Preview
ROBERT H. PITTMAN #172154
County Counsel
IVAN R. JIMENEZ #313644
Deputy County Counsel
County of Sonoma
575 Administration Drive, Room 105
Santa Rosa, California 95403-2815
Telephone: (707) 565-2421
Fax: (707) 565-2624
Ivan. Jimenez@sonoma-county.org
Attorneys for Plaintiff
COUNTY OF SONOMA
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SONOMA
10 Case No. 23CV02161
il COUNTY OF SONOMA,
DECLARATION OF IVAN R. JIMENEZ IN
12 Plaintiff, SUPPORT OF COUNTY OF SONOMA’S EX
PARTE APPLICATION FOR A
13 Vv.
TEMPORARY RESTRAINING ORDER AND
ORDER TO SHOW CAUSE FOR A
14 DAVID SCOTT HANSEN AND PRELIMINARY INJUNCTION
REGINA VICTORIA HANSEN AS
15 TRUSTEES OF THE HANSEN
FAMILY TRUST, DATED MARCH
16 16, 2011, AND THE HANSEN Date: January 18, 2024
FAMILY TRUST, DATED MARCH Time: 10:30 a.m.
17 16, 2011, and DOES 1 through 20,
Dept. 18
inclusive,
Honorable Christopher M. Honigsberg
18
Defendants.
19
20
I, IVAN R. JIMENEZ, hereby declare as follows:
21
1 lam a Deputy County Counsel for the County of Sonoma. I am licensed to practice
22
law in the California courts. I am one of the attorneys assigned to represent Respondents County
23
of Sonoma and the Sonoma County Permit and Resources Management Department (“Permit
24
Sonoma”) (collectively referred to as the “County”). I have personal knowledge of each fact stated|
25
in this declaration.
26
2. On November 3, 2022, an Administrative Hearing took place to consider
27
Defendants’ appeal of violations of the Sonoma County Code issued by Permit Sonoma for an
28
Declaration of Ivan R, Jimenez ISO County of Sonoma’s Ex Parte Application for a TRO
1
unpermitted fuel tank and unpermitted grading, on the property located at 8404 Brand Lane,
Penngrove, California, Assessor Parcel Number 047-202-044 (“the Property”).
3 On December 16, 2022, an Administrative Decision and Order was issued which
upheld the violations, ordered Defendants to obtain permits to abate the violations, ordered
Defendants to reimburse the County its abatement costs incurred in the administrative process, and
ordered Defendants to pay civil penalties.
4 Defendants did not seek judicial review of the Administrative Order within the time
set forth in Code of Civil Procedure section 1094.5 and 1094.6.
5 On January 17, 2024, I provided timely notice pursuant to Rule 3.1203 of the Rules
10 of Court to Defendants that the County would file the present Ex Parte Application with
i Department 18 of the Court no later than 10:30a.m. on January 18, 2024. I sent notice via email to
12 both Defendants and Timothy Hannan, the last known attorney for Defendants, after I was unable
13 to reach them via phone. The notice specified the County’ Ex Parte Application would: “request a
14 temporary restraining order immediately enjoining David Scott Hansen and Regina Victoria
15 Hansen, Trustees of the Hansen Family Trust Dated March 16, 2011, and the Hansen Family Trust
16 Dated March 16, 2011, and their employees, contractors, agents, representatives, successors, and
17 assigns from: (i) creating any violations of the Sonoma County Building, Grading, Septic, or
18 Zoning Codes or regulations on the real property known as 8404 Brand Lane, Penngrove,
19 California, Assessor Parcel Number 047-202-044 (“the Property”); (ii) expanding the current
20 violations that exist on the Property; and (iii) engaging in any unpermitted construction,
21 unpermitted grading, or unpermitted occupancy of travel trailers on the Property. The Ex Parte
22 Application will also request the Court set an Order to Show Cause hearing on why a preliminary
23 injunction should not issue and extend the TRO until the Court issues a judgment in the pending
24 public nuisance action filed by the County against David Scott Hansen and Regina Victoria
25 Hansen, Trustees of the Hansen Family Trust Dated March 16, 2011, and the Hansen Family Trust
26 Dated March 16, 2011.”
27 6 At approximately 12:09p.m. on January 17, 2024, Mr. Hannan contacted me via
28 phone and confirmed that he represents Defendants in this matter, that he received my email
Declaration of Ivan R. Jimenez ISO County of Sonoma’s Ex Parte Application for a TRO
2
1 || providing notice of the Ex Parte Application, and that Defendants intended to file an opposition to
2 || the County’s Ex Parte Application.
3
4
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct. Executed this 18"" of January, 2024, in Santa Rosa, California.
w —
TAME GeineZ
10
il
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Declaration of Ivan R. Jimenez ISO County of Sonoma’s Ex Parte Application for a TRO
3
Preview
ROBERT H. PITTMAN #172154 County Counsel IVAN R. JIMENEZ #313644 Deputy County Counsel County of Sonoma 575 Administration Drive, Room 105 Santa Rosa, California 95403-2815 Telephone: (707) 565-2421 Fax: (707) 565-2624 Ivan. Jimenez@sonoma-county.org Attorneys for Plaintiff COUNTY OF SONOMA SUPERIOR COURT OF CALIFORNIA COUNTY OF SONOMA 10 Case No. 23CV02161 il COUNTY OF SONOMA, DECLARATION OF IVAN R. JIMENEZ IN 12 Plaintiff, SUPPORT OF COUNTY OF SONOMA’S EX PARTE APPLICATION FOR A 13 Vv. TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE FOR A 14 DAVID SCOTT HANSEN AND PRELIMINARY INJUNCTION REGINA VICTORIA HANSEN AS 15 TRUSTEES OF THE HANSEN FAMILY TRUST, DATED MARCH 16 16, 2011, AND THE HANSEN Date: January 18, 2024 FAMILY TRUST, DATED MARCH Time: 10:30 a.m. 17 16, 2011, and DOES 1 through 20, Dept. 18 inclusive, Honorable Christopher M. Honigsberg 18 Defendants. 19 20 I, IVAN R. JIMENEZ, hereby declare as follows: 21 1 lam a Deputy County Counsel for the County of Sonoma. I am licensed to practice 22 law in the California courts. I am one of the attorneys assigned to represent Respondents County 23 of Sonoma and the Sonoma County Permit and Resources Management Department (“Permit 24 Sonoma”) (collectively referred to as the “County”). I have personal knowledge of each fact stated| 25 in this declaration. 26 2. On November 3, 2022, an Administrative Hearing took place to consider 27 Defendants’ appeal of violations of the Sonoma County Code issued by Permit Sonoma for an 28 Declaration of Ivan R, Jimenez ISO County of Sonoma’s Ex Parte Application for a TRO 1 unpermitted fuel tank and unpermitted grading, on the property located at 8404 Brand Lane, Penngrove, California, Assessor Parcel Number 047-202-044 (“the Property”). 3 On December 16, 2022, an Administrative Decision and Order was issued which upheld the violations, ordered Defendants to obtain permits to abate the violations, ordered Defendants to reimburse the County its abatement costs incurred in the administrative process, and ordered Defendants to pay civil penalties. 4 Defendants did not seek judicial review of the Administrative Order within the time set forth in Code of Civil Procedure section 1094.5 and 1094.6. 5 On January 17, 2024, I provided timely notice pursuant to Rule 3.1203 of the Rules 10 of Court to Defendants that the County would file the present Ex Parte Application with i Department 18 of the Court no later than 10:30a.m. on January 18, 2024. I sent notice via email to 12 both Defendants and Timothy Hannan, the last known attorney for Defendants, after I was unable 13 to reach them via phone. The notice specified the County’ Ex Parte Application would: “request a 14 temporary restraining order immediately enjoining David Scott Hansen and Regina Victoria 15 Hansen, Trustees of the Hansen Family Trust Dated March 16, 2011, and the Hansen Family Trust 16 Dated March 16, 2011, and their employees, contractors, agents, representatives, successors, and 17 assigns from: (i) creating any violations of the Sonoma County Building, Grading, Septic, or 18 Zoning Codes or regulations on the real property known as 8404 Brand Lane, Penngrove, 19 California, Assessor Parcel Number 047-202-044 (“the Property”); (ii) expanding the current 20 violations that exist on the Property; and (iii) engaging in any unpermitted construction, 21 unpermitted grading, or unpermitted occupancy of travel trailers on the Property. The Ex Parte 22 Application will also request the Court set an Order to Show Cause hearing on why a preliminary 23 injunction should not issue and extend the TRO until the Court issues a judgment in the pending 24 public nuisance action filed by the County against David Scott Hansen and Regina Victoria 25 Hansen, Trustees of the Hansen Family Trust Dated March 16, 2011, and the Hansen Family Trust 26 Dated March 16, 2011.” 27 6 At approximately 12:09p.m. on January 17, 2024, Mr. Hannan contacted me via 28 phone and confirmed that he represents Defendants in this matter, that he received my email Declaration of Ivan R. Jimenez ISO County of Sonoma’s Ex Parte Application for a TRO 2 1 || providing notice of the Ex Parte Application, and that Defendants intended to file an opposition to 2 || the County’s Ex Parte Application. 3 4 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 18"" of January, 2024, in Santa Rosa, California. w — TAME GeineZ 10 il 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Declaration of Ivan R. Jimenez ISO County of Sonoma’s Ex Parte Application for a TRO 3