Record Cites

Cause of action against county

Did not comply with CEQA (page 9-10)

Claim against LCI

Didn’t comply with APA in changing regulations (page 10-11)

Claim against Governor

Unconstitutional to tell LCI to amend

Homelessness not state of emergency

(page 10-11)

Dismissed claim against county

Page 13

Both move for summary judgment

Pages 15-16

Homelessness crisis main facet of GP campaign

Deposition (page 18)

Gave blankets to homeless in neighborhoods

GP Dep Page 18

Constituents asking GP to help

Dep. page 18

EO told LCI to amend regs so local governments don’t have to require CEQA environmental review for affordable housing projects

GP Dep. (page 19); EO (page 25-27)

Executive Order

Page 25-27

Wanted to issue as soon as possible

GP Dep. (19)

Types of risks homeless individuals face

Illness

Premature death

Physical abuse

Mental illness

Substance abuse

Alternatives GP looked into

Legislative options

Fast track pilot programs

Negotiate with localities directly

(Page 21)

LCI is executive branch agency

GP Dep. (page 22)

Emergency proclamation

Pages 23-24

200K homeless

2/3 unsheltered

Proclamation (Page 23)

1.2 million extremely low income households

Proclamation (Page 23)

400,000 affordable rentals

Proclamation (page 23)

Cost of living growing

Wages and public assistance not

Proclamation (page 23)

Lack of affordable housing leads to homelessness

Proclamation (page 23)

Need systematic approach in light of ineffectiveness of other options

EO (page 25)

CEQA good purpose but in practice just a lot of red tape

EO (page 25)

AB 130 & SB 131

EO (page 25), Bee article (page 32)

All affordable housing projects don’t need environmental review

EO (page 26)

Lasts indefinitely

EO (page 26)

Quarterly reports by LCI and coalition of advocates

EO (page 27)

Qualifying criteria to be an affordable housing project

EO (page 26)

CCG mission

Enforcing environmental compliance in CA (Hanagan Dep. 28)

How CCG learned about SHP/EO

Bee article (Hanagan Dep. page 28n Bee article page 32)

CCG knew about AB130/SB131

But EO gives blanket exemption/even in environmentally sensitive areas

Also bills went through legislative process

Hanagan Dep (page 29)

CCG didn’t reach out first, just immediately filed suit

Hanagan Dep p. 29

CCG acknowledges suit delaying affordable housing

Hanagan Dep. page 31

Sac Bee article

Page 32

SHP description (elements and page numbers)

500 units

Intends to be for extremely low income households to address homelessness

Apartments and businesses/community spaces

By builder with no violations

Located on infill land with minimal environmental sensitivity

Pages 35-37

Swainson’s hawk (threatened species)

Page 32

Remus affidavit

Pages 39-41

Luke Remus qualifications

Half Moon Bay city manager

League of CA cities board member

HMB measures to address homelessness

Job fair

Tent shelters

Food banks/potlucks

Basic healthcare

Page 40

HMB eradicated homelessness (date and page number)

June 1, 2025

Page 40

Remus sent letter to GP but got no response (date sent and page number)

June 25, 2025

Page 40

Other cities in CA are using similar methods to HMB

Page 40

“Varied and targeted efforts”

Page 41

Trial court opinion

Pages 42-47

Trial court outcomes (content and pages)

Sustained D’s evidentiary objection to Remus affidavit (page 43)

Homelessness is emergency (page 44)

EO is constitutional (page 46)

“Chronic” conditions not N/A

Opinion page 45

Cases trial court uses

Schwarzenegger

Ghost Golf

Newsom

TC: No procedural issues with how GP did EO

Page 46

CCG appeals (date and page)

October 17, 2025 (page 48)

TC Opinion date

October 13, 2025