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Exhibit In Support of First Amended, Verified Cross-complaint for Injunctive Relief and Damages – Declaration of Lonnie Haughton

As summarized by AVELAR’s Senior Partner Lonnie Haughton in his paper, Express Finding” Requirements for Local Amendments to California’s Title 24 Building Codes, a local jurisdiction’s amended building standards are “not effective or operative” unless properly adopted with “express findings” and filed with the California Building Standards Commission.

These strict procedural requirements are described in Mr. Haughton’s Declaration filed in federal court on behalf of homeowner Janet Summerfield in her cross-complaint against the City of San Bernardino.

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