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HomeMy WebLinkAboutAppeal LetterAND E WT DICKMAN Attorney at Law Law Offices of ANDRFW DICKMAN, P.A. 9111 Park Drive Miami Shores, FL 33138 May 10, 2004 VIA FAX & HAND DELIVERY Terasita L. Fernandez, Director Office of the Hearing Boards CITY OF MIAMI 444 SW 2''' Ave, Seventh Floor Miami Florida 33130-1910 Tel: 305.758.3621 Fax: 305.758.0508 Cell: 305,335.1303 aredrewdickman@bellsou.ih.rnet Re: Approximately 500, 510 and 520 NE 29 Street, Item 2004-0779, Variance from Ordinance No. 11000, as amended, the Zoning Ordinance of the City of Miami, Article 9, Section 908.9, Waterfront yards (c), Waterfront yard areas, to allow a waterfront yard setback of 10'0" average, required 20'0" average, and 10'0" minimum (15'0" minimum required). Dear Ms. Fernandez: This firm represents Mr. Aurora Brito Redondo in connection with his appeal of the above referenced variance approved by the City of Miami Zoning Board on April 26, 2004. My client is a property owner within 500 feet of this project, who is adversely affected by the Zoning Board's decision. Pursuant to Miami Zoning Code, Article 20, please consider this our formal notice of appeal, and in support alleges: • The decision of the Zoning Board was not based on substantial competent evidence; • The decision of the Zoning Board departs from the essential requirements of the law; • The decision of the Zoning Board failed to afford adequate due process; and • The decision of the Zoning Board is not consistent with the City' s adopted Land Development Regulations and Comprehensive Plan. We appreciate your scheduling this matter before the Commission at your earliest convenience. Very truly yogis, Andrew aickan, AICP, Esq.