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HomeMy WebLinkAboutR-99-0726J-99-837 9/28/99 RESOLUTION NO.o o 1 A RESOLUTION OF THE MIAMI CITY COMMISSION AUTHORIZING AND DIRECTING THE CITY MANAGER TO TAKE ALL ACTION NECESSARY TO INITIATE AND ASSIST IN THE IMMEDIATE RELOCATION OF THE RESIDENTS OF THE PROPERTIES LOCATED AT 1501 NORTHWEST 59'" STREET, 1270 NORTHWEST 60"" STREET, AND 1320, 1321, AND 1370 NORTHWEST 61S STREET, MIAMI, FLORIDA, SAID AUTHORIZATION AND DIRECTION CONTINGENT UPON THE FINDINGS OF THE CITY ATTORNEY AND THE CITY MANAGER THAT MIAMI LTD. II IS IN DEFAULT OF ITS CONTRACT; AUTHORIZING THE CITY MANAGER TO EXECUTE ANY DOCUMENT(S) NECESSARY, IN A FORM ACCEPTABLE TO THE CITY ATTORNEY, FOR SAID PURPOSE; AND FURTHER DIRECTING THE CITY MANAGER TO IMMEDIATELY NOTIFY THE CITY COMMISSION OF ACTIONS TAKEN AND TO PRESENT THE CITY COMMISSION WITH A RELOCATION PLAN. BE IT RESOLVED BY THE COMMISSION OF THE CITY OF MIAMI, FLORIDA: Section 1. The City Manager is hereby authorized and directed to take all action necessary to initiate and assist in the immediate relocation of the residents of the properties located at 1501 Northwest 59`h Street, 1270 Northwest 60th Street, and 1320, 1321, and 1370 Northwest 61"t Street, Miami, Florida, said authorization and direction contingent upon the findings of the City Attorney and the City Manager that Miami Ltd. II is in CITY COMI USSION MEETING OF ? Resolution No. R a default of its contract. Section 2. The City Manager is hereby authorized!' to execute any document(s), in a form acceptable to the City Attorney, for said purpose. Section 3. The City Manager is hereby further directed to immediately notify the City Commission of actions taken and to present the City Commission with a relocation plan. Section 4. This Resolution shall become effective immediately upon its adoption and signature of the Mayor.' PASSED AND ADOPTED this 28th day of September 1999. JOE CAROLLO, MAYOR In accordance with Miami Code Sea 2-36, since the Mayor did not indicate approval of 'his legislation by sinning it in the said I^vi 'Ct^.n .. :•� Lacomes effective %V11h the O! 7sc of t; C "' l t! ' t CCrnrCi55:G urn regarding same, without the [0ayorjr,<erci4ng ATTEST: � WetCiTi�La3li! WALTER J . FOEMAN , C I TY ,,5L,ERK APPROV A S TOJ ORM'AND CO RECTNESS :t/ },. Jw ! i bbAr .e�` A—TiPJANDRO VILARELLO TTORNEY W,11 : BSS 1 The herein authorization is further subject to compliance with all requirements that may be imposed by the City Attorney, including but not 1 limited to those prescribed by applicable City Charter and Code i t provisions. i 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. f If the Mayor vetoes this Resolution, it shall become effective immediately upon override of the veto by the City Commission. i 2 f - S CITY OF MIAMI, FLORIDA INTER -OFFICE MEMORANDUM S2 'o ! Honorable Mayor and DATE September 22. 1999 FILE Member �f the City Commission SUBJECT: Discussion Item ' FROM: REFERENCES: l na City Commission Meeting City Manager ENCLOSURES. September 28. 1999 ` Please place an item on the agenda of the September 28'h City Commission MCC tino regarding the status of Section S Housing unit inspections for the properties located at 1320, 1321 and 1370 N.W. 61s' Street. DB/GC W 9 9 - 721 R CITY OF MIAMI, FLORIDA INTER -OFFICE MEMORANDUM S2 O Honorable Nlavor and DAZE September 72. 1999 FILE Member f the City Commission 's SUBJECT: Discussion Item FROM: — - na �i � r-----�-" REFERENCES City Commission Meeting City Manager ENCLOSURES: September 28. 1999 Please place an item on the agenda of the September 28`h City Commission Meeting regarding the status of Section 8 Housing unit inspections for the properties located at Donald Warshaw September 27, 1999 City Manager Relocation Plan Miami Ltd. Arthur E. Teele, Jr. i Commissioner i I ; i am following up on a concern for the citizens of District 5. It was my understanding from the September 21, 1999 Commission Meeting that the City Manager's office would provide for the September 28, 1999 City Commission Meeting a Comprehensive Relocation Plan for the residents of 1320, 1321 and 1370 Northwest 61 1 Street, as stated in on the record pertaining to the future of these residents. The item is not on the agenda; however, I plan to bring the matter up at 11:00am. Regards. s r � I cc: Alejandro Vilarello, City Attorney J Walter Foeman, City Clerk { i 99" r�c� i CITY OF MIAMI, FLORIDA INTER -OFFICE MEMORANDUM TO: Donald Warshaw DATE : September 27, 1999 FILE: City Manager SUBJECT: Relocation Plan Miami Ltd. FROM: Arthur E. Teele, Jr. REFERENCES: j Commissioner EN_ I am following up on a concern for the citizens of District 5 It was my understanding from the September 21, 1999 Commission Meeting that the City Manager's office would provide for the September 28, 1999 City Commission Meeting a Comprehensive Relocation Plan for the residents of 1320, 1321, 1370, 1501 and 1270 Northwest 61 Street, as stated in on the record pertaining to the future of these residents. The item is not on the agenda; however, I plan to bring the matter up at 11:00am Regards. ��. A1-:_I:1 Model City �. Employment, Inc. MiL keUng Cctngt ltiutts i lrtntc _ Evangelist Lee B Vanety Model Gty Ghzen Participation (Chairman) Tony Brown Prod I'Aami/Dade Community Outreach Committee (Chairman) (Y2k Coordinator) 'Helping Indigent Citizens' 13850 N,W. 26th Ave. • Opa locka, Florida 33054 Office (305) 687-2325. 6pt (305) 842-9927, Fax: (305) 238-3975 t MODEL w 77ZEMN R 17CIPAWN COJIJMEE O�r..1ac9E. �i O Fv+w� "L " & 1INQV, c � A&P# a~ lour C""�`"�`"IV Cerr"*#v tom► "Um RE; p+DL ICAL CORRUPTION M IAA ZMi)[)STRIAL PAS C L TY CIW .. bI=L Cm FL. CASE ... 99-2280 filed August 17, 1999 AT?: RI 9C3K=S, FEDERAL PROSEONM PATREAU or Mm"ICATION Dear Mr. Scruggs, I an wrijing this letter to you as a duty bound community activillt. My Name a l v"Velist Lee Variety, and Y as the Sel.acted Chairman of the m avmi Dade community outreach committee. I THS pla"URS OF GREETING YOU AT THE FED CAL COURT Housz, YOU SAT TN THE ]LOBBY AAVIWG A tM&T WITH My f,`RMT ARID UV FRIEW AND ATMRNEY, Milt. FRANR RUSIVO, ESQ. P.A. This place during the BaBa Siseako Trial, when I w alk*d up tot Fri . I ITING THZS P CQUIPLILINT ID =F==C3 TO THE POINC jNDUGTRIAL PARR, IN L12=TY CITY FLC IDA. ZL ZaAL MWBACTIONS TRANSPIRING RMWURN THE DADS Cp ' y Q %CIAI a Arm zip DRXVA= 3rr� �``�.if . ���: i�F7lii'Z�tJAZ.B ARE ATT ING Lo EM=18TR]CT A P WECT WET Ea&hO U ' +A. IN TEE P T d i IAI DAD2 COUNTY, ARD UUNI CWMMY DEVELOPUMT CUIiP, WS B$V�3 LT F3 =Ip"111,10M.PL IO i TO PROV J VZOLATIONS OF OVIMPA TO CLXMTS, USING FWMAL TAX IOLUMS. You will Oe provided with the proof of theoe atatementa, At your office in, Miemi, Florida. WE 4 OUM ALSO LIEF TO X2ZT NITS You O+ wic co rzss orlrlcs of ZC0110KIC I NVEWPHENT, DJWZ COUMM mnn.GT=. L C(TY CIMEN PAR 77CIPA TIM COANIM Lar a i'lifllQy !.ltwie WftW Opa-�ayia Bro+.a�tt Ca�rw+rrt�td'(y OMB Caia�r Cont. page 2 AWow (M W 40$ l Pat*" t'M 842-pr2T Cot,"; ,al. AND TEE qmMUNITY ACTION AGMCY. This sting will also provift us with brief went to discuss updates and Solutions for our RUIDZNTSSI in reference to Y 2 K . I Please Co tact us for an Appointment at your "rliest Convenience. II l 1 Sincerely, C cc. � �18'T L. B. dARISTY n FEDERAL A NT GREGORY PLEASE CALL..'.. FRANK RUB O, ATTORNEY (305) 842 9927, U. S. CON ESS MODEL CITY CITIZEN PARTICIPATION ORRIN HAT U.S. U.S. SENATOR MIAMI QADE�COMMUNITY OUTREACH COMMITTEE t l , I � � t _ i 1 } i ' 99- 726 6qe Rfleml ffitme9 aa..ni.a. aic eeo zrc Thursday, August 191999 bU51nt5 Feds to provide $6.75 million fc Poinciana and Cuyahoga parks By AUSTIN MILLER tine will primarily focus on two long time. it's not. going to be Times Staff Writer economically deprived communi- high tech jobs which outsiders tie. of Ponciana Park in Liberty may come in and take advantage The U,S. Housing and Urban racy and Cuyahoga Park in Opa - of," 3evelopmctii Agency has locka. Since the two parks have been :nnounccd it A111 .give 56.75 mil- Officials from the congress- contarninated—from hay.ng on to help create jol)s in the woman's office estimate that 200 gasoline stations, dry cleaning )tally depressed neighborhoods new jobs will be created stem- stores and abandon factories— urrounding Poinciana ming from this revitalization pro- Miami -Jude County will be ndustrial and Cuyahoga Parks ject, responsible for redeveloping the ^spectively. "Other areas in the county are sites. J.S. Congresswoman Carrie availabie for these funds but "The main thing the congress- 'eek initially proposed the, tnir: these two communities were tar- woman wants to do is to make e and USHUD Secrktary, 'that geted because of the high unem- sure that busbiesses co}-rie to and ::drew Cuomo agreed it . slayment," said Rich Glasgow. revitalize the az,ea.to a point that as a worthwhile project. Economic Development Team the coiiimunity 'would see `e has pledged $1.75 in grants coordinator from improvcrnenX ` ''in their id an additional 65 million in Congresswoman,bli�ertt's Offlce. Glasgow said. ' "And with this an guarantees to help clean up "The ' jobs coming lhip'. those kind of incentive, we hope that .. rntaminated sites in and .areas are joba we believe wij! 1?uslnesses i6lt want to come set ound Dade County. Th ,iriiti rem4,n #ri .t ie �ggpj munity ford up shop.. 1 S 1 1 1 1 99- 'i4b BCD" "1" P. MST Y.IamarY finis or, UNIT= •?A'Y' $ UIGMICT C70t! 'pSOUTRA" VISTAIX2 Or TIA)"M I CONTEM mcw vivistim ; 99 m 2 ThyT CA"8 0 !iLr. ■r/6�.riC�w� p10GdCL CITY X9CbiWT CITZKA4I NMA218 JVDM ( CLASS ACTION LAWSUIT) PIAINTIrT MAGISTRATE XWE Vs . IDUBE Ammim D C�OItBir1► HT AND Jed; DAD.. CITY OF M AMI GOVERN14ENT ET. AL. MIAMI-W. ++ggr Vast wv m um m" mw ids. . -^ a ° am mmum an Y Or/sLopowT CERTZR i aaa�s f �esa��Px. L� �L7tM11XTT-Lot air � v p a WR �. 13850 nw 26th ave. (109) 687 Z325 1 DZSPNR (34S) 842 0927 99- 726 CASE NO 99--2280f Thi.* is an action to redress the deprivation, under the color of tate Law, of Priviledges, Rights or lmmunities Secured to the Pi intiffs by the 14th Amendment of the Conatitution of the Un ted States and the 42 U.S.C. as 1961 and 1983, and to redres Violations of State Law, Including $REACH OF CONTRACT �[ AND TI US IWrLr"ERiNCE WITH CONTRACT. Jurisdiction is Conforredlon this Court by Title 28 U.S.C. as 1331 and 1343, snd this lourt 9 Pendent Jurisdiction to Entertain Plaintiffs Florida State Based Claim. JURISDICTION AND VIME 1. The Jurisdiction of this Court is Invoked pursuant to 28 U.S.1C. as 1331 and 1343, and the Courts Per -dent Jurisdiction to Entertain Plaintiffs State Based Claims. 2. venue is proper in this Court pursuant to 28 U.S.C. so 1391, 0ecause the Defendants are subject to Personal Jurisdiction in this District and because all or a substantial portion of,, the events which give rise to this claim fcr Relies" arose in tjhis District. THE PARTIES 3. PLAINTirr SCOTT PROJg9CTS COMMUNITY OUTRBACA COMIT'i°EE, WITH STANDING IS AND AT ALL MATERIAL TINE$ WAS A INDIGmr TAXPAYERS CITIZENS ROWIDBNTIAL COKKITTEB BSSIDIM IN THE STATE OF FLORIDA WITH THEIR! PRINCIPAL PLACE OF STANDING LOCATED AT JAMES S. SCO T Bohn FROJOCTS, IN LIBERTY CITY, FLORYDA. ®. LIBERTY CITY - XWEL CITY INDIGENT CITIZEaqS IS A LOCAL, CIVIf, RIGHTS ACTIVIST COMMITTEE, CONSISTING OF TUB MIAMI LIKITED RZOIDPINTS ASSOCIATION ALONG WITH OTRER CONCERNI 1 PARENTS IN TSB IM14 ZA` Z WDEL CITY AREA, &SEEING EQUAL JUSTICE. TOE PRINCIPAL M=Tlnr- PLACE AT THIS TIME 19 LOCATED AT 3170 n.w. 61 tst Street in LIBERTY CITY, FLORTDA. PI.A14TIFFS ARE FILING A JOINT CLASS ACTION LAWSUIT AND ITS AUTHORXZED REPRESENTATIVE IS L-VANGSLIST LUZ VARI , A NATIONAL CQNSULTAEff AND =414UNITY ACTIVIST, AND AS A CONS301MCE T�l,8 WF, W A SRNIFICYA2Y TO THE CONTRACT IN DETAIL. TLUS I.&WSU T is ALSO BEING IrILtED TO BOUND THE AYJLRN TO THE RIDS CRISr S IN ]MH ARRAS - i 1 f i 99 120 L- 3 1 99-2280 5. Defendant Metropoiltan dad* County (MDC or the County) is and at all material times .I&s a County Yuzeuarlt to Artiste 8, Seotlall 1 of the Constitution of the State of Florida. 60 Defendant City of Miami 1e ana at all material times was a C t.y pursuant to they laws of the Constitution of the State a Florida. 7. Defendant U.S. HUD, ANDREW CUOMO et. al. is a Co -Defendant of MIAMI-DA,DE COUNTY (AM). References to MOC and U.S. HUD are intended, being the Federal Wunder. 8. U.S. HUD is a Federal provider of Taxpayers monies and is bblieved to be registered in Washington D.C. and doing business in the U,B.A. -PIS LAg$UYT IS DOCUMENTATION, TOTING THAT U.S. HUD WILL BN HBLD �P fij: - NOW, AM IN THE tUTURN, BY THN LOCA PEOPLE OF DADS COUNTY A T8E NATION. U.S. HUD SUMLD ALSO HB HELD LEGAULY RB6WM8Ii$1[ BY THE U.S. CONGRZ&S FOR ILLISGALLY APPROVING NZAMI D"S C $TZZS GRIT "PLXCATI.ON WITHOUT THN AUTHENTIC C ONSMT or TRZ SCU= HONNS RNSIDENTS, OR PROP= SIGKA7VRRB. 'r=f $BOi34D FC1%d? E, BB HELD L3 GALLY BINDrW FOR SPREADING THE AIDS VIRUS T ROUGWUT MIAMI S VACATION PARADISH AND SUBMMN C ONKUNITISS . T al HAS I BED ,SPED IC NUM88iW i7a AIDE RM&M L?i:ATN$ IN TXX8 MR. DErMDlb,NT DADS COUNTY HUD IS AND AT ALL KATBRIAL i TIPM WAS TH$ HOUSING AND URBAN DBVZLOPNMM P'OR THE DZPMANT MIAMI DADA COUNTY. 10. DEFENDANT CITY OF MIk14I GOVERNMENT IS AND AT ALL 1SA"ati" WAS A REPRBSEMATIVR OF KIAKI VA08 COUNTY F'Ef WtAL FUG IN WERENCE TO VARIOUS ASSOCIATED A29AS . 11 . DEPEd'7I3ANT U.S. GM4ATOR BOB GRAHAM TO THE U.S. CONGRESSIONAL S,tli:PREGENTATIVE AND IS AT L"LL t T=I:A.L, `PINNS RES'PONSIBLO TO TfM U.S. CQVG 8 POR THE HIANT OAD$ COUNTY MEA . 12. �, :.DEVENDA.NT U.S. CONG=BSWO�M C!"RXE P. KM IS Tog U.S. coNG ESSIONAL RZPRESEMITATIVS FOR THESE A tIC" BLACK8 JWD T99 POOP, AMD IF AT ALL 01ATERIAL TIMES RZSPOWSIBLE TO THIS U.S. COMMSPS !'OR TflZ MIANI DADS COUNTY ARM%. (2) 9 9 - "14 0 CASE NO. 99-2200 1 DEFENDANT NEW CENTURY COMMUNITY DSVELOPKBNT CEWMR IF REIN SUED IN THIS LAWSUIT, AND IS BEING MELD DUTY BOUND TO THEI WRITTEN OBLIGATION TO THE COMMUNITY THEY SFRVX AS A FEDERAL FUNDED RECIPIENT. NCDC IS ALSO S'SING PETITIONED BY THE t UNI , ASKING THE FEDERAL COURT AND THE U.S. CONGRESS TO REVIEW IMEIR RECORDS BASED ON PERFORMANCE, AND TO HOLD NCDC RSS,PONS SLE FOR THEIR. ROLE IN CREATING THIS NAJ'OR CRISIS, AND EPEDIM10 COMMUN17Y CONFLICT ALONG WITH MIApI DADE COUNTY. j 14'. DEFENDANT GREATER MIAMI URBAN LEAGUE IS BEING SUED IN IS LAWSUIT, AND IS BRING HELD DUTY BOUND TO THE WRITTEN OBLIGATI N TO THE C JNITY THEY SERVE AS A FEDERAL FUNDED RECIPIEN GREATER MIAMI URBAN LEAGUE IS ALSO BRING PETITIONED BY THE C UNITY, ASKING THE FEDERAL COURT AND THE U.S. CONGRESS TO REVIE THEIR RECORDS BASED ON PERFORMANCE, AND TO HOLD GRUL RESP"WSI LE FOR THEIR ROLE IN CREATING THIS MAJOR CRISIS, AND SPEDIMIC COMMUNITY CONFLICT ALONG WITH MIAMI DADE COUNTY, AND THE CITY or kYAMI. i AMERIC'AN CITIZENS RIQUEST I t THE LIRE Y CiTY RESIDENTS THAT INCLUDES SCOTT HOBOES PROJiMS, ARE REQU ING TO THE U.S. COURTS TO UPHOLD THEIR CONSTITUTIONAL RIGHTS BE PROVIDED FEDERALLY FUNDED LEGAL AID ATTORNEYS, AS YNDrG UNITED STATES CITIZENS. t � j BACKGROUND 15. On or about July 7th, 1997 and dating back to July 7th, 1987 hereby the ten year Poinciana Industrial Park Resolutionlwas Breached, under the Objectives of Chapter 10A of the CodO of Metropolitan Miami Dade County, Florida. 16. The Purpose for this undertaking tend program was for the cl arance and reconstruction of Slum and Blighted Areas in Community Development Area No. 5 Model City, Dade County, Florida an wct5 intended and engaged in carrying out a Redeveloptn nt Program as Approved by Resolution No. R-397-85, and Resolu ion No. R-1169-84. New Century Community Development Program is !and at all material times was working under the Approved Guidelines for Defendant Metro Miami Dade County. 17. NCDC was Approved by Miami Dade County ae the Master Developer cf the Poincianas Industrial Center. Located in the Area bounded by nw 79th at. on the north, nw 27th ayea7Ue 0fl the west, eq3d by the Florida -past Coast Railroad on the SOUth a�no by nw Z nd av6. on the east. i t (3) 39- fGs CASE NO. 99-2280 18. NCDC was supposed to Redevelop or cause the Re- developm nt of the Property, for the purpose of providing ,lobs for the 7ameS E. Scott Homes Project RESIDENTS and the surrounding Community. This was to be done, in accordance with the uses Specified in the Poinciana Industrial Center Master Plan. 19. Miami Dade County AGREED that the AGEEMENT and the FULMLMENT of the AGEEMENT, ARE IN THE BEST INTEREST OF THE SCOTT HOMtS PROJECT RESIDE14TS and the SURROUNDING AREAS OF THE COUNTY RE$IDENTS. The County also Agreed, that it was in the LEST INTEREST OF THE HEALTH, SAFETY, MORALS, AND WELFARE OF THE RESID�NTS. 20.1 This Agreement was done with the SPECIFIC GOAL OF CREATING CONOMIC DEVELOPMENT A4D PROVIDING JOSS to the Residence of this E ighted Community who are American Blacks, and the Needy. 21, MIAMI DADE COUNTY AND NEW CENTURY DEVELOPMENT CENTER CONCEALEDIINF'ORMATION IN THE CONTRACT FROM THE SCOTT PROJECT RESIDENTSr AND FURTHERED THE SPREADING OF POVERTY, CRIME, AND THE IMPACT ON THE AIDS VIRUS CRISIS IN THE AREA. 22. MIAMI DADE COUNTY AND NEW CENTURY DEVELOPMENT CENTER COPIED OUT Extreme and outrageous Conduct and Dis-reguard for the INDIGENT CITIZENS Living in The MODEL CITY AREA. This Agreement ponspired to Mis-Represent information in the same manner thait their signatures were used by DADE COUNTY HUD TO ACHIEVE APPROVAL APD FEDERAL FUNDING TO TEAR DOWN THE SCOTT HOMES PROJECTS. MIAMI DADE COUNTY IS GUILTY OF MAKING FALSE OR t1IS-leading STATEMENTS:WITH RECKLESS DISREGUARD FOR POOR PEOPLE. 23. The Poinciana Industrial Park Agreement was signed in accordannce with the Public Purposes and Provisions of... Applicable!Federal, State and Local Laws and Requirements under which the Center has been Undertaken and is being Assigned. 24. THE NCDC CONTRACT READ, THAT THE COMPANY WAS SUPPOSED TO JOINT VENTURE WITH OTHER QUALIFIED County Partners upon approval of MIAMI DADE COUNTY in WRITING. Supposedly, Conveying or Leasing parcels to qualified entities, but instead they used the Federal Funding for their own Personal interest and for MIAMI DADE COUNTY EXCHANGE PROTECTS. ALL OF THE DOCUMENTS TO THIS AG KENT WERE WRITTEN AND APPROVED BY THE OFFICE OF THE COUNTY ATTORNEY, DAUB COUNTY FLORIDA. (4) sq-- %� CASE NO. 99-2280 25. The Contracted Agreement provided that the Model City Area, be early on, assisted following the Riots,..... With ECONOMIC DEVELOPMENT AND JOB CREATION IN THE BLACK COMMUNITY. 25. THE' -SOLE PURPOSE of the model city lane being awarded to the NCDC, WAS TO PROVIDE 800 JOBS TO THE BLACK COMMUNITY and SELF SUFFICIENCY, which would ALLOW the SCOTT HOMES PROJECT BLACK CHILDREN to become ECONOMIC DEVELOPERS ENTERING INTO THE 21st CENTURY. Thus, no longer DEPRIVING THE AMERICAN BLACK COMMUNITY FROM ITS OWN OWNED AND OPERATED ECONOMIC DEVELOPMENT COMMUNITY, BUT NEVER TRANSPIRED. 27. Based on Information and Belief, DEFENDANT MIAMI DADE COUNTY IS RESPONSIBLE FOR CONSPIRING WITH NCDC TO DEPRIVE, NEGLECT, AND TO WITH hold jabs and federal funds, by RE -routing MONIES TO THEIR PROJECTS. The Plaintiffs can Produce clear Documentation TO PROVE ALL ALLEGED CHARGES. This Information will be Submitted to the Court upon the Federal Governments Request. 28. Further, MIAMI DADE COUNTY AND NCDC, willfully Discriminatecscaused Community Neglect, and Breach of Contract. This was done in its efforts to Ruin and Destroy the Model City Area. DEFENDANT MIAMI DADE COUNTY BREACHED THE CONTRACT AGREEMENT BY REFUSING TO FULFILL THE JOBS SPECIFICATION and by NOT MEETING THE DEMAND OR THE COMMUNITIES ERGONOMIC PROMISE. 29. Thus causing the rise of un-educational skills, CRIME, gIQLENCE, AND CONTRIBUTING TO THE STRESS RELATED CAUSES, DUE TO NO INCREASE IN COMMUNITY JOBS. This breach of Community Trust is also ONE OF THE MAIN CONTRIBUTING FACTORS TO TH:1 WELFARE MOTHERS .JOBLESS CHILD BIRTH DATE. 3C. Plaintiffs Rights to enter into or to enforce this Contract Agreement has been Conspired against and has been taken away by Miami Dade County and IMCDC to willfully with hold the communiti.:.s Taxpaying Dollars. Thus, DEPRIVING PLAIN9TIFFS OF THE SAME RIGHTS OF OTHER RACES OF ..U.S. CITIZENS. 31. The actions of the Defendants, set forth in the proceeding STATEMENT OF FACTS, Maliciously, Fraudulently, and Prematurely denie-1 the Community its Legal Rights to Compensation under the Contract without notice or any other Process or safeguards, and Deprived the Community of Jobs and of Property Ownership. STAGGERING THE AMERICAN BLACK COMMUNITIES JOB DEVELOPMENT TRAINING, EDUCATIONAL OPTIONS, AND ECONOMIC GROWTH. (5) 99- rI A4U ti CASE NO. 99-2280 32. MIAMI DADE COUNTY AND NCDC also created CRIME, HEALTH HAZZARDS, AND FOR THE LACK OF SUPPORT, CONTRIBUTED TO THE STRESS RELATED AIDS CRISIS, THAT HAS NOW BECOME A DISASTEROUS CONDITION OF WHICH U.S. HUD WAS FUNDED BY CONGRESS TO CORRECT. SECOND CLAIM FOR RELIEF 33. CITY OF MIAMI GOVERNMENT IS BEING SUED FOR EXTREME AND OUTRAGEOUS CONDUCT AND DIS-REGUARD FOR MIAMI CITIZENS WHO ARE INDIGENT RESIDENTS LIVING IN IMPROPER U.S. HUD HOUSING CREATING HEALTH RAZZARDS TO THE WOMEN AND CHILDREN. ALSO, FOR CONSPIRING TO MIS -represent information with dale county hud. 34. U.S. HUD IS A CO-DEFENDANT IN THIS CASE AND IS THE FUNDING SOURCE FOR MIAMI DADE COUNTY AND FOR THE CITY OF MIAMI, AND HAS WILLINGLY ALLOWED NEGLEGENCE AND ACCEPTED FALSE DOCUMENTATION THAT RELATES TO THIS CASE FROM DEFENDANTS MIAMI DADE COUNTY, AND THE CITY OF MIAMI WITHOUT CONDUCTING A THOROUGH FEDERAL INVESTIGATION. 35. U.S. SENATOR BOB GRAHAM IS A DEFSNDANT IN THIS CASE FOR BEING NEGLEGENT TO THE LIBERTY CITY INDIGENT CITIZENS, AS A U.S. LEGISLATIVE REPRESENTATIVE, PROVING TO BE A DETERRANT FOR A UN -safe PERIOD OF TIME, CONTRIBUTING TO PAIN, SUFFERING, A BLOCKED INDUSTRY, LACK OF JOBS, PROPER HOUSING, AND THE DEVELOPMENT OF HIGHER EDUCATIONAL VALUES. 36. U.S. CONGRESSWOMAN CARRIE P. MEEK IS A .DEFENDANT IN THIS CASE FOR BEING NEGLEGENT TO THE LIBERTY CITY INDIGENT CITIZENS, AS A U.S. LEGISLATIVE REPRESENTATIVE, PROVING TO BE A DETERRANT FOR A UN -safe period of time, contributing to pain, SUFFERING, A BLOCKED INDUSTRY, LACK OF .'DOHS, LACK OF PROPER HOUSING, AND THE DEVELOPMENT OF HIGHER EDUCATIONAL VALUES. 37. GREATER I4IM11 URBAN LEAGUE IS A DEFENDANT IN THIS CASE FOR CONDUCTING THEIR ORGANIZATION AS A MA EAGER FOR SLUM LANDLORDS LIKE MIAMI LIMITED LTD. ALSO, FOR THE URBAN LEAGUES HOUSING DEVELOPMENT TACTICS TO TARE OVER U.S. HUD HOUSING COMMUNITIES, AND THEIR CRIME FIGHTING STRATEGIES, WHICH ONLY BENEFITS GMUL AND THAT HAS CONTRIBUTED TO INCREASED HOMELESSNESS AND SOME TEMPORARY NON -effective crime solutions. THIS OUTRAGEOUS CONDUCT AND DIS-REGUARD FOR AMERICAN BLACK FAMILIES HAS CONTRIBUTED TO FURTHER PAIN AND SUFFERING AND HAS FORCED SOME POOR PEOPLE INTO WORSE HEALTH CONDITIONS. (6) 39- ri4 CASE NO. 99-2280 THIRD CLAIM FOR RELIEF 38. All of these Defendants actions deprived the plaintiffs of property without due process of law and discriminated against the AMERICAN BLACK AND THE POOR COMMUNITY in the Model City area, on the account of race. In Direct Violation of the 14th Amendment, 42 U.S.C. ss 1961 and 1983, and other applicable provisions of FEDERAL, STATE, AND LOCAL LAWS. 39. All defendants have exhibited a malicious and wanton disreguard for plaintiffs Constitutional RIGHTS and in addition to the actual damages they have caused. PLAINTIFFS are entitled to recover PUNITIVE DA14AGES FROM THEM IN AN AMOUNT TO BE DETERMINED BY THE COURT, SUFFICIENT TO DETER THEM AND OTHERS FROM UNDERTAKING SUCH CONDUCT IN THE FUTURE. FOURTH CLAIM FOR RELIEF 40. All defendants have commited harmful neglect and have and interfered with the communities legal rights for which plaintiffs seek both Compensatory and Punitive Damages. RELIEF REQUESTED WHEREFORE, plaintiffs Respectfully Request that this Court enter into Judgement as follows a. Declaring that the actions taken by the Defendants were Unlawful and in violation of the Equal protection Clause of the 14th Amendment and the Due Process Clause to the UNITED STATES CONSTITUTION, 42 U.S.A. ss 1981 and 1983, the FLORIDA STATE CONSTITUTION AND OTHER APPLICABLE FEDERAL, STATE AND LOCAL LAWS. b. Declaring the Defendants breach based on neglegence of Contracted Agreements, and that same was Arbitrary and Capricious and in violation of the Constitution and Laws of the State ofO,,.., ►"r410 Florida and the United States. (7) CASE NO. 99-2280 C. Declaring that the actions taken by Uefecidant Miami Dade County and the other Defendants were an Un-exc.:sable Tortious Interference with the Peoples Economic Growth, which was to Create Jobs and Create Home Ownership Opportunities. d. THE COURT IS ASKED TU AWARD THE PLAINTIFFS COMPENSATORY DAMAGES IN AN AMOUNT TO BE DETERMINED BY THE COURT, BUT NO LESS THAN 2 Billion Dollars. e. THE COURT IS ALSO ASKED TO AWARD THE PLAINTIFFS PUNITIVE DAMES AGAINST DEFENDANTS ir. a amount sufficient . to DETER them and others from undertaking like Unlawful Conduct I n the Future. f. THE COURT IS ASKED TO AWARD REASONABLE Attorney fees incurred by theca in curuiection wit:c this action, as well as Interest, cost and disbursements of this action, g, THE COURT IS ASKED TO GRANT SUCH OTHER AND FURTHER RELIEF to plaintiffs as may be just, equitable and proper. JURY DEMAND PLAINTIFFS SCOTT PROJECTS COMMUNITY OUTREACH COMMITTEE, WITH STANDING, AND THE LIBERTY CITY -model city indigent citizens, with standing, humbly demand a trial by jury for and by our peers, for all issues Triable as of Right in this Action. RESPECTFULLY SUBMITTED L'VANME IS T LEE B. VARI Y CONI. 1TY OUTREACH, CHAIR 13850 nw 26th avenue OPA LOCKA, FLORIDA 33054 (305)- 687-2325 Beeper- 842-9927 (8� AUTHORIZED REPRESENTIVE. IL CASE NO. 99-2280 VSRIFICATION OF COMPLAINT STATE OF FLORIDA ) ) so; COUNTY OF DADE } I, LEE VARIETY, being duly sworn, deposes and nays as follows. 1. I have read the foregoing Verified Complaint and.know the contents thereof to be true, except as to the matters therein stated to be on information and belief, and, as to those matters, I have reason to believe that they are true. FURTHZR AFFIANT SAYETN NAUGHT. .., I ` EVANGELIST L= S. V IETY CONKUNITY OUTRZAIR SEF'ORL ME..the undersigned, duly authorized to take acknowledgements in the State and County aforesaid, personally appeared LEE VARIETY, known to me to be the persan designated in the foregoing Sworn Statement and he acknowledged before me that he executed the same froaly and voluntarily the purposes described therein. WITNESS, MY SAD AND tiff icial Seal. this � day of�1999 in the County and State first above written, . NOTARY PUBLIC SEAL OF OVFICE F - oyp SEATRIZ PEREI Enekon A 0 B�ZGQ2 CITY OF MIAMI, FLORIDA INFER -OFFICE MEMORANDUM TO: The Honorable Mayor and Members of DATE SEP Z 8 1999 FILE: the City Commission SUBJECT Status ol'Miami Limited II Section 8 Housing Project i FROM Donald II. arSll'IN1' REFERENCES f City Manager ENCLOSURES: i RECOMMENDATION: This memorandum serves to provide a status report regarding the City's efforts to address the substandard housing conditions and the quality of life issues that impact the one hundred and nine (109) families that currently reside in the Section 8 multifamily apartment buildings under contract with Miami Limited 1I. Current Status of Housing; Quality Standards Inspections As you may be aware. during the week of June 29-July 1, 1999, compliance inspections were conducted by the I-Iousing Unit ofthe Department of Community Development at the five (5) Section 8 housing projects located in the Model City neighborhood. The results of the inspections are listed below: Cumulative HQS Inspections Results from All Buildings Passed Failed Vacant Units Out of No. of Units Inspections Inspections Units HAP Contract 140 1 108 28 3 The property owner was given thirty (30) days to correct all violations which were cited by the City. During the week of August 2-5, 1999, follow-up compliance inspections were conducted by the Housing Inspection Unit of the five (5) Section 8 Housing Projects, and the results of the inspections are listed below: Passed Failed Vacant Units Out of No. of Units Inspections Inspections Units HAP Contract 140 7 102 28 3 On August 20, 1999, the property owner was notified in writing that the City planned to conduct additional follow-up inspection on Monday, September 20, 1999. In addition to notifying the property I CITY OF MIAMI, FLORIDA INTER -OFFICE MEMORANDUM TO, The Honorable Mayor and Members of I,gTI_ SEP 2 8 1999 FILE } the City C01111111SS1011 SUBJECT Status of Miami Limited II Section 8 Housing Project FROM Do41.lIaw REFERENCES City Manager ENCLOSURES RECOMMENDATION_: i This memorandum serves to provide a status report regarding the City's efforts to address the substandard housing conditions and the duality of life issues that impact the one hundred and nine (109) families that currently reside in the Section 8 multifamily apartment buildings under contract with Miami Limited 11. Current Status of Housing Qualih, Standards Inspections As you may be aware. during the week of June 29-July 1, 1999, compliance inspections were conducted by the I lousing Unit of the Department of Community Development at the five (5) Section 8 housing projects located in the Model City neighborhood. The results of the inspections are listed below: f s F Cumulative HQS Inspections Results from All Buildings Passed Failed Vacant Units Out of 1 No. of Units Inspections Inspections Units HAP Contract 140 1 108 28 3 The property owner was given thirty (30) days to correct all violations which were cited by the City. r. During the week of August 2-5, 1999, follow-up compliance inspections were conducted by the Housing Inspection Unit of the five (5) Section 8 Housing Projects, and the results of the inspections are listed below: Passed Failed Vacant Units Out of No. of Units Inspections Inspections Units HAP Contract 140 7 102 28 3 On August 20, 1999, the property owner was notified in writing that the City planned to conduct additional follow-up inspection on Monday, September 20, 1999. In addition to notifying the property "-: L_ owner that the City planned to reinspect all five (5) multifamily apartment buildings.. the property owner was also given a thirty (30) day written notice that the City planned to terminate the HAP contract on any apartments which failed that \\,ere designated in the following categories: • Apartments that have been vacant for over six (6) months or more: • Apartments which were cited for life safety violations during the inspections of'June 29-July I and August 2-5, 1099. On September 20. 1999, f011ovV-up compliance inspections were conducted by the City inspectors on all five (5) multifamily apartment buildings, and the results of the inspections are listed below: Passed Failed Units Out of No. of Units Ins ections Inspections HAP Contract 140 25 112 3 Of the one hundred twelve (112) apartments which failed HQS inspections, twenty-three (23) were vacant units which the property owner failed to rectify the various HQS violations which were cited during the inspections of August 2-5, 1999. Pursuant to the City Commission's directive at its meeting of September 21, 1999, the Department of Community Development has identified and retained the services of the Indigo Service Corporation to perform an independent assessment of the recent HQS inspections completed by City staff. In addition, a request for assistance from Miami -Dade County's Housing Agency to conduct a random sampling of the apartments inspected by the City has been made. Based on our timetable, the follow- up inspections by Indigo Service Corporation and the County will be completed by Friday. October 1, 1999. As you are aware, due to the sensitive nature of the outcome of the inspections and to further substantiate the City's position in a court of law if it is necessary, the outside and independent inspections by the aforementioned entities would further assist in supporting the City's position in the event of any future litigation against the City by the property owner. It is anticipated that a final report on the status of the inspection activities will be completed and submitted to the City Commission on or before October 15, 1999. Establishment of Section 8 Voucher Program/Preparation of Listing of Current and Former Residents As per the City Commission directive at the .July 27, 1999 City Commission meeting, the Department of Community Development has met with the Miami -Dade Housing Agency to secure technical assistance and direction in connection with the establishment of a Section 8 Voucher Program for the current residents of the Miami Limited 11 Section 8 Housing Project. In addition, the Department has identified and established a listing of the current and former residents. Status of Section 8 Resident Relocation Plan As you arc a\\ -are, while the residents have expressed their eagerness to be relocated from the Miami Limited 11 housing coniplcx. the Cite must comply with the restrictions of HUD regulations to insure compliance with the law and at tlhe same time protect the City against any potential liability. Should the City �Viministration, based on the most recent inspections by the City, and the additional inspections which will he carried -out by outside and independent parties, determine that the owner/management o1' the Niliaiiii Limited 11 project is unable to comply with MUD regulations for maintaining tlhe contract, the City is preparing to assist the residents in an orderly relocation into safe and sanitary housing accoihhIII odations in the private housing marketplace. On September 15. 1999. 1 contacted A/Ir. Merrett R. Stierheim, County Manager, to request tlhe assistance of Miami -Dade County in working with the City of Miami to formulate an action plan for the relocation of the residents that currently reside in the Miami Limited 11 Section 8 housing projects. In January 1999. Mianii-Dade County terminated its Section 8 Housing Assistance Payments (HAP) contract with the owner of the Miami Limited f Section 8 Housing Project. Tile contract was terminated due to the high vacancy rate which existed in each of the eight (8) multifamily buildings, serious building code violations, failure to meet HUD's Housing Quality Standards, and the owner's failure to make the necessary repairs to buildings to provide safe, sanitary and decent housing accommodations for tlhe residents. Several County agencies formulated a task force and worked collectively in processing and relocating the approximately ninety-six (96) former residents of the Miami Limited I Section 8 Housing Project previously administered by the Miami -Dade Housing Agency. A task force has been established consisting of representatives of the; City's Office of Workforce Development, Miami -Dade Housing Agency, HOPE, Inc., HRS, Miami Dade's Community Action Agency (CAA) to develop the City's Strategic Relocation Plan for the relocation of residents. A draft of the City's Plan should be completed by mid -October. On Wednesday. September'-)'-), 1999, the Director of the Department of Community Development met with Ms. Karen "Turner -Cato, Director of Public Housing with U.S. HUD, to discuss the status of the Miami Limited I1 Section 8 Project. Should the City determine that it has no other option but to terminate the I fAP contract with the owner, the balance of the funding which remains under the Miami Limited 1I contract would be used to issue replacement Mod Rehab Vouchers to the tenants currently residing in the Section 8 housing projects. In addition, it is anticipated that funding to defray the cost of relocating the residents would be allocated from any administrative reserves available through the Section 8 Moderate Rehabilitation Program. Presently, a review and audit of the program's administrative handing and project reserves are underway. In addition, a request to secure past financial records associated with the City's Section 8 Moderate Rehabilitation has been requested from U.S. I -IUD. This financial audit is anticipated to be completed by the end of October. In the event the ownerlmanagenhent of the Miami Limited 11 project is able to comply with HUD regulations for maintaining the contract, the City Administration will move forward in assisting the 9- wi4b 3 larger and overcrowded households in an orderly relocation to larger bedroom units in the private housing marketplace. Under this plan priority will be given to larger families. 7 In closing. a I1leeting iS being scheduled to be chaired by the Honorable Carrie Meek and representatives from the City, Nliami-Dade Count\ and the U.S. Department of Housing and Urban Development, to discuss the Miami Limited II Section 8 Housing Project and the overall revitalization of the immediate neighborhood. DHW/DB/GC\N7/,lBH/mb j 4 99- 2G