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CHRISTOPHERJ. DIAZ, Bar No. 235249
christoy .diaz@bbklaw.com
DENISE HANSEN, Bar No. 156363 Electronically
denise. hansen@bbklaw.com.
r
ANDREW E. LOPEZ, Bar No. 337993
andrew. lopez@bbklaw.com. 3/21/2024
BEST BEST & KRIEGER LLP Bs y /s/ Priscilla Tovar
Deputy Clerk
2001 N. Main Street
Suite 390
Walnut Creek, Califomia 94596
Telephone: (925) 977-3300
Facsimile: (925) 977-1870
EXEMPT FROM FILING FEES PURSUANT
Attol for mdent TO GOVERNMENT CODE SECTION 6103
TOWN OF HILLSBOROUGH
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF SAN MATEO
11
12 MAHMOOD PANJWANL, Case No. 23-CIV-04568
Bs
£4
BE
gi 13 Petitioner,
oe NOTICE OF LODGING OF
mez 14 Vv. CERTIFIED AGENCY FILE
15 COUNTY OF SAN MATEO, SAN MATEO
COUNTY HEALTH, PUBLIC HEALTH
16 POLICY AND PLANNING; PENINSULA
HUMANE SOCIETY & SPCA.
17 (“PHS/SCPA”); TOWN OF
HILLSBOROUGH; PROGRAM MANAGER,
18 OF ANIMAL CONTROL AND LICENSING,
19 Respondent(s).
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61236,06000\42073182.1
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NOTICE OF LODGING OF CERTIFIED AGENCY FILE
NOTICE OF LODGING OF CERTIFIED AGENCY FILE
TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that, pursuant
to Govemment Code section 53069.4, in the matter
of Mahmood Panjwani vs. County of San Mateo, et al., in the Superior Court of the State of
Califomia, County of San Mateo, located at 400 County Center, Redwood City, Califomia 94063
(“Court”), in case number 23-CIV-04568, Respondent Town of Hillsborough (“Tor "), by and
through its attomeys
of record, has prepared and hereby lodges the Town’ s file with Department
23 of this Court, consisting of one bound volume consecutively paginated as Bate Numbers
HB000001 through HB000106, inclusive (“Agency File”). The Agency File has been lodged with
10 this Court concurrently with this Notice. The City reserves the right to augment the Agency File
11 with other documents
as necessary.
12 The Index to the Agency File is attached hereto as Exhibit A. The certification of this
13 Agency File, executed by the Town of Hillsborough Town Clerk Lisa Natusch, is attached hereto
Bg 14 as Exhibit
B.
15 This Notice and the certified Agency File has been served on Respondent via United States
16
17
18 Dated: March 21, 2024 BEST BEST & KRIEGER LLP
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21
*y KakE A Z
DENISE HANSEN
ANDREW E. LOPEZ
22 Attol for Respondent
TOWN OF HILLSBOROUGH
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NOTICE OF LODGING OF CERTIFIED AGENCY FILE
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12 EXHIBITA
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INDEX TO AGENCY FILE
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EXHIBIT A—INDEX TO AGENCY FILE
INDEX TO AGENCY FILE
Mahnood Panjwani vs. County of San Mateo, et al.
San Mateo Superior Court Case No. 23-CIV-04568
DESCRIPTION PAGE NO.
June 29, 2023 San Mateo County Health Decision Letter HB000001
November 7, 2022 Letter Re Emotional Support Animal HB000005
June 7, 2023 Request For Vicious Animal Hearing HB000006
June 8, 2023 Letter Re Setting Administrative Hearing HBO000010
June 10, 2023 Dangerous / Vicious Animal Report - Redacted. HBO00012
June 13, 2023 Letter Re Rescheduling Administrative Hearing HB000034
June 21, 2023 Email Confirming Bark Busters Appointment HB000036
Letter from Mahmood Panjwani Re Summary of Further HB000037
Evidence
Bark Busters Training Exercise Recommendations HB000038
10. Transcription of Audio Recording of Vicious Animal Hearing HB000039
61236.06000\42073200.1
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EXHIBITB
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CERTIFICATION OF AGENCY FILE
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EXHIBIT B—CERTIFICATION OF AGENCY FILE
CERTIFICATION OF AGENCY FILE
I, Lisa Natusch, do hereby declare as follows:
1 Tam the Clerk of the Council for the Town of Hillsborough. In this capacity, I am
familiar with and responsible for maintaining the official records.
2 I do hereby certify that the attached documents, consisting of one bound volume
consecutively paginated as pages HB000001 through HB000106, constitute the full, true, and
correct record of proceedings related to Activity No. A23-287273. These records comprise the
Agency File for Mahmood Panjwani vs. County of San Mateo, et al., San Mateo County Superior
Court case number 23-CIV-04568.
10 3 The Town reserves the right to further supplement the administrative record as
11 necessary.
12 I declare under penalty of perjury under the laws of the State of California that the foregoing
13 is true and correct.
14 Executed this 20" Nay of March, 2024, at Town of Hillsborough, California.
15
16 ‘A NATUSCH
ity Clerk
Ly TOWN OF HILLSBOROUGH
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CERTIFICATION OF AGENCY FILE
61236.06000\42073313.1
PROOF OF SERVICE
At the time of service I was over 18 years of age and not a party to this action.
business address is 2855 E. Guasti Road, Suite 400, Ontario, Califomia 91761. On
March 21, 2024, I served the following document(s):
NOTICE OF LODGING OF CERTIFIED AGENCY FILE;
AGENCY FILE
O By fax transmission. Based on an agreement of the parties to accept service by fax
transmission, I faxed the documents to the persons at the fax numbers listed below.
No enor was reported
by the fax machine
that I used. A copy of the record of the fax
transmission, which I printed out, is attached.
By United States mnil. I enclosed the documents in a sealed envelope or package
addressed to the persons at the addresses listed below (specify one):
10 [1] _ Deposited the sealed envelope with the United States Postal Service, with the
postage fully prepaid.
11
12 x] Placed the envelope for
business practices. I am
collection and mailing, following our ordinary
readily familiar with this business's practice for
fs
ga
BE
ge 13 collecting and processing correspondence for mailing. On the same day that
Se correspondence is placed for collection and mailing, it is deposited in the
mez 14 ordinary course of business with the United States Postal Service, in a sealed
eavelope with postage fully prepaid.
15
16 Michael
H. Porrazzo Attorney for Petitioner
The Porrazzo
Law Firm MAHMOOD PANJWANI
17 30212 Tomas, Suite 365
18 Rancho Santa Margarita, CA. 92688
Tel: (949) 348-7778
19 Fax: (949) 209-3514
Email: —mbhporazzo@porazzolaw.com
20
I declare under penalty of perjury
under the laws of the State of Califomia
that the
21 above is true and correct.
22 Executed on March 21, 2024, at Rancho Cucamonga, Califomia.
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25 Prrmede Crambed-
Pamela Cranifed )
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61236.06000\42073182.1
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PROOF OF SERVICE
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CHRISTOPHERJ. DIAZ, Bar No. 235249 christoy .diaz@bbklaw.com DENISE HANSEN, Bar No. 156363 Electronically denise. hansen@bbklaw.com. r ANDREW E. LOPEZ, Bar No. 337993 andrew. lopez@bbklaw.com. 3/21/2024 BEST BEST & KRIEGER LLP Bs y /s/ Priscilla Tovar Deputy Clerk 2001 N. Main Street Suite 390 Walnut Creek, Califomia 94596 Telephone: (925) 977-3300 Facsimile: (925) 977-1870 EXEMPT FROM FILING FEES PURSUANT Attol for mdent TO GOVERNMENT CODE SECTION 6103 TOWN OF HILLSBOROUGH SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SAN MATEO 11 12 MAHMOOD PANJWANL, Case No. 23-CIV-04568 Bs £4 BE gi 13 Petitioner, oe NOTICE OF LODGING OF mez 14 Vv. CERTIFIED AGENCY FILE 15 COUNTY OF SAN MATEO, SAN MATEO COUNTY HEALTH, PUBLIC HEALTH 16 POLICY AND PLANNING; PENINSULA HUMANE SOCIETY & SPCA. 17 (“PHS/SCPA”); TOWN OF HILLSBOROUGH; PROGRAM MANAGER, 18 OF ANIMAL CONTROL AND LICENSING, 19 Respondent(s). 20 21 22 23 24 25 26 27 28 61236,06000\42073182.1 -1- NOTICE OF LODGING OF CERTIFIED AGENCY FILE NOTICE OF LODGING OF CERTIFIED AGENCY FILE TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that, pursuant to Govemment Code section 53069.4, in the matter of Mahmood Panjwani vs. County of San Mateo, et al., in the Superior Court of the State of Califomia, County of San Mateo, located at 400 County Center, Redwood City, Califomia 94063 (“Court”), in case number 23-CIV-04568, Respondent Town of Hillsborough (“Tor "), by and through its attomeys of record, has prepared and hereby lodges the Town’ s file with Department 23 of this Court, consisting of one bound volume consecutively paginated as Bate Numbers HB000001 through HB000106, inclusive (“Agency File”). The Agency File has been lodged with 10 this Court concurrently with this Notice. The City reserves the right to augment the Agency File 11 with other documents as necessary. 12 The Index to the Agency File is attached hereto as Exhibit A. The certification of this 13 Agency File, executed by the Town of Hillsborough Town Clerk Lisa Natusch, is attached hereto Bg 14 as Exhibit B. 15 This Notice and the certified Agency File has been served on Respondent via United States 16 17 18 Dated: March 21, 2024 BEST BEST & KRIEGER LLP 19 20 21 *y KakE A Z DENISE HANSEN ANDREW E. LOPEZ 22 Attol for Respondent TOWN OF HILLSBOROUGH 23 24 25 26 27 28 61236.06000\42073182.1 -2- NOTICE OF LODGING OF CERTIFIED AGENCY FILE 10 11 12 EXHIBITA 13 INDEX TO AGENCY FILE 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 61236.06000\42073182.1 EXHIBIT A—INDEX TO AGENCY FILE INDEX TO AGENCY FILE Mahnood Panjwani vs. County of San Mateo, et al. San Mateo Superior Court Case No. 23-CIV-04568 DESCRIPTION PAGE NO. June 29, 2023 San Mateo County Health Decision Letter HB000001 November 7, 2022 Letter Re Emotional Support Animal HB000005 June 7, 2023 Request For Vicious Animal Hearing HB000006 June 8, 2023 Letter Re Setting Administrative Hearing HBO000010 June 10, 2023 Dangerous / Vicious Animal Report - Redacted. HBO00012 June 13, 2023 Letter Re Rescheduling Administrative Hearing HB000034 June 21, 2023 Email Confirming Bark Busters Appointment HB000036 Letter from Mahmood Panjwani Re Summary of Further HB000037 Evidence Bark Busters Training Exercise Recommendations HB000038 10. Transcription of Audio Recording of Vicious Animal Hearing HB000039 61236.06000\42073200.1 10 11 12 EXHIBITB 13 CERTIFICATION OF AGENCY FILE 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 61236.06000\42073182.1 EXHIBIT B—CERTIFICATION OF AGENCY FILE CERTIFICATION OF AGENCY FILE I, Lisa Natusch, do hereby declare as follows: 1 Tam the Clerk of the Council for the Town of Hillsborough. In this capacity, I am familiar with and responsible for maintaining the official records. 2 I do hereby certify that the attached documents, consisting of one bound volume consecutively paginated as pages HB000001 through HB000106, constitute the full, true, and correct record of proceedings related to Activity No. A23-287273. These records comprise the Agency File for Mahmood Panjwani vs. County of San Mateo, et al., San Mateo County Superior Court case number 23-CIV-04568. 10 3 The Town reserves the right to further supplement the administrative record as 11 necessary. 12 I declare under penalty of perjury under the laws of the State of California that the foregoing 13 is true and correct. 14 Executed this 20" Nay of March, 2024, at Town of Hillsborough, California. 15 16 ‘A NATUSCH ity Clerk Ly TOWN OF HILLSBOROUGH 18 19 20 21 22 23 24 25 26 2 28 CERTIFICATION OF AGENCY FILE 61236.06000\42073313.1 PROOF OF SERVICE At the time of service I was over 18 years of age and not a party to this action. business address is 2855 E. Guasti Road, Suite 400, Ontario, Califomia 91761. On March 21, 2024, I served the following document(s): NOTICE OF LODGING OF CERTIFIED AGENCY FILE; AGENCY FILE O By fax transmission. Based on an agreement of the parties to accept service by fax transmission, I faxed the documents to the persons at the fax numbers listed below. No enor was reported by the fax machine that I used. A copy of the record of the fax transmission, which I printed out, is attached. By United States mnil. I enclosed the documents in a sealed envelope or package addressed to the persons at the addresses listed below (specify one): 10 [1] _ Deposited the sealed envelope with the United States Postal Service, with the postage fully prepaid. 11 12 x] Placed the envelope for business practices. I am collection and mailing, following our ordinary readily familiar with this business's practice for fs ga BE ge 13 collecting and processing correspondence for mailing. On the same day that Se correspondence is placed for collection and mailing, it is deposited in the mez 14 ordinary course of business with the United States Postal Service, in a sealed eavelope with postage fully prepaid. 15 16 Michael H. Porrazzo Attorney for Petitioner The Porrazzo Law Firm MAHMOOD PANJWANI 17 30212 Tomas, Suite 365 18 Rancho Santa Margarita, CA. 92688 Tel: (949) 348-7778 19 Fax: (949) 209-3514 Email: —mbhporazzo@porazzolaw.com 20 I declare under penalty of perjury under the laws of the State of Califomia that the 21 above is true and correct. 22 Executed on March 21, 2024, at Rancho Cucamonga, Califomia. 23 24 25 Prrmede Crambed- Pamela Cranifed ) 26 27 28 61236.06000\42073182.1 -5- PROOF OF SERVICE