Preview
David Finkelstein (SBN 47791)
Brian Cohen (SBN 316427)
FINKELSTEIN & FUJI, LLP
1528 S. El Camino Real, Suite 306
San Mateo, CA 94402
Telephone: (650) 353-4503
Facsimile: (650) 312-1803
Attorneys for Plaintiff
ADAKITE 1031, LLC
THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN MATEO
(UNLIMITED JURISDICTION)
10
ADAKITE 1031, LLC, a California limited Case No.: 22-CIV-03729
il liability company;
DECLARATION OF STANLEY LO IN
12 Plaintiff, SUPPORT OF PLAINTIFF ADAKITE 1031,
LLC’S MOTION FOR SUMMARY
13 Vv. JUDGMENT OR, IN THE ALTERNATIVE,
SUMMARY ADJUDICATION
14 RG DEVELOPMENTS, an unknown business
entity, GREG GAMBRIOLI, an individual; Date: October 7, 2024
15 ARBOR CO TREE CARE, a California
corporation; GILBERT WOLCOTT, an Time: 2:00 p.m.
16 individual, WOLCOTT GILBERT LLC, a Dept: 23
Delaware limited liability company; Judge: Hon. V. Raymond Swope
17 GAMBRIOLI DEVELPMENTS INC., a
California Corporation; BUSINESS Trial Date: None
18 ALLIANCE INSURANCE COMPANY, a Complaint Filed: 9/12/2022
California Corporation, AMERICAN
19 CONTRACTORS INDEMNITY COMPANY,
a California Corporation; and DOES 1-10,
20 inclusive;
21 Defendant(s).
22
23
24
25 I, STANLEY LO, declare as follows:
26 1 I am the managing member of Plaintiff ADAKITE 1031, LLC. The following facts
27
are personally known to me, and if called as a witness, I could and would testify competently to
28
-1-
DECLARATION OF STANLEY LO IN SUPPORT OF PLAINTIFF ADAKITE 1031, LLC’S MOTION FOR
SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATION
them.
2. Plaintiff ADAKITE 1031, LLC (“Plaintiff’ or “Adakite”) is the owner of property
located at 1868 Floribunda Avenue, Hillsborough, CA 94010 (the “Property” or “Subject Property”
or “Subject Premises”). I am informed and believe that Defendant WOLCOTT GILBERT LLC
(“Wolcott”) is the owner of property located at 15 Greenview Lane, Hillsborough, CA 94010 (the
“Neighboring Property” or “Neighboring Premises”).
3 It is my understanding that the Property is designated as a historical landmark.
Attached hereto as Exhibit 1 and incorporated herein by reference are documents relating to the
10 historical aspects of the Property.
11
4. Attached hereto as Exhibit 2 and incorporated herein by reference are pictures of
12
trees along the property line at the Property around 2018.
13
5 Attached hereto as Exhibit 3 and incorporated herein by reference are pictures of
14
15 trees along the property line at the Property in June 2022, after the tree destruction at issue in this
16 lawsuit.
17 6 As of February 1, 2022, Plaintiff leased the Property to some tenants pursuant to a
18
lease agreement (the “Lease”). Attached hereto as Exhibit 4 and incorporated herein by reference is
19
a true and correct copy of the Lease as well as the current lease regarding the Property. These tenants
20
declined to renew their lease.
21
7 On or about March 6, 2022, Defendant Greg Gambrioli called me. Gambrioli asked
22
23 me whether he could cut down Plaintiff's Monterey cypress trees in the course of construction on
24 the Neighboring Property for Wolcott. I unequivocally rejected Defendant Gambrioli’s request. On
25 March 28, 2022, I sent a text message to Gambrioli, again unequivocally stating: “Please do not
26
touch any [sic] my trees.” Attached hereto as Exhibit 5 and incorporated herein by reference is a
27
true and correct copy of this text message. I never provided permission to any of the defendants to
28
-2-
DECLARATION OF STANLEY LO IN SUPPORT OF PLAINTIFF ADAKITE 1031, LLC’S MOTION FOR
SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATION
come onto the Subject Property in 2022 or to remove and/or damage and/or cut trees located on
and/or partially on the Subject Property in 2022.
8 I strongly believe that Defendant Gambrioli personally dislikes me and wishes to
harm my financial interests and that this was the case at all relevant times.
9 On or about March 31, 2022, Wolcott’s landscape architect Michael Callan contacted
me by email, proposing a plan to cut down Plaintiff's Monterey cypress trees in the course of
construction on the Neighboring Property. I again unequivocally rejected this request.
10. Several months passed without further communication on this subject from any of
the Defendants. Then, on or about June 21, 2022, I was shocked to discover that somebody, I
10
believe Defendants, had cut and destroyed several of Plaintiff's Monterey cypress trees. I strongly
ll
believe that Defendants RG and Wolcott instructed the other Defendants to trim, cut, and destroy
12
Plaintiff's Monterey cypress trees, despite knowing that these trees belonged to Plaintiff and were
13
on Plaintiffs Subject Property.
14
11. I was told by a staff member at my office that at approximately 5:20 p.m. on June 21,
15
2022, an anonymous caller made a threatening call to my office. Attached hereto as Exhibit 6 and
16
incorporated herein by reference is a transcript of this call that I was provided by my staff member.
17
12. Shortly thereafter, I believe that somebody made a complaint to the Town of
18
Hillsborough regarding “business activity” at the Subject Property and that this complaint led to the
19
harassment of Plaintiff's tenants at the Subject Property.
20
13. Attached hereto as Exhibit 7 and incorporated herein by reference is a true and
21
correct copy of an email chain between my office and Plaintiff’s tenant at the Subject Property
22
regarding the destruction of trees on the Subject Property.
23
14. Attached hereto as Exhibit 8 and incorporated herein by reference is a true and
24
correct copy of an email chain between me and an employee of the Town of Hillsborough’s
25
Building and Planning Department regarding the destruction of trees on the Subject Property.
26
15. I specifically informed the individuals engaged in cutting the trees on the Subject
27
Property in June 2022 that they were trespassing and did not have permission to cut the trees. I also
28
-3-
DECLARATION OF STANLEY LO IN SUPPORT OF PLAINTIFF ADAKITE 1031, LLC’S MOTION FOR
SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATION
called and left a voicemail at the Arbor Co Tree Care office phone number.
16. I strongly believe that the current state of the trees presents a hazard to Plaintiff's
tenants at the Subject Property. I therefore intend to remove and replace the trees as soon as this
litigation is resolved. This is especially true given that the Subject Property is currently listed for
sale. Attached hereto as Exhibit 9 and incorporated herein by reference is a true and correct copy of
the deed by which Plaintiff took title to the Subject Property. Attached hereto as Exhibit 10 and
incorporated herein by reference is a true and correct copy of the current listing of the Subject
Property.
17. Attached hereto as Exhibit 11 and incorporated herein by reference is a true and
10 correct copy of the current lease of the Subject Property.
11
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 on April 10, 2024, at Burlingame, California,
15
16
Stanley Lo
17
18
19
20
21
22
23
24
25
26
27
28
-4-
DECLARATION OF STANLEY LO IN SUPPORT OF PLAINTIFF ADAKITE 1031, LLC’S MOTION FOR
SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATION
EXHIBIT “1”
EXHIBIT “1”
II LLSPOROUGH HISTORIC RESOURCES INVENTORY
——_-—.
j A No.
Ss }
lke Historic name: None NK Status 5$3
a Common name: None foval Des.
a Address: 1864 Floribunda Cross-Corridor:
Che Wil orough Vicinity Univ Zip: 94010 Counby: SMA
quad Map 4c uns 18/
Se Parcel No. 028-210-060 Other
G Property Category Building Number of District Rerources:
75 Description This
ts a two-story stucco Spanish Colonial Revival In 4e composed of
a main b with a hipped roof and wings projecting from front und back, The
main Cacade looks as though it may have undergone considerable renovation. The
central bay is recessed. AL the lefLl, a two-story wing projects forward slightly,
and at the right and one-story wing, which is probably an addition, projects
forward further. The usin entrance 8 in a one-story block which projects at the
center between Lhe tho wings, This 18 topped with a plain molded cornice and a
balustrade. The door is centered between tio Tuscan columns and is crowned with
an arched transom (or a fanlight without radiating glazing bara}. fron grill-work
covers the windows on either side of the entrance. Both upstairs and down, ac t,
of the windows are sash windows with sullLipsned glazing and plain surrounds. From
the bac , the house consists of a simple hipped box with e@ one-story wing
projecting forward at the left (a continuation of the one-story addition at the
front) and a less extended two-story wing al the right, The latter has an end
chimney with a tiled top. at the center, French doors open out to the garden,
8. Alterations/Dates:
% Related Features:
a) 10. Plauniag Agency:
Hillsborough Plan, Dept.
eae) i. Owner/Add tesa:
Alfred Ducato
4 ae
Ly KS | al
BX \,
12, Type /Onner.: Private
_ AF
1—m~
EE
omy =
13 Present Use: 7
residential
—
da. Zomiug: Kel
—
15. Threats : private
deve lopment
16 Construction date(s): L924F Original location: same Date Moved:
17. Architect: Unknown Builder: Unknown
18
19
Historic
Context for
Attributes:
Evaluation:
2 - Single
Theme
Family
Later
Property
Subdivisions Area Hillsborough
e
Period 1916-1940 Property Type residence Context Formally Developed? yes
20. Evaluation: This house ig an example of the simplification of period revival
styles after about 1920, Only the tile roof, stucco walls and tile chimney-top
assert its connection with the Spanish Colonial Revival. The addition of the one-
story entrance, with its columns and balustrade, is out of character and disrupts the
facade.
According to a 1920s era map, one of the first owners of this property was Cliff
M, Weatherwax, listed in the 1926 City Directory as a lumberman.
21 Sources: Official Town Map, Hillsborough, n.d. {SMCHA collection); 1926 San
Mateo-Hillsborough City Directory.
22. Applicable NR Criterla:c
N
MAP
2a, Other Recognition:
State Landmark No.:
+ ~)
24. Evaluator/Yr.:
Wickert/1990
»
nS ev’ e 3)
25.
Solomonson/1990
Survey Type: v yo
y
*|
comprehensive OW
Jf
26 Survey Name:
Hilisborough Historical or ¥x
7 ou“
Building Survey KOSD
en) ay
27 dune 1990 a ©
San Mateo Hist, Assoc.
Co. ws ws
%
1700 W. Hillsdale Blvd. ez
San Mateo, CA 94402 ee >
(415) 574-6441
*
av
a
win
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Form conforms to OHP HRI form 8/B9
> io" \e
NB: 4florl864 nw
September 14, 2018
Elizabeth Cullinan
Town of Hillsborough
1600 Floribunda Avenue
Hillsborough CA 94010
Historic Preservation Standards Review for Proposed Alterations at 1868 Floribunda Avenue
Overview
The house is a prominent example of Spanish Colonial Revival, constructed before 1920. The house is included
in the Town of Hillsborough Historic Resource Inventory. The proposed scope of work as shown on drawings
dated July 30, 2018 by Chu Design Associaites includes alterations to the street-facing facade, demolition of a
detached garage and construction of a new detached loggia building.
Standards
The Secretary of the Interior’s Standards for the Treatment of Historic Properties! include two general
recommendations that appear relevant here:
Distinctive materials, features, finishes, and construction techniques or examples of craftsmanship that characterize a property will
be preserved.
New additions, exterior alterations, or related new construction will not destroy historic materials, features, and spatial relationships
that characterize the property. The new work shall be differentiated from the old and will be compatible with the historic materials,
features, size, scale and proportion, and massing to protect the integrity of the property and its environment.
Locating the attached exterior addition at the rear or on an inconspicuous side of a historic building; and limiting its size and
scale in relationship to the historic building,
In applying the Standards, it is important to understand which elevation(s) is the primary public face of the
building. Primary facades receive higher importance in preservation than secondary facades. The house at
1868 Floribunda Avenue has two primary facades: the south facade fronting onto Floribunda Avenue and the
west facade containing the main entry to the house.
The house has experienced multiple additions since its initial construction for Mrs. Edith McBean Kiersted in
the late 1910s. No plans have survived from this early era but insurance maps show the expansion of the house
by the second owners, Cliff and Auli Weatherwax during the 1930s. Mr. Weatherwax died in 1939 and his
widow sold the property to Walter B. Brandt in 1943. The additions made before 1949 should be considered
to have acquired historic merit. This would include the basic massing of the main house, and the garden house
structure in the northwest corner of the property. The second accessory building on the 1949 map has either
been moved or demolished; none of the accessory buildings on the site today — with the exception of the garden
house — appear to be contributing elements to the historic character of the property.
2 Viewed at http://www.nps.gov/history/hps/tps/standguide/.
~~
Most properties change over time; thase changes that have acquired historic significance in their own right shall be retained and
preserved.
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The main house appears to have retained its shape and general massing since 1949, with a few notable
exceptions: the addition of a second floor balcony and support structure on the terrace partially obscuring the
south facade, addition of decorative stone pavers throughout the site, and a second floor addition to the rear
(north) fagade.
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South facade showing addition to support second floor balcony. Photograph courtesy Peter Lam.
Comments
This house, which has always had the eclectic, irregular massing typical of Spanish Colonial Revival architecture,
is complex and the large site contains a number of accessory buildings and garden features. The character
defining features of Spanish Colonial Revival include: arched openings, plan wall surfaces, tile roofs, and
irregular massing. This house was built for Edith McBean Kiersted, one of the heirs to the Gladding McBean
tile company, which provided ted roof tile throughout California. While the house has been modified the
character defining features remain highly visible.
The changes to the street-facing facade could be viewed as an improvement as the removal of the arched
openings and their replacement with rectangular doorways recalls the original configuration of doors and
windows on this facade (although placed forward of the original front wall), Unfortunately the drawings do
not provide enough detail on the doors — they are specified as “stained wood” on Sheet A8 — which should
contain glass panes (i. “French” doors) to more closely recall the original windows and doors on this elevation.
The removal of the existing garage and its replacement with an open-sided loggia structure has no effect on
historic materials or the character of this house.
Summary
‘The proposed garage additions are sensitively designed and respectful of the original style and materials of the
house and in general meet the spirit of the standard: “The new work shall be differentiated from the old and will be
_
compatible with the historic materials, features, size, scale and proportion, and massing.” The historic character of the house
would be improved by removal of the arched openings on the front elevation and their replacement with French
doors, aligned with the windows on the second story. The proposed demolition of a recently constructed
garage and construction of a small loggia building at the rear of the house would have no effect on the historic
character of the site.
I recommend approval of the proposed project, after receiving confirmation regarding the configuration of the
new doors on the front elevation. The historic character of this property has been partially compromised by
modern improvements however its historic style, massing and feeling remains strong.
Submitted by: Laura Jones, Ph.D. Heritage Resources Consulting
September 14, 2018
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Preview
David Finkelstein (SBN 47791) Brian Cohen (SBN 316427) FINKELSTEIN & FUJI, LLP 1528 S. El Camino Real, Suite 306 San Mateo, CA 94402 Telephone: (650) 353-4503 Facsimile: (650) 312-1803 Attorneys for Plaintiff ADAKITE 1031, LLC THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN MATEO (UNLIMITED JURISDICTION) 10 ADAKITE 1031, LLC, a California limited Case No.: 22-CIV-03729 il liability company; DECLARATION OF STANLEY LO IN 12 Plaintiff, SUPPORT OF PLAINTIFF ADAKITE 1031, LLC’S MOTION FOR SUMMARY 13 Vv. JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATION 14 RG DEVELOPMENTS, an unknown business entity, GREG GAMBRIOLI, an individual; Date: October 7, 2024 15 ARBOR CO TREE CARE, a California corporation; GILBERT WOLCOTT, an Time: 2:00 p.m. 16 individual, WOLCOTT GILBERT LLC, a Dept: 23 Delaware limited liability company; Judge: Hon. V. Raymond Swope 17 GAMBRIOLI DEVELPMENTS INC., a California Corporation; BUSINESS Trial Date: None 18 ALLIANCE INSURANCE COMPANY, a Complaint Filed: 9/12/2022 California Corporation, AMERICAN 19 CONTRACTORS INDEMNITY COMPANY, a California Corporation; and DOES 1-10, 20 inclusive; 21 Defendant(s). 22 23 24 25 I, STANLEY LO, declare as follows: 26 1 I am the managing member of Plaintiff ADAKITE 1031, LLC. The following facts 27 are personally known to me, and if called as a witness, I could and would testify competently to 28 -1- DECLARATION OF STANLEY LO IN SUPPORT OF PLAINTIFF ADAKITE 1031, LLC’S MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATION them. 2. Plaintiff ADAKITE 1031, LLC (“Plaintiff’ or “Adakite”) is the owner of property located at 1868 Floribunda Avenue, Hillsborough, CA 94010 (the “Property” or “Subject Property” or “Subject Premises”). I am informed and believe that Defendant WOLCOTT GILBERT LLC (“Wolcott”) is the owner of property located at 15 Greenview Lane, Hillsborough, CA 94010 (the “Neighboring Property” or “Neighboring Premises”). 3 It is my understanding that the Property is designated as a historical landmark. Attached hereto as Exhibit 1 and incorporated herein by reference are documents relating to the 10 historical aspects of the Property. 11 4. Attached hereto as Exhibit 2 and incorporated herein by reference are pictures of 12 trees along the property line at the Property around 2018. 13 5 Attached hereto as Exhibit 3 and incorporated herein by reference are pictures of 14 15 trees along the property line at the Property in June 2022, after the tree destruction at issue in this 16 lawsuit. 17 6 As of February 1, 2022, Plaintiff leased the Property to some tenants pursuant to a 18 lease agreement (the “Lease”). Attached hereto as Exhibit 4 and incorporated herein by reference is 19 a true and correct copy of the Lease as well as the current lease regarding the Property. These tenants 20 declined to renew their lease. 21 7 On or about March 6, 2022, Defendant Greg Gambrioli called me. Gambrioli asked 22 23 me whether he could cut down Plaintiff's Monterey cypress trees in the course of construction on 24 the Neighboring Property for Wolcott. I unequivocally rejected Defendant Gambrioli’s request. On 25 March 28, 2022, I sent a text message to Gambrioli, again unequivocally stating: “Please do not 26 touch any [sic] my trees.” Attached hereto as Exhibit 5 and incorporated herein by reference is a 27 true and correct copy of this text message. I never provided permission to any of the defendants to 28 -2- DECLARATION OF STANLEY LO IN SUPPORT OF PLAINTIFF ADAKITE 1031, LLC’S MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATION come onto the Subject Property in 2022 or to remove and/or damage and/or cut trees located on and/or partially on the Subject Property in 2022. 8 I strongly believe that Defendant Gambrioli personally dislikes me and wishes to harm my financial interests and that this was the case at all relevant times. 9 On or about March 31, 2022, Wolcott’s landscape architect Michael Callan contacted me by email, proposing a plan to cut down Plaintiff's Monterey cypress trees in the course of construction on the Neighboring Property. I again unequivocally rejected this request. 10. Several months passed without further communication on this subject from any of the Defendants. Then, on or about June 21, 2022, I was shocked to discover that somebody, I 10 believe Defendants, had cut and destroyed several of Plaintiff's Monterey cypress trees. I strongly ll believe that Defendants RG and Wolcott instructed the other Defendants to trim, cut, and destroy 12 Plaintiff's Monterey cypress trees, despite knowing that these trees belonged to Plaintiff and were 13 on Plaintiffs Subject Property. 14 11. I was told by a staff member at my office that at approximately 5:20 p.m. on June 21, 15 2022, an anonymous caller made a threatening call to my office. Attached hereto as Exhibit 6 and 16 incorporated herein by reference is a transcript of this call that I was provided by my staff member. 17 12. Shortly thereafter, I believe that somebody made a complaint to the Town of 18 Hillsborough regarding “business activity” at the Subject Property and that this complaint led to the 19 harassment of Plaintiff's tenants at the Subject Property. 20 13. Attached hereto as Exhibit 7 and incorporated herein by reference is a true and 21 correct copy of an email chain between my office and Plaintiff’s tenant at the Subject Property 22 regarding the destruction of trees on the Subject Property. 23 14. Attached hereto as Exhibit 8 and incorporated herein by reference is a true and 24 correct copy of an email chain between me and an employee of the Town of Hillsborough’s 25 Building and Planning Department regarding the destruction of trees on the Subject Property. 26 15. I specifically informed the individuals engaged in cutting the trees on the Subject 27 Property in June 2022 that they were trespassing and did not have permission to cut the trees. I also 28 -3- DECLARATION OF STANLEY LO IN SUPPORT OF PLAINTIFF ADAKITE 1031, LLC’S MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATION called and left a voicemail at the Arbor Co Tree Care office phone number. 16. I strongly believe that the current state of the trees presents a hazard to Plaintiff's tenants at the Subject Property. I therefore intend to remove and replace the trees as soon as this litigation is resolved. This is especially true given that the Subject Property is currently listed for sale. Attached hereto as Exhibit 9 and incorporated herein by reference is a true and correct copy of the deed by which Plaintiff took title to the Subject Property. Attached hereto as Exhibit 10 and incorporated herein by reference is a true and correct copy of the current listing of the Subject Property. 17. Attached hereto as Exhibit 11 and incorporated herein by reference is a true and 10 correct copy of the current lease of the Subject Property. 11 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 on April 10, 2024, at Burlingame, California, 15 16 Stanley Lo 17 18 19 20 21 22 23 24 25 26 27 28 -4- DECLARATION OF STANLEY LO IN SUPPORT OF PLAINTIFF ADAKITE 1031, LLC’S MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATION EXHIBIT “1” EXHIBIT “1” II LLSPOROUGH HISTORIC RESOURCES INVENTORY ——_-—. j A No. Ss } lke Historic name: None NK Status 5$3 a Common name: None foval Des. a Address: 1864 Floribunda Cross-Corridor: Che Wil orough Vicinity Univ Zip: 94010 Counby: SMA quad Map 4c uns 18/ Se Parcel No. 028-210-060 Other G Property Category Building Number of District Rerources: 75 Description This ts a two-story stucco Spanish Colonial Revival In 4e composed of a main b with a hipped roof and wings projecting from front und back, The main Cacade looks as though it may have undergone considerable renovation. The central bay is recessed. AL the lefLl, a two-story wing projects forward slightly, and at the right and one-story wing, which is probably an addition, projects forward further. The usin entrance 8 in a one-story block which projects at the center between Lhe tho wings, This 18 topped with a plain molded cornice and a balustrade. The door is centered between tio Tuscan columns and is crowned with an arched transom (or a fanlight without radiating glazing bara}. fron grill-work covers the windows on either side of the entrance. Both upstairs and down, ac t, of the windows are sash windows with sullLipsned glazing and plain surrounds. From the bac , the house consists of a simple hipped box with e@ one-story wing projecting forward at the left (a continuation of the one-story addition at the front) and a less extended two-story wing al the right, The latter has an end chimney with a tiled top. at the center, French doors open out to the garden, 8. Alterations/Dates: % Related Features: a) 10. Plauniag Agency: Hillsborough Plan, Dept. eae) i. Owner/Add tesa: Alfred Ducato 4 ae Ly KS | al BX \, 12, Type /Onner.: Private _ AF 1—m~ EE omy = 13 Present Use: 7 residential — da. Zomiug: Kel — 15. Threats : private deve lopment 16 Construction date(s): L924F Original location: same Date Moved: 17. Architect: Unknown Builder: Unknown 18 19 Historic Context for Attributes: Evaluation: 2 - Single Theme Family Later Property Subdivisions Area Hillsborough e Period 1916-1940 Property Type residence Context Formally Developed? yes 20. Evaluation: This house ig an example of the simplification of period revival styles after about 1920, Only the tile roof, stucco walls and tile chimney-top assert its connection with the Spanish Colonial Revival. The addition of the one- story entrance, with its columns and balustrade, is out of character and disrupts the facade. According to a 1920s era map, one of the first owners of this property was Cliff M, Weatherwax, listed in the 1926 City Directory as a lumberman. 21 Sources: Official Town Map, Hillsborough, n.d. {SMCHA collection); 1926 San Mateo-Hillsborough City Directory. 22. Applicable NR Criterla:c N MAP 2a, Other Recognition: State Landmark No.: + ~) 24. Evaluator/Yr.: Wickert/1990 » nS ev’ e 3) 25. Solomonson/1990 Survey Type: v yo y *| comprehensive OW Jf 26 Survey Name: Hilisborough Historical or ¥x 7 ou“ Building Survey KOSD en) ay 27 dune 1990 a © San Mateo Hist, Assoc. Co. ws ws % 1700 W. Hillsdale Blvd. ez San Mateo, CA 94402 ee > (415) 574-6441 * av a win >) ? \" i > Form conforms to OHP HRI form 8/B9 > io" \e NB: 4florl864 nw September 14, 2018 Elizabeth Cullinan Town of Hillsborough 1600 Floribunda Avenue Hillsborough CA 94010 Historic Preservation Standards Review for Proposed Alterations at 1868 Floribunda Avenue Overview The house is a prominent example of Spanish Colonial Revival, constructed before 1920. The house is included in the Town of Hillsborough Historic Resource Inventory. The proposed scope of work as shown on drawings dated July 30, 2018 by Chu Design Associaites includes alterations to the street-facing facade, demolition of a detached garage and construction of a new detached loggia building. Standards The Secretary of the Interior’s Standards for the Treatment of Historic Properties! include two general recommendations that appear relevant here: Distinctive materials, features, finishes, and construction techniques or examples of craftsmanship that characterize a property will be preserved. New additions, exterior alterations, or related new construction will not destroy historic materials, features, and spatial relationships that characterize the property. The new work shall be differentiated from the old and will be compatible with the historic materials, features, size, scale and proportion, and massing to protect the integrity of the property and its environment. Locating the attached exterior addition at the rear or on an inconspicuous side of a historic building; and limiting its size and scale in relationship to the historic building, In applying the Standards, it is important to understand which elevation(s) is the primary public face of the building. Primary facades receive higher importance in preservation than secondary facades. The house at 1868 Floribunda Avenue has two primary facades: the south facade fronting onto Floribunda Avenue and the west facade containing the main entry to the house. The house has experienced multiple additions since its initial construction for Mrs. Edith McBean Kiersted in the late 1910s. No plans have survived from this early era but insurance maps show the expansion of the house by the second owners, Cliff and Auli Weatherwax during the 1930s. Mr. Weatherwax died in 1939 and his widow sold the property to Walter B. Brandt in 1943. The additions made before 1949 should be considered to have acquired historic merit. This would include the basic massing of the main house, and the garden house structure in the northwest corner of the property. The second accessory building on the 1949 map has either been moved or demolished; none of the accessory buildings on the site today — with the exception of the garden house — appear to be contributing elements to the historic character of the property. 2 Viewed at http://www.nps.gov/history/hps/tps/standguide/. ~~ Most properties change over time; thase changes that have acquired historic significance in their own right shall be retained and preserved. y at ae — a st a _— _-—~ _—~ ~/ — ~~. we. ~, ms r ‘sae a "Nove, oe, WHE ey fa whet ewer * Sect 96,, she ~28 09 oR: <-> A PP pe Sanborn Map Company, May 1920. City of San Mateo, including Hillsborough. Sheet 41. Isa “itty f wz] Ete Rp. che 8 ety yy 00% Tae ad Wea MER Way a) iy eet ween a tal LER wks uf Adon ef Cae ae flog OND a £2 Eso = S aa Sanborn Map Company, February 1949. City of San Mateo, including Hillsborough. Sheet 41. The main house appears to have retained its shape and general massing since 1949, with a few notable exceptions: the addition of a second floor balcony and support structure on the terrace partially obscuring the south facade, addition of decorative stone pavers throughout the site, and a second floor addition to the rear (north) fagade. oe 1p i zu eT i ee cel a me ie fa = South facade showing addition to support second floor balcony. Photograph courtesy Peter Lam. Comments This house, which has always had the eclectic, irregular massing typical of Spanish Colonial Revival architecture, is complex and the large site contains a number of accessory buildings and garden features. The character defining features of Spanish Colonial Revival include: arched openings, plan wall surfaces, tile roofs, and irregular massing. This house was built for Edith McBean Kiersted, one of the heirs to the Gladding McBean tile company, which provided ted roof tile throughout California. While the house has been modified the character defining features remain highly visible. The changes to the street-facing facade could be viewed as an improvement as the removal of the arched openings and their replacement with rectangular doorways recalls the original configuration of doors and windows on this facade (although placed forward of the original front wall), Unfortunately the drawings do not provide enough detail on the doors — they are specified as “stained wood” on Sheet A8 — which should contain glass panes (i. “French” doors) to more closely recall the original windows and doors on this elevation. The removal of the existing garage and its replacement with an open-sided loggia structure has no effect on historic materials or the character of this house. Summary ‘The proposed garage additions are sensitively designed and respectful of the original style and materials of the house and in general meet the spirit of the standard: “The new work shall be differentiated from the old and will be _ compatible with the historic materials, features, size, scale and proportion, and massing.” The historic character of the house would be improved by removal of the arched openings on the front elevation and their replacement with French doors, aligned with the windows on the second story. The proposed demolition of a recently constructed garage and construction of a small loggia building at the rear of the house would have no effect on the historic character of the site. I recommend approval of the proposed project, after receiving confirmation regarding the configuration of the new doors on the front elevation. The historic character of this property has been partially compromised by modern improvements however its historic style, massing and feeling remains strong. Submitted by: Laura Jones, Ph.D. Heritage Resources Consulting September 14, 2018 EXHIBIT “2” EXHIBIT “2” ey ce Se i ie eee BS eS a3 a Bh A 4 ie = a ae ns —_ . is vs x a if i is ee LAE IS A EZ Aa a ali — ekabhik! L LED E hg iHe vd Beet TT aa Sz 2Y ———- 2 AY my INN MN a HN IIL Fae be oe i iii ii Ns aa i en! a i l an) a i bei | fx = Bee b= oa \3 | a a Laas Ms sa coat oR yo! es 2y i A i ae & 4 9 Sallis os Fs ag} ie a a cate ee ps 4 _ rir = ey & "Ee 4 a a Ch a Pe Ec Pu we an Fe ie I va: es S ate 3 Ca tS a npeS a Vl a is ee os eer 7 a f iY aaaw 5 ep WE eg SK S <\, ws gsi Sty S \* S 3 7c aie LYyi, ye Ly un Lp t 4 SSSs & cs “yp Pires a YyY = re t S be 26 Y or o, t 7 ~ gb Be ” <2 J i ae =: Z/; a ee aaa gus Om: oe S row zi bi) ow ™ Im an By INI it HH i ye ea ee