The binding Notice and Order names an authorized official but is signed by an inspector the code does not list, with no produced delegation or approval record bridging that signature.
A “Notice and Order” is the city’s formal legal document declaring a building unsafe and starting the clock on repairs, fees, and possible demolition. SCC §8.100.720 The city’s own code says only a short, fixed list of people can sign one: the top building official and four named deputies — a deputy chief, a “principal building inspector,” a supervising engineer, and a code-and-housing-enforcement chief. SCC §8.96.105 SCC §15.04.100 On this order the name printed on the date line, Bo Cosley, is a “principal building inspector” — one of the four — Code Enforcement contacts and the city’s recorded follow-up notice was signed by another of the four. Card 14 So the city plainly knows how to put someone on the list behind an order. But the actual signature on this binding order belongs to a different person, Paul Lovato, whose title — Building Inspector III — is nowhere on that list; M124 and when the order was reissued more than two years later he signed it again as “Building Inspector 4,” still not the listed rank. M543 M554 The owner’s representative pushed the city through repeated public-records requests to hand over its complete file, and when it did, the file held no document — no memo, no email, no approval note — putting Lovato on the list or showing the named official ever authorized him to sign in his place. R.25-3549 R.26-1549 R.26-1965 M001–M631
Bottom line: the city’s own code names exactly four people who may sign this order; the man who actually signed it is not one of them, and the complete file the city closed the request on holds nothing that makes him one.The April 12, 2023 Notice and Order face page M124 recites that the Chief Building Official “has caused to be inspected and has determined” the building substandard and/or dangerous, then orders repair or demolition under the City’s Notice-and-Order procedure. SCC §8.100.720 The City’s code fixes who may act as that official: SCC §8.96.105 ties the order-issuing “building official” to the Chief Building Official and the assistants described in SCC §15.04.100. Section 15.04.100 lists those assistant titles: Deputy Chief Building Official, Principal Building Inspector, Supervising Engineer, and Code and Housing Enforcement Chief. The order’s date line names Bo Cosley, Principal Building Inspector Code Enforcement contacts — a listed title; the “By” signature beneath it is Paul Lovato, Building Inspector III M124 — a title that does not appear in the authority list. That is the procedural gap: if the City says Lovato could sign anyway, the City needs the authority bridge, and the produced file does not contain one.
That same unbridged signature structure repeated on the September 2, 2025 reissued Notice and Order: the document is dated under Willie Harris, Principal Building Inspector, but signed “By” Paul Lovato, Building Inspector 4 — M543 M554 still not the listed “Principal Building Inspector.” A full-text search of the 631-page May 2026 production returns zero instances of “delegat,” “designee,” or “authorized representative.” M001–M631
SCC §8.96.105 defines the “building official” for this article to include the Chief Building Official and “his or her assistants as described in Section 15.04.100.” SCC §15.04.100 lists the assistant titles in full: (A) Deputy Chief Building Official, (B) Principal Building Inspector, (C) Supervising Engineer, and (D) Code and Housing Enforcement Chief. The Chief Building Official class specification further defines the role. CBO job spec Building Inspector III and Building Inspector IV are not on that list.
The April 12, 2023 Notice and Order face page is dated under “Bo Cosley, Principal Building Inspector” — a title on the SCC §15.04.100 list Code Enforcement contacts — and the signature line below it, after “By,” is Paul Lovato, Building Inspector III, a title that does not appear in the authority list. M124
The recorded companion notice in the same enforcement matter was signed by Peter Lemos, Code and Housing Enforcement Chief — another SCC §15.04.100 listed title. Card 14 That matters because the record shows the City knew how to place a listed official behind this enforcement matter.
The September 2, 2025 reissued Notice and Order repeats the pattern: the document is dated under Willie Harris, Principal Building Inspector, but signed “By” Paul Lovato, Building Inspector 4. M543 M554 Building Inspector 4 is still not Principal Building Inspector, and neither title — Building Inspector III or Building Inspector 4 — appears in the SCC §15.04.100 list. The title change mid-case is addressed separately at Card 43.
The closed-as-complete productions R.25-3549 R.26-1549 R.26-1965 contain no standing delegation, written designation, case-specific authorization, review note, approval email, task entry, or other record placing Lovato within the SCC §15.04.100 authority chain or empowering him to sign “By” for Cosley. A full-text search of the 631-page May 2026 production returns zero instances of “delegat,” “designee,” or “authorized representative.” M001–M631
This card does not depend on claiming that every “By” signature is automatically invalid. The narrower point is record-based: the City’s own code identifies the official chain for the Notice-and-Order authority, SCC §8.96.105 SCC §15.04.100 the April 2023 order’s only signature line is by a title outside that chain, M124 the same unbridged structure appears again in 2025, M543 M554 and the produced file contains no delegation, designation, routing, or approval record connecting Lovato to the listed official’s authority. M001–M631
The strongest City answer is that this was Cosley’s order and Lovato merely executed it as routine practice. Routine practice is not the missing record. If that signature path was authorized, the City should be able to produce the date-effective authority bridge, identify its scope, and explain why it was absent from the produced enforcement file. R.25-3549 R.26-1549 R.26-1965 The corrective question is not “trust us”; it is production of the authority record or correction of the enforcement consequences that depend on it.