Conkwright v. City of Del Mar regarding parking issues at 1201 Camino del Mar

Attached is my "request for admissions" sent to the City Attorney a couple of weeks ago.

The City has a few more weeks to respond.

George Conkwright

TO RESPONDENT, CITY OF DEL MAR, “RESPONDENT” AND ITS ATTORNEY OF RECORD:

PETITIONER, GEORGE A. CONKWRIGHT, hereby requests that Respondent, CITY OF DEL MAR, admit the truthfulness of each of the facts set forth below, and the authenticity of the documents attached hereto, within thirty (30) days from the date of service of this Request.

Pursuant to California Code of Civil Procedure Section 203(f), Respondent is required to admit in whole or in part that portion of the request that is true. Respondent is required to reasonably and clearly qualify any portion of the request that is denied

DEFINITIONS

Words in BOLDFACE CAPITALS in the Notice are defined as follows:

“YOU[R]” means Respondent, CITY OF DEL MAR and its agents, employees, attorneys, officers, managers, or anyone acting on their behalf.

“RESPONDENT” means “CITY OF DEL MAR”.

“WRITINGS” means and includes the following handwriting, typewriting, printing, photocopying, computer disc, photographing, and every other means of recording upon any tangible thing any form of commination or representation, including letters, words, pictures, figures, symbols, or combinations thereof pursuant to Evidence Code Section 250.

“PETITION” means the Petition filed in the San Diego County Superior/Municipal Court, * Branch case number 37-2011-00054394-CU-PT-NC

“RESPONSE” means the Answer or Response of the CITY OF DEL MAR to the PETITION filed in the San Diego County Superior/Municipal Court, San Diego Branch case number 37-2011-00054394-CU-PT-NC

-----------(other boilerplate definitions omitted)---------

All other terms are defined either within each request itself, or by common usage and denotation.

REQUEST FOR ADMISSIONS:

(1) Admit that 1201 Camino del Mar is a commercial building with approximately 10,000 square foot and will still have 41 on-site parking spaces, even after replacement of the of 7 town and country spaces in front of the building with a new food-serving deck.

(2) Admit that 1201 Camino del Mar has more on-site parking that the total of all the on-site parking spaces at the following ten restaurants combined, including all the buildings they’re housed in, which represents over 50,000 square feet of commercial lease space in Del Mar.

Board & Brew, Americana, Starbucks, Crepes & Corks, Zel’s, Bruegger’s Bagels, Cafe Secret,Jimmy O’s, Sushi Japone, and Sbicca

(3) Admit that no other commercial building in Del Mar, except for 1201 Camino del Mar, has ever been required to comply with Del Mar’s parking ordinance which requires one parking space per 90 square feet of inside dining area.

(4) Admit that the following restaurants also have outside dining areas, which are located on private property but provide no parking for these outside dining areas:

Board & Brew located at 1212 Camino del Mar; Zel’s located at 1247 Camino del Mar; Crepes & Corks located at 1328 Camino del Mar; El Fuego located at 1342 Camino del Mar; Starbucks and Bruegger’s Bagels located at 1435 Camino del Mar; Sbicca located at 215 Fifteenth Street; Smashburger and six other restaurants in the Plaza located at 1555 Camino del Mar.

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