HomeMy WebLinkAbout20260310_Request for Judicial Notice- City_City v Smith
REQUEST FOR JUDICIAL NOTICE
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J. CHRISTINE DIETRICK, SBN 206539
City Attorney, City of San Luis Obispo
MATTHEW R. SILVER, SBN 245528
MSilver@CivicaLaw.com
SEAN E. MORRISSEY, SBN 297371
SMorrissey@CivicaLaw.com
NICHOLAS GARCÉS
NGarces@CivicaLaw.com, SBN 273277
CIVICA LAW GROUP APC
4000 Barranca Parkway, Suite 250, PMB #782
Irvine, California 92604
Phone: 949-592-0165
Fax: 949-335-1701
Attorneys for Plaintiffs
City of San Luis Obispo, and
People of the State of California
Exempt from filing fees pursuant to
Government Code section 6103.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN LUIS OBISPO
THE PEOPLE OF THE STATE OF
CALIFORNIA, EX REL, J. CHRISTINE
DIETRICK, CITY ATTORNEY OF THE CITY
OF SAN LUIS OBISPO; and,
THE CITY OF SAN LUIS OBISPO, a California
municipal corporation,
Plaintiff,
v.
LAUREL CREEK, LP, a California Limited
Partnership;
LAUREL CREEK, II, L.P., a Delaware limited
partnership;
1160 LAUREL LANE, LLC, a California limited
liability company;
PATRICK N. SMITH a/k/a PATRICK SMITH, an
individual;
SMITH AND COMPANY, A REAL ESTATE
INVESTMENT DEVELOPMENT
CORPORATION, a California corporation;
PATRICK N. SMITH a/k/a PATRICK SMITH, AS
TRUSTEE OF THE PATRICK N SMITH 2004
LIVING TRUST;
Case Number: 25CV-0667
Action Filed: October 16, 2025
Judge: Hon. Tana L. Coates
Dept.: 4
REQUEST FOR JUDICIAL NOTICE IN
SUPPORT OF PLAINTIFF CITY OF SAN
LUIS OBISPO’S EX PARTE APPLICATION
FOR APPOINTMENT OF RECEIVER, OR
ALTERNATIVELY, FOR AN ORDER
SHORTENING TIME
Filed concurrently with:
1. Ex Parte Receivership Application;
2. Memorandum of Points and Authorities;
3. Declaration of Senior Code Enforcement
Supervisor John Mezzapesa;
4. Declaration of Supervising Building Inspector
Trevor Nelson;
5. Declaration of Fire Marshal Josh Daniel;
6. Declaration of Attorney Morrissey;
7. Declaration of Proposed Receiver Griswold;
8. Appendix of Exhibits;
9. [Proposed] Receivership Order;
10. Proof of Service.
ELECTRONICALLY FILED3/10/2026 9:29 AM
REQUEST FOR JUDICIAL NOTICE
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CPIF CALIFORNIA LLC, a California limited
liability company;
CPIF LAUREL CREEK, LLC, a Washington
limited liability company;
ALL WALL SYSTEMS, INC., a Delaware
corporation;
AMERICAN RIVIERA BANK, a California
corporation;
ARNOLD BUILDERS, INC., a California
corporation;
B & B CONSTRUCTION CLEANUP INC., a
California corporation
BLUE STEEL CONCRETE, LLC, a California
limited liability company;
COAST ENGINEERING & DESIGN INC., a
California corporation;
CONSOLIDATED ELECTRICAL
DISTRIBUTORS, INC., d/b/a CALIFORNIA
ELECTRICAL SUPPLY, a Delaware corporation;
CULBERT PLUMBING INC., F/K/A CULBERT
CONSTRUCTION AND PLUMBING, INC., a
California stock corporation;
EMPIRE ELECTRICAL SOLUTIONS, INC., a
California corporation;
FAMCON PIPE & SUPPLY, INC., a California
corporation;
G W SURFACES, a California corporation;
HOMER T. HAYWARD LUMBER CO ., a
California corporation;
KIRK CONSTRUCTION, a California corporation;
LC LENDERS, LLC, a Delaware limited liability
company;
LW CONSTRUCTION, INC., a California
corporation;
MAHOGANY CONSTRUCTION, INC., a
California corporation;
NOLAN CHURCH DOING BUSINESS AS
COLORTRENDS PAINTING & DECORATING,
a California sole ownership or proprietor business;
SCHINDLER ELEVATOR CORPORATION, a
Delaware corporation;
THE SHERWIN-WILLIAMS COMPANY, an
Ohio corporation;
UNITED RENTALS (NORTH AMERICA) INC.,
a Delaware corporation;
US AIR CONDITIONING DISTRIBUTORS,
LLC, a Delaware limited liability company; and,
DOES 1 through 50, inclusive,
Defendants.
Hearing:
Date: March 12, 2026
Time: 8:30 a.m.
Dept: 4
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REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF PLAINTIFF CITY OF SAN LUIS
OBISPO’S EX PARTE APPLICATION FOR APPOINTMENT OF RECEIVER, OR
ALTERNATIVELY, FOR AN ORDER SHORTENING TIME
Plaintiff City of San Luis Obispo (“City”) hereby requests that the Court take judicial notice of
the following in support of its Receivership Application:
1. Grant Deeds for the parcels of real property located at 150 Laurel Lane, San Luis Obispo,
California, 93401, Assessor’s Parcel Numbers 004-962-036, 004-962-037, and 004-962-042 (“Subject
Property”) recorded June 24, 2020, in the San Luis Obispo County Record’s Office (“SLO Official
Records”), with record number 2020031255 (“Grant Deed 1”), and Grant Deed recorded on April 1,
2021, in SLO Official Records, with record number 2021024686 (“Grant Deed 2”) (collectively “Grant
Deeds”). The City bases this request on Evidence Code sections 452, subdivision (c), (g), and (h), 453,
1530, and 1600. Pursuant to Evidence Code section 452, subdivision (c), the Court has the authority to
take judicial notice of the Grant Deeds because each is maintained as an official record with the County
of San Luis Obispo. (Fontenot v. Wells Fargo Bank, N.A. (2011) 198 Cal.App.4th 256, 265 [court may
take judicial notice of a document’s recordation, the date the document was recorded and executed, the
parties to the transaction reflected in a recorded document, and the document’s legally operative
language]; Cooke v. Sup. Ct. (1989) 213 Cal.App.3d 401, 416 [records of a county are properly noticed
under Evidence Code section 452(c) because counties are legal subdivisions of the State.].) True and
correct copies of the Grant Deeds are attached as Exhibit 1 to the Appendix of Exhibits filed
concurrently with this Request For Judicial Notice (“RJN”) and are incorporated herein.
2. Notices of Violation issued between 2021 and 2022 (“2021-2022 NOVs”). The City bases
this request on Evidence Code section 452 subdivisions (c), and (h), 453, and 1530. The Court has the
authority to take judicial notice of the 2021-2022 NOVs because they are maintained as official records
with the City of San Luis Obispo and the facts within are not reasonably subject to dispute and are
capable of immediate and accurate determination. (Trinity Park, L.P. v. City of Sunnyvale (2011) 193
Cal.App.4th 1014, 1027, disapproved on another ground in Sterling Park, L.P. v. City of Palo Alto (2013)
57 Cal.4th 1193, 1210 [official acts and reports of cities are properly noticed under Evidence Code
sections 452 subdivision (c)]. True and correct copies of the 2021-2022 NOVs are attached to the
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Appendix of Exhibits as Exhibit 2 filed concurrently with this RJN and is incorporated herein.
3. 2024 Temporary Occupancy Certificates issued by the City. The City bases this request
on Evidence Code section 452 subdivisions (c), and (h), 453 and 1530. The Court has the authority to
take judicial notice of the 2024 Temporary Occupancy Certificates because they are maintained as
official records with the City of San Luis Obispo and the facts within are not reasonably subject to
dispute and are capable of immediate and accurate determination. (Trinity Park, L.P. v. City of Sunnyvale
(2011) 193 Cal.App.4th 1014, 1027, disapproved on another ground in Sterling Park, L.P. v. City of Palo
Alto (2013) 57 Cal.4th 1193, 1210 [official acts and reports of cities are properly noticed under Evidence
Code sections 452 subdivisions (b) and (c)]. True and correct copies of the 2021-2022 NOVs are attached
to the Appendix of Exhibits as Exhibit 3 filed concurrently with this RJN and is incorporated herein.
4. March 10, 2025, Notice and Order of Violations (“March 2025 NOV”). The City bases this
request on Evidence Code sections 452 subdivisions (b), (c), and (h), 453, and 1530. The Court has the
authority to take judicial notice of the March 2025 NOV because it is maintained an official record with
the City of San Luis Obispo and the facts within are not reasonably subject to dispute and are capable of
immediate and accurate determination. (Trinity Park, L.P. v. City of Sunnyvale (2011) 193 Cal.App.4th
1014, 1027, disapproved on another ground in Sterling Park, L.P. v. City of Palo Alto (2013) 57 Cal.4th
1193, 1210 [official acts and reports of cities are properly noticed under Evidence Code sections 452
subdivisions (b) and (c)]. A true and correct copy of the March 2025 NOV is attached to the Appendix
of Exhibits as Exhibit 4 filed concurrently with this RJN and is incorporated herein.
5. Inspection Photographs of the Subject Property taken on March 13, 2025, (“March 13, 2025,
Photographs”). The City bases this request on Evidence Code section 452 subdivisions (c), and (h),
453 and 1530. Pursuant to Evidence Code section 452(c), the Court has the authority to take judicial
notice of photos because they are maintained as official records because they are maintained as official
records with the City of San Luis Obispo and the facts within are not reasonably subject to dispute and
are capable of immediate and accurate determination. (Trinity Park, L.P. v. City of Sunnyvale (2011) 193
Cal.App.4th 1014, 1027, disapproved on another ground in Sterling Park, L.P. v. City of Palo Alto (2013)
57 Cal.4th 1193, 1210 [official acts and reports of a city are properly noticed under Evidence Code section
452(c)].) True and correct copies of the March 13, 2025, Photographs are attached as Exhibit 5 to the
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Appendix of Exhibits filed concurrently with this RJN and are incorporated herein.
6. Notice of Abatement Proceedings (“NOAP”), recorded April 14, 2025, in the SLO Official
Records, with document number 2025-010157. The City bases this request on Evidence Code sections
452, subdivisions (b), (c), (g), and (h), 453, 1530, and 1600. Pursuant to Evidence Code section 452(c),
the Court has the authority to take judicial notice of the NOAP because it is maintained an official record
with the City of San Luis Obispo and the facts within are not reasonably subject to dispute and are
capable of immediate and accurate determination. (Trinity Park, L.P. v. City of Sunnyvale (2011) 193
Cal.App.4th 1014, 1027, disapproved on another ground in Sterling Park, L.P. v. City of Palo Alto (2013)
57 Cal.4th 1193, 1210 [official acts and reports of cities are properly noticed under Evidence Code
sections 452 subdivisions (b) and (c)]. Additionally, the NOAP is subject to judicial notice because it is
maintained as an official record with the County of San Luis Obispo. (Fontenot v. Wells Fargo Bank,
N.A. (2011) 198 Cal.App.4th 256, 265 [court may take judicial notice of a document’s recordation, the
date the document was recorded and executed, the parties to the transaction reflected in a recorded
document, and the document’s legally operative language]; Cooke v. Sup. Ct. (1989) 213 Cal.App.3d
401, 416 [records of a county are properly noticed under Evidence Code section 452(c) because counties
are legal subdivisions of the State.].) A true and correct copy of the NOAP is attached as Exhibit 6 to
the Appendix of Exhibits filed concurrently with this RJN and is incorporated herein.
7. Inspection Photographs of the Subject Property taken on April 25, 2025, (“April 25, 2025,
Photographs”). The City bases this request on Evidence Code section 452 subdivisions (c), and (h),
453 and 1530. Pursuant to Evidence Code section 452(c), the Court has the authority to take judicial
notice of photos because they are maintained as official records with the City of San Luis Obispo and
the facts within are not reasonably subject to dispute and are capable of immediate and accurate
determination. (Trinity Park, L.P. v. City of Sunnyvale (2011) 193 Cal.App.4th 1014, 1027, disapproved
on another ground in Sterling Park, L.P. v. City of Palo Alto (2013) 57 Cal.4th 1193, 1210 [official acts
and reports of a city are properly noticed under Evidence Code section 452(c)].) True and correct copies
of the April 25, 2025, Photographs are attached as Exhibit 7 to the Appendix of Exhibits filed
concurrently with this RJN and are incorporated herein.
8. Inspection Photographs of the Subject Property taken on April 30, 2025, (“April 30, 2025,
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Photographs”). The City bases this request on Evidence Code section 452 subdivisions (c), and (h),
453 and 1530. Pursuant to Evidence Code section 452(c), the Court has the authority to take judicial
notice of the photos because they are maintained as official records with the City of San Luis Obispo
and the facts within are not reasonably subject to dispute and are capable of immediate and accurate
determination. (Trinity Park, L.P. v. City of Sunnyvale (2011) 193 Cal.App.4th 1014, 1027, disapproved
on another ground in Sterling Park, L.P. v. City of Palo Alto (2013) 57 Cal.4th 1193, 1210 [official acts
and reports of a city are properly noticed under Evidence Code section 452(c)].) True and correct copies
of the April 30, 2025, Photographs are attached as Exhibit 8 to the Appendix of Exhibits filed
concurrently with this RJN and are incorporated herein.
9. The City’s May 5, 2025, Construction Board of Appeals Resolution (“CBOA
Resolution”). The City bases this request on Evidence Code section 452 subdivisions (b), (c), (g), and
(h), 453 and 1530. The Court has the authority to take judicial notice of the CBOA Resolution because
it is maintained as an official record with the City of San Luis Obispo and the facts within are not
reasonably subject to dispute and are capable of immediate and accurate determination. (Trinity Park,
L.P. v. City of Sunnyvale (2011) 193 Cal.App.4th 1014, 1027, disapproved on another ground in Sterling
Park, L.P. v. City of Palo Alto (2013) 57 Cal.4th 1193, 1210 [official acts and reports of cities are properly
noticed under Evidence Code sections 452 subdivisions (b) and (c)]. Additionally, judicial notice of the
CBOA Resolution is warranted as a legislative enactment issued by and under the authority of a public
entity in the United States. (Evidence Code § 452(b); Trinity Park, L.P. v. City of Sunnyvale (2011) 193
Cal.App.4th 1014, 1027 (courts “may take notice of local ordinances and the official resolutions, reports,
and other official acts of a city.”), overruled on others grounds, Sterling Park, L.P. v. City of Palo Alto
(2013) 57 Cal.4th 1193; see also Save Lafayette v. City of Lafayette (2018) 20 Cal.App.5th 657, 662 fn.1
[granting request for judicial notice of city’s public records, including local ordinances, legislative
enactments, and staff reports]; See, e.g., Long Beach Equities, Inc. v. County of Ventura (1991) 231
Cal.App.3d 1016, 2024 [stating “resolutions, reports, and other official acts of County and City” are
appropriate for judicial notice].) A True and correct copy of the CBOA Resolution is attached to the
Appendix of Exhibits as Exhibit 9 filed concurrently with this RJN and is incorporated herein.
10. Inspection Photographs of the Subject Property taken on September 2, 2025, during the
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posting of the N&O (“September 2, 2025, Photographs”). The City bases this request on Evidence
Code section 452 subdivisions (c), (g) and (h), 453 and 1530. Pursuant to Evidence Code section 452(c),
the Court has the authority to take judicial notice of the photos because they are maintained as official
records with the City of San Luis Obispo and the facts within are not reasonably subject to dispute and
are capable of immediate and accurate determination. (Trinity Park, L.P. v. City of Sunnyvale (2011) 193
Cal.App.4th 1014, 1027, disapproved on another ground in Sterling Park, L.P. v. City of Palo Alto (2013)
57 Cal.4th 1193, 1210 [official acts and reports of a city are properly noticed under Evidence Code section
452(c)].) True and correct copies of the September 2, 2025, Photographs are attached as Exhibit 10
to the Appendix of Exhibits filed concurrently with this RJN and are incorporated herein.
11. Notice of Pendency of Nuisance Abatement Action with the Notice and Order to Repair or
Abate (“NoP with N&O”) as an attachment for the Subject Property recorded on September 8, 2025, in
the SLO Official Records, with document number 2025026224. The City bases this request on evidence
code 452, subdivisions (b), (c), (g), and (h), 453, 1530, and 1600. Pursuant to Evidence Code section
452(c), the Court has the authority to take judicial notice of the NoP with N&O because it is maintained
as an official record with the City of San Luis Obispo and a recorded document with the County of San
Luis Obispo, and pursuant to Evidence Code section 453, it is being provided to all parties with sufficient
notice and providing the Court with sufficient information to take judicial notice. (Trinity Park, L.P. v.
City of Sunnyvale (2011) 193 Cal.App.4th 1014, 1027, disapproved on another ground in Sterling Park,
L.P. v. City of Palo Alto (2013) 57 Cal.4th 1193, 1210 [official acts and reports of cities are properly
noticed under Evidence Code section 452(c)]; Fontenot v. Wells Fargo Bank, N.A. (2011) 198
Cal.App.4th 256, 265 [court may take judicial notice of a document’s recordation, the date the document
was recorded and executed, the parties to the transaction reflected in a recorded document, and the
document’s legally operative language]; Cooke v. Sup. Ct. (1989) 213 Cal.App.3d 401, 416 [records of
a county are properly noticed under Evidence Code section 452(c) because counties are legal
subdivisions of the State].) A true and correct copy of the NoP with Emergency N&O is attached as
Exhibit 11 to the Appendix of Exhibits filed concurrently with the RJN and is incorporated herein.
12. Inspection Photographs of the Subject Property taken on October 3, 2025, during the posting
of the 3-Day Notice (“October 3, 2025, Photographs”). The City bases this request on Evidence Code
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section 452 subdivisions (c), (g) and (h), 453 and 1530. Pursuant to Evidence Code section 452,
subdivision (c), the Court has the authority to take judicial notice of the photos because they are
maintained as official records with the City of San Luis Obispo and the facts within are not reasonably
subject to dispute and are capable of immediate and accurate determination. (Trinity Park, L.P. v. City
of Sunnyvale (2011) 193 Cal.App.4th 1014, 1027, disapproved on another ground in Sterling Park, L.P.
v. City of Palo Alto (2013) 57 Cal.4th 1193, 1210 [official acts and reports of a city are properly noticed
under Evidence Code section 452(c)].) True and correct copies of the October 3, 2025, Photographs
are attached as Exhibit 12 to the Appendix of Exhibits filed concurrently with this RJN and are
incorporated herein.
13. 3-Day Notice and Proofs of Service, (“3-Day Notice and Proofs of Service”). The City
bases this request on Evidence Code sections 452, subdivisions (b), (c), and (h), 453, and 1530. Pursuant
to Evidence Code section 452, subdivision (c), the Court has the authority to take judicial notice of the
3-Day Notice and Proofs of Service because they are maintained as official records with the City of San
Luis Obispo and the facts within are not reasonably subject to dispute and are capable of immediate and
accurate determination. (Trinity Park, L.P. v. City of Sunnyvale (2011) 193 Cal.App.4th 1014, 1027,
disapproved on another ground in Sterling Park, L.P. v. City of Palo Alto (2013) 57 Cal.4th 1193, 1210
[official acts and reports of cities are properly noticed under Evidence Code sections 452 subdivisions
(b) and (c)]. True and correct copies of the 3-Day Notice and Proofs of Service are attached as Exhibit
13 to the Appendix of Exhibits filed concurrently with this RJN and are incorporated herein.
14. Inspection Photographs of the Subject Property taken on December 8, 2025, (“December 8,
2025, Photographs”). The City bases this request on Evidence Code section 452 subdivisions (c) , (g)
and (h), 453 and 1530. Pursuant to Evidence Code section 452, subdivision (c), the Court has the
authority to take judicial notice of the photos because they are maintained as official records with the
City of San Luis Obispo and the facts within are not reasonably subject to dispute and are capable of
immediate and accurate determination. (Trinity Park, L.P. v. City of Sunnyvale (2011) 193 Cal.App.4th
1014, 1027, disapproved on another ground in Sterling Park, L.P. v. City of Palo Alto (2013) 57 Cal.4th
1193, 1210 [official acts and reports of a city are properly noticed under Evidence Code section 452(c)].)
True and correct copies of the December 8, 2025, Photographs are attached as Exhibit 14 to the
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Appendix of Exhibits filed concurrently with this RJN and are incorporated herein.
15. Inspection Photographs of the Subject Property taken on February 27, 2026, (“February 27,
2026, Photographs”). The City bases this request on Evidence Code section 452 subdivisions (c) , (g)
and (h), 453 and 1530. Pursuant to Evidence Code section 452, subdivision (c), the Court has the
authority to take judicial notice of the photos because they are maintained as official records with the
City of San Luis Obispo and the facts within are not reasonably subject to dispute and are capable of
immediate and accurate determination. (Trinity Park, L.P. v. City of Sunnyvale (2011) 193 Cal.App.4th
1014, 1027, disapproved on another ground in Sterling Park, L.P. v. City of Palo Alto (2013) 57 Cal.4th
1193, 1210 [official acts and reports of a city are properly noticed under Evidence Code section 452(c)].)
True and correct copies of the February 27, 2026, Photographs are attached as Exhibit 15 to the
Appendix of Exhibits filed concurrently with this RJN and are incorporated herein.
16. Court Entered of Defaults to various defendants (“Entered Defaults”). The City bases this
request on Evidence Code sections 452, subdivision (d), 453, and 1530. Pursuant to Evidence Code
section 452, subdivision (d), the Court has the authority to take judicial notice of the Entered Defaults
because they are maintained as official “[r]ecords of (1) any court of this state.” True and correct copies
of the Entered Defaults are attached as Exhibit 17 to the Appendix of Exhibits filed concurrently with
this RJN and is incorporated herein.
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17.Court Entered of Dismissal to various defendants ("Entered Dismissals").The City bases
2 this request on Evidence Code sections 452,subdivision (d),453,and 1530.Pursuant to Evidence Code
3 section 452,subdivision (d),the Court has the authority to take judicial notice of the Entered Defaults
1
4 because they are maintained as official "[r]ecords of (1)any court of this state."True and correct copies
5 of the Entered Dismissals are attached as Exhibit 18 to the Appendix of Exhibits filed concurrently with
6 this RJN and is incorporated herein.
8 Dated:March 9,2026 CIVICA LAW GROUP,
NICHOLAS GARCES
Attorneys for Plaintiffs
PEOPLE OF THE STATE OF CALIFORNIA
CITY OF SAN LUIS OBISPO
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10 By:
MA
11i SEAN MORRISSEY
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