. >> we will now hear from ms. lopez, attorneys for the respondent, department of public health. >> before i leave, i would like to have the documents submitted into the administrative record. >> thank you. >> counselor, before you start, is there a reason why there was no brief submited? >> i do intend to address that. . do you want to hear from me? >> just an error. i requested a late filing brief and a denial of the request. i asked the opposing counsel and informed them that i would be submitting the same documents that i submitted at the director's hearing. these are the same documents. i have nothing more to tell you except for what we have presented in this administrative record on the projector. >> thank you, counselor. >> thank you. >> good evening, president swig, commissioners. i am valerie lopez, deputy city attorney with the office of the city attorney appearing on behalf of the department of public health. appellant's appeal lacks merit. first, before i get into the substantive grounds, i want to address th