2024-09-25 Appellant's Request for Subpoena Duces Tecum, Exhibit 1-2

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only if there was "compliance with relevant building codes" and if the Facility was a "County pre-approved structure." • March 1, 2023: DPW, through counsel, offered a"path forward"to satisfy the pre- approval and exemption requirements it identified on February 10, including the following: o "Submit the building plans for the 4 pre-fabricated modules." o "The design professional would also need to provide the plans for the foundation and calculations for wind and seismic loads." o "The applicable code provision is: 2018 IBC, Section 3113 Relocatable Buildings." o "Arrange for the inspection of the foundation and the attachment of the modules to the foundation, and certification that the modules are the modules identified in the plans." • November 14, 2023: After I`o Processing worked for months in good faith to meet the March 1 criteria(which were focused on structural plans), DPW abruptly added new, additional criteria for pre-approval, including that I`o Processing would need "electrical and plumbing permits" in order to receive County preapproval. • November 27, 2023: DPW induced I`o Processing to stay its appeal to the Board (which at the time was scheduled for hearing on December 2023), by offering yet another set of criterion for pre-approval. This time, DPW instructed I`o Processing to "submit plans stamped by an architect and by a structural engineer, as appropriate, for review by the Building Division," while informing I`o Processing that DPW will "honor"the currently issued electrical permit but"may"require a plumbing permit. Notably, this criteria recognized that no new electrical permit was required. In verbal conversations, Mr. Steve Pause, on behalf of DPW, assured I`o Processing that he did not believe a plumbing permit was required because there was no underground piping and the property utilized an existing, fully-permitted connection to County water. • June 10, 2024: In reliance on DPW's latest instructions, I`o Processing submitted "plans stamped by an architect and by a structural engineer" as well as detailed wind and seismic calculations, exactly as DPW had instructed. In response, DPW made new demands, which were not in the terms of the November 27 offer, including a 7 4871-5206-8494.1.071717-00001