Mircea,
We are in receipt of the below correspondence. I understand City staff separately responded to you regarding recordation of the map. Please note that Quimby Act fees are exempt from the requirements of Gov. Code sections 66001 and 66006 per the definition of “fee” in Gov. Code section 66000(b).
Nira F. Doherty | Partner
she, her, hers
Burke, Williams & Sorensen, LLP
181 Third Street - Suite 200, San Rafael, California 94901
D 415.755.2603 | O 415.755.2600 | F 415.482.7542
ndoherty@bwslaw.com
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From: Mircea
Sent: Wednesday, January 21, 2026 1:24 PM
To: Doherty, Nira F. ; Murphy, Justin I C
Cc: Mitch, Azalea A ; Ebby Sohrabi ; city.council@menlopark.gov; Yung, Brandon@HCD ; Andres, Troy@HCD ; Wilcox, Mindy@HCD ; jack@yesinmybackyard.org
Subject: Formal Protest of Recreation Fee and Confirmation of Final Parcel Map Recordation – 12 Maywood Lane
[EXTERNAL]
________________________________
Nira and Justin-
This email serves as a formal protest by the Applicant regarding the $127,400 recreation fee imposed in connection with the property located at 12 Maywood Lane, Menlo Park, California, and the City’s actions that are obstructing and delaying the recording of the Final Parcel Map for this property.
The Applicant disputes the legal basis, applicability, and amount of the recreation fee as currently assessed. The Applicant further objects to any effort by the City to condition, withhold, or delay recordation of the Final Parcel Map based on payment of this disputed fee.
The Final Parcel Map has otherwise satisfied all applicable conditions and requirements for recordation. Conditioning recordation on payment of a contested fee is improper and has resulted in unwarranted delay and harm to the Applicant.
Accordingly, the Applicant:
· Formally protests the imposition of the $127,400 recreation fee;
· Objects to the obstruction and delay of the Final Parcel Map recordation; and
· Reserves all rights, claims, and remedies, including but not limited to the right to initiate legal action against the City of Menlo Park to challenge the fee and to recover any fees paid under protest, together with interest, costs, and attorneys’ fees as permitted by law.
Nothing in this correspondence shall be construed as a waiver of any rights, defenses, claims, or remedies, all of which are expressly reserved.
For clarity and to avoid any further delay, please note that the disputed fees were paid today under protest, and the Applicant will be present at the City counter tomorrow afternoon at 1 PM to pick up the two (2) Mylar copies signed Final Parcel Map signed by Public Works, as well as the City Clerk or PW lien letter necessary for San Mateo County recordation.
Please confirm the City’s position regarding recordation of the Final Parcel Map without further delay and confirm that all required documents will be available for pickup as indicated.
Sincerely,
Mircea Voskerician
12 Maywood LLC/Owner