HomeMy WebLinkAbout Submittal-Alfredo Gonzalez-Memo regarding file 8049Submitted into the public
record for item(s) SR.6,
on 11-19-2020, City Clerk
MEMORANDUM
TO: City of Miami ("City")
FROM: Genovese Joblove & Battista, P.A.
BY: Alfredo L. Gonzalez, Esq.
SR•
RE: File ID 8049 in City of Miami Agenda for November 19, 2020
(Noise Ordinance Amendment)
I. INTRODUCTION
A. My name is Alfredo L. Gonzalez, I am an attorney with Genovese Joblove & Battista
with offices located at 100 SE 2nd Street, Suite 4400, Miami, FL 33131.
B. It is my pleasure to be here representing Ball and Chain a Restaurant and Lounge
located at 1513 SW 8 h Street, Miami, FL 33135.
C. My client is specifically affected by the Noise Ordinance under consideration as agenda
Item 8049.
D. We would like to request additional time to address the Commission on these issues
either now or at the discussion of the Ordinance when it comes up for public hearing.
11. DISCUSSION
A. We object to the passage of this Ordinance for the following reasons:
1. Due Process/Legal Protection. The Ordinance under consideration is an arbitrary
and capricious use of the police power and violative of my clients' equal protection
rights under the United States and Florida Constitution. The City is passing an
Ordinance that after taking into account exceptions and vesting will apply only to
my clients existing use of the property. Further the Ordinance is unconstitutionally,
vague and overly broad.
2. Equitable Estoppel. City is equitably estopped to apply this Ordinance to our
property since City has in bad faith and in violation of clear obligations under the
Miami 21 City Code Section 7.1.2.4 failed to award our clients a Warrant applied
for in October, 2019. The issuance of such Warrant would have grandfathered and
vested our client with the right to play music at the restaurant on their property now
not allowed under this Ordinance. See, Coral Springs Street Systems, Inc. v. City of
Sunrise, 371 F. 3d 1320 (2004).
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In essence the City delayed the process of issuing the Warrant long enough to pass
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the Noise Ordinance that prohibited such use. This action was taken
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notwithstanding the obligation of the City under the Miami 21 City Code Section
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7.1.2.4 to issue a Warrant decision letter within 21 calendar days of receiving a
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completed application. We never received such letter or were advised that the
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application was incomplete.
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We filed in October 2019 and over one year later we cannot get the City to do
something that the City's Code provides 21 days to achieve. This is simply bad
faith.
I want to introduce into the record a letter sent by our zoning counsel to the City
attorney dated November 15, 2020 outlining the history of the Warrant application
and attached hereto as Exhibit "A."
3. Master Plan and Zoning. The area were the property is located is a tourist and
entertainment center which will be negatively impacted by this Ordinance. The area
will be in a complete disadvantage as to other entertainment centers in the City.
The property is master planned under the City Comprehensive Master Plan (Master
Plan) as restricted commercial which promotes intensive commercial use, including
entertainment facilities. Restricting outdoor music in this area is in conflict with the
land use category and thus inconsistent with the City Master Plan. Further the
property is zoned T6-8-0 under Miami 21 zoning code. This Urban Core zoning
allows intensive commercial and residential uses. The properties directly impacted
by our use are zoned as T5-0, Urban Core where entertainment establishments are
allowed as of right. The Noise Ordinance is inconsistent with the zoning applicable
to the property.
4. Taking. The Ordinance inordinately burdens our clients' property and will expose
the City to a claim under Florida's Bert J. Harris Act (Florida Statute 70.001).
We hereby request that the Ordinance not be passed or alternatively that our property be
vested under the filed Warrant with the City. _
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305-913-0356
V ALERIE.HABER(i_�GRAY-ROBINSON.COM
November 15, 2020
VIA E-MAIL
Victoria Mendez
City Attorney, City of Miami
Office of the City Attorney
444 SW 2nd Avenue, Suite 952
Miami, Florida 33130
Dear Ms. Mendez:
333 S.E. 2ND AVENUE
SUITE 3200
MIAMI, FLORIDA 33131
TEL 305-416-6880
FAx 305-416-6887
gray-robinson.com
BOLA RATON
FORT LAUDERDALE
FORT MYERS
GAINF.'SVILLE
JACKSONVILLL•
KFY WEST
LAKF.LAND
MELBoURNE
MIAMI
NAPLES
OBLANDO
IALLAHASSFE
TAMPA
WASHINGTON, DC
WEST FAIM BEACH
Due to the lack of a response from the City regarding the warrant application for The Mad
Room LLC d/b/a Ball and Chain ("Applicant'), located at 1513 SW 8U' Street, Miami, FL (the
"Property"), I am writing the instant correspondence to address the efforts Applicant has made
with respect to its outdoor dining warrant (the "Dining Warrant'), with the hopes that this detailed
timeline will stress the urgent nature of my repeated requests that the Dining Warrant Decision
Letter be issued As I mentioned in prior correspondence to the City, the letter of intent, warrant
notification letter, and draft warrant decision letter in connection with the Dining Warrant are rife
with mention of the alcohol service establishment expansion to cover the outdoor (see highlighted
provisions below), so the use of the outdoor areas for alcohol service was understood by the parties
all along, yet was only raised by the City more than one year after the Dining Warrant Application
was submitted.
A history of the Dining Warrant application is as follows:
October 15, Applicant filed a warrant application (PZ-19-4801) for outdoor dining,
2019 specifically referencing the alcohol use in its letter of intent as follows:
"Applicant will operate a tavern/bar and food service establishment with outdoor
dining, with alcohol beverage sales through FL Division of Alcohol Beverages
and Tobacco license #BEV2307635." A noise attenuation plan is also included
in the letter of intent.
As of October 15, 2019, the City was on notice that the outdoor dining warrant
contemplated alcohol sales and consumption in the area covered by the outdoor
dining warrant, yet the City did not raise the need to a separate alcohol warrant
application until one year later.
GRAYROBINSON
PROFESSIONAL ASSOc1AnON
VIA E-MAIL
Victoria Mendez
November 15, 2020
Page 2
Submitted into the public
record for item(s) SR.6,
on 11-19-2020, City Clerk
Moreover, the plans submitted with the outdoor dining warrant clearly indicate an
"outdoor bar" with a c-shaped bar rea. These plans were reviewed by all necessary
departments, and Applicant never received any comments regarding outdoor
alcohol sales, service or consumption. Specifically, the plans were reviewed by
various City disciplines, notably:
• Jacqueline Ellis on 10/17/20, 10/15/20, 10/7/20, 9/3/20, 9/2/2020, 1/8/20
• Joseph Ruiz on 6/4/20, 10/5/20, 10/9/20, 10/14/20
• Julia Cerrato on 6/29/20
In total, plans and documents relating to this application were viewed 545 times
by City representatives from the time of application to the date of this
correspondence, yet the first mention of the necessity of a separate warrant for
alcohol was not identified until 1 year after application.
On this day, invitations to view the application were sent out by E-Plan to relevant
reviewers, including, Jacqueline Ellis, Francisco Garcia, Tamara Frost, Rafael
Rodriguez, Joseph Ruiz, Kemar Brown,
Nov. 1,
Applicant uploaded the required plans to E-Plan in connection with the outdoor
2019
dining warrant.
January 6,
Applicant uploaded revised plans to E-Plan.
2020
January 7,
Applicant was notified via Eplan that the Application bad successfully passed
2020
prescreen. This notification informed Applicant that "Based on the nature of your
application (scope of work) required disciplines have been identified and will
review concurrently." Indeed, no such disciplines identified any issues relating to
the alcohol use.
March 22,
Applicant uploaded revised plans to Eplan in response to City comments
2020 &
regarding same.
April 2,
2020
May 23,
City reviewer Maria Adeyafa added a comment to Applicant through EPlan
2020
requesting that Applicant "Provide current operating 4COP alcohol license which
GRAYRoBiNSON
NROFESSIONAL ASSOCIATION
VIA E-MAIL
Victoria Mendez
November 15, 2020
Page 3
Submitted into the public
record for item(s) SR.6,
on 11-19-2020, City Clerk
would be used for the establishment," and Applicant promptly provided a copy of
same.
This would have been an opportunity for the City to raise the alcohol warrant
issue, but it was not raised until nearly 6 months later.
July 23,
Applicant paid a Planning Fee in the amount of 4,843.00 in connection with the
2020
Wan -ant application (transaction ID 2020205001-170-1), and uploaded revised
plans in response to City comments re: same.
August 17,
Applicant uploaded a revised Ietter of intent, in response to City comments re:
2020
same. Again, this letter of intent clearly indicates the alcohol use_
August 20,
The City provided Applicant with the Warrant Notification Letters, which
2020
included reference in the "Detailed description of proposal" section drafted by
City staff that "The Applicant's proposed use will be an Alcohol Service
Establishment (bar) with an Outdoor Dining Area, located with a total square
footage is 4,843."
August 26,
Applicant provided proof of certified mailing of the Warrant Notification Letters.
2020
October 1,
City reviewer Maria Adeyefa indicated by email to me that she would send the
2020
draft Warrant Decision Letter to me by Monday (10/4/20). I also spoke with Ms.
Adeyefa by telephone, wherein she indicated that the letter was ready to go, and
that it was only awaiting signature by Jacqueline Ellis, who had been on vacation.
Having received no letter, I followed up with Maria on 10/7/20, and again on
10/8/20.
October 9,
City issued Draft Warrant Decision Letter to Applicant, which included the
2020
following references recognizing the use of the space for sales and consumption
of alcohol beverages:
• P 1: "Request ... Warrant pursuant to ART 6 Sec 6.3.2.1 ... to allow
outdoor dining for a tavern bar and food service establishment with
a 4COP quota license.
• P2: #5: "The proposed outdoor dining will be incidental to the
existing tavern/bar and food service establishment, in which the
applicant will amend the CU to reflect the added uses."
#7" Applicant has submitted the necessary information, which is
attached to this file, and is considered an official record on file with the
Planning De artment. This information attached demonstrates
CRAYRosuvsoN
PROFESSIONAL ASSOCIATION
VIA E-MAIL
Victoria Mendez
November 15, 2020
Page 4
Submitted into the public
record for item(s) SR.6,
on 1119-2020. City Clerk
compliance with the guidelines and criteria required for this type of
permit, as specified in Miami 21 Code.
0 "#12: Pursuant to Art 7, sec. 7.1.2.4 of Miami 21 the application has
been reviewed and found sufficient.
• Conditions:
• #2: warrant for outdoor dining has been approved to operate in assn
with tavern/bar and FSE with 4COP quota..."
• #5: 4COP alc license should apply to the tavern/bar, FSE & outdoor
dining use within the tenant space. Additional expansion or
modification to be approved layout by current or future tenants requires
new warrant." (emphasis added).
October 12,
1 provided minor feedback on the Warrant Decision Letter to the City via e-mail,
2020
asking for the removal of condition #4 which improperly referenced the
establishments as a "restaurant' under 4-1 of the City Code.
October 15,
Applicant opened its establishment to the public, and was visited by City Code
2020
Enforcement and cited for excessive noise, which applicant had performed a
decibel reading of and found to be at ambient, conversational levels.
The City of Miami, through Zoning Director Joseph Ruiz, provided Applicant
with a copy of a Complaint for Injunctive relief alleging that Applicant does not
have the authority to use the outdoor seating area and "pineapple" bandshell in the
back patio of the Property, and demanding that Applicant cease use of such area,
which Applicant promptly complied with.'
October 19,
This was the date whereon the City of Miami Planning Director was required to
2020
issue a Warrant Decision Letter, per Section 7.1.2.4 of Miami 21:
"Where there is no referral to the Coordinated Review Committee, the Planning
Director shall issue an intended decision within twenty-one (21) calendar days of
a determination that the application is complete. The applicant shall have seven
(7) calendar days from receipt of the notice of the intended decision to request a
conference with the Planning Director to discuss revisions or additional
information regarding the application. Within ten (10) calendar days of the
conference, or if no conference is requested, the Planning Director shall issue
'As you know, I am not involved in any current or proposed litigation (if any) against the City of Miami, and have
indicated to my client that I can only act in an administrative capacity in assisting with the warrant application(s). I
received a copy of this Complaint from my client, but have not been involved in any pre -litigation efforts or
involved in any ongoing litigation. 1 have been forthright about my limited scope with the you as well, so I hope
you understand that this correspondence is merely a cordial attempt to spell out my efforts so you can hopefully
understand the urgency and timeliness of the warrant issue.
GRAYROBINSON
PROFESSIONAL ASSOCIATION
VIA E-MAIL
Victoria Mendez
November 15, 2020
Page 5
Submitted into the public
record for item(s) SR.6,
on 11-19-2020. City Clerk
written findings and determinations regarding the applicable criteria set
forth in this section and any other applicable regulations." (emphasis added).
To date, I have not receive_ d such Final Warrant Decision Letter, despite repeated
requests for same.
October 19,
The undersigned participated in a video conference with the City Attorney,
2020
Zoning, Planning, Fire, and Building Departments, where it was raised for the first
time that a separate alcohol warrant was required based on the City's review of
the previously -approved Class II permit covering the Property. This was raised
more than one year after the Dining Warrant application was submitted.
At this meeting, I again requested that the Final Warrant Decision Letter be issued
in compliance with the timing requirements set forth in Section 7.1.2.4 of Miami
21.
October 27,
I participated in a follow-up video conference with the City departments listed
2020
above, and, despite promises that a determination on the Outdoor Dining Warrant
and process forward for the alcohol warrant would be made, no such clarification
was offered to Applicant.
I followed that meeting up with a detailed a -mail to Mr. Garcia, with you and Ms.
Dooley in carbon copy, outlining all instances where the Dining Warrant
referenced alcohol sales and consumption, submitting that no further submission
should be required for an alcohol warrant. At the end of that email, I reiterated
that "We want to ensure that the dining warrant is approved before 2nd reading of
the outdoor music ordinance, given we submitted this application over a year ago
and just within the past few weeks are being alerted that separate action is needed
on the alcohol warrant."
October 29,
I participated in a video call with Assistant City Attorney Rachel Dooley, and
2020
Jordan Shaw, litigation counsel to Applicant. I again did not receive clarification
on when a determination would be made on the Dining Warrant, despite my
urgings that the time had well passed for such a determination. Ms. Dooley
promised to push Mr. Garcia for a clear path forward for Applicant.
On this same day, Ms. Dooley followed up with Mr. Garcia asking for
feedback on my October 27ffi e-mail. Mr. Garcia responded that: "I am copying
my colleagues Jeremy Calleros Gauger, Joe Ruiz, Jacqueline Ellis and Maria
Adeyefa, who are conducting the necessary research in order to chart a path
forward toward compliance for the subject establishment. We will be meeting
GRAYROWNSON
PROFESSIONAL ASSOCIATION
VIA E-MAIL
Victoria Mendez
November 15, 2020
Page 6
Submitted into the public
record for item(s) SR.6,
on 11-19-2020, City Clerk
again internally very soon to memorialize our findings and subsequently share
them with the applicants."
October 29,
I participated in another video conference with the multiple City departments, and
2020
still received no clarification as to path forward on the Dining Warrant, although
Mr. Garcia indicated that he was going to require that Applicant submit an alcohol
service establishment warrant application to modify the previously -approved
Class H permit covering the Property, but did not specify how the Outdoor Dining
warrant would be treated, and whether a Final Warrant Decision Letter was
forthcoming.
October 30,
Ms. Dooley followed up again with the Planning Department regarding my
2020
October 27t' e-mail.
November
I sent a follow-up email to the City Attorney, Planning & Zoning Departments
2, 2020
asking for confirmation that I would receive a response on the Final Warrant
Decision Letter.
You responded indicating that: "I will only comment on the discreet issue on
whether a warrant application is needed for the expansion of the alcohol service
establishment, in addition to your outdoor dining warrant application (even
though you allude to alcohol service in your outdoor dining application). My
review of the code provisions indicate that you do need two applications. Simply
alluding to a warrant for an outdoor alcohol service establishment is not enough."
This was not supported by any legal citation, and no clarification was provided
regarding the Dining Warrant.
November
I responded to your email as follows:
3, 2020
"By that logic, the outdoor dining warrant need not reference outdoor alcohol
entitlements since those are covered in the alcohol service establishment warrant.
Can you please indicate when the outdoor dining warrant will be issued? As
we discussed, a condition can be included in the outdoor dining warrant indicating
that outdoor alcohol consumption will be as approved by separate warrant. This
is done frequently with respect to other contingent approvals on warrants like
obtaining a CU. It is imperative that we receive a decision on the outdoor
dining warrant today. The draft letter has already been prepared and with the
addition of one condition that "alcohol consumption in the exterior ofthe premises
shall be subject to approval of an extension of the previously -approved Class II
ermit for an alcohol service establishment" this is ready to issue. The re uired
GRAYRoniNsoN
PROFESSIONAL ASSOCIATION
VIA E-MAIL
Victoria Mendez
November 15, 2020
Page 7
Submitted into the public
record for item(s) SR.6,
on 11-19-2020. City Clerk
timing set forth Miami 21 for issuance of a decision letter on the outdoor
dining warrant has long passed." (emphasis added).
November Another video conference between Applicant's representatives and various City
4, 2020 departments was held, wherein I again repeatedly pleaded for an answer from the
City on the Outdoor Dining issue, stressing the time sensitive nature of the request.
Mr. Garcia indicated that due to his departure from the City, Mr. Jeremy Gauger
would be reviewing the associated issues.
November Per the City's request and recommendation, and due to the City's delay in making
13, 2020 a formal determination on the outdoor dining warrant, Applicant submitted an
alcohol service establishment warrant application ((PZ-20-9331) to modify the
existing Class II permit issued for the Property to reflect alcohol sales and
consumption in the exterior of the premises.
The undersigned followed the application up with an e-mail to you indicating that
the application had been filed, and asking for confirmation that "the outdoor
dining warrant letter will be issued immediately to allow for the sale of food and
non-alcoholic beverages in the outdoor dining area as set forth in PZ19-4801, and
to allow for the sale, service and consumption of alcohol beverages once the
instant modification to the Class II permit is approved by the City."
That evening, I received a telephone call from Interim Planning Director Jeremy
Gauger indicating that he had provided feedback to you on the warrants on
November 9°i, and understood that you would be communicating those findings
to me, but learned on Nov. 13 that he was to provide the updates to me. He
apologized for the delay, and e-mailed me his reports analyzing the warrant issues.
In those reports, there is again no mention of when we can expect to receive the
Outdoor Dining Warrant Final Decision Letter.
As of the date of this correspondence, I have not received clear guidance on when the Dining
Warrant Final Decision Letter will be issued, and as is evidenced by the above timeline, the City
has not complied with the timelines required by Miami 21 for issuance of same. Thus, by way of
this correspondence, I respectfully request that such letter be issued on or before close of
business on Monday, November 16, 2020. My client's rights to utilize the Property are beine
severely compromised by the City's delay.
Thanks again for your time on this matter, and please do not hesitate to call me any time to discuss.
I can be reached at 305-298-8734 (cell) or 305-913-0356 (office) whenever if convenient for you.
GRAYROBINSON
PROFESSIONAL ASSOCIATION
VIA E-MAIL
Victoria Mendez
November 15, 2020
Page 8
Sincerely,
Valerie Haber
CC: Jeremy Gauger; Bill Fuller; Ben Bush; Zack Bush (via e-mail).
Submitted into the public
record for item(s) SR.6,
on 11-19-2020. City Clerk
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November 19, 2020
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VIA EMAIL
Mayor Francis Suarez
Commissioner Alex Diaz
de la Portilla
City of Miami
City of Miami
3500 Pan American Dr.
3500 Pan American Dr.
Miami, Florida 33133
Miami, Florida 33133
fsuarezna miami ov.com
adiazdelaportillaAmiamiaov.com
Commissioner Ken Russell Commissioner Joe Carollo
City of Miami City of Miami
3500 Pan American Dr. 3500 Pan American Dr.
Miami, Florida 33133 Miami, Florida 33133
krussellAmiamigov.com jcarolloAmiami ov.com
Commissioner Manolo Reyes Commissioner Jeffrey Watson
City of Miami City of Miami
3500 Pan American Dr. 3500 Pan American Dr.
Miami, Florida 33133 Miami, Florida 33133
mreyesna,miami.gov.com khardemon(&miamijzov.com
City Manager Arthur Noriega City Attorney Victoria Mendez
City of Miami Assistant City Attorney Barnaby Min
3500 Pan American Dr. City of Miami
Miami, Florida 33133 3500 Pan American Dr.
anoriema@miamijzov.com Miami, Florida 33133
vmendez(a, amigov.com
Re: Public Comment on S.R. 6, Proposed Ordinance 8049
Dear Ms. Mendez, Mr. Min, the City Commissioners, and Mr. Mayor:
I am writing on behalf of Mad Room, LLC, d/b/a Ball & Chain. It is my understanding
that the City received 8 hours and 52 minutes of public comment on S.R. 6, which you assert
represents over 300 public comments. I have reviewed the video of the City Commission
meeting, as well as Ms. Mendez's on -the -record position that she has consulted with the State
Attorney General, whom Ms. Mendez claims, without evidence, has taken the position that
public comment can simply be read into the record once, since it is a similar script.
ZF11www.zpllp.com
Submitted into the public
record for item(s) SR.6,
on 11-19-2020. City Clerk
First of all, there is zero doubt that the City could not stop all 300+ individuals from
speaking if these individuals had risked their health to publicly appear at the City Commission
meeting. Nor is there any evidence that City officials actually listened to the nearly 9 hours of
public comment, particularly given the extremely limited timeframe city officials had in which to
do so. While some comments may have been similar, a substantial number contained
particularized grievances, not capable of being quickly summarized as Ms. Mendez
disingenuously asserts. Further, the City is requiring each individual to state their name and their
address, yet the City Commission will not hear the sheer magnitude of the public comments or
feel the full weight of all of the public comments if it simply refused to play all 8 hours and 52
minutes of public comment for the public.
Further, while you may be confident that your actions satisfy your requirement to have
open meetings and take public comment under Florida law, there can be zero doubt that refusing
to accept public comment in the manner violates the First Amendment protections incorporated
to States and municipalities by the Fourteenth Amendment as recognized in Gitlow v. People of
the State of New York, 268 U.S. 652 (1925).
This action also violates the City's own Citizens' Bill of Rights as enumerated in the City
Charter. More specifically, it violates Section (A)(3) by interfering with the rights of freedom of
speech. As you undoubtedly know, pursuant to Section (C) of the Citizens' Bill of Rights,
"[a]ny public official, or employee who is found by the court to have willfully violated this
section shall forthwith forfeit his or her office or employment." This would not only include Ms.
Mendez and Mr. Min but also your clients that sit on the City Commission and choose to allow
this action to move forward without objection. Although the Mayor is a non -voting member of
the City Commission, he is by City Charter the presiding member of the City Commission. His
failure to address this matter would also implicate him in a violation of the City's Charter, and
specifically a willful violation of the Citizens' Bill of Rights.
Many of you are members of the Florida Bar. You know full well that precluding public
comment in this manner violates the First Amendment. Your decision to read a purported
"summary" of nearly 9 hours of public comment made by hundreds of impacted City residents,
many with specific and particularized grievances that cannot simply be a captured in a
"summary," does not constitute a reasonable time, place and manner restriction.
Additionally, if S.R. 6 is enacted and Ball & Chain is not grandfathered in, my client
reserves the right to challenge the enactment as violative of the First Amendment, the Fifth
Amendment, the Fourteenth Amendment, the Citizens' Bill of Rights incorporated in the City
Charter, as well as the letter and spirit of Florida law requiring open meetings and public
comment.
To the members of the Bar: We are putting you on notice as members of the Florida Bar
that you are legally and ethically bound to ensure that the rights of Miami residents are not
blatantly violated. To all of you: We are putting you on notice that your failure to evaluate the
legal legitimacy of Ms. Mendez's and Mr. Min's position (which clearly violates Federal, State
and local law) also runs afoul of established law. If you continue to push this issue without
observing the lawful requirements, it will only reinforce my client's position that they were
Submitted into the public
record for item(s) SR.6,
ZFIIwww.xpllp.com on 11-19-2020, City Clerk
being targeted and that this legislation was pushed through without sunshine and public input,
and for sole purposes of political retaliation.
Govern yourself accordingly.
Thank you.
Respectfully,
jordanA. Shaw
Jordan A. Shaw, Esq.
Cc: Ashley Moody (via email)