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Susan Brandt-Hawley/SBN 75907

BRANDT-HAWLEY LAW GROUP
P.O. Box 1659
Glen Ellen, CA 95442
707.938.3900, fax 707.938.3200
susanbh@preservationlawyers.com
Attorneys for Petitioner
Protect Telegraph Hill

SUPERIOR COURT OF THE STATE OF CALIFORNIA

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FOR THE COUNTY OF SAN FRANCISCO

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Petitioner,

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Case No. CPF-14-514060

Protect Telegraph Hill,

an unincorporated association;

v.
City and County of San Francisco;
Board of Supervisors of the City
and County of San Francisco,
and Does 1 to 5;
Respondents.
_____________________________/

Reply Brief in support of

Petition for
Writ of Mandamus
Hearing Date: November 19, 2015
Time:
1:30 p.m.
Dept:
503

Jeremy Ricks, Tracy Kirkham,

and Joe Cooper, and Does 6 to 10;

Hon. Teri L. Jackson

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Real Parties in Interest.

_____________________________/

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____________________________________________________________________________________________________

Reply Brief in support of Petition for Writ of Mandamus

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Table of Contents

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Introduction ................................................................................................................. 1
Discussion ................................................................................................................... 2

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A. Unusual Circumstances and Significant Environmental Impacts

Qualify for an Exception to the Projects Categorical Exemptions ..................... 2

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The Project Impairs Protected Public Views ................................................. 2

Other Unusual Circumstances and Environmental Impacts
Defeat the Categorical Exemptions .............................................................. 7

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B. Adoption of Mitigation Precludes the Categorical Exemptions .......................... 9

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Conclusion ........................................................................................................................ 15

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Table of Authorities

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Case Law

Page

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Berkeley Hillside Preservation v. City of Berkeley (Berkeley Hillside 1) (2015)

60 Cal.4th 1086.......................................................................................... 2, 7, 8
Berkeley Hillside Preservation v. City of Berkeley (Berkeley Hillside 2) (2015)
___ Cal.App.4th ___ ........................................................................................ 14
Lotus v. Department of Transportation (2014)
223 Cal.App.4th 645 ....................................................................................... 11
Salmon Protection and Watershed Network v. County of Marin (2004)
125 Cal.App.4th 1098 ...................................................................................... 14
Stanislaus Natural Heritage Project v. County of Stanislaus (1996)
48 Cal.App.4th 182 .......................................................................................... 12
____________________________________________________________________________________________________

Table of Contents and Authorities

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Sundstrom v. County of Mendocino (1988)

202 Cal.3d 296................................................................................................ 12
Wollmer v. City of Berkeley (2011)
193 Cal.App.4th 1329 ..................................................................................... 14

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CEQA Guidelines
15300.2 (c) .................................................................................................................... 3

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15370 ...................................................................................................................... 11
Appendix G ................................................................................................................... 2

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San Francisco Planning Code

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101.1(b) ............................................................................................................ passim

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____________________________________________________________________________________________________

Table of Contents and Authorities

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Introduction
Ive lived four doors down from this property since 1977. And its a
magical spot. Its really a quasi-public piece of property I walk down
those steps on a daily basis and I see hundreds of thousands of tourists
a year in a rather romantic spot taking pictures of the city. The way this
massive project is, it not only takes the views away, it takes the light
away . . . (Administrative Record (AR):1051 [Peter Dwares].)

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Petitioner Protect Telegraph Hill has met its burden of proof. Upon the fair
application of the facts to the law, the City should not have approved the luxury
condominium project at 115 Telegraph Hill Boulevard without environmental review.

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Issuance of a conditional use permit is also insupportable in light of impacts to public

vistas from Pioneer Park, in violation of the Citys Planning Code.
Mandates of the California Environmental Quality Act and the Citys General
Plan and Planning Code protect Telegraph Hill and Pioneer Park for the benefit of the

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people of San Francisco and enthralled visitors from around the world. This Courts
peremptory writ will enforce those mandates in the public interest.
Protect Telegraph Hill respectfully requests judgment and a writ setting aside
the categorical exemption and the project approval. The City may again exercise its
discretionary land use authority after complying with CEQA and the Planning Code.

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Discussion
Protect Telegraph Hill continues to substantially rely on its opening brief, and
in this reply will necessarily focus on matters that most warrant further clarification

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and response in limited space. The facts fully support this Courts peremptory writ

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setting aside the categorical exemption and conditional use permit.

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Reply Brief in support of Petition for Writ of Mandamus

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A.

Unusual Circumstances and Significant Environmental Impacts

Qualify for an Exception to the Projects Categorical Exemptions

The Project Impairs Protected Public Views. Impairment of public views from
Pioneer Park is of great import not just because of the stand-alone aesthetic and visual

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impacts, but because in San Francisco a project that blocks vistas from a public park

violates the Planning Code and adopted land use plans. (Opening Brief, pp. 20-22.)

Appendix G of the CEQA Guidelines [14 Cal.Code Regs, 15000 et seq.] Section X,

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subd.(b), identifies land use conflicts as significant environmental impacts:

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Would the project conflict with any applicable land use plan, policy, or regulation

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of an agency (including, but not limited to the general plan, specific plan, local

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coastal program, or zoning ordinance) adopted for the purpose of avoiding or

mitigating an environmental effect?
The City fully concedes that Planning Code Section 101.1 mandates that City parks
and their access to vistas be protected from development. (City Brief, p. 10, italics

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added; AR:1881.) Any conflict with Section 101.1 is both a significant environmental

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impact and an unusual circumstance that defeats categorical exemption.

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And that is the case.

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The City ackowledges that Berkeley Hillside Preservation v. City of Berkeley

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(Berkeley Hillside 1) (2015) 60 Cal.4th 1086 addresses the unusual circumstances

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exception to categorical exemptions and holds that proof that a project will (rather

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than may) have a significant effect makes that project unusual. (Id., p. 1103, Opening

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Brief, p. 18, City Brief, pp. 7-8 .) That evidence, if convincing, necessarily also

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establishes that an activity will have a significant effect on the environment due to
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Reply Brief in support of Petition for Writ of Mandamus

unusual circumstances. (Ibid.) This meets both of the two steps required to defeat a

categorical exemption. (Ibid.) Thus, an administrative record proving that a project will

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have a significant impact based on a conflict with a mandatory provision in a land use

plan also proves unusual circumstance defeating the use of a categorical exemption

under the unusual circumstances exception. (Guidelines, 15300.2, subd.(c).)

The parties agree on the law applicable to exception to categorical exemptions.

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But they offer diametrically-opposed answers to the big question: Would the luxury

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condominiums proposed at 115 Telegraph Hill Boulevard significantly impair

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sweeping views of San Francisco from Pioneer Park?

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The City says no. Petitioner Protect Telegraph Hill says yes. In this

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circumstance, the Court may find a site visit accompanied by counsel to be fruitful.

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The site is well known to the Citys staff and decisionmakers and is thus arguably part of

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the record as it is known by the City. The famous vista is also subject to judicial notice.

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Why debate the presence or absence of a view when the clear answer is a short drive

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away? The Court can see, like thousands of other visitors, the spectacular view of

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downtown San Francisco from Pioneer Park directly through the project site.

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Yet the City continues to deny that the 115 Telegraph Hill Boulevard project

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would impair views from Pioneer Park. Its opposition brief attempts to refute claims of

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blocked park vistas and related significant environmental impacts (City Brief, pp.10-

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12), or unusual circumstances relative to City policies regarding protection of public

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views (City Brief, pp. 15-16), or, by reference, violation of General Plan and planning

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policies also essential to issuance of a conditional use permit. (Id., p. 24.)

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Reply Brief in support of Petition for Writ of Mandamus

But the City offers only circular, conclusory statements to support its insistence

that vistas from Pioneer Park would not be impaired by the projects mass and height,

and these do not rise to the level of substantial evidence:

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[T]here is no significant impact on public views because, as the Planning

Commission found, the Project does not obstruct public views. (City Brief, p. 10.)

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The project will not adversely affect any public parks It is located below

Coit Tower and Pioneer Park on Telegraph Hill, and will incorporate green rooftops to

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ensure that the Project blends with the hillside when viewed from above. (City Brief,

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pp. 10, 15-16, citing AR:12, 14.)

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The City argues that a diagram copied in the opening brief at page 22 (AR:1931)
ironically proves that the project does not obstruct public views from Pioneer Park,
but only from the Filbert Steps. (City Brief, p. 10). The City misinterprets the diagram,
as explained below, post, p. 6.)

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The City points out that at the Board of Supervisors, when asked if the Project

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violated General Plan policies intended to protect public views, Department staff

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concluded that the General Plan does protect views from public vistas but it is

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our opinion that both Pioneer Park and Coit Towers views of downtown are not being

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obstructed by this Project because the project is similar in height to adjacent buildings
and progresses down the hill. (City Brief, p. 11, citing AR:1079.)
Petitioner Protect Telegraph Hill, on the other hand, spent much of its opening
brief directing the Court to photographs and graphic evidence and substantial first-

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hand testimony in the record proving (1) that sweeping southern views from the stairs

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and landings in Pioneer Park are enjoyed and treasured by residents and tourists, and

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Reply Brief in support of Petition for Writ of Mandamus

(2) that the views would be substantially impaired by the project. (Opening Brief,

passim.) It is not relevant to the question of blocked views that the building adjacent to

the project site is of similar height.

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Additional evidence throughout the record includes the public hearing transcripts

before the Citys Planning Commission and Board of Supervisors. (E.g., AR:783-1125.)

Protect Telegraph Hill regrets that it cannot here describe for the Court all of the

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compelling, richly-textured first-hand testimony and reports in the record regarding the

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projects impacts to iconic public vistas and other environmental issues relevant to the

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projects design and location. The Court is instead respectfully referred to the Board of

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Supervisors hearing transcript from November 2014, in particular, for a capsulization

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of key issues from all sides. (AR:1016-1125.)

The City relies on a photo of the vista looking south from Coit Tower, with the
project site shown in red in the foreground. (AR:261.) The project admittedly does not
block this elevated view; this is the apparent basis for the Citys opinions that the
project is below Coit Tower and would blend into the vista. (Ante, p. 4.)
It is not the view from the top of Coit Tower that is at issue. Testimony
throughout the record addresses the much more accessible and widely-enjoyed public

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views from the Pioneer Park stairs and lower landing, apparent in photographs in the

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opening brief. (Opening Brief, pp. 3-4.) One relevant drawing by the project architect

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depicts both the unobstructed view from the top of Coit Tower and [as altered by

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project opponents to add dashed lines and descriptive text] how and where public views

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are blocked from southern stairs & landings in Pioneer Park:

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Reply Brief in support of Petition for Writ of Mandamus

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(AR:1931, Opening Brief, p. 22.) This is the graphic that the City finds ironic and relies

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on as proof that the project would not obstruct public views from Coit Tower or Pioneer

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Park, but might only partially block some views from the Filbert Steps unprotected by

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the Planning Code because they are not in a park. (City Brief, p. 10, ante, p. 4.)
The dashed lines on the drawing show the sightline not from the Filbert Steps
but, from the southern stairways and landings in Pioneer Park that would be directly
blocked by the height and mass of the project. (AR:1931.) These face the wide City vista,

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as depicted in other photographs in the record. (E.g., AR:27, Opening Brief, p. 3.)
As mentioned in the opening brief, over the last two decades Telegraph Hill
residents funded and designed the rebuilding of the Pioneer Park stairways and
landings, including the subject stairway and landing leading down to the Filbert Steps.

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(Opening Brief, pp. 4-5, AR:2007.) Involved local architect, F. Joseph Butler, AIA,

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noted that the Citys Urban Master Plan calls for the retention of scenic vistas from

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public parks. (AR:2007.) He explained that [T]he stair to Filbert Street was

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Reply Brief in support of Petition for Writ of Mandamus

designed to take advantage of the view. (AR:2007.) At a meeting with the project

applicants in 2012, Mr. Butler and others urged that they design their condominiums to

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preserve public vistas, but instead the project changed for the worse. (Ibid.)
The local Telegraph Hill Dwellers also provided two photographic depictions of

the view from one portion of the Pioneer Park steps both with and without the project.

A third photograph depicts an alternate project design proposed to allow the project to

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be built while providing an 18 foot view corridor to partially mitigate the project

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impacts. (AR:1933 [current vista], 1935 [vista with project], 1936 [a rejected

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compromise proposal].) While small-scale photographs cannot do justice to the view

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from the park, the blocking of the vista by the proposed project is undeniable.

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In sum: the proposed project will not protect widely-enjoyed public

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vistas from the Pioneer Park stairs and landing and thus will conflict with

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the Planning Code: the City has offered no substantial evidence to the

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contrary. Under the direction of the Supreme Court in Berkeley Hillside 1, this is both

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an unusual project circumstance and a significant environmental impact. The unusual

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circumstances exception to the claim of categorical exemption is thus met.

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A peremptory writ should issue to set aside the categorical exemption and require

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the City to set aside the project approval and prepare an Initial Study and appropriate
environmental document before further consideration.
As explained in the opening brief, the violation of the Planning Code also requires
that the conditional use permit be set aside as part of the writ. (Opening Brief, p. 25.)

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Reply Brief in support of Petition for Writ of Mandamus

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Other Unusual Circumstances and Environmental Impacts Defeat the

Categorical Exemption. The opening brief describes, and the record proves, the

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unusual nature of pedestrian and vehicle traffic on narrow, winding Telegraph Hill

Boulevard due to the many thousands of residents and tourists visiting Pioneer Park

and Coit Tower. Yet the Citys overarching, untenable approach to this case is to

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portray the project site as ordinary and to assure the Court that any environmental
impacts will be adequately addressed by the routine application of building codes,
transportation guidelines, and geotechnical review practices by its development staff.
For example, the City contends that the project location adjacent to a sensitive

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intersection, on a curvy road, near a transit stop, a pedestrian crosswalk, and a stop

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sign, in an area frequented by tourists is not unusual but is common. (City Brief,

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p. 14.) The City further contends that [n]o two locations are exactly alike, and many are

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near notable scenic or historic sites. (City Brief, p. 14.) Locating a driveway near the

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subject intersection is not unusual because all sidewalks in San Francisco are in fact

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pedestrian facilities; therefore all driveways in the City cross the pedestrian right of

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way. (Ibid.) Under such logic, no City project would warrant CEQA review.

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The fact that no two sites are the same and that urban sidewalks, streets, and

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driveways abound fails to account for the Supreme Courts references in Berkeley

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Hillside 1, supra, 60 Cal.4th 1086, to size and location as features that may qualify as

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unusual circumstances within a categorical exemption class. (Id., p. 1105.) Protect

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Telegraph Hill respectfully refers the Court to its prior discussion of pedestrian and
vehicle traffic and topography/geotechnical issues, upon which it continues to rely.
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Reply Brief in support of Petition for Writ of Mandamus

(Opening Brief, pp. 19-25.) The Citys reliance on future study of traffic and

geotechnical issues out of any public process fails to adequately describe the actual

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project and precludes exemption for that reason as well.

B.

Adoption of Mitigation Precludes the Categorical Exemptions

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The City contends that what petitioner Protect Telegraph Hill describes as

mitigation measures that preclude categorical exemption are just generally applicable

regulations and run-of-the-mill conditions on a project approval that have nothing to

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do with CEQA compliance. (City Brief, pp. 17, 23.) As with its conclusory statements
denying the [obvious] views from Pioneer Park, saying so does not make it true.
Protect Telegraph Hill will not repeat all of the opening briefs discussion of
mitigation measures, and continues to rely on its earlier analysis. (Opening Brief, pp.

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10-15.) This reply will focus on issues relating to Garfield Elementary School that easily

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illustrate how project-specific mitigations defeat the use of a categorical exemption.

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The school representatives grave concerns about project impacts surfaced for

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the first time at the CEQA hearing before the Board of Supervisors, as the school had

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just become aware of the project a few days prior. The school principal [Jason Owens],

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the Chief Facility Officer for the San Francisco Unified School District [David Golden],

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and San Francisco Board of Education Commissioner [Sandra Lee Fewer on behalf of

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the San Francisco Board of Education] all testified that due to the projects scope and

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unaddressed environmental issues, a CEQA process rather than a categorical exemption

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should address traffic safety, noise, air quality, and dust affecting the school. (Opening

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Reply Brief in support of Petition for Writ of Mandamus

Brief, p. 13.) As Principal Owens explained,

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Garfield Elementary School [is] located on a really steep slope.

Its so steep that normal school buses cannot make it to our school

The developer intends to pump concrete from this location up to the project

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site further up the Filbert Steps. This will take several months, entail
countless truck trips, [and] will have significant noise, pollution, safety,
and accessibility issues to the entire Garfield School community
The project should not have been exempted from environmental review
I respectfully urge you to require environmental analysis
(AR:1044-1045; Opening Brief, pp. 1, 5 [photo], 13-15.) Following some discussion, the

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project applicants attorney acknowledged that the project had indeed been amended

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to get concrete trucks off of Telegraph Hill Boulevard and improve the situation

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there. (AR:1091, italics added.) At the close of the hearing at the Board of Supervisors,

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the Board directed the applicant to consult with Garfield School and the School District

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regarding construction staging, traffic, and truck route plans. New project

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restrictions and conditions were added to the project approval to comply with that

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direction, and are attached to the opening brief. (Opening Brief, p. 14, AR:1117-1121.)

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Whether the adopted measures to protect Garfield School are called restrictions

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or conditions or mitigations is not dispositive; as in many things in life, the substance

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rather than the label is what is important. The Supervisors point in requiring the

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measures (and the Planning Commissions point in adopting others) was to reduce

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significant project-related environmental impacts. In CEQA parlance, that is

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mitigation; avoiding, minimizing, rectifying, reducing, or eliminating impacts, or

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Reply Brief in support of Petition for Writ of Mandamus

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compensating. (Opening Brief, p. 15; CEQA Guidelines, 15370.)

As explained in Lotus v. Department of Transportation (2014) 223 Cal.App.4th
645, p.656, n.8, project conditions are elements of a project whereas mitigations are

adopted to reduce environmental impacts. (Opening Brief, pp. 11-12.) The intent of the

new school-related traffic measures is unequivocal: to deal with environmental impacts

of this particular project in its constrained, unusual, particular setting.

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This is not just a gotcha to defeat the categorical exemption, there is a very real

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problem: the project has been approved without environmental review. We do not

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know, and the Board of Supervisors does not know, and the public and the Garfield

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School students, parents, faculty, and school administrator do not know, what the

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actual mitigation might be for impacts to the school both in session and while students

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and faculty are in transit, and whether it will be effective, or sufficient, or will in turn

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cause additional unstudied environmental impacts.

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The fact that the construction staging was moved from Telegraph Hill Boulevard

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to Garfield School illustrates the problems created when mitigation measures are

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adopted for a project that is approved with a categorical exemption rather than an

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environmental review process with public comment. Mitigation measures can have

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their own impacts, as happened in this case when the concrete truck staging was moved
away from Telegraph Hill Boulevard to improve the situation there. (Ante, p. 11.)
That is why during CEQA review a deferral of identification of mitigation
measures to future study triggers preparation of an EIR: if mitigation remains

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uncertain there is no support for a finding that a significant impact has been mitigated
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Reply Brief in support of Petition for Writ of Mandamus

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to a less than significant level. (E.g., Sundstrom v. County of Mendocino (1988) 202

Cal.App.3d 296.) The courts have long held that agencies should not use mitigation

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measures as a device to avoid disclosing project impacts in an appropriate CEQA

process. (E.g., Stanislaus Natural Heritage Project v. County of Stanislaus (1996) 48

Cal.App.4th 182, pp. 195-196.)

In the negative declaration and EIR framework, deferred mitigation is only

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allowed when there are enforceable performance standards. For categorical

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exemptions, mitigation is not allowed at all. The whole point of the streamlined

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categorical exemption process for minor projects is the presumption of no significant

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environmental impact so that there is no need either for mitigation or, obviously, for

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performance standards for that non-existent mitigation. This case thus presents a

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double legal problem: the City adopted mitigation measures [both for Garfield School

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and for other traffic and geotechnical impacts] with their specifics deferred to future

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study without any performance standards or public process.

This project proposes concrete truck staging at Garfield School in order to pump
concrete up steep Telegraph Hill to the project site. The City can call the special
mitigations for the concrete trucks run-of-the-mill project conditions, and pretend

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that adopting those mitigations seconds after finalizing the categorical exemption

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somehow takes them out of the realm of CEQA, but that does not change the facts.

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Similarly, the contention that the project as originally proposed would have no

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significant environmental effects due to compliance with state and local laws does not

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address the newly-added mitigation measures, including but not limited to those for
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Reply Brief in support of Petition for Writ of Mandamus

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Garfield School added by the Board of Supervisors, and does not support the categorical

exemption. (City Brief, p. 18, italics added.)

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The City contends that the Garfield School conditions were simply a more

specific articulation of the internal City SFMTA Blue Book requirements to provide

advance notice of construction activities to administrators at adjacent schools and to

make arrangements with school officials to maintain passenger and school bus

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loading zones. (City Brief, p. 19.) A look at the actual adopted special restriction goes

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further than requiring notice of activities and arrangements for loading zones per the

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Blue Book. It requires consultation with Garfield, the San Francisco Unified School

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District, nearby residents in identified blocks, and City Planning Staff

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before finalizing the construction staging, traffic and truck route plans,
including (a) a schedule of delivery times and dates during which
construction materials are expected to arrive and (b) the methods to be
used to monitor truck movement onto and out of the building site so as
to minimize traffic and pedestrian conflicts on Telegraph Hill Boulevard,
Filbert Street and Kearny Street.
(AR:61.3, attached to Opening Brief.)
The City also added a condition requiring a parabolic mirror and signs at the

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project driveway. (City Brief, p. 5, AR: 404-409.) It discounts the mitigation, although

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admittedly not a standard SFMTA Blue Book item, by relying on Wollmer v. City of

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Berkeley (2011) 193 Cal.App.4th 1329. (City Brief, p. 20.) However, the positive effort

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to improve the project for the benefit of the community in the Wollmer case involved a

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left turn lane that was at the Citys highest priority for intersection improvements due
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Reply Brief in support of Petition for Writ of Mandamus

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to existing pre-project problems. (Id., p. 1353.) Here, the reason for the mirror and

signage are project-specific. As described by the City, they must aid drivers exiting the

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Projects driveway and warn[]pedestrians of the driveway crossing. (City Brief, p.20.)
Without the project, there is no driveway and no need for the mirror or signage.
The Garfield School concrete staging and the projects new-driveway mitigations
are not similar to the already-desired turn lane in Wollmer, but are akin to Salmon

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Protection & Watershed Network v. County of Marin (2004) 125 Cal.App.4th 1098,
where reliance on mitigation measures defeated categorical exemption. (Id., p. 1108.)
Finally, the First Districts opinion in Berkeley Hillside Preservation v. City of
Berkeley (Berkeley 2) (2015) __Cal.App.4th __, on remand from the California

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Supreme Court, also addresses mitigation measures for a residential project approved

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on a categorical exemption. A construction management traffic plan was represented as

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standard for the Berkeley Hills area. (Slip Opinion, p. 17.) The Court held that the plan

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was a common and typical concern in any urban area and upheld exemption. (Id., p.

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19.) The Courts ruling is fact-driven, without reference to any special considerations

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such as are here presented by the unstudied impacts of a concrete truck staging area at

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an elementary school already constrained by the steep narrow roads of Telegraph Hill.

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Public environmental review of those mitigations will ensure their adequacy and
enforceability; categorical exemption is precluded and a writ should issue .

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____________________________________________________________________________________________________

Reply Brief in support of Petition for Writ of Mandamus

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Conclusion

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In this case, more than in most environmental mandamus cases, petitioner looks

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forward to the mandamus hearing in which to review this record with Court.
This reply has focused on the simplest issues in this action. The City has not
provided any substantial evidence to counter the fact that the project conflicts with the
San Francisco Planning Code mandate that vistas from public parks must be protected.
The City does not address the view from the southern steps and landing at Pioneer Park
at all. Since Protect Telegraph Hill has proven that the project will conflict with a land
use plan provision designed to protect the environment, under the applicable case law

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it has proven both an unusual circumstance and a significant environmental impact.

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Categorical exemption is therefore disallowed under the unusual circumstances

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exception. The adoption of mitigation measures also precludes categorical exemption.

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As discussed throughout the opening brief and the record, there are many other

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grounds upon which a writ may issue, including the fact that the conditional use permit
cannot be approved due to the same violation of the public vista protection for parks.
The site at 115 Telegraph Hill Boulevard is deserving of this Courts enforcement
of CEQA and of the Citys own Code and plans to protect Telegraph Hill and Pioneer

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Park for City citizens and its appreciative visitors. Protect Telegraph Hill respectfully

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requests that the Court issue judgment and a peremptory writ in the public interest.

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October 29 , 2015

Respectfully submitted,
Susan Brandt-Hawley
Attorney for Protect Telegraph Hill

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____________________________________________________________________________________________________

Reply Brief in support of Petition for Writ of Mandamus

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Protect Telegraph Hill v. City of San Francisco, et al.

San Francisco County Superior Court Case No. CPF-14-514060

PROOF OF SERVICE
I am a citizen of the United States and a resident of the County of Sonoma.
I am over the age of eighteen years and not a party to this action. My business
address is P.O. Box 1659, Glen Ellen, California 95442.
On October 29, 2015, I served one true copy of:

Reply Brief in Support of Petition for Writ of Mandamus

x

By emailing a copy to counsel as noted below.

Andrea Ruiz Esquide
Office of the City Attorney
1 Dr. Carlton B. Goodlett Place
Room 234
San Francisco CA 94102-4682

Attorney for Respondents

andrea.ruiz-esquide@sfgov.org
Daniel Frattin
James Reuben
Reuben & Junius LLP
1 Bush Street
6th Floor
San Francisco CA 94104

Attorney for Real Parties

in Interest

dfrattin@reubenlaw.com
jreuben@reubenlaw.com
I declare under penalty of perjury that the foregoing is true and correct and
is executed on October 29, 2015, at Glen Ellen, California.

Susan Brandt-Hawley