIOR COURT 5'F U
CA e‘Fr
74785 Highway 111, Suite 105 COUNTY 0F SAN BERNXRdmg'A
SAN BERNARDINO
Indian Wells,CA 92210 DISTRICT
Telephone: (760) 322-9240
Facsimile: (760) 565-1 189
\OOOQOKUIhb-DNH
Email: wade@sbemp.com
Attorneys for Plaintiff CITY OF NEEDLES
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO — SAN BERNARDINO DIVISION
LLP
Pinkney
105
CITY OF NEEDLES, a Charter City, Case No.: CIVSle 1693Q
& Suite
Assigned for A11 Purposes to:
92210
Plaintiff; Hon. Lynn Poncin GH‘IH
Murphy 111,
CA
v.
Wells,
Highway
Empey
LORRAINE L. CUSSON, a Joint Tenant; DECLARATION OF SENIOR CODE
Baron
Indian
WILLIAM SCHMIDT, a Joint Tenant; ENFORCEMENT OFFICER ADRIAN A8
CHAVEZ RE EXECUTION OF
74-785
COUNTRYWIDE TITLE CORPORATION,
Slovak Beneficiary; and DOES through 10, 1 ABATEMENT WARRANT,
inclusive, ABATEMENT COSTS AND STAFF XV:J
TIME
MQONUIAMNchwQOxUl-Ath—tc
Defendants.
NNNNNNNNNHHHHHHHHHH
Warrant Issued June 22, 2021
Date: December 16, 2021
Time: 9:00 a.m.
Dept: 828
I, ADRIAN CHAVEZ, declare as follows:
1. I am now, and at all times mentioned in this Declaration, have been employed as the
Senior Code Enforcement Officer by the City of Needles. This Declaration is filed in support of the
City’s Return on Abatement Warrant and in support 0f the City’s Application for an award of staff
time charges and abatement costs, scheduled for hearing on December 16, 2021.
1
DECLARATION OF SENIOR CODE ENFORCEMENT OFFICER ADRIAN CHAVEZ RE
EXECUTION OF ABATEMENT WARRANT, ABATEMENT COSTS AND STAFF TIME
2. On June 22, 2021, this Court granted the City’s ex parte Application and issued an
Abatement Warrant permitting the City t0 abate public nuisances on the Property described in the
Warrant.
3. On September 13, 202 1 Iposted the Warrant on the Property.
,
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4. When I posted the Warrant, I observed the conditions on the Property that are
described in the Application.
5. On 0r about September 14, 2021, the City’s contractor, Phillips Construction, abated
the public nuisances on the Property. The contractor’s invoice for $7,800 t0 d0 the work is attached
as Exhibit “1”.
6. There are the following outstanding citations 0n this Property:
LLP
February 22, 2021 $ 1,500.00
Pinkncy
105
& Suite
92210 March 8, 2021 5,850.00
Murphy 111,
CA
March 22, 2020 14, 550.00
Wells,
Highway
Empey
Total $ 21,900.00
Indian
Baron
74-785
Copies 0f the printouts regarding the citations are attached as Exhibit “2”.
Slovak
7. The City incurred staff time charges in the amount 0f $1,408.88 and City costs in the
NNNNNNNNNr—IHHHHt—AHHHr—A
amount 0f $57.75 as further itemized in the spreadsheet attached hereto as Exhibit “3”.
8. In addition, the City incurred attorney’s fees in the amount 0f $2,970.80 and legal
wQGNMAWNchmQQm£wNH©
costs in the amount of $357.15 as described in the Wade Declaration filed concurrently with this
declaration.
9. The sum of the City’s costs and fees to abate the nuisances on the Property total
$34,494.58. An spreadsheet 0f all fees and costs is attached hereto as Exhibit “3”.
2
DECLARATION OF SENIOR CODE ENFORCEMENT OFFICER ADRIAN CHAVEZ RE
EXECUTION OF ABATEMENT WARRANT, ABATEMENT COSTS AND STAFF TIME
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ORIGINAL " JOHN O. PINKNEY, Bar No. 162586 EXEMPT FROM FILING FEES PURSUANT LENA D. WADE, Bar No. 258356 TO GOVERNMENT (:qu SECTION m 6103 SLOVAK BARON EMPEY MURPHY & PINKNEY LLP s- r.‘ SUPERIOR COURT 5'F U CA e‘Fr 74785 Highway 111, Suite 105 COUNTY 0F SAN BERNXRdmg'A SAN BERNARDINO Indian Wells,CA 92210 DISTRICT Telephone: (760) 322-9240 Facsimile: (760) 565-1 189 \OOOQOKUIhb-DNH Email: wade@sbemp.com Attorneys for Plaintiff CITY OF NEEDLES SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO — SAN BERNARDINO DIVISION LLP Pinkney 105 CITY OF NEEDLES, a Charter City, Case No.: CIVSle 1693Q & Suite Assigned for A11 Purposes to: 92210 Plaintiff; Hon. Lynn Poncin GH‘IH Murphy 111, CA v. Wells, Highway Empey LORRAINE L. CUSSON, a Joint Tenant; DECLARATION OF SENIOR CODE Baron Indian WILLIAM SCHMIDT, a Joint Tenant; ENFORCEMENT OFFICER ADRIAN A8 CHAVEZ RE EXECUTION OF 74-785 COUNTRYWIDE TITLE CORPORATION, Slovak Beneficiary; and DOES through 10, 1 ABATEMENT WARRANT, inclusive, ABATEMENT COSTS AND STAFF XV:J TIME MQONUIAMNchwQOxUl-Ath—tc Defendants. NNNNNNNNNHHHHHHHHHH Warrant Issued June 22, 2021 Date: December 16, 2021 Time: 9:00 a.m. Dept: 828 I, ADRIAN CHAVEZ, declare as follows: 1. I am now, and at all times mentioned in this Declaration, have been employed as the Senior Code Enforcement Officer by the City of Needles. This Declaration is filed in support of the City’s Return on Abatement Warrant and in support 0f the City’s Application for an award of staff time charges and abatement costs, scheduled for hearing on December 16, 2021. 1 DECLARATION OF SENIOR CODE ENFORCEMENT OFFICER ADRIAN CHAVEZ RE EXECUTION OF ABATEMENT WARRANT, ABATEMENT COSTS AND STAFF TIME 2. On June 22, 2021, this Court granted the City’s ex parte Application and issued an Abatement Warrant permitting the City t0 abate public nuisances on the Property described in the Warrant. 3. On September 13, 202 1 Iposted the Warrant on the Property. , ©wQQUI£bJNH 4. When I posted the Warrant, I observed the conditions on the Property that are described in the Application. 5. On 0r about September 14, 2021, the City’s contractor, Phillips Construction, abated the public nuisances on the Property. The contractor’s invoice for $7,800 t0 d0 the work is attached as Exhibit “1”. 6. There are the following outstanding citations 0n this Property: LLP February 22, 2021 $ 1,500.00 Pinkncy 105 & Suite 92210 March 8, 2021 5,850.00 Murphy 111, CA March 22, 2020 14, 550.00 Wells, Highway Empey Total $ 21,900.00 Indian Baron 74-785 Copies 0f the printouts regarding the citations are attached as Exhibit “2”. Slovak 7. The City incurred staff time charges in the amount 0f $1,408.88 and City costs in the NNNNNNNNNr—IHHHHt—AHHHr—A amount 0f $57.75 as further itemized in the spreadsheet attached hereto as Exhibit “3”. 8. In addition, the City incurred attorney’s fees in the amount 0f $2,970.80 and legal wQGNMAWNchmQQm£wNH© costs in the amount of $357.15 as described in the Wade Declaration filed concurrently with this declaration. 9. The sum of the City’s costs and fees to abate the nuisances on the Property total $34,494.58. An spreadsheet 0f all fees and costs is attached hereto as Exhibit “3”. 2 DECLARATION OF SENIOR CODE ENFORCEMENT OFFICER ADRIAN CHAVEZ RE EXECUTION OF ABATEMENT WARRANT, ABATEMENT COSTS AND STAFF TIME