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HomeMy WebLinkAboutThe Natural Solution Directcare (PA2005-287) 359 San Miguel DrCITY OF NEWPORT BEACH PLANNING COMMISSION STAFF REPORT Agenda Item No. 3 February 9, 2006 TO: PLANNING COMMISSION FROM: Planning Department Brandon Nichols, Assistant Planner (949) 644 -3234, bnichols @city.newport- beach.ca.us SUBJECT: Appeal of Planning Director's Use Permit No. 2005 -053 (PA2005 -287) 359 San Miguel Drive, Suite 107 APPELANT: Clinique Ergonique ISSUE Appeal of the decision on Planning Director's Use Permit No. 2005 -053 (Exhibit 1) RECOMMENDATION Staff recommends that the Planning Commission deny the appeal and uphold the Planning Director's approval of Use Permit No. 2005 -053. BACKGROUND On January 4, 2006, the Planning Director approved Use Permit No. 2005 -053 allowing the introduction of an independent massage facility in conjunction with acupressure /acupuncture and wellness center. As part of the approval, a waiver was also granted allowing the massage use to be located within 500 feet of an existing massage establishment located at 359 San Miguel Drive. On January 13, 2006, the proprietor of the existing massage facility appealed the Planning Director's decision to approve the Use Permit. Both massage facilities are located in the APF (Administrative, Professional, and Financial Commercial) Zone. DISCUSSION Appeal In the appeal, the appellant cited the following reasons for appealing the Planning Directors approval: Appeal of Planning Director's Use Permit No. 2005 -053 February 9, 2006 Page 2 The proposed business will be in direct competition with the appellant's existing business. The proposed business will offer some of the same services provided by the appellant's existing business. As a result, potential clients may confuse the identities of the competing tenants. The appellant has been in business for a number of years and has made a substantial investment to establish the business and its clientele. Analysis Massage establishments are permitted in the APF zone subject to the approval of a Use Permit pursuant to Chapter 20.87 (Massage Establishments) of the Newport Beach Municipal Code (Exhibit 2). Chapter 20.87 regulates massage uses and establishes conditions required for their approval. The stated purpose of the Chapter is to protect the health, safety and general welfare by regulating the location of massage establishments thereby preventing their concentration in certain non - commercial areas of the City. The intent of the Chapter is to "promote the operation of legitimate massage services and prevent problems of blight and deterioration that can be brought about by the concentration of large numbers of massage establishments'. The Chapter is not intended to regulate economic competition and contains no language allowing or establishing grounds for denial based on economic considerations. To regulate the location and concentration of massage uses, Chapter 20.87 establishes two location requirements: 1. Massage establishments cannot be located within 500 feet of any public or private school, park or playground, civic center, cultural site or church site; or, 2. Within 500 feet of any other massage establishment site. The Chapter also permits the Planning Director to waive these location requirements if certain findings can be made. In this case, a waiver was approved to permit the location of the proposed massage use within 500 feet of the appellant's existing massage facility. It was the Planning Director's determination that the waiver of the location requirement would not be detrimental to the community for the following reasons: The massage establishment is not located within 500 feet of a public or private school, playground, civic center, cultural site or church site. The massage use will be located in a managed commercial center. The proposed use will not create a concentration of massage establishments that would be detrimental to the neighborhood or create neighborhood blight since the proposed massage use is part of a larger facility that specializes in acupressure and acupuncture services. Appeal of Planning Director's Use Permit No. 2005 -053 February 9, 2006 Page 3 Should complaints be received about the proposed use, the Planning Director or Planning Commission may add or modify the conditions of approval or revoke the Use Permit. (Exhibit 1, Standard City Requirement #4). Similar waiver requests have become more common as beauty salons, day spas and acupuncture /acupressure facilities have sought to add massage services as an amenity for their customers. In situations where waivers have been approved, neither the Planning Department nor the Police Department have received complaints regarding the operation of the massage facilities. CONCLUSION As stated, the purpose and intent of Chapter 20.87 is to establish regulations that protect the health, safety and general welfare of the community and promote the operation of legitimate massage services. It is the opinion of staff that the Use Permit and location waiver, as conditioned, are consistent with the legislative intent of the Chapter 20.87 The appellant's grounds for appeal are based upon the potential economic competition created by the proposed business. It is staffs opinion that neither the Zoning Ordinance in general, nor Chapter 20.87 in particular, contain any language requiring or permitting the denial of a Use Permit due to economic competition. Staff is therefore recommending that the appeal be denied and the approval of the Planning Director be upheld. ENVIRONMENTAL REVIEW This project has been reviewed, and it has been determined that it is categorically exempt from the requirements of the California Environmental Quality Act under Class 1 (Existing Facilities). The proposed massage use will require only minor tenant improvements to the exisitng commercial building. PUBLIC NOTICE Notice of this hearing was published in the Daily Pilot, mailed to property owners within 300 feet of the property and posted at the site a minimum of 10 days in advance of this hearing consistent with the Municipal Code. Additionally, the item appeared on the agenda for this meeting, which was posted at City Hall and on the city website. ALTERNATIVES Uphold the appeal, and deny the Use Permit. Appeal of Planning Director's Use Permit No. 2005 -053 February 9, 2008 Page 4 Prepared by: Submitted by: Brandon Nichols, Assistant Planner Patricia L. Temple, Plar4ning Director Exhibits: 1. Planning Director's Use Permit No. 2005 -053 2. Chapter 20.87 (Massage Establishments) of the NBMC 3. Letter to Property Manager (submitted with the appeal) EXHIBIT 1 Use Permit No. 2005 -053 1 January 4, 2006 USE PERMIT NO. UP2005 -053 (PA2005 -287) PLANNING DEPARTMENT 3300 NEWPORT BOULEVARD NEWPORT BEACH, CA 92663 (949) 644 -3200 FAX (949) 644.3229 The Natural Solution Directcare Attn: Lisa Sheridan 636 Veneto Irvine, CA 92614 Staff Person: Javier S. Garcia, 644 -3206 Appeal Period: 14 days after approval date Application: Planning Director's Use Permit No. UP2005 -053 (PA2005 -287) Applicant: The Natural Solution Directcare Site Address: 359 San Miguel Drive, Suite 107 Legal Description: APN 442- 091-01 as Modified and Approved. To allow the introduction of an independent massage facility in conjunction with a accupressure /accupuncture and wellness center. The 750 square foot facility is located within an existing multi- tenant commercial building. No new construction is proposed with this application and the massage use will be provided within one of the three treatment rooms. Also included in the application is a request to waive the location requirements that limit the distance between such independent massage establishments to a minimum of 500 feet. There is an independent massage establishment located at 369 San Miguel Drive, Suite 125, which provides massage services as its primary function. The subject facility is not solely a massage establishment but provides massage services as an amenity to the primary acupressure and acupuncture facility. The property is located in the APF (Administrative, Professional, Financial Commmercial) District. Director's Action: Approved January 4, 2006 FINDINGS: The property is designated for "Administrative, Professional and Financial Commercial" use by the Land Use Element of the General Plan. The personal service facility specializing in acupressure, acupuncture and health is a permitted use within that designation. to 2. This project has been reviewed, and it has been determined that it is categorically exempt from the requirements of the California Environmental Quality Act under Class 1 (Existing Facilities). 3. The approval of Use Permit No. UP2005 -053 will not, under the circumstances of this case, be detrimental to the health, safety, peace, morals, comfort, and general welfare of the city for the following reasons: • The proposed use is located in a managed commercial building with coordinated tenant management and is not a blighted area. There are no urban renewal or neighborhood conservation programs in effect in the area. • The proposed use is located within 500 feet of an existing independent massage establishment. However, given the list of services provided by the establishment it is not anticipated to create or cause any detrimental affect on the surrounding commercial or residential uses and supports the request for the waiver of the location requirement in this particular case. The proposed use will not create a concentration of massage uses in the neighborhood that would be detrimental to the neighborhood or create neighborhood blight since the proposed facility provides services other than solely massage services which supports the request for the waiver of the location requirement in this particular case. • The proposed use is not within 500 feet of a place of religious worship, school or playground. • Compliance with all other applicable regulations of the Municipal Code will be required and enforced. • The proposed operation of the massage establishment is an ancillary service use to the commercial tenants and residents in the neighborhood and is consistent with the legislative intent of Chapter 20.87 of the Municipal Code. 4. The proposed massage establishment will not be contrary to the public interest or injurious to nearby properties. It is consistent with the legislative intent and the location requirements for massage establishments established in Chapter 20.87 of the Municipal Code for the following reasons: • The massage establishment is not within 500 feet of a public or private school, playground, civic center, cultural site or church site. • The massage establishment is part of a larger facility that specializes in acupressure and acupuncture services, which is a use found in commercial districts. CONDITIONS: 1. The development shall be in substantial conformance with the approved floor plan. January 4, 2006 1A1JSERSIPLMSharedlPA'slPAs - 20051PA2005- 2871UP2005 -053 appr.doc Page 2 2. The tenant space will primarily be used as a personal service facility specializing in acupressure and acupuncture services and limited group meditation instruction. Massage services are provided as an amenity to the primary services. 3. Only one licensed massage technician shall be permitted to operate within the facility at any one time, and the addition of any additional massage technicians to the business shall be subject to an amendment of this Use Permit. No more than one treatment room shall be permitted to provide massage services at any one time. 4. The hours of operation of the personal improvement/massage therapy facility shall be limited between the hours of 8:00 a.m. and 9:00 p.m., daily, and shall also be subject to the operational requirements provided in Chapter 5.50 and 20.87 of the Newport Beach Municipal Code. The massage use shall operate only between 8:00 a.m. and 9:00 p.m. of the regular business hours of the primary business (personal service facility) and shall not operate at any time that the primary business is closed or not in operation. That is to say that the massage use cannot operate without the primary use in operation and in accordance with the provisions of Chapter 5.50 of the Newport Beach Municipal Code cannot operate between the hours of 10:00 p.m. and 8:00 a.m. 5. All applicable requirements of Chapter 5.50 of the Municipal Code shall be fulfilled 6. No temporary "sandwich" signs, balloons or similar temporary signs shall be permitted, either on -site or off -site, to advertise the proposed use, unless specifically permitted in accordance with the" Sign Ordinance of the Municipal Code. Temporary signs shall be prohibited in the public right -of -way, unless otherwise approved by the Public Works Department in conjunction. with the issuance of an encroachment permit or encroachment agreement. Standard City Requirements: 1. All signs shall conform to the provisions of Chapter 20.67 of the Municipal Code 2. The facility shall be designed to meet exiting and fire protection requirements as specified by the Uniform Building Code and shall be subject to review and approval by the Building Department. 3. The project shall comply with State Disabled Access requirements. 4. Should complaints be received by the Planning Department, the Planning Director or the Planning Commission may add to or modify conditions of approval to this use permit (to address the complaints or rectify any problems that may arise), or revoke this permit upon a determination that the operation which is the subject of this approval causes injury, or is detrimental to the health, safety, peace, morals, comfort, or general welfare of the community. January 4, 2006 I:IUSERSIPLN\Shared\PXsIPAs - 20051PA2005- 2871UP2005 -053 appr.doc Page 3 6 5. This approval shall expire unless exercised within 24 months from the end of the appeal period, in accordance with Section 20.91.050 of the Newport Beach Municipal Code. The decision of the Planning Director may be appealed by the applicant or any interested party to the Planning Commission within 14 days of the date of the decision. Any appeal filed shall be accompanied by a filing fee of $570.00. PATRICIA L. TEMPLE, Planning Director By Javier S Garcia Zoning Administrator Attachments: Appendix property owner Vicinity Map Eastlund Properties Letter of Opposition 359 San Miguel Drive, Suite 107 Site Plan and Floor Plan Newport Beach, CA 92660 Existing Parking Plan Appeared in Opposition: None Appeared in Support: None January 4, 2006 I:WSERSIPLN1SharedTA's1PAs - 20051PA2005- 2871UP2005 -053 appr.doc Page 4 APPENDIX Discussion The proposed personal service facility provides individual massage treatment as an amenity to the primary acupressure and acupuncture service facility. In accordance with Section 20.15 of the Municipal Code, personal service establishments in the APF Districts are a permitted use within that designation. However, the addition of massage services to such a facility requires the approval of muse permit by the Planning Director in each case. The facility generally provides acupressure, acupuncture and health and meditation instruction services and will also provide accommodations for a massage technician within a portion of the facility. As shown on the floor plan, the overall square footage of the personal service facility is approximately 750 square feet, with the square footage devoted to massage activity limited to one of the existing three rooms containing approximately 180 square feet of floor area each. The applicant has proposed hours of operation of the facility with a 9:00 a.m. opening hour. The authorized hours for massage use by the Municipal Code limits the opening hour to 8:00 a.m. The Planning Director has limited the hours of operation to between 8:00 a.m. and 9:00 p.m., daily. The massage service will be available by appointment during regular business hours of the primary use only. Section 20.87 Compliance - Location Waiver Reguest Section 20.87 of the Municipal Code sets forth the provisions that govern the establishment and location of massage services within the City. It is intended to allow and promote the operation of legitimate massage service facilities and to prevent problems of blight and deterioration that might accompany or be brought about by large numbers of massage establishments. The spirit and intent of Chapter 20.87 seeks to prevent the establishment of uses that may act as fronts for illegal activity by dispersing the location of massage establishments, preventing their concentration within certain noncommercial areas of the city, and by establishing specific Zoning Districts in which the use is permitted. Monitoring of the facility by the Planning Department, Police Department and Code Enforcement Officer shall ensure compliance with the provisions of the Municipal Code requirements and the intent of this Chapter. The waiver of the location requirement will accommodate the facility that is located within 500 feet of a second facility located at 369 San Miguel Drive, Suite 125 (250 feet distant). That facility is an independent massage facility that provides only massage services. There is a second facility, Spa Gregories, located at 200 Newport Center Drive (480 feet distant) which provides massage as an amenity in conjunction with a hair, skin and beauty treatment facility. January 4, 2006 1AU3ERSIPLMShared\PXs1PAs - 20051PA2005- 2871UP2005 -053 appr.doc Page 5 II The subject facility will provide massage as an amenity to the primary personal service use (acupressure, acupuncture and mediation instruction). Staff is of the opinion that the limited hours of the facility, and provision of massage as an amenity and not a primary use, will prevent any detrimental affect on the surrounding commercial and residential uses. Letter of Opposition Attached is a copy of a letter that a neighboring tenant has sent to the landlord of the property is provided for information only. The neighbor demands protection from competition by the subject facility that they imply will compete directly with their existing wellness facility located in suite 110 of the subject building. It should be noted that the neighboring facility is a health and beauty facility (they characterize it as a spa) as well as a wellness center. The neighboring facility had previously argued that they should be classified as a medical use and not an independent massage establishment since their facility and patrons were under direct care and oversight by an on site physician. The Planning Department and the Police Department agreed and classified the facility in suite 110 as a medical office use and therefore not subject to use permit requirements of Chapter 20.87 of the Newport Beach Municipal Code related to independent massage establishments. The Zoning Code does not establish specific location requirements or intended to protect wellness centers or any other use classification from competitors locating within the same building or even next. door. The waiver of location requirement requested in this application is not related to the existence of a neighboring wellness center. Title 5 Compliance In addition to the Title 20 requirements mentioned above, Title 5 of the Municipal Code (Business Licenses and Regulations) also includes provisions for the review and approval of operator permits, massage technician permits, and requirements of operation for massage establishments. The applicable permits and necessary business license as required by the Municipal Code must be secured before the operation of the massage establishment. Parking Requirement Since the subject use is a personal service use, the parking demand for the use is no greater than for a general office or a retail use that is permitted by right without approval of a use permit. The proposed use is not an intensification of the permitted retail personal service use. January 4, 2006 1AUSERSTLN1Shared\PRs1PAs - 20051PA2005- 2871UP2005 -053 appr.doc Page 6 \1 EXHIBIT 2 Chapter 20.87 of the NBMC 1 �` Sections: 20.87.005 20.87.010 20.87.020 20.87.025 20.87.030 20.87.005 Int CHAPTER 20.87 MASSAGE ESTABLISHMENTS Intent And Purpose Definitions Massage Establishments As An Accessory Use Massage Establishments As An Independent Use Amortization ent And Purpose Page 20.87 -1 Massage Establishments It is the purpose of this chapter to establish reasonable and uniform regulations which will serve to protect the health, safety, peace, morals, comfort or general welfare of the community by dispersing the location of massage establishments, as defined herein, thereby preventing their continued concentration within certain noncommercial areas of the City of Newport Beach and by establishing specific zoning districts in which such establishments shall be permitted. It is the intent of this chapter that the regulations be utilized to promote operation of legitimate massage services, and to prevent problems of blight and deterioration which accompany and are brought about by large numbers of massage establishments that may act as fronts for prostitution and other illegal activity. 20.87.010 Definitions As used in this chapter, the following terms shall have the meanings indicated: A. Massage Establishment. "Massage Establishment" shall mean any business conducted within the City of Newport Beach where any person, for money or any other consideration, administers to another person a massage as defined in Section 5.50.010 of the Municipal Code. B. Establishment. "Establishment" shall include the opening of such a business as a new business, the relocation of such business, or the conversion of an existing business location to any massage establishment' use, the expansion of any existing business, the alteration or enlargement of any existing business, or any of the uses within such a business, or any addition to existing uses within an existing business. 1124/179 I$ Page 20.87 -2 Massage Establishments 20.87.020 Massage Establishments As An Accessory Use A massage establishment which is operated as an accessory use in conjunction with an approved health club, athletic club, gym, or hotel which is or will be operated pursuant to an approved use permit; or in conjunction with a medical office or chiropractic office which is regulated by State law, shall be permitted in any district where the primary use is permitted. For the purpose of this section, an accessory use shall mean a use which is not more than 25 percent of the floor area of the related health or athletic activities of the primary use. 20.87.025 Massage Establishments As An Independent Use A massage establishment which operates as an independent use, shall be permitted in the M- 1-A District, RMC, RSC, and APF Districts, commercial areas of PC Districts and commercial areas of the SP -4 (Newport Shores Specific Plan), SP -5 (Mariner's Mile Specific Plan), and SP -9 (Old Newport Boulevard Specific Plan) Districts, subject to the securing of a use permit approved by the Planning Director in each case, and provided further that such establishment conforms to the following: A. Location Requirements. Notwithstanding any other provision of the Municipal Code, no use permit shall be approved by the City of Newport Beach for any massage establishment if the proposed site is located: Within 500 feet of any public or private school, park or playground, civic center, cultural site or church site; or 2. Within 500 feet of any other massage establishment site. B. Waiver of Location Restrictions. Any property owner or his authorized agent may apply for a waiver of the location restrictions contained in this section. The Planning Director, after a public hearing, may waive any location restriction, if all the following findings are made: The proposed use will not be contrary to the public interest or injurious to nearby properties, and that the spirit and intent of this section will be observed; and 2. The proposed use will not enlarge or encourage the development of an urban blight area; and The establishment of an additional regulated use in the area will not be contrary to any program of neighborhood conservation nor will it interfere with any program of urban renewal; and 11/24/99 Page 20.87 -3 Massage Establishments 4. The use at the proposed location will not adversely affect the use of a place used exclusively for religious worship, school, park or playground; and 5. All applicable regulations of this Municipal Code will be observed. 20.87.030 Amortization Any massage establishment as defined in this chapter which was lawfully in existence as of the effective date of this chapter (March 25, 1992) which does not comply in whole or in part with the provisions of this chapter, shall be terminated or otherwise be brought into full compliance within 1 year of the effective date of this chapter (March 25, 1992). For those establishments which cannot be brought into compliance with these provisions because they are not in an approved district, the use may be extended for only one additional period of time, to be established by the Planning Director, upon a showing by the applicant that such extension is reasonably necessary to permit the owner of the massage establishment to amortize or otherwise recover any along term investment in the massage establishment. Any request for an extension of the 1 year amortization period must be made in writing by the owner of the massage establishment to the Planning Director not later than 60 days prior to the end of the 1 year period provided for in this section. The Planning Director may grant an extension of up to 1 additional year if the business is otherwise in compliance with all other applicable provisions of law, and upon a showing by the applicant: A. That the business involves a substantial financial investment in real property, improvements or stock in trade, or B. The business is subject to a written long term lease entered into prior to January. 14, 1991 with a termination date extending beyond 1 year from the effective date of this chapter, or C. Other factors establishing the nature of the business is such that the business cannot be easily relocated. 11/24/99 �5 EXHIBIT 3 Letter to Property Manager 1(-P rr- ALAN W. CURTIS Attorney at Law December 21, 2005 Joan Edwards Randolph Eastland Properties LLC A Delaware Limited Liability Company Corporate Offices 359 San Miguel Drive, Suite 206 Newport Beach, CA 92660 Re; Interference with quiet enjoyment Suite 110, 200, 206, 359 San Miguel Drive, Newport Beach Dear Joan Edwards Randolph, This office represents the Tenants at 110, 200 and 206, 359 San Miguel Drive, Newport Beach, CA 92660. These tenants have long term leases with you as landlord. The business conducted on the premises is that of an anti-aging medical spa that includes income from massage and other treatments commonly associated with an anti-aging medical spa. We have learned that you intend to Iease a first floor unit practically adjacent to our facility that. will be directly competing with our business. In our opinion, this constitutes an infringement of our right to quiet enjoyment, as specified by clause 32 in the master lease of July 25, 2000. This business is now in its sixth year, enjoys healthy revenues and has developed and cultivated an ever - growing customer base. In addition, it has actively advertised its business and location through print ads and the sponsorship of several public events, at considerable cost. The tenants have invested a substantial amount of their vital resources in an effort into making its location at 359 San Miguel Drive not only a success, but its headquarters and a model for its further expansion to other locations, both locally and internationally. Significant and costly improvements, special event promotion, and prominent advertisement campaigns have been made to further this location. As such, any devaluation of the worth of this business and its location would result not only in a direct loss of revenues from direct competition with another immediate provider of services, but an additional loss to its ability to project those revenues to future locations being now actively considered. Those revenue projections play a crucial role in whether a potential investor, lender, or contractor will be willing to invest or participate in helping to build the company's future. Currently, the tenants have yearly financial reports documenting their building success and increase in revenues from year to year, a trend which can be expected to increase on a percentage curve. However, faced with the impending competition from a spa rival providing services at a directly adjacent location, the uncertainty of retaining this rate of growth, and perhaps the viability of the entire business becomes in question. Another factor adding to the damage to quiet enjoyment involves the likelihood of confusion of the identities of the competing tenants. Word of mouth referral is a vital factor in Telephone: 949 - 718 -6300 ♦ Facsimile: 949 - 718 -6301 ♦ E -mail: alan@netunes.com 11 Another factor adding to the damage to quiet eroyment involves the likelihood of confusion of the identities of the competing tenants. Word of mouth referral is a vital factor in the success or failure of the very competitive spa business, and it has been demonstrated that negative word of mouth is many times more damaging than positive word of mouth can be positive. A company enduring the spreading of negative word of mouth experiences often has no choice but to counter this perception with an expensive ad or promotional campaign to boost its image. While the tenants are not aware of the character or quality of the potential rival tenants, it has no control over the quality of their services offered and may suffer if their customers confuse their services with ours. This confusion once established in the public mind is not easily dispelled or overcome, oftentimes resulting in the need to move to new locations. Yet another factor damaging to quiet enjoyment is the fact that the company employs certain professionals to provide services to their customers. A potential rival tenant not only will be competing for customers, but will also be constantly seeking new and more talented employees, and no doubt may be interested in hiring away current and potential employees of the spa. This creates tension and confusion not only for management but for the staff in dealing with these delicate employment issues. In your public Notice you state a waiver of location requirements that limits the distance between such independent massage establishments to a minimum of 500 feet My client does not agree to such a waiver and in fact demands that you do not waive the protection of the laws that would allow you to place this new facility within 15 feet of and in practically the same building facing our leasehold. Also please be advised that we are currently evaluating the renewal of the existing lease on the second floor for Suites 200 and 206, and the acquisition of the third floor directly above Suite 200 and 206 and Suite 125. A decision will be made in mid to late January 2006 concerning the additional leases. I am enclosing a brochure from our Wellness Division and two pages showing the type of testing and treatments we are currently performing and a 5 Y2 X 8 V2 brochure of the various treatments and packages we are selling. Based upon the foregoing and your notice of intend to lease Suite 125 to a massage facility in conjunction with an acupressure /acupuncture and wellness center that would be in direct competition with my client, this cannot be allowed Demand is hereby made that you cease and desist any such conduct immediately. My client intends to file a copy of this letter with the City of Newport Beach Planning Directors office and object to the issuar'ce Permit UP2005453. 7- Your immediate attention to this matter is appreciated. q n W. Curtis / Attorney for Tenants urte 110, 200,206 359 San Miguel Drive Newport Beach, CA 92660 Telephone: 949- 718 -6300 ♦ Facsimile: 949 -718 -6301 ♦ e -mail: alaz@neumes.com 2 1 1�