Loading...
HomeMy WebLinkAboutSubmittal-Vice Chair Russel-Letter from Berger Singerman on Behalf of Camp BiscayneBERGER SINGERMAN December 13, 2017 The Honorable Keon Hardemon Chairman, City of Miami Commission 3500 Pan American Drive Miami, Florida 33133 The Honorable Wifredo Gort Commissioner, City of Miami 3500 Pan American Drive Miami, Florida 33133 The Honorable Manolo Reyes Commissioner, City of Miami 3500 Pan American Drive Miami, Florida 33133 VIA EMAIL AND HAND DELIVERY 'ihmitted into the pkblic record t' r, ite�? (s)Z Z� Z 5 on t_� (11 . City Clerk Jeffrey Scott Bartel (305) 714-4364 jbartel@bergersingerman.com The Honorable Ken Russell Vice Chairman, City of Miami Commission 3500 Pan American Drive Miami, Florida 33133 The Honorable Joe Carollo Commissioner, City of Miami 3500 Pan American Drive Miami, Florida 33133 Re: Ransom Everglades School (the "School") -- Planning and Zoning Agenda Items PZ.22 3277 & PZ.23 3276 Dear Chairman and Members of the City Commission: This firm represents the Camp Biscayne Waterway Owners Association (the "Neighbors") who own property adjacent, and in immediate vicinity, to the School's recently -acquired "Las Brisas" property, the subject of the above -referenced matters pending before the City of Miami. We write to advise the City that the Neighbors have a number of concerns regarding the subject application and the School's intended and potential use of the subject property. Accordingly, my client has reached out and communicated with the School and to the Camp Biscayne Homeowners Association (of which the Neighbors are all members) to resolve a number of serious Neighbor concerns about the above -referenced matters, which materially and potentially adversely affect the Neighbors and its members. Despite our communications, as of this hour, matters remain unresolved. In the interest of demonstrating goodwill and a desire to amicably resolve matters, and without the need to litigate matters before the City Commission that we hope can be settled, the Neighbors do not object to the City Commission considering the above -referenced matters on first reading and do not presently intend to appear at tomorrow's first reading. That said, on 8267485-3 1450 Brickell Avenue I Suite 1900 I Miami, Florida 33131-3453 t: 305-755-9500 f: 305-714-4340 W W.BERGERSINGERMAN.COM r U ►nrlfi.\ 11‘ce 04\44�05e`— r a�n er e.r S\� ecnk h ''11 t a � � a at P December 13, 2017 Page 2 Submitted into the record ffr it m(s) on \ I i �lic et City Clerk behalf of the Neighbors, we wish to provide the City notice that the Neighbors, its members, counsel, supporters and potential witnesses reserve all due process rights, including the right to appear and fully present evidence and testimony at the second reading and public hearing, which second hearing is presently contemplated by the City for January 2018, if such appearance by the Neighbors and its supporters remains warranted. Moreover, in an absolute abundance of caution, a court reporter is attending tomorrow's hearing at the Neighbors' request. We hope that the City Commission will also encourage the School to work in good faith with the Neighbors to resolve Neighbor concerns, as that is the Neighbors' sole goal as well. We very much wish to avoid the possibility of future dispute resolution and/or litigation. Thank you very much. Sincerely yours, JSB/md Enclosures cc: Mr. Daniel J. Alfonso, City Manager Victoria Mendez, Esq., City Attorney Mr. Todd B. Hannon, City Clerk Mr. Devin Cejas, Acting Zoning Administrator Mr. Francisco Gonzalez, Director Rafael Suarez -Rivas, Esq., Senior Assistant City Attorney Amy E. Huber, Esq. (via email only) Estrellita Sibile, Esq. (via email only) 8267485-3 ri ®. BERGER SINGERIvIAN