On March 20, 2023, the City of Sacramento opened a code enforcement case against 4880 T Street, a property owned by the Jacqueline M. Baritell Trust. The property owner is a medically frail, wheelchair-bound elderly woman.
Over the next three years, the city assessed over $32,000 in administrative penalties and monitoring fees Penalty Timeline CSV, recorded a cloud on the property's title, and conducted almost 30 cycles of penalties and lien hearings — all without ever lawfully entering or inspecting the property Official Case File.
The official case file, obtained through the California Public Records Act, disproves the city's own enforcement actions on their face.
Every fact on this page is sourced exclusively from the city's own official records. Read them yourself.
Each failure is sourced from the official case file and public statutory record. Click any authority to read the actual law.
| # | Documented Failure | Authority Violated | Severity |
|---|---|---|---|
| 1 | No warrant obtained, no consent given, no legal authority to inspect Case File | CCP §1822.50 | CRITICAL |
| 2 | State-law inspection prerequisite not shown on face of file before N&O issued Case File | H&S §17980(c)(1) | CRITICAL |
| 3 | N&O certifies inspection occurred — inspector's own note proves he never entered Email Thread | SCC §8.100.720(A) | CRITICAL |
| 4 | N&O and Correction List contradict each other — same date, same official Violation Listing | SCC §8.100.720(A)(2) | CRITICAL |
| 5 | Stated basis for N&O provably false from inspector's own case notes Case File Notes Email Proof | Official Case File | CRITICAL |
| 6 | No documented specific condition — violations are boilerplate code text, not property observations Violation Listing | SCC §8.04.120 | HIGH |
| 7 | Owner asked three times in writing for specifics — never answered Email Thread pp.4,7,9 | SCC §8.100.720(A)(2) | HIGH |
| 8 | Over $30,000 assessed without legal authority — charges continue to accrue Penalty Timeline | SCC §8.100.860 | HIGH |
| 9 | Compliance trap: permits ordered while city's own document admits inspection incomplete Violation Listing | SCC §8.100.720(A)(2) | HIGH |
| 10 | Waiver of appeal inapplicable — N&O identified no specific condition to appeal Demand p.5 | SCC §8.100.770 | HIGH |
| 11 | No certified mail return receipt in case file for April 12, 2023 N&O Case File | H&S §17980 | HIGH |
| 12 | Recorded cloud signed by Peter Lemos — no documented connection to case, no delegation Demand p.4 | H&S §17985 | HIGH |
| 13 | Recorded cloud identifies property by street address only — not a legal description Demand p.4 | Gov. Code §27201 | HIGH |
| 14 | N&O invokes “Chief Building Official” — signed by different title, two undocumented delegations Demand p.3 | SCC §8.100.720(A) | ON RECORD |
| 15 | 8/21/2025 first property entry — zero findings documented in case file Case File p.9 | Official Case File | ON RECORD |
| 16 | Material communications absent from official file Saakian Thread | Official Case File | ON RECORD |
Every enforcement action in this case rests on a single claim: that Inspector Lovato inspected 4880 T Street and determined it to be substandard. The official case file disproves that claim in the inspector's own words.
I arrived onsite at 12:00 pm and from the front of the dwelling there looks to be no work going on. There are items in the driveway that look to be removed from the garage. I knocked at the front door and there was no answer so I left my card at the front door and took pictures around the property. I then went to the alley to see if I could drive to the back of the dwelling and there is a gate there blocking access.— Paul Lovato, Case Notes, 03/20/2023 Case File
He saw nothing. He couldn't reach the backyard. He left a card.
The owner's representative, Christopher Foley, emailed Paul Lovato the same day Paul received the complaint. Paul responded within hours. Contact was established. Email Thread pp.1-2
Yet on April 11, Paul would enter into the case file: “Due to lack of contact from the Owner...” — a statement his own April 4 notes disprove.
I met with neighbors to access their backyard to verify work performed. I did verify there is an addition to the detached garage going on. Neighbors stated there was generators running the previous night. I took pictures of what I saw from where I was standing. A N&O will be requested.— Paul Lovato, Case Notes, 04/10/2023 Case File
He never entered 4880 T Street. He never sought a warrant under CCP §1822.50. He never obtained owner consent. He stood in a neighbor's yard and looked over the fence.
His own April 7 note reveals the neighbor was the complaining party: “I contacted the complaining party to find out if the work can be viewed from their property.” Case File
Two days after standing in a neighbor's yard, the Notice and Order was issued. Its face certifies:
The Chief Building Official has caused to be inspected and has determined that the building(s) at 4880 T ST, Sacramento, California… (is)(are) in sub-standard and/or dangerous condition.— Notice and Order, 04/12/2023, signed Bo Cosley, executed Paul Lovato
Under Cal. Health & Safety Code §17980(c)(1), enforcement proceedings may commence only after the agency “has inspected or caused to be inspected a building and has determined that the building is a substandard building.” That did not happen until 896 days later.
The owner's representative asked Paul Lovato three times in writing what specific violation existed:
From April 12, 2023 through September 2, 2025 — 896 days — not one city official entered the property. Every penalty during this period was assessed under a Notice and Order that certified an inspection that never occurred. Case File Activities
The automated system assessed: Full Penalty Timeline CSV
The N&O simultaneously ordered the owner to obtain permits within 30 days. But the Correction List — same document, same date — states:
This is not a complete Violation List of building code violations. Neither interior nor exterior has been completely inspected.— Correction List, Code B31, attached to N&O dated 04/12/2023 Violation Listing
A complete inspection shall have been done with a list of violations and all paperwork/plans may need to be submitted before a permit can be issued.— Same Correction List, same date Violation Listing
The owner was ordered to comply within a deadline while the city's own document stated the prerequisites for compliance had not been met. Under SCC §8.100.720(A)(2), a Notice and Order must contain “a brief and concise description of the conditions found to render the building substandard.” This one contained boilerplate.
On February 5, 2026, Paul Lovato emailed Karin Owens — an unauthorized third party — dictating the exact scope of work for the building permit. Karin Owens Email
On February 27, 2026, Permit RES-2603471 was issued. The scope matches Paul's email verbatim. Fee: $522.96. Building Permit
Inspector Lovato engaged in multiple rounds of communication that do not appear in the official case activity log, case notes, or any filed document. Under City of San Jose v. Superior Court (2017), communications on personal devices in connection with public business are public records subject to production.
Karin Owens ([email protected]) first appears in the case file on April 10, 2025, calling as the “PO's friend.” Case File Notes
By October 2025, she was being cc'd on attorney correspondence alongside the property owner and the contractor. Saakian Thread pp.3-5
By February 2026, Paul Lovato was emailing her directly to dictate the scope of work for the building permit — bypassing the owner, the owner's representative, and the attorney of record.
In October 2025, attorney Mark Saakian pushed for a permit. The owner's representative pushed back, arguing no permit requirement existed under the N&O. The contractor, Arthur Popov, quit: Full Thread (8 messages)
Sorry Mark, I am am not placing myself into this. It is talking too much of my time. All the listed items are done. I do not feel comfortable pulling permit for anything they ask and be stuck with this misc items. I am out.— Arthur Popov, Best of Remodel Inc., October 20, 2025 Saakian Thread p.4
On September 16, 2025, Paul emailed an 11-item “Correction Notice” to the property's contractor. This document bears no formal enforcement authority under the Sacramento City Code. It expanded the scope beyond the original N&O without issuing an amended or supplemental order as required by SCC §8.100.720. Correction Notice + Photos
The official case file for Case 23-009185 totals 590 pages and 165,487 words. A forensic analysis of every entry attributed to every city employee reveals that the total original, human-authored content across all 22 personnel over 2.5 years is 185 words. Full Analysis
That is 0.112% of the case file. The other 99.888% is machine-generated: Accela automated entries, fee cycle boilerplate, and fill-in-the-blank hearing templates.
Paul Lovato, the assigned case worker for 2.5 years, wrote 117 words. His entire original output consists of exactly 3 entries:
I met with neighbors to access their backyard to verify work performed. I did verify there is an addition to the detached garage going on. Neighbors stated there was generators running the previous night. I took pictures of what I saw from where I was standing. A N&O will be requested.— Paul Lovato, April 10, 2023 (51 words) Case File
Any contact from owner? Re-visit site. Add condition? if not, call contact to see if I can gain access to see work Buster prelim sent out 2 weeks ago— Paul Lovato, April 11, 2023 (29 words) Case File
I happened to be driving by the property and saw work was being performed so I stopped to talk with someone and no one would answer me. I then called their attorney and I received his voicemail.— Paul Lovato, October 22, 2025 (37 words) Case File
The remaining 19 employees contributed zero original words. Nine hearings and collections staff each processed thousands of dollars in penalties using identical fill-in-the-blank templates. Over $33,000 in fees was generated by a case file where the total human contribution would not fill a single paragraph. Read the Complete Analysis
The City's own 311 export (Request 25-3549) does not contain the March 2023 complaint that supposedly triggered the entire case. 311 Gap Summary
A November 7, 2023 building complaint explicitly references a follow-up to ticket 230317-1609966. That ticket — the alleged March 17, 2023 complaint that started everything — is absent from the export the City produced.
What the 311 export actually contains:
The entire enforcement chain hangs on a complaint the City cannot produce. Every penalty before September 2025 lacks a documented trigger. Full 311 Gap Analysis
The City's case file export contains 125 “Case Photo” entries with 123 valid filenames recorded. But when you open the PDF, every photo dated before June 26, 2024 renders as an empty placeholder — blank icons where evidence should be. Photo Gap Report
Zero Paul Lovato photos appear anywhere in the renderable portion of the document. The inspector's photographs — the ones he claims to have taken from the neighbor's yard, the ones cited as the basis for the Notice and Order — are not viewable in the production.
The City delivered a case file where all early-period photos are blank placeholders. This is either evidence destruction, a defective production, or deliberate withholding. The formal demand specifically requests all case photographs in original .JPG format with intact EXIF metadata per Gov. Code §7922.570(b)(1). Full Photo Gap Report
A systematic review of every activity row in the case file reveals that virtually every required supporting document is absent from the official record. This is not a few gaps — it is a pattern of missing documentation across every category. Missing Records Checklist
| Document Category | Expected | Produced |
|---|---|---|
| Re-inspection worksheets / field notes | 25 | 0 |
| Monitoring billing packets (authorization, invoice, proof of service) | 24 | 0 |
| Admin penalty billing packets | 23 | 0 |
| Certified mail return cards / envelope scans | 27 | 0 |
| Posting declarations with photo proof | 25 | 0 |
| HCAAB hearing packets + council follow-up | 21 | 0 |
| DLHO hearing packets | 19 | 0 |
Additionally missing: the initial complaint intake, initial inspection report, Buster Prelim referral memo, title cloud request and recorder receipt, online title report, and the Notice & Order packet itself.
The City assessed $33,120 in fees supported by records where virtually every required supporting document does not exist. Full Missing Records Checklist
The automated penalty system assessed $33,120 over 2.5 years. A review of the fee structure reveals undocumented changes and a year of billing with no underlying activity. Penalty Timeline
Early monitoring fees were assessed at $305. Mid-case, the rate increased to $380. No documentation authorizing this increase was produced in any CPRA response. The City has not identified the approval, the effective date, or the authority for the change.
The 23rd administrative penalty doubled from $1,000 to $2,000 with no documented escalation approval, no signed memo, and no advance notification to the property owner.
The City's 311 system shows zero complaints or activity for 4880 T Street during all of 2024. Yet during that same year, the automated system assessed:
No inspection occurred. No complaint was filed. No field visit was documented. The machine ran on its own.
The case file contains multiple entries documenting certified mail returned to the City as undeliverable: Case File
Note the trust name: “BARTITELL” — misspelled on official City documents. The correct name is Baritell.
Despite knowing that mail was not being received, the City continued to assess monthly penalties and monitoring fees. Each returned letter confirmed the City was billing a person who was not receiving their notices — and the automated system continued without pause.
The failures documented at 4880 T Street are not isolated. A review of Sacramento's Housing Code Advisory and Appeals Board (HCAAB) and Dangerous Buildings Lien Hearing Officer (DLHO) transcripts reveals the same patterns across multiple Paul Lovato cases. Full Hearing Extracts
In the HBB Holdings case (23-005565, 0 21st Avenue), a board member directly challenged Paul for claiming fees without documenting site visits — the same gap that exists at 4880 T Street:
Paul, I have a couple. So you mentioned in your summary that it was a third monitoring fee. Yet I don't see a list of when you visited it previously.— Board Member, HCAAB Hearing, November 13, 2024 Hearing Extract
In the 36th Avenue case (24-039656), the homeowner was assessed $1,597.50 before his compliance window expired:
He was assessed with the fine of $1,597 before he even could do something about it.— Hearing testimony, HCAAB, June 11, 2025 Hearing Extract
A property owner challenged $720 for boarding a window — six screws and a piece of wood:
$1,000 to put a piece of wood up and six screws. And that is basically my complaint. But $1,000 to patch a window when it only costs $240 to fix the window properly.— Mr. Daniels, HCAAB Hearing, 2024 Hearing Extract
Across every case examined:
25 other Paul Lovato cases from CPRA releases are available for review. Hearing Extracts
On April 2, 2026, a formal demand titled “Notice of Documented Procedural Invalidity and Formal Demand for Case Closure” was hand-delivered and emailed to Doug Pierson, incoming Principal Building Inspector. Read the Full Demand (9 pages)
The demand makes six specific requests, with a 14-day response window:
Source: Official Case File Email Thread Penalty Data
| Property Owner | Jacqueline M. Baritell Trust (Jackie Baritell) — medically frail, wheelchair-bound |
| Owner's Rep | Christopher Foley — primary contact from April 4, 2023 onward Email Thread |
| Inspector | Paul Lovato, Building Inspector III, HSG & Dangerous Buildings Case File |
| PBI (outgoing) | Bo Cosley — signed N&O, present at 8/21/2025 first entry, retiring |
| PBI (incoming) | Doug Pierson — formal demand addressed to him Demand |
| Enforcement Chief | Peter Lemos — signed title cloud; no documented connection to case Demand p.4 |
| Third Party | Karin Owens ([email protected]) — received off-record communications Email |
| Attorney | Mark Saakian, Saakian Law APC, Roseville CA Email Thread |
| Contractor | Arthur Popov, Best of Remodel Inc. — quit Oct 20, 2025 Email p.4 |
Every document below was obtained from the City of Sacramento's official case record or through the California Public Records Act. Click to view. Browse Full Archive (105 files)
Paul Lovato — the inspector whose conduct is being questioned — is the same person who receives, processes, and filters the CPRA responses about his own case. Every request for records that would reveal his actions passes through him. A request for a third-party intermediary was made. The requests continued to flow through Paul. Full CPRA Narrative
Four CPRA requests were filed between September 2025 and March 2026 under Gov. Code §7922.530. Each time, the City produced bulk database exports — Citizenserve PDFs, Accela spreadsheets — then closed the request. The records that would show what Paul actually did at the property never appeared.
| Record Category | Times Requested | Status |
|---|---|---|
| March 2023 originating complaint (ticket 230317-1609966) | 3 | Never produced |
| Monitoring reports for any of 24 billed cycles ($9,120) | 2 | Never produced |
| Inspector field notes or worksheets (25 re-inspections) | 3 | Never produced |
| Billing authorization memos for penalties | 2 | Never produced |
| Paul Lovato's emails about case 23-009185 | 2 | Never produced |
| Paul Lovato's text messages about case 23-009185 | 1 | Never produced |
| Accela audit logs (who edited entries, timestamps) | 1 | Never produced |
| Certified mail return card scans (27 entries) | 1 | Never produced |
The City's response pattern is consistent: produce bulk database exports that contain no original work product, then close the request. When challenged, reopen briefly, release another batch of the same type, then close again. The records that would show what Paul actually did — or didn't do — are the records that never appear.
The City billed $9,120 in monitoring fees across 24 cycles without producing a single document showing that monitoring actually occurred. Not one monitoring report. Not one field note. Not one site visit log. The fees were generated by a system, and when asked to produce the evidence that the monitoring happened, the City produced nothing. Read the Full CPRA Timeline
Every statute cited in this audit. Click to read the full text of the law.
| Citation | Subject | Link |
|---|---|---|
| CCP §§1822.50–52 | Inspection warrants — requirements for inspection without consent | Read Law |
| H&S §17980(c)(1) | Agency must inspect and determine substandard before enforcement | Read Law |
| H&S §17985 | Recording of notices; final disposition requirement | Read Law |
| Gov. Code §27201 | Legal description requirement for recorded instruments | Read Law |
| Gov. Code §7922.530 | California Public Records Act — right of access | Read Law |
| Gov. Code §7922.570(b) | CPRA — production in native electronic format | Read Law |
| SCC §8.100.720 | Notice and Order content requirements | Read Law |
| SCC §8.100.770 | Appeal rights and waiver provisions | Read Law |
| SCC §8.100.860 | Administrative penalties for N&O noncompliance | Read Law |