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HomeMy WebLinkAbout29- City Administrator CITY OF SAN BERIRDINO - REQUEST ' 3R COUNCIL ACTION SHAUNA CLARK Request for re-hearing of Mayor From: Subject: City Administrator and Common Council decision Dept: upholding denial of issuance of operating permit by Police Date: August 10 , 1993 Dept. -- Desert Inn Motel. Synopsis of Previous Council action: 6/21/93 Mayor and Common Council upheld decision of Chief of Police and Police Commission to deny operating permit to Desert Inn Motel. Recommended motion: 1 . That the request for a re--hearing of the Mayor and Common Council ' s decision to uphold the decision of the Police Chief and Police Commission to deny an operating permit to the Desert Inn Motel, be denied. or 2 . That the Mayor and Common Council approve the request by the Desert Inn Motel for a re-hearing of their decision upholding the Chief of Police and Police Commission' s denial of an operating permit and set a public hearing for September 20 , 1993 at 10 : 00 a.m. to hear only additional testimony that has not been previously submitted. Signature Contact person: Dan Robbins Phone: 5607 Supporting data attached: yes Ward: FUNDING REQUIREMENTS: Amount: Source: (Acct No.) (Acct. Description) Finance: Council Notes: 75-0262 Agenda Item No CITY OF SAN BERORDINO - REQUEST K)R COUNCIL ACTION STAFF REPORT On November 30, 1992 , the Police Commission heard an appeal on the denial by the Chief of Police of the issuance of a business permit to Jack and Linda Liao for operation of the Desert Inn Motel at 607 W. 5th Street. After hearing the testimony presented by the Liao's and Deputy City Attorney Frank Rhemrev, the Police Commission denied the appeal. On June 21, 1993 , Mayor and Council heard an appeal of the Police Commission decision to uphold the Chief of Police's denial of the operating permit. At that time, based upon findings presented in a staff report by the Assistant Chief of Police which found that the Liao's have been convicted of a crime of moral turpitude; have significant arrests or police investigations concerning related crimes; and during the application process, Mr. Liao denied the arrests and conviction, the Mayor and Council denied the appeal. Attached is a request from the attorney representing the Liao's for re-consideration of the decision by the Mayor and Council based upon the fact that only 6 of the 7 Councilmembers were present on June 21 and that Mrs. Liao was ill and unable to be present at that hearing. Should the Mayor and Council approve the request for re- consideration, it is recommended that a stipulation be made that only additional testimony not previously submitted, be considered and that September 20, at 10: 00 a.m. be set as the hearing date and time. 75-0264 1 ing Chan ( 147363) ttorney At Law 2 752 S . Atlantic Blvd. , onterey Park, CA 91754 3 hone: (818) 458-5557 Fax: ( 818) 458-1619 ttorney for Appellant 4 Wen-Hsiung Liao 5 BEFORE THE MAYOR AND COMMON COUNCIL 6 OF THE CITY OF SAN BERNARDINO 7 8 In re Appeal of Denial of ) usiness Permit ) MOTION TO STAY AND RE-CONSIDER 9 ) DENIAL OF BUSINESS PERMIT BY ppellant: Wen-ITsiung Liao ) 10 POLICE COMMISSION AND ) SUPPORTING BRIEF 11 ) 12 ) 13 14 Wen-Hsiung Liao, Appellant and owner of Desert Inn 15 Motel, through and by his counsel, requests that the City Council 16 of the City of San Bernardino reconsiders the decision of the 17 Police Commission in denying Appellant' s business permit on the 18 following grounds: 19 1 . In the appeal hearing at the City Council on June 21, 1993, 20 only 6 Council members were present, 3 of whom voted in favor of 21 Appellant. Appellant did not have a fair chance to present his 22 case before a full body of the City Council . 23 2 . In upholding the decision of the Police Commission, the City 24 Council relied on the evidence against Appellant that he and his 25 wife pled no contest to a charge of maintaining a disorderly 26 house in 1983 . Because of her cancer problem, Appellant' s wife 27 was unable to testify at the hearing regarding said incident. 28 Pagel - i 1 Appellant ' s wife now requests to be given an opportunity to 1 testify. 2 Appellant further requests that the decision of the 3 Council Meeting on June 22 , 1993 be stayed pending the decision 4 on this motion to reconsider. 5 1� �1 Date: June 23 , 1993 7 Sing Chan, attorney for Appellant 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Page2 ` PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF Los Angeles State of California. i am employed in the county of business address is: n 1 am over the age of 18 and not a party to the within action; my 'fRO C••!h A�Inntir}IVCt. On 6 /24 19 9 3 1 served the foregoing document described as Monterey Park,CA 91754 Motion to sta and re—consi r in this action on by placing the true copies thereof enclosed in scaled envelopes addressed as stated on the attached mailing list: by placing O the original ® a true copy thereof enclosed in sealed envelopes addressed as follows: City Attorney 300 North ' D' Street San Bernardino, CA 92418-0001 (BY MAID_) I caused such enveiope with postage thereon fully prepaid :o -c placed .in the United State- mail at Monterey Park , California. , ark , California. Executed on h/�4 � 19 9 33 at Monte�e� � C State of California that the above is true and correct. (State) 1 declare under penalty of perjury under the laws of th (Federal) I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made. Bessie Wong - Signature Type or Print Name CTU&sn1 fxanooK TOWSAVfn(O'CW"EO 9197( WW 0SCOWNY tow VM MO?W1 CC F. r."7 to we h CMee.fte au"a f�Arr Covrl ti J IN`1993 KU RECEIVED cu OFFICE OF ',. CITY co q�;" ATTORNEY Law Offices Of Sing Chan 752 i, Atlaiztic L..t:levard • Montere.yAXa 0 Califo 191754 Telephone (818) 458-5557 (8 — FACSIMILE C0 SHEET � � Sl t 1993 TOTAL PAGES FAXED: DATE: ,..�_( ILL TO G�a e hn NAME, i NAME: ____� COMPANYs REGARDING: � FAX#: Enclosed please find: LJJ' VL 6 ] Pursuant to your request. i ] For your records. f ] For you.c information. ] Please sign and return. ] please review and contact me. [ ] Please handle. i ] other: jr34 29 _ 4l-) t, /93 1 Sing C"'.^.an ( 147363) Attorney At Law 2 752 S . Atlantic Blvd. , Monterey Park, CA 91754 3 Phonai. 1818) 458-5557 Fax: (818) 458-1619 Attorney for Appellant 4 Wezi-H.s iung Liao 5 BEFORE THE CITY COUNCIL 6 OF THE CITY OF SAN BERNARDINO 7 8 In ,re Appeal of Denial of ) Bus i:nes s Permit 9 ) BRIEF IN SUPPORT OF MOTION TO RECONSIDER 10 } Dates Sept. 20, 1993 } 10:00 A.M. 11 ) Place: Council Chambers City Hall 12 ; 300 North "D" Street San Bernadino, CA 14 Key Witness was not able to appear due to illness 15 1. 14x-3 . LIAO was part of the management of the Desert Inn Motel 16 during pariod of operation of which the San Bernardino Police 17 ch.a.11jaiiged it with improper management and therefore recommended 1$ denia'L of business permit. 19 2 . -.'11:e key evidence of the Police offered to support its denial 20 rec:(ATI'VaTIdati.on was that Mr. Liao was convicted of maintaining a 21 disord. rly house back in 1983, solely because he was the co-owner 22 of the motel . In this specific instance, Mr. Liao was not even 23 in tI.;.F motel and Mrs. Liao was the only witness . 24 person who can tell the 3 . T�irs . Liao, therefore, is the only p 25 City gi.th respect to that instance and also on the management of 26 the it,_2tei- 27 28 Pagel r..rr. 4 . A fair hearing implies that the party who is challenged of 1 wrong doing is given ample chance to present evidence to rebut 2 that challenge. Mrs . Liao has cancer for years and is difficult 3 to rjove around. Given that the City failed to give proper 4 consideration to Mr. Liao's testimony related to the above 5 conviction, Mrs . Liao is now willing to make herself available to 6 the hearing. 7 5 . Appellant hereby requests that his Motion to Reconsider be 9 granted. 10 1) � Date:: Sept 15 , 1993 ng 12 Si Chan, attorney for Appellant 13 14 15 16 17 18 19 20 21 22 233 24 25 26 27 28 Paget