1 THE LAW OFFICE OF FRANCISCO GUTIERREZ 220 Montgomery Street, Suite 1920 2 San Francisco CA 94104 Telephone: (415) 805-6508 Facsimile: (415) 484-7832 3 Email:
[email protected] 4 BOARD OF APPEALS 5 CITY AND COUNTY OF SAN FRANCISCO 6 Appeal of, ) Appeal No.: 17-055 7 MAHER MEMARZADEH, PhD ) ) APPELLANT’S BRIEF 8 Appellant, ) ) Date: February 28, 2018 vs. ) Time: 5:00 pm 9 ) SAN FRANCISCO PUBLIC WORKS ) Subject property: 408 Cortland Ave 10 BUREAU OF URBAN FORESTRY ) Public Works Order: 185812 ) 11 Respondent. ) ) 12 I. INTRODUCTION 13 Appellant Maher Memarzadeh, PhD (“Appellant”), is the owner of 408-412 Cortland Avenue. 14 Appellant appeals the determination by the Director of Public Works denying him a permit to plant 15 two Platanus x acerifolia street trees at his property. Appellant has worked closely with Stephen 16 Keller in the San Francisco Department of Public Works Bureau of Urban Forestry (“BUF”) for many 17 months to resolve the matter, including by presenting a detailed planting plan and by offering to plant 18 other tree species instead of Platanus trees. Appellant proceeds with his appeal on the ground his 19 planting plan for two Platanus trees is reasonable and addresses all concerns raised by BUF. 20 Appellant respectfully requests that the Board of Appeals grant his appeal and issue an order 21 overruling the decision of the Director of Public Works and directing DPW to issue the permit 22 adopting Appellant’s planting plan. 23 /// 24 APPELLANT’S BRIEF Appeal No.: 17-055 1 1 II. BACKGROUND 2 A. The Determination by the Director of Public Works.