Agenda Packet_2026-02-03 - Laserfiche WebLink

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' INTRODUCTION f E This Appeal is submitted to formally challenge the approval of Conditional Use Permit e Modification CUP No. 1982-18-MOD-1 granted to Forty Martyrs Armenian Church / Ari Guiragos Minassian School on October 27, 2025. The proposed two-story, 4,846 sq. ft. classroom building—representing a programmatic expansion from K-6 to K-8—was approved under a Class 14 CEQA Categorical Exemption, despite substantial evidence that the exemption is inapplicable, improperly applied, and prejudicially dismissive of the rights of the adjacent R-1 single-family residential property directly and uniquely affected by the project. The Sally C. Gutierrez Trust property at 5401 W. Tampion Avenue is not only the closest residence to the project site—it is the sole R-1 property that directly abuts and shares borders with the institutional campus, creating a uniquely severe impact not experienced by any other household. Long-term residents include senior citizens, one of whom is ADA- covered with mobility limitations, and who rely on the quiet use and enjoyment of their home as protected by residential zoning standards. The approval of this CUP modification, without addressing the direct and compounding impacts to this residence, represents a breakdown in procedural fairness, environmental review integrity, and R-1 residential protections. This Appeal seeks correction, proper review, and the restoration of lawful due process owed to the affected residents. RESERVATION OF RIGHTS, PRESERVATION OF OBJECTIONS &„CONTESTATION OF RECORD The Appellants hereby fully reserve all rights and formally contest the entirety of the project record, staff findings, hearing testimony, exhibits, data, and conclusions relied upon in granting this approval. The Appellants state as follows: 1. No portion of the administrative record is accepted as accurate, complete, or reliable unless expressly stated by the Appellants. 2. All verbal statements, written assertions, slides, exhibits, data, and environmental representations made by the Applicant, City staff, or consultants are contested, disputed, and preserved for challenge. 3. The Appellants assert insufficient time, access, and transparency in the review of project documents and therefore reserve the right to supplement this Appeal as additional information becomes available, including upon receipt of an official transcript or certified record. 4. The Appellants explicitly preserve the right to raise any and all CEQA, land-use, zoning, procedural, ADA, due-process, and equal-protection arguments in future - administrative or judicial proceedings. This Reservation of Rights is intentionally placed at the beginning of this Appeal and will be included again at the end of the final section, in full, to ensure double-layer legal preservation and to prevent any waiver, forfeiture, or procedural default of arguments not fully known at the time of filing. 2 City Council 18 — 18 2/3/2026