The only garage-addition verification recites the order in the future tense and was logged under two dates, while the 04/11 photo-taking visit the City claims has no 04/11 photograph behind it.
Before a city can charge a property owner over unpermitted work, an inspector is supposed to actually verify the work and write down what was found. SCC §8.100.700 SCC §8.100.720 Here the inspector’s only note verifying the garage addition ends with “a notice and order will be requested” — future tense, meaning the order had not yet been written when he recorded the one thing that was supposed to justify it. M001 The only photos behind that note are the highest frame numbers on his camera that day; M013 the frames just before them, produced from three other Sacramento cases, show those neighbor-lot shots came after stops at other properties R.26-1863 23-000633 23-000351 23-007617 — though he had also photographed 4880 T Street that morning and returned at a 3:00 pm meeting the neighbors had set up days earlier. M013 M024 The same short narrative about meeting the neighbors then shows up in the file under two different dates, one day apart, so it can read as if it came before the order. M001 M024 A later note claims he came back at 7 a.m. the next morning to take photos and issue the order, M024 but the file contains no photo of this property from that day. M013 None of this lined up until the owner’s representative pulled the records from several separate public-records requests — including photo lists from unrelated cases — and set the camera’s frame numbers side by side. R.25-3549 R.26-1549 R.26-1863
Bottom line: on the city’s own paperwork, the only verification of the garage addition was a future-tense note, logged under two dates — and that only became visible once someone forced the records out and lined up the camera’s frame numbers across cases.The single verification the inspector placed on the record as to the garage addition is the re-inspection note M001: “I did verify there is an addition to the detached garage going on… I took pictures of what I saw from where I was standing. A N&O will be requested.” “Will be requested” is future tense — by the inspector’s own pen the order had not yet issued when this verification was recorded. The only photographs behind it are the last frames of the inspector’s route that day, sequentially after frames the same camera captured the same day at three other Sacramento properties R.26-1863. The same neighbor-verification narrative was then entered into the produced file under two different dates M001 M024.
Before a city can charge a property owner for unpermitted work, an inspector must actually verify the work and document what was found. SCC §8.100.700 SCC §8.100.720 Here the inspector’s only verification of the garage addition states “A N&O will be requested” — future tense — meaning the order had not yet been written when the verification was recorded M001. The only photographs tied to that note are the highest frame numbers on the camera that day M013; the frames immediately preceding them were taken at three other Sacramento properties the same morning R.26-1863. The identical neighbor-verification narrative appears under two different dates M001 M024. A later note claims the inspector returned at 7 a.m. the next morning to take photos and issue the order, yet the produced file contains no photograph of 4880 T Street dated 04/11/2023 M013. These contradictions became visible only after the owner’s representative obtained and aligned the frame-number sequences across multiple CPRA productions. R.25-3549 R.26-1549
The re-inspection entry in the Activities log ends “A N&O will be requested.” M001 It is the only inspector-authored verification of the garage addition in the produced file; the later 2025 violation and permit narratives M024 describe garage construction in general terms and never restate this verification. The phrase is unambiguous: when the inspector wrote it, the order was still a future event. SCC §8.100.700 SCC §8.100.720
The only photographs of the addition — IMG_1492(1) and IMG_1493, “View from neighbors lot of work performed,” dated 04/10/2023 M013 — carry the highest frame numbers of the inspector’s 04/10 route. The same camera also captured three earlier 04/10/2023 frames at 4880 T Street — IMG_1372 (“View of detached garage from front of dwelling”), IMG_1373 (“Entry to dwelling”), IMG_1374 (“Card left at site”) M013 — reflecting a morning visit, with the neighbor-lot frames taken at the 3:00 pm meeting the 04/07 phone note had scheduled. M024 The neighbor-lot frames’ monotonic numbers fall sequentially after photographs the same camera captured the same day at three other Sacramento properties, produced cross-case under one NextRequest export R.26-1863: 5081 10th Ave, Case 23-000633 (IMG_1483.jpg, 04/10/2023, “Front of dwelling”) 23-000633; 2916 La Solidad Way, Case 23-000351 (IMG_1484.jpg, 04/10/2023) 23-000351; and 7311 Krishna Dr, Case 23-007617 (IMG_1486–1489, 04/10/2023, “Beds in sunroom” / “Signs someone is living in garage”). 23-007617 The frame numbers are camera-assigned and run in monotonic sequence across four separate cases the same day; the order of the route is fixed by the City’s own cross-case production, not by argument.
The identical neighbor-verification narrative appears in the produced file under two different dates: dated 04/10/2023 in the Activities log M001 and dated 04/11/2023 in the Notes section M024. The phone-call note records the neighbor meeting as scheduled for 04/10/2023 M024 — consistent with the Activities log date and inconsistent with the Notes date. The duplication allows the one existing verification note to appear to straddle two dates, lending ambiguity to when the verification was actually recorded.
The 04/11/2023 case note M024 reads:
“7:00 am. I arrived to SFR to take photos and update case files. Due to lack of contact from the Owner and failure to obtain an HDB permit I issued the Notice and Order.” M024 — General Case Note, 04/11/2023
No photographs of 4880 T Street dated 04/11/2023 appear anywhere in the produced file. M013 R.26-1965 The note asserts a 7 a.m. photo visit to the property; the documents index records no such photograph. GC §7920.000
The only garage-addition verification is the re-inspection note M001, which speaks of the order in the future tense; the photographs behind it are the closing frames of a multi-property route, established by the cross-case production R.26-1863 23-000633 23-000351 23-007617; the same narrative was logged under two dates M001 M024; and the 04/11 case note that places a photo-taking visit before issuance M024 is unsupported by any 04/11 photograph. M013
The strongest realistic City response is that the 04/10 observation verified the addition, and the order properly followed it. The City’s record cannot be reconciled from either direction. Stand on the 04/11 case note — “7:00 am. I arrived to SFR to take photos… I issued the Notice and Order” M024 — and the file holds no photograph of the property dated 04/11/2023 to support it. M013 Stand instead on the only photographs that exist — the 04/10 frames — and they are the closing shots of a multi-property route M013 R.26-1863, taken after the verification note had already recited the order in the future tense. M001 The frame numbers are camera-assigned and run in sequence across four separate cases the same day, so the order of the route is established by the City’s own cross-case production, not by argument. Either way, the City cannot support its own 04/11 “I arrived to SFR to take photos… I issued the Notice and Order” note without producing a 04/11 photograph its closed-as-complete production does not contain. M013 M124 Card 47