See how Europe tackles billboard problems

Here's a piece of news from across the pond. This is how one group deals with the billboard problems in France.

DISPATCH FROM PARIS

In Paris, an anti-ad insurgency

Activists opposed to billboards invite police to rallies where they tag the offending signs, seeking a day in court.

By Sebastian Rotella and Audrey Bastide
7:33 PM PST, January 31, 2009

Reporting from Paris -- Over the centuries, the French have cultivated the fine art of rebellion.

The list of targets encompasses tyrants, wars, colonialism and, above all, capitalism in its many manifestations. The latest enemy may seem unlikely: billboards.

The Dismantlers, as a nationwide group of anti-ad crusaders call themselves, aren't violent or loud or clandestine. In fact, they invite the police to protest rallies where they deface signs. With a copywriter's flair, one of their slogans warns: "Attention! Avert your eyes from ads: You risk being very strongly manipulated." The goal of the Dismantlers is to get arrested, argue the righteousness of their cause in court and, you guessed it, gain publicity.

"We challenge the mercantile society that destroys all human relationships, professional relationships, health, the environment," said Alexandre Baret, 35, a founder of the group. "It's a message that proposes to attack advertising as the fuel of this not very healthy society."

Despite the stick-it-to-the-man rhetoric, there were neckties and briefcases in the crowd at an evening rally here a while back. Part-time insurgents had come from work for the gathering in the Place Malesherbes, an elegant, tree-lined plaza graced by statues of the author Alexandre Dumas and his musketeer hero D'Artagnan, one of literature's most irrepressible swashbucklers.

The 80-odd demonstrators, looking bohemian and stylish, listened to Baret set the ideological stage. The red-bearded schoolteacher and father of four explained that he doesn't want to abolish advertising, just limit signs to no more than 1.2 feet by 1.6 feet. The current wall-size dimensions are obtrusive and oppressive, he said.

The large and colorful billboards that are a fixture of the Paris streetscape are hard to ignore, especially the many suggestive ads for undergarments. Some consider them artistic; religious fundamentalists condemn them as proof of Western decadence.

"You see commercial messages every day, you get them right in the face, in the subway, in the street, all the time, and if you don't want to, you do not have the choice," Baret declared over a megaphone. "So we are obliged to resort to civil disobedience. In a symbolic manner, we will tag a few billboards in order to provoke debate and push for things to progress."

Baret urged the crowd to give a cordial welcome to the police. Advised by the activists ahead of time, the authorities had dispatched a squad of riot police, the renowned head-thumpers of the CRS, or Republican Security Companies.

The officers formed a cordon: burly and stern in blue uniforms, black gloves, pants tucked into lace-up boots. They looked bemused. They were no doubt thankful to tangle with polite leftists instead of housing-project gangs who have been known to "welcome" police with bricks, Molotov cocktails and gunfire.

Under Baret's direction, three activists approached billboards promoting audiovisual products and a television talk show and spray-painted them with slogans. The police slapped on handcuffs and led their prisoners to a van. There was applause. An accordion accompanied the crowd in a popular song, "The Deserter," with lyrics modified for the occasion. And that was that.

The Dismantlers represent an enduring contradiction of the French mentality. The center-right won the last elections by a comfortable margin. Juggernaut industries sell the world everything from jets to trains to wine. The average citizen enjoys long vacations, a beach or country home and a lifestyle that is the envy of the West.

Nonetheless, a large percentage of the population tells pollsters that it is hostile to the capitalist system. That ideological current produced the anti-advertising movement, which took off in 2003 and has won sympathy with its mix of economic and environmental messages.

"I think that when you get down to it, they are right," said Marina, 33, a restaurant worker who stopped to see what the fuss was about in the Place Malesherbes. "Between TV, Internet and advertising billboards, we are told about consumption all the time."

But Marina expressed doubt that this particular mini-revolution would triumph.

"I find it funny, but a little useless," she said. "I think tagging ads bothers passersby more than anything. A sign full of graffiti is even worse than having to look at an ad."

Unlike anarchists or other groups that engage in hit-and-run tactics, the Dismantlers see the courtroom as a battlefield of choice. They gather contributions to pay fines that are often low because judges tend to be lenient and the vandalism is calculated to remain minimal.

Baret appeared at a hearing last month on charges of "unauthorized advertising." The case involved an incident in 2007 when he was caught plastering commuter trains with the "avert your eyes" stickers.

Baret, who like his fellow insurgents is a veteran defendant, had refused to pay the $58 fine. His lawyer argued that his actions were less destructive than the 57,000 giant signs that fill the train stations of France.

"The advertisements are energy-intensive, they use paper from forests," the lawyer said. "It's an assault on individual liberties, an advertising aggression."

In response, the prosecutor reminded the accused that "the tribunal is not a tribune." A lawyer representing the French railroad company, which demanded a symbolic $1.30 in damages and $650 for legal costs, chided the activists for returning to rabble-rousing of "years ago."

A verdict is expected in February. But the Dismantlers say they have already won by making people stop and think about the messages that bombard them each day.

"The advertising budget in France is $39 billion a year," said Antoine Trouillard, a 26-year-old philosophy student and activist.

"That's equivalent to the entire education budget in France. . . . Our movement goes a lot further than a simple symbolic gesture. And that's what we want the public to understand."

rotella@latimes.com

Bastide is a special correspondent.

Arraignment continued in 10801 sign case

Today was the arraignment date for a 44 count criminal complaint handed down by the City of Los Angeles and levied against Barry Rush of World Wide Rush, 10801 building owners Frank Rahban and a list of others -- see all the individuals involved and details by clicking here.

They are charged with numerous infractions from fire code violations to unlawfully installing OUTDOOR LIGHTING WITHOUT A PERMIT. We were notified that the arraignment date was continued and a new arraignment was set for April 2, 2009. We learned that many times these complicated cases follow in this direction.

Stay tuned.

NEWS STORY LINKS WWR TO TREE CUTTING

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Lori Shepler / Los Angeles Times

One of the 15 trees that got a major whacking is next to the 405 Freeway near the Sherman Oaks Galleria. A row of 15-foot trees were cut down to 3 or 4 feet.

Lori Shepler / Los Angeles Times

L.A. officials miffed at mysterious trimming of trees near billboards
One of the 15 trees that got a major whacking is next to the 405 Freeway near the Sherman Oaks Galleria. A row of 15-foot trees were cut down to 3 or 4 feet.

Removal of the landscaping improved the visibility of enormous ads placed by outdoor advertising firm World Wide Rush. Company officials deny involvement in the vandalism.

By Alexandra Zavis
9:02 PM PST, February 25, 2009

The mysterious felling of roughly two dozen trees near city billboards has provoked finger pointing between state transportation officials and an advertising firm, and added fuel to a heated debate involving outdoor advertising in Los Angeles.

Vandals apparently used chain saws to cut back the trees, which had been planted along the 10 and 405 freeways under a California Department of Transportation landscaping initiative. It seems the rogue tree cutters wanted to increase the visibility of enormous ads erected by the World Wide Rush advertising company, said Daniel Freeman, a Caltrans deputy district director for maintenance.

"I can't imagine why anyone else would want to cut down these trees," Freeman said.

The advertising firm says it had nothing to do with the matter.

Paul Fisher, a Newport Beach lawyer representing World Wide Rush, accused officials of looking for ways to get around federal rulings that limit the city's ability to ban digital signs and large ads known as "supergraphics," which cover entire buildings.

Freeman said the trees were cut back in December and January, just before World Wide Rush put up supergraphics for Tropicana juice on a parking structure at the Sherman Oaks Galleria and a six-story building on National Boulevard, near the 10 Freeway.

The damaged landscaping included a row of 15-foot Brisbane box evergreens that were cut down to 3 or 4 feet, Freeman said. Caltrans had planted the trees near the Galleria at a cost of about $2,500 to $3,000 each, in order to screen the 405 Freeway, he said.

"I am particularly annoyed that these were the ones that got hit," Freeman said. "These were essentially brand new."

Five or six more trees were felled near the building on National Boulevard, he said, along with five belonging to the shopping mall.

Katherine Defever, a Galleria representative, said mall officials were baffled when they noticed the destruction and had initially assumed that Caltrans officials were cutting back landscaping themselves.

Freeman said Caltrans was notified of the cutting by City Atty. Rocky Delgadillo, who filed criminal charges in January against World Wide Rush and National Investment Co. -- owners of the building at 10801 National Blvd. -- for allegedly putting up an unauthorized sign and violating safety regulations.

World Wide Rush contends the charges are in contempt of a federal ruling that found a 2002 city ban on new billboards unconstitutional. Although that decision is under appeal, the company won an injunction preventing officials from banning supergraphics at 34 buildings, including the one on National.

Freeman said the sign on National violates the California Outdoor Advertising Act, which gives Caltrans control over advertising displayed within 660 feet of a freeway. The department is conducting its own investigation into the matter, he said.

While Freeman hopes to replace the damaged landscaping, he said the department would not be able to afford to put in mature trees like the ones that were lost.

alexandra.zavis@latimes.com

IF CALTRANS DIDN'T CHOP DOWN THOSE TREES...

Reports say that healthy trees in front of 10801 were hacked down -- and not by Caltrans state officials. See story from the Daily News:


Felled roadside trees stump Caltrans Officials

By Sue Doyle, Staff Writer

Updated: 02/23/2009 09:52:13 PM PST

Toxic spills, chunks of concrete and discarded mattresses are among the things Caltrans workers keep a watchful eye on.

Now they have something else to add to their list of worries: rogue landscapers.

Over the past several months, rows of 15-foot trees that were to be used as noise barriers or screens near the 405 and 10 freeways have been cut down in an apparent bid to make nearby billboards - one of them illegal - more visible.

All of the ads were for Tropicana orange juice and all of them might have been put up by the same billboard company, World Wide Rush, which did not return phone calls. Tropicana also did not return calls.

It's not the first time trees near billboards have disappeared in Los Angeles. A

Some photos of the 21 heavily trimmed trees.

magnolia tree was hacked down in 2001 along the Sunset Strip and three palm trees were poisoned near Los Angeles International Airport a few years later.

But this is one of the first times Caltrans has had to deal with the problem. As for who the culprits could be, officials say they're stumped.

"It's really disturbing to me and disturbing to staff, because we have a lot of dead and dying landscape," said Daniel Freeman, Caltrans' deputy district director of maintenance. "And here someone comes along and cuts down healthy ones for no good reason."

City Attorney Rocky Delgadillo has filed charges against World Wide Rush, which put up the illegal billboard near the 10 Freeway and National Boulevard, and the owner of the

six-story building where it hangs.

A spokeswoman for the Sherman Oaks Galleria said World Wide Rush also operated the two billboards attached to the mall's parking structures, where other trees were cut down.

But the culprits - who probably used chain saws to take down a total of 17 Brisbane Box evergreens that can grow to 60 feet - have never been seen, or heard of, despite their noisy trade.

Their hasty landscaping jobs can be seen near the Sherman Oaks mall, where 12 trees were cut down, and at the 10 Freeway and National Boulevard offramp, where five other trees were felled. The trees cost at least $1,500 each, plus some $1,000 has spent to keep them up over the years.

"They did a terrible job cutting them down," Freeman said, describing the $42,500 in damage. "They weren't landscapers."

Given today's free-falling economy, it's unknown when the state agency can afford to replace the mutilated trees, Freeman said.

The trees are part of a massive landscaping investment the state agency makes to muffle clanky roadway noise and add easy-breathing aesthetics to its 45,000 miles of highway and freeway lanes.

Freeman said it looks like the trees were cut with chain saws, allowing the vandals to act quickly.

Vandals are believed to have worked in the dead of night, chopping each tree, leaving about half standing jagged in the ground and then hiding the debris behind other landscaping.

Caltrans was notified of its trashed trees near National Boulevard after receiving a phone call in late January from Delgadillo's office.

Delgadillo filed criminal charges on Jan. 30 against World Wide Rush and the building owner for illegally erecting the massive billboard without a permit and for installing a bright supergraphic sign after the city issued a moratorium on them.

The Federal Highway Administration is producing a study for Congress on supergraphic and digital signs to see if their razzle-dazzle displays distract drivers and endanger the highways. The report should be done this year.

When charges were filed, the supergraphic billboard in question advertised Tropicana orange juice. It has since been changed.

"It's still illegal. It doesn't matter what it says," said Asha Greenberg, assistant city attorney. "It's the fact that it's there."

Greenberg said charges for cutting down the trees are not included in the lawsuit, but that the office is interested in hearing from anybody who saw it happen.

Staff at the Sherman Oaks Galleria noticed a "severe pruning of the trees" next to the 405 Freeway and on five of their own trees in late December, said Katherine Defevere, general manager.

Weeks later two billboards for Tropicana orange juice were hung from the landmark mall's parking structure. Defevere said they are owned by World Wide Rush and that it's the first time the mega mall ever displayed billboards on its parking garage.

Defevere said the trees were too short to ever block the freeway view of the signs and believes that the hacked trees were a landscaping error.

"We don't know what happened," Defevere said. "We think someone did it by mistake."

sue.doyle@dailynews.com 818-713-3741

BILLBOARD Q & A OF THE DAY

Q: Outside of downtown, most of the city’s commercial areas are composed of streets closely bordered by apartment houses and single-family homes. What measures would you support to protect residents in those apartments and homes from light trespass and views of billboards, supergraphic signs, and other commercial advertising located on adjacent commercial properties?

A: We can regulate bright lights as a nuisance. As noted above, moreover, I support a ban on new billboards — including wrapping buildings in tacky plastic bags.

• WALTER MOORE, CANDIDATE FOR MAYOR, L.A., CA

Click here to find out what other public figures who are running for government positions have to say about the signage problem in Los Angeles.

Dr. Allan with the Bill Handel Show KFI AM640

First interview was aired on the John and Ken Show on Saturday 1/31/09 -- See audio link below the related links on the left side bar.

Second interview was aired on the Bill Hanel Show on Friday 2/20/09 -- See audio link on the top of page on the left side bar.

There was another interview on the Doug McIntyre show on 02/04/09, but there was not much time to get the message out, but we did follow up with a post that sent the message loud and clear.

What Happens in Court at a Criminal Arraignment?

From an article on the web... for link click here.
By Steve Thompson

Arraignment is one of the lesser-understood portions of the criminal court process, and is necessary to establish the identity of a defendant and to determine a plea. Each state handles criminal arraignment differently, but there are a few things that remain the same no matter where you live.

The most important thing to remember is that criminal arraignment is a court appearance, and should be treated as such.When you appear in court at a criminal arraignment, you will be taken in front of a judge. You have the option to request legal counsel at that time, either in the form of a private attorney or as a public defender.

You can also waive your right to counsel if you prefer to represent yourself, but this isn't advisable. Not only are you entering a plea, but you will also be given a bail amount.When you first stand in front of the judge in court at a criminal arraignment, you will be asked to verify who you are. This is to ensure that there are no mistakes in the identity of a defendant, and to avoid such defenses later at trial.

You may be asked to provide photo identification for the court, or your word may be taken at face-value.In some states, the judge will take the time at a criminal arraignment to explain the charges against the defendant. If this is the case, he or she may also state the possible punishment, such as the maximum fine or jail sentence.

In other states, the defendant is simply handed a statement that has been prepared by the prosecutor, and outlines the charges and the reasons for their existence.You will also be asked to enter a plea at criminal arraignment, which will be put on the record. It is not advisable to enter a guilty plea in court at this time because, even if you intend to plead guilty, you may be able to receive a reduced charge as a result of a plea agreement with the prosecutor. However, you do have the choice to enter a plea of guilty, not guilty, or, in some states, no contest.Once you have entered a plea, your defense attorney (or you) and the prosecutor will be allowed to make recommendations as to the bail amount.

The judge can do one of three things: set a bail amount, release the defendant on his own recognizance, or deny bail entirely. In most states, remand (bail denial) is reserved only for first-degree murder charges, and only non-violent offenders are released on their own recognizance (ROR).The final court business at a criminal arraignment is the scheduling of future trials and hearings. For misdemeanors and other smaller crimes, the trial date may be set at this time, and you'll be told to appear whenever the court fits you in.

For felony charges, however, a preliminary hearing is usually scheduled, but not the actual trial date. The trial will not commence until after discover, jury selection and motion hearings.

---

2009 © Associated Content, All rights reserved.
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WOW: AMENDED 44 COUNT CRIMINAL COMPLAINT

Here's a scanned document of the 44 count criminal complaint. This copy is for reference only -- Since it was scanned, there most likely are some errors. If you would like to have a signed and sealed pdf, send an email and we will reply back with one to you.

ARRAIGNMENT SET FOR THURSDAY, FEB. 26, 2009

THE PEOPLE OF THE STATE OF CALIFORNIA,
VA 02/26/2009 Bkg no. Plaintiff,
vs.
WORLD WIDE RUSH, A PENNSYLVANIA LLC. HORBORCO, LLC.
BARRY LEIGH RUSH M 08/05/1957
LESLYE M. RUSH F 05/25/1961
FRANK RAHBAN M 03/05/1942
LOIS F. AGAPAY F 03/24/1951
aka LOIS KAY GLOWOSKI, LOIS KAY FORSHEE
SENOUBAR RAHBAN F 01/08/1921
DJAMSHID YOUNESSI M 06/12/1945
SAEED YOUNESI M 11/29/1952
PERRY RAHBAN M 04/06/1940
aka PARVIZ RAHBAN
SAID RAHBAN M 09/17/1945
RALPH ABOULAFIA M 10/28/1923
MD GRAPHIC INSTALLERS, INC.
MARK DENNY M 12/17/1966
LAMC 91.6201.4, LAMC 57.12.02, BP 5405,
BP 5440, BP 5350, PC 372
(44 COUNTS) Defendant(s).

FIRST AMENDED MISDEMEANOR COMPLAINT
FILED IN L.A. SUPERIOR COURT FEB. 17, 2009
SIGNED: JOHN A. CLARKE, EXECUTIVE OFFICER/CLERK
Issued by
ROCKARD J. DELGADILLO City Attorney
By: ERIC ROSENBLATT,
DEPUTY CITY ATTORNEY

INTRODUCTION

On December 26, 2008, city of Los Angeles Ordinance No. 180445, also known as the Interim Control Ordinance ("ICO"), became effective. That ordinance provides in relevant part that, "for a period of 90 days from the effective date of this ordinance, or until a permanent ordinance which amends the citywide provisions governing Off-Site Signs, including Supergraphic Signs becomes effective, whichever occurs first[,]... [n]o person shall erect, place, alter or construct any Off-Site Sign…”

As of the date of the filing of this First Amended Complaint, the ICO remains effective.

COUNT I
On or about DECEMBER 27, 2008 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully erect, construct, or install a sign support structure, to wit, did install cables and eyebolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3, and in contravention to the Interim Control Ordinance.
TCIS 91.6201.4/01

COUNT II
For a further, separate and SECOND cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in Count I hereof, affiant further alleges that on or about JANUARY 15, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT III
For a further, separate and THIRD cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about JANUARY 16, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01


COUNT IV
For a further, separate and FOURTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about JANUARY 17, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI
AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT V
For a further, separate and FIFTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about JANUARY 18, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT VI
For a further, separate and SIXTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about JANUARY 19, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT VII
For a further, separate and SEVENTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about JANUARY 20, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY -RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT VIII
For a further, separate and EIGHTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about JANUARY 21, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT IX
For a further, separate and NINTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about JANUARY 22, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT X
For a further, separate and TENTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about JANUARY 23, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT XI
For a further, separate and ELEVENTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about JANUARY 24, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT XII
For a further, separate and TWELFTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about JANUARY 25, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT XIII
For a further, separate and THIRTEENTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about JANUARY 26, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT XIV
For a further, separate and FOURTEENTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about JANUARY 27, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT XV
For a further, separate and FIFTEENTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about JANUARY 28, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT XVI
For a further, separate and SIXTEENTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about JANUARY 29, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit, those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT XVIII
For a further, separate and SEVENTEENTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about JANUARY 30, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT XVIII
For a further, separate and EIGHTEENTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about JANUARY 31, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT XIX
For a further, separate and NINETEENTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about FEBRUARY 1, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT XX
For a further, separate and TWENTIETH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about FEBRUARY 2, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT XXI
For a further, separate and TWENTY-FIRST cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about FEBRUARY 3, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT XXII
For a further, separate and TWENTY-SECOND cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that beginning on or about JANUARY 15, 2009, and until on or about FEBRUARY 4, 2009, at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Subsection A of Section 57.12.02 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; FRANK RAHBAN; BARRY LEIGH RUSH; LESLYE M. RUSH; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully install and maintain an obstruction to an opening in an exterior wall required for Fire Department access, in such a manner as to obstruct access or egress, or cause a hazardous condition in the event of fire or other emergency, by obstructing windows of an occupied high-rise building at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles with the installation of an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts.
MCI 57.12.02/01

COUNT XXIII
For a further, separate and TWENTY-THIRD cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that beginning on or about JANUARY 15, 2009 and until on or about FEBRUARY 4, 2009, at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 5405 of the California Business and Professions Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully place and maintain an advertising display, consisting of an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, within 660 feet from the edge of the right-of-way of the I-10 Freeway, which is an interstate or primary highway, which advertising display was and is visible from an interstate or primary highway, without a written permit from the Director of the California Department of Transportation, in violation of the Outdoor Advertising Act, California Business and Professions Code Section 5200 et seq.
MCI BP 5405/04

COUNT XXIV
For a further, separate and TWENTY-FOURTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth the previous counts herein alleged, affiant further alleges that beginning on or about JANUARY 15, 2009 and until on or about FEBRUARY 4, 2009, at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 5440 of the California Business and Professions Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully place and maintain an advertising display, consisting of an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, on property adjacent to a section of a freeway that has been landscaped, which advertising display was and is designed to be viewed primarily by persons traveling on the main-traveled way of the landscaped freeway, in violation of the Outdoor Advertising Act, California Business and Professions Code Section 5200 et seq.
MCI 5440/04

COUNT XXV
For a further, separate and TWENTY-FIFTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth the previous counts herein alleged, affiant further alleges that beginning on or about JANUARY 15, 2009 and until on or about FEBRUARY 4, 2009, at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 5350 of the California Business and Professions Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully place and maintain an advertising display, consisting of an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, within an area affected by the provisions of the Outdoor Advertising Act, California Business and Professions Code Section 5200 et seq., in the State of California, without first having secured a written permit from the Director of the California Department of Transportation or from his authorized agent.
MCI 5350/04

COUNT XXVI
For a further, separate and TWENTY-SIXTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that beginning on or about JANUARY 15, 2009 and until on or about FEBRUARY 4, 2009, at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 372 of the California Penal Code was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN;
`DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully maintain or commit a public nuisance, as defined in Section 5461 of the Business and Professions Code by the placement or existence of en advertising display in violation of the Outdoor Advertising Act, California Business and Professions Code Section 5200 et seq., and did so by placing and maintaining a sign, consisting of an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles.
MCI 372/21

COUNT XXVII
For a further, separate and TWENTY-SEVENTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in Count I hereof, affiant further alleges that on or about FEBRUARY 12, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully erect, construct, install, alter, move, convert, use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising DR. PHIL and CBS TELEVISION, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT XXVIII
For a further, separate and TWENTY-EIGHTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about FEBRUARY 13, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising DR. PHIL and CBS TELEVISION, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT XXIX
For a further, separate and TWENTY-NINTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about FEBRUARY 14, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was
committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising DR. PHIL and CBS TELEVISION, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT XXX
For a further, separate and THIRTIETH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about FEBRUARY 15, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising DR. PHIL and CBS TELEVISION, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT XXXI
For a further, separate and THIRTY-FIRST cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about FEBRUARY 16, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising DR. PHIL and CBS TELEVISION, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT XXXII
For a further, separate and THIRTY-SECOND cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about FEBRUARY 17, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully use or maintain a sign or sign support structure, to wit, an approximately 50' by 140' vinyl sign advertising DR. PHIL and CBS TELEVISION, attached to the north exterior wall of the building by way of cables and eye-bolts, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT XXXIII
For a further, separate and THIRTY-THIRD cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about FEBRUARY 12, 2009 and continuing thereafter, at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Subsection A of Section 57.12.02 of the Los Angeles Municipal Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; FRANK RAHBAN; BARRY LEIGH RUSH; LESLYE M. RUSH; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully install and maintain an obstruction to an opening in an exterior wall required for Fire Department access, in such a manner as to obstruct access or egress, or cause a hazardous condition in the event of fire or other emergency, by obstructing windows of an occupied high-rise building at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles with the installation of an approximately 50' by 140' vinyl sign advertising DR. PHIL and CBS TELEVISION, attached to the north exterior wall of the building by way of cables and eye-bolts. MCI 57.12.02/01

COUNT XXXIV
For a further, separate and THIRTY-FOURTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about FEBRUARY 12, 2009 and continuing thereafter, at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 5405 of the California Business and Professions Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully place and maintain an advertising display, consisting of an approximately 50' by 140' vinyl sign advertising DR. PHIL and CBS TELEVISION, attached to the north exterior wall of the building by way of cables and eye-bolts, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, within 660 feet from the edge of the right-of-way of the I-10 Freeway, which is an interstate or primary highway, which advertising display was and is visible from an interstate or primary highway, without a written permit from the Director of the California Department of Transportation, in violation of the Outdoor Advertising Act, California Business and Professions Code Section 5200 et seq.
MCI BP 5405/04

COUNT XXXV
For a further, separate and THIRTY-FIFTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth the previous counts herein alleged, affiant further alleges that on or about FEBRUARY 12, 2009 and continuing thereafter, at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 5440 of the California Business and Professions Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully place and maintain an advertising display, consisting of an approximately 50' by 140' vinyl sign advertising DR. PHIL and CBS TELEVISION, attached to the north exterior wall of the building by way of cables and eye-bolts, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, on property adjacent to a section of a freeway that has been landscaped, which advertising display was and is designed to be viewed primarily by persons traveling on the main-traveled way of the landscaped freeway, in violation of the Outdoor Advertising Act, California Business and Professions Code Section 5200 et seq.
MCI 5440/04

COUNT XXXVI
For a further, separate and THIRTY-SIXTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth the previous counts herein alleged, affiant further alleges that on or about FEBRUARY 12, 2009 and continuing thereafter, at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 5350 of the California Business and Professions Code, was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR. RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully place and maintain an advertising display, consisting of an approximately 50' by 140' vinyl sign advertising DR. PHIL and CBS TELEVISION, attached to the north exterior wall of the building by way of cables and eye-bolts, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, within an area affected by the provisions of the Outdoor Advertising Act, California Business and Professions Code Section 5200 et seq., in the State of California, without first having secured a written permit from the Director of the California Department of Transportation or from his authorized agent.
MCI 5350/04

COUNT XXXVII
For a further, separate and THIRTY-SEVENTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about FEBRUARY 12, 2009 and continuing thereafter, at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 372 of the California Penal Code was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully maintain or commit a public nuisance, as defined in Section 5461 of the Business and Professions Code by the placement or existence of an advertising display in violation of the Outdoor Advertising Act, California Business and Professions Code Section 5200 et seq., and did so by placing and maintaining a sign, consisting of an approximately 50' by 140' vinyl sign advertising DR. PHIL and CBS TELEVISION, attached to the north exterior wall of the building by way of cables and eye-bolts at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles.
MCI 372/21

COUNT XXXVIII
For a further, separate and THIRTY-EIGHTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about FEBRUARY 12, 2009 and continuing thereafter, at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 93.0201 of the Los Angeles Municipal Code was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully install, alter, reconstruct or repair any electrical wiring, to wit, OUTDOOR ELECTRICAL ILLUMINATION, without having obtained a permit therefor from the Los Angeles Department of Building and Safety.
TCIS 93.0201/01

different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that on or about FEBRUARY 12, 2009 and continuing thereafter, at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 93.0104 of the Los Angeles Municipal Code was committed by WORLD WIDE RUSH, A PENNSYLVANIA LLC; HARBORCO, LLC; BARRY LEIGH RUSH; LESLYE M. RUSH; FRANK RAHBAN; LOIS F. AGAPAY AKA LOIS KAY GLOWASKI AKA LOIS KAY FORSHEE; SENOUBAR RAHBAN; DJAMSHID YOUNESSI; SAEED YOUNESI; PERRY RAHBAN AKA PARVIZ RAHBAN; SAID RAHBAN; AND RALPH ABOULAFIA, who at the time and place last aforesaid, did unlawfully install, operate or maintain electrical systems or equipment, to wit, OUTDOOR ELECTRICAL ILLUMINATION WITHOUT A PERMIT, which do not comply with all of the applicable provisions of the Los Angeles Electrical Code.
TCIS 93.0104/01

COUNT XXXX
For a further, separate and FORTIETH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that beginning on or about DECEMBER 27, 2008 and until on or about JANUARY 15, 2009 at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 91.6201.4 of the Los Angeles Municipal Code, was committed by MD GRAPHIC INSTALLERS, INC. and MARK ALLEN DENNY, who at the time and place last aforesaid, did unlawfully erect, construct, or install a sign or sign support structure, to wit, did install cables and eye-bolts and an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, or cause or permit those actions to be done, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, without having first obtained a building permit from the Department of Building and Safety in accordance with the provisions of Los Angeles Municipal Code Sections 91.6201.2 and 91.106.3.
TCIS 91.6201.4/01

COUNT XXXXI
For a further, separate and FORTY-FIRST cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that beginning on or about JANUARY 15, 2009, at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Subsection A of Section 57.12.02 of the Los Angeles Municipal Code, was committed by MD GRAPHIC INSTALLERS, INC. and MARK DENNY, who at the time and place last aforesaid, did unlawfully install and maintain an obstruction to an opening in an exterior wall required for Fire Department access, in such a manner as to obstruct access or egress, or cause a hazardous condition in the event of fire or other emergency, by obstructing windows of an occupied high-rise building at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles with the installation of an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts.
MCI 57.12.02/01

COUNT XXXXII
For a further, separate and FORTY-SECOND cause of action, being a different offense but belonging to the same class of crimes and offenses set forth in the previous counts herein alleged, affiant further alleges that beginning on or about JANUARY 15, 2009, at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 5405 of the California Business and Professions Code, was committed by MD GRAPHIC INSTALLERS, INC. and MARK DENNY, who at the time and place last aforesaid, did unlawfully place and maintain an advertising display, consisting of an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, within 660 feet from the edge of the right-of-way of the I-10 Freeway, which is an interstate or primary highway, which advertising display was and is visible from an interstate or primary highway, without a written permit from the Director of the California Department of Transportation, in violation of the Outdoor Advertising Act, California Business and Professions Code Section 5200 et seq.
MCI BP 5405/04



COUNT XXXXIII
For a further, separate and FORTY-THIRD cause of action, being a different offense but belonging to the same class of crimes and offenses set forth the previous counts herein alleged, affiant further alleges that beginning on or about JANUARY 15, 2009, at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 5440 of the California Business and Professions Code, was committed by MD GRAPHIC INSTALLERS, INC. and MARK DENNY, who at the time and place last aforesaid, did unlawfully place and maintain an advertising display, consisting of an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, on property adjacent to a section of a freeway that has been landscaped, which advertising display was and is designed to be viewed primarily by persons traveling on the main-traveled way of the landscaped freeway, in violation of the Outdoor Advertising Act, California Business and Professions Code Section 5200 et seq.
MCI 5440/04

COUNT XXXXIV
For a further, separate and FORTY-FOURTH cause of action, being a different offense but belonging to the same class of crimes and offenses set forth the previous counts herein alleged, affiant further alleges that beginning on or about JANUARY 15, 2009, at and in the City of Los Angeles, in the County of Los Angeles, State of California, a misdemeanor, to wit, a violation of Section 5350 of the California Business and Professions Code, was committed by MD GRAPHIC INSTALLERS, INC. and MARK DENNY, who at the time and place last aforesaid, did unlawfully place and maintain an advertising display, consisting of an approximately 50' by 140' vinyl sign advertising TROPICANA ORANGE JUICE, attached to the north exterior wall of the building by way of cables and eye-bolts, at 10801 WEST NATIONAL BOULEVARD within the City of Los Angeles, within an area affected by the provisions of the Outdoor Advertising Act, California Business and Professions Code Section 5200 et seq., in the State of California, without first having secured a written permit from the Director of the California Department of Transportation or from his authorized agent.
MCI 5350/04

DR. PHIL'S SIGN COMES DOWN IN 6 DAYS

We give CBS and Dr. Phil credit here. Their ad went up against the 10801 building last week, and with all the negative feedback from the public, they ordered it to come down.

Paul Fisher, attorney for World Wide Rush states in the article printed below: "We would not have posted a sign if we were not absolutely certain that it was not a hazard".

Mr. Fisher said the sign met all state and local fire safety standards.

We would like to know what does that mean? If we can get that documentaion from Mr. Fisher, we would be glad to post it. In a previous sign (Tropacana O.J. Ad -- Pepsico, Inc.) that went up on the 10801 building, the Los Angeles Fire Dept. cited the building for 2 fire code violations and put the building on a fire watch. Then when they put up another sign (CBS - Dr. Phil Show), the LAFD again cited them for fire code violations and put the building on a fire watch.

How many citations from the LAFD does the building owners and World Wide Rush have to receive before they stop putting up these hazardous signs that risk public safety? To see the fire code violations, click here.

Has Mr. Fisher had any conversations with the Chiefs or Captains.of the LAFD? We suggest that you contact Chief Fry at 213-978-3575 and he will explain the dangers that your sign poses to the occupants of 10801.

Here's the latest from the Associated Press:

Outcry spurs removal of `Dr. Phil' billboard

By Robert Jablon, The Associated Press

Updated: 02/20/2009 10:16:13 PM PST -- For Article link, click here.

An enormous advertisement for the "Dr. Phil" show was removed from the side of a West Los Angeles building after tenants complained that it blocked their view and might be a fire hazard.

At the request of show officials, the 60-by-100-foot ad was removed on Thursday night from a building on National Boulevard in West Los Angeles, less than a week after it was erected.

"We simply responded to the concerns of the tenants," Theresa Corigliano, a spokeswoman for the show, said Friday. "We would rather have folks view our show, than to block their view."

The billboard company that placed the ad on the six-story building took it down at the request of CBS and the show, said Paul Fisher, an attorney for World Wide Rush LLC.

Corigliano said she received three e-mails from tenants. However, Fisher said he understood that the network and show had received "quite a bit of e-mails and correspondence and phone calls" from people who believed the vinyl mesh sign was a fire hazard.

Fisher said the sign met all state and local fire safety standards.

"We would not have posted a sign if we were not absolutely certain that it was not a hazard," he said.

The Pennsylvania-based company has been locked in a battle with the city over so-called supergraphics, the wall-sized ads placed on the sides of more than a dozen local buildings to serve as enormous billboards.

The ads can cost more than $100,000. Fisher said that the "Dr. Phil" sign was supposed to remain up for 90 days. Because it was taken down sooner, Fisher said, the billboard company will not charge the advertisers for putting it up. He estimated the loss at tens of thousands of dollars.

City prosecutors are investigating supergraphics that allegedly went up in violation of a 90-day city moratorium on the giant signs that went into effect in December. More than 20 criminal charges have been filed against World Wide Rush, alleging fire code violations and other offenses from a juice ad that preceded the "Dr. Phil" sign.

The moratorium was put in place while the city considered new regulations to limit billboards. The Planning Commission was scheduled to consider the rules on Thursday.

New Blog Format Underway

As promised, the posts are cleaned up.

There was quite a bit to go through. If there is any place where you feel personal comments are made against any one's character, write the blog or make a comment.

Once again, why was this done?

• To avoid leagal battles with anyone
• To bring all the attention to the the issues: Keep advertising safe, Stop blighting the urban landscape

CLEAN UP OF BLOG UNDER WAY

After reviewing the blog, I can see how it can be offensive and I've already removed one third of the material. I plan to have this as an issue based site with no personal attacks.

I am aware that legal is tracking this site closely and I don't want to create problems. I really don't. I feel we have made our point and will be scaling back all the fluff. Give us a day and by tomorrow it will be cleaned up.

I especially want Paul Fisher to email me after today, if there are any parts of the blog that needs deleting. I plan to keep our issues in line with the information coming out of the L.A. government.

We will move away from personal references that may be offensive and keep it issue based. We welcome your comments.

World Wide Rush threatens Dr. Allan

In one of my recent posts, I asked folks from the other side of the issue to write and I just received a very serious letter from the attorney that is representing World Wide Rush, LLC, the company responsible for putting up the last two supergraphics over the 10801 location.

I am considering this a harassment letter and I have already contacted the city attorney's office by email asking for their help.

I will include everything in this post that is involved with this notification. This post will consist of 3 main items:

First, I will let you see the letter, then I will comment on the contents, then I will include the email I sent to the city attorney's office.

============

1) Paul E. Fisher's letter to me

Law Office of

Paul E. Fisher

A Professional Corporation

Paul E. Fisher

1000 Bristol St. No., #17-106 Newport Beach, California 92660

Tel (949) 675-5619 Fax (949) 675-5641

February 17, 2009

VIA FEDERAL EXPRESS

David Allan a/k/a David Allan Overstein

10801 National Blvd., Suite 580

Los Angeles, CA 90064

RE: 10801 National Blvd.

Dear Mr. Allan,

This office represents World Wide Rush, LLC in regard to this matter. My client currently operate a supergraphic signs at 10801 National Blvd. pursuant to a permanent injunction issued by a federal district court judge. The injunction prohibits the City of Los Angeles from, among other things, interfering with the signs’ operation or issuing citations to it because the City refuses to process any permit applications or conduct any inspections of the signs.

My client has alerted us to a website which you have apparently created seeking to have the sign removed. We have represented outdoor advertising companies in First Amendment matters for almost 20 years and vigorously support the concept of freedom of expression. However, I must advise you that the purpose of your website appears to be to damage my client’s business relations both with the owner of this property and with its advertising clientele.

While you are certainly entitled to communicate truthful information to whomever you choose, please be aware that you are publicizing false and misleading information. For example, you have repeatedly referred to our client’s sign as “illegal.” As indicated above, the signs are not illegal in any way and have not been so adjudicated in any court. Furthermore, you have recently posted comments on your website which call for violence. While not a complete list, you have suggested that Dr. Phil be wrapped in the supergraphic sign and be “toss[ed]…off the pier.” You have also suggested that someone should take a gun and shoot out the lighting fixtures illuminating the signs. You have also called for “revenge” and suggested that it would be appropriate for individuals to apply the principle of “an eye for an eye.”

The types of signs currently displayed at the above referenced property are lawful and comply with all safety requirements of the Uniform Building Code as well as state and local fire codes. Any suggestion that the signs represent any type of safety hazard is completely false. We demand that you immediately retract all false, misleading and dangerous statements and issue an apology. If you do not do so by Friday, February 20, 2009, we will take all appropriate legal steps to protect our client’s legal interests.

Very truly yours,

PAUL E. FISHER

PEF/tpb

==============

2) Comments and response to the letter

Mr. Fisher, overall I view your letter as a form of harassment and an infringement of my first amendment rights. I view this as a very serious matter and don't take what you say lightly.

First a little housekeeping issues: You misspelled my name and also addressed me as Mr. Allan. From now on it's Dr. Allan to you. Thank you.

I would first like to respond as best I can to your allegations. My responses will be preceded by "DA:". Whatever is not said, I refer you to the email I just sent to the City Attorney's office. That will be in section 3 of this post.

In paragraph 2, "My client has alerted us to a website which you have apparently created..."

DA: Let's be honest with the viewers. Your client didn't alert you to anything. We meet when the second sign went up on Feb. 12, 2009 -- and you told me you were familiar with the blog. Frankly, I liked you. You were very professional and I thought we had a very mature, relaxed conversation. I even told you I sympathized with World Wide Rush (WWR) regarding the lawsuit, but that did not have anything to do with the issue at hand -- the fact that your sign company was putting up a second sign -- the same sign that was deemed to be a fire hazard and a danger to the entire building.

In paragraph 2, "the purpose of your website appears to be to damage my client's business relations both with the owner of this property and with its advertising clientele"

DA: The purpose of my blog is to provide information, both facts and commentary as a way to alert the public. I enjoy writing and like to have some fun when I can. It so happens that a lot of the information that has revolved around your client is negative. I don't have anything personal against World Wide Rush, I just want WWR to obey the law and don't endanger lives with their advertising.

There may be things looked at as personal attacks, and if that's the case I definitely don't endorse that and I apologise for any personal attacks on character. My upset with this issue may have triggered a few comments here and there that were a little harsh. For this I am sorry. I promise that from this point forward to make sure that the focus is more issue based. I did purposely name names for the sake of shaming them -- I want to believe that this will make a difference and prevent others from doing the same.

In paragraph 3, "...false and misleading information."

DA: My statements were based on the public information I heard with my own 2 ears. The term "illegal" is used at Jack Weiss's press conference -- see letter in next section.

In paragraph 3, "...on your website which calls for violence."

DA: I never called for violence. those quotes you reference were other comments from another article. Take a look at a few of these comments:

Let's roll Dr. Phil up in that thing and throw him off a pier.Comment #20, left at 02/13/09 04:16 PM

Wouldn't it be cool if some tagger was able to spray paint a devil's horn's and goatee on that kid?Comment #19, left at 02/13/09 03:21 PM

These quotes and other similar ones can be found here.

You neglected this quote in the blog that I actually stated: statement dated February 17, 2009 7:16 PM: And I want to state publicly that I always seek lawful, non-violent ways to handle disputes. I intend to continue to stand up for what is right with this blog and will intensify actions legally and non-violently until justice is served.

And if that doesn't tell you enough, then I will make a formal statement here and now: I want to make it really clear... I am a non-violent type of person, I'm quiet and to myself, I'm a musician, father, and doctor. I help folks with their health everyday. My main job is to help people live a healthier life -- to live longer, feel better and look younger. I'm a doc that works with kids and families. I've never been a vocal activist regarding any cause. This is the first time I am just standing up for myself against what I believe to be a major injustice against me and the tenants of 10801 and many folks in our beautiful city. I seek non-violent means to bring my point across. If you look here at this post, I give the readers the true power and it's everything but violent -- WRITE, VOTE, TAKE LEGAL ACTION, SPREAD THE WORD. Don't take a few sentences out of context and tell me I'm promoting violence!

In your last paragraph, I find what you say here is appalling: "The types of signs currently displayed at the above referenced property are lawful and comply with all safety requirements of the Uniform Building Code as well as state and local fire codes. Any suggestion that the signs represent any type of safety hazard is completely false."

DA: I'm not familiar with the Uniform Building Code. All I know is what my city officials told me and it's the exact opposite to what you are saying -- see letter.

In closing, I feel your way off base here in your letter and I view this as a form of harassment. I would just like you to leave me alone. I don't want to get tangled up in any legal battle. If you continue to push the issue, I'll have no choice but to find some high powered city official to support my position -- Exercising my first amendment right. The right to freedom of speech -- the right you told me you believe in.

=============

3) Email to City Attorney's Office (City Attorney to remain anonymous for now):

2/20/09

Dear L.A. City Attorney:

I just received this disturbing letter from Paul E. Fisher, who is the attorney representing World Wide Rush, LLC. (see attached pdf file). He is accusing me of false statements on my blog that will adversely affect his client's reputation with the building owner at 10801 and with other advertising accounts.

He wants me to retract statements that he believes to be false and told me that if I don't retract these statements he will pursue all appropriate legal steps to protect his client's legal interests (please see letter). Isn't it ironic that the very attorney that has represented freedom of speech and the first amendment for the last 20 years, is trying to suppress an American citizen from having that same freedom. I'm asking for help from the city attorney's office, because almost all the information I've been posting in my blog has come from information disseminated from government employees. I view his letter as harassment and I want Paul E. Fisher to leave me alone. FYI: Since I've shared everything to this point with my blog readers and followers, I have also posted this email.

I placed his letter on my blog and responded to his concerns as best I could, but most of his comments contradict statements I've heard from city and fire department personnel (please review that information at www.10801takesigndown.blogspot.com). He wanted an apology and I did apologise. I apologised for any statements I made that personally attacked any person's character. I don't think that is fair and if I said anything in that way, it was in a moment of upset and I apologise. And for the record from this point on, I will be extremely careful not to focus on any one person's character, but focus on the issues at hand -- Don't risk lives with advertising campaigns. Urban blight is another issue I've become passionate about since this ordeal started. I realized if the owners could get away with the sign at 10801, what message would that relay to all office buildings in L.A. Our city would look awful, tacky and inhospitable.

Many statements I made were tongue and cheek comments that would offer the readers a little fun. I also included some posts just for fun to add a little entertainment value to a very serious message.

Mr. Fisher insinuated that my blog had violent overtones and I was promoting violence. That's the farthest from the truth. The violence he referred to were other comments from readers and not my own thoughts or recommendations. He neglected to include this statement dated February 17, 2009 7:16 PM: And I want to state publicly that I always seek lawful, non-violent ways to handle disputes. I intend to continue to stand up for what is right with this blog and will intensify actions legally and non-violently until justice is served.

I did purposely list names of folks that are involved with this issue, because I felt that some public shame would stop them from their negligent deeds and unfortunately that proved not to be the case. Those involved may not have liked their names put on the public airwaves, but that did not stop them from continuing to endanger the public. I believe all those public statements are within my first amendment rights.

According to my video files from the Jack Weiss press conference, documentation from the LAFD and numerous conversations I've had with Capt. McCarthy, Capt. Fasmer and Chief Fry of the LAFD all point to the information I put out on the public airwaves.

These are quotes verbatim from Council member Jack Weiss's press conference:

Council member Jack Weiss: "Not only is this sign illegal because it was put up after the city banned new signs, but it is clearly a danger to the lives of the people working inside this building. LAFD came out to inspect this building and issued a notice to comply. This notice to comply is based on the fact that the fire department thinks this is dangerous and a hazard to public health. The fire department has asked that this sign be taken down, and was it taken down?"

Jack Weiss demanded that the owner of this building should "HAVE THE BOOK THROWN AT THEM"!

Los Angeles Fire Chief Fry: "Supergraphic signs (referring to the sign that was put up by World Wide Rush) trap people inside the buildings preventing firefighters from getting in and getting people out. LAFD has no idea how this product will react if exposed to any fire. This could become almost like a gasoline type of material to where a small fire can become a tremendous catastrophe for the people inside. So we have a huge concern. Because WORLD WIDE RUSH IS NOT COMPLYING WITH THE LAFD, THEY ARE MORE INTERESTED IN PROFITS RATHER THAN SAFETY."

Barbara Brodie (from the Coalition to Ban Blight): "This sign is a fire hazard for the tenants in the building and the firefighters. Also, these signs are designed to distract so this endangers drivers and pedestrians across the city."

So this is where I've received my information from and I'm informing the public and expressing my first amendment rights. It appears that Mr. Fisher has much different views than our city leaders. I see Paul Fisher has a role -- and that is to protect World Wide Rush's interests. I see our city leaders have a role to protect the City of Los Angeles Citizens and to stand up against companies that break the law. That's why I choose to believe in our city leaders and if Paul Fisher wants to take legal action at what I've said, then he must also take legal action against all of our city leaders that have spoken on this issue.

I'm asking for your help. Please have the city shield me from Paul E. Fisher and World Wide Rush and help protect my first amendment rights.


Sincerely,

Dr. David Allan


--
Dr. David Allan, D.C., C.C.F.C.
spokesperson for
The Coalition for 10801 Tenant Safety & Justice
10801 National Blvd Suite 580
Los Angeles, CA 90064
www.10801takesigndown.blogspot.com

cc: "Rocky Delgadillo LA City Attorney" <Rocky.Delgadillo@lacity.org>, "Jack Weiss LA City Council" <Councilmember.Weiss@lacity.org>, "Mayor Antonio R Villaraigosa" <mayor@lacity.org>