HomeMy WebLinkAboutNS-1335ORDINANCE NO. NS- 1335
AN ORDINANCE OF THE CITY OF SANTA ANA AMENDING
THE SANTA ANA MUNICIPAL CODE BY AMENDING SECTIONS
22-1 THROUGH 22-15, AND REPEALING SECTIONS 22-16
THROUGH 22-18 RELATING TO THE REGULATION OF
MASSAGE ESTABLISHMENTS, MASSAGE TECHNICIANS, AND
THE PRACTICE OF MASSAGE.
THE CITY COUNCIL OF THE CITY OF SANTA ANA DOES ORDAIN
AS FOLLOWS:
SECTION 1: That section 22-1 of the Santa Ana Munici-
pal Code is hereby amended to read as follows:
Section 22-1. Definitions
Unless the particular provision or the context other-
wise requires, the definitions and provisions contained
in this section shall govern the construction, meaning,
and application of words and phrases used in this
Chapter.
(a) "Massage" means any method of pressure on, or
friction against, or stroking, kneading, rubbing,
tapping, pounding, vibrating, or stimulating the
external parts of the human body with the hands or
with the aid of any mechanical or electrical apparatus
or appliances, or with or without supplementary aids
such as rubbing alcohol, liniments, antiseptics, oils,
powder, creams, ointments, or other similar prepara-
tions commonly used in this practice.
(b) "Massage establishment" means any establishment
having a fixed place of business where any individual,
firm, association, partnership, corporation, or com-
bination of individuals, engages in, conducts, carries
on or permits to be engaged in, conducted or carried
on, massages, baths, or health treatments involving
massage or baths as the principal functions.
(c) "Massage technician" means any person who, for
any form of consideration whatsoever, gives or admin-
isters to another person a "massage" as defined or
baths as the principal function.
(d) "Recognized school of massage" means any school
or institution of learning which teaches the theory,
ethics, practice, profession, or work of massage,
which school or institution has been approved pursuant
to the California Education Code and which requires a
resident course of study of not less than one thousand
(1,000) hours to be given in not less than six (6)
calendar months before the student shall be furnished
with a diploma or certificate of graduation. Schools
offering a correspondence course not requiring actual
attendance shall not be deemed a recognized school.
The City of Santa Ana shall have a right to confirm
that the applicant has actually attended class in a
recognized school.
SECTION 2: That section 22-2 of the Santa Ana Munici-
pal Code is hereby amended to read as follows:
Section 22-2. Massage Establishment Permit Required
ORDINANCE NO. NS- 1335
Page two
It shall be unlawful for any person, association,
partnership or corporation to engage in, conduct or
carry on, in or upon any premises within the City of
Santa Ana, the business of a massage establishment
without a permit issued pursuant to the provisions
of this ordinance for each and every such massage
establishment.
SECTION 3: That section 22-3 of the Santa Ana Munici-
pal Code is hereby amended to read as follows:
Section 22-3. Massage Establishment Permit
(a) Any person, corporation or partnership desiring
to obtain a permit to operate a massage establish-
ment shall make application to the Chief of Police
or his designated representative. Prior to submit-
ting such application a nonrefundable fee of two
hundred dollars ($200) shall be paid to the Depart-
ment of Finance to defray, in part, the cost of in-
vestigation and report required by this ordinance.
The Department of Finance shall issue a receipt show-
ing that such permit application fee has been paid.
The receipt, or a copy thereof, shall be supplied to
the Chief of Police at the time such application is
submitted.
(b) The application for permit does not authorize
conducting a massage establishment business until
such permit has been granted.
(c) Each applicant for a massage establishment permit
shall furnish the following information:
(1) The full true name and any other names
used by the applicant.
(2) The present address and telephone number
of the applicant.
(3) The previous addresses of applicant, if
any, for a period of three (3) years immediately
prior to the date of the application and the
dates of residence at each.
(4) Acceptable written proof that the applicant
is at least eighteen (18) years of age.
(5) The applicant's height, weight, color of
eyes and hair, and date of birth.
(6) Two photographs of the applicant at least
two (2) inches by two (2) inches taken within
the last six months.
(7) Business, occupation or employment history
of the applicant for the three (3) years im-
mediately preceding the date of application.
(8) The business license history of the appli-
cant and whether such applicant, in previously
operating in this or any other city, state or
territory under license, has had such license
revoked or suspended, the reason therefor, and
the business activity or occupation subsequent
to such action of suspension or revocation.
ORDINANCE NO. NS- 1335
Page three
(9) Ail convictions, including ordinance viola-
tions, exclusive of traffic violations, stating
the dates and places of any such convictions.
(10) If the applicant is a corporation, the name
of the corporation shall be set forth exactly
as shown in its articles of incorporation or
charter, together with the state and date of
incorporation, and the names and addresses of
each of its current officers and directors,
and each stockholder holding more than five
percent (5%) of the stock in the corporation.
If the applicant is a partnership, the appli-
cant shall set forth the name, residence
address and dates of birth of each of the part-
ners, including limited partners. If the appli-
cant is a limited partnership, it shall furnish
a copy of its certificate of limited partnership
as filed with the County Clerk. If one or more
of the partners is a corporation, the provisions
of this subsection pertaining to corporations
shall apply. The applicant corporation or part-
nership shall designate one of its officers or
general partners to act as its responsible manag-
ing officer. Such designated persons shall
complete and sign all application forms required
of an individual applicant under this ordinance,
but only one application fee shall be charged.
(11) The name and address of the owner and lessor
of the real property upon which the business is
to be conducted, and a copy of the lease or
rental agreement.
(12) Such other identification and information,
including written waivers pursuant to the Educa-
tion Code, as the Police Department may require
in order to discover the truth of the matters
hereinbefore specified as required to be set
forth in the application.
(13) The Chief of Police may require the applicant
to furnish fingerprints when needed for the pur-
pose of establishing identification.
(d) The applicant, if an individual, or designated
responsible managing officer, if a partnership or
corporation, shall personally appear at the Police
Department of the City of Santa Ana and produce proof
that the two hundred dollar ($200) application fee
has been paid and shall present the application con-
taining the aforementioned and described information.
(e) The Chief of Police shall have a reasonable time
in which to investigate the application and background
of the applicant. The Chief of Police or his repre-
sentative shall render a recommendation as to the
approval or denial of the permit to the City Manager.
The Department of Building Safety and Housing, the
Fire Department and the Orange County Health Depart-
ment shall inspect the premises proposed to be devoted
to the massage establishment and shall make separate
recommendations to the City Manager concerning com-
pliance with the foregoing provisions. The proprietor
of such establishment shall pay a fee established by
resolution of the City Council to the County Health
Officer as reimbursement for the County Health Officers'
Public Health and Sanitation Services for said inspec-
tion.
ORDINANCE NO. NS- 1335
Page four
(f) The City Manager, after receiving the application
and aforementioned recommendations, shall grant the
permit if he finds:
(1) The required fee has been paid.
(2) The application conforms in all respects to the
provisions of this ordinance.
(3) The applicant has not knowingly made a material
misrepresentation in the application.
(4) The applicant has fully cooperated in the inves-
tigation of his application.
(5) The applicant if an individual, or any of the
stockholders of the corporation, any officers or
directors, if the applicant is a corporation, or
any of the partners, including limited partners, if
the applicant is a partnership, has not within five (5)
years prior to the application filing date been con-
victed in a court of competent jurisdiction of an
offense involving conduct which requires registration
under California Penal Code section 290, or of conduct
which is a violation of the provisions of California
Penal Code sections 314, 315, 316, 318, 647(a), 647(b),
647(d) or 647(h), or any crime involving dishonesty,
fraud, deceit, or moral turpitude.
(6) The applicant has not had a massage establishment
permit or massage technician permit or other similar
license or permit denied or revoked for cause by this
city or any other city located in or out of this state
within the five (5) years prior to the date of applica-
tion.
(7) The massage establishment as proposed by the appli-
cant would comply with all applicable laws, including
but not limited to, health, zoning, fire and safety
requirements and standards.
(8) The applicant is at least eighteen (18) years of
age.
(g) Any person, corporation or partnership denied a permit
by the City Manager pursuant to these provisions may appeal
to the City Council pursuant to Chapter 3 of the Santa Ana
Municipal Code.
SECTION 4: That section 22-4 of the Santa Ana Municipal
Code is hereby amended to read as follows:
Section 22-4. Massage Technician Permit Required
It shall be unlawful for any person to act as a massage
technician unless such person holds a valid permit issued
by the City of Santa Ana pursuant to the provisions of
this ordinance.
SECTION 5: That section 22-5 of the Santa Ana Municipal
Code is hereby amended to read as follows:
Section 22-5. Massage Technician Permit
(a) Any person desiring to obtain a permit to act as a
massage technician shall make application to the Chief of
Police or his designated representative. Prior to sub-
mitting such application a nonrefundable fee of one hun-
dred dollars ($100) shall be paid to the Department of
ORDINANCE NO. NS- 1335
Page five
Finance to defray, in part, the cost of investigation
and report required by this ordinance. The Department
of Finance shall issue a receipt showing that such
permit application has been paid. The receipt, or a
copy thereof, shall be supplied to the Chief of Police
at the time such application is submitted.
(b) The application for permit does not authorize act-
ing as a massage technician until such permit has been
granted.
(c) Each applicant for a massage technician's permit
may furnish all the information required by section
22-3(c) (1) through 22-3(c) (9) of this ordinance, and
shall in addition furnish the following information:
(1) A certificate from a medical doctor licensed to
practice in the S~ate of California, stating that
the applicant has within thirty (30) days immediately
preceding the date of application been examined and
found to be free of any contagious or communicable
disease.
(2) A diploma or certificate of graduation from a
"recognized school," if any.
(3) The massage establishment, if any, at which the
applicant expects to be employed.
(4) Such other identification and information, in-
cluding written waivers pursuant to the Education
Code as the Police Department may require in order
to discover the truth of the matters hereinbefore
specified as required to be set forth in the appli-
cation.
(5) The Chief of Police may require the applicant
to furnish fingerprints when needed for the purpose
of establishing identification.
(d) The Chief of Police shall have a reasonable time in
which to investigate the application and background of
the applicant. The Chief of Police or his representative
shall render a recommendation as to the approval or de-
nial of the permit to the City Manager.
(e) The City Manager, after receiving the application
and aforementioned recommendation, may grant the permit
if he finds in accordance with sections 22-3(f) (1)
through 22-3(f) (6), and in addition finds:
(1) The applicant has furnished an acceptable
medical certificate in compliance with this ordinance.
(2) The applicant has furnished an acceptable diploma
or certificate of graduation from a "recognized
school" or in lieu thereof has demonstrated competence
and proficiency to the satisfaction of the City
Manager through continuous experience as a massage
technician for a two (2) year period prior to the
effective date of this ordinance, or is an active
member in good standing in the California Massage
Technicians Association or the American Massage and
Therapy Association.
ORDINANCE NO NS-1535
Page six
(3) The applicant has not had a massage establish-
ment permit or a massage technician's permit or
other similar license or permit denied or revoked
for cause by this city or any other city located
in or out of this state within the five (5) years
prior to the date of application.
(4) The applicant is at least eighteen (18) years
of age.
(f) Any person denied a permit by the City Manager pur-
suant to these provisions may appeal to the City Council
pursuant to Chapter 3 of the Santa Ana Municipal Code.
SECTION 6: That section 22-6 of the Santa Ana Municipal
Code is hereby amended to read as follows:
Section 22-6. Exemptions
The provisions of this ordinance shall not apply to the
following classes of individuals while engaged in the
performance of the duties of their respective professions:
(a) Physicians, surgeons, chiropractors, osteopaths, or
physical therapists who are duly licensed to practice
their respective professions in the State of California.
(b) Hospitals, nursing homes, sanatoriums, or other health
care facilities duly licensed by the State of California.
(c) Nurses registered under the laws of the State of
California.
(d) Barber shops and beauty parlors, barbers and beauti-
cians who are duly licensed under the laws of the State
of California when engaged in such practice within the
scope of their license.
(e) Accredited high schools and colleges, and coaches
and trainers therein while acting within the scope of
their employment.
(f) Trainers of any amateur, semi-professional or pro-
fessional athlete or athletic team.
SECTION 7: That section 22-7 of the Santa Ana Municipal
Code is hereby amended to read as follows:
Section 22-7. Massage Establishment Facilities
Every massage establishment shall maintain facilities
meeting the following requirements:
(a) Sign: Subject to applicable ordinances, a recogniz-
able and legible sign shall be posted at the main entrance
identifying the establishment as a massage establishment.
(b) Lighting: Minimum lighting shall be provided in accord-
ance with Article 220 of the National Electric Code, and,
in addition, at least one artificial light of not less than
forty (40) watts shall be provided in each room or enclo-
sure where massage services are performed on patrons.
(c) Ventilation: Minimum ventilation shall be provided in
accordance with Section 1105 of the Uniform Building Code.
ORDINANCE NO NS-t335
Page seven
(d) Equipment: Adequate equipment for disinfecting and
sterilizing instruments used in performing the acts of
massage shall be provided.
(e) Water: Hot and cold running water shall be provided
at all times.
(f) Linen Storage: Closed cabinets shall be provided for
storage of clean linens, and approved receptacles shall
be provided for storage of soiled linen.
(g) Separation of Sexes: If male and female patrons are
to be served simultaneously at the massage establishment,
a separate massage room or rooms, separate dressing facili-
ties and separate toilet facilities shall be provided for
male and female patrons, and each such separate facility
or room shall be clearly marked as such.
(h) Bathing, Dressing, Locker, Toilet Facilities:
Adequate bathing, dressing, locker, and toilet facilities
shall be provided for patrons. A minimum of one tub or
shower, one dressing room containing a separate locker for
each patron to be served, which locker shall be capable
of being locked, and a minimum of two toilets and two
wash basins in separate rooms, one for males and one for
females, shall be provided for every massage establishment.
(i) Facilities for Employees: A minimum of one separate
wash basin shall be provided in each massage establishment
for the use of employees of any such establishment, which
basin shall provide soap or detergent and hot and cold
running water at all times and shall be located within or
as close as practicable to the area devoted to the perform-
ing of massage services. In addition, there shall be pro-
vided sanitary towels in permanently installed dispensers
at each wash basin.
(j) Compliance with Code: Proof of compliance with all
applicable provisions of the Santa Ana Municipal Code shall
be provided.
SECTION 8: That section 22-8 of the Santa Ana Municipal
Code is hereby amended to read as follows:
Section 22-8. Massage Facilities Operation
Every massage establishment shall comply with the follow-
ing operating requirements. These requirements shall be
prominently and publicly displayed in a conspicuous place
upon every premises operating under the provisions of
this ordinance.
(a) Each person employed or acting as a massage technician
shall have a valid permit issued by the City of Santa Ana,
and it shall be unlawful for the owner, operator, respon-
sible managing employee, manager or permittee in charge of
or in control of the establishment to employ or permit a
person to act as a massage technician as defined in this
Code who is not in possession of a valid unrevoked massage
technician's permit.
(b) Bath and massage operations shall be carried on and
the premises shall be open only between the hours of 7:00
a.m. and 12:00 midnight.
ORDINANCE NO. NS-1335
Page eight
(c) A list of services available and the cost of such
services shall be posted in an open, public place on
the premises, and shall be described in readily under-
standable language. No owner, operator, responsible
managing employee, manager, or permittee shall permit,
and no massage technician shall offer to perform any
services other than those posted.
(d) The massage establishment permit, and a copy of the
permit of each and every massage technician employed in
the establishment, shall be displayed in an open and
conspicuous place on the premises.
(e) Every permittee operating a massage establishment
shall keep a written record of the date and hour of
each treatment, the name and address of each patron, the
name of the employee administering the treatment and the
type of treatment administered. Such records shall be
open to inspection only by officials charged with enforce-
ment of these provisions for law enforcement and public
health and for no other purposes, including use of the
file by owners or employees of the establishment charged
with maintaining the file. The information furnished or
secured as a result of any inspection shall remain confi-
dential. Any unauthorized disclosure or use of such in-
formation by any officer or employee of the City of
Santa Ana or County of Orange or owner or employee of the
massage establishment shall constitute a misdemeanor and
such persons shall be subject to the penalty of the pro-
visions of this chapter in addition to any other penalties
provided by law. Such records shall be maintained for a
period of two (2) years.
(f) Massage establishments shall at all times be equipped
with an adequate supply of clean sanitary towels, cover-
ings and linens. Clean towels, coverings and linens shall
be stored in cabinets. Towels and linens shall not be used
on more than one (1) patron unless they have first been
laundered and disinfected. Disposable towels and cover-
ings shall not be used on more than one (1) patron. Soiled
linens and paper towels shall be deposited in approved
receptacles.
(g) In any establishment in which massage services are
rendered only to members of the same sex at any one time,
such persons of the same sex shall be placed in a single
separate room or the operators of the massage establish-
ment may elect to place such persons of the same sex in
separate rooms or booths having adequate ventilation to
an area outside said room or booth while massage services
are being performed.
(h) Wet and dry heat rooms, steam or vapor rooms or cab-
inets, shower rooms and compartments, toilet rooms and
pools shall be thoroughly cleaned and disinfected as
needed, and at least once each day the premises are open,
with a disinfectant approved by the Health Department.
Bathtubs shall be thoroughly cleaned with a disinfectant
approved by the Health Department after each use. All
walls, ceilings, floors and other physical facilities for
the establishment must be in good repair and maintained
in a clean and sanitary condition.
(i) Instruments utilized in performing massage shall not
be used on more than one (1) patron unless they have been
sterilized using approved sterilizing methods.
ORDINANCE NO. NS- 1335
Page nine
(j) Massages shall not be given unless patrons are
wearing clothing fully covering their genitals and
female patrons are in addition wearing clothing fully
covering their breasts. Where such clothing is fur-
nished patrons by the massage establishment, it shall
not be used by more than one (1) patron unless it has
first been laundered and disinfected. Massage techni-
cians shall be fully clothed from the knee to the neck
in clean, opaque, light-colored clothing.
(k) No persons shall enter, be or remain, in any part
of a massage establishment while in the possession of,
consuming, or using any alcoholic beverage or drugs
except pursuant to a prescription for such drugs. The
owner, operator, responsible managing employee, manager
or permittee shall not permit any such person to enter
or remain upon such premises.
(1) No massage establishment shall operate as a school
of massage, nor use the same facilities as that of a
school of massage. It shall be unlawful for any person
to perform any massage upon a member of the general
public while on the premises of a school of massage.
Instructors and students of such schools may practice
massage only upon a bona fide employee of the school
or student. A dummy may be used.
SECTION 9: That section 22-9 of the Santa Ana Municipal
Code is hereby amended to read as follows:
Section 22-9. Inspections
The Department of Building Safety and Housing, Fire and
Health Departments shall, from time to time and at least
twice each year, make an inspection of each massage estab-
lishment in the City of Santa Ana for the purpose of de-
termining that the provisions of this Code are met. The
proprietor or operator of such establishment shall pay a
fee established by resolution of the City Council to the
County Health Officer as reimbursement for the County
Health Officer's public health and sanitation services
in connection with the enforcement of this Chapter.
SECTION 10: That section 22-10 of the Santa Ana Municipal
Code is hereby amended to read as follows:
Section 22-10. Sale or Transfer
(a) Upon the sale or transfer of any interest in a massage
establishment, the permit shall be null and void. A new
application shall be made by any person, firm or entity
desiring to own or operate the massage establishment. A
fee of twenty-five dollars ($25) shall be payable for
each such application involving sale or other transfer
of any interest in an existing massage establishment. The
provisions of section 22-3 of this Chapter shall apply to
any person, firm, or entity applying for a massage estab-
lishment permit for premises previously used as such
establishment.
(b) Any such sale or transfer of any interest in an exist-
ing massage establishment or any application for an exten-
sion or expansion of the building or other place of business
of the massage establishment, shall require inspection and
shall require compliance with section 22-7 of this Chapter.
ORDINANCE NO. NS- 1335
Page ten
SECTION 11: That section 22-11 of the Santa Ana Municipal
Code is hereby amended to read as follows:
Section 22-11. Change of Location or Name
(a) A change of location of any of the aforementioned
and described premises may be approved by the Chief of
Police and City Planner, provided all ordinances and
regulations of the City of Santa Ana are complied with
and a change of location fee of five dollars ($5) is
deposited with the City.
(b) No permittee shall operate under any name or conduct
any establishment under any designation not specified in
his permit.
SECTION 12: That section 22-12 of the Santa Ana Municipal
Code is hereby amended to read as follows:
Section 22-12. Prohibited Conduct
(a) It shall be unlawful for any massage technician to
massage the genital area of any patron or the breasts of
any female patron or for any operator of a massage estab-
lishment to allow or permit such massage in such massage
establishment.
(b) It shall be unlawful for any massage technician to
perform any massage services in any commercial establish-
ment other than a premises holding a valid massage estab-
lishment permit or office occupied by the customer.
(c) It shall be unlawful for any operator of a massage
establishment to violate the provisions of sections 22-2,
22-7, 22-8, 22-10, or 22-11 of this ordinance.
(d) It shall be unlawful for any massage technician to
violate the provisions of sections 22-4, 22-8(j), 22-8(1),
22-11(b) or to act as a massage technician in any estab-
lishment which does not have a license therefor as re-
quired by section 22-2.
(e) Any persons violating the provisions of section
22-12(a), 22-12(b), 22-12(c) or 22-12(d) shall be guilty
of a misdemeanor.
SECTION 13: That section 22-13 of the Santa Ana Municipal
Code is hereby amended to read as follows:
Section 22-13. Suspension or Revocation
When the City Manager finds that any person holding a
permit under the provisions of Chapter 22 has violated
the provisions of this Chapter he may revoke the permit.
No such revocation shall become effective until the permit
holder has been notified in writing by certified mail of
his right to appeal the revocation decision pursuant to
the provisions of Chapter 3 of this Code. If a timely
appeal is filed, the revocation shall be effective only
upon decision of the City Council. Otherwise the revoca-
tion shall become effective after the timely appeal period
has passed.
ORDINANCE NO. NS- 1335
Page eleven
SECTION 14: That section 22-14 of the Santa Aha Munici-
pal Code is hereby amended to read as follows:
Section 22-14. Conducting as a Nuisance
Any massage establishment operated, conducted or main-
tained contrary to the provisions of this Chapter shall
be and the same is hereby declared to be unlawful and
a public nuisance and the City Attorney may, in addition
to or in lieu of prosecuting a criminal action hereunder,
commence an action or actions, proceeding or proceedings,
for the abatement, removal or enjoinment thereof, in the
manner provided by law; and shall take such other steps
and shall apply to such court or courts as may have juris-
diction to grant such relief as will abate or remove such
massage establishment and restrain and enjoin any person
from operating, conducting or maintaining a massage es-
tablishment contrary to the provisions of this Chapter.
SECTION 15: That section 22-15 of the Santa Ana Municipal
Code is hereby amended to read as follows:
Section 22-15: Existing Businesses
The provisions of this Chapter shall be applicable
to all persons and businesses described herein whether
the herein described activities were established before
or after the effective date of this Chapter.
SECTION 16: That section 22-16 of the Santa Ana Municipal
Code is hereby repealed.
SECTION 17: That section 22-17 of the Santa Ana Municipal
Code is hereby repealed.
SECTION 18: That section 22-18 of the Santa Ana Municipal
Code is hereby repealed.
SECTION 19: If any section, subsection, sentence, clause,
phrase or portion of this ordinance is for any reason held to
be invalid or unconstitutional by the decision of any court of
competent jurisdiction, such decision shall not affect the valid-
ity of the remaining portions of this ordinance. The City
Council of the City of Santa Ana hereby declares that it would
have adopted this ordinance and each section, subsection, sen-
tence, clause, phrase or portions thereof irrespective of the
fact that any one or more sections, subsections, sentences,
clauses, phrases or portions be declared invalid or unconstitu-
tional.
SECTION 20: Neither the adoption of this ordinance nor
the repeal hereby of any ordinance shall in any manner affect
the prosecution for violation of ordinances, which violations
were committed prior to the effective date hereof, nor be con-
strued as affecting any of the provisions of such ordinance
relating to the collection of any such license or penalty or
the penal provisions applicable to any violation thereof, nor
to affect the validity of any bond or cash deposit in lieu there-
of, required to be posted, filed or deposited pursuant to any
ordinance and all rights and obligations thereunder appertaining
shall continue in full force and effect.
ORDINANCE NO. NS- 1335
Page twelve
on the
ADOPTED by the City Council of the City of Santa Ana
20th day of December , 1976, by the following vote:
AYES: COUNCILMEN: Yamamoto, Bricken, 0rtiz,
Garthe, Brandt, Ward
NOES: COUNCILMEN: None
ABSENT: COUNCILMEN: Evans
ATTEST:
CLERK OF THE COUNCIL
APPRO~-ED AS TO FO~.P~:
KEITH L. GOW
CITY ATTORNEY