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HomeMy WebLinkAboutM-92-06044 12 ZONING FACT SHEET Pz LOCATION/LEGAL 1809 Brickell Avenue Lot 52, Block 8, MARY b WILLIAM BRICKELL (8-96) APPLICANT/OWNER United Teachers of Dade (UTD) Lucia A. Dougherty, Esq. "UTD Towers" 1809 Brickell Ave. 1221 Brickell Avenue Miami, Florida 33131 Miami, Florida 33131 Home: Work: 579-0500 ZONING R-4 Multifamily High -Density Residential REQUEST Appeal of the April 10th, 1992 decision of the Zoning Administrator bearing Zoning Interpretation No. ZI-92-2, Ordinance No. 11000, as amended, the Zoning Ordinance of the City of Miami, Article 18, Section 1800, Generally, that the use of the Community and Recreation Building at the UTD Building at the above location, for union mee+ings, not associated directly with the condominium owners, is not permitted as an accessory use. RECOMMENDATIONS: PLANNING, BLDG b ZONING Denial. PUBLIC WORKS No Comments. PLAT AND STREET No Comments. DADE COUNTY TRANSPORTATION No Comments. ENFORCEMENT HISTORY, IF ANY C.E.B. Case No: N/A Last Hearing Date: N/A Found: N/A Violation(s) Cited: N/A Affidavit of Non -Compliance issued on: N/A Lien Recorded on: N/A Total Fines To Date: N/A Comments: N/A HISTORY There is an existing Class C #90-1582, which was issued on October 19, 1990. The Class C was issued for an expansion to the Community and Recreation Building of an existing residential complex. There is also a memorandum in the Class C file, dated November 28, 1990. See attached. ANALYSIS Recommend approval of appeal which will reverse the Zoning Board's decision and uphold the Zoning Administrator's interpretation. Permitting the union meetings to be held in this residential building will disrupt peace and tranquility of this residential community. 92- 604 APPLICATION NUMBER 92- 51 May 18, 1992 Item# 6 Page 1 05/14/92 n � . 0 ZONING BD At its meeting of May id, 1992 the Zoning Board granted an appeal reversing the April 10, 1992 decision of the Zoning Administrator ZI 92i-2, by Resolution ZB 54-92, by a 6-2 vote. CITY COMMISSION At its meeting of July 16, 1992, the City Commission continue the above. 1 4- LAW OFFICES KAYE & ROGER, P.A. 800 EAST CYPRESS CREEK ROAD SUITE 400 FORT LAUDERDALE. FLORIDA 33334 R08ERT L KAYE t 1 RANDALL K ROGER N u_. ;. j May 30, 1992 Uanni*, Building and Zoning Department Z��y of Miami Awn: earing Board Division 2a N.-T. 2nd Street/P.O. Box 330708 Miami, FL 33233-0708 TELEPHONE (305) 928MM 1.800.914.0680 TELEFAX (305) 772-0319 Re: Appeal City of Miami Zoning Board hearing of May 18, 1992 Granting Appeal of City of Miami Zoning Administrator's Determination concerning Application No.: 92-51 (1809 Brickell Avenue - Lot 52, Block B, Mary and William Brickell (B-96)) Dear Hearing Board Division: Pursuant to Section 2002 of the City Zoning Ordinance for the City of Miami, please be advised that the Brickell Homeowners Association, Inc., that entity representing 17 communities in the Brickell area, and T. Sinclair Jacobs, individually, request a review of the decision rendered by the Miami Zoning Board on May 18, 1992 concerning the above captioned matter. It is the contention of the Brickell Homeowners Association, Inc. that the property located at 1809 Brickell Avenue is being used for commercial purposes in direct violation of the existent zoning code effecting the Brickell area. The use of the building by the United Teachers of Dade (UTD) Union Stewards is not an accessory use nor a use which was ever permitted by the City of Miami. Despite UTD's counsel's assurance to the contrary, the City was unable to locate, and UTD's counsel unable to produce, any documentable evidence in support of the City's granting of such usage. The burden of presenting this documentation rests on the proponent of such entitlement. An alternative argument presented by UTD's counsel is that the City of Miami is estopped from enforcing the City's zoning regulations based on the assertion that the City has been aware of the situation (the commercial use) and has failed to enforce the law. In order for the estoppel argument to succeed, UTD has presented a "detrimental reliance" argument. UTD has asserted that their purchase of property on Coral Way, without facilities to accommodate union meetings, qualifies as the necessary reliance. However, it appears that the Union only relocated at that time because the City was i 92- 604 LA Gl Planning, Building City of Miami May 30, 1992 Page 2 and Zoning Department notified of the existence of commercial offices operating out of the Stanley Axelrod Tower (1809 Brickell). Thus, UTD was acting improperly then and, only with City pressure, commenced to conform its operation to comply with the law. Now, again, the City has learned of the Union's failure to abide by the law and is being encouraged by the neighboring homeowners to enforce the zoning code. The City can not permit the continued illegal use of the property based on the possibility that the City "might" have known about the use if that use was improper in the first occurrence. To provide otherwise would allow a single unchallenged illegal act, whether civil or criminal, to serve as a blank check for future violations of a similar character. To permit the Union to utilize the property located at 1809 Brickell Avenue in an illegal manner is to allow those individuals who are not residents of the Brickell community, to openly break the law and flaunt such occurrence before the City's face. It is the hope of the Brickell Homeowner Association, Inc. and its Membership that the City will not be (as the Zoning Board appeared to be) swayed by such "dramatic" presentations as packing the City's gallery with Union members, whose only interest in the property is for its continued illegal use, but rather to maintain the integrity of the zoning ordinances and the residential tone of Brickell Avenue between 15th and 25th Roads. Sincerely, i� �ANDAL K. GER RKR/alc cc: E. Sinclair Jacobs Brickell Homeowners sociation, Inc. 92- 604 LAW OFFICES KAYE & Roci:rt. P.A. Jogx G. FLPTCHEE ATTORNEY AT LAW SUITE 304 1600 RED ROAD SOUTH MIAMI, rL02HDA 03143 - 5484 TELEPHONE (305) 665.7521 FAX (305) 665.0328 May 28, 1992 Teresita Fernandez Chief of the Zoning Department 275 N.W. 2nd Street Miami, FL 33128 Re: Appeal of Zoning Board decision/application no. 92-51 Dear Ms. Fernandez: This is to give you notice that Laura Rodriguez joins in the appeal filed by the Brickell Place Condominium Association, Inc. Laura Rodriguez testified at the Zoning Board hearing, and is a unit owner at Brickell Place. The basis for her appeal is the same as set forth in the Brickell Place Condominium Association, Inc. appeal, in which she joins. JGF/wm cc: Lucia Dougherty Joseph A. Genuardi Sergio Rodriguez Arnold Rabin T. Sinclair Jacobs Laura Rodriguez oh: letcher 11r. Ed 9Z UR Z6. 'A ON103H 92— 604 1 1. Jonrr G. FLJ9TCnE.0 1 V ATTORNEY AT LAW SUITE 304 7600 RED ROAD '•' SOUTH MIAXI, VtX)AZDA C38143 - 5484 co - `r TELEPHONE (305) 665-7521 w FAX (305) 665-0328 w - Teresita Fernandez Chief of the Zoning 275 N.W. 2nd Street Miami, FL 33128 Dear Ms. Fernandez: May 27, 1992 Department Re: Appeal of Zoning Board decision/application no. 92-51 It is my understanding that you are the Clerk for the zoning boards and the person designated by the City Manager pursuant to Section 2002, City Zoning Ordinance, for the filing of appeals from the zoning board to the City Commission. The purpose of this letter is to appeal to the City Commission the decision of the zoning board, application no. 92-51 regarding property at 1809 Brickell Avenue, which was the subject of agenda item 6 for the Miami Zoning Board meeting of Monday May 18, 1992. The appellant in this case is the Brickell Place Condominium Association, Inc., which is the owner of a condominium unit at 1901 Brickell Avenue and which is the representative of the condominium association members at that address. The basis of the appeal is that the property which was the subject matter of the hearing before the Zoning Board, the property at 1809 Brickell Avenue, is being improperly used. The property is residential yet the site is being used for United Teachers of Dade (UTD) Union Stewards meetings contrary to the City's zoning ordinance. No special exception, variance, or other relief permits such utilization. The zoning board did not give reasons for its decision, which reversed the April 10, 1992, decision of the Zoning Administrator (ZI 92-2). It is thus difficult for us to advise you as to where the zoning board went wrong except to say that it was totally inappropriate. The decision of the (9 92- 604 Page 2 Teresita Fernandez May 27, 1992 zoning board should be reversed by the County Commission. Cordially, oh G. etcher JGF/wm cc: Lucia Dougherty Joseph A. Genuardi Sergio Rodriguez Arnold Rabin T. Sinclair Jacobs Zi: Ed SZ AN Z6. „J )MV06 JNIL N iN iN JO U3 92- 6047- r. f M f' 92- 604 Ms. Elba Morales offered the following Resolution and moved its adoption. RESOLUTION ZB 54-92 A RESOLUTION GRANTING THE APPEAL AND REVERSING THE DECISION OF THE ZONING ADMINISTRATOR BEARING ZONING INTERPRETATION NO. ZI-92-2, OF APRIL 10, 1992 STATING THAT THE USE OF THE COMMUNITY AND RECREATION BUILDING AT THE UNITED TEACHERS OF DADE (UTD) BUILDING AT 1809 BRICKELL AVENUE, FOR UNION MEETINGS, NOT ASSOCIATED DIRECTLY WITH THE CONDOMINIUM OWNERS, IS PERMITTED AS AN ACCESSORY USE FOR THE PROPERTY LOCATED AT THE ABOVE LOCATION ALSO DESCRIBED AS LOT 52, BLOCK B, MARY AND WILLIAM BRICKELL (B-96). Upon being seconded by Mr. Ronald Fox the motion was passed and adopted by the following vote: to AYES: Ms. Basila and Morales Messrs. Moran-Ribeaux, Alonso-Poch, Fox and Sands NAYES: Messrs. Milian and Barket ABSENT: Mr. Luaces and Ms. Perez -Nodal Ms. Fernandez: Motion carries 6 to 2. May 18, 1992 Item # 6 Zoning Board 92- 604 A T T 0 R N F; I S A T 1. A I I � N U � I 6 Lucca A. Doumtmy 305-579-0603 April 15, 1992 Ms. Teresita Fernandez Hearing Boards City of Miami 275 N.W. 2nd Street Miami, Florida 33128 Re: Appeal of ZI 92-2 United Teachers of Dade WM) Building at 1809 Brickell Avenue Dear Ms. Fernandez: This is an appeal of the above -styled zoning interpretation, which is attached hereto as Exhibit "A." The interpretation is arbitrary and capricious, unreasonable, and contrary to law. It further is a violation of substantive and procedural due process. Please find attached the February 25,1992 letter and exhibits and November 12,1991 letter to Joseph Genuardi as the grounds for this appeal. We are enclosing our firm's check in the amount of $400.00, which represents the filing fee. Please advise as to the date that the appeal will be heard by the Zoning Board. Sincerel , cia A. Dougherty LAD/jhd enclosures c:\dw\hW\%MWW9.nr 92- 604 GREENBERG, TRAURIG, HOFFMAN, LIPOFF, ROSEN & QUENTEL, P.A. 1221 BRICKELL AVENUE MIAMI, FLORIDA 33131 305-579-0500 FAX 305-579-0717 MIAMI FORT LAUDERDALE WEST PALM BEACH 4�9ttlj of SERGIO RODRIGUEZ, AICP 'sett? testis Director April 10, 1992 Ms. Lucia A. Dougherty, Esq. Greenberg, Traurig, Hoffman, Lipoff, Rosen & Quentel, P.A. 1221 Briekell Avenue Miami, FL 33131 Re: United Teachers of Dade (UTD) Building at 1809 Brickell Avenue, ZI 92-2 Dear Ms. Dougherty: CESAR H. ODIO City Manager This is in response to your letters requesting my determination on whether the UTD Council of Building Stewards may continue to hold their monthly meeting in the Community and Recreational Building. I have reviewed all the information you have sent me to date and researched all our records and cannot find any written evidence that this use was ever permitted by the City of Miami. The building was built in 1966 under the City of Miami Comprehensive Zoning Ordinance 6871, which classified the site under a R-5A (High Density Multiple Residential) zoning district. The recreational building was permitted for the use of the condominium owners and their guests. The use of this facility for union meetings was not permitted as an accessory use. There is evidence from letter written by Frank A. Williams, Jr., Chief Zoning Inspector, requiring that all union activities be removed. There is no evidence that Mr. Williams concurred with Ms. Elizabeth J. du Fresne that union meetings could be held, as stated in her letter, dated October 18, 1977. Under the Zoning Ordinance 9500, which became effective in June of 19839 the site was classified RG-2.2/7(SPI-4) (General Residential). This classification did not permit as accessory use any meeting not associated directly with the condominium owners. Presently, under Zoning Ordinance 11000, as amended, the site is zoned R-4 (Multifamily High -Density Residential). The Union Stewards meetings is also not permitted as an accessory use. Exhibit "Art L PLANNING, BUILDING AND ZONING DEPARTMENT 9 2- 604 275 N.W. 2nd Street/P.O. Box 330708/Miami, FL 33233-0708/(305) 579-6800 a IL Lucia Dougherty 9 Y April 10, 1992 Page 2 Therefore, it is my opinion that the Union Stewards meetings are not permitted and therefore must cease. Failure to discontinue this use will result in the City of Miami utilizing all remedies available by law to enforce compliance. This interpretation may be appealed by any aggrieved person within fifteen (15) days of its rendering to the Zoning Board. The procedure for appeal is outlined in Article 18 of the City of Miami Zoning Ordinance 11000, as amended. Yours truly, J' S4 A. Genuardi, P.E. ing Administrator JAG/ j g cc: Sergio Rodriguez, Director Guillermo Olmedillo, Deputy Director G. Miriam Maer, Esq., Law Department File John G. Fletcher 7600 Red Rd., Suite 304 Miami, FL 33143-5484 ' Rocco Pace, President P.O. Box 490093 Key Biscayne, FL 33149 c T. Sinclair (Tory) Jacobs Brickell Homeowners Association S.W. 15 Road Suite 203 r Miami, FL 33129 92- 604 i� -� GflEfNBEBG I fl fl U fl I G Lucca A. DOUGHmmy 305-579-W3 February 25, 1992 Mr. Joseph A. Genuardi . Zoning Administrator City of Miami 275 N.W. 2nd Street Miami, Florida 33128 Re: United Teachers of Dade Towers ("UTD Towers") ,1908 Brickel_i Avenue Dear Joseph: This letter will respond to your January 29, 1992 letter advising that the United Teachers of Dade have three weeks in which to furnish proof that the City of Miami permitted the use of the UTD Towers at 1908 Brickell Avenue for its monthly union meetings. In response to your request, please be advised as follows: 1. The UTD Towers was financed under $ 202 of the Housing Act of 1959, 12 U.S.C. 1701q. An applicant for loan assistance for the construction of housing for the elderly or handicapped must be ... an established organization the purposes of which include promotion of the welfare of elderly or handicapped families or must be sponsored by a fraternal, civic, religious, charitable or similar organization with a long-term social and financial its affairs during the life of the loan (emphasis added). (24 CFR § 2773). 2. The United Teachers of Dade is the sponsor and owner of the UTD Towers. As shown in Exhibit "A", the governing body of the United Teachers of Dade is "the elective representatives of the membership known as the Council of Building Stewards." It is this Council which meets at the UTD Towers on a monthly basis. Therefore, it is the owners of the building, that must maintain a continuing interest in support of the project, which meet in the building on a monthly basis. As will be discussed later, the City has been on notice since 1977 that these Council meetings were taking place on a monthly basis and has never challenged this use by the owners of the building. GREENRERG. TRAURIG, HOFFMAN. LIPOFF. Rom & QUENTEL. P.A. 1221 BRtccELL AVENUE MIAMI, FLORIDA 33131 305-579-0500 FAx 305-579-0717 9 2 -- 604 MIAMI FORT LAUDERDALE WEST PALM BEACH .. . 66 W ) V Mr. Joseph A. Genuardi February 25, 1992 Page 2 3. 12 USC 1701(q) subparagraph (a) (1) provides: The purpose of this section is to assist private non-profit corporations ... to provide bo acing and related facilities for elderly or handicapped families (emphasis added). "Housing and related facilities" is defined as . . Structures suitable for dwelling use by elderly or handicapped families, and structures suitable for use as cafeterias or dining halls, com_m__unily rooms or buildin_gS,, workshops, or infirmaries or other inpatient or outpatient health facilities, or other essential service facilities. (24 CFR $ 277.1(h)). Community rooms must be distinguished from social centers, which is specifically noted in the following provision: An eligible facility must be financially feasible and essential for the welfare of the project residents, and may include such facilities as project management office space, project workshops and storage space, recreation and social centers, snack bars, craft shops, multi -purpose rooms, laundry facilities, and cafeterias or dining halls. (24 CFR § 277.4(e). This distinction is particularly relevant in light of Exhibit "B," which is a letter from Elizabeth J. DuFresne in which she advised Frank A. Williams, then Chief Zoning Inspector, on October 18, 1977 that in response to his notice of violation for the removal of trailers which were used for union activities, that she was reflecting and documenting their mutual understanding that: Since the facility is available to all non -Profit organizations under the HUD guidelines, United Teachers of Dade will continue to make occasional use of that facility for union meeting purposes. his specifically includes, but is not limited I further enclose for your consideration two other letters written to City of Miami Commissioners in August, 1977, in which she advised that the City's request to cease all union and legal activities in UTD Towers as a violation of the zoning law was contrary to the Commission's understanding in July of that year. I have researched the July minutes, ~• GREENBERG TRAURIG n Mr. Joseph A. Genuardi February 25, 1992 Page 3 and, although said minutes are a continuation of a prior meeting which I have not been able to locate, at said meeting the City Commission approved a PAD for the construction of the second tower. At that time, the opponents stated: They are running at that place right now a four member law firm and a printing press day and night in the present building so now they say to you, please approve us, we'll do our good work on the upper floors but in the lower floors we will have four member union law offices, and we will have our printing press. They moved out as we know the trailers. Another thing that wasn't mentioned, very important I submit, the application is not just for a building it is also to expand the auditorium. The plans for the auditorium expansion are not specific. Am MINTIMM) o7KreWlT4M7o--M,W4AqN 1 • qlkil 11 } 1 . &MM411111 At the meeting in which the PAD was approved, there was an indication that the law and Union offices were illegal. Such uses ceased when the new union offices were constructed. However, even the opponents did not indicate that the union (Council) meetings were illegal. The City certainly had knowledge of their existence prior to July 21, 1977 and subsequent to that time. Nothing has occurred since 1977, to indicate to the United Teachers of Dade that the City believes that the Council meetings are illegal. My view is that the PAD approval included a recognition that the meetings of the building owners were permitted even if the zoning ordinance is not interpreted to provide such an accessory use. 4. Since 1977, the City has known about the meeting and has considered this use legal It has never sent a notice of violation for the conduct of union (Council) meetings at said premises. Even the notice of violation which was sent to the UTD Towers m 1977 indicated that the illegal use was the use of the trailers for the office structure (Exhi'bit "C"). Even if the City were to determine that the meeting of the building owners is illegal at this time, the City is estopped from changing its mind. The United Teachers of Dade relied, to its detriment, on the Citys actions and representations. As you know, the union did not challenge City's 1977 interpretation and, instead, constructed an entirely new building for its union headquarters. It did so with the understanding that it could continue to use the auditorium at the UTD Towers for its Council meetings. At your request I will furnish affidavits to this effect I (P 92- 604 GREENBERG TRAURIG fk c C Mr. Joseph A. Genuardi February 25, 1992 Page 4 You should know that there is no specific objection that either the Brickell Homeowners Association or the Brickell Place Condominium Association has with respect to the use of this property for Council meetings. I have met with both parties and asked them if they could identify any issues or any matters that we could correct that were bothering the Associations. Both responded saying that there was nothing specific about the union meetings that they found objectionable. However, they wanted the law enforced I think it is wrong for the City to cause the United Teachers of Dade the expense, time and energy to justify their existence when there is no specific public need, necessity or objection simply because two neighbors want to test the limits of the zoning law. I want to remind you of the Brickell Bank Case where the City changed its mind and decided the zoning ordinance which permitted a savings and loan association did not also permit a bank. The City lost that case and was required to pay damages and fees to Brickell Bank. L.AD Jjhd enclosure cc: Mr. Sergio Rodriguez Mr. Guillermo Olmedillo Mr. Pat Tornillo Mr. Murray Sisselman William DuFresne, Esq. ../WML^S1dV&-M U Sincere Lucia A. Dougherty GREENRERC TRAURIG 09- 604 17 t 4CIT i t of �fita.mt SERGIO RODRIGUEZ, AICP = CESAR H. 0010 ""'i 11"' �= City Manager Director ,� y B January 29, 1992 Ms. Lucia Dougherty Greenberg, Traurig, Hoffman, Lipoff, Rosen & Quentel, P.A. 1221 Brickell Ave. Miami, FL 33133 Re: United Teachers of Dade (UTD) 1908 Brickell Avenue Stewards Meetings Dear Ms. Dougherty: I have reviewed all the documents you furnished me and researched the records with the City of Miami in order to make a determination on whether the United Teachers of Dade Union stewards may continue to hold their monthly meeting in the Community and Recreational Building at 1908 Brickell Avenue. To date, I have not found enough evidence to allow the meetings to continue. Please furnish me, within three (3) weeks from receipt of this letter, further proof that the City of Miami approved the holding of these meetings as a permitted accessory use in 1966 and confirmed by Mr. Frank A. Williams, Jr., Chief Zoning Inspector in 1977, or any other documentation to support your argument, in order for me to reach 'a final decision in a timely manner. If you require any further information, please feel free to contact me. Very truly yours, 3se A. Genuardi, P.E. i Administrator 92- 604 PLANNING, BUILDING AND ZONING DEPARTMENT 275 N.W. 2nd Street/P.O. Box 330708/Miami, FL 33233-0705/(305) 579-M Lucia bougherty J nuar 2h 19g2 �i JAG/j g cc: Sergio Rodriguez Ggillermo Olmedillo File .% John G, Fletcher 7600 Red Rd., Suite 304 S. Miami, FL 33143-5484 T. Sinclair (Troy) Jacobs Brickell Homeowners Association 195 S.W. 15 Rd., Suite 203 Miami, FL 33129 Roco U. Pace, A.I.A. Pace Associates P.O. Box -490093 Key Biscayne, FL 33149 i I 71 a y , Page 2 -a G B [ I H B I B 6 `00 I fl fl � fl I G Lucca A. DOUGHERTY 305-5 7 9-W3 November 12, 1991 Mr. Joseph A. Genuardi Zoning Administrator City of Miami 275 N.W. 2nd Street Miami, Florida 33128 Re: United Teachers of Dade ("UTDII) 1908 Brickell Avenue Building Permit No. 90-10404 Dear Joseph: As I have formerly advised you, UTD is the organization which owns and manages UTD Towers; hence, the monthly meeting of the management of the building (the union stewards) is not an illegal activity as proposed by certain neighbors (Exhibit #1). Secondly, it is the position of my client that this "meeting" use, which has been conducted since 1968, is not illegal since it is a nonconforming use established prior to any ordinance which allegedly outlawed such activity. Even today, such activity would be permitted with a Special Exception. As support for such a proposition, is the attached letter written by UTDIs attorney in 1977 indicating an agreement with the then Zoning Administrator (Exhibit #2). This activity was obviously considered either a permitted use or an accessory use at the time the building was constructed. Since neither you nor I could find the exact legislation in effect at the time that the building was constructed, a presumption in favor of the property owner must be given. Thirdly, it is UTD's position that the use by the union stewards of the assembly room in UTD Towers is permitted presently as an accessory use of the building. Obviously, any resident could have parties in the assembly room once a month with the same number of people; hence, the use of the assembly room by the owners of the building cannot be illegal. GREENBERG. TRAURIG, HOFFMAN. LIPOFF. ROSEN & QUENTEL. P.A. 92- f� 1221 BRICKELL AVENUE MiAMt. FLORIDA 33131 30S-579-0500 FAx 30S-579-0717 MIAMI FORT LAUDERDALE WEST PALM BEACH 4 Mr. Joseph A. Genuardi November 12, 1991 Page 2 With respect to the church parking lot, across the street on Brickell Avenue, and its use by the UTD members, please find enclosed the case of 100 Lincoln Road vs. City of Miami Beach, in + which the court held that the leasing of space to adjoining neighbors is not illegal unless the ordinance specifically prohibits such leasing (Exhibit #3). As you know, the UTD has a lease agreement with the church for its lots during the time when it is not being used by parishioners; hence, the use is legal both by the church parishioners and by UTD. We would, therefore, ask for your administrative interpretation regarding the above. Sinc ly, Acia A. Dougherty LAD/ jhd enclosure cc:Mr. Guillermo E. Olmedillo William DuFresne, Esq. John G. Fletcher, Esq. sz- so4Iq GREENBERG TRAURIG a m m a n u e L Lucniarah 1770 Brickell Avenue Miami, Florida 33129 chlurc ' l Bruce A. Gibson, Pastor Church / 854.0840 June 19, 1991 To Whom It May Concern: The United Teachers of Dade rents our parking lot when they have meetings at Stanley Axlrod UTD Towers. They rent it on an annual basis and have an agreement through 1995. They utilize the paved areas on our grounds. Further they provide guards for traffic control and to assure there are no problems. Ct, i , TRUCE GIBSON, PASTOR IMMANUEL LUTHERAN CHURCH Submitted into the public record in connection 'th item �''z'�.� on 9 •Z atty Hirai City Clerk 9 2- 604 �s united Teachers of Dade 2929 S.W. 3rd Avenue (Coral Way) Miami, Florida 33129 (305)854-0220 4 Pat L. Tornillo, Jr. Murray Sisseltnan 'MM Executive Vice President President i JUNE 191 1991 BRUCE GIBSON, PASTOR I MANUEL LUTHERAN CHURCH 1 70 BRICKELL AVENUE MIAMI, FLORIDA 33129 :DEAR PASTOR GIBSON: I WISH TO ASSURE THAT THE UNITED TEACHERS OF DADE CAN THROUGH 1995 CONTINUE TO USE THE CHURCH PARKI14G LOT AS WE HAVE D014E IN THE PAST, 1990 $800.00 1992 11.10 $ 00 00 109gy5 11.10.00 ,100.00 1995 1 IF THIS AGREEMENT IS SATISFACTORY WITH YOU PLEASE SIGN THIS LETTER BELOW WHERE YOUR NAME APPEARS AND RETURN IT TO ME. YOURS TRULY, P T L, ORWILLO, JR� EXECUTIVE VICE PRESIDENT UNITED TEACHERS OF DADE BRUCE GIBSON, PASTOR IMMANUEL LUTHERAN CHURCH Submitted into the public record in connection with item�z �z' on Matty Hirai City Clerb 2 _ 604 Affiliations: Florida Education Association/United (FEA/United) • American Federation of Teachers (AFT) American Federation of Labor -Congress of Industrial Organizations (AFL-CIO) BEFORE ME personally appeared Mindy L. Pallot, who being first duly sworn, deposes and says: 1. That she is a resident of the city of Miami, Florida. 2. That she has resided at Brickell Place, 1925 Brickell Avenue, Apartment D-609, Miami, Florida 33129, for over six (6) years. 3. That the entire time that she has resided at Brickell Place, she never knew that the United Teachers of Dade or any other organization held meetings at the UTD Building which is located at 1809 Brickell Avenue, Miami, Florida. 4. That the only disruption to the normal everyday traffic that occurs on Brickell Avenue, are the movies that are filmed periodically at the Brickell Place condominium buildings. 5. That she has never been inconvenienced by any traffic generated by the UTD Building. 6. That she does not object to the United Teachers of Dade utilizing the UTD Building located at 1809 Brickell Avenue for a community and recreation building for union meetings. DATED this S day of July, 1992. Mindy L allot Submitted into the public record in connection with item IPZ-IeZ on 9 �2-10 Matty Hirai 9 ? -- 604 City Clerk STATE OF FLORIDA ) SS: COUNTY OF DADE ) The foregoing instrument was acknowledged before me this /sue day of July, 1992 by Mindy L. Pallot. She appeared before me, is personally known to me or—pr r7�d __ __as and [did] *j- take a oath. Notary: [NOTARIAL SEAL) Print Name: Notary Public, State of _ - a.. .g My commission expires: OFFICIAL NOTARY SEAL ESTHER HERNANDEZ NOTARY PUBLIC STATE OF FLORIDA °?/14/ft\ALr\P"LOT.A" COMMISSION NO, AA594980 MY COMMISSION EXP, AUQUST 7,1992 Submitted into the public record in connection with 2 item z /z on ?cat ty��st�-Izrc (� Gzty Cle-` 9 -- S 0 /1� J// ::•jj+ PETITION 1 i 000+ 1 4 a 0 0 + residents of Stanley Axlerod UTD Towers, 1t „ 1 4 • 0 0 + Lami, Florida 33129, hereby petition the 17,00+ C 15*0o+ :he United Teachers of Dade to continue to h is at the auditorium at the Stanley Axlerod 15 oo+ 1v 1'6-00+ 15.00+ 13.00+ 1 any manner to them holding their meetings s ..18•D0+ we appreciate the fact that they have 16+00+ 16.00+ ned this apartment facility on Biscayne Bay 1 7 • 0 0 + r be affordable to moderate income families. 18.00+ e 1 witted into the public record iu Connection , with ite _�on .292- 604 z ic1 ttY Hirai City Clerk �- PBT1TY02� W91 the undersigned residents of Stanley Axlerod UTD Towers, 1809 Brickell Avenue, Miami, Florida 33129, hereby petition the City of Miami to allow the United Teachers of Dade to continue to hold their Union meetings at the auditorium at the Stanley Axlerod UTD Towers. We do not object in any manner to them holding their meetings at this building and we appreciate the fact that they have constructed and maintained this apartment facility on Biscayne Bay that would otherwise not be affordable to moderate income families. 4subraitted into the public record in connection items with on .2 9,z..92- s44 atty Hirai City Clerk U VETITION lJ �i WE, the undersigned residents of Stanley Axlerod UTD Towers, 1809 Brickell Avenue, Miami, Florida 33129, hereby petition the City of Miami to allow the United Teachers of Dade to continue to hold their Union meetings at the auditorium at the Stanley Axlerod UTD Towers. We do not object in any manner to them holding their meetings at this building and we appreciate the fact that they nave constructed and maintained this apartment facility on Biscayne Bay that would otherwise not be affordable to moderate income families. I. • PITITION WE, the undersigned residents of Stanley Axlerod UTD Towers, 1809 Brickell Avenue, Miami, Florida 33129, hereby petition the City of Miami to allow the United Teachers of Dade to continue to hold their Union meetings at the auditorium at the Stanley Axlerod UTD Towers. We do not object in any manner to them holding their meetings at this building and we appreciate the fact that they have constructed and maintained this apartment facility on Biscayne Bay that would otherwise not be affordable to moderate income families. yi7 y 17146 92- 644 I • ' I IPBTiT1ON WE, the undersigned residents of Stanley Axlerod UTD Towers, 1809 Srickell Avenue, Miami, Florida 331290 hereby petition the City of Miami to allow the United Teachers of Dade to continue to hold their Union meetings at the auditorium at the Stanley Axlerod UTD Towers. We do not object in any manner to them holding their meetings at this building and we appreciate the, fact that they have constructed and maintained this apartment facility on Biscayne Bay that would otherwise not be affordable to moderate income families. i RAW' W-" - -, P, I - - - ' PETITION WF, the undersigned residents of Stanley Axlerod UTD Towers, 1609 Brickell Avenue, Miami, Florida 331291 hereby petition the City of Miami to allow the United Teachers of Dade to continue to hold their Union meetings at the auditorium at the Stanley Axlerod UTD Towers. We do not object in any manner to them holding their meetings at this building and we appreciate the fact that they have constructed and maintained this apartment facility on Biscayne Bay t I that would otherwise not be affordable to moderate income families. � � I ,r 92- 604 B TITION WF, the undersigned residents of Stanley Axlerod VTD Towers, 1809 Brickell Avenue, Miami, Florida 33129, hereby petition the City of Miami to allow the United Teachers of Dade to continue to hold their Union meetings at the auditorium at the Stanley Axlerod UTD Towers. We do not object in any manner to them holding their meetings at this building and we appreciate the fact that they have constructed and maintained this apartment facility on Biscayne Bay that would otherwise not be affordable to moderate income families. ,J � 7/a ? a'� 7 4 Oz- 92•- 604 • 92- 604 P -PETITION WE, the undersigned residents of Stanley Axlerod UTD Towers, 1809 Brickell Avenue, Miami, Florida 33129, hereby petition the City of Miami to allow the United Teachers of Dade to continue to hold their Union meetings at the auditorium at the Stanley Axlerod UTD Towers. We do not object in any manner to them holding their meetings at this building and we appreciate the fact that they have constructed and maintained this apartment facility on Biscayne Bay that would otherwise not be affordable to moderate income families. r IN r. , �.� � r r s� �'i- -✓ �' ~ 92- 604 WE, the undersigned residents of Stanley Axlerod UTD Towers, 1809 Brickell Avenue, Miami, Florida 33129, hereby petition the City of Miami to allow the United Teachers of Dade to continue to hold their Union meetings at the auditorium at the Stanley Axlerod UTD Towers. We do not object in any manner to them holding their meetings at this building and we appreciate the fact that they have constructed and maintained this apartment facility on Biscayne Bay that would otherwise not be affordable to moderate income families. I� kr i PHTITION WE, the undersigned residents of Stanley Axlerod UTD Towers, 1809 Brickell Avenue, Miami, Florida 33129, hereby petition the City of Miami to allow the United Teachers of Dade to continue to hold their Union meetings at the auditorium at the Stanley Axlerod UTD Towers. We do not object in any manner to them holding their meetings at this building and we appreciate the fact that they have constructed and maintained this apartment facility on Biscayne Hay that would otherwise not be affordable to moderate income families. ltit 1004 10f I UZ A" �'Ar I = F; � I W, 11 L/ .:�.. ' �iP 1 �7A 92- 604 9 WE, the undersigned residents of Stanley Axlerod UTD Towers, 1909 hrickell Avenue, Miami, Florida 33129, hereby petition the City of Miami to allow the United Teachers of bade to continue to hold their Union meetings at the auditorium at the Stanley Axlerod UTD Towers. We do not object in any manner to them holding their meetings at this building and we appreciate the fact that they have constructed and maintained this apartment facility on Biscayne Bay that would otherwise not be affordable to moderate income families. / i/a 1W 11 0 Ic 011, L 22- flo3 t �r �! 92— 604 PLTITIDN WE, the undersigned residents of Stanley Axlerod UTD Towers, 1809 Drickell Avenue, Miami, Florida 33129, hereby petition the City of Miami to allow the United Teachers of Dade to continue to hold their Union meetings at the auditorium at the Stanley Axlerod UTD Towers. We do not object in any manner to them holding their meetings at this building and we appreciate the fact that they have constructed and maintained this apartment facility on Biscayne Bay that would otherwise not be affordable to moderate income families. 92-- 604 �A ley PETITIO WE, the undersigned residents of Stanley Axlerod UTD Towers, 1809 Brickcll Avenue, Miami, Florida 33129, hereby petition the City of Miami to allow the United Teachers of Dade to continue to hold their Union meetings at the auditorium at the Stanley Axlerod •UTD Towers. We do not object in any manner to them holding their meetings at this building and we appreciate the fact that they have constructed and maintained this apartment facility on Biscayne Bay that would otherwise not be affordable to moderate income families. l , 1360 92-- 604 a t -� b f PETITION WE, the undersigned residents of Stanley Axlerod UTD Towers, 1809 Brickell Avenue, Miami, Florida 33129, hereby petition the City of Miami to allow the United Teachers of Dade to continue to hold their Union meetings at the auditorium at the Stanley Axlerod UTD Towers. We do not object in any manner to them holding their meetings at this building and we appreciate the fact that they have constructed and maintained this apartment facility on Biscayne Bay that would otherwise not be affordable to moderate income families. I pia. / 7/� a.u-¢--- 1LA� /� '/ w PETITION WF, the undersigned residents of Stanley Axlerod UTD Towers, leog Brickell Avenue, Miami, Florida 33129, hereby petition the city of Miami to allow the United Teachers of Dade to continue to hold their Union meetings at the auditorium at the Stanley Axlerod UTD Towers. We do not object in any manner to them holding their meetings at this building and we appreciate the fact that they have constructed and maintained this apartment facility on Biscayne Bay that would otherwise not be affordable to moderate income families. /511 1514 /sia 15017 f5-07 / Y / �J p � �.s tw �}% a,c,�� � 5 � `����-1 �'9'`' i���-s� •/T/�e=eG��i ��.•� 92- 604 4,9 v (/6/3 /60 ve WE, the undersigned residents of Stanley Axlerod UTD 'rowers, 1809 Brickell Avenue, Miami, Florida 33129, hereby petition the City of Miami to allow the United Teachers of Dade to continue to hold their Union meetings at the auditorium at the Stanley Axlerod UTD Towers. We do not object in any manner to them holding their meetings at this building and we appreciate the fact that they have constructed and maintained this apartment facility on Biscayne Bay that would otherwise not be affordable to moderate income families. 1� � 92- 604 PETITION WE, the undersigned residents of Stanley Axlerod UTD mowers, 1809 Brickell Avenue, Miami, Florida 33129, hereby petition the city of Miami to allow the United Teachers of Dade to continue to hold their Union meetings at the auditorium at the Stanley Axlerod UTD Towers. We do not object in any manner to them holding their meetings at this building and we appreciate the fact that they nave constructed and maintained this apartment facility on Biscayne Bay that would otherwise not be affordable to moderate income families. /7/6 /7o-7 1 7O s"-C i o S' 0 7 1 ! 7G;� ad P©g i 703 SERGIO RODRIGUEZ, AICP Director 1, tsill l� VV July 79 1992 Lucia A. Dougherty, Esq. Greenberg, Traurig, Hoffman, Lipoff Rosen & Quentel, P.A. 1221 Briekell Avenue Miami, FL 33131 He: UTD Towers 1809 Briekell Avenue Private Lodge: ZI-92-2 Dear Ms. Dougherty: CESAR H. ODIO City Manager This is to confirm that according to the City of Miami Zoning Ordinance 11000, as amended, the R-4 district in which the UTD Towers is located, does permit as a conditional accessory use private clubs and lodges, not for profit, by Special Exception. The Zoning Ordinance in Article 25, Definitions, defines as follows: "Club or Lodge: The term "club or lodge" prefers to buildings or portions of buildings constructed and reserved primarily for club or lodge or fraternal organization purposes. Application of the regulations set out herein is intended to be limited to the physical facilities involved for zoning purposes only and does not include authorization or control of the organization itself. For the purpose of this zoning ordinance, clubs and lodges shall be construed as being separate and distinct from fraternities and sororities. Clubs and lodges containing dwelling units and/or lodging units other than for managers or other employees shall be subject to regulations applying to 'dwelling or lodging uses in addition to any special regulations applying to such clubs and lodges". The Webster's dictionary defines Lodge, as: "A local chapter of a fratern%l oaeda iz nto tie public hall of such chapter". LL r record in connection with item e-Z-1Z PLANNING, BUILDING AND ZONING DEPARTMENT atty Hirai 275 N.W. 2nd Street/P.O. Box 330708/Miami, FL 33233-0708/(305) 579-6800CitY C1er 9 2' V O 4 The Illustrated Book of Development defines Lodge as: 11(2) The place where members of a local chapter of an association hold their meetings; and, the local chapter itself". The United Teachers of Dade Organization, according to its constitution, is an organization of professionals formed for a unity of purpose to promote and enhance the education, knowledge, welfare, ethical standards and best interests of the teaching profession engaged in the profession for the benefit of the general public. This falls within the definition of a lodge or fraternal organization. Therefore, it is my opinion that your client may apply for a Special Exception to use space within the UTD Tower complex for the purpose of holding meetings related to the United Teachers of Dade. Yours truly, .�c.c W Genuardi, P.ministrator t JAG/ j g Enclosure cc: Sergio Rodriguez Guillermo Olmedillo G. Miriam Maer, Esq. File John G. Fletcher 7600 Red Rd., Suite 304 'Miami, FL 33143-5484 Rocco Pace, President P.O. Box 490093 Key Biscayne, FL 33149 T. Sinclair ( Tory) Jacobs Brickell Homeowners' Association 195 S.W. 15 Road, Suite 203 Miami, FL 33129 02- 604 I; J ' v � jkyjy f ZONING' Church. A building or structure which by design and constrgt�ton L primarily intended x :�;'. 's for the conduct of organized religious services and aaaodnted ace"sory'uses. This definitionk: may include meditation gardens.,1 t • City. The City of Miami, Florida. �} City Code. The Municipal Code of the city, as emended. City commission. The city commission of the city. Civic club. A building used for recreation, sodat, eduediixidll, culturd activities, usually owned and operated by a public or nonprofit group or agency. ' Clinic, medical or dental. EstablishMonb p�+oviding medical, surgical and other health" care services to individuals, including offioes of physicians,' dentjab and'other health care . practitioners and customary accessory types of medical or dental servicei and not involving the overnight stay of patients. a' Club or lodge. The term "club or lodge" refers to buildings or portions of buildings con- structed and reserved primarily for club or lodge or Vatersial organization purposes. Applica' tion of the regulations set out herein is intended to be limited to the physical feailiities involved for zoning purposes only and does not include authorisation or control of the organization itself. For the purpose of this zoning ordinance, clubs and lodges shall be construed as being ,I separate and distinct from fraternities and sororities. Clubs and lodges containing dwelling units and/or lodging units other than for managers or other employs ­be subject, to regulations applying to dwelling or lodging uses in addition to any special regulations ap- plying to such clubs and lodges. Club, night. See Nightclub. Coin -operated laundry. An establishment providing washing, drying of dry leaning ma-, '{ chines on the remises for rental use to the neral public for '� t. P B'e p fancily'.; laundea'ing or dry�I ,• .. , cleaning purposes. j f',,,, ' i Colleges and universities. Educational institutions authorized by the state to award 6 calaureate or higher degrees. Commercial marina. A marina providing servicea to the general public, not accessory to:F •. a specific residential development, tr- err U Commercial parking. Any parking area or parking garage utilised by. either the general public or private users and requiring compensation:. -Commercial vehicle. A commercial vehicle ie aqy vehicle"dssigisod,iatended or used for, transportation of people, goods, or thinM not including privaite�pamenger ve iclee and trailers for private nonprofit transport of goods and/or boats: Commission. See city commission. j Common open space. An open space area +within or relaxed to a, sdte designated as a dmte and owaez's of '� development and designed and intended for the use+ or e44iieint -of zbciA. . 691 • ff f 1-4 LITTORAL LAND Land that'abuti'a large' ody of water such' an ocbt f or sea.. ;F r - '�' "`III ® © LOADING SPACE An off-street space or berth used for the loading or % — loading of commercial vehicles. .'iV s '�' LOCAL AUTHORITY Any city. town, village or other legally authorized aae charged with administration and enforcement of use regulations. Ste MUNICIPALITY.. ® LOCAL HOUSING Any public body authorized to engage in the'deve14 AUTHORITY ment or administration of subsidized or publiehousiq HE®I1 LOCAL A public improvement provided to a specific area whirl IMPROVEMENT benefits that area and which is usually paid for byspteW assessment of benefitting properly owners. ® LODGER A transient renter whose meals may or may not be in. I cluded in the cost of his rent. Ste BOARDER. LODGING HOUSE A facility in which rental sleeping accommodations art' provided and which meals also may be supplied as pan ®� of the fee. Ste BOARDING HOUSE. ® LONG -'GERM CARE An institutiodor a distinct part of an institution whirl ' FACILITY is licensed or approved to provide health care undal medical supervision for 24 or more consecutive hours to two or more patients who areiinot related to the govero. ing authority or its members by marriage, blood of adoption. .'Comnwitt. A long-term are facility may `be either s skilled nursing facility,, where patients receive above a certain number of hours. of nursing care daily (New Jersey requires 2.75 hours), or intermediate care facility. where patients receive'" than the established number of hours of nursing care`daily. In addition"to a nursias home, other long-term cur facilities are governmental medical institutions, or'nursing units in a home for tbt i18• 92-- 604 iv Et. "ff ZONING 7. Guest homes (except in Area bounded by S.W.15 Road; S.W. 25 Road; BrkJ ll A"Due : :1 and Biscayne Bay). - 8. Occupancy of private pleasure craft as living quarters is prohibited. Houseb u" we prohibited. 9. Community based residential facilities, licensed by MRS, for six (6) or fewer clients j (not including drug, alcohol or correctional rehabilitation facilities and dangerous { mentally ill persons) when located at least one thousand (1,000) feet hom any existing similar facility, measured from the nearest point of the site of the existing facility to• the nearest point of the site of the proposed facility, provided they are registered with the planning, building and zoning department pursuant to section 934.2.1. 10. Community based residential facilities, licensed by MRS, with bom seven (7) to a,, maximum of fourteen (14) clients (not including drug, alcohol or correctional rehabil• ' itation facilities and dangerous mentally ill persons) when located at least one thou- sand two hundred (1,200) feet from any existing similar facility, or five hundred (5W) feet from any single-family district measured from the nearest point of the site of the existing facility to the nearest point of the site of the proposed fadlity, provided they are registered with the planning, building and zoning department pursuant. to section 934.2.1. , Permitted Accessory Uses: Same as for R-1 Single -Family Residential. i Conditional Principal Uses: Same as for R-3 and in addition: 1. Adult daycare centers shall be permitted by Class I Special Permit if for fqur (4) adults j or less, and by Class n Special Permit If for five (5)L edulta or"more, subject to the .. requirements and limitations of section 93b, Adult'daycare centers. !� 2. Community based residential facilities, with more than fourteen (14) residents in- cluding staff permitted only by Special E=eption with. city commission. Approval, subject to the requirements and limitations of section 934. S. Convalescent homes, nursing homes, institutions for the aged or infirm: and orphan- ages are permitted only by Special E3weption with city commission "approval, subject to the requirements and limitations of section 934: t` 4. Child daycare centers, rs, subject to the restrictions and limitations In section 936, per- �' witted by Class I Special Permit. - Conditional Accessory Uses. - Same as for R-3 and in addition: 1. Private clubs and lodges, not for profit, shall be permitted only by. Special Exception. Where permitted, the floor area of any such private club or lodge shall be limited by convenience establishment requirements. : . 107 . 1 11u111 place to place. 4. Of or relating to travcL,:,,; , lo•co•sm:o•tor (lb'ka•tnb'tar) adj. [lst. locus, + Let. motor, ;mot ideates, as a person who fixes the m ' < movere, to move.] LoCOMOTM 1. los rotor ataxia n Tabes dondis. .: Se. Gael. loch.] Scot L A lake. L A loco -weed (161k8-w1d') tt. A plant of the genera OxyMpfs or As- °L tragalus of the western and central United States, causing severe k. lokhfa < lokhios, of childbirth < poisoning when eaten by livestock. • surge of blood tissue and mucus loe•u-bur (18kc 'ya•lar) also loco -late (-Ut', -lit) or locu lat-ed `. wla'chi•al ad% (•1a'tid) adj. [LocuL(trs) + -AR.] Having, formed of, or divided into small cells or cavities. «-loc'n-cation a -it, bar, and loca, enclosure.] 1. A loe-ule (18k'ydal) n. [Nlat < Lat loculus, little place. --see Local. Is, hold, or secure and operated by Lus.] A small cavity or compartment within an organ or part, as a iation. L A section of a waterway, plant ovary. • J or lower vessels from level to level. loe•u•lus (16k'ya las) n., pl. •M (-li') [NlAt. < Lat., little place, dim. exploding the charge. 4. An inter- of locus, place.] A locule. _nts or parts. S. A wrestling hold to -cum to-nens (181kom' to nene, -nonz) n. [Med. Lat., one hold - is body. •-v. locked, lockdns, ing a place.] Cbfefly Brit. A person, esp. a physician or member of lock, as against entry dock the the clergy, who substitutes for another. as if by locking docked up the lo-cus (18'kas) n., pI. •ei (.W, 411) [Lat.] L A locality: place. LThe • �•' ne by or as if by means of a lock configuration or set of all points satisfying specified geometric condi• To put and keep in a specific locus elas-ski-eus (klls'I-kas) n, plulocisition that a Sent occies on a chromosome. elaw%i-ei (kl3s'%at',-kr) _et boring job> 3. To interlock and bile. 4. To link or clasp firmly : [NLat.] A passage from a standard or classic work that Is cited as an ,• illustrative example. tle or struggle <locked in com• lo-cust (181kast) n. [ME < Lat. locusts.] L Any of numerous gram - with locks. b. To pass (a vessel) hoppers of the family Locustidae, often traveling in swarms and caus• terpress type) in a chase or press ing damage to vegetation. L A cicada. 3. at. A North American tree, r ', 'o fasten (a curved plate) to the Robinfa pseudoacacfa, with compound leaves, fragrant white flower •, , vest (funds) in such a way that clusters, and hard, durable wood. b. A similar or related tree, as the ,; ash. 4. Computer Sci. To end the honey locust or the carob. 4. The wood of a locust tree. �'+:'• Sisk) in such a way as to deny lo•eu•tion (18•ky�'shan) n. [ME Iocucfon < Lat. locutfo < Ioqui, ecome fastened by or as if by a to speak.] L A particular phrase, word, or expression considered 1 i "ERLOCS. 3. To become rigid or from a stylistic point of view. Z Style of speaking: PHRASEOLOGY. rattrway lack. -.lock horns. To lode (lad) n. [ME lode, way < OE lad.] L a. A rock fissure filledIs ' k out. To withhold work from with a metalliferous ore. b. A vein of mineral ore deposited between k, stock, and barrel. Together clearly demarcated nonmetallic rock layers. L A rich supply or to loca.) L a. A strand or curl of lode -star also load -star (18d'stie) n ME lodesurre : lode, way head. L A small wisp or strand, (< OE lad) + sterre, star < OE steorra.] L A star, esp. the North Star, - used as a point of reference. L A guiding interest or principle. ship through a lock. L The toll lode -stone also load -stone (lbd'stbn') n. [Obs. lode, way (< ME '• j s• < OE lad) + STONE.] L A magnetized piece of magnetite. L A strong I L An enclosure that can be attraction. r she safekeeping of items. 3. A lodge (18j) n. [ME < Oft loge, of Germanic orig.] 'L a. A cottage or 1 insulated refrigerated room or cabin used as a temporary, often seasonal, residence <a hunting lodge> b. A small house on the grounds of an estate orig. used by a a gymnasium, with lockers in gatekeeper or caretaker. c. An inn. L a. A North American Indian •: •� stored. L A room for changing living unit, as a wigwam, Kogan, or long house. b. The group of • . _., •„ ig pool, Indians living in such a unit. 3. a. A local chapter of a fraternal ') adj. Of, pertaining to, or ap- organization. b. The meeting hall of such a chapter. c. The members 1` <bought some locker•room of such a chapter. 4. The den of an animal, as the dome -shaped �! > structure built by beavers. —v lofted, lollstins, loft -ea. —Vt. etch < loc, lock, of Germanic L a. To provide with quarters temporarily, esp. for sleeping. b. To keepsake or picture, usu. wom rent a room to. G To establish or place in quarters <lodginig troops e in homes> L To serve as a repository for: HAnoa. 3. To leave, 2. A symptom of tetanus, in place, or deposit, as for safety. 4. To force, fix, or implant. S. To of a tonic spasm of the mus• register (a charge) in court or with an appropriate party: PmL 6. To vest (e.g., authority). 7. Archaic. To beat (crops) down flat. —vi. •� n. L A usu. thin nut screwed L a. To live in a place temporarily. b. To rent accommodations, esp. • : ' - iosening. L A self-locking nut. for sleeping. L To be or become embedded. of work from employees and lodge -went (1811mant) n. var. of =GMEATt'. swing a labor dispute. lodge -pole pine (18j'pel') a A pine, Pinus contorts of western .� repairs or makes locks. North America, having light wood used in construction. » �; n which the marchers follow lodger (18j'ar) n. One that lodges, esp. one vrho rents and lives in a ,t andardized procedure closely furnished room. lodging (181%4) n. L A place to live. L often lodsinss. sleeping accommodations. 3.lodsinsa. Rented rooms. -- lodg-ment also lodgement (18j'mant) a, L The act of lodging d cut or urge y young or state of being lodged. L A place for lodging. 3. An accumulation or+ n, edible, gallop, circus deposit. 4. A military foothold gained in enemy territory. : ;