October 27, 2003

TO:
Dennis Lockhard, Fire Marshall AND
Jay Elbettar, Director of Building Dept.
City of Newport Beach

This letter is a formal complaint for violations of occupancy in TWO residential
property located at:

FIRST LOCATION
1811 West Balboa, Newport Beach

This residential property DOES NOT have a Calif. State license to operate as a
Residential Treatment Center nor business license.  They are, however, housing drug
and alcohol addicts and/or staff as part of the Narconon business operated across the
alley (1810 W. Oceanfront).  There is NO Certificate of Occupancy on file with the
city of Newport Beach for this property to operate in this way.

- COMPLAINT - Excessive Occupancy.  Excessive occupancy of this property is evident
by multiple bunk beds in each bedroom INCLUDING the living room.  Also, evident are a
large number residents entering/exiting the property at all hours, particularly to
cross the alley to the Narconon property (1810 W. Oceanfront) to access all services,
meals, laundry, meetings, trash, sauna, weight room, offices, etc.

. I AM REQUESTING THIS COMPLAINT BE INVESTIGATED
. I AM REQUESTING THAT 'IF' A CERTIFICATE OF OCCUPANCY AND/OR FIRE CLEARANCE IS
ISSUED FOR THIS PROPERTY, IT BE APPROPRIATE TO ZONING IN A RESIDENTIAL AREA.
. I AM REQUESTING ANY DESIGNATION OF 'OCCUPANCY' DETAIL TOTAL PERSONS (BEDS/RESIDENTS
AND STAFF) OCCUPANCY.
 [Special Note- In speaking with the Officer of the Day, today in the State Office of
Alcohol and Drugs Program, she reported their office considers a certificate of
occupancy to be a designation of 'bed use' and not a consideration of staff or those
working on the property.  Several other cities in California are very specific with
the state program on 'occupancy' to avoid the use of # of occupants in such a minimal
way.]

SECOND LOCATION
1810 West Oceanfront, Newport Beach

Currently this residential property is the 'southern California headquarters' of
Narconon. Inc. and licensed as a Residential Treatment Center by California's Drug
and Alcohol Program. The city's Certificate of Occupancy states 27 persons.  In
speaking with the Officer of the Day, today, in the State Office of Alcohol and Drugs
Program, she reported their office considers a 'certificate of occupancy' to be a
designation of 'bed use' and DOES NOT include Narconon staff & other employees
(counselors, treatment analysts, etc.) on the property.  Narconon's advertising for
this property boast 32 beds, 34 staff and one to one counseling for the residents.
This is a total of 66 persons.  Several other cities in California are very specific
with the state program on 'occupancy' to avoid the misuse of # of occupants in such a
minimal way.

. I AM REQUESTING THE CITY MAKE THE CURRENT 'CERTIFICATE OF OCCUPANY' FOR THIS
PROPERTY UNQUESTIONINGLY CLEAR TO THE STATE DRUG AND ALCOHOL PROGRAM.  POSSIBLY ADD
WORDING, SIMILAR TO OTHER CITYS', ON THE CERTIFICATE ITSELF:
27 TOTAL (RESIDENTS, STAFF AND EMPLOYEES)

Please contact me with any questions.  I would like to be kept informed regarding
actions initiated and pertinent developments.

Sincerely,



______________________________
Dr. Linda Orozco
1805 W. Balboa Blvd.
949-673-5416



cc.
Sharon Wood, City Asst. Manager