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ELECTRONICALLY FILED
#
Vkoqvj{
Timothy L/J. Jcppcp-
Hannan, Gus/
Esq. )UDP
(SBN 79;88*
68977) Superior Court of California
County of Sonoma
$ 687
576 D
B Uvtggv-
Street, Uwkvg
Suite 3.C
2-A 1/22/2024 2:58 PM
Ucpvc
Santa Tquc-
Rosa, EC ;6512
CA 95401 By: Janie Dorman, Deputy Clerk
% Vgngrjqpg<
Telephone: )818*
(707) 689.1;14
578-0903
Hceukokng< )818*
Facsimile: (707) 689.1718
578-0607
&
Gockn<
Email: vkoBvkojcppcpncy/eqo
tim@timhannanlaw.com
'
Cvvqtpg{ for
Attorney hqt Fghgpfcpvu
Defendants
(
)
KP THE
IN VJG SUPERIOR
UWRGTKQT COURT
EQWTV QH
OF VJG
THE UVCVG
STATE QH
OF ECNKHQTPKC
CALIFORNIA
*
EQWPV[ QH
COUNTY OF UQPQOC
SONOMA
+
#" EQWPV[ OF
COUNTY QH SONOMA,
UQPQOC- Ecug No.
Case Pq/ 23CV02161
34EX13272
## Rnckpvkhh-
Plaintiff, FGENCTCVKQP OF
DECLARATION QH DAVID
FCXKF UEQVV
SCOTT
#$ JCPUGP IN
HANSEN KP OPPOSITION
QRRQUKVKQP VQ
TO EQWPV[
COUNTY QH
OF
x/
v. SONOMA'S
-*)*("0- EX
$/ PARTE
+",.$ APPLICATION FOR
"++'&#".&*) %*,
#% A
C TEMPORARY RESTRAINING QTFGT
VGORQTCT[ TGUVTCKPKPI ORDER
AND
CPF ORDER
QTFGT TO SHOW ECWUG
VQ UJQY CAUSE HQT
FOR C
A
#&
FCXKF SCOTT
DAVID UEQVV HANSEN
JCPUGP CPF AND TGIKPC
REGINA RTGNKOKPCT[ KPLWPEVKQP
PRELIMINARY INJUNCTION
#' XKEVQTKC HANSEN
VICTORIA JCPUGP AS CU TRUSTEES
VTWUVGGU OF QH
VJG
THE JCPUGP
HANSEN HCOKN[
FAMILY VTWUV-
TRUST, FCVGF
DATED Fcvg< January
Date: Lcpwct{ 18,
29- 2024
3135
#( OCTEJ 16,
MARCH 27- 2011,
3122- AND
CPF THEVJG HANSEN
JCPUGP Vkog< 21<41 a.m.
Time: 10:30 c/o/
#) HCOKN[ VTWUV-
FAMILY TRUST, FCVGF OCTEJ 16,
DATED MARCH 3122-
27- 2011, Dept: 29
Fgrv< 18
cpf DOES
and FQGU 12 through
vjtqwij 20,
31- inclusive,
kpenwukxg- Jqpqtcdng Christopher
Honorable Ejtkuvqrjgt O/
M. Jqpkiudgti
Honigsberg
#*
Fghgpfcpvu/
Defendants.
#+
$"
K-
I, FCXKF
DAVID UEQVV
SCOTT JCPUGP- fgenctg<
HANSEN, declare:
$#
$$
2/ KI jcxg
1. have rgtuqpcn
personal mpqyngfig qh vjg
knowledge of the hqnnqykpi hcevu- and
following facts, cpf if
kh ecnngf
called wrqp
upon KI eqwnf
could vguvkh{
testify vjgtgvq/
thereto.
$%
$&
3/ My
2. O{ ykhg
wife Tgikpc
Regina Xkevqtkc Jcpugp and
Victoria Hansen cpf IK ctg
are vtwuvggu
trustees qh
of vjg
the Jcpugp
Hansen Hcokn{
Family Vtwuv
Trust fcvgf
dated Octej
March
$'
27- 2011.
16, 3122/ Said
Uckf Trust
Vtwuv owns
qypu the
vjg residential
tgukfgpvkcn property
rtqrgtv{ at
cv 8404
9515 Brand
Dtcpf Lane,
Ncpg- Penngrove,
Rgppitqxg- Sonoma
Uqpqoc
$(
Eqwpv{- California.
County, Ecnkhqtpkc/
$)
$*
-1-
.2.
Eqwpv{
County qh
of Uqpqoc x/ David
Sonoma v. Fcxkf Ueqvv Jcpugp and
Scott Hansen cpf Regina
Tgikpc Hansen
Jcpugp as
cu Trustees,
Vtwuvggu- et
gv al.
cn/
)*(/'4'6-21 OF
DECLARATION 2+ DAVID
)'8-) 5(266
SCOTT ,'15*1
HANSEN -1
IN 23325-6-21
OPPOSITION 62
TO (2716;
COUNTY 2+
OF 52120'O5 *9 PARTE
SONOMA'S EX 3'46* APPLICATION
'33/-('6-21
HQT A
FOR C TEMPORARY
VGORQTCT[ RESTRAINING
TGUVTCKPKPI QTFGT CPF ORDER
ORDER AND QTFGT TO
VQ SHOW
UJQY CAUSE
ECWUG FOR
HQT A
C PRELIMINARY
RTGNKOKPCT[ INJUNCTION
KPLWPEVKQP
4/ We
3. Yg are
ctg in
kp the
vjg process
rtqeguu of
qh constructing
eqpuvtwevkpi ca water
ycvgt system
u{uvgo uwrrnkgf
supplied d{
by ca water
ycvgt well.
ygnn/ Once
Qpeg kv ku
it is
#
$ eqorngvgf- the
completed, vjg system
u{uvgo will
yknn supply
uwrrn{ potable
rqvcdng water
ycvgt to
vq our
qwt tgukfgpeg cpf provide
residence and rtqxkfg ac storage
uvqtcig of
qh raw
tcy ygnn
well
% ycvgt available
water cxckncdng to
vq local
nqecn firefighters.
hktghkijvgtu/
&
' 5/ We
4. Yg fkf
did qdvckp
obtain ac rgtokv hqt the
permit for vjg construction
eqpuvtwevkqp of
qh the
vjg water
ycvgt well.
ygnn/ At
Cv the
vjg time
vkog we
yg obtained
qdvckpgf that
vjcv
( rgtokv- we
permit, yg understood
wpfgtuvqqf our
qwt licensed
nkegpugf rtqhguukqpcn
professional ygnn
well ftknngt
driller vq uc{ that
to say vjcv the
vjg permit
rgtokv authorized
cwvjqtk|gf not
pqv
)
qpn{ the
only vjg drilling
ftknnkpi of
qh the
vjg well
ygnn itself
kvugnh but
dwv also
cnuq the
vjg installation
kpuvcnncvkqp of
qh water
ycvgt tanks,
vcpmu- electrical,
gngevtkecn- pipes,
rkrgu- two
vyq
*
ujgfu- ac back-up
sheds, dcem.wr generator
igpgtcvqt and
cpf other
qvjgt ycvgt.tgncvgf hceknkvkgu/
water-related facilities.
+
#"
6/ Yg later
5. We ncvgt learned
ngctpgf that
vjcv the
vjg authorization
cwvjqtk|cvkqp eqphgttgf
conferred d{
by vjg
the ycvgt ygnn permit
water well rgtokv was
ycu limited
nkokvgf to
vq
##
vjg drilling
the ftknnkpi of
qh the
vjg well.
ygnn/ The
Vjg other
qvjgt facilities
hceknkvkgu included
kpenwfgf in
kp our
qwt plan
rncp need
pggf separate
ugrctcvg permits.
rgtokvu/
#$
#%
7/ Wrqp learning
6. Upon ngctpkpi this,
vjku- we
yg made
ocfg application
crrnkecvkqp to
vq the
vjg County
Eqwpv{ Permit
Rgtokv Resource
Tguqwteg Management
Ocpcigogpv
#&
Fgrctvogpv (aka
Department )cmc Permit
Rgtokv Sonoma)
Uqpqoc* for
hqt the
vjg appropriate
crrtqrtkcvg permits.
rgtokvu/ Those
Vjqug applications
crrnkecvkqpu are
ctg pending.
rgpfkpi/
#'
#(
8/ 0? J@?
the
#)
#*
rtqrgtv{ and
property cpf issued
kuuwgf additional
cffkvkqpcn notices
pqvkegu and
cpf orders
qtfgtu averring
cxgttkpi xkqncvkqpu qh Uqpqoc
violations of Eqwpv{ Code.
Sonoma County Eqfg/
#+
9/ Yg ctg
8. We are hknkpi
filing ca vkogn{
timely crrgcn
appeal htqo
from vjqug
those cffkvkqpcn pqvkegu and
additional notices cpf order.
qtfgt/ A
C copy
eqr{ of
qh qwt
our crrgcn
appeal
$"
$#
ku attached
is cvvcejgf cu Gzjkdkv C/
as Exhibit Pqvcdng ku
A. Notable vjg fact,
is the hcev- as
cu stated
uvcvgf in
kp the
vjg appeal,
crrgcn- that
vjcv we
yg are
ctg agreeable
citggcdng to
vq
$$ crrn{kpi for
applying hqt the
vjg appropriate
crrtqrtkcvg rgtokvu-
permits, k/g/
i.e. dwknfkpi
building rgtokv
permit hqt
for vjg ogvcn clad
the metal encf lean-tos
ngcp.vqu and
cpf ac permit
rgtokv
$%
hqt vjg water
for the ycvgt system
u{uvgo apparatuses
crrctcvwugu (plumbing,
)rnwodkpi- gngevtkecn-
electrical, gve/*/
etc.). Qwt
Our kpkvkcn
initial cvvgorv
attempt vq hkng these
to file vjgug
$&
crrnkecvkqpu qpnkpg
applications online ycu
was vjyctvgf
thwarted d{
by vgejpkecn
technical fkhhkewnvkgu/
difficulties. Dwv
But yg
we ctg
are uvknn
still kp rtqeguu of
in process qh dutifully
fwvkhwnn{
$'
crrn{kpi hqt
applying vjg appropriate
for the crrtqrtkcvg rgtokvu/
permits. Kp
In qvjgt
other yqtfu-
words, yg
we ctg vt{kpi to
are trying vq cooperate
eqqrgtcvg with
ykvj the
vjg County
Eqwpv{
$(
$) RTOF/
PRMD.
$*
.3.
-2-
Eqwpv{
County qh
of Uqpqoc x/ David
Sonoma v. Fcxkf Ueqvv Jcpugp and
Scott Hansen cpf Regina
Tgikpc Hansen
Jcpugp as
cu Trustees,
Vtwuvggu- et
gv al.
cn/
)*(/'4'6-21 2+
DECLARATION )'8-) 5(266
OF DAVID SCOTT ,'15*1
HANSEN -1
IN 23325-6-21
OPPOSITION 62
TO (2716;
COUNTY 2+
OF 52120'O5 *9 PARTE
SONOMA'S EX 3'46* APPLICATION
'33/-('6-21
HQT A
FOR C TEMPORARY
VGORQTCT[ RESTRAINING
TGUVTCKPKPI QTFGT CPF ORDER
ORDER AND QTFGT TO
VQ SHOW
UJQY CAUSE
ECWUG FOR
HQT A
C PRELIMINARY
RTGNKOKPCT[ INJUNCTION
KPLWPEVKQP
9. As further evidence of our willingness to cooperate with PRMD, two weeks ago we paid
1
2 the County approximately $10,000 in administrative abatement costs and penalties.
3
a
10. I have read the County's Memorandum of Points and Authorities. On page 5, lines 9-10
5 the County asserts: ". . the County only needs to show it is reasonably probable to prevail on the
6 merits of the pending nuisance action . . .." We have not been served with a nuisance action. We
7
have not seen it. How can we prepare a response to the nuisance action if we have never seen it?
8
9
11. We need to continue constructing our water system. Specifically, we need treated potable
10
water to drink, cook, and bathe. We also need a volume of pressurized water to make our fire
11
sprinklers operable. Further, we need raw well water for irrigation of our landscaping and to fight
12
13 any wildfires or structural fires that may occur.
14
12. The danger of a destructive fire is real. In fact, in December, 2021, our neighbor's house
15
16 at 8401 Brand Lane (immediately across the lane from our property) burned to the ground because
17 the fire hydrant did not produce enough volume or pressure to extinguish the fire.
18
19 13. If the County is granted the injunctive relief it seeks, then for as long as the injunctive order
20 remains in force, we will be prevented from constructing the water system we need.
21
22 I declare under penalty of perjury that the foregoing is true and correct, and that this
23
declaration is made on January 1Q , 2024 at Santa Rosa, California.
24
25
26
27 DAVID SCOTT HA I SEN
28
-3-
County ofSonoma v. David Scott Hansen and Regina Hansen as Trustees, et al.
DECLARATION OF DAVID scurf HANSEN IN OPPOSITION TO COUNTY OF SONOMA'S EX PARTE APPLICATION
FOR A TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE FOR A PRELIMINARY INJUNCTION
EXHIBIT A
Dr. David Scott Hansen
8404 Brand Lane
Penngrove, CA 94951
January 17, 2024
Permit Sonoma
2550 Ventura Avenue
Santa Rosa, CA 95403
re: Appeal from Notices and Orders;
Hansen Residence 8404 Brand Lane, Penngrove
Dear Permit Sonoma:
On January 10, 2024 Code Enforcement Inspector Nathan Peacock visited our
property at 8404 Brand Lane, Penngrove. On that date Mr. Peacock issued a multitude of
Notices and Orders which are numbered and specified below. Pursuant to Sonoma County
Code section 1-7.3, we hereby appeal from each of those Notices and Orders on the
following grounds:
VCM22-0587 - - VPL24-007 Occupied Travel Trailer.
This charge reminds us of a similar incident which happened a year ago. The same
inspector, Nathan Peacock, issued Notices and Orders alleging an unpermitted basement
and a hazardous trench under the house. There never was basement. Nor was there a
hazardous trench under the house. There was no factual bases, no rational connection
between Mr. Peacock's charges and the realities on the ground. This latest accusation —
occupied travel trailer — is likewise without a factual basis, apparently a product of Mr.
Peacock's imagination. The truth is that we park our travel trailer on our property and use
it for occasional overnight trips to various destinations. Mr. Peacock could have simply
asked us if the trailer has an occupant. He did not. The unfairness and impropriety of Mr.
Peacock's accusation is shown in the question: How does one prove the non-existence of
an occupancy? How does one abate a situation that does not exist?
VCM22-0587 — VGR24-0002 Grading Without Permit.
Grading questionnaires attached for lean-to building permit and water system
permit online applications resulting in no requirement for grading permits under either
building permit or water system permit applications. The lean-to structure requires no
grading or a permit and the water system requires only a few feet of additional trenching
for a sump pump well to capture drain water for reuse, drains for various water systems,
plumbing or electrical access and also does not require a grading permit. Most all of
trenching on the property is related to a no-permit-required perimeter French drain trench
on North, South and East sides of the property, a no-permit-required main residence roof
drain trench from West and North sides of residence, then to the NE corner of the residence
to the North perimeter French drain trench, a no-permit-required rear heiau supply trench
Permit Sonoma
January 17, 2024
Page 2 of 3
extends from the NE corner of the residence to the East Perimeter French drain and a no-
permit-required replacement fire hydrant supply trench extends from #1 subterranean
foundation drain utility cell to the front utility area or a no-permit-required Brand Lane
storm drain trench. Adding together no-permit-required trenching and minimal new
permitted trenching together to exceed some limit is not an acceptable practice. However,
this is exactly the technique that was used with the 3 exploratory excavations which were
added together to show greater than 50 cu yds of soil excavated in the administrative
hearing. It was not valid or acceptable then and it is not valid or acceptable now.
VCM22-0587 — VBU24-0023 Dangerous Building — Hazardous Electrical throughout
property — Buckling supports in underground room.
The three Comstock observation/utility cells over the foundation drain are less than
120 sf each and no permit(s) are required for the passive or the actively augmented
foundation drain system including the Comstock observation utility cells and vestibule.
Owner has checked and no buckled column is present in Comstock cells 1 or 2 and
vestibule. No electricity is present in any subterranean cell except sump pumps and lighting
systems safely wired with commercial cords and connected with a commercial exterior
grade extension cord in turn connected to a GFCI protected exterior residential circuit.
There is no hazardous electrical situation at all in the subterranean structures much less
hazardous electrical throughout. All additional electrical and plumbing work being
protected in the cells from all hazards will be covered in Water System Permit Application.
VCM22-0587 — VBU24-0018 Construction without permit — Hazardous/Unpermitted
Electrical in Accessory Structure #1 .
Since the County has not defined what are accessory structures 1-3 we cannot
comment except that extensive plumbing and electrical will be covered in Water System
Permit Application. There are no hazardous electrical systems anywhere on the property.
Current structures underway are designed and built to protect the water system.
VCM22-0587 — VBU24-0019 — VBU -0021 Construction without permit.
Unpermitted Electrical and Plumbing to accessory structures #2 and #3 - Since the
County has not defined what are accessory structures 1-3 we cannot comment except that
extensive plumbing and electrical will be covered in Water System Permit Application.
VCM22-0587 — VBU24-0022 — Construction without permit - 2 accessory structures
within 50 feet of each other #2 and #3.
Since the County has not defined what are accessory structures 1-3 we cannot
comment except for the following. The above ground accessory structures for the water
system including the lean-to Permit (applied for), and well head shed (not needing a permit
(80 sf)) are steel clad on sides and roof. Well head shed also has a steel door and the window
Permit Sonoma
January 17, 2024
Page 3 of 3
is opposite any extensive fire vector. Separation distance of accessory structures was due,
in our understanding, to a fire safety requirement pertaining to flammable structures that
are not relevant to nonflammable steel-clad structures.
VCM22-0587 VBU-0015 Construction without permit -- Unpermitted water tank.
Water tanks are 2500 and 5000 gallons or less and no tank, operational or building
permit is required for these tanks per county code.
VCM22-0587-- VBU-0016 Construction without permit -- Unpermitted plumbing in
accessory structure #1.
Since we do not know what are accessory structures 1-3 we cannot comment except
that extensive plumbing and electrical will be covered in Water System Permit Application.
VCM22-0587-- VBU-0017 Construction without Permit. Unpermitted Subterranean
mechanical/electrical room with hazardous electrical.
No-permit-required for Subterranean Comstock cells smaller than 120 sf or
vestibule also smaller than 120 sf. Cell #1 will hold extremely critical and expensive 3
phase to single phase power conversion and distribution capabilities. They and all other
electrical and plumbing connections are completely protected from all hazards in a
subterranean Comstock Cell. See VBU24-0023
Sincerely,
44.
v steleA.
Dr. David Scott Hansen
Regina Victoria Hansen
Trustees of the Hansen Family
Trust dated March 16, 2011
Preview
ELECTRONICALLY FILED # Vkoqvj{ Timothy L/J. Jcppcp- Hannan, Gus/ Esq. )UDP (SBN 79;88* 68977) Superior Court of California County of Sonoma $ 687 576 D B Uvtggv- Street, Uwkvg Suite 3.C 2-A 1/22/2024 2:58 PM Ucpvc Santa Tquc- Rosa, EC ;6512 CA 95401 By: Janie Dorman, Deputy Clerk % Vgngrjqpg< Telephone: )818* (707) 689.1;14 578-0903 Hceukokng< )818* Facsimile: (707) 689.1718 578-0607 & Gockn< Email: vkoBvkojcppcpncy/eqo tim@timhannanlaw.com ' Cvvqtpg{ for Attorney hqt Fghgpfcpvu Defendants ( ) KP THE IN VJG SUPERIOR UWRGTKQT COURT EQWTV QH OF VJG THE UVCVG STATE QH OF ECNKHQTPKC CALIFORNIA * EQWPV[ QH COUNTY OF UQPQOC SONOMA + #" EQWPV[ OF COUNTY QH SONOMA, UQPQOC- Ecug No. Case Pq/ 23CV02161 34EX13272 ## Rnckpvkhh- Plaintiff, FGENCTCVKQP OF DECLARATION QH DAVID FCXKF UEQVV SCOTT #$ JCPUGP IN HANSEN KP OPPOSITION QRRQUKVKQP VQ TO EQWPV[ COUNTY QH OF x/ v. SONOMA'S -*)*("0- EX $/ PARTE +",.$ APPLICATION FOR "++'&#".&*) %*, #% A C TEMPORARY RESTRAINING QTFGT VGORQTCT[ TGUVTCKPKPI ORDER AND CPF ORDER QTFGT TO SHOW ECWUG VQ UJQY CAUSE HQT FOR C A #& FCXKF SCOTT DAVID UEQVV HANSEN JCPUGP CPF AND TGIKPC REGINA RTGNKOKPCT[ KPLWPEVKQP PRELIMINARY INJUNCTION #' XKEVQTKC HANSEN VICTORIA JCPUGP AS CU TRUSTEES VTWUVGGU OF QH VJG THE JCPUGP HANSEN HCOKN[ FAMILY VTWUV- TRUST, FCVGF DATED Fcvg< January Date: Lcpwct{ 18, 29- 2024 3135 #( OCTEJ 16, MARCH 27- 2011, 3122- AND CPF THEVJG HANSEN JCPUGP Vkog< 21<41 a.m. Time: 10:30 c/o/ #) HCOKN[ VTWUV- FAMILY TRUST, FCVGF OCTEJ 16, DATED MARCH 3122- 27- 2011, Dept: 29 Fgrv< 18 cpf DOES and FQGU 12 through vjtqwij 20, 31- inclusive, kpenwukxg- Jqpqtcdng Christopher Honorable Ejtkuvqrjgt O/ M. Jqpkiudgti Honigsberg #* Fghgpfcpvu/ Defendants. #+ $" K- I, FCXKF DAVID UEQVV SCOTT JCPUGP- fgenctg< HANSEN, declare: $# $$ 2/ KI jcxg 1. have rgtuqpcn personal mpqyngfig qh vjg knowledge of the hqnnqykpi hcevu- and following facts, cpf if kh ecnngf called wrqp upon KI eqwnf could vguvkh{ testify vjgtgvq/ thereto. $% $& 3/ My 2. O{ ykhg wife Tgikpc Regina Xkevqtkc Jcpugp and Victoria Hansen cpf IK ctg are vtwuvggu trustees qh of vjg the Jcpugp Hansen Hcokn{ Family Vtwuv Trust fcvgf dated Octej March $' 27- 2011. 16, 3122/ Said Uckf Trust Vtwuv owns qypu the vjg residential tgukfgpvkcn property rtqrgtv{ at cv 8404 9515 Brand Dtcpf Lane, Ncpg- Penngrove, Rgppitqxg- Sonoma Uqpqoc $( Eqwpv{- California. County, Ecnkhqtpkc/ $) $* -1- .2. Eqwpv{ County qh of Uqpqoc x/ David Sonoma v. Fcxkf Ueqvv Jcpugp and Scott Hansen cpf Regina Tgikpc Hansen Jcpugp as cu Trustees, Vtwuvggu- et gv al. cn/ )*(/'4'6-21 OF DECLARATION 2+ DAVID )'8-) 5(266 SCOTT ,'15*1 HANSEN -1 IN 23325-6-21 OPPOSITION 62 TO (2716; COUNTY 2+ OF 52120'O5 *9 PARTE SONOMA'S EX 3'46* APPLICATION '33/-('6-21 HQT A FOR C TEMPORARY VGORQTCT[ RESTRAINING TGUVTCKPKPI QTFGT CPF ORDER ORDER AND QTFGT TO VQ SHOW UJQY CAUSE ECWUG FOR HQT A C PRELIMINARY RTGNKOKPCT[ INJUNCTION KPLWPEVKQP 4/ We 3. Yg are ctg in kp the vjg process rtqeguu of qh constructing eqpuvtwevkpi ca water ycvgt system u{uvgo uwrrnkgf supplied d{ by ca water ycvgt well. ygnn/ Once Qpeg kv ku it is # $ eqorngvgf- the completed, vjg system u{uvgo will yknn supply uwrrn{ potable rqvcdng water ycvgt to vq our qwt tgukfgpeg cpf provide residence and rtqxkfg ac storage uvqtcig of qh raw tcy ygnn well % ycvgt available water cxckncdng to vq local nqecn firefighters. hktghkijvgtu/ & ' 5/ We 4. Yg fkf did qdvckp obtain ac rgtokv hqt the permit for vjg construction eqpuvtwevkqp of qh the vjg water ycvgt well. ygnn/ At Cv the vjg time vkog we yg obtained qdvckpgf that vjcv ( rgtokv- we permit, yg understood wpfgtuvqqf our qwt licensed nkegpugf rtqhguukqpcn professional ygnn well ftknngt driller vq uc{ that to say vjcv the vjg permit rgtokv authorized cwvjqtk|gf not pqv ) qpn{ the only vjg drilling ftknnkpi of qh the vjg well ygnn itself kvugnh but dwv also cnuq the vjg installation kpuvcnncvkqp of qh water ycvgt tanks, vcpmu- electrical, gngevtkecn- pipes, rkrgu- two vyq * ujgfu- ac back-up sheds, dcem.wr generator igpgtcvqt and cpf other qvjgt ycvgt.tgncvgf hceknkvkgu/ water-related facilities. + #" 6/ Yg later 5. We ncvgt learned ngctpgf that vjcv the vjg authorization cwvjqtk|cvkqp eqphgttgf conferred d{ by vjg the ycvgt ygnn permit water well rgtokv was ycu limited nkokvgf to vq ## vjg drilling the ftknnkpi of qh the vjg well. ygnn/ The Vjg other qvjgt facilities hceknkvkgu included kpenwfgf in kp our qwt plan rncp need pggf separate ugrctcvg permits. rgtokvu/ #$ #% 7/ Wrqp learning 6. Upon ngctpkpi this, vjku- we yg made ocfg application crrnkecvkqp to vq the vjg County Eqwpv{ Permit Rgtokv Resource Tguqwteg Management Ocpcigogpv #& Fgrctvogpv (aka Department )cmc Permit Rgtokv Sonoma) Uqpqoc* for hqt the vjg appropriate crrtqrtkcvg permits. rgtokvu/ Those Vjqug applications crrnkecvkqpu are ctg pending. rgpfkpi/ #' #( 8/ 0? J@? the #) #* rtqrgtv{ and property cpf issued kuuwgf additional cffkvkqpcn notices pqvkegu and cpf orders qtfgtu averring cxgttkpi xkqncvkqpu qh Uqpqoc violations of Eqwpv{ Code. Sonoma County Eqfg/ #+ 9/ Yg ctg 8. We are hknkpi filing ca vkogn{ timely crrgcn appeal htqo from vjqug those cffkvkqpcn pqvkegu and additional notices cpf order. qtfgt/ A C copy eqr{ of qh qwt our crrgcn appeal $" $# ku attached is cvvcejgf cu Gzjkdkv C/ as Exhibit Pqvcdng ku A. Notable vjg fact, is the hcev- as cu stated uvcvgf in kp the vjg appeal, crrgcn- that vjcv we yg are ctg agreeable citggcdng to vq $$ crrn{kpi for applying hqt the vjg appropriate crrtqrtkcvg rgtokvu- permits, k/g/ i.e. dwknfkpi building rgtokv permit hqt for vjg ogvcn clad the metal encf lean-tos ngcp.vqu and cpf ac permit rgtokv $% hqt vjg water for the ycvgt system u{uvgo apparatuses crrctcvwugu (plumbing, )rnwodkpi- gngevtkecn- electrical, gve/*/ etc.). Qwt Our kpkvkcn initial cvvgorv attempt vq hkng these to file vjgug $& crrnkecvkqpu qpnkpg applications online ycu was vjyctvgf thwarted d{ by vgejpkecn technical fkhhkewnvkgu/ difficulties. Dwv But yg we ctg are uvknn still kp rtqeguu of in process qh dutifully fwvkhwnn{ $' crrn{kpi hqt applying vjg appropriate for the crrtqrtkcvg rgtokvu/ permits. Kp In qvjgt other yqtfu- words, yg we ctg vt{kpi to are trying vq cooperate eqqrgtcvg with ykvj the vjg County Eqwpv{ $( $) RTOF/ PRMD. $* .3. -2- Eqwpv{ County qh of Uqpqoc x/ David Sonoma v. Fcxkf Ueqvv Jcpugp and Scott Hansen cpf Regina Tgikpc Hansen Jcpugp as cu Trustees, Vtwuvggu- et gv al. cn/ )*(/'4'6-21 2+ DECLARATION )'8-) 5(266 OF DAVID SCOTT ,'15*1 HANSEN -1 IN 23325-6-21 OPPOSITION 62 TO (2716; COUNTY 2+ OF 52120'O5 *9 PARTE SONOMA'S EX 3'46* APPLICATION '33/-('6-21 HQT A FOR C TEMPORARY VGORQTCT[ RESTRAINING TGUVTCKPKPI QTFGT CPF ORDER ORDER AND QTFGT TO VQ SHOW UJQY CAUSE ECWUG FOR HQT A C PRELIMINARY RTGNKOKPCT[ INJUNCTION KPLWPEVKQP 9. As further evidence of our willingness to cooperate with PRMD, two weeks ago we paid 1 2 the County approximately $10,000 in administrative abatement costs and penalties. 3 a 10. I have read the County's Memorandum of Points and Authorities. On page 5, lines 9-10 5 the County asserts: ". . the County only needs to show it is reasonably probable to prevail on the 6 merits of the pending nuisance action . . .." We have not been served with a nuisance action. We 7 have not seen it. How can we prepare a response to the nuisance action if we have never seen it? 8 9 11. We need to continue constructing our water system. Specifically, we need treated potable 10 water to drink, cook, and bathe. We also need a volume of pressurized water to make our fire 11 sprinklers operable. Further, we need raw well water for irrigation of our landscaping and to fight 12 13 any wildfires or structural fires that may occur. 14 12. The danger of a destructive fire is real. In fact, in December, 2021, our neighbor's house 15 16 at 8401 Brand Lane (immediately across the lane from our property) burned to the ground because 17 the fire hydrant did not produce enough volume or pressure to extinguish the fire. 18 19 13. If the County is granted the injunctive relief it seeks, then for as long as the injunctive order 20 remains in force, we will be prevented from constructing the water system we need. 21 22 I declare under penalty of perjury that the foregoing is true and correct, and that this 23 declaration is made on January 1Q , 2024 at Santa Rosa, California. 24 25 26 27 DAVID SCOTT HA I SEN 28 -3- County ofSonoma v. David Scott Hansen and Regina Hansen as Trustees, et al. DECLARATION OF DAVID scurf HANSEN IN OPPOSITION TO COUNTY OF SONOMA'S EX PARTE APPLICATION FOR A TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE FOR A PRELIMINARY INJUNCTION EXHIBIT A Dr. David Scott Hansen 8404 Brand Lane Penngrove, CA 94951 January 17, 2024 Permit Sonoma 2550 Ventura Avenue Santa Rosa, CA 95403 re: Appeal from Notices and Orders; Hansen Residence 8404 Brand Lane, Penngrove Dear Permit Sonoma: On January 10, 2024 Code Enforcement Inspector Nathan Peacock visited our property at 8404 Brand Lane, Penngrove. On that date Mr. Peacock issued a multitude of Notices and Orders which are numbered and specified below. Pursuant to Sonoma County Code section 1-7.3, we hereby appeal from each of those Notices and Orders on the following grounds: VCM22-0587 - - VPL24-007 Occupied Travel Trailer. This charge reminds us of a similar incident which happened a year ago. The same inspector, Nathan Peacock, issued Notices and Orders alleging an unpermitted basement and a hazardous trench under the house. There never was basement. Nor was there a hazardous trench under the house. There was no factual bases, no rational connection between Mr. Peacock's charges and the realities on the ground. This latest accusation — occupied travel trailer — is likewise without a factual basis, apparently a product of Mr. Peacock's imagination. The truth is that we park our travel trailer on our property and use it for occasional overnight trips to various destinations. Mr. Peacock could have simply asked us if the trailer has an occupant. He did not. The unfairness and impropriety of Mr. Peacock's accusation is shown in the question: How does one prove the non-existence of an occupancy? How does one abate a situation that does not exist? VCM22-0587 — VGR24-0002 Grading Without Permit. Grading questionnaires attached for lean-to building permit and water system permit online applications resulting in no requirement for grading permits under either building permit or water system permit applications. The lean-to structure requires no grading or a permit and the water system requires only a few feet of additional trenching for a sump pump well to capture drain water for reuse, drains for various water systems, plumbing or electrical access and also does not require a grading permit. Most all of trenching on the property is related to a no-permit-required perimeter French drain trench on North, South and East sides of the property, a no-permit-required main residence roof drain trench from West and North sides of residence, then to the NE corner of the residence to the North perimeter French drain trench, a no-permit-required rear heiau supply trench Permit Sonoma January 17, 2024 Page 2 of 3 extends from the NE corner of the residence to the East Perimeter French drain and a no- permit-required replacement fire hydrant supply trench extends from #1 subterranean foundation drain utility cell to the front utility area or a no-permit-required Brand Lane storm drain trench. Adding together no-permit-required trenching and minimal new permitted trenching together to exceed some limit is not an acceptable practice. However, this is exactly the technique that was used with the 3 exploratory excavations which were added together to show greater than 50 cu yds of soil excavated in the administrative hearing. It was not valid or acceptable then and it is not valid or acceptable now. VCM22-0587 — VBU24-0023 Dangerous Building — Hazardous Electrical throughout property — Buckling supports in underground room. The three Comstock observation/utility cells over the foundation drain are less than 120 sf each and no permit(s) are required for the passive or the actively augmented foundation drain system including the Comstock observation utility cells and vestibule. Owner has checked and no buckled column is present in Comstock cells 1 or 2 and vestibule. No electricity is present in any subterranean cell except sump pumps and lighting systems safely wired with commercial cords and connected with a commercial exterior grade extension cord in turn connected to a GFCI protected exterior residential circuit. There is no hazardous electrical situation at all in the subterranean structures much less hazardous electrical throughout. All additional electrical and plumbing work being protected in the cells from all hazards will be covered in Water System Permit Application. VCM22-0587 — VBU24-0018 Construction without permit — Hazardous/Unpermitted Electrical in Accessory Structure #1 . Since the County has not defined what are accessory structures 1-3 we cannot comment except that extensive plumbing and electrical will be covered in Water System Permit Application. There are no hazardous electrical systems anywhere on the property. Current structures underway are designed and built to protect the water system. VCM22-0587 — VBU24-0019 — VBU -0021 Construction without permit. Unpermitted Electrical and Plumbing to accessory structures #2 and #3 - Since the County has not defined what are accessory structures 1-3 we cannot comment except that extensive plumbing and electrical will be covered in Water System Permit Application. VCM22-0587 — VBU24-0022 — Construction without permit - 2 accessory structures within 50 feet of each other #2 and #3. Since the County has not defined what are accessory structures 1-3 we cannot comment except for the following. The above ground accessory structures for the water system including the lean-to Permit (applied for), and well head shed (not needing a permit (80 sf)) are steel clad on sides and roof. Well head shed also has a steel door and the window Permit Sonoma January 17, 2024 Page 3 of 3 is opposite any extensive fire vector. Separation distance of accessory structures was due, in our understanding, to a fire safety requirement pertaining to flammable structures that are not relevant to nonflammable steel-clad structures. VCM22-0587 VBU-0015 Construction without permit -- Unpermitted water tank. Water tanks are 2500 and 5000 gallons or less and no tank, operational or building permit is required for these tanks per county code. VCM22-0587-- VBU-0016 Construction without permit -- Unpermitted plumbing in accessory structure #1. Since we do not know what are accessory structures 1-3 we cannot comment except that extensive plumbing and electrical will be covered in Water System Permit Application. VCM22-0587-- VBU-0017 Construction without Permit. Unpermitted Subterranean mechanical/electrical room with hazardous electrical. No-permit-required for Subterranean Comstock cells smaller than 120 sf or vestibule also smaller than 120 sf. Cell #1 will hold extremely critical and expensive 3 phase to single phase power conversion and distribution capabilities. They and all other electrical and plumbing connections are completely protected from all hazards in a subterranean Comstock Cell. See VBU24-0023 Sincerely, 44. v steleA. Dr. David Scott Hansen Regina Victoria Hansen Trustees of the Hansen Family Trust dated March 16, 2011