name what's his or her name her name is uh miss reinhardt okay and who else
oh she was the only one i talked to because okay i got you understood
good sorry so um so you enter you entered from did what i believe mr reuter asked you the question
when you first came to the building you you came to the door on written house square correct yes
that's correct all right and did you try to enter from written house square when it and just to be
clear when we say written house square it's not the actual square it's what the street is called
so um and that's the front of the building correct yes that is correct yeah and did you try to get
into the building through that front door or did you just didn't decide to walk around the back
no i didn't try to get into because i had been there before and i knew that the entrance to
where we needed to go was in the rear so we just took a picture of the front and walked around to
So we just took a picture of the front and walked around to the rear.
of the reader.
And to be clear, it's not the only entrance.
It's maybe the entrance that's closest to where it is, correct?
Would that be fair to say?
Because as you stated, you can cut into and out of that bar restaurant through the hotel lobby, correct?
Yes, that is correct.
All right.
and then you said at the back door when you you came up with miss inspector tolbert
that there were three people at the door correct at the back door yes that is correct and were those
and and at least one of them was worked there at the hotel or did more than no there were three
people standing outside and one of one person who was going from inside to outside checking with the
people at the back okay and did you know whether those people that were waiting there whether they
had a reservation whether it just walked up did you know did you you didn't talk to them at all
correct no we didn't okay so you didn't know if they were meeting guests of the hotel there
no yeah okay and were they um were they were they smoking while they were there while they
were waiting uh one of them was um for the we were we were standing outside for about 10 minutes
one of them was but uh then he you know finished the cigarette and they were still standing out
there were they being it's 10 o'clock at night were they being loud not at that time okay were
they being loud at another time no okay just wanted to make sure just want to make sure all
All right. So then you enter and and then you you see about 20, 30 people, correct?
Yes, that is correct. And are they standing, seating, sitting, sitting, sitting, sitting, sitting.
OK. And did you just were you just in the room where the where the bar is located or did you go into any other portions, areas of the bar restaurant?
We checked the bar area, and then we walked to the back near the exit door just to make sure, you know, that we walked to the back.
There's a little room back there.
And then just looked at the bathroom, and then we went up the steps.
We weren't there very long.
So that room is a little room between the bar restaurant and the lobby, correct?
It's kind of like off the side there.
And was it loud inside when you were there?
no okay and then you passed and you passed through a doorway from the from the bar restaurant into
the lobby correct that is correct and someone was at the front desk correct yes okay and
mr reuter asked you you saw neither at the front of the bar uh well at the front of the hotel
or at the back of the hotel or you know the bar restaurant you didn't see any signage
indicating the name of the bar restaurant you know this is where you get in anything along
those lines correct no okay that is i'm sorry that is correct okay right and let me ask you
a question when you were coming around from the front uh to the back could you hear anybody at
the back entrance waiting to get in no okay quiet and when you walk through the and when you walk
through the the bar restaurant and you saw 20 to 30 people did you um did you speak with any of
them no okay so you don't have any way to know whether the 20 to 30 people that are were in there
were guests of the hotel or not correct no that is i'm sorry that is correct that's correct thank
you thank you very good you thank you for being clear you're helping the reporter um you've done
this before i think so um um and did you did any of them come up to you and talk to you and give
you any indication of whether they were guests of the hotel or whether they were visitors a
guests of the hotel or unrelated to the hotel at all no okay and did you speak to any of the
other staff members other than uh mr jason elliott and um i guess the person who was at the door at
the back door um with the other people that were waiting apparently to get in did you have any other
conversations with any other employees no just give me one minute
um prior prior to your either of your inspections did you review the zoning code
prior to your
well let me back up a second do you know how a how a hotel is presently defined in the zoning code
like what's it called we what do you mean by occupancy or do you mean by
no in the zoning code like what the use category is what we call use category do you know
So let me put it this way. Is there a zoning code? Is there a use called hotel?
No, I'm not quite sure how it's dictated.
You know, how we how we do it is we go to, you know, our our our computer records and we check what that zoning is for and what their last approved zoning was for.
And that's what we use to, you know, kind of verify what we see when we're out there doing our inspection.
Right. And that's in terms of permitting.
But and I and that sounds like a great plan.
Makes sense.
But in terms of what in the zoning code, in order to have a permit, right, you need a permit for a hotel, correct?
But in 2012, the zoning code changed.
and do you know under the current zoning code what hotels are now called what category use
category they fall under in the zoning code no i'm not 100 sure okay does um if i told you
visitor visitor accommodations would that ring a bell have you heard of that yes i have heard of
Okay. And in terms of visitor accommodations, would it, I mean, do you know, do you, would you agree or disagree that a hotel under the current zoning code is what's called a visitor accommodations?
Well, I would agree.
Okay. And do you know what the definition of visitor accommodations is?
Not so.
I would have, you know, I would be assuming if I said yes. So no, I would say no.
So if I read you the definition, it says visitor accommodations, uses that provide temporary lodging for fewer than 30 days where rents are charged by the day or by the week or a portion thereof, and may also provide food and entertainment primarily to visitors and tourists.
Do you have any reason to believe that that's not the definition of visitor accommodations in the zoning code?
Okay. And by that definition, it says that a hotel can provide food and entertainment, but it doesn't need to be provided exclusively to visitors.
I'm going to object. Again, we're getting into the legal argument here. He's described what he saw.
i'll stop i'll stop on that question let me just ask him that one more question
would you do you have anything in your inspection when you were out saturday night
that would lead you to believe that the bar restaurant was not providing food or entertainment
primarily to visitors or tourists um as of saturday no okay all right i have no further
the questions of this witness uh just a very brief uh redirect inspector williams um you said
that when you talked when you were out in the alleyway there were two or three other persons
one of whom uh apparently worked there uh and i again forgive me if you already answered this but
were they out there smoking a cigarette or they were out there talking or do you do you recall
originally they were they were smoking but we were out there for 10 minutes so then they
they had stopped and he he was checking with them you know you know i guess waiting to see
whether they want to come in but he kept checking with them while we were waiting for mr uh elliot
okay um what was the weather like was it raining on saturday night not at that time no it was nice
okay all right thank you just one follow-up mr williams the people that were waiting at the back
Or you, again, you don't, and I believe I asked this question, so excuse me if it's
been asked and answered already.
You don't know whether or not they had reservations that, you don't, you don't know whether they
just walked up and say, Hey, can we come in?
Or whether they walked up and they had reservations.
You don't know, correct?
That is correct.
And if they had reservations, you don't know what time their reservations, whether they
were early, late, what have you, correct?
That is correct.
And again, you don't know whether, as oddly as it may seem, they were guests of the hotel or coming to visit guests of the hotel, correct?
That is correct.
Okay. I have no further questions.
No further questions.
Thank you, Inspector. We'll answer your testimony.
Next witness, please.
Thank you. I think I may call Ms. Christina Cavalieri.
Christina Cavalieri. Okay.
Chair, we have one hand, a Leslie Gersten up.
Okay, let's see if that's our...
That's fine.
There goes Ms. Christina.
Okay, good. Thank you.
Just so it's clear for the record, and I think the board's aware of this,
but uh Ms Gerstein is counsel for uh Ms Cavalieri uh Ms Cavalieri so I think she Ms Gerstein there's
a separate matters that are going on uh and uh Ms Gerstein I think has a as her attorney has a right
to be present I don't think Mr Orphanidis has any objections no I mean she could be present
obviously she can't participate or or she can't guide her the testimony obviously
Oh, good morning. Can you hear me?
Yes, who is this?
That sounds like it doesn't.
I mean, it might be it might be Ron.
It might be Ron, because I know Leslie had another engagement at 11.
So he might be using her login.
Or not. I don't know.
I see Christine identified.
Yes, we can swear in Ms. Cavallari.
Cavallari, could you state your name, please, and spell it for the court reporter?
Christina, C-R-I-S-T-I-N-A, Cavallari, C-A-V-A-L-I-E-R-I.
Do you swear or affirm to tell the truth, the whole truth, and nothing but the truth?
Do we have a counsel for her?
uh yes miss miss cavalieri is i saw uh somebody logging in under leslie's id is now not promoted
again so if whoever's using that id hi you're here whoever you are hi good morning it's it's uh
ron patterson on behalf of miss cavalieri i'm standing in for um leslie who is at court all
Right. Ron, could you state your name, please?
Sure. Sure. Ronald Patterson.
Wait, wait, wait. I object. I object. Wait, object. What's going on?
I'm representing Ms. Cavalieri on personal behalf.
Yeah, I think he could be present, but I agree that.
No, he doesn't. He doesn't. She gets sworn in. He's not going to speak, so he doesn't get to say anything.
If you ask a question that's inappropriate or a privilege, I'm going to object. I have a right to do that.
I would say that if there's a privilege question that comes up, he might have a right to object.
But of course, so I'm so so, David, I'm going to swear him in and then we'll make sure that we buy by all rules when she's testifying.
OK, so I mean, Mr.
Reuters witness. Yes.
Again, Ronald Patterson, P-A-T-T-E-R-S-O-N, Claire Harrison Law Firm, 1835 Market Street, Philadelphia, PA.
Right. Do you swear a firm to tell the truth, told truth, nothing but the truth?
I do. Proceed, Leonard.
you speak uh okay great thank you uh so you've stated your name uh miss cavallari what is your
address at 1709 rittenhouse square okay and uh is it fair to say that you live adjacent to the
property in question today it is okay how long have you lived there uh i would say about 20 25 years
Prior to its current use as a boutique hotel, what had it been before?
It was a bed and breakfast.
So as long as you've lived there, it's either been a bed and breakfast or visitor accommodations or hotel or boutique.
It's always been a guest house.
Is that fair to say?
It has been a bed and breakfast.
I'm not going to define it in other terms.
That's what it was advertised as.
What is the zoning classification for the neighborhood, if you're aware?
What kind of zoning is it?
I believe residential.
Do you know if the hotel is also residential, if you know?
I don't know.
Do you know if the current owners submitted any plans for a bar at this location?
To my knowledge, they did not.
How would you know?
uh well if you recall my husband would have to speak better to that
given conversation he's had with mr chopra
and who is mr chopra mr chopra is one of the owners of the establishment okay and and to if
you under if you know and and if you don't know just so you don't know uh when you say the owner
the establishment are you talking about the hotel or the bar restaurant i'm talking about
I'm talking about the bar restaurant.
the bar restaurant is it your understanding based on the
Is it your understanding, based on the conversations that you've had, that the bar restaurant is under different ownership than the hotel?