HomeMy WebLinkAboutZB Appeal LetterT O EKES OF tviiCHAE .- OFF
R54 NE 78'`.€. STREET.
BOCA RATON, FL 3-3487-1752
TEL: (786) 280-75 ;5
z \x: (586) 620-6525
February 8, 2005
Office of Hearing Boards
444 SW 2nd Avenue, 7th Floor
Miami, FL 33130
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Re: City of Miami Class II Special Permit (the "Permit") Final Decision
re: Spring Garden Point Park (File No. 04-0423)
Dear Sir or Madam:
We serve as pro bono legal counsel to Rebecca Long (the "Appellant"). On
behalf of Rebecca Long, we hereby notify you that we intend to file an appeal (the
"Appeal") of the decision of the Miami Zoning Board in the above referenced matter.
Enclosed please find a check in the amount of Five Hundred Dollars ($500.00) for the
applicable filing fee.
The grounds for the Appeal are as follows:
1. The Class II Special Permit Notification Letter was defective and
improper because it states that the permit being applied for relates to
"Shoreline Improvements Along Miami River Side of Park" and the final
permit that was issued encompasses both "Riverfront and park
improvements (Spring Garden Point Park)" (emphasis added).
The decision of the Miami Zoning Board was not impartial and unbiased,
as evidenced by defamatory statements made by Charles Flowers, a
member of the Miami Zoning Board, at the Zoning Board hearing on
January 24, 2005, which were directed at Appellant, and such statements
were false and malicious and damaged the reputation of Appellant, who
was appearing before the Zoning Board.
3. The findings and conditions for the Permit are misleading and incomplete
because the plans and drawings submitted by the City of Miami, Park and
Recreation Department, for Spring Garden Point Park cover two (2)
2.
Office of Hearing Boards
February 8. 2005
Page 2
-- one along the Seybold Canal and the other along the Miami River -- and
both parcels are intended to be used together; however, the Permit that
was issued only covers the Miami River parcel, and, as a result, the
conditions set forth in the Permit do not go far enough to protect the
Appellant's use and enjoyment of her property, which is adjacent to
Spring Garden Point Park.
Please feel free to contact the undersigned at (786) 280-7575, if you have any
questions or comments regarding the foregoing.
Sincerely,
LAW OFFICES OF
MICHAEL H. HOFFM.AN, P.A.
Michael H.. Hoffman, Esq.
Florida Bar No. 127523
Enclosure