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August 8, 2023 <br />Page 2 <br />the Title Report Guarantee that is part of Mr. Donnelly's Application, that the alley would <br />"revert to the Owner of Lot 57 by operation of law". That statement is untrue. <br />4) If the City were to grant Mr. Donnelly's application, the alley would revert to the public, the <br />public owns it now, it's circular, the public owns it now and they'll own it if the vacation were <br />granted. It does not "revert" to Mr. Donnelly by operation of law. I have no idea what the <br />Title Officer meant with those words, and I don't think anyone else knows either. <br />5) It seems to me that it is clear that the application is flawed in that the Title Report <br />Guarantee included has part of the Application has a misstatement of fact in it, i.e., a lie. I <br />believe that this misstatement of fact was caused by Mr. Donnelly emailing Mr. Josue Reano <br />of Chicago Title in which he says "It seems like this part of the title report reads a little <br />off ... the alley being vacated to the public? Shouldn't the alley be vacated back to us as the <br />owners?" Mr. Donnelly and all the previous owners to Lot 57 were never the owners of the <br />alley from the time the Tract Map was recorded in 1925 until today's date. That alley <br />belongs to the public in fee simple absolute. <br />6) 1 will be in attendance on August 15, 2023, to speak on behalf of my clients and I would like <br />to have my 3-minute time slot used to argue other things than the matter contained in this <br />letter, so hence, this letter. Please discuss this issue with your client before the meeting of <br />August 15tb. I have sent a copy to the Mayor and to the City Council members, I hope they <br />have an opportunity to read it and to read the email attached in which Mr. Donnelly suborns <br />the Title Officer, who was correct at the outset and is incorrect as the application currently <br />sits. <br />Very trul yours, <br />KkG.SnydeYr <br />KGS:im <br />cc: Thai Viet Phan, Councilmember <br />Jessie Lopez, Councilmember <br />Johnathan Ryan Hernandez, Councilmember <br />Benjamin Vazquez, Councilmember <br />Phil Bacerra, Councilmember <br />David Penaloza, Councilmember <br />Kristine Ridge, City Manager <br />Jennifer L. Hall, City Clerk <br />