Loading...
HomeMy WebLinkAbout21CV-0734 - Demurrer Filed - After 1st Appearance_to First Amended Petition1 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612JEFFREY V. DUNN, Bar No. 131926 jeffrey. dunn@bbklaw.com DANIEL L. RICHARDS, Bar No. 315552 daniel.richards@bbklaw. com BEST BEST & KRIEGER LLP 18101 Von Karman Avenue Suite 1000 Irvine, California 92612 Telephone: (949) 263-2600 Facsimile: (949) 260-0972 CHRISTINE DIETRICK, Bar No. 206539 cdietrick@slocity.org CITY OF SAN LUIS OBISPO CITY ATTORNEY’S OFFICE Attorneys for Defendants and Respondents City of San Luis Obispo and City Council of and for the City of San Luis Obispo EXEMPT FROM FILING FEES PURSUANT TO GOVERNMENT CODE SECTION 6103 SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN LUIS OBISPO NHC SLO, LLC,Petitioner and Plaintiff, v. CITY OF SAN LUIS OBISPO; CITY COUNCIL OF AND FOR THE CITY OF SAN LUIS OBISPO; AND DOES 1-10, INCLUSIVE, Defendants and Respondents. Case No. 21CV-0734 Judge: Rita Federman CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER TO FIRST AMENDED PETITION AND DEMURRER TO FIRST AMENDED PETITION Filed concurrently with: 1. Request for Judicial Notice. 2. Declaration of Daniel Richards, and 3. Proposed Order] Date: December 29, 2022 Time: 9: 00 a.m. Dept.: 2 Action Filed: 2 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612NOTICE OF DEMURRER TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on December 29, 2022, at 9:00 a.m., or as soon thereafter as the matter may be heard in Department 2 of the above-entitled court, located at 1050 Monterey Street, San Luis Obispo, California 93408, Respondents City of San Luis Obispo and City Council of and for the City of San Luis Obispo will and hereby does demur to the First Amended Petition of Petitioner NHC SLO, LLC. The demurrer is brought on the grounds that the first (and only) cause of action fails to state facts sufficient to constitute a cause of action. The Demurrer is based upon this Notice, the Demurrer, the accompanying Memorandum of Points and Authorities, the concurrently filed Declaration of Daniel L. Richards, the concurrently filed Request for Judicial Notice, all papers and records on file in this action, and on such other matters as the court may consider at the time of the hearing. This demurrer follows a conference of counsel that was held on August 10, 2022. Declaration of Daniel L. Richards [“Richards Decl.”] at ¶ 11.) Dated: August 16, 2022 BEST BEST & KRIEGER LLP By: JEFFREY V. DUNN DANIEL L. RICHARDS Attorneys for Defendants and Respondents City of San Luis Obispo and 3 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612DEMURRER Respondents City of San Luis Obispo and City Council of and for the City of San Luis Obispo will and hereby do demur to Petitioner’s First Amended Petition pursuant to Code of Civil Procedure § 430.10 and § 430.30. This demurrer is made on the following grounds: DEMURRER TO FIRST CAUSE OF ACTION 1. The First Cause of Action is barred as a matter of law because it fails to state facts sufficient to constitute a cause of action. (Code Civ. Proc. § 430. 10(e).). Dated: August 16, 2022 BEST BEST & KRIEGER LLP By: JEFFREY V. DUNN DANIEL L. RICHARDS Attorneys for Defendants and Respondents City of San Luis Obispo and 4 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612TABLE OF CONTENTS Page I. INTRODUCTION .............................................................................................................. 7 II. STATEMENT OF FACTS ................................................................................................. 8 A. Helios Dayspring’s Criminal Conduct and NHC’s Misrepresentations ................. 9 1. Spending Money for Illegal Purposes ....................................................... 10 2. Falsification of Documents ....................................................................... 11 3. Perjury ....................................................................................................... 11 4. Tax Fraud and Tax Evasion ...................................................................... 11 B. Falsehoods in NHC’s Cannabis Operator Application ......................................... 11 C. False Statements in Connection with Transfer to Valnette Garcia ....................... 12 D. Subsequent History ............................................................................................... 13 III. LEGAL ARGUMENT ...................................................................................................... 14 A. Standard of Review ............................................................................................... 14 1. NHC’s Disqualification was authorized by the Municipal Code .............. 14 2. NHC’s Disqualification was Authorized by NHC’s Agreement .............. 16 B. NHC has Unclean Hands ...................................................................................... 16 C. NHC’s Claims are Moot ....................................................................................... 18 D. NHC’s Claim for Declaratory Relief Fails............................................................ 19 E. The 5 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612TABLE OF AUTHORITIES Page(s) State Cases Am. Bd. Of Cosm. Surgery v. Med. Bd. Of California (2008) 162 Cal.App.4th 534 ............................................................................................................... 14 Avco Community Developers, Inc. v. South Coast Regional Com. (1976) 17 Cal.3d 785 .......................................................................................................................... 15 Ball v. FleetBoston Fin. Corp. (2008) 164 Cal.App.4th 794 ............................................................................................................... 19 Blain v. Doctor's Co. (1990) 222 Cal. App. 3d 1048 ............................................................................................................ 16 Blumenthal v. Superior Ct. (1980) 103 Cal.App. 3d 317 ................................................................................................................ 16 Breneric Associates v. City of Del Mar ( 1998) 69 Cal.App.4th 166 ................................................................................................................. 14 Brown v. Grimes (2011) 192 Cal. App.4th 265 ............................................................................................................... 17 Carrancho v. Cal. Air Res. Bd. (2003) 111 Cal.App.4th 1255 ............................................................................................................. 14 Chapman v. Superior Court (2005) 130 Cal. App.4th 261 ............................................................................................................... 14 Cilderman v. City of Los Angeles (1998) 67 Cal.App. 4th 1466 ............................................................................................................... 20 City & Cnty. of San Francisco v. Burton (1962) 201 Cal.App.2d 749 ................................................................................................................ 20 Communities for a Better Envt. v. State Water Resources Control Bd. (2003) 109 Cal.App.4th 1089 ............................................................................................................. 14 Cryolife, Inc. v. Superior Court (2003) 110 Cal.App.4th 1145 ............................................................................................................. 14 Goat Hill Tavern v. City of Costa Mesa (1992) 6 Cal. App.4th 1519 ................................................................................................................. 15 Molina v. 6 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE, CALIFORNIA 92612People v. Garner (1977) 72 Cal.App.3d 214 .................................................................................................................. 20 Rakestraw v. California Physicians’ Service (2000) 81 Cal.App.4th 39 ................................................................................................................... 14 San Diego Cty. Dep't of Pub. Welfare v. Superior Ct. (1972) 7 Cal. 3d 1, 496 P.2d 453 ........................................................................................................ 16 Simmons v. Ghaderi (2008) 44 Cal.4th 570 ......................................................................................................................... 16 Federal Statutes 18 U.S.C. § 666(a)(2) ...................................................................................................................... 9 State Statutes Code Civ. Proc. § 1085 ................................................................................................................. 14 Code Civ. Proc. § 1089 ................................................................................................................. 14 Municipal Code § 9.10.070 ......................................................................................... 10, 14, 15, 7 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612MEMORANDUM OF POINTS AND AUTHORITIES I.INTRODUCTION In 2019, NHC SLO, LLC (“Petitioner” or “NHC”), led and owned by its Chief Executive Officer, majority owner (88 percent), sole manager, and primary principal, Helios Dayspring, applied for one of a limited number of Commercial Cannabis Operator Permits (“Cannabis Permit”) in the City of San Luis Obispo (“City”). As the City later learned, NHC and Mr. Dayspring concealed and failed to disclose in the application process – as required – Dayspring’s shocking history of criminal and fraudulent conduct, which included bribing elected officials and committing felony tax evasion. Prior to the public learning of the criminal indictment of Dayspring, but clearly during a period of time that such information was known to Dayspring, he transferred his ownership to his long-time business and romantic partner, Valnette Garcia. It is this transfer that NHC argues precludes the City from terminating a Cannabis Permit originally approved only because of NHC’s and Dayspring’s multiple, knowing, and material misrepresentations and omissions upon which Dayspring actively induced the City to rely on in the application review and contingent permit issuance process. In other words, a permit obtained through fraud.The petition for writ of mandate fails as a matter of law. The City’s Municipal Code expressly warns applicants that misrepresentation and omissions will result in automatic disqualification, and NHC and each of its principals contractually agreed that misrepresentation and omissions would lead to their disqualification and Cannabis Permit nullification. NHC’s representations of Dayspring’s history of legal compliance and his lies in his background check application constitute false or misleading statements and/or omissions of material information. Finally, a writ of mandate is an equitable remedy, and the equities do not favor an order requiring an award of a permit that was procured by fraud to a party with unclean hands, and a permit that would financially benefit Dayspring and his applicant partners and affiliates, despite his bribery of public officials, tax fraud, and fraudulent procurement of a City cannabis permit. NHC has already been given an opportunity to amend its Petition to state a claim, and it is clear that it cannot do so. NHC’ 8 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612and nearly all amendments are not further factual allegations, but only legal arguments that do not cure the insuperable defects in the petition. (See First Amended Petition [“First Amd. Pet.”] at ¶¶ 106–131, 139–141.) Because the legal defects in NHC’s petition cannot be cured by further amendment, the demurrer should be sustained without leave to amend. II.STATEMENT OF FACTS In 2019, NHC applied for one of a limited number of Cannabis Permits available in the City. (First Amd. Pet. Ex. A at NHCSLO000026.) When NHC applied for a Cannabis Permit in 2019, Helios Dayspring was the CEO, majority owner, sole manager, and principal of NHC. (RJN Ex. 3 at p. 2; Ex. 4 at p. 30.) He signed the application submitted by NHC. (RJN Ex. 3 at p. 6.) NHC’ s merits-based application emphasized the expertise, and history of regulatory compliance of Dayspring as a reason why the City should choose NHC to receive one of the limited number of permits. (RJN Ex. 4 at, e.g., p. 12.) On the strength of its application and the representations in that application, NHC was selected as one of the few applicants allowed to move forward in the approval process. The remaining steps included a background check and obtaining a number of other local permits. Notably, NHC’s Cannabis Permit would not become active until “the issuance of a use permit for the commercial cannabis activity.” (First Amd. Pet. Ex. E at NHCSLO000038; RJN Ex. 1.) As the City later learned, however, prior to (and apparently continuing through) the submission of this application and the permitting process, Dayspring engaged in a concealed pattern of fraudulent and criminal conduct – specifically, conduct involving the operation of Mr. Dayspring’ s cannabis enterprises. (First Amd. Pet. Ex. H at NHCSLO00078–107.) Once the City became aware of and conducted its due diligence regarding the significance of these concealments and misrepresentations under the City’s permitting process, the City notified NHC that it was automatically disqualified from activating, obtaining, or holding a Cannabis Permit on October 6, 2021. (First Amd. Pet. Ex. E.) Following an opportunity provided to NHC to review and present any information or argument to the City Manager that NHC deemed relevant, held on October 14th, the City sent a final memorandum of decision affirming the automatic disqualification on October 9 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612the disqualification was NHC’s misrepresentations and omissions and ongoing concealment throughout the City’ s application and permitting process concerning the criminal activities of its CEO, owner, landlord, and principal – Helios Dayspring. NHC’s argument presented by its legal counsel prior to the City’s final determination in the automatic termination and revocation process, and here, is that Dayspring’s interest in NHC was transferred to his fellow applicant and business partner, Valnette Garcia, on October 20, 2020, before knowledge of Dayspring’s various felonies became public knowledge and known to the City. (See, e.g., First Amd. Pet at 4:25–28, id. at ¶ 20, Id. Ex. F at NHCSLO000046.) However, NHC alleges and acknowledges that Dayspring remains the “landlord/property” owner of the building at which NHC hopes to operate, and thus remains in a position to both exercise substantial control over the operation and to benefit financially from NHC’s operation. See, e.g., First Amd. Pet. at p. 4 fn. 2 [Mr. Dayspring . . . has no interest in the cannabis business or permit, other than as a landlord/property owner.”]; ¶ 12 [“[NHC’s] landlord [Dayspring] has spent approximately $4. 1 million dollars building out the retail cannabis facility. . . .”]; ¶¶ 22–23, 61; Id. Ex. H at NHCSLO0000148 [Memorandum signed by Sargeant Chad Pfarr, dated October 8, 2021, memorializing discussion with NHC staff who indicated that they had had numerous recent conversations with Dayspring regarding the cannabis store].) A.Helios Dayspring’s Criminal Conduct and NHC’s Misrepresentations The City’s decision was based in substantial part on the criminal conduct of Dayspring. First, as Dayspring has admitted, he committed federal program bribery, in violation of 18 U.S.C. 666(a)(2). Dayspring committed this felony by bribing an elected County Supervisor repeatedly from 2016 to 2019. In 2017, Dayspring unsuccessfully attempted to bribe another unnamed local mayor. (See First Amd. Pet. Ex. H at NHCSLO00089–97.) From 2014 to 2018, Dayspring admitted that he fraudulently underreported his taxable income by approximately $9,000, 000. (Ibid.) For at least the calendar year 2018, he willfully, knowingly and intentionally submitted a false tax return that was signed under penalty of perjury in other words, Dayspring committed perjury. Despite an obligation to disclose, Dayspring failed to disclose any of this 10 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612NHC’s application or the City’s subsequent extensive background check process during which he was provided ample opportunity to disclose and explain any information pertinent to the application and background process. (RJN Ex. 5.) As the City informed NHC, Municipal Code section 9.10.070(C) provides for automatic disqualification of an applicant if the applicant “made one or more false or misleading statements or omissions in the application process.” ( First Amd. Pet. Ex. E; RJN Ex. 1.) In connection with NHC’s application, NHC also agreed and acknowledged that disqualification and/or nullification would result in the event of false statements or omissions in connection with its application. The Cannabis Permit Application, signed by Dayspring on behalf of NHC, provided: “Applicants providing false or misleading information in the permitting process will result in rejection of the application and/or nullification of any issued permit.” (RJN Ex. 3 at p. 6 [emphasis added].) On May 19, 2019, Dayspring submitted a signed cannabis background check questionnaire. When signing this background check questionnaire, Dayspring acknowledged: I acknowledge that by signing the documents contained in this Background Package, that all information that I have provided is true and correct. I acknowledge that any information omitted, not disclosed, or found to be false is subject to disqualification for a Cannabis Business Operator Permit. RJN Ex. 5 at p. 2.) As part of this questionnaire, Dayspring was asked whether he had engaged in a variety of illegal conduct. In a subsequent interview with Detective Suzie Walsh, he was asked a number of follow up questions. The City determined following public disclosure of Dayspring’s criminal pleas, that Dayspring made, at least, the following false or misleading statements or omissions: ( Id. at pp. 4–6.) 1.Spending Money for Illegal Purposes Dayspring was asked whether he had ever “spent money for illegal purposes.” He checked the “yes” box. (Id. at p. 4.) At his subsequent police interview, Dayspring clarified that this affirmative answer was only a reference to illegal purchases of marijuana before it was legal to purchase in California. He did not, either in response to the written question, or in response to verbal follow up questioning, disclose the criminal misconduct that was the basis of his federal plea agreement. 11 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612false and misleading statements and omissions and that Dayspring spent money for the illegal purpose of bribing an official. (First Amd. Pet. Ex. H at NHCSLO000065–66.) 2.Falsification of Documents Dayspring was asked whether he had ever engaged in “forgery,” which was explained by the questionnaire to include, for purpose of the questionnaire, “falsifying any type of document.” He checked the “no” box.” (RJN Ex. 5 at p. 6.) The City determined that the response to the questionnaire constitutes a false statement and that Dayspring committed forgery, as the term was used in the questionnaire, by falsifying his tax returns. (Pet. Ex. H at NHCSLO000066.) Additionally, and as a separate and independent ground for disqualification, the City found that any monies retained or gained by Dayspring as the result of his fraudulent and/or underreported taxes, if spent for any purpose other than the payment of taxes as required, would also constitute an illegal expenditure of money by Dayspring. (Ibid.) 3.Perjury In reviewing the application/background forms, the City also noted that Dayspring was asked whether he had ever committed perjury. He checked the “no” box. (RJN Ex. 5 at p. 6.) The City found that was a false or misleading statement or omission. Dayspring pled guilty to submitting intentionally false and fraudulent tax returns signed under penalty of perjury, acts which constitute perjury. (First Amd. Pet. Ex. H at NHCSLO000066.) 4.Tax Fraud and Tax Evasion Dayspring was asked whether he had been involved “in any matter regarding a tax lien, tax fraud, or evasion of taxes.” He checked the “no” box. (RJN Ex. 5 at p. 7.) The City found that this statement constitutes a false or misleading statement or omission. Dayspring had committed tax fraud and tax evasion in 2014, 2015, 2016, 2017, and 2018, as evidenced by his federal plea agreement. (First Amd. Pet. Ex. H. at NHCSLO000066–68.) B.Falsehoods in NHC’s Cannabis Operator Application The City also determined that NHC made a series of false or misleading statements in its merit-based Cannabis Business Operators 12 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612Dayspring had a history of regulatory compliance, and compliance with taxation laws. (RJN Ex. 4 at p. 12.) The City found this to be a false or misleading statement and that “Helios Dayspring” had not “compl[ied] with all tax laws.” (First Amd. Pet. Ex. H at NHCSLO000068.) The City also found that NHC’s omissions concerning the criminal conduct of Dayspring were misleading and likely affected NHC’s score. (First Amd. Pet. Ex. H NHCSLO000068–70.) NHC’s application also stressed the experience and track record of success of Helios Dayspring and highlighted this experience and history of success and compliance as a reason why the City should select NHC for one of the few competitive Cannabis Permits available in the City. See, e.g., RJN Ex. 4 at pp. 11–12.) The application satisfied financial criteria by relying on the wealth of Dayspring (wealth which was, at least in part, the result of bribery and tax evasion). (Id. at p. 32.) The application satisfied the “Property Control” criteria by indicating that the APNs associated with the project “are fully owned by Helios Dayspring.” (Id. at p. 31.) The City found that NHC likely would not have received the score it did and would not have been allowed to move forward had the City known of the substantial and ongoing criminal history of Dayspring. (First Amd. Pet. Ex. H at pp. NHSCLO000068–70.) The City also concluded that Dayspring’s failure to disclose the substantial back taxes owed to the IRS on his personal financial statements constituted a false or misleading statement or omission. (Id. at NHCSLO000070.) This failure resulted in a substantial overstatement of the financial assets available to NHC and Dayspring. (Ibid.) The City found that these were misleading omissions that likely would have affected the outcome of the application process. C.False Statements in Connection with Transfer to Valnette Garcia The City also concluded that the circumstances surrounding Dayspring’s transfer of ownership to Garcia supported an inference that Garcia and NHC knew or should have known of the criminal investigation of Dayspring and potentially the forthcoming criminal charges at or around the time NHC and Dayspring undertook to transfer his interest to Garcia. (Pet. Ex. H at NHCSLO000070–72.) The City concluded that the failure to disclose these matters to the City in connection with the transfer of ownership to Garcia constituted “a continuation and reaffirmation by NHC, Ms. Garcia and 13 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612providing false or misleading statements or omissions of highly relevant information to the City in order to obtain and wrongfully maintain the Cannabis Operator Permit.” (Ibid.)1 In its memorandum of decision, the City also noted that, in each formal communication to NHC since the facts of the criminal misconduct became known to the City, the City has advised that the City was conducting a separate inquiry into the implications of the criminal plea and that any actions or communication related to the construction permits should not be construed as related to the Cannabis Permit considerations. (Id. at NHCSLO000072.) Finally, the City found that NHC had engaged in misrepresentations in connection with the revocation process, in that NHC omitted or affirmatively hid the fact that Dayspring remained NHC’s landlord, continuing to derive substantially above market financial benefit from NHC, and his continuing involvement with NHC until “caught” by the City. ( First Amd. Pet. Ex. H at NHCSLO000072–74.) D.Subsequent History The City issued its final memorandum of decision, re-affirming the automatic disqualification of NHC, on October 19, 2021. (First Amd. Pet. Ex. H.) On January 7, 2022 – approximately three months later – NHC served the petition for writ of mandate. NHC then waited an additional two weeks to file an ex parte application, which was heard on February 1, 2022. This Court denied NHC’ s ex parte application. Following the hearing on the ex parte application, the City demurred, and that demurrer was heard on July 7, 2022. This Court sustained the City’s demurrer, with leave to amend, concluding, among other things, that (1) the Municipal Code permitted automatic disqualification of NHC in light of NHC and Dayspring’s misrepresentation; (2) NHC’s unclean hands barred the relief NHC seeks; and (3) NHC’s petition was moot in light of the expiration of NHC’s unactivated permit on October 22, 2021. On July 15, 2022, NHC filed a First Amended Petition. The only new factual allegations in the Amended Petition are found at paragraphs 97–99, in which NHC argues that the City engaged in selective enforcement of its municipal code because Helios Dayspring “provided 1 In its final memorandum of decision, the City also reiterated its limited role in the transfer of ownership to Garcia, in light of the regulations applicable at the time and the fact that Garcia had already been through the City’s background check process. The applicable process effectively 14 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612financial capital for all three successful cannabis retail business permits with the City of San Luis Obispo.” The remaining amendments are largely found at paragraphs 106–131 and paragraphs 139– 141, and consist of NHC’s legal arguments. III.LEGAL ARGUMENT A.Standard of Review Mandamus proceedings are subject to the general rules of civil proceedings. (Chapman v. Superior Court (2005) 130 Cal. App.4th 261, 271.) Where the pleading fails to allege specific facts showing entitlement to relief, the petition is subject to a general demurrer. (Ibid; see also, Code Civ. Proc. § 1089.) A demurrer tests the legal sufficiency of factual allegations in a pleading. (Breneric Associates v. City of Del Mar (1998) 69 Cal.App.4th 166, 180.) A demurrer will lie where the face of the complaint or matters subject to judicial notice clearly disclose a defense or bar to recovery. (Cryolife, Inc. v. Superior Court (2003) 110 Cal.App.4th 1145, 1152.) While the court must assume the truth of all material facts pleaded, it must disregard contentions, deductions, conclusions of fact or law, or allegations to the contrary of facts of which judicial notice may be taken. (Rakestraw v. California Physicians’ Service (2000) 81 Cal.App.4th 39, 42-44.) NHC seeks a writ of mandate challenging the City’s automatic disqualification of it. NHC’s challenge is properly reviewed as petition for ordinary mandamus because no hearing was required by law. (Code Civ. Proc. § 1085; Am. Bd. Of Cosm. Surgery v. Med. Bd. Of California 2008) 162 Cal.App.4th 534, 547.) The standard of review in ordinary mandamus is highly deferential. (Carrancho v. Cal. Air Res. Bd. (2003) 111 Cal.App.4th 1255, 1265.) NHC’s challenge involves the interpretation of the Municipal Code, and the City is entitled to deference in its interpretation of its municipal code. (Communities for a Better Envt. v. State Water Resources Control Bd. (2003) 109 Cal.App.4th 1089, 1107.) 1.NHC’s Disqualification was authorized by the Municipal Code Municipal Code section 9. 10.070(c) provides that “an applicant shall be disqualified from applying for, or obtaining, a commercial cannabis operator permit if . . . The applicant made one or more 15 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 926129.10.070(d) provides a permit is “ activated by the issuance of a use permit for the commercial cannabis activity . . . together with all other applicable city permits and state licenses, and the commercial cannabis operator thereafter opening and continuously operating the commercial cannabis activity.” (RJN Ex. 1 at § 9.10. 070(d).) As NHC admits, it has not complied with the requirement of Section 9.10.070(d), and the permit is not active. (See, e.g., First Amd. Pet. at ¶¶ 13, 21–22, 44, 54, 63.) Until the Cannabis Permit is active, NHC has no operative permit, and may still be “disqualified from . . . obtaining” the Cannabis Permit under Section 9.10.070(c). NHC’s claim that it had a “vested right” to operate a commercial cannabis location is without merit. NHC seems to conflate traditional vested rights in the land use and development context (which can allow a developer to complete construction in accordance with the terms of an issued permit regardless of subsequent legislative changes, see Avco Community Developers, Inc. v. South Coast Regional Com. ( 1976) 17 Cal.3d 785) with the “fundamental vested rights” inquiry which determines whether a court must exercise independent judgment in a writ proceeding. (See Goat Hill Tavern v. City of Costa Mesa ( 1992) 6 Cal.App.4th 1519, 1525.) NHC does not argue that the independent judgment test applies. Nor could NHC so argue; NHC’s desire to sell marijuana involves a quintessentially economic interest, and no “vested, fundamental right.” Molina v. Board of Administration, etc. (2011) 200 Cal.App.4th 53, 60.) Even if the traditional vested rights land use doctrine was implicated here, the doctrine generally only provides protections once an entity has obtained all necessary land use entitlements and the entity performs substantial work and incurs substantial liabilities in good faith reliance on those land use entitlements. (Avco Cmty. Devs., Inc. v. S. Coast Reg'l Com. 1976) 17 Cal.3d 785, 797.) A Cannabis Permit, and especially one that is not yet active, is merely a step in the process. An aspiring cannabis operator must also obtain a conditional use permit and a variety of approvals from the City (see RJN Ex. 2 at § 17.86.080(E)(1)(a).) To the extent funds have been spent to undertake “expensive and extensive renovations of [the] property,” those funds were expended by NHC’s landlord, Helios Dayspring, during a period of time when he was inarguably aware that he had engaged in, and concealed on an ongoing basis from the City, 16 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612Municipal Code warns applicants that licensure creates no vested right. (RJN Ex. 2 at § 17.86.080(E)(2).) NHC made numerous false statements in the application process, any one of which would mandate disqualification. 2.NHC’s Disqualification was Authorized by NHC’s Agreement In connection with its application for a Cannabis Permit, NHC contractually agreed that any false or misleading representation or omission would result in disqualification and revocation of permit, and waived any inconsistent rights in the Municipal Code. In NHC’s original commercial cannabis application form, NHC acknowledged that: Applicants providing false or misleading information in the permitting process will result . . . nullification or revocation of any issued permit.” (RJN Ex. 3 at p. 6 [emphasis added].) This is evidence of the City’s interpretation of its own ordinance, NHC’s acknowledgement and agreement with this interpretation, and an independent contractual agreement and waiver of any broader rights provided by the Municipal Code. (See, e.g., Simmons v. Ghaderi (2008) 44 Cal.4th 570, 585 [A person may waive rights and privileges, including those conferred by statute, unless otherwise prohibited by specific statutory provision].) NHC and Dayspring provided false or misleading information in the permitting process. As NHC agreed, this merits “rejection of the application and/or nullification or revocation of any issued permit.” (RJN Ex. 3 at p. 6 [emphasis added].) B.NHC has Unclean Hands A writ of mandate is an equitable remedy, and equitable defense such as unclean hands can bar the issuance of such equitable relief. (See, e.g., Blumenthal v. Superior Ct. (1980)103 Cal.App.3d 317, 320 [“it is within our discretion to deny a petition on such equitable grounds including unclean hands].”]; San Diego Cty. Dep't of Pub. Welfare v. Superior Ct. (1972) 7 Cal. 3d 1, 9, 496 P.2d 453, 458 [“[T]he writ should not issue in aid of one who does not come into court with clean hands . . . .”].) When the relevant facts are not in dispute (and here, they are alleged by NHC, incorporated by reference into the Amended Petition, or subject to judicial notice) a demurrer may be sustained on the grounds that the doctrine of unclean hands bars a cause of action. (Blain 17 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612NHC’s success in the early stages is because of its knowing misrepresentations, made with the intent that the City rely upon the representations, and the City did in fact rely upon the misrepresentations to its detriment – the City would not have issued a Cannabis Permit had NHC not lied about Dayspring’s criminal conduct. NHC only proceeded as far as it did because of fraud. NHC has unclean hands, and equity should not allow it to profit from its fraud. Further, Dayspring’ s romantic partner, Garcia, has never shown or represented that she did not know of Dayspring’s forthcoming indictment when she received his transfer of ownership, and it strains credulity to believe that she had no such knowledge, given Garcia’s and Dayspring’s close personal relationship and because the transfer was, apparently, for no consideration. (RJN Ex. 6 at pp. 4–5.) In other words, NHC now relies on the success of its wrongful misrepresentations and concealment of criminal misconduct to contend that the City is precluded from taking action based on its dishonest conduct. Finally, despite Dayspring’ s purported divestiture of interest in NHC, NHC alleges he is still the landlord and stands to reap substantial financial benefit from the operation of a cannabis enterprise. (First Amd. Pet. at 4:25–28.) Dayspring’s undeniably unclean hands weigh against the issuance of an injunction that would inure to his benefit. NHC’s newly minted argument that the City, too, has unclean hands is meritless. The City did not commit a host of felonies, or lie on any application concerning a history of felony bribery and felony tax evasion. The only “unclean hands” NHC points to is an allegation of selective enforcement. As is explained below in Section III.F, this allegation is meritless. In any event, the doctrine of unclean hands acts defensively, and prevents a party with unclean hands from obtaining relief. It cannot be used affirmatively to seek relief against a party with allegedly unclean hands. (See, e. g., Brown v. Grimes (2011) 192 Cal.App.4th 265, 284 Even if the unclean hands doctrine against Grimes did bar Brown's action, the doctrine cannot be used affirmatively by Grimes to recover on his cross-complaint, for unclean hands is a defense.”].) The City seeks no affirmative relief in this lawsuit. NHC does seek relief, and this Court should again conclude 18 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612C.NHC’s Claims are Moot NHC’s permit expired by operation of law, and NHC’s claims are moot. San Luis Obispo Municipal Code section 9.10.070(D) provides in relevant part: Each commercial cannabis operator permit must be activated within twelve months of issuance. . . . Failure to timely activate the permit shall be deemed abandonment of the permit and the permit shall automatically lapse. RJN Ex. 1 at § 9.10.070(D).) NHC was granted an un-activated permit on October 22, 2019. First Amd. Pet. Ex. A.) NHC was granted a total of one additional year to activate its permit. RJN Exs. 7, 8, 9.) Two years from October 22, 2019 was October 22, 2021. NHC’s un-activated permit terminated by operation of law on October 22, 2021, and NHC’s claims are moot. In the First Amended Petition, NHC argues that its claims are not moot because “the City made it legally and factually impossible for Petitioner to ‘activate’ its permit.” (First Amd. Pet. at 119.) This argument fails for a number of reasons. First, NHC fails to show or allege that it took any steps to protect its rights or prevent automatic termination. There is no allegation that NHC requested that the City extend this deadline. There is no allegation that the City misled NHC into believing the time period before automatic termination was tolled or suspended. NHC did not file this lawsuit or seek a temporary restraining order until January of 2022, well after the unactivated permit had expired by operation of law. Even when NHC did seek injunctive relief, it did not seek the more modest relief of extending this deadline, and instead sought only the full reissuance of its permit. NHC slept on its rights, and its claims are now moot. Further, there is no showing that the legislative purpose of San Luis Obispo Municipal Code section 9.10.070(D) would be served by tolling its operation in a time period when it is impossible” to activate a permit. Presumably, applicants would not allow an unactivated permit to expire unless there was some bar to activating it, e.g., an inability to obtain state licensure or pass building inspection. The automatic expiration provision of the Municipal Code serves the salutary purpose of providing finality and certainty of termination to “unactivated” permits that could otherwise forever languish in a liminal state of unactivated but impossible to activate. Finally, the 19 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612or capricious act of the City. The only cause of the “impossibility” of NHC activating its permit was NHC and Dayspring’s misconduct and conscious decisions to lie about that misconduct. D.NHC’s Claim for Declaratory Relief Fails To the extent NHC also attempted to state a claim for declaratory relief, that claim fails. NHC’s declaratory relief claim is derivative and duplicative of the petition for writ of mandate, and the demurrer should be sustained because the petition fails for the reasons described above. Ball v. FleetBoston Fin. Corp. (2008) 164 Cal.App.4th 794, 800.) E.The City did Not Engage in “Selective Enforcement” NHC’s argument that the City engaged in “selective enforcement” fails. The City did not engage in “selective enforcement,” and if it had this would not preclude the City from enforcing the law and would not grant NHC immunity from the consequences of its misconduct. First, and most fundamentally, NHC has not shown or alleged that the applicants were required to disclose third parties who provided “financial capital.” NHC has thus not effectively alleged that any of the other operators made prohibited misrepresentations or omissions, much less misrepresentation even remotely analogous to NHC and Dayspring’s lies concerning Dayspring’s history of felony bribery and tax evasion. (Compare First Amd. Pet. at ¶ 97 allegation that other operators failed to disclose Dayspring’s financial involvement] with RJN Ex. 3 [requirement that individuals with 10% or greater ownership stake be disclosed and background checked, but no similar requirement for contributors of “financial capital”].) Second, NHC has not shown or alleged that any of the other retailers’ permits are unactivated such that the City could determine that grounds for automatic termination exist. Finally, “selective enforcement” is not a stand-alone doctrine that could support NHC’s claim for affirmative relief from this Court. Even if the City was seeking to enforce a penal statute, NHC could not state an equal protection based “selective enforcement” claim. NHC, by virtue of Helios Dayspring’ s ownership and control at the time of the misrepresentation and omissions, is not similarly situated to the other cannabis retails in the City. NHC and Helios Dayspring, by virtue of making misrepresentations concerning the criminal history of NHC’s Chief Executive 20 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612not similarly situated to any other cannabis operator who did not make such misrepresentations concerning the criminal history of their owners, managers, and Chief Executive Officers. NHC does not belong to any protected class, and it was rational for the City to determine that grounds for automatic termination existed only as to NHC, because only NHC submitted an application signed by Helios Dayspring lying about the criminal acts of Dayspring. (See, e.g., People v. Garner (1977) 72 Cal. App.3d 214, 217–18 [“The selective enforcement of the statute against bookmakers and not against bettors, however, is not based on an invidious and unjustifiable standard. A distinction drawn on the basis of the difference in the kind of criminal conduct, even though of equal culpability under the law, is neither suspect nor invidious.”]; Cilderman v. City of Los Angeles ( 1998) 67 Cal.App.4th 1466, 1470 [“What the equal protection guarantee prohibits is state officials purposefully and intentionally singling out individuals for disparate treatment on an invidiously discriminatory basis.”] [internal citations omitted]; City & Cnty. of San Francisco v. Burton ( 1962) 201 Cal.App.2d 749, 755 [“Assuming the city had permitted’ others to violate the ordinance, mere inaction is not necessarily the result of an intentional or arbitrary scheme to discriminate against defendants. . . . Permitting some persons to violate a zoning regulation does not preclude its enforcement against others”].) Finally, NHC failed to exhaust its’ administrative remedies as to this issue and has waived it. NHC had the opportunity to address the City’s determination that grounds for automatic disqualification existed, and generally argued that NHC had made no misrepresentation and that the City’s municipal code did not permit termination of its unactivated permit. (See First Amd. Pet. Ex. F; see also Ex. H at pp. NHCSLO000063 [describing arguments made by NHC at meeting with City].) NHC may not raise this argument for the first time now, in reliance on extra-record evidence that was not before the City Manager at the time of the decision. More fundamentally, irrespective of any other alleged conduct by any other party, there is simply no allegation, nor could there be, that there is any evidence of similar criminal misconduct or misrepresentations on the part of any other party. There is no allegation of such criminal conduct confirmed by an independent investigative or enforcement agency. It was more than rational for the City 21 - CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER AND DEMURRER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612Dayspring and the vague financial entanglements alleged by NHC. IV.CONCLUSION The demurrer should be sustained in full and without leave to amend. Dated: August 16, 2022 BEST BEST & KRIEGER LLP By: 82508.00018\34822950.1 PROOF OF SERVICE 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612Proof of Service I, Janice Liu, declare: I am a citizen of the United States and employed in Orange County, California. I am over the age of eighteen years and not a party to the within-entitled action. My business address is 18101 Von Karman Avenue, Suite 1000, Irvine, California 92612. On August 16, 2022, I served a copy of the within document(s): CITY OF SAN LUIS OBISPO NOTICE OF DEMURRER TO FIRST AMENDED PETITION AND DEMURRER TO FIRST AMENDED PETITION by transmitting via facsimile the document(s) listed above to the fax number(s) set forth below on this date before 5:00 p.m. by placing the document(s) listed above in a sealed envelope with postage thereon fully prepaid, the United States mail at Irvine, California addressed as set forth below. by placing the document(s) listed above in a sealed envelope and affixing a pre-paid air bill, and causing the envelope to be delivered to a agent for delivery. by personally delivering the document(s) listed above to the person(s) at the address(es) set forth below. by transmitting via e-mail or electronic transmission the document(s) listed above to the person(s) at the e- mail address(es) set forth below.John Armstrong Armstrong Law Group 23232 Peralta Drive, Suite 102 Laguna Hills, CA 92653 Phone: (949) 942-6069 Email: john@armstronglawgroup.co Attorneys for Petitioner I am readily familiar with the firm's practice of collection and processing correspondence for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more 82508.00018\34822950.1 -2 - PROOF OF SERVICE 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612I declare under penalty of perjury under the laws of the State of California that the above is true and