An action under San Francisco’s Tree Dispute Resolution Ordinance about a neighbor’s tree that has grown to obstruct the plaintiff’s view is an action in the nature of one for a continuing nuisance, even though obstruction of view by trees was not actionable at common law.  Accordingly, there is no statute of limitations on such an action since the harm (obstruction of view) continues, restarting the limitations period each day.  Also, there is no need under the ordinance for the plaintiff to present photographic evidence that the view was unobstructed before the tree grew.  Oral testimony to that effect suffices.