They Always Win

Case Overview

On March 20, 2023, the City of Sacramento opened a code enforcement case against 4880 T Street, a property owned by the Jacqueline M. Baritell Trust. The property owner is a medically frail, wheelchair-bound elderly woman.

Over the next three years, the city assessed over $32,000 in administrative penalties and monitoring fees Penalty Timeline CSV, recorded a cloud on the property's title, and conducted almost 30 cycles of penalties and lien hearings — all without ever lawfully entering or inspecting the property Official Case File.

The official case file, obtained through the California Public Records Act, disproves the city's own enforcement actions on their face.

Every fact on this page is sourced exclusively from the city's own official records. Read them yourself.

16 Documented Failures

Each failure is sourced from the official case file and public statutory record. Click any authority to read the actual law.

The Inspection That Never Happened

Every enforcement action in this case rests on a single claim: that Inspector Lovato inspected 4880 T Street and determined it to be substandard. The official case file disproves that claim in the inspector's own words.

March 20, 2023 — The First Visit

I arrived onsite at 12:00 pm and from the front of the dwelling there looks to be no work going on. There are items in the driveway that look to be removed from the garage. I knocked at the front door and there was no answer so I left my card at the front door and took pictures around the property. I then went to the alley to see if I could drive to the back of the dwelling and there is a gate there blocking access.— Paul Lovato, Case Notes, 03/20/2023 Case File

He saw nothing. He couldn't reach the backyard. He left a card.

April 4, 2023 — Contact Established

The owner's representative, Christopher Foley, emailed Paul Lovato the same day Paul received the complaint. Paul responded within hours. Contact was established. Email Thread pp.1-2

Yet on April 11, Paul would enter into the case file: “Due to lack of contact from the Owner...” — a statement his own April 4 notes disprove.

April 10, 2023 — Standing in a Neighbor's Yard

I met with neighbors to access their backyard to verify work performed. I did verify there is an addition to the detached garage going on. Neighbors stated there was generators running the previous night. I took pictures of what I saw from where I was standing. A N&O will be requested.— Paul Lovato, Case Notes, 04/10/2023 Case File

He never entered 4880 T Street. He never sought a warrant under CCP §1822.50. He never obtained owner consent. He stood in a neighbor's yard and looked over the fence.

His own April 7 note reveals the neighbor was the complaining party: “I contacted the complaining party to find out if the work can be viewed from their property.” Case File

April 12, 2023 — The Notice and Order

Two days after standing in a neighbor's yard, the Notice and Order was issued. Its face certifies:

The Chief Building Official has caused to be inspected and has determined that the building(s) at 4880 T ST, Sacramento, California… (is)(are) in sub-standard and/or dangerous condition.— Notice and Order, 04/12/2023, signed Bo Cosley, executed Paul Lovato

Under Cal. Health & Safety Code §17980(c)(1), enforcement proceedings may commence only after the agency “has inspected or caused to be inspected a building and has determined that the building is a substandard building.” That did not happen until 896 days later.

The Three Requests for Specifics

The owner's representative asked Paul Lovato three times in writing what specific violation existed:

• April 4, 2023 — First contact email asking what the case was about. Paul responded with the 311 complaint text, no specifics. Email Thread pp.1-2
• April 14, 2023 — Formal request for clarification. Paul responded in 9 minutes: “Either permits are required to legalize the work, or it is to be removed.” Zero specifics. Email Thread pp.4-6
• April 25, 2023 — Third request for “the specific purpose and scope of the inspection.” Never answered. Email Thread p.9

The Penalty Machine — $32,070

From April 12, 2023 through September 2, 2025 — 896 days — not one city official entered the property. Every penalty during this period was assessed under a Notice and Order that certified an inspection that never occurred. Case File Activities

The automated system assessed: Full Penalty Timeline CSV

• 23 administrative penalties ($1,000 each; final cycle $2,000)
• Monthly monitoring fees ($305, later raised to $380)
• Multiple lien hearings with $20 collection fees each
• Cumulative total: $32,070 and counting
• All assessed under SCC §8.100.860, which authorizes penalties only for violation of a valid Notice and Order

The Compliance Trap

The N&O simultaneously ordered the owner to obtain permits within 30 days. But the Correction List — same document, same date — states:

This is not a complete Violation List of building code violations. Neither interior nor exterior has been completely inspected.— Correction List, Code B31, attached to N&O dated 04/12/2023 Violation Listing

A complete inspection shall have been done with a list of violations and all paperwork/plans may need to be submitted before a permit can be issued.— Same Correction List, same date Violation Listing

The owner was ordered to comply within a deadline while the city's own document stated the prerequisites for compliance had not been met. Under SCC §8.100.720(A)(2), a Notice and Order must contain “a brief and concise description of the conditions found to render the building substandard.” This one contained boilerplate.

The Permit That Paul Wrote

On February 5, 2026, Paul Lovato emailed Karin Owens — an unauthorized third party — dictating the exact scope of work for the building permit. Karin Owens Email

On February 27, 2026, Permit RES-2603471 was issued. The scope matches Paul's email verbatim. Fee: $522.96. Building Permit

Off-Record Communications

Inspector Lovato engaged in multiple rounds of communication that do not appear in the official case activity log, case notes, or any filed document. Under City of San Jose v. Superior Court (2017), communications on personal devices in connection with public business are public records subject to production.

The Karin Owens Channel

Karin Owens (kowensfoley@gmail.com) first appears in the case file on April 10, 2025, calling as the “PO's friend.” Case File Notes

By October 2025, she was being cc'd on attorney correspondence alongside the property owner and the contractor. Saakian Thread pp.3-5

By February 2026, Paul Lovato was emailing her directly to dictate the scope of work for the building permit — bypassing the owner, the owner's representative, and the attorney of record.

The Saakian Email Thread

In October 2025, attorney Mark Saakian pushed for a permit. The owner's representative pushed back, arguing no permit requirement existed under the N&O. The contractor, Arthur Popov, quit: Full Thread (8 messages)

Sorry Mark, I am am not placing myself into this. It is talking too much of my time. All the listed items are done. I do not feel comfortable pulling permit for anything they ask and be stuck with this misc items. I am out.— Arthur Popov, Best of Remodel Inc., October 20, 2025 Saakian Thread p.4

The Correction Notice That Isn't One

On September 16, 2025, Paul emailed an 11-item “Correction Notice” to the property's contractor. This document bears no formal enforcement authority under the Sacramento City Code. It expanded the scope beyond the original N&O without issuing an amended or supplemental order as required by SCC §8.100.720. Correction Notice + Photos

The Formal Demand

On April 2, 2026, a formal demand titled “Notice of Documented Procedural Invalidity and Formal Demand for Case Closure” was hand-delivered and emailed to Doug Pierson, incoming Principal Building Inspector. Read the Full Demand (9 pages)

The demand makes six specific requests, with a 14-day response window:

1. Immediate case closure — written confirmation within 14 calendar days
2. Full dismissal of all penalties and fees — complete accounting, all liens released, final disposition recorded per H&S §17985(b)
3. Production of inspection records — all records constituting the “inspection” certified by the N&O
4. Off-record communications entered into file — all emails, texts, and communications between Paul Lovato, Karin Owens, Chris Foley, Bo Cosley, and all other parties
5. Production of the laptop photograph — the specific photo shown during the April 2023 meeting
6. Native electronic records — all case photos in original .JPG format with EXIF metadata per Gov. Code §7922.570(b)(1)

Two Paths

• Path 1: Administrative Closure — Close the case, dismiss charges, release liens, record final disposition. Estimated 15 business days.
• Path 2: Escalated Litigation — If no response in 14 days, the record goes to Superior Court, the City Auditor, the California Attorney General, and appropriate oversight bodies. The city will be defending a record its own inspector wrote.

Full Timeline

Source: Official Case File Email Thread Penalty Data

Key People

Source Documents

Every document below was obtained from the City of Sacramento's official case record or through the California Public Records Act. Click to view.

Official Case Records

• 📄Official Case File — File Detail ReportCitizenserve Case 23-009185, 34 pages. Activities, Violations, Documents, Notes.PDF
• 📄Violation Listing — Citizenserve Public PageAll 12 violations: B31, B59 (03/20/2023) + 10 added 08/29/2025 after first actual entry.PDF
• 📄Correction Notice — September 16, 202511-item list from Paul Lovato with property photos. Not a formal enforcement instrument.PDF
• 📄Building Permit RES-2603471Issued 02/27/2026. $522.96. Scope matches inspector's email verbatim.PDF

Email Communications

• ✉April 2023 Email Thread — 10 Gmail ScreenshotsChris Foley ↔ Paul Lovato. Three requests for specifics. Nine-minute response. Never answered.PDF
• ✉Saakian Email Thread — October 20258 messages. Mark Saakian, Chris Foley, Arthur Popov, Karin Owens. Contractor walks off.PDF
• ✉Karin Owens Email — January 2026Chris Foley to Karin Owens re: scope creep risks and legal framework.PDF

The Demand

• ⚖Notice of Documented Procedural Invalidity9 sections, 16 failures, 6 demands. Delivered April 2, 2026.PDF

Financial

• 📈Penalty Timeline — Full TableEvery penalty, date, amount, cumulative total. $32,070 through 23 cycles. View in browser.VIEW

Legal Research

• ⚖Legal Findings (California-Focused)California statutes and Sacramento City Code analysis.PDF
• ⚖Factual Basis Requirement for Dangerous Building NoticesLegal standard for N&O issuance in Sacramento.PDF
• ⚖Legal Standards for Code Enforcement NoticesPrimary sources for March–April 2023 enforcement actions.PDF

CPRA Analysis

• 📄CPRA Violations — Executive SummaryCalifornia Public Records Act violations in city's handling of records requests.PDF
• 📄Evidentiary Findings — CPRA ViolationsGaps between what was requested and what was produced.PDF

CPRA Record

Multiple California Public Records Act requests were filed under Gov. Code §7922.530:

A foundational evidence request submitted November 26, 2025 targeted the factual basis for every fee cycle. The city has not produced monitoring documentation for any billed cycle. CPRA Violations Summary

Applicable Law

Every statute cited in this audit. Click to read the full text of the law.