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VIA HAND DELIVERY
Teresita Fernandez
Chief, Hearing Boards Division
City of Miami
444 S.W. 2°d Avenue
7th Floor
Miami, Florida 33130
FEW CARDENAS BA.K
KELLOGG LEHMAN
DE
TAGUE
YMQND 8C. LEVINE, L L P
September 30, 2003
. T 1 A
Re: Appeal of Historic and Environmental Preservation ("HEP') Board Decision: East Coast
Fisheries Designation: 40 S.W. North River Drive, Miami, Florida
Our File No.: 44532.002
Dear Ms. Fernandez:
This law firm represents RiverHouse Pier I Limited ("RiverHouse"), owner of the above -referenced
property ("Property"). On September 16, 2003, the HEP Board designated the Property historic. Pursuant
to §23-4(b)(5) of the Code of the City of Miami, RiverHouse appeals the HEP Board's decision, and encloses
all required materials in support of the appeal. Please note that we are unable to include a copy of the
resolution because it is not available. We will provide you with a copy as soon as it becomes available.
RiverHouse appeals the HEP Board's decision because the Property fails to meet required criteria
for designation, as set forth under §23-4 of the Code. The Property does not have significance in the
historical, cultural, archeological, aesthetic, or architectural heritage of the city. Moreover, the property is
in virtually irreparable condition, as documented by the engineer report which was submitted into the record
at the HEP Board meeting. An additional copy of the engineer's report will be provided under separate
cover. The Property, therefore, does not have the required integrity of design to qualify for designation.
Indeed, the engineer's report indicates that the Property is appropriate for demolition and replacement, rather
than historic designation.
We look forward to presenting this issue to the City Commission as soon as possible.
Sincerely,
Santiago D. Echemendia, P.A.
Bob de la Fuente
For the Firm
Encl.
cc: Sarah Eaton
Peter Swartz