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HomeMy WebLinkAboutR-93-0803d-93-844(b) 11/17/93 19 93- 803 `• •1I. fWAVOUDOOC7' ^ r al" r 1 r a 01 • 1 •1 r :• '�r Ir r a< r ' 1 ' D a+lNai' •1 air r • •u r N. • • • • lal n aii 1 !1 r • •+r r • 1 • r r • • rr • . • N Ir Ir air r 1 !•!r • 1 • r r • • rr PEI a a+r s •1 • • r N • an' ■• a+ lal ate • •1 !• . .. •+ �, yr � . • . !•1 1' •1 • ' . a+ r •1 1 • ' al' r Ir �• . • . •1 • • rr r r ' an' r alr • alr i•� • `•' • ar r r • • rr.• ;• • • . r ,`N' r: air i a►1 rr: • !1 laic lal' • D r •� lal' a• •1 alr atr 1i,4141a{;�, MMREAS, the Miami Zoning Hoard at its meeting of October 18, 1993, Item No. 3, duly adopted Resolution ZB 102-93 by a seven to two (7-2) vote, granting a Speci.a7. Exception, as set forth herein; and WHEREAS, Manuel Rosado has taken an appeal to the City Commission from the Zoning Board's decision; and WHEREAS, the City Commission after careful consideration of this matter and notwithstanding the decision of the Zoning Boars]., finds that the application for a Special Exception does not meet the applicable requirements of the Zoning Ord:ixlance, and deems it advisable arA in the best interest of the general welfare of the City of Miani and its inhabitants to grant the appeal., reverse the decision of the Zoning board and deny the Special. Exception; I • lal• ar • - �• alr 1 ••. I r •1 • 1 • r ^ r C n tea CITY COMUSSION MEETING OF DEC 1 6 1993 Resolution No. 93- 803 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 Miami. Zoning Board to grant a Special Exception from Ordinance No. 11000, as amended, the Zoning Ordinance of the City of Miami, Florida, Articles 13 and 16, and as listed in the Code of the City of Miami, Florida, as amended, Section 4-14, for distance requirements between two non -cop package Liquor stores (for consumption off -premises only) to permit a 918.9' distance separation (1500' minimum distance required) for non -cop package liquor stores for the property located at 3030 Southwest 8th Street, Miami, Florida, (more particularly described in Exhibit "A" attached hereto and made a part hereof); zoned C-1 restricted commercial, is hereby reversed, the appeal is granted, and the Special Exception is hereby denied. Section 3. This Resolution shall become effective immediately upon its adoption. PASSED AND ADOPTED this 16 th day of December 1994. P. aiAkc, MAYOR A o � MATR HIRAI , CITY C = -0111P %174, G. MIRIAM MAER CHIEF ASSISTANT CITY ATTORNEY GMM/awa/bss/M3999 ....,• Va - 0 111111111111111111 •J n We) ••a 93- 803 - 2 - EXHIBIT A Legal Description All of Lots i and West half of Lot 7, lass the North 20 fast thereof, and the South 40 feet of the Zest half of Lot 7, RICICSONOIS SOBDMSION, according to the plat thereof, recorded in Plat Book "B", Page 130, of the Public Records of Dad*. County, Florida. 0 Lots S, 6, 7 and •, Block 1; Lots 1, 2, 3, 4, S and 6, Block 4; and Lot 1, Block S, HILAH PARK, according to the Plat thereof, recorded in Plat Book 9, Page 72, of the Public Records of Dade County, Florida. FVIR That portion of S.W. 9th Street and S.W. loth Street, lying between the Last Riqht-of-Way boundary of S.W. 31st Avenue (formerly known as S.W. 29th Avenue) and the West boundary of Lot 8, HICKSONoS SOBDMSION, according to the plat thereof recorded in Plat Book 090, at Page 130, of the Public Records of Dade County, Florida. 93- 803 ) ZONING FACT SHEET Pt-2 LOCATION/LEGAL 3030 SW 8 Street (Complete legal description on file with the Hearing Boards Office) APPLICANT/OWNER Jorgar Corp./Ciprox, Inc./Elias B.Miskel, Esq. for Pace & S.Chudnow, Kobrowski & Rithard Schechter Esq.for owner 201 S. Bayshore Blvd. P.O. Box 1900 1500 Miami Center#210 1500 Miami Center #210 Ft.Lauderdale,FL 33302 Miami,FL 33131 Miami, FL 33131 944-3283 .379-9134 ZONING C-1 Restricted Commercial REQUEST Special Exception as listed in the City of Miami Code, Chapter 4, Section 4-14, for distance requirements between two non -COP package liquor stores (for consumption off -premises only) to permit a 918.9' distance separation (1500' minimum distance required) for non -COP package liquor stores, following the procedures of the Special Exception requirements as listed in Ordinance No. 11000, as amended, the Zoning Ordinance of the City of Miami, Articles 13 and 16, for the above subjectproperty zoned C-1 Restricted Commercial. RECOMMENDATIONS: PLANNING, BLDG & ZONING Denial. PUBLIC WORKS No Comment. PLAT AND STREET N/A DADE COUNTY TRANSPORTATION No Comment. ENFORCEMENT HISTORY, IF ANY C.E.B. Case No: N/A Last Hearing Date: N/A Found: N/A Violations) Cited: N/A Affidavit of Non -Compliance issued on: N/A Daily Fine: $0.00 Lien Recorded on: N/A Total Fines To Date: N/A CEB Action: N/A HISTORY Continued from the ZB hearing of 9/20/93 to 10/18/93. Granted on 10/18/93 for 12 mo. to obtain a bldg. permit by Res. 102-93 by a vote of 7-2. ANALYSIS When alcoholic beverage establishment distance requirements were reduced from 2500 feet to 1500 feet in 1990, it was visualized that the new standard (1500 feet) was liberal and that only in rare 4nstances would a special exception be required to reduce said distance. The applicant in this case is within 918.9 feet of one liquor store, 1635 feet from another and approximately 700 feet from a beer and wine bar. As a grocery store, Pace will be able to sell beer and wine for off -premises consumption. The Planning, Building and Zoning Department is recommending denial based on findings that: 1) the established distance requirements are reasonable for the area and given the close proximity of other such establishments already serving the area; 2) there are already over 1100 establishments in the City of Miami that sell alcoholic beverages; 3) there are residentially zoned properties within 375 feet of the site and the facility's parking areas directly abut residential properties. It should also be noted for the record that parking supply, on -site loading, ingress and egress, drainage and utilities are adequate; however signs and lighting require controls. ZONING BOARD Granted for 12 mo. in which a bldg. permit must be obtained. APPELLANT Manuel Rosado CITY COMMISSION APPLICATION NUMBER 93- 188 Page 1 October 18, 1993 9 3 - 803 M-4'A :AROENS •fl A t�11=+��•li•�i•:�D�If.i` �•44. ��S�•:y 1(• •rA F;TaRNF'I '0, � W ••.wI f• f•1 y�•w � ' Q :l12212111OhD4D i••1111 ! 27 !t It01 bl� of •�� 1--i ! Q } 1 ; •.f 2 • •�M r I I p '� !� ill7,•Ilit •'•!tllo !I•Ie�•Ir • ItI•1jl.11lt Qr In} •Z'i.lolli 12 1 - • 1`� • f y g sC 6 S T 1 � i I 1 • ; 24 I I 1 � � ( I � '• I I.4•• i i /•1' •I• i1�2•It7�2t12'It01'•i •' • • to 2>,ii3112d1e ••I'+I • i• 1• �2 ! • fl.•It •�l• 72 i 2 7 • 1 I+�/ • „ P 6 _ •2 N t• 2 t I • I17�12 1 • wJ • IoII. 12 9 t•12lit'!o''a o •s•w�lei 2 13 I• I I• e r l e l •o ! • I• I• I ?is e l 10 11 .!14 W. 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I - .. r Yr 1 I REQUEST FOR REVIEW BY THE CITY COMMISSION ----------------------------------------- Comes now Manuel. Rosado, pro se, and respectfully requests a review by the Miami City Commission on the matter of Pace Warehouse, of 3030 S.W. 8th Street for a Special Exception for distance requirements between two non -cop package liquor stores. This case was Heard by the Miami Zoning Board in its meeting of October 18, 1993. Among the reasons for review are the following: 1.- Pace Warehouse states in its application that it sells about forty percent (40%) wholesale. This is in direct violation of Section 401 of the City of Miami Zoning Ordinance. The store is located in a C-1 (restricted commercial) zone. Section 401 for C-1 reads: "... No wholesaling, or jobbing shall be conducted ...". The Board allowed PACE'S attorney to dance her w way around the subject by talking about low 72 prices. - 2.- The Zoning Board gave undue attention to: a) supposedly hardships PACE would suffer. b) supposedly promises made "by City officials" m =? (never identified) to PACE as to their ability to open a liquor store. Bulding permits do N not show any evidence of a liquor store. This was in violation of Sec. 1303 of the City of Miami Zoning Ordinance, which states that special permits " shall be issued or denied only in accordance with the procedures, standards, and requirements of this zoning ordinance." 3.- The proposed liquor store would be less than fifty (50) feet from residential property, in violation of Section 4-14g.2, City of Miami Code, which calls for a minimum distance of three hundred seventy five feet. Pace's own drawing showed the entrance to the proposed liquor store to be nine feet from the eastern side of the store. There are about twenty feet from the store wall to the monst ruous wall separating PACE's property from residential properties. The Board did not properly consider this. They went with the skilfully worded explanation in PACE's application, which reads: "the portion of the PACE Membership Warehouse Store selling liquor off premises is more than 375 feet from the door of any residence". Section 4-14g.2 reads: "whether there are residentially zoned areas within 375 feet of the subject site ..." 93- 803 7 4.- The Board did not properly take into consideration the opinion of the planning and zoning•ppofessionals of the City of Miami, who opposed the special exception. This proposed store is not only 919 feet from one liquor store; it is barely over the legal distance to another (1634.8 feet by PACE's own drawing). To have a third liquor store in the area goes against any sane zoning practices. 5.- The Circuit Court in and for Dade County has recently found in favor of Martha Weinberg, dba Boulevard Liquors in a case similar to this but with only one stablished liquor store. 6.- Contrary to the picture of benevolence that PACE paints about itself in its application, PACE will be a net EXPORTER OF WEALTH from the City of Miami. That company does not generate any new wealth; it merely shuffles the way money is 4 spen3. Many little stores in the area may die; their place to be taken by a giant who will export Miami's wealth to some other place. It is time for the City of Miami to validate its own Code and Zoning Ordinance. Enough has been given away. Respectfully, Manuel Rosado 12230 S.W. 103 Terrace Miami, Fi. 33176 (305) 541-6125 594-7740 w .. 1�3 93- Mr. George Barket offered the following Resolution and moved its adoption. RESOLUTION ZB 102-93 AFTER CONSIDERING THE FACTORS SET FORTH IN SECTION 1305 OF ORDINANCE 11000, AS AMENDED, THE ZONING BOARD GRANTED A SPECIAL EXCEPTION AS LISTED IN ORDINANCE NO. 11000, AS AMENDED, THE ZONING ORDINANCE OF THE CITY OF MIAMI, ARTICLE 13 AND 16 AND AS LISTED IN CITY OF MIAMI CODE FOR DISTANCE REQUIREMENTS BETWEEN TWO NON -COP PACKAGE LIQUOR STORES (FOR CONSUMPTION OFF -PREMISES ONLY) CHAPTER 4, SECTION 4-14, TO PERMIT A 918.9' DISTANCE SEPARATION (1500' MINIMUM DISTANCE REQUIRED) FOR NON -COP PACKAGE LIQUOR STORES FOR THE PROPERTY LOCATED AT 3030 SW 8 STREET, ALSO DESCRIBED AS EXHIBIT A, ATTACHED; ZONED C-1 RESTRICTED COMMERCIAL. THIS SPECIAL EXCEPTION HAS A TIME LIMITATION OF TWELVE (12) MONTHS IN WHICH A BUILDING PERMIT MUST BE OBTAINED. Upon being seconded by Mr. Carlos Gener, the motion was passed and adopted by the following vote: AYES: Ms. Basila and Morales Messrs. Sands, Gener, Barket, Milian and Alonso-Poch NAYES: Messrs. Luaces and Fox ABSENT: None Ms. Fernandez: Motion carries 7 to 2. c October 18, 1993 Item #3 Zoning Board 93- 803 t CITY OF MIAMI, FLORIDA INTER -OFFICE MEMORANDUM TO : Joseph W . McManus, Deputy DirectorpATE November 19, 1993 FILE . Planning, Building & Zoning Dept. FROM : uan C. nzalez, Actin oning Administrator? SUBJECT : PACE Warehouse Manuel Rosado's Letter received November 2, 1993 REFERENCES: ENCLOSURES: Pursuant to a letter received by our department by Manuel Rosado concerning PACE Warehouse, please be advised of the following answers to the four (4) questions raised in the aforementioned letter. Included in the reply are the Building Officials comments. Question #1 South Wall not of the height promised. Answer Field inspected by Zoning NET Inspector for Little Havana, Edward Borges and walls found to be in compliance with approved plans. Furthermore, the Building Plans Examiner will also investigate for compliance. Question #2 Non -construction workers on site, which has no C.O. These workers are in danger in a location without final electrical, mechanical or fire inspections. Answer They have permission to stock and suppl,; merchandise. They submitted a hold harmless letter dated 0--tober 3, 1993 to the Building Official. Furthermore, a T.C.O. has been issued as of this date. 93- 803 1 Joseph W. McManus November 19, 1993 Page 2 of 2 Question #3 Future operator has declared in its application for a special permit that its business is forty percent (40%) wholesale. The site is Zoned C-1 (retail only). Answer According to PACE's attorney Bonnie Miskel, PACE has a general membership policy open completely to the general public of which all sales are done by retailing. The forty .(40) percent mentioned in Rosado's letter is from a statement taken from PACE that 40 percent of their customers resale the purchased merchandise since they buy cheaper at PACE. However, PACE at no time sells wholesale only retail to the general public and has no control over what the customer does once they leave the premises. Question #4 As opposed to a shopping center, there is only one "premises" (one address, one control, one water meter, one electric meter...) at this site. As per section 1302 of the Miami Zoning Ordinance, they have to have all their special permits before getting a C.O. and/or C.U. They do not have their special exception for a proposed liquor store, as an appeal is in process. Answer Only a temporary C.O. has been issued on the site. PACE has obtained all permits to construct and is •now eligible for a temporary C.O. The liquor distance separation appeal will be heard by the City Commission. As of this date no sale, of Liquor is being done by PACE. Since there is only a Temporary C.O. on file a temporary Certificate of Use has been issued. JCG: tc cc: Teresita Fernandez Zoning file Central file 93- 803 12. ►35 �3 j To: City of Miami Planning, Building and Zoning Department Attention: Mr. .Joseph W. McManus, Deputy Director COMPLAINT Comes now Manuel Rosado, pro se and formally complains about violations to the City of Miami Zoning Ordinance and other statutes at the construction site on 3030 S.W. - 8th Street, Miami, Florida. "•�' ca The future operator of the site -Pace Warehouse- has advertised an opening on November 5, 1993, which lends urgency to this complaint. Among the violations you will find: 1) south wall not of the height promised. 2) non -construction workers on site, which has no C.O. These workers are in danger in a location without final electrical, mechanical or fire inspections. 3) future operator has declared in its application for a special permit that its business is forty percent (40%) wholesale. The site is zoned C-1 (retail only). 4) as opposed to a shopping center, there is only one "premises" (one address, one control, one water meter, one electric meter ...) at this site. As per section 1302 of the Miami Zoning Ordinance, they have to have all their special permits before getting a C.O. and/or C.U. They 'do not have their special exception for a proposed liquor store, as an appeal is in process. I am ethically obligated to let you know that I am not an impartial observer. I own a liquor store at 2955 S.W. 8th Street and I am opposing PACE's application for a liquor store at the site. However, I do believe that violations exist at the site and that the city /state/ national regulations should be applied evenly to all: powerful and not so powerful. 93- 803 0 Please feel free to contact me if I may be of any assistance, and please keep me informed of developments at the mentioned site. Respectfully, v� Manuel Rosado 12230 S.W. 103 Terrace Miami, Florida 33176 (305 ) 541-6125 (305) 594-7740 i CC: Juan Gonzalez, Acting Zoning Administrator Robin Vickers, Acting Zoning Administrator Santiago Jorge Ventura, Deputy Director Chief Carlos Jimenez, Fire Chief Captain Wally Moon, Fire Captain 93- 803 The October 8, 1993 Santiago Jorge -Ventura City of Miami Building and Zoning Department 275 N.W. 2nd Street Miami, FL 33128 RE: Property located at: Job Description: Building Permit No.: Gentleman: 3030 S.W. 8th Street PACE Membership warehouse 93-5008606 . Company By this letter we are requesting: Special permission to stock and supply the above captioned property. We agree' that we will indemnify and save harmless the City of Miami Building and Zoning Department, its employees, and the City of Miami Building Official from and against any and all claims, demands, actions, awards, judgements, suits at law, in equity or before administrative tribunals, costs, and expenses, including reasonable attorney's fees, which may arise from or as a result of the issuance of a new permit, We furthermore assume responsibility for the correction, if required of work performed as stated in the above request. �� b�-�-�.d,`,,,,,� ...;.� vim- k�. o��..l► �'f� b,..�—.�.�-zs , .A�. Very truly yours, CONSTRUCTOR: Sig ature Signature Gam' �i � S L i�� /� c:?1�3' _y✓�, �"'� ",� Ll' �—r—t.�.. Print Name Print Name State of Florida) County of Dade) Before me, the undersigned authority, personally appeared under oath depose(s) and say(s) that he is the legal owner of the above referenced property. Sworn and suscribed to before me on the 44t"�day of c�e,'r`o.•1,�; 1993. My commission expires r ovia The new"eale4i btmpany September 17, 1993 City of Miami Building and Zoning Department 275 N.'W. 2nd Street Miami, FL 33128 RE: Property Located at Job Description: Building Permit No.: Gentleman: (�a.uuhuset'lc+.t S�tulceo. 3030 S.W. 8th Street - PACE Membership Warehouse 93-5008606 Bj Ahis letter we are requesting:' Temgora(v Certificate of Occupancy.for the above captioned property. This request is being made for the following reasons: There is still work pending on the property but we expect to finish within ninety (90Y days. We would like to be able to start moving 'tenants into the building. We agree that we, will indemnify and save harmless the City of Miami Building and Zoning Department, its employees, and the City of Miami Building Official from and against any and all claims, demands, actions, awards, judgements, suits'at law, in equity or before administrative tribuhais,,costs and expenses, incruding reasonable attorney's.fees, which may arise from or as a result of the issuance of a -new permit. We furthermore assume responsibility for -the correction, if required of work performed as stated in the above request. Very truly yours, OWNER: Signature Print Name • _/reOrint Name i r�. ��• a mod► State of Florida) County of Dade) Before me, the undersigned authority, personally appeared under oath depose(s) and say(s) that he is the legal owner of the above referenced property. Sworn and subscribed to before me on this 2"l day of 1993. My commission : MYIYA M GARCIA-vERA --�-- :. .. =0M / M 2=114 j mm: WY 19, Im Notary Public "''r Rl, R4� BgtNd 1AN Ik�ty fli01C lbldlrKTtter� NOTE: If Temp CO is granted, a non-refundable fee of $250.00 is rec;:.jired made payable to "City of Miami". When a bond is requested that is a sepa to cost. 1 .1 803 CITY OF MIAMI, FLORIDA , INTER -OFFICE MEMORANDUM TO Juan C. Gonzalez, Acting Zoning Administrator r FROM Julie 0. Bru Assistant City Attorney Law Department DATE : September 23, 1993 FILE . A-93-862 SUBJECT : Legal Opinion First Rights to Liquor Store Application REFERENCES: ENCLOSURES. The undersigned is in receipt of a request for legal opinion, (the "Query"), pertaining to the above captioned issue, a copy of which is attached hereto for your convenient reference. One of the questions set forth in the Query concerns an application for a variance which was scheduled for a hearing before the Zoning Board on September 20, 1993. Consequently, because time was of the essence, the aforementioned issue• was discussed via conference call wherein you, Irma Abella, Miriam Maer, Joel Maxwell and I participated. During said discussion you elaborated as to the facts, and revised certain information set forth in the Query, as follows: 1. You indicated that as to Mr. Alberto' Miguel, referred• to in your memo as "the first applicant", contrary to what is stated in the Query, an application for a Certificate of Use to operate a liquor store was not submitted, but rather Mr. Miguel submitted a "Certified Distance Survey". 2. The same correction was noted for, Pace Warehouse, referred to in your memo as "the second applicant". 3. Finally, as to Mr. Manuel Rosado, referred to as "the third applicant", you clarified that, Mr. Rosado submitted a Certified Distance Survey on July 23, 1993, and an Application for Certificate of Use on August 20, 1993. Based on the foregoing, we agreed that the information provided in the Query was incorrect in that only one (1) of the three (3) parties referred to therein is, in fact at this time "an applicant" for a Certificate of Use. Consequently, by way of this memo, I recapitulate, in writing, the response provided verbally during the aforementioned telephonic conference, and suggest that you recind the Query and seek a legal opinion on the underlying issue involved in this instance. 93- 803 19 Juan Gonzalez Page - 2 - September 23, 1993 At the onset, we advised that as to Mr. Alberto Miguel there is no application pending at this time nor could there ever have been one since Mr. Miguel was never an owner, agent or tenant of the location in question. Therefore, no further consideration was merited in relation to the other two (2) parties. With regard to Pace Warehouse, as previously noted, there is no application for Certificate of Use pending at this time. Furthermore, Section 4-10 of the Code of the City of Miami, in pertinent part, states that: No Certificate of Use and/or Occupancy shall be issued ............. if the proposed place of business is situated less than five hundred (500') feet from a place of business with a prior alcoholic beverage license. (emphasis supplied). Accordingly, at such time as Pace submits an application for a Certificate of Use, a determination should be made as to whether or not there is another place of business within the requisite distance with a prior alcoholic beverage. Thus we agreed that Pace's request for a variance, which had been scheduled before the Zoning Board is at this time premature. Finally, we advise that at this time Mr. Manuel Rosado's application for a Certificate of Use should not be denied on the basis that Pace Warehouse submitted a Certified Distance Survey on a date prior to Rosado submitting a survey. Nothwithstanding the aforementioned, there remains an issue, which although not explicitly set forth in the Query, is nevertheless the underlying question with regards to the specific issues addressed above. Specifically, there remains the following issues: Is a liquor vendor who submits a Certified Distance Survey in accordance with Section 4-10 and 4-15 of the Code of the City of Miami, prior to submitting an application for Certificate of Use and/or Occupancy, entitled to rely on the status quo of said Survey until such time as said vendor actually submits the application for the Certificate of Use and/or Occupancy? ion93- 803 Juan Gonzalez Page - 3 - September 23, 1993 I would note that my review of the Code indicates that there is no provision at this time which entitles any individual to what you refer to as "first rights to a liquor store application". However, your discussion seems to indicate that under certain circumstances, as a matter of policy, your department recognizes certain "priority rights" related to licensing requirements during the permitting process related to development and construction of establishments which operate package stores and/or bars. Accordingly, this issue should be examined. comprehensively in order to determine whether a code amendment should be proposed or is in fact necessary to award such "priority rights". I trust this memo, which summarizes the verbal opinions rendered on September 20, 1993, will suffice in response to the Query dated September 14, 1993. Therefore, you should formally notify this office, in writing of the same, and if you agree with my suggestion, revise your request so as to address the issue discussed in the preceding paragraph. JOB:kd:P192 cc: Cesar Odio, City Manager Sergio Rodriguez, Asssitant City Manager Joel E. Maxwell, Assistant City Attorney G. Miriam Maer, Assistant City Attorney Irma M. Abella Assistant City Attorney 93- 803 � LA 1 CITY OF MIAMI, FLORIDA I . "I INTER -OFFICE MEMORANDUM TO A. Quinn Jones, III DATE September 14, 1993 City Attorney Law Department SUBJECT Request for Legal Opinion: First rights to Liquor Store Application FROM REFERENCES tl Cesar H. Odlo ENCLOSURES City Manager c-"`' , .� Your legal opinion is requested on the following question: "WHICH OF THE FOLLOWING APPLICANTS NOW HAS FIRST RIGHTS TO --:A., LI$JOR STORE APPLLICATION: w A) AN APPLICATION SUBMITTED JULY 2, 1993, WHICH COMPLIES WITH ALL DISTANCE REQUIREMENTS BUT HAS NOT OBTAINED A LEASE AND IS IN LITIGATION WITH THE LANDLORD; B) AN APPLICATION SUBMITTED JULY 191 1993, WHICH COMPLIES WITH ALL DISTANCE REQUIREMENTS EXCEPT IT IS WITHIN 1500 FEET OF A), IS NOW UNDER CONSTRUCTION, HAVING NEITHER A TEMPORARY OR FINAL CERTIFICATE OF OCCUPANCY, OR C) AN APPLICATION SUBMITTED JULY 23, 1993, FOR THE SAME LOCATION AS A) WHICH COMPLIES WITH ALL DISTANCE REQUIREMENTS EXCEPT IT IS WITHIN 1500 FEET -OF B), AND W14ICH NOW HAS A LEASE?" BACKGROUND One of the applicants (B) is applying for a variance from the distance requirements (from A) before the Zoning Board on September 20th. Your opinion may make moot the application for variance, so that your immediate attention in this matter would be appreciated. The attached memorandum gives more background. Attachments 93- 803 23 CITY OF MIAMI, FLORIDA INTER -OFFICE MEMORANDUM I , Sergio Rodriguez, Assistant DATE September 10, 1993FILE City Manager & Director Pla ning, Building & Zoning Dept. SUa,ECT Legal Opinion on Liquor Survey application ! 10M ` REFERENCES uan C. Gonzalez, Ac in Z •%ing Administrato i ENCLOSURES: Pursuant to the following situation, I am requesting a legal opinion on which applicant has the first rights to claim a location according to submittal of a proposed liquor survey for a liquor package store. i 2955 SW 8 Street First Applicant Alberto Miguel On July 2, 1993, a distance liquor survey was submitted by Alberto Miguel for a proposed liquor package store. Review of the survey indicated compliance with applicable distance requirements. The applicant never obtained the final lease and is currently in litigation with the owner. 3030 SW 8 Street Second Applicant PACE Warehouse j On July 19, 1993, a second distance survey was submitted by PACE Warehouse for a proposed liquor package store. They were notified at the time of the submittal of the survey that a prior applicant has submitted a survey which will effect their application, since both sites are within 1500 feet of each other. Furthermore, as of this date the site is under construction and does not have either a temporary or final Certificate of Occupancy,. 2955 SW 8 Street Third Applicant Manuel Rosado On July 23, 1993, a third liquor survey was submitted for the same site as the first applicant by a different tenant who obtained the actual leasehold for the site. The applicant was notified of the prior submittals of surveys by the first & second applicants. 93- 803 25 Sergio Rodriguez Seember 10, 1993 Par 2 of 2 Findings of Fact The first applicant Alberto Miguel is currently in litigation with the owner, since the lease was given to the third applicant which is in current possession of the property and has applied for a Certificate of Use and has received several inspections. The first applicant was not allowed to obtain a Certificate of Use since he could not obtain possession of the property since the actual lease and possession of the site was given to the third applicant by the owner of the Building. Furthermore, since the second applicant, PACE Warehouse is as of this date still in construction, they could not obtain a Certificate of Use application. Questions for Legal Opinion By this memorandum I am requesting the following legal opinions. 1. Does the first applicant, Alberto Miguel have any rights to demand the City "Reserve" his application for first rights to the site until his litigation over the lease is concluded with the owner who gave the leasehold to the third applicant. 2. Does the second applicant, PACE Warehouse have any rights to claim their location as a valid application since they were second in applying, and the first applicant did not obtain possession of the property, even though the PACE Warehouse is under construction, and does not have a valid Certificate of Occupancy. 3. Do.es the third applicant, Manuel Rosado have a right to claim he is the only valid applicant since the first applicant never obtained obsession of the site, and the second applicant is under construction and does not posses a Certificate of Occupancy. JCG: tc Enclosures cc: Joseph W. McManus Zoning file Central file � A6 93- 803 L CITY 04 FLORIDA r.�'eml, �. I 6 Ah To"YsarMH H. od' SEp 2 Q 199393 SE DATE y anage SUBJECT �7 EVE® FROM : A: u i n City At rny ne , REFERENCES e ENCLOSURES: September 15, 1993 FILEMIA-93-005 Alcoholic Beverage Distance Separation Your request of September 10, 1993 You have requested a legal opinion on the following question: WHETHER THE DISTANCE SEPARATION REQUIREMENTS SET FORTH IN SECTIONS 4-12 and 4-13 OF. THE CODE OF THE CITY OF MIAMI, PROHIBITING THE SALE OR OTHER DISPOSAL OF ALCOHOLIC BEVERAGES WITHIN SPECIFIED DISTANCES OF PUBLIC SCHOOLS, ALSO APPLIES TO PRIVATE SCHOOLS. The answer.to the question is in the negative. Sections 4-12 and 4-13, of the Code of the City of Miami provide as follows: Section 4-12. Same -From churches and public schools in central commercial district. No certificate of use and/or occupancy shall be issued to any applicant for the sale of liquor to be consumed either upon the premises or off the premises and/or for the sale of beer and wine to be consumed on the premises in the central commercial district where the proposed place of business of the applicant is within three hundred (300) feet of a church or public school; provided the method of measurement that shall be applied' to determine whether or not the the proposed place of business of the applicant qualifies, shall be by measurement made or taken from the main front entrance of the place of business to the nearest point on a parcel of land occupied by a church or parcel of land set aside for, and used, or proposed to be used, for public school purposes, and the measurement shall be made along the route of 93- 803 27 Cesar H. Odio Sep nber 15, 1993 City Manager Page -.2- MIA930005 ordinary pedestrian traffic (emphasis supplied). Section 4-13. Same -From churches and public schools in combination residential commercial districts. No certificate of use and/or occupancy shall be issued to any applicant for the sale of liquor to be consumed either upon the premises or off the premises and/or for the sale of beer and wine to be consumed on the premises in the combination residential and commercial district to where the proposed place of business is within three hundred (300) feet of a church or nearer than one thousand (1,000) feet to any public school; provided the method of measurement that shall be applied to determine whether or not the proposed place of business of the applicant qualifies shall be by measurement made or taken from the main front entrance of the place of business to the nearest point on a parcel of land occupied by a church or a parcel of land set aside for, and used, or proposed to be used, for public school purposes, and the measurement shall be made along the route of ordinary pedestrian traffic (emphasis supplied). The above cited City Code sections prohibit the sale or consumption of alcoholic beverages within specified distances of churches and public schools. These sections do not contain a definition of the term "public school." Consequently, the inquiry is whether the phrase "public school," when used in reference to the aforementioned distance requirement, includes "private schools." In statutory construction, statutes must be given their plain and obvious meaning and it must be assumed that the legislative body knew the plain and ordinary meaning of the words. Rinker Materials Corp. v. City of North Miami, 286 So.2d 552 (Fla. 1973); Rose v. Town of Hillsboro Beach, 216 So.2d 258 (Fla. 4th DCA 1968). If words used therein clearly express the legislative intent, other rules of construction and interpretation are unnecessary and unwarranted. Marion County Hospital District v. Namer, 225 So.2d 442 (Fla. 1st DCA 1969). Municipal ordinances are subject to the same rules of construction as are state statutes. Rinker Materials Corp. v. City of North Miami, 286 So.2d at 553; Great Outdoors Trading v. City of High Springs, 550 So.2d 483 (Fla. 1st DCA 1989). Accordingly, the phrase "public school" as used in the above cited ordinances must be given its plain and obvious meaning. 28 - t, 93 803 Cesar H. Odio City Manager Se ?mber 15, 1993 Pay,: -3- MIA930005 The distinction between "public school" and "private school" is clear. The dictionary definition of "private school" is as follows: A school that is established, conducted, and primarily supported by a non -governmental agency. On the other hand, "public school" is defined as: a tax -supported school controlled by a local governmental authority; specific: an elementary or secondary school in the U.S. providing free education for the children of residents of a specified area. Webster's Third New International Dictionary (unabridged) 1005, 1836 (1981). In accordance with the foregoing definitions, Webster's II New Riverside University Dictionary 951, 936 (1984), defines "private school" and "public school" as follows: Private school: A secondary or elementary school run and supported by private individuals or a corporation instead of by a government or public agency. Public school: A U.S. elementary or secondary school supported by public funds and providing free education for children of a community or district. The doctrine of "expressio unius est exclusio alterius" is germane in this instance. It is a legal maxim of statutory interpretation which means that the expression of one thing is the exclusion of another. Based on the herein quoted definitions, application of said maxim indicates that the herein cited code section's reference to the phrase "public school" expressly contemplates only those schools which secure funding in major part from the government, and said reference does not embrace private schools as commonly defined. 93- 803 29, Cesar H. Odio ' SeE inber 15, 1993 City Manager Page_-4- MIA930005 CONCLUSION Based on the foregoing, Sections 4-12 and 4-13, of the Code of the City of Miami must be interpreted to mean that the distance requirement's set forth therein apply to public schools only, and not to private schools. In accordance with the aforementioned conclusion, a City Code amendment would be necessary if the City desires to apply the distance requirements referenced herein to private schools. PREPARED BY: REVIEWED BY: ie 0. Bru Rafael 0. Diaz istant Cit Attorney Deputy City Atte ney AQJ/JOB/kd/M283 cc: Sergio Rodriguez, Asst. City Manager/Director, Planning, Building and Zoning Department Joseph W. McManus, Deputy Director, Planning, Building and Zoning Department Juan C. Gonzalez, Acting Zoning Administrator Jo King Reid, Zoning Inspector II Gisela Alfonso, Zoning Inspector I 93- 803 30. , tf t21MI A. QUINN JONES, III City Attorney September 17, 1993 *VIA FAX AND U.S. MAIL (30S): S79.6700 Telecopier:(305)579.3399 Harvey Reisman, Esquire Megabank Building, 4th Floor 46 S.W. 1 Street Miami, Florida 33130-1610 Re: Your Chapter 119 Public Records Request of September 17, 1993; Package Liquor Stores; Pending request for Legal Opinion received by this office September 16, 1993 (Our file#A-93-862).. Dear Mr. Reisman: Pursuant to your Chapter 119 request, please find enclosed a copy of the City Manager's request for legal opinion relative to property located at 2955 S.W. 8 Street. Si cerely, c�I <Ptanitl /Jel E.MAttachments ( Cief AssiCity Attorney JEM/mis/M241 cc: Cesar H. Odio City Manager Julie 0. Bru Assistant City Attorney Juan Gonzalez Acting Zoning Administrator 93- 803 OFFICE OF THE CITY ATTORNEY/Dupont Plaza Center, Suite 300/300 Biscayne Boulevard Way/Miami, Florida 331313 �` . / ?r.i -BLE MIA 305-356-5202 F p 7 MCOA LANK NUA.DINO . 1r0UR+hs /600vk MARVlY 1. Rt.6tNAN •• 60Wrl"wt6T /IR6T 6TRCtr -eLao-4cm! (sae) ses•lels TV-2COMIEN (305) 350 • CZO8 September 17, 1993 (FAX 579.3399) Joel E. Maxwell, Esq. City of Miami Office of City Attorney 300 Biscayne Boulevard Way, Ste. 300 Miami, Florida 33131 Re: Pad age Liquor Stores Dear Mr. Maxwell: I understand you have received a request for a legal opinion form the City Manager with respect to the priorlUes, If any, of applications for Issuance of Certificates of Use with respect to promises located at 3030 Southwest 5th Street and 2955 Southwest 8th Street, both located In the City of Miami. Pursuant to Florida Statute 119, 1 request a copy of the request for your opinion and would appreciate It if you would fax it to me at your earliest convenience, Sincerely yours, HIR:Is HARVEY 1, REI N, P.A. inn t; 93- 803 33 Delt-.a Due Date When Giving a Closii_ Jate and Change Status from "0" to "A" NUMBER DATA FORM CITY OF MIAMI LAW DEPARTMENT Record Number A _ 9300862 Date # Issued 9 17 93 Date Request Attorney JOB Received 9 16 93 Client PBZ Date Due 9 27 93 FIRST RIGHTS TO Date Closed LIQ.STORE APP. Status 0 Subject Matter LEGAL OPINION REQUESTED: FIRST RIGHTS TO LI UOR STORE APPLICATION A B OR C . Comments 93- 803 34 ,s CITY OF MIAMI. FLORIDA INTEROFFICE MEMORANDUM r0 A. Quinn Jones, III DATE September 14, 1993 ` City Attorney '- Law Department SUBJECT Request for Legal Opinion: First rights to Liquor Store Application `q�rJ REFERENCES Cesar H. Odio City Manager ENCLOSURES Your legal opinion is requested on the following question: _. "WHICH OF THE FOLLOWING APPLICANTS NOW HAS FIRST RIGHTS TO`A: LIQUOR STORE APPLLICATION: - A) AN APPLICATION SUBMITTED JULY 2, 1993, WHICH COMPLIES WITH ALL DISTANCE REQUIREMENTS BUT HAS NOT OBTAINED A LEASE AND IS IN LITIGATION WITH THE LANDLORD; B) AN APPLICATION SUBMITTED JULY 19, 1993, WHICH COMPLIES WITH ALL DISTANCE REQUIREMENTS EXCEPT IT IS WITHIN 1500 FEET OF A), IS NOW UNDER CONSTRUCTION, HAVING NEITHER A TEMPORARY OR FINAL CERTIFICATE OF OCCUPANCY, OR C) AN APPLICATION SUBMITTED JULY 23, 1993, FOR THE SAME LOCATION AS A) WHICH COMPLIES WITH ALL DISTANCE REQUIREMENTS EXCEPT IT IS WITHIN 1500 FEET.OF B), AND WHICH NOW HAS A LEASE?" BACKGROUND One of the applicants (B) is applying for a variance from the distance requirements (from A) before the Zoning Board on September 20th. Your opinion may make moot the application for variance, so that your immediate attention in this matter would be appreciated. The attached memorandum gives more background. Attachments 93- 803 35 r cfifia ianxi OF SERGIO RODRIGUEZ, AICP ,3 CESAR H. ODIO Director City Manager I Gf,�O,FVO�` September 3, 1993 i I i i Manuel Rosado c/o Omni Liquors 12230 SW 103 Terr. i Miami, FL 33176 i Certificate of Use i Application 2955 SW 8 St. #101 i i Dear Mr. Rosado: Please be advised that I am in receipt of your application for a Certificate of Use for a proposed Liquor package store. i By this letter I am informing you that your application will be placed on hold until the following two (2) items are cleared. 1. A Legal opinion on whether a private school is exempt from distance requirements as set forth in Chapter 4 of the City Code concerning Liquor establishments and distance separation from schools. 2. A Legal opinion on what applicant has first rights concerning submittal of Liquor distance surveys. As you are aware the City has another application for a liquor package store on the same location you have submitted your application. The applicant Alberto Miguel submitted his distance survey prior to yours, but due to a leasing problem, has not been able to acquire possession of the property and currently is in legal action with the owners of the property. 93- 803 37 Manuel Rosado September 3, 1993 Page 2 of 2 Furthermore, there is a third applicant (PACE Warehouse) who has submitted a third application for a liquor package store that is within the mandated 1500 feet required by Code. Due to the above mentioned situations I am requiring a second legal opinion on what should be the process to handle this situation. If further Zoning information is required on this matter, please call my office at 350-7876. ry truly yours, ZoningJuan •Adminilt , Ac ing JCG: tc Enclosures cc: Zoning file Central file 803 3� 93- t- l_11 1 (1 1) t=:EFi T r t_t IFII_•ATE OF USE STATUS: 1 ACTIVE E NON-FI NANr_: I AL I Nt !t_I I KY E+I_ttilN f-t.t NUMBER: 2141 A c;Ss,29SS SW _ +HELL: FOLll_I rt. N N ncr-+ r- • '� •` • � _. .. � F'fM , :: � • • . T'h1.�li r• �W � "�,� ,..••t .^ 'tL+•a 1 i •ice Orr _ City of Miami - Qocr..;;..,� CERTIFICATE OF USE .. i j i i i i r, For Building & Zoning 1. Building must be open to all inspectors. Department Use Only Certificate No: 2, The inspection fee is not refundable. z3. Sign Permit is required for all signs. ,--, o 4. Do not operate business until Certificate of Use and Occupational License are issued. Audit Number, 5, Make check(s) or money order(s) payable to the City of Miami. C.O. No: 6. This document is issued pending collection of funds from the instrument of payment Zoned: rnr 1. Name of Owner/Agent: Fee: 2. Name of Business: d M L/ c{ OA S Zonin Rspector Date 3. Business Address:. ❑ Cash ❑ Check No: %�}� 4. Telephone No: 5. No. of Seats: 6. Square Footage: Approved by: /� S 7ep- 4/ .L **q• 7- 7. Mailing Address: iJ S, e% / 03 Zoning Inspection Chief Date 8. Approved Use: /�-'AGfcA s 7-40A2 +`iLlOoj-0A SclkJe-%j 0 N F/LG) d - t/J ,.I,h ve raid ih application• and I .do freely .an i-ofuntarily 911ffe that the and information, contained thereinare•trce.and, correct. _-statements Signatureof Owner/Agent Date. 1) BZ/CA 203 Rev. 04/93 :Distribution: -White• - Owner/Agent; Pink- Occupational Licenses; 'Goldenrod — Owner/ :Agent (aher a certificate number is issued): Card - Building & Zoning Dept 93- go3 39 CITY OF r FLOnIDA INTER -OFFICE MEMORANDUM o A. Quinn Jones, III DATE Augustz,r20,-_'1993..• FILE City Attorney = '` liLIFUL'CT Legal Opinion, Chapter 4, Sections 4-12 & 4-13 City Code of Miami ROM REFERENCES Sergrg, riguez, Director Pla iBuilding & Zoning Dept. ENCLOSURES Please provide a legal opinion whether the term "public schools" as continued in Sections 4-12 and 4-13, Chapter 4, Miami City Code, is construed to include any schools (whether public or private) as set forth in connection with distance requirements. This questions arose as a result of an application for a liquor package store proposed to be located at 2955 SW 8 Street. The required alcoholic beverage survey indicated the location of a private elementary and middle school within the 1,000 foot distance separation. Inspector Gisela Alfonso requested clarification concerning the "private" versus "public" school issue. Joel Maxwell was contacted by Acting Zoning Administrator, Jo King Reid, and subsequently Julie Bru of your staff commenced research. Please call Mrs. Reid at 579-6800 ext. 739 if additional information is required by your department. Thank you for your assistance. SR: tc cc: Joseph W. McManus, Deputy Director Juan C. Gonzalez, Acting Zoning Administrator Gisela Alfonso, Zoning Inspector I Zoning file Central file 1� 93- 803 41 MIAM1 CODE Sec. 4-11. Same —From residential districts. No license for the sale of liquor and/or beer and wine for consumption on the premises shall be permitted nearer than five hundred (500) feet to an R (residential) district, unless such institution is so arranged and the building so constructed and the business is so conducted as to prevent the emission of sounds, vibrations and odors. (Ord. No. 9585, 4 2, 3.24.83) Sec. 4-12. Same —From churches and public schools in central commercial district. No license for the sale of liquor to be consumed either upon the premises or off the premises or for the sale of beer and wine to be consumed on the premises shall be issued in the central commer- cial district to any person, firm or corporation, where the place of business is within three hun- dred (300) feet of a church or public school; pro- vided the method of measurement that shall be applied to determine whether or not a place of business applying for a license to sell liquor for consumption either on or off the premises [quali- fies,) shall be by measurement made or taken from the main front entrance of the said place of business to the nearest point on a parcel of land occupied by a church or parcel of land set aside for, and used, or proposed to be used, for public school purposes, and the said measurement shall he made along the route of ordinary pedestrian traffic. (Ord. No. 9585, § 2, 3.24.83; Ord. No. 9664, § 1, 7.28.83) Sec. 4-13. Same —From churches and public schools in combination residential. commercial districts. No license for the sale of liquor to be consumed either upon the premises or off the premises or for the sale of beer and wine to be consumed on the premises shall be issued in the combination resi- dential and commercial district to any person, firm or corporation, within three hundred (300) feet of a church or nearer than one thousand (1,000) feet to any public school; provided the method of measurement that shall be applied to determine whether or not a place of business applying for a license to sell liquor for consumption either on or 9upp. No. 38 1 4.14 off the premises (qualifies,) shall be by measure- ment made or taken from the main front entrance of the said place of business to the nearest point on a parcel of land occupied by a church or a parcel of land set aside for, and used, or proposed to be used, for public school purposes, and the said measurement shall be made along the route of ordinary pedestrian traffic. (Ord. No. 9585!§ 2, 3.24-83; Ord. No. 9664, § 1, 7.28.83) Sec. 4-14. Exceptions to distance require- ments. (a) The restrictions hereinabove set forth shall not be applicable to apartment -hotels, and mo- . Leis,* with fifty (50) or more guest rooms or to office buildings containing at least sixty thousand (60,000) square feet devoted to and maintained for office room space, and said hotels, motels, and office buildings may contain places of business for the sale of liquor and/or beer and wine to be con. sumed on the premises where such sales are con- ducted in an orderly manner, and where such sale of liquor and/or beer and wine in said hotels, apartment -hotels, motels or office buildings is strictly incidental to the principal hotel, motel or office building use and where there are no signs of any type exhibited or displayed to the outside, indi- cating that liquor and/or beer and wine is obtain- able therein, and where the room for the sale of liquor and/or beer and wine as conducted does not open upon any public street or sidewalk. Not more than one (1) certificate of use and/or occupancy for consumption on the premises shall be issued for any one (1) hotel, upartment-hotel, motel or office building. (b) The restrictions as to distance as hereinabove set forth shall not be applicable to bona fide res- taurants and dining rooms where the sale of li- quor and/or beer and wine is entirely incidental to the principal use of sellingjood, and where no sign or display is made to the outside indicating that alcoholic beverages are obtainable therein and where such restaurant has a space of at least four thousand (4,000) square feet, having accom- modations for service of two hundred (200) or more patrons at tables and containing all necessary equipment and supplies for serving full course *City code cross reference —Hotels and motels, ch. 25, A 364 9 i - $'0 3 APPLICATION FOR SPECIAL EXCEPTION File Number . HEARN Within the City generally, or within certain toning districts, certain structur,6l�, usAI$ aso/om j Qrpancies specified in this ordinance are o 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 to promote the general purposes of this Zoning Ordinance, and, in particular, to protect adjoining properties and the neighborhood from avoidable potentially adverse effects. It is further intended that the expertise and judgement 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) Formal public notice and hearing is mandatory for Special Exceptions. The Zoning board shall be solely responsible for 4eterminat Ws on applications for Special Exceptions. All applications shall be referred to the director of the Oepartant of Planning, building and Zoning for his rscoamendations and the director shall make any further referrals required by these regulations. to Bonnie Miskel* , hereby apply to the City of Mini Zoning bard for approval of a Special Exception for property located at3030 S.W. 8th Street. Miami.. Florida. Nature of Proposed Use (Be specific) A portion of the property to be used for the sale of liquor to be consumed off the premises. See Exhibit nV �+ support of this application, the following uteri&) is submitted: ✓/ 1. Two copies of a survey of the property prepared by a State of Florida Registered Land Surveyor. _Z,*2.0 Four copies of: the.site plan shoring (as required) property boundaries, existing (if any) and proposed structure(s), parking, landscaping etc; building elevations and dimensions &W computations of lot area and building spacing. 3. Affidavits disclosing ownership of property covered by application and /4. disclosure of interest form (attach to application). • Certified list of owners of real estate within a 376-foot radius of the outside boundaries of property covered by the application. S. At least two photographs that show the entire property (tared and improve - ants). 6. other (Specify) 7. Fee )f f 2980 to apply toward the cost of processingo W . . - . . 9 3— 803 4' .. ..--,.._.6:., - knolen Tnr. 3 Special Exception .:.:..:................... M-00 Surcharge equal to #" ic&�N .fie mr fvn above, not to exceed six hundred and {iffy o ars (SM) except froo agencies of the city; such surcharge to be refunded to the applicant if tkre is no appeal from a property owner within three hundred and seventy-five (319) feet of the subject property. (City Code - Section 62-61) Signature _�►.,.� !� o 4w*P--w Authorized Agent of Pace Membership Warehouse, Inc.. Now Ruden. Barnett. Merlorky- Smith Schuster & Russell, P.A. Address Post Office Box 1900 i Fort Lauderdale, Florida 33302 phone 305-764-6660 STATE OR FLORIDA) COUNT/OF S5: ���► ; ('5 k e I being dully smrn, deposes and says thatshe is the Omer) (AV thorized Agent of Owner) of the real property described in answer to question /1 above; thatshe has read the foregoing answers and that the sass are true and cosplete; and (if acting as agent for owner) thatshe has authority to execute this petition on behalf of the aw%ep, Pace Membership Warehouse, Inc. SWORN TO AND SUij RIfED be re se this day of 199 S. My Cossission Expires: 1101eK PAk 3fde of flees Of forrir4:.a :X, In: Nov. 20, 1993 bndad Thry Troy Fein • Iruyronra rne, (1wei Notary Hubl ,/State of f10des at Large 93•-. 803 AFFIDAVIT STATE OF FLORIDA) )ss: COUNTY OF DADE ) Before me, the undersigned authority, this day personally appeared Steven L. Chudnow, who being by me first duly sworn, upon oath, deposes and says: 1. That he is the owner, or the legal representative of the owner, joining in the submission of the accompanying application for a public hearing as required by Ordinance 11000 of the Code 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 represents, if any, have given their full and complete permission for him to act in their behalf for the change or modification of a -classification or regulation of zoning as set out in the' L . accompanying petition. 3. That the pages attached hereto and made a part of this affidavit contain the current names, mailing addresses, phone numbers and legal descriptions for the real property of which he is the owner or legal representative. 4. The facts as represented in the application and documents submitted in conjunction with this affidavit are true and correct. FURTHER AFFIANT SAYETH NOT. Sworn to and subscribed before me this 19th day of Auguet, 993. Notary Pu c, State o For a My commission expires: (N.P. Seal) MIAMI 136728.1 - CMA I NOTARY PUBLIC STATE OF FLORIDA BONDED�TNRU tGE ER& IRS* Utc'J* STEVEN L. CHUDNOW, legal representative of the owners -.- to w ' 93- 803 45 OWEN'S LIST Owwr's Male Richard Schechter c/o American Business Center moirg Address .34 S.E. 2nd Avenue, Suite 700, Miami. FL 33131. Telophone kakr c/o Steven Chudnow, Esq. 305-358-6300 Legal Description: See Exhibit "A" WWII Om Elias Kobrowski c/o American Business Center Neiling Address 34 S.E. 2nd Avenue, Suite 700, Miami, FL 33131 ToI"hwe Nusw c/o Steven Chudnow, Esq. 305-358-6300 Lapl O"Criptlon: See Exhibit "A" Jorgar Corporation, a Florida corporation - a wholly owned or~ Is Mane a haiAfAry of .7n2ara_ma. Inc., a PaALManian corporation, whose z - sole stockholder (bearer stock) is Carlos Lindenfeld. Rsiiing Amms c/o Steven Ch dnow. Eno., Shutts i Bowen 201 South Biscayne Blvd., 1500 Miami Center, Miami, FL*-33131 Tel"Wa Wow __ 305-358-6300 Legal DUCHOtion: See Exhibit "A" Ciprox, Inc., a Florida corporation - whose sole shareholders OWNIsNews ----- Ar�_e�rt..e r;.,a-..�+-tot �..a n�- E-ta --- c/o Steven Chudnow, Esq., Shutts i Bowen ftiIIng Address 201 Seu h Biscayne 91vd-. 1500 Mian+;s�entwr. Miami. -PT, 33131 305-358-6300 Telephone New Legal Description: See Exhibit "A" Any other real auto Pe" rty owned individ"lly, jointly, or soveraily (by corporetles, portnefthip or privately) within 371 feet of the SUNat site is listed a follows: Street Address Level OeuriptiM - Adie�in�c-Prenerty See Exhibit "C" Street Address Legal Description Street Address Lpal Description 9 3- 803 1 013CLOSURI OF OWNIRSNIP 1. Legit description and street address of subject rest property! Please see Exhibit "A", attached 77 2. Owner(s) of subject real proporty and percera3ge ofi;e10LVsMPr Vinancio e: City of Miami Ordinanca No. 9419 requires disclosure of all Rartles havinq a interest, either direct or indirect, in the subject matter of a presentation, request or petition to the City Commission. Accordingly, question 12 requires disclosure of shareholders of corporations, beneficiaries of trusts, and/or any other interested parties, together with their addresses and proportionate interest. Please see Exhibit 1 , attached S. Legal description and street address of any real property (a) owned by any party listed in answer to question 12, and (b) located within VS feet of the subject real property. Please see Exhibit "C", attached IWMM ATTORNIY FOR OWNER STATE OF FLORIDA } SS: COUNTY OF OADI } Steven L. Chudnow , being duly sworn, deposes aye says that he is the (Owner) (Attorney for Owner) of the real property described in answer to question 01,, above; that he has read the foregoing answers and that the some are true and coeiplete; and (if aeting as attorney for owner) that he has authority to extote the Disclosure - of Ownership form on behalf of the owner. Steven L. C SWORN TO AND SUISCRIOID before at this 6 t day of August , 199 3 NY CWISSION IX►IRIS: 10TAR7 PUBLIC STATY OF PLOF= BONDED THRU GE4MM 3A. tM . (SSAL) � f stlorida at La t e on � 1 93- 803 47 EXHIBIT 1 Ownership Interests JORGAR CORP., a Florida corporation 75% i CIPROX, INC., a Florida corporation 5% Elias Kobrowski 10% Richard Schechter 10% 1. Richard Schechter American Business Center 34 S.E. 2nd Avenue Suite 700 Miami, FL 33131 2. Elias Kobrowski American Business Center 34 $-.E. 2nd Avenue Suite 700 Miami, FL 33131 3. Jorgar Corporation, a Florida corporation - A wholly owned subsidiary of Jucarama, Inc., a Panamanian corporation, whose sole stockholder (bearer stock) is Carlos Lindenfeld. 4 c/o Xavier L. Suarez, Esq. Shutts & Bowen 201 South Biscayne Boulevard 1500 Miami Center Miami, FL 33131 4. Ciprox, Inc., a Florida corporation - Whose sole shareholders are Carlos Lindenfeld and Danya Lindenfeld. ! c/o Xavier L. Suarez, Esq. Shutts & Bowen 201 South Biscayne Boulevard 1500 Miami Center Miami, FL 33131 MIAMI 127937.1 - CMA 803 49 M(HIBIT A Legal Description All of Lots 0 and Nest halt of Lot 7, less the North 20 feet thereof, and the South 40 feet of the East half of Lot 7, HICKSON,, S MMDMSION, according to the plat thereof, recorded in Plat Book "n", Page 130, of the Public Records of Dade' ` County, Florida. 0 Lots 5, 6, 7 and 0, Block 1; Lots 1, 2, 3, 4; 5 and 6, Block 4; and Lot 1, Block 5, HILAH PARK, according to the Plat thereof, recorded in Plat Book 9, Page 72, of the Public Records of Dada County, Florida. 0 That portion of S.N. 9th Street and S.N. loth Street, lying between the East Right -of -Nay boundary of S.N. 31st Avenue (formerly known as S.W. 29th Avenue) and the West boundary of Lot 0, HICKSON'S SUBDIVISION, according to the plat thereof recorded in Plat Book "B", at Page 130, of the Public Records of -Dada County, Florida. 93- 803 49, !shOtt "C" Adjoininq Property j TAgal Desoriptiont The North 2io, test of the Mast 1/2 of Tract 7 less the North =0 feet thereof for road R.O.N. "Miokson tlubdivisioe" Pf. "B" P. 130 Public Moaords of Dade COMty/ j TOGS xis Tract "U" of "MA-pler Motors modivision" according to the plat oeeoof as of Dae recorded in Plat $eck iZ at Page it of the Publi Florida (also known as Lots b an I d 6 of "aickson"s lubdLvisianO aoaordir to tee Plat thereof as recorded in Plat Book "B" at Page i�0 less the Mouth 646.78 toot thereof and less the Borth 20*00 loot thereof, Dade County, plorida). I �n 93- 803 EXHIBIT "D" PACE MEMBERSHIP WAREHOUSE, INC. ("Pace") sells merchandise such as, but not limited to, electronAcs, toys, stationary and office products, clothing��.•health � and beauty supplies, housewares, appliances and -'food products. Pace is not exclusively retail in nature. Rather, Pace also acts as a wholesaler with approximatel'Q3 fc (��QQ ( $) percent of Pace's sales to retailers for resale. Urili� discounters such as K-Mart and Target, whose gross profit margin is approximately twenty (20%) percent, Pace's gross margin is between eight and ten (8-10%) percent, thus appealing to a wider base of consumers and providing certain people with the ability to purchase merchandise that they might not otherwise be able to afford. Pace anticipates employing a minimum of one hundred thirty-five (135) employees. Ninety to ninety-five (90-95%) percent of those employees will be local residents. Of the 135 people hired to work at the Pace location, Pace will pay in compensation and benefits approximately $1.3 million per year. A good portion of the income of those employees hired will be spent on local products in local stores. In addition to the $1.3 million per -year in employee compensation and benefits, Pace will spend approximately $325,000 in local non -payroll operating expenses. Additionally, over $9 million will be used for purchasing local merchandise to be resold at the Pace location. Pace sells a large assortment of merchandise and other products. Included in its sales, is the sale of liquor for consumption off premises. Before selecting the Miami location, Pace spent a great deal of time and money researching and investigating the demographics of the location, its marketability and the feasability of locating a Pace membership warehouse store at the proposed Southwest 8th Street location ("Pace Location"). A portion of the research and investigation was directed towards zoning. During its investigation, Pace learned that retail sales of a variety of products, including the sale of alcohol is permitted under current zoning regulations. Pace entered into a lease for the Pace Location and commenced site planning, preparation and development. During the course of its site preparation, Pace spoke to a representative from the City of Miami Planning, Building and Zoning Department. Based on information provided to Pace, Pace refrained from submitting a survey until after another applicant submitted a survey for a location within 500 feet of the Pace Location. After months of planning, preparation and expenditures, Pace may be unable to locate liquor sales at the Miami location. 1 F/3776LM/2 9 3- 803 51 Pace is very committed to serving the City of Miami and the surrounding community by providing quality merchandise and products including liquor for less. The Pace Location is an active member of three chambers of commerce in South Florida, the Greater Miami Chamber at—Com3pexpe, Coral Gables Chamber of Commerce, and Camera ,cJT,,C9mercio de la Pequena Havana. The Pace organization also per'ticipates in contributions to various charities such as the Camillus House and Liga Cubano Contra el Cancer. The Pace Loca�on i� id riffin to throughout the year canned goods and various o uc s o those charities and others. For the Liga Cubano Contra el Cancer, Pace will locate canisters throughout the warehouse. The local sales representatives will actively promote the charities fundraisers. Furthermore, the Pace staff will participate in local telethons and radiothons. Finally, Pace has chosen to support two juvenile sports teams by providing equipment, uniforms, and food donations. The applicant is seeking an exception to the distance requirements provided in Section 4-10 of the Charter and Code of the City of Miami ("Code") requiring that no Certificate of Use and/or Occupancy be issued to any applicant for the sale of liquor off premises in the central commercial district if the proposed place of' business of such applicant is situated less than 500 feet from a place of business with a prior alcoholic beverage license; and further, that no Certificate of Use and/or Occupancy be issued to any applicant for'sale of liquor off the premises in a district designated as a combination residential and commercial district, if the place of business of the applicant is situated less than 1,500 feet from a place of business with a prior alcoholic beverage license. The restrictions as to distance between package liquor stores for consumption off premises only may be modified by the Zoning Board by special exception review pursuant to Section 4-14(g) of the Code. The Zoning Board will review and base its findings on the following criteria: (i) whether there is ample off street parking on the same site as is the subject establishment or whether there is adequate off street parking off the site or whether there is adequate parking in combination. whether there are residentially zoned areas within 375 foot radius of the subject site and how the subject site is screened in terms of noise, odor and light from these residential areas. how, and to what extent, advertising signs on the establishment have been satisfactorily minimized in size and reduced in lighting intensity. 2 �*� F/3778LM/2 ✓ 3 - 803 (iv) how and to what extent the proposed establishment meets the standards in Section 1305, Zoning ordinance 96.• 11000, which are not otherwise requirediE•'W'•be considered above. If applicant meets the above referenced criteria, the Zoning Board shall. grant the special exception. ,AUG -9 Pi 1 :23 Under the present circumstances, and as the site plan reflects, there is more than adequate off street parking on site. The portion of the Pace Membership Warehouse Store selling liquor off premises is more than 375 feet from the door of any residence. Furthermore, the only advertising sign identified on the premises related to the sale of alcohol is merely for purposes of identifying the specific location of the portion of the store open to the sale of alcohol and is minimized in size. The signage is located over the door and is approximately 10 inches high and 4 feet wide. Finally, Section 1305 of the Miami Zoning Code addresses the following areas: (i) Ingress and egress - The ingress and egress to the structure is consistent with all City and South Florida Building Code requirements. off Street Parking and Loading - As identified on the site plan, off street parking and loading facilities are adequate and consistent with pedestrian safety and convenience, internal traffic flow and control, arrangement of access in case of fire or other emergency and is adequately landscaped. Refuse and Service Areas - As identified on the site plan, the refuse and service areas are separate from and screened off to remove the refuse areas from the view of the public. Pace has arranged for frequent collection and deliveries, and shipments and other activities are located away from pedestrian and traffic flow. The refuse and delivery areas are walled to prevent public access. (iv) Signs and Lighting - Proposed lighting for signs on the premises is compatible and in harmony with adjoining and neighboring property. (v) Utilities - The use of the portion of the store for the sale of alcohol shall have no effect on utility availability and capacity nor will it have any other adverse effects on adjoining or nearby property. 3 93- 803 F/3778LN/2 53 (vi) Drainage - The location of the portion of the store open for the sale of alcohol shall have no effect on drainage. Pace meets all of the �r�cl tic}ns and criteria for approval of the special exception pursuant to Section 4-14(g) of the City of Miami Code of Ordinances. Accordingly, we respectfully request approval of this 5$pl46p4op1lfOr Special Exception. JL y� F/3T79LN/2 *54 4 93- 803