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Mr. Galvin M. Cory Page 2 October 2, 1951 The second question is whether there are any city licenses or state lavs pertaining to hotels and motels vhioh aight differentiate between the two, the next step being to ascertain hov these motels were licensed. There are two other oases Z found not Involving the Rent Control Lav: Edvards v. City of Los Angeles. 119 Pao. 2d 570, and Jusnaal v. City of flUnflmla. 1 6 4 SW 2d 610. The Edvards case involved a license tax on persons letting rooms in hotels, rooming houses, boarding houses, apartment houses or lodging houses and the court held that structures placed side by side, or some in the rear of another, or in a circle, or semi-circle, and frequently called "Inns" or "Courts", do not lose their identity as "hotels*, "rooming houses* or "apartments* merely by bestoving upon them a different a p p e lla t io n # if in faot they are used to lodge the public. In the Juengel case, there was a city ordinance regulating "every building, group of buildings or other structure or structures, kept * * * or held out to the public to be a place vhere sleeping accommodations are furnished for pay to transients, tourists or persons traveling by automobiles in vhioh one or more rooms, cottages, cabins or buildings vere supplied for the accommodations of such guests". The court expounded at length on the definition of a hotel and held that the accommodations for rent to transients or permanent guests had the essential character!sties of a hotel, stating "a tourist camp is none the less a hotel because the business or occupation Is conducted through the use of a group of buildings rather than through the use of one". Incidentally. Z can not find that the vord "motel* is used in any of the legal dictionaries or AIR Indices. On the face of my preliminary investigation, it seems to me that the motel association might get away with this idea unless ve can build up some evidence that they vers estopped fey their registration under the Rent Control Act or by their securing of licenses or other permits covering the regulations of motels and auto "courts rather than hotels. Z vould appreciate it if you w o u ld discuss this matter with hr. Johnson and see vhat oan be worked out. EEB:AF E. £. Bennett