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HomeMy WebLinkAboutR-99-0308J-99-319 (a) ((,�� 4/23/99 RESOLUTION NO. 5 9 0 8 A RESOLUTION OF THE MIAMI CITY COMMISSION AFFIRMING THE DECISION OF THE ZONING BOARD THEREBY GRANTING A SPECIAL EXCEPTION FROM THE ZONING ORDINANCE OF THE CITY OF MIAMI, FLORIDA, ARTICLE 4, SECTION 401, SCHEDULE OF DISTRICT REGULATIONS, TO PERMIT A PARKING LOT IN THE CBD CENTRAL BUSINESS ZONING DISTRICT FOR THE PROPERTY LOCATED AT APPROXIMATELY 151 NORTHEAST FIRST STREET, MIAMI, FLORIDA, PER PLANS ON FILE, WITH A TIME LIMITATION OF 12 MONTHS TO PULL A BUILDING PERMIT AND SUBJECT TO THE FOLLOWING CONDITIONS: (1) A NEW SITE PLAN MUST BE SUBMITTED FOR REVIEW AND APPROVAL WHICH MODIFIES THE LAYOUT SO AS TO LOCATE ONE OF THE THREE HANDICAPPED SPACES ALONG THE EAST SIDE OF THE PROPERTY, AND THE OTHER TWO ALONG THE WEST SIDE; AND (2) A NEW LANDSCAPE PLAN MUST BE SUBMITTED FOR REVIEW AND APPROVAL WHICH INCREASES THE AMOUNT AND SIZES OF THE PROPOSED LANDSCAPE MATERIALS - PARTICULARLY ALONG NORTHEAST FIRST STREET AND THE SIDES OF THE PROPERTY. WHEREAS, the Miami Zoning Board at its meeting of February 22, 1999, Item No. 8, duly adopted Resolution No. ZB-1999-0150 by a five to one (5-1) vote, granting a special exception as hereinafter set forth; and WHEREAS, Zoning Ordinance No. 11000, as amended, the Zoning Ordinance of the City of Miami, requires City CITY COMUSSION ME ING OF APR 2 7 1999 Revolution No. 99- 3U8 It"_ 071 Commission approval of the special exception as hereinafter set forth; and WHEREAS, the City Commission after careful consideration of this matter, finds the application for special exception does meet the applicable requirements of Zoning Ordinance No. 11000, as amended, and deems it advisable and in the best interest of the general welfare of the City of Miami and its inhabitants to affirm the decision of the Zoning Board and grant the Special Exception as hereinafter set forth; NOW, THEREFORE, BE IT RESOLVED BY THE COMMISSION OF THE CITY OF MIAMI, FLORIDA: Section 1. The recitals and findings contained in the Preamble to this Resolution are hereby adopted by reference thereto and incorporated herein as if fully set forth in this Section. Section 2. The decision of the Zoning Board to Grant a Special Exception from Ordinance No. 11000, as amended, the Zoning Ordinance of the City of Miami, Florida, Article 4, Section 401, Schedule of District Regulations, to permit a parking lot in the CBD Central Business Zoning District for the property located at approximately 151 Northeast First Street, Miami, Florida, more particularly legally described as Lots 17 and 18, Block 104 NORTH, as recorded in Plat Book B, Page 41, of the Public Records of Miami -Dade County, Florida, per plans on file, with a time limitation of 12 months to pull a building permit, subject to the following conditions: (1) a new site plan must be submitted for review and approval which - 2 - 99- 308 r• h'- modifies the layout so as to locate one of the three handicapped spaces along the East Side of the property, and the other two along the West side; and (2) a new landscape plan must be submitted for review and approval which increases the amount and sizes of the proposed landscape materials - particularly along Northeast First Street and the sides of the property, is hereby affirmed and the Special Exception is hereby granted. Section 3. This Resolution shall become effective immediately upon its adoption and signature of the Mayor.!' PASSED AND ADOPTED this 27th day of April 1999. JOE CAROLLO, MAYOR In accordance with Miami Code Sec. 2-36, since the Mayor did not indicate approval of this legislation by signing it in the designated place provided, said legislation now becomes effective with the elapse of ten (10) days m the date of Comm;ssicn tic^ regarding same, without the May r exe ci 'ing o. ATTEST: / vJalter J. Foe . C' Clerk WALTER J. FOEMAN CITY CLERK APPROVED TO hRM CORRECTNESS.t/ RNEY 61:YMT:BSS:hdb If the Mayor does not sign this Resolution, it shall become effective at the end of ten calendar days from the date it was passed and adopted. If the Mayor vetoes this Resolution, it shall become effective immediately upon override of the veto by the City Commission. - 3 - S9- 408 1V- i Z-2 ZONING FACT SHEET Case Number: 1998-0183 22-Feb-99 Item No: 8 Location: 151 NE 1 Street Legal: (Complete legal description on file with the Office of Hearing Boards) Applicant: Erie Corporation Lee S. Schwartz 2699 S. Bayshore Drive 100 N. Biscayne Blvd. #1410 7th Floor Miami, FL 33133 Miami, FL 33132 App. Ph: (305) 856-2444 Rep. Ph: (305) 577-0188 ext Rep. Fa (� _ ext Zoning: CBD Central Business District Request: Special Exception as listed in Ordinance No. 11000, as amended, the Zoning Ordinance of the City of Miami, Article 4, Section 401, Schedule of District Regulations, to permit a parking lot in the CBD Central Business District zoning district. Recommendations: Planning and Development: Approval with conditions Public Works: No comments Plat and Street Committee: N/A Dade County Transportation: No comments Enforcement History, If any C.E.B. Case No: Last Hearing Date: Found: Violation(s) Cited: N/A Ticketing Action: Daily Fine: Affidavit Non -Compliance Issued on: Warning Letter sent on: Total Fines to Date: Lien Recorded on: CEB Action: See attached Exhibit "1" History: Analysis: Please see attached. Zoning Board Resolution No: ZB 1999-0150 Zoning Board: Approval with conditions Appellant: Ronald and Dorothy Leventhal Comply Order by: Vote: 5-1 99- 308 4- Iu. Anel Rodriguez �9 ! LFIQ] C I T Y O F M I A M I r ARPS PROPERTY SYSTEM LIEN INQUIRY BY FOLIO / ADDRESS (15) PAGE NO: !00011 G FOLIO (011004011201 ADDRESS [ 151) [NE] 11 ] (ST ] UNIT [ ] LEGAL: 1) MIAMI NORTH PB B-41 4) 2) LOTS 17 & 18 BLK 104 5) 3) LOT SIZE 100.000 X 150 = LIEN NO TYPE STATUS DATE COMP / ACCTNO FRONTAGE COST/AMT DUE CE9804051 AL50 PEND 12/11/1998 .00 0.00 4521H ALO1 PRE-PEND 05/11/1991 100.00 2,060.66 SELECT ACTION: 1-INQ ENTER ACTION [1 J NO MORE RECORDS XMIT [ J Window ARPSWIN/1 at PRODUCTION 9 6 Pg=1 FORM RCV LTAI Date: 4/16/99 Time: 11:53:01AM = 9- 3� i - Anel Rodriguez 54, bi 4- it, 'I ra449G G f-3 !ADVI ] SECURITY [ ] ACTION [L] SCR [ ] MOD [ ] +/- [+ ] PAGE 1 !9804051] !1571] COMPLAINT TRACKING MODULE (33) !C ] VIOLATION MAINTENANCE SCREEN )MPLAINT NO: [9804051] TYPE: 525 STAT: LA LA BOARD: [C ] CASE NO: 9804051 REF NO: [1571) COMPLY DUE 12/06/1998 COMPLIED DATE [ ] TKT TIME ADDRESS: E- 147 NE 1 ST TKT DATE TICKET NO: TICKET FINE: MAINT BY: II DATE: 03/09/1998 STATUTE: C DIVN: Z SUBDIV: TRACKING: CREATE DATE: 03/09/1998 VIOLATION DESC: FAILURE TO MAINTAIN EXTERIOR SURFACE STATUS: [A] OF BUILDING. LEGAL DESCRIPTION: MIAMI NORTH PB B-41 PRIM: CBD LOTS 17 & 18 BLK 104 SD1: LOT SIZE 100.000 X 150 OVERRIDE: [ ] CUSTOM VIOLATION / CORRECTION TEXT CLARIFICATION: [THE EXTERIOR CONDITION OF THE BUILDING IS AN ] [EYESORE FOR THE COMMUNITY. ] f ] CORRECTION: [PLEASE IMPROVE THE APPEARANCE OF YOUR PROPERTY. ) [ 1 t ] PRESS <XMIT> TO CONTINUE Window BZWIN/1 at PRODUCTION 22 1 Pg=1 FORM RCV LTAI Date: 4/16/99 Time: 11:52:33AM 09- 068 I Z" 1 :X";�;+ Anel Rodriguez Pcx3 -r— 3 !ADBD ) SECURITY [ I ACTION [L] SCR [ ) MOD [ ) +/- [+ J PAGE 1 !98040511 ! ] COMPLAINT TRACKING MODULE !9804051] (35) BOARD MAINTENANCE SCREEN COMPLAINT: [9804051) TICKET [ ] BOARD: C $5000 FLAG: N LIEN FLAG: P OWNER NAME: ERIE CORPORATION STAT: LA LA PEND LIEN: 12/11/1998 EXACT ADDR: 147 NE 1 ST NET: 7 CERT LIEN: ASSIGNED: Z II ISRAEL IBANEZ REF NO: CERT BY: CASE NO (98040513 HEARING DATE [10071998] OUTCOME [GAF ] INSTALLMENTS [ J APPEAL: (N) DATE [ J DEADLINE C ] PER DIEM: 250.00 2ND PARTY NAME:[ERIE CORPORATION } CAP: 0.00 ADDR [SOPHIE GILBERT ] DADE CNTY LIEN: BOOK [ ] (9801 COLLINS AVE APT 18-W ] [ ] FROM PAGE [ ) CITY [MIAMI BEACH ) STATE [FLI ZIP [33154-1824] TO PAGE [ j REMARKS: [ON 10/7/98 FOUND GUILTY;60 DAYS COMPLY BY 12/6/98 ] ($250 PD ] [ } BOARD STATUS: C ADMIN BOARD CALC TOTAL PER FEE COST EXPENSES FINE PER DIEM DIEM ADJ CURR BALANCE: 0.00 0.00 0.00 0.00 32750.00 0.00 TOTAL DUE: 32750.00 PRESS <XMIT> TO CONTINUE Window BZWIN/l at PRODUCTION Date: 4/16/99 Time: 11:52:41AM 22 1 Pg=1 FORM RCV LTAI J- a w I °4,- ANALYSIS FOR SPECIAL EXCEPTION 151 NE 1" Street. CASE NO. 1998-0183 Pursuant to Section 401 of Article 4 of Ordinance 11000, as amended, The Zoning Ordinance of the City of Miami, Florida, the subject proposal has been reviewed to allow a commercial parking lot within the Central Business District (CBD), as follows: The following findings have been made: • It is found that this request is in order to allow a total of 55 parking spaces (including 3 handicapped parking spaces) on the subject lot; this is specifically being accomplished by proposing to utilize a car -lift system which will allow vertical parking on a surface lot without permanent garage construction. • It is found that the requested Special Exception will be beneficial to the area in providing more parking spaces for the public within Downtown. + It is found that NE I" Street is a one-way street going west and as such, with appropriate screening along the easterly side of the lot, and strategic placement of the handicapped spaces (which do not include lifts) a majority of the vehicles parked on the subject property can be screened so as to render them imperceptible via vehicular traffic. • It is found that the depicted landscape plan is insufficient to provide the type of screening envisioned for this specific type of proposal; the landscape plan should include heavier hedging and larger trees with additional landscape along the sides of - ` the property. l • It is found that upon compliance with the conditions specified below, this project will J not have any adverse impacts on the surrounding area. Based on these findings, the Planning Department is recommending approval of the application with the following conditions: 1) A new site plan must be submitted which modifies the layout so as to locate one of the three handicapped spaces along the east side of the property, and the other two along the west side. 2) A new landscape plan must be submitted for review and approval which increases the amount and sizes of the proposed landscape materials - particularly along NE 1" Street and the sides of the property. 0 i m m.*,wA s eowt9."I MIAIM ARENA we. ciwloiiii� e THATCHER ENTERPRISES PROPERTY TR.-A- I t.9ttX °o 660009 ago -.-a - - la. .100 LASON Systems, Inc. S.i . 6954 N.W. 12 STREET. MIAMI, FLORIDA 33126 305-477-9149 •800-287-4799 • FAX 305-477-7526 THE FOLLOWING IS AN IT WILL TAKE MULTIPLE IMAGES M r L r L AL a , i• � 4't''�' � uo � e �, „ � , .. � ` is } { : d `•� ,'; r • r �• a+ %br t w ,'.%,.fl•(4w ���:�_ .fit 'At�. b `� � ' .., . � _•r I + ". 1 . .� _ � .., .rr•.rn�.� a r) i>.:. . ++ aua.-..1.{f : `rsa.r,,,1..�..K'a?..�n� � ,t'. + 1..� . L Of r � W r `�w µ�11rr. M� •• .�tt,r• � C.. o+ � t r. r. w�. .. Lei 9-7 i i -1 _•ti gh �i ` • � l� � � � * .,i y 'J �a� as �.L��F . r ujy{.� i v.. ... r � �i�' � �. � -. � �l!wlrr , r +►Y1� ,.-•waa...iw-:.+ wo TO THE HONORABLE MAYOR AND CITY COUNCIL OF THE CITY OF MIAMI, THE STATE OF FLORIDA BY AND THROUGH THE OFFICE OF HEARING BOARDS: NOTICE OF APPEAL FROM: DECISION ON ITEM NUMBER EIGHT (8) BY THE CITY OF MIAMI ZONING BOARD ON FEBRUARY, 22, 1999 - - - SPECIAL EXCEPTION APPLICATION NUMBER 1998-0183/151 ----------------------------------- March 8, 1999 RESPECTFULLY SUBMITTED BY: RONALD S. LEVENTHAL DOROTHY A. LEVENTHAL 353 Woodlawn Drive Marietta, Georgia 30067 Telephone: (770) 565-7757 Telecopier: (770) 578-6514 9 9 zo Ronald S. Leventhal Dorothy A. Leventhal 353 Woodlawn Drive Marietta, Georgia 30067 Telephone: (770) 565-7757 Facsimile: (770) 578-6514 March 8, 1999 original Via Federal Express Copy Via Telecopier to (305) 416-2035 Ms. Teresita L. Fernandez, RA, AICP Chief, Office of Hearing Boards City of Miami 444 S.W. Second Avenue, 7th Floor Miami, Florida 33130 Re: NOTICE OF APPEAL From: c c 61 Decision On: Special Exception Application #1998-01831151 N.E. First Street, Miami, Florida, heard before The City of Miami Zoning Board on February 22, 1999, Item Number 8 Dear Ms. Fernandez: Please be advised that the undersigned, Ronald S. Leventhal and Dorothy A. Leventhal (the "Leventhals" or "Appellants"), as to the interest we represent in the property located at 151 N.E. First Street, Miami, Florida (the "Property"), hereby appeal to the Mayor and the City Council of the City of Miami from the decision of the City of Miami Zoning Board with respect to the decision by that Board on February 22, 1999, on Agenda Item Number 8, in connection with Application Number 1998-0183. In accordance with the requirements for such an Appeal, we respectfully submit that the Five Hundred Dollar ($500.00) filing fee is not payable, due to the interest we represent in the Property. While there is disagreement between the various equity holders with respect to whether or not the interest is held by and through a corporation or whether or not it is now a tenancy in common, that remains a legal issue to be resolved by a court of competent jurisdiction. The interests of Dorothy A. Leventhal and Ronald S. Leventhal are at risk (regardless of the nature or the status of the title holder, either as to equity interests or creditors, as a result of the decision of the zoning Board). 9 9 - �08 FERNANDEZ March 8, 1999 Page Two Although we do not believe the $500.00 is due, out of an abundance of caution, a check in such amount is enclosed for the appeal fee, subject to refund if it is not due as a result of the interests of the Leventhals. This Appeal is based, inter alia, upon the following: (1) That we contend there has been a failure of the Application to be proffered, presented and pursued before the City of Miami, by and through its Zoning Board or otherwise, by any legally authorized and proper representative with authority to act on behalf of the interest represented by the undersigned and therefore the Property. (2) That we contend the Application has been derived through a process inconsistent with the laws of, inter alia, the State of Florida. (3) That we contend the variance sought results in a diminution in value of the Property in that it contemplates a demolition of an existing physical structure (the building on the property estimated to be in excess of Twenty Five Thousand (25,000) square feet). (4) That we contend, the granting of the special exception and variance and resulting demolition adversely impacts upon the interest represented by the undersigned; the undersigned assert they represent, the sole (known to the undersigned) creditors of the Property based on the assertion of dissenters, rights under Florida Law if the entity is a valid corporation -- further, if dissenters, rights were not available for the opponents of an election to destroy the building and lease a parking lot, then the proponents before the City are taking actions which fly in the face of the documents they have submitted to the City; if Erie is not a valid corporation, then all equity holders must actually execute the Application, which they have not. (5) That we contend the requirement imposed by the Zoning Board on February 22, 1999 of a hold -harmless agreement is non-specific; the Record of that decision does not delineate as part of the Record that a "circuitous" indemnity not be permitted to be delivered by the Erie entity (which we challenge) as compared to the individuals who comprise the proponents of the special exception in their individual capacities, in a sum sufficient to protect the interests represented by SJ` JG8 %- FERNANDEZ March 8, 1999 Page Three the City and therefore the undersigned; the hold -harmless agreement should also be in a form fully assignable "at the sole and exclusive discretion of the City of Miami," should such an assignment be desirable in order to avoid any further involvement by the City of Miami in this matter. (6) That we contend there has been by the Miami Zoning Board unequal treatment, by having given possible greater weight or credibility to the statements made by counsel, Richard Ivans, when Ivans was expressly permitted not to take an oath requiring him to make all statements in an absolute and truthful manner under penalty of perjury; this unequal treatment, due to Ivans being an attorney and a resident of the State of Florida, impacts the rights of the Appellants to procedural due process, in that the rules of evidence were construed procedurally unconstitutionally. Additionally, this unequal treatment impacted the rights of the Appellants to substantive due process and equal protection and violated the privileges and immunities clause. See Fourteenth Amendment, United States Constitution. (7) That we contend statements made by Ivans, taken as being under oath or being deemed truthful by the Zoning Board were in fact either defamatory, misleading or designed to be misleading; that we contend that the facts to be proffered by this (evidentiary) appeal will reflect that Ivans omitted to tell and disclose certain facts which, had such facts been disclosed, would have caused statements he made, otherwise not misleading; this is together with a methodology by Ivans, we contend, of imparting false inferences to the Zoning Board to result in an inappropriate decision with the false inferences including but not limited to the statement by Ivans that the signature by Dorothy Leventhal (as secretary) on a certain lease document purportedly between the entity known as Erie and the purported lessee -applicant, Centre City Parking through Mr. Lee Schwartz, was a "clean" delivery of same, when in fact it was conditioned on conditions which were unfulfilled, causing the half-truth statement by Ivans before the Zoning Board to be false and known to be false and fraudulent by Ivans. (8) That we contend Ivans' statement to the effect that each family had its Ronald Leventhal to bear was known by Ivans to be defamatory, misleading and designed to impart to the Zoning Board an inference that it was the 09- t 0 rA FERNANDEZ March 8, 1999 Page Four Leventhals who were incorrect in the positions asserted, both between the various parties in the dispute over the Property, as well as the issues at that time before the Zoning Board; in fact, we contend, the absolute, unequivocal, unrefutable contrary is true: Ivans is and remains a main problem in this matter, due to what we contend are the serious frauds, outright lies and false inferences perpetrated by Ivans in this matter, together with conflicts of interests and other improprieties; we contend that Ivans and others participated and acted in illegal concert to deprive the Leventhals of certain of their rights under the Constitutions of Florida, Georgia and the United States, including the rights to due process, notice, and certain rights with respect to interests in property, and that the inferences regarding Ronald S. Leventhal and direct inflammatory statements made by Ivans regarding Ronald S. Leventhal are an attempt by Ivans and those acting in concert with him to maneuver the Zoning Board and others around the issues and misdirect actions accordingly. (9) That in general, the Appellants hereby respectfully object to any change in the status of the zoning ordinance and any variance thereof, as is presently affixed to the subject Property. (10) That the Appellants further respectfully object to any actions by any governmental authority, including but not limited to the City of Miami and their representatives, individually and in their official capacities, to in any way further the alleged improper and illegal conduct of the zoning Applicants) and those participating and acting in concert with and otherwise representing the Applicant(s), as an infringement upon their Property rights as are set forth under the United States Constitution, the Georgia Constitution and the Florida Constitution. (11) That the Appellants respectfully submit that the zoning ordinance and laws of the City of Miami and the State of Florida, as written, are unconstitutional as applied, to the extent that they would purport to authorize the City of Miami, acting through the Zoning Board and the City Council, to accept at face value the authority of those who presently purport to represent the interests of the Property owners of the Erie Property, based upon the fact that such has clearly been refuted by the Appellants and has at best been supported only in a hollow manner by the proponents of the Application. 009— { .. n FERNANDEZ March 8, 1999 Page Five (12) That the Appellants respectfully deem the process to grant a variance for the purpose of the demolition of the sole asset erected on the subject Property to be, in light of the financial damage that would be caused to the Appellants, an unconstitutional deprivation of property rights, not supported by any ordinance, statute or regulation which would in any way permit such to be effectuated by any official in any official capacity on behalf of the City of Miami, or otherwise. (13) That the Appellants respectfully object to any decision to proceed with the Application in any manner as being arbitrary and capricious, favoring unsubstantiated authority, particularly in the face of the rebuttal and statements as to the lack of such authority by any proponents to proceed. (14) That the Appellants respectfully request that a complete Record of these proceedings be made for further, if necessary, judicial review and that full disclosure be made by each of the proponents of the Application, as is required by law, as to financial and other matters that affect the within pending matter. (15) The Appellants respectfully object to any person appearing before the City Council in these proceedings without all statements made being under oath and under penalty of perjury. (16) That the Appellants appeal to the Mayor and the City Council on such other and further grounds as may be presented by the undersigned, including but not limited to the procedural constitutional and substantive rights evolving out of the interest represented herein and the preservation of the structure on the Property and its affect on the citizens and property owners of Miami or any of them. Enclosure: (1) Check c:\rs1\appeal.not Very truly yours, R " o y ald S . Levent al Dor th "Le thal t 9 208 r L A t-I TO THE HONORABLE MAYOR AND CITY COUNCTV OF THE CITY OF MIAMI, THE STATE OF FLORIDA BY AND THROUGH THE OFFICE OF HEARING BOARDS SUPPLEMENT TO NOTICE OF APPEAL FROM: DECISION ON ITEM NUMBER EIGHT (8) BY THE CITY OF MIAMI ZONING BOARD ON FEBRUARY, 22, 1999 - - - SPECIAL EXCEPTION APPLICATION NUMBER 1998-0183/151 ----------------------------------- March 25, 1999 RESPECTFULLY SUBMITTED BY: RONALD S. LEVENTHAL DOROTHY A. LEVENTHAL 353 Woodlawn Drive Marietta, Georgia 30067 Telephone: (770) 565-7757 Telecopier: (770) 578-6514 S 9 - !D V ( Ronald S. Leventhal Dorothy A. Leventhal 353 Woodlawn Drive k Marietta, Georgia 30067 — 1 Telephone: (770) 565.7757 Facsimile: (770) 578-6514 March 25, 1999 Original Via Certified united States Mail =_ Ret./Rec./Req. Z 315 075 575 And a Copy Via Telecopier To (305) 416-2035 Ms. Teresita L. Fernandez, RA, AICP Chief, Office of Hearing Boards City of Miami 444 S.W. Second Avenue, 7th Floor Miami, Florida 33130 Re: SUPPLEMENT TO NOTICE OF APPEAL From: .Decision On: _ Special Exception Application #1998-0183 151 N.E. First Street, Miami, Florida, heard before The City of Miami Zoning Board on February 22 1999 Item Number 8 Dear Ms. Fernandez: Please be advised that the undersigned, Ronald S. Leventhal and Dorothy A. Leventhal (the "Leventhals" or "Appellants"), as to the interest we represent in the property located at 151 N.E. First Street, Miami, Florida (the "Property"), hereby supplement our timely appeal of March 8, 1999, docketed on March 9, 1999, to the Mayor and the City Council of the City of Miami from the decision of the City of Miami Zoning Board with respect to the decision by that Board on February 22, 1999, on Agenda Item Number 8, in connection with Application Number 1998-0183. This document serves as the SUPPLEMENT TO NOTICE OF APPEAL ("SUPPLEMENT"). We are herein addressing and specifying the basis for the last error that we charged, in Paragraph 16, wherein we stated "on such other and further grounds." The supplement to Paragraph 16 is as follows: f - 3 _ 4 ;1 - i �V� Ms. Teresita L. Fernandez March 25, 1999 Page Two (16) That a review of the transcript of the proceedings held before the City of Miami Zoning Board at its bi-monthly on February 22, 1999 (the "ZONING TRANSCRIPT"), manifests several issues which require review by the City Council of Miami, both as to legality and propriety, as such affected the Zoning Board's decision: (a) That at Page 9 of the ZONING TRANSCRIPT, Assistant City Attorney Trehy stated that: "I suggested that at a minimum we get a release and hold harmless from this corporation. You may want to seek additional protection." (b) That continuing, on Page 9 of the ZONING TRANSCRIPT, Ms. Trehy stated: "I can advise you that legally, as you know, under the corporation statutes and Florida statutes, the President and Vice -President do have apparent authority to sign, but we have put on notice, late, eleventh hour as it is, that there may be some concerns with the authorization for this Application." (c) That notably, in response to the concerns raised by Ms. Treyhy, Mr. Richard Ivans was not under oath, as Ms. Treyhy stated at Page 11: "Well, fortunately, we don't swear them (attorneys) in and second we lost the person to swear people in;" referring to Mr. Ivans, attorney at law, she was correct in the sense that it was fortunate for Mr. Ivans that he was not placed under oath, as that would have assisted, we contend, in a possible perjury charge, perhaps if not by the City prosecutors, the district attorney or other governmental agency. However, The Board is required to take testimony under oath. City of Miami Code, Article X, Sec. 2-816. See also City of Miami Code, Article X, Section 815(d) requiring that "all testimony shall be under oath . . . Of course, other evidence (such as documents, including letters) are admissible and must be considered by the Board pursuant to, among other things, Article 16, Sec. 1604. This is necessary, it would seem, so that the Board can meet its requirements, requirements that the Board failed to meet because it failed to, inter alia, making findings of fact. (d) That, by way of partial background, a meeting was held by the representatives of the equity holders of Erie, on April 16, 1995 to properly document the continuing existence of Erie in terms of maintaining its corporateness, as is set forth in numerous cases promulgated under the Florida statutes, which address the 99- 13C8 V K• Ms. Teresita L. Fernandez March 25, 1999 Page Three issues of corporate formalities, fraud upon the public, the basis upon which creditors may pierce the corporate veil and the bases for which a corporation would lose its corporateness or its right to function as a corporation. (e) That the minutes of that 1995 meeting to cure matters were never signed, and the election of any officers emanating from that meeting were never ratified and subsequently approved in writing, consistent with Florida statute -- unless something has been done clandestinely, not otherwise known to the Leventhals. (f) That Dorothy Leventhal is secretary of the Erie entity and has been since the late 1980's, if Erie maintains its corporateness; Sophie Gilbert is President and Janet Weinstein is Vice President. (g) That Ronald S. Leventhal holds a contractual interest to a percentage undivided interest of the rights of Dorothy A. Leventhal since September 9, 1998, and having held, at prior times when Erie was validly operating as a corporation before it lost its corporateness, the proxy rights to vote all of the interests of Dorothy Leventhal. (h) That without counsel, and without any notice to the Leventhals, the remaining equity holders of Erie actually signed a listing agreement, we contend, in a clandestine and fraudulent manner, acting ultra wires the Erie entity if in fact it was a corporation (maintained its corporateness), in early 1997. (i) That in March 1998 there was a legitimate agreement to sign a listing agreement with Cushman & Wakefield through Mr. Mark Gilbert, the son of Dr. Arthur Gilbert, a broker with Cushman & Wakefield in Miami. (j) That the signing of the listing agreement with Cushman & Wakefield manifestly states on its face that it is being signed by Dorothy Leventhal, not in support of the proposition that Erie is a corporation, but that her signature for her own direct interest in the property, as to Twenty Five Percent (250), such being known to the remaining holders who contended they signed for the entity. (k) That nevertheless the listing went forward with an agreed upon sale price for the property. a .t.. s It,. Ms. Teresita L. Fernandez March 25, 1999 Page Four (1) That shortly thereafter, Mark Gilbert contacted Ronald Leventhal in 1998 and stated that he had resurrected prior negotiations from 1996 with his friend, Michael "Mickey" Meyer of Centre City Parking. (m) That the Leventhals had serious concerns about any proceedings with Centre City in 1998 due in part to the information proffered by agents of Central Parking Company who were viewing the property, in late 1996-early 1997, that the site did not effectively economically work for a parking lot on a long-term basis with a significant up front commitment, absent using the creative elevator systems that Centre City is bent on using, and that the use of such was highly questionable. (n) That nevertheless, in the summer of 1998, negotiations proceeded through Richard Ivans with the Leventhals, substantively negotiating on an arrangement with Centre City, trying to determine if, inter alia, appropriate protection could be afforded for those who would use the parking lot as such would affect the owners of the property as the equity holders. (o) That this procedure was based upon the premise that the Leventhals had no choice but to accede to the demolition of the building that they wished to see preserved, for which they had offered $500, 00.00 to fund, on an arms length basis, and that the Leventhals, not attorneys, while they are competent to represent their interests, were at the time not as familiar with Florida law as they are today, and still learning. (p) That in the 1998 process of seeking to negotiate the arrangements with Centre City, Leventhal received what he contends was a "strange" call from Mark Gilbert, requesting that an up front commission, based upon a twenty (20) year lease arrangement be advanced by the equity holders. (q) That Ronald Leventhal analyzed the calculations based on the proposal, noting that first, in his view, commissions are not payable up front and that even if they were, on a 20 year basis, such a significant amount of funds being advanced in commissions would represent a substantial portion or more than half the amount that the Leventhals and all equity holders were insisting be escrowed by Centre City in order for the lease to be signed. SQ9-. CGS t, Ms. Teresita L. Fernandez March 25, 1999 Page Five (r) That the Leventhals immediately passed on their concerns with respect to that coincidence in the numbers to other equity holders in Erie. (s) That several efforts were made to finalize the lease document and on a Thursday, July 8, 1998, via Federal Express, a signed lease was received at the residence of the Leventhals in Atlanta from the offices of Mark Gilbert in Miami, containing a lease document signed by Centre City and by the President of Erie, Sophie Gilbert. (t) That the document required the signature of Dorothy Leventhal, secretary. (u) That with respect to the lease document received, the signature of Sophie Gilbert was an extremely close copy, but in fact was a forgery. (v) That a handwriting analysis expert concluded that the witness to the forgery was female but that the forgery may have been carried out by a male individual. (w) That being the forged document was forwarded by Mark Gilbert, the Leventhals asserted their view that he had forged his Grandmother's signature and someone at the offices of Cushman & Wakefield in fact may have witnessed the forgery. (x) That the Leventhals reported this matter to the remaining equity holders of Erie, who represent the interests of some of the minority owners, and who purportedly constitute the Board of Directors. (y) That it was immediately confirmed, that Sophie Gilbert neither signed the lease nor authorized (nor could she as a matter of corporate law) her signature on the document, via telephone conversation with Mr. Ronald Deblinger, Ms. Janet Weinstein and the Leventhals -- Deblinger contacted Mrs. Gilbert while the remaining parties were on hold. (z) That the Leventhals nevertheless voted to proceed with the lease arrangement telephonically at a meeting involving, among others, Richard Ivans and Dr. Gilbert: in that meeting on July 29, 1998, the Leventhals made clear that they would not proceed with a final signing of a legitimately prepared lease document with Centre City absent some arrangement to (1) reinstate the corporateness of Erie or to confirm that it is not a corporation and to not remain in a dispute with respect SJ- "G8 r I Ms. Teresita L. Fernandez March 25, 199:9 Page Six to its integrity, which arrangement had to (2) provide protection against Mark Gilbert ever becoming involved in Erie and (3) that damages be assessed against Cushman & Wakefield who, to date, still has not, to the knowledge of the Leventhals, terminated the relationship with a person who commits forgery and then forwards the document through the equivalent of the U.S, mail, to fraudulently induce another to execute same, Mark Gilbert, and (4) that there be protection with respect to the flow of funds so that the funds cannot be impeded by any other persons as to the Twenty Five Percent (25%) equity interest of the Leventhals, thereby enhancing the eighty (800) percent rule set forth in the original articles of incorporation. (aa) That the Leventhals, notwithstanding having sent a letter to Richard Ivans and the purported Board of Directors the day of the July 29, 1998 meeting, via telecopier, and notwithstanding that Mr. Ivans stated he "noted" the requirements of the Leventhals as part of the record of the meeting to authorize the lease, which is the premise upon which the Application is proffered to the City of Miami, we contend Mr. Ivans appropriated the signature of Dorothy Leventhal on the lease document under intentional and false pretenses and did not state to attorney Jay Schwartz, the attorney for Centre City, the facts regarding the conditions governing the signature of Dorothy Leventhal on the lease document. (bb) That the lease document required notice to Dorothy Leventhal, specifically, of all significant events and that not one notice has been forwarded to Dorothy Leventhal by Centre City, therefore constituting multiple events of default on the lease. (cc) That at no time prior to the July 29, 1998 meeting and the meeting on November 8, 1998 to authorize Lee Schwartz of Centre City to proceed with the Application before the City of Miami, were the Leventhals or any of the other equity holders of Erie, who may not have desired to risk remaining involved, given notice of their right to be bought out in accordance with Florida's dissenters' statute. (dd) That the failure to have given notice by Mr. Ivans, purportedly acting for the purported company and of the remainder of the purported Board of Directors, seeking to significantly alter and modify the property by the demolition of its sole structure, constitutes a clear 0r VC AL UL { Ms. Teresita L. Fernandez March 25, 1999 Page Seven unauthorized departure from the required statutes of Florida in obtaining the Board authorization for the lease and the signature of Lee Schwartz to be legitimate and proper on the Application to the City of Miami. See South End Improvement Group, Inc. v. Mulliken, 602 So. 2d 1327 (1992) (which while a derivative action matter, addresses the important issue that the requirement that a shareholder notice and consent requirement be given thereby triggering dissenters' rights, that "a disposition of corporate assets may be considered `substantially all' if either its quantitative or qualitative impact, or both, would fundamentally change nature of corporation"). (ee) That while in the South End matter the disposition of land as a contribution represented Ninety -Eight Percent (980) of the disposition of its assets, thereby bringing into play the dissenters' right statute on a mandatory basis, in the Erie matter, the demolition of its sole building, the source of its revenue and an enhancement to the property (had it been property maintained by the equity holders as the Leventhals urged repeatedly, and as it still could be and should be to provide facilities for the citizens of Miami, within walking distance to a metro railway system), clearly constitutes a quantitative impact and, even if that were even remotely offset by paving the property (which in light, inter alia, of the nature of the lifting systems risks it is not), a qualitative impact that would fundamentally change the nature of the Erie property. Id. at 1331-32. (ff) That notably, South End cites to, among other cases, a matter where the physical plant, similar to the Erie building, constituting over Fifty -One Percent (5101) of the corporate assets and generating less than Fifty Percent (500) of its sales, was a disposition of "substantially all" of its assets. (gg) That in this matter, taking the easy way out after inheriting property in good standing and in good repair, the majority of the equity holders would prefer to see the sole source of revenue demolished rather than maintained and revived. (hh) That while that may be within their purview, Florida statutes require that no Board authorization used as a basis to apply to the City of Miami for any special exception Application is legal, absent the Leventhals, �00 i Ms. Teresita L. Fernandez March 25, 1999 Page Eight and anyone else who is an equity holder, in a similar circumstance, who would prefer not to go along with such, being offered, in writing, dissenters' rights by statute. (ii) That the Leventhals, beginning in the late Fall of 1998, were in contact with the City of Miami by and through its Board of Hearings Office to frequently check into whether or not any purported Application had been submitted. (jj) That the failure to obtain a proper Board authorization for the Application to be presented to the Zoning Board was an issue raised by the Leventhals prior to the time the Application was submitted. (kk) That the Leventhals have repeatedly made clear their contention that the Application is void ab ini tio, and is not obtained in accordance with Florida statute, and therefore any resulting activities, including the vote by the Zoning Board, even if it were correct substantively and procedurally (which it is not) , within the parameters of "discretion" and not otherwise arbitrary and capricious, are a nullity. (11) That the Leventhals have made clear their contention that the participation of the City of Miami in this matter is essential and fundamental to what the Leventhals contend is illegal ultra vires conduct by certain of the equity holders who the Leventhals contend are acting in concert with one another and perhaps with third parties to obtain the requisite special exception in order to then, economically and feasibly in the view of Centre City, demolish the sole erected aoset on the property, and that as was discussed in the ZONING TRANSCRIPT, there is no present economic viability of the property, standing alone as a parking lot, absent the use of the lifting system for cars. See ZONING TRANSCRIPT, PP. 3-4. (mm) That on November 5, 1998, an Affidavit was executed by Lee Schwartz of Centre City Parking, stating that he was the legal representative of the owner of. the Erie property, authorized to proceed with the special exception Application. (nn) That the special exception Application was executed on November 5, 1998. ��Q9- *'0 fA Ms. Teresita L. Fernandez March 25, 1999 Page Nine (oo) That notably, on November 8, 1998, Minutes of a meeting of the purported Board of Directors of Erie took place, stating solely that Lee Schwartz was authorized "to continue" to proceed with the special exception Application. (pp) That nowhere are there any Minutes which reflect that Lee Schwartz was, prior to November 8, 1998, with any specificity whatsoever, allowed to serve as the legal representative to the purported Erie entity. (qq) That Lee Schwartz is not, to the knowledge of the Leventhals, an attorney at law, nor is he listed with the Secretary of State of Florida or elsewhere as the President or Vice President of Erie, if Erie is a corporation. (rr) That therefore any reliance by the City of Miami on Florida statutes respecting the apparent authority of corporations to proceed with such Applications, is clearly misplaced for all of the reasons set forth supra and further because neither the President nor Vice President of the purported corporate entity signed the special exception Application. (ss) That further, with respect to the statements by Mr. Ivans to the Zoning Board that Ronald S . Leventhal has no standing, Ronald Leventhal, as is set forth supra in September 1998, rather than merely indemnifying Dorothy Leventhal, which under Georgia law would otherwise give him standing to be vouched into any proceeding, is the assignee of an undivided interest of Dorothy Leventhal's rights in and to the property whatever form the entity may be, which under Florida law, that constitutes standing. See Equity Resources Inc. v. County of Leon, 643 So.2d 1112, 1117 (1994). (tt) That moreover, Mr. Ivans, to the extent that at Page 13 of the ZONING TRANSCRIPT he indicated that the Leventhals had no standing or were not citizens or tax payers in Miami, Florida, misstated the truth, since Dorothy Leventhal, per se, owns a Fifty Percent (5001) undivided interest in a tract of property within the City of Miami paying real estate taxes of approximately Thirty Six Thousand ($36,000.00) per year as well as an ownership interest through a corporate entity in another tract of real property in Miami, Florida, paying additional taxes annually; clearly, notwithstanding the fact that Dorothy Leventhal is a bona fide tax payer, individually, in the City of Miami of reasonable consequence, 09 _ Ms. Teresita L. Fernandez March 25, 1999 Page Ten the Leventhals are unaware of any view between the states of Florida and Georgia that abrogate not only comity in the court system, but respect for the rights and property interests held in each state by citizens of the other state. (uu) That the City Council, with respect, even if for any reason it views the record of the zoning hearing to be otherwise proper, not warranting an appeal -- with which the Leventhals would respectfully disagree, as a matter of fundamental and procedural and substantive due process -- that the issue must be addressed by the City Council as to the propriety of the acceptance of the Application in the first instance. (vv) That until final action is taken on the Zoning Board's decision, the matter of the Application being defective and, as the Leventhals contend, fraudulently proffered, remains within the breast and purview of the City of Miami and its Mayor and Council, and that we believe the City is a citizen for purposes of diversity jurisdiction. See Moor v. Almeda County, 411 U.S. 693, 93 S.Ct. 1785 (1973) (holding that a county was a citizen for purposes of diversity jurisdiction). Further, under, inter alia, Burger King Corporation v. Rudzewicz, 471 U.S. 462, 105 S.Ct. 2174 (1985, parties can create jurisdiction and become subject to the regulations and sanctions of another state for the consequences of their actions within (or aimed at) citizens of another state. See Zobel v. Williams, 457 U.S. 55, 102 S.Ct. 2309 (1982) (emphasizing that when a state distributes benefits unequally (based on the discussion of non -residency at the Zoning Hearing] , such are scrutinized under the equal protection clause of the Fourteenth Amendment; the United States Constitution protects persons against barriers to interstate movement and noting that citizens of one state are protected by the unconstitutional actions of another state under the privileges and immunities clause). See also Boston Stock Exchange v. State Tax Commission, 429 U.S. 318, 97 S.Ct. 599 (1977) (holding that no state may, consistent with the commerce clause, discriminate against interstate commerce by providing an advantage to local business or imposing a greater burden on out -of -staters). Also see Austin v. New Hampshire, 420 U.S. 656, 95 S.Ct. 1191 (1975) and Metropolitan Life Insurance Company v. Ward, 470 U.S. 869, 105 S.Ct. 1676 (1985). Also see Braddy v. Florida Department of Labor and Employment Security, 133 F.3d 797 (llth Cir. 1998). Sy- �08 ,.. Ms. Teresita L. Fernandez March 25, 1999 Page Eleven (ww) That we respectfully submit allowing this matter to proceed, absent which there is no viability for the demolition of the building, is inconsistent with the immunities afforded the City of Miami and its agents, the reason being that while generally a city may rely upon a proper interpretation of statute and when doing so in good faith may be immune from liability, that clearly the record before the City, as has been stated since the beginning to the Office of Hearings Boards, that other Florida statutes have been violated in order to obtain the purported requisite authority for this matter to proceed with the City of Miami being on notice, that the City and its Mayor and Council may not be immune to in any way act with or for or to assist in any way even indirectly any action which would support the demolition of the sole asset on this property, depriving the Leventhals of property rights. (xx) That if for any reason, the City of Miami believes the appeal in this matter is not of a zoning appeal nature but of an appeal of the Application being considered, which is a distinction without a difference, then that issue at a minimum should be heard on the appeal of this matter on April 27, 1999. (yy) That the Zoning Board, while requiring an indemnification, was non-specific as to its contents and details. (zz) That the Leventhals submit that Erie is not in the indemnification business and that such document would flow in violation of dissenters' rights which must again be afforded before any valid authority is givan for the indemnification flowing out of the same nucleus of facts and circumstances to proceed due to the exposure to Erie, whatever its status. (aaa) That the Leventhals object to the delivery of any hold harmless agreement or the acceptance by same as is now required by the Zoning Board, unless it is in true and proper form to protect the citizens of Miami to the utmost and that it comes from individuals of substantial independent net worth, separate from the property at issue in these proceedings. s e7J_ J�� Ms. Teresita L. Fernandez March 25, 1999 Page Twelve (bbb) That to the extent any matter proceeds, in favor of C the applicant, on any basis, the Leventhals respectfully insist upon a right of appeal or other administrative - hearings to address these issues, either before the City Council, a panel, board or otherwise, consistent with which the Leventhals reserve any and all rights they have both in law and in equity, against, with great reluctance, against the City of Miami and'its officials in their official and individual capacities. (ccc) That the right of the Leventhals to assert their = interests to protect their property rights herein are - properly consistent with their assertions of fraud and cumulatively with their exercise of dissenters' rights, not acknowledged by Mr. Ivans and the ultra wires group purportedly operating the Erie Property. See Fla. Stat. § 607.1302(5). (ddd) That most troublesome are Chairman's Barquett's statements, at Page 17, of the transcript, to his seemingly friend, Lee Schwartz, that: "Lee, is there - anything else you want to say in closing? He took the ball and ran with it. Now, don't you fumble on the goal line . . . Lee, you did a good job." Very tr�u�lyj yours, % R. ald S. Leventhal Dorothy Leve thal c:\erie\appea12.not 0 9 tJ lJ Miami Zoning Board Resolution: ZB 1999-0150 Monday, February 22,1999 Ms Gloria M. Basila - offered the following Resolution and move its adoption Resolution: AFTER CONSIDERING THE FACTORS SET FORTH IN SECTION 1305 OF ORDINANCE NO. 11000, THE ZONING BOARD GRANTED THE SPECIAL EXCEPTION AS LISTED IN ORDINANCE NO. 11000, AS AMENDED, THE ZONING ORDINANCE OF THE CITY OF MIAMI, ARTICLE 4, SECTION 401, SCHEDULE OF DISTRICT REGULATIONS, TO PERMIT A PARKING LOT IN THE CBD CENTRAL BUSINESS ZONING DISTRICT FOR THE PROPERTY LOCATED AT APPROXIMATELY 151 NE 1ST STREET LEGALLY DESCRIBED AS LOTS SEVENTEEN (17) AND EIGHTEEN (18) OF BLOCK ONE HUNDRED FOUR (104) NORTH OF THE CITY OF MIAMI, PLAT BOOK "B", PAGE 41, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. THIS SPECIAL EXCEPTION WAS GRANTED PER PLANS ON FILE WITH A TIME LIMITATION OF TWELVE MONTHS IN WHICH A BUILDING PERMIT MUST BE OBTAINED, SUBJECT TO THE FOLLOWING CONDITIONS BY THE PLANNING DEPARTMENT: 1) A NEW SITE PLAN MUST BE SUBMITTED WHICH MODIFIES THE LAYOUT SO AS TO LOCATE ONE OF THE THREE HANDICAPPED SPACES ALONG THE EAST SIDE OF THE PROPERTY, AND THE OTHER TWO ALONG THE WEST SIDE; AND 2) A NEW LANDSCAPE PLAN MUST BE SUBMITTED FOR REVIEW AND APPROVAL WHICH INCREASES THE AMOUNT AND SIZES OF THE PROPOSED LANDSCAPE MATERIALS - PARTICULARLY ALONG NE 1ST STREET AND THE SIDES OF THE PROPERTY. Upon being seconded by Mr. Humberto J. Pellon, the motion was passed and adopted by the following vote: Mr. George Barket Ms. Gloria M. Basila Mr. Charles J. Flowers Ms. Ileana Hemandez-Acosta Mr. Humberto J. Pellon Mr. Fidel A. Perez Mr. Juvenal Pina Ms. Fernandez: Motion carries 5-1 Yes Yes Away Yes Yes No Yes AYE: 5 NAY: 1 ABSTENTIONS: 0 NO VOTES: 0 ABSENTS: 1 Case No.: 1998=0183 Item Nbr: 5 9 9 - "d8 Miami Zoning Board Resolution: ZB 1999-0150 Monday, February 22,1999 Case No.: 1998-0183 4.- 0 Teresita L. Fernandez, Chief Office of Hearing Boards Item Nbr: g S9- 308 ZONING BOARD ACTION 1 _ _ . SPECIAL EXCEPTION 1 move that the request on Agenda Item k ?' be (DENIED) Qthat the requirements of Article 16 (WERE) (WERE N sans ed by relevant evidence in the mold of the public hearing. V(a) as stated in the City's-5ndirigs of fur, or L . (b) as demonstrated by the petitioner, or (c) on the basis of the following: The Zoning Board, in its decision to (GRANT) (DENY) the special exception, shall make written find:ags that the applicable requirements of this Zoning Ordinance, Section 2305, (HAVE) (HAVE NOT) been met (CIRCLE APPROPRIATE CONDITIONS) 1305.1 Ingress and Egress. .Due consideration shall be given to adequacy of ingress and egress to the property and strucntre and uses thereon, with particular reference to automotive and pedestrian safety and convenience, traffic flow and control, and access in case of fire and emergency. 13052 OfEstreet Parking and Loading. Due consideration shall be given to offsttreet parking and loading facilities as related to adjacent streets, with particular reference to automotive and pedestrian safety and convenience , internal traffic flow and control, arrangement in relation to access in can of fire or other emergency, and screening and landscaping. 13053 Refuse and Service Areas. Due consideration shall be given to the location, sane, design, and screening of refire and service area to the manner in which refuse is to be stored. and to the man act and timing of refuse collection and deliveries, shipments, or other service activities, as such matters relate to the location and nature of uses on adjoining properties and to the location and character of adjoining public ways 1305:4 i gad Li h ' Due consideration shall be given to the umber, size, character, location, and orientation of proposed signs, and of proposed lighting for signs and premises, with particular reference to traffic safety, glare, and compatibility and harmony with adjoining and nearby property and the character of the area 19 1305.5 Utilities. Due srderation shall be given to utilities required, with particular `esferenoe to availability and capacity of systems, location of connections, and potentially adverse appearance or other adverse effects on adjoining and nearby property and the character of the area 1305.6 Drainage- Due consideration shall be given for drainage, with particular referent to effect on adjoining and nearby properties and on general drainage systems in the area. Where major drainage volumes appear likely and capacity of available systems is Rmnd marginal or inadequate, consideration shall be given to possibilities for recharge of groundwater supply on the property, temporary retention with gradual discharge, or other remedial measures. 1305.7 Preservation of Natural Features. Due consideration shall be given to provision for the preservation of existing vegetation and geological features whenever possible. 1305.9 Control of Potentially Adverse Effects Generally. In addition to consideration of detailed elements indicated above, as appropriate to the particular class or kind of special permit and the circumstances of the particular case, due consideration shall be given to potentially adverse PEE av generally on adjoining and nearby properties, the area, the neighborhood, or the City, of use or occupancy as proposed, or its location, construction, design. character, scale or manner of operation. Where such potentially adverse effects are found, consideration shall be given to special remedial measures appropriate in the particular circumstances of the case, including screening or buffering. landscaping, control of manner or hours of operation, alteration of use of such space, or such other measures as are required to assure that such potential adverse effects will be eliminated or minimized to the maximum extent reasonably feasible, and that the use of occupancy will be compatible and harmonious with other development m the area to a degree which will avoid substantial depreciation of the value of nearby property — Sigunue i 4. E Agenda Item ;) - as- 1117 Sy- 6®8 71, WE -SS SEROTA HELFMAN PASTORIZA & GUELIES, P.A. ATTORNEYS AT LAW 266S SOUTH BAYSHORE DRIVE 99 APR 1 l r C7 All 8: K SUITE 420 MI `\ LILLIAN ARANGO DE LA HOZ' BROWARD OFFICE PATRICIA M. BALOYRA MIAMI, FLORIDA 33133 1132 SOUTHEAST SECOND AVENUE MITCHELL A. BIERMAN NINA L. BONISKE ELAINE M. COHEN JAMIE ALAN COLE DANIEL H.COULTOFF MICHELLE M. GALLARDO JENNIFER GOMBERG DOUGLAS R. GONZALES EDWARD G. GUEDES STEPHEN J. HELFMAN JOHN R. MERIN. JR. ROBERT W. HOLLAND* JILL A. JARKESY' CHRISTOPHER F. KURTZ GILBERTO PASTORIZA NANCY RUSIN' GAIL D. SEROTA' JOSEPH H. SEROTA JEFFREY P. SHEFFEL DANIEL A. WEISS' RICHARD JAY WEISS DAVID M. WOLPIN STEVEN W. ZELKOWITZ VIA FACSIMILE & U.S. MAIL Ms. Teresita Fernandez Hearing Boards City of Miami 444 S.W. 2nd Avenue, 8th Floor Miami, Florida 33131 TELEPHONE (305) 854-0800 TELECOPIER (305) 854-2323 WWW.WSH-FLALAW.COM Re: Legal Representation Dear Ms. Fernandez: April 1-, 1999 FORT LAUDERDALE, FLORIDA 33316 TELEPHONE (9S4) 763-4242 TELECOPIER (9S4) 764-7770 PALM BEACH OFFICE 1872 SOUTHWEST 17TH STREET BOCA RATON, FLORIDA 33486 TELEPHONE (561) 392-8762 TELECOPIER (561) 392-7551 'OF COUNSEL Pursuant to our telephone conversation, please be advised that the undersigned will be representing Erie Corporation in the appeal filed by Ronald S. Leventhal and Dorothy A. Leventhal of the decision of the City of Miami Zoning Board granting various approvals to the property located at 151 N.E. 1st Street Miami. Florida. I have PrclnsPC1 a cnnx.. of the lnnhvirt re"isra+ion r J J b form. me. Thank you for your cooperation in this matter. Should you have any questions, please call Very truly yours, Stephen J. Helfman SJH/ms 510001 Enclosure CITY OF MIAMI OFFICE OF HEARING BOARDS APPLICATION FOR SPECIAL EXCEPTION _lit11#ltiiilkkltki!lttk#tiiilkaiiiklillkillltikl#ilkiiiliili#ittlkillkiiliitdli!!tt#ltkktkkl#ttk SECTION 2-653 OF THE CODE OF THE CITY OF MIAMI, FLORIDA, AS AMENDED, GENERALLY REQUIRES ANY PERSON WHO RECEIVES COMPENSATION, REMUNERATION OR EXPENSES FOR CONDUCTING LOBBYING ACTIVITIES TO REGISTER AS A LOBBYIST WITH THE CITY CLERIC, PRIOR TO ENGAGING IN LOBBYING ACTIVITIES BEFORE CITY STAFF, BOARDS, COMMITTEES AND THE CITY COMMISSION. A COPY OF SAID ORDINANCE IS AVAILABLE IN THE OFFICE OF THE CITY CLERK (MIAIWII CITY HALL), _ LOCATED AT 3500 PAN AMERICAN DRIVE, MIAMI, FLORIDA, 33133. iikll!#ilk#ktk!#il#ilikilliikkiiikiiiiikflkktlriMiiiikikkiiildkiilliARliiill###i#!kk!lkkkttttilkt NOTE: THIS APPLICATION MUST BE TYPEWRITTEN AND SIGNED IN BLACK INK, Within the City generally, or within certain zoning districts, certain structures, uses, and/or occupancies specified in this ordinance are of a nature requiring special and intensive review to determine whether or not they should be permitted in specific locations, and if so, the special limitations, conditions, and safeguards which should be applied as reasonably necessary promote the general purposes of this ming Ordinance and, in particular, to protect adjoining properties and the neighborhood from avoidable potentially adverse effects. It is further intended that the expertise and judgment of the Zoning Board be exercised in making such determinations, in accordance -with the rules, considerations and limitations relating to Special Exceptions (see Article 16 of the Zoning Ordinance). Formal public notice and hearing is mandatory for Special Exceptions. The Zoning Board shall be solely responsible for determinations on applications for Special Exceptions except when otherwise provided for in the City Code. All applications shall be referred to the Director of the Department Planning and Development for his recommendations and the Director shall make any further referrals required by these regulations. I, LQe S. Schwartz , hereby appl to the City of Miami Zoning Board for approval of a Special Exception for the property located at ] b I N•E. First St., Miami, Fl.., 3;i 13Z , folio number 01-0110-040-11' Nature of Proposed Use (please be specific): Commercial parking lot, In support of this application, the following material is submitted. 1. Two original surveys of the property prepared by a State of Florida Registered Land Surveyor within one year from the date of application. 2. Four copies -signed and sealed by a State of Florida Registered Architect or Engineer -of site plans showing (as required) property boundaries, existing (if any) and proposed structure(s), parking, landscaping, etc.; building elevations and dimensions and computations of lot area and building spacing. s'L,, K 3. Affidavits disclosing ownership of property covered by applications and disclosure of interest from (attaches. to application). _____ 4. Certified list of owners of real estate within a 375-foot radius of the outside boundaries of property covered by the application. 5. At least two photographs that show the entire property (land and improvements). 6. Recorded warranty deed and tax forms for the most current year available that show the present owners) of the property. 7. Other (Specify and attach cover letters explaining why any document you are attaching is pertinent to this application). 8. Fee of $ to apply toward the cost of processing according to Section 62-156 of the Zoning Ordinance: SpecialException...............................................................................................$ 800.00 Special Exception requiring automatic city commission review.......................$2,000.00 Extensionof time for special exception......................................,......................$ 500.00 Public hearing mail notice fees, including cost of handling and mailing per notice.........................................................................$ 3.50 Surcharge equal to applicable fee from item above, not to exceed eight hundred dollars ($800.00) except from agencies of the city; such surcharge to be refunded to the applicant if there is no appeal from a property owner within three hundred and seventy-five (375) feet of the subject property. Signature Name I.eP S. Schwartz Address __ 100 N. Biscayne Blvd. #1410 Miami, FL. ,33132 Telephone .305-577-0188 Date November 2, 1998 3 • r �J �08 I IW STATE OF FLORIDA COUNTY OF MIAMI-DADE The foregoing instrument was acknowledged before me this F,Fr.t day of Ptw:w188;L 1991? , by jXS S4-NwAA-t who is persona own to me or who has produced as identification and wh(rd id not) take an oath. IRA86MA cANTALLOPS MY 00"W'iss55 �• EExOe. Jan. z M Name: 17 +, °ondW by HAi Notary Public -State of Florida + N�° 800-422.I SW Commission No.: i. c. -k ' � '-,' '� My Commission Expires: , I , _ /� i •, STATE OF FLORIDA COUNTY OF MIAMI-DADE The foregoing instrument was acknowledged before me this day of 19 , by of a corporation, on behalf of the corporation. He/She is personally known to me or has produced as identification and who did (did not) take an oath. Name: Notary Public -State of Florida Commission No.: My Commission Expires: STATE OF FLORIDA COUNTY OF MIAMI-DARE The foregoing instrument was acknowledged before me this day of 19 , by partner (or agent) on behalf of a partnership. He/She is personally known to me or who has produced as identification and who did (did not) take an oath. Name: - ---- Notary Public -State of Florida Commission No.: My Commission Expires: AFFIDAVIT STATE OF FLORIDA .} ) SS COUNTY OF MIAMI-DADS ) Before me, the undersigned authority, this day personally appeared �„ £ £� eiw A,ETZ who being by me first duly sworn, upon oath, deposes and says: 1. That he/she is the owner, or the legal representative of the owner, submitting the accompanying application for a public hearing as required by the Zoning Ordinance of the City of Miami, Florida, affecting the real property located in the City of Miami, as described and listed on the pages attached to this affidavit and made a part thereof. 2. That all owners which he/she represents, if any, have given their full and complete permission for him/her to act in his/her behalf for the change or modification of a classification or regulation of zoning as set out in the accompanying petition. 3. That the pages attached hereto and made a part of this affidavit contain the current names, mailing addresses, telephone numbers and legal descriptions for the real property of which he/she is the owner or legal representative. 4. The facts as represented in the application and documents submitted in conjunction with this affidavit are we and correct. Further Affiant sayeth not. Appli=RsSign�=m STATE OF FLORIDA COUNTY OF MIANfl-DARE The foregoing instrument was acknowledged before me this i day of 19 q'� , by of Nye. She is rsonall kno me or has produced and wh didJdid not) take an oath. corporation, on behalf of the corporation. as identification Name: -A—. ,(4 s �-- r-r\ri Q..a - +.1 Notary Public -State of Florida Commission No.: C.(, `il ) --.,>Z.SS My Commission Expires: t k m \G�1� �•%' '&* iw►seti A cwvrALLLOPS aP '� My 66 * * EmPhm Jan. 12. ton BON by t� OWNER'S LIST Owner's Name F.RTF CORPORATION Mailing Address 2699 S. Bayshore Drive 7th Floor Zip Code 33133 Telephone Number 205-856.2444 Legal Description: Lots 17 and 18, block 104, "City of Miami" according to the flat brook B at page 41, of the Public records of Dade County, Florida. - Owner's.Name Mailing Address Zip Code Telephone Number =_ Legal Description: Iwner's Name Mailing Address Zip Code , Telephone Number — Legal Description: Any other real estate property owned individually, jointly, or severally (by corporation, partnership or privately) within 375 feet of the subject site is listed as follows: Street Address Street Address Street Address It.- Legal Description Legal Description Legal Description y- 608 DISCLOSURE OF OWNERSH]P 1. Legal description and street address of subject real property: Lot 17 and 18, block 104, City of Miami, according to the Plat thereof, recorded in Plat Book "B" at Page 41,,of the Public Records of Dade County, Florida. Address: 151 N.E. First Street, Miami, Florida, 33132 2. Owner(s) of subject real property and percentage of ownership. Note: Section 2-618 of the Code of the City of Miami requires disclosure of all parties having a financial interest, either direct or indirect, in the subject matter of a presentation, request or petition to the City Commission. Accordingly, question #2 requires disclosure of shareholders of corporations, beneficiaries of trusts, and/or any other interested parties, together with their addresses and proportionate interest. Owner of property: Erie Corporation - See attached Exhibit "1" Mailing address: Erie Corporation, Attn: Mr. Richard /vans, P.A., 2699 S. Bayshore Drive, 7th Floor, Miami, FL., 33133. 3. Legal description and street address of any real property (a) owned by any party listed in answer to question 92, and (b) located within 375 feet of the subject real property. None Owner or Attorney for Owner STATE OF FLORIDA COUNTY OF MIAMI-DADE r The foregoing instrument was acknowledged before me this �day of 19 Ck, by of a corporation, on behalf of the corporation. has produced and wh6-did-oid not) take an F�►"�����^ IRA�EIri/► CAMTAI.tppa MY coJ"=& CCfaq * �r .. �a, toao as identification c-, r. C' C, n Z--c*v4k7 Name: �.Sc%NN,-- Lvs-\'tcslkG?S. Notary Public -State of Florida Commission No.: C.. C 4b Ja 5.S My Commission Expires: 1 i�l J9— a Jan-20-99 03:16P Katz"'*BarronwSquitero 94' 3483620 P.02 Exhibit 'T' Based upon a review of the books and records of the Corporation, the Shareholders of Eric Corporation and their respective interests are as follows: Name No. of Shares Ownership Peroenkage Dorothy Ann Leventhal 153.00 25% Jean Deblinger 106.79 17.45% Ronald Deblinger 23.105 3.775% Adrienne Kristall 23.105 3.775% Sophie Gilbert 106.79 17A5 % Arthur Gilbert 23.105 3.775% Yvonne Winig 23.105 3.775% Janet R.Weinstein 153.00 25% Totals: 612.00 100 % 0 9 - 308 t.. M O a O N t0 M Do a 'M ri a 01 0 L. ai 4J 0 Cr N C 0 L ro m 4J ro a>r a m M O m o� 0 N l C ro r) irporate Inquiry Menu ,eIofI Florida Division of Corporate Inquiry Menu: :Please select an inquiry type from the list below, then enter a Corporations rP search key in the search field. Press SEARCH to begin the search. Public Access = gnqulryby, 1/20/99 CORPORATE DETA:L RECORD SCREEN 3.09 PM r corporation I Tmkmark Name :NUM. 143561 ST:FL ACTIVE/F'L PROF:: FL:.: 12/21/1944 rOfterrReglebwedAQenlName FEIV: 59-0607980 t^ Registered AgeniName NAME : ERIE CORPORA=:ON IPR:NCIPA_,: MIAMI BEACH F:.. CHANGED: 05/01/95 i%Trademark0anerName ADDRESS -e—W MIAMI BF—kCH, FL 33-54 US r PEI Number MAIL:NG 9601 COLL:NS AVE. CHANGED: 05/01/95 r` Documeot (ADDRESS 18 W Number MIAMI BEACH, FL 33154 US r`TrukroarkName 1PA NAME SOPHIE GILBERT 1RA ADOR : 9e01 COLLINS AVE. APT. 16 W. ADDR CHG: 05/21/75 iSearch String:: MIAMI BEACH, FL 33154 .................................................... ANN REP : ;i996j BN 04/04/96 ;1997) BN 03/03/97 (1998; BY 02/23/96 (icmepaae ,I Off` -ere ---- T14:9 IS NOT OFFIC:AL RECORD; SEE DOCUM=NHS IF QUEST:ON OR CONFLICT — http://ccfcorp.dos. state.fl. us/c&i-bin/corpweb. exe9radC orSearch=CORICHR&vlenu=COR&txtSearch String=143 561 1/20:99 O� CJ� NOV 11 '98 05:17PM AUDIOCOMM CORPORATE REtOLUTIGN P.2 I i In accordance with Florida Statutes Section 607.0704, the undersit*lbed, being the owners and holders of more than fifty-one percent (51 %) of the iF'ed and outstanding shares -of capital stock of Erie Corporation, a Florida corpc1rti,tion (the "Company"), hereby adopt the following corporate resolutions in lieu of hoiclor a formal meeting of the shareholders of the Company: ' }i RESOLVED, that Michael Meyers or Lee Schwartz, may eontin*00 to represent the Company before the Special Exception Hearing Boardl•:nf the City of Miami in connection with the pending Special Exception Hearing for that certain real property commonly known as 151 N.E. i; irst Street, and in any proceedings ancillary thereto. FURTHER RESOLVED, that this Resolution shall remain in full foice and effect and may be relied upon by the City of Miami until such time as the City of Miami may receive notice from the Company that, this Resolution has been rescinded. IN WITNESS WHEREOF, the undersigned shareholders have duly e�$puted this Corporate Resolution as of the 80' day of November, 1998. Sh eholders: ) 7 PW Name: �e of 4%a C./N Print Name Print Name: Print Name i Print Name H:1uB%D0C51050150011CRN ua091.wpD 1 , It. - "NOV' 11 ' 98 * • 05: ! 7PM -AUDI OCOMM CORPORATE RESOLUTION P. 3 f In accordance with Florida Statutes Section 607,0704, the undersigned, being , the owners and holders of more than fifty-one percent (51 %) of the .issued and outstanding shares of capital stock of Erie Corporation, a Florida ,corppl a-.tlon (the "Company'), hereby adopt the following corporate resolutions in lieu of holder a forma( meeting of the shareholders of the 'Company: RESOLVED, that Michael Mayers or Lee Schwartz, may continue to represent the Company before the Special Exception Hearing Board of the City of Miami in connection with the pending Special Exception Hearing for that certain real property commonly -known as 151 N.E.-First Street, and in any proceedings ancillary thereto. FURTHER RESOLVER, that this Resolution shall remain in full force and effect and may be relied upon by the City of Miami until such time as the City of Miami may receive notice from the Company that,this Resolution has been rescinded. iN WITNESS WHEREOF, the undersigned shareholders have duly executed this Corporate Resolution as of the 8'h day of November, 1998, Shareh ers: Print Name: Print Name Print Name: Print Name Print Name H:1LIB160C;105o160otICRP19u809�.wPo S 9 0 "y,r NOV 11 '98 05:17PM AUDIOCOMM P.4 CORPORATE I1168OLUTION In 110=e161`100 with Florida Stetutes Slogan $07.0704, the underaigned, being the ownwo and holders of mom then fifty-one patent (51 %) of the lssuW end outstanding shams of capital stock of Eris Corporation, a Florida, ccrpora�tion (the v ompany' 1, hereby adopttho following corporate resolutions in lieu of holder a formal meeting of the shareholders of the Company: i SOLVED, that Michael Mayer; or Lac Schwartz, may continue to noresornt the Company befofs the Special rowsiRtion HWIng Board of the City of Miami in connection with the pending SpsclAl Excepddh Hearino for that certain reel property cornmonly known as 151 Nx. Fiat SUM, and in any proceedings ancillary thereto. t:trMIER RESQLVW, thatthle Raselution shall ramaln in full force and affect and may be relied upon by the City of Miami until such thus as the Chy of Miami may reoolvo notice from ft Company that this Resolution has been reaolnded. r 1N W1TNE.SS WHEREOF, the undersigned shareholders have duly axe"' sd this Corporate Resolution as of tho P day of November, 1998. Print Narne Print Name. Print Name Print Name M;1Lii5D9CG1Q601i0D� tGAltiiYd00LtIRp {j, FC 017 SYSTEMS. IMC. - SOUTHEAST 6954 N.W. 12 STREET, MIAMI, FLORIDA 33126 305-477-9149 - 800-287-4799 - FAX 305-477-7526 condition ,, WARRAMrr Do = ." eaw•.M•- — V ► old 6 R it ►wa aawtar ar ►a..... tM�•.e. 1L�i5 +actdcn2ure. &fed. of peceater a. D. 39 4S arrvrcN. -- ELISE T. JDiIN -and�-F•JP.F_y_G- SOBb he- nust:nd - - xau at "i wf U.e f,itiety of :114 ...i !,� "��d stele of Xi:eJn� n of the revu Peru Ana FPTr c.1=P0B(•TTl71i - a terperetion ..i.,:np nwd•r it., t.%•. Of tl.t Of— rlorl G= � h..:we :10 rrrnt:p.l dace +( 6...A..r;n dv f."ttay wf. _ IL•ad State eC Fiari%.i s. 4 la -full, atttherie..l to tran.aet hda:nn.c in the Stnto of Florida- Patty er the wceend rant WrrNI %iTn: Thai tiro wid port. -ILL . or the fins pan, for and in .ww•'utr.wt:ea of L6 auon of un a�- � • j w=!,..•-r to baml paid by tl.e ..id party of 11rc ►!-end Poet, the reae3pt whereof it lweby eekwer- }} 1• dv..I_ _i b •sated, bargained and .eirl to &See au:d party of the aeeettd pe,t.:t....eaaar.. awd t e • ! rimy kft�cr. lire folte..:n: dearriiad Iowa. e:taate, ly:n; end boos in {he Couety of Ea"e ! � ••d Sum of Florida. wait; ` Lots g,vl:utQen (.L?) tinc Ei;ttt.at: (itl) Of ' =lock One*hunarec Four (1J4) NORTH, DF iiiF. : 'CI;:' OF 4ILMI, Ln ee County, Fiarlra, Lcearv- $ Ing to trap Plur. ts.rtreor racurteo In P-it ? % �oo:c •E" s; [ ,..ge 41, :0. re.. ?ul-.it: ! •-e ,P�- 91095 Sl- i•;ale 4u..nt%,i.nrita; '.JGcikLt: +itrt t,:- tuileL•ti;_ �.ri itt;tr ►v;at rrts 1JCL tcd t,.treort, tt:t slid ,.re.:iaes being iaprovee .itn a ro_el bui.LQin= nak PnJ-a L!s Ct.t •F19H$_h fdJT_%Lo, JocLted .0 147-4;-i+i- Y NortueLst rtr.t Street, ml:. , Fiorica. Tnia deed is executed subject to reatrtetl.)rts :nd :.i=it::ion:: of recoro; "jilrg orcimtices �,9i09ta'r { t ' of the City or ui►o1,Florir:t; Lad ":uts :or �e tue year 1i►45 &nd subserpent yehrs. - w :.._ �• And um «:d par`,Eso( the firer p.rt aa,��.. 6"; (aUj :PvrirmY the dtk to .aid l.ai, end will d+erad j Blot darn ruiner dr leerr■l dliau of aA patwae w) tows oc or. IN �ll7dESS t7iiYREOF. IL...td ►ea+ --it the tint part h—ve tnee•.ete «• trtoir raawd%, wool r"Li the day dad year alw.• vritus .. S:�.d, aeakd ud deri.e.ed is pttsaeet of at: it t -_.-.... —I ;A...:. A t: srATE Or tluaaul[aoC !%+l 1 IIr.RIbY tS7ITTIY. TVs w- •k:. d•f t►et+•-nllr wf-..d Fet... «...w •rt:... d.lf wtkrf.af 1. .d..lslwe .� ...►. wl s•i- 1.i.-+f•dPoo-" • Te•R 7 TIWA !.Pro kr t.Cv r :,ylr ••.. .. 1 • . : . ....... . V. t- ..- .At 16— t. 1•- the pw-, _ t d.•wl►ed Is mod -6 R-Mnl lM rot-e•We of fj..•d twaw•.I-dt-•t I..t... v s'r. .. t.;t! . ,•.-..--..euwad G• use frw* OW •el+.e.•llf I" t►• I-sp. 01--44 -1p.+-1. ' .'•: AKIs I RYtTgO1 CUITIF1f.'Tim w�-.w J7`'!1 h...,..e «. ! AI' .. M sk- rlf• .f sk..ei.L� ,yr.�kt ^. .f]!'.i r ... +.•w•ts •.d 7rw.+. ;� •..•+:...:. t.4.- -A .%..k try •ed t.d.t• me..w.nttlr rd wwt 1t lw sold Mnb.-.t. /dl .-1-+•a.rl.- dw .6 wJ. .. J_� 1...r.1f • $.My ...«.. d dA top Oe pan"".t r.e..s.l"i telM.tii.M.s •ed r...y.wt .11 16- .itkt. list. +-•1 I+....t '/7� k_-- " . • - •r nrw..+t. �..�..�1. 4:11a w .q.it.l.t., w •-J s- .►• W. d.w:1..) slww�•►..•1 .I.w .-Ir" .•4 ..hAwt w....q.. s :..., ..w....l....Mr.Mr..w r I-N srT V%* -•. h.,d .-d .tr f.l rai •• Y1 .� Gw•Nf .f -.l V.s../ C:RMr•evr .• I -.. �. t . ny f. y I'R .L7 �� �=` r A. •t7�,.a__ V, f SMAKHY f%KTIrY. T►...- .1a. do? •.w-•.ifl wP••rnt la n wt. .. .rf...r f.if nskwiM .. .q.:.s. ,. V wa ..A .N. «i...t.Ia.t..•� i►� t- ... r-tl 1...w N he ike serowL r- •t-teriMd w ewd .iw t•.e•s!d the t.r.e•.-e •1.•A. •nl err.-.I.de-d ►rf... -.. +t sk•t .. r ..-•..1wus-I Oh- -...- 1s..11 ud alw.tw ilY f-t 0- n-tt-•••.S.M..ar•.w-ed. V . O IT�F�� .. f 1..-.1 ..d-ii.:af «.! -t-..r..�.� .. r:---.. •tom.... ..... �... tno 1• I � _ i L' ! � w_ •L� f 1 s.r! I r LOOP Li14, 1 i ; rf L :v rL :vJ It F 9- 13 0S C i 4 P -... . _....�- .. .'. _,�-_... t r wwArtAAir" cc= A M.s'.•w-.• seem R. t ad Pam YmpiY Pm.,"—* cdw" . N. (94b 3ttarnuwr. st-d. th • a, at Gece�Oer A, D. If 44 s6T vL-v— VISE t. J3EIB -and F. y G. JOH.4, her husband .r a- Cw-w of :It t:�'�,•R� -.�t State 0 wi.eon.^in rort1U=Af OW fw.t perti, s-d.��7C TF .942papt?Tnt; - a-rtrrn,ie" t -.i.ti,.e «w•i-r A— low. wf the S..,w of FaOT10i � Iwwx it r,iwcipkl plow .f 1....«.o.. ;- tow f~4! ft. Daa Md Sate or rlorit.L a-d Isufelle oiubarisrd r tronrct b-.;eras in the Suh dfM+idw puy of lhr.eeead raec w IT'/NOLM fi: 7h:1 the said ratt1 4 . of The first tart, W and ;- n.w.i.forathra of the era of ,� I4n .C:l�j.?.d) _L•s11Lrs daa �thcr. v_i.tw.t+st cjrtaictrrtti fir, to hsa•1 paid hw she rid party of the ,wand park the roeelpi ,•Aereef ie f.ancby settee— •� 1.•ta..l- -i:;L !—s-teef. h.,t;.;-ed noel .eta ee tl.a MOW pony of the rawest pen. ate-.seea.e.a .wd alai -.:ar foeeett. Use fatlo�;s� dorv4bei fasl e;t-me. J&,T and icing in the Gee-ty -t CACt c . 4'h -d Seta of Florid.. awrite t_ i Lots S,veutoen (17) and Ei;atertrai A ' Block One'humarec Four (1JS) NORTH, 3F THE , �-A, 44-� CITY gF SILMI, L ce County, Faorica, sce�ro .r- Lag ca um Plbt ttreor rarurdon in Y-tat book -Ea L t r�ei"• Sl a , :o: cr v ?uL-Sc ,F • card: ►f'•91O9S Si !'Je Lu6nty, i-�riuu; XVIia. Alta t.:a L; Akan.= W-4 tm;+r7vaafnta -- loe:ted ee.ereoa. 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