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Michael Nagel 10212024 My interest in project AS23-21 at 315 Las Animas Ave, Gilroy Owner of 9250 Monterey Rd., Gilroy. 10acre parcel. APN: 835-05-009 APN 835-05-009 shares a common border with 315 Las Animas Ave property, is surrounded by other parcels, with the sole Ingress/ egress requiring passing over the Pacific RR (see attached map) APN 835-05-009 is effectively land-locked with no clear access. APN 835-05-009 was created in a faulty subdivision by the city / county some 150 years ago Frequent problems with ingress/ egress resulted in emergency calls to Pacific RR for repair/ maintenance Faulty subdivision has led to a major safety hazard for residents and potential future businesses which has not been addressed by the City of Gilroy California Supreme Court – Land-locked cases California has recognized the issues related to historical faulty subdivision. California law provides an "easement by necessity". Here are some cases: Reese v. Borghi (1963) This case helped establish the principle that an easement by necessity can be created when a property becomes landlocked due to a conveyance Murphy v. Burch (2009) This is a more recent case where the California Supreme Court addressed the issue of easements by necessity and clarified some aspects of when they can be granted Granting an "easement by necessity" is an involved, costly and long process California Supreme Court clearly recognizes the liability would be borne by the city The City of Gilroy – liabilities and options for moving forward Egress / ingress from APN 835-05-009 is a clear hazard which the City of Gilroy needs to address Lack of addressing this issue creates a safety hazard for current and future residents and businesses and exposes the City of Gilroy to major liability Incorporating an "easement by necessity" is costly Option for resolving liability: Placing a requirement on project AS23-21 to provide road access through its property for APN 835-05-009 residents This approach provides a simple, low effort, low cost for resolving a major City of Gilroy laibility /