HomeMy WebLinkAboutLetter from AppellantBERCOW RADELL FERNANDEZ & LARKIN
ZONI!NIG, LAND USE AND ENVIRONI'iENTAL LAW
DIRECT LINE: (305) 377-6220
E-Mail: JBereow@brzoninglaw.com
VIA HAND -DELIVERY
June 17, 2017
Ms. Olga Zamora, Chief
City of Miami Hearing Boards
Miami Riverside Center (MRC)
444 SW 2nd Avenue, 3rd Floor
Miami, Florida 33130
Re: Babylon International, Inc. - Deferral of FILE ID 1227-Final Designation Appeal
for 240 SE 14 ST
Dear Ms. Zamora:
This law firm represents Babylon International, Inc. ("Appellant") with regard to
the appeal of the Final Designation of the property located at 240 SE 14 Street in Miami,
Florida (the "Property") as Historic pursuant to Chapter 23 of the City of Miami Code(the
"Appeal"). This law firm similarly represents the Appellant in the Circuit Court of the
Eleventh Judicial Circuit in the matter of Babylon International, Inc. vs. the City of Miami,
case number 2016-010409-CA-01(the "Lawsuit").
The Appeal was originally scheduled for City Commission consideration on
January 26, 2017. At that time, the matter was "Indefinitely Deferred" due to the
pendency of the Lawsuit and an appellate review scheduled before the Third District
Court of Appeals. The Appeal is currently scheduled before the City Commission for
July 27, 2017, However, the Appellant intends to continue litigating the Lawsuit, even
though we have provided the requested address labels for notice to neighboring property
owners as required by the City Code. We believe that in light of the ongoing Lawsuit, the
Appeal should be deferred as it was in January.
By this letter, we request that the City mark the item on the agenda as being
deferred and not send out the notice letters to neighboring property owners. This action
by the City will allow the Lawsuit to proceed in an orderly fashion.
SOUTHEAST FINANCIAL CENTER • 200 SOUTH BISCAYNE BOULEVARD, SUITE 850 • MIAMI, FLORIDA 33131
PHONE. 305.374.5300 • FAX. 305.377.6222 • WWW.BRZONINGLAW.COM
Ms. Olga Zamora, Chief
City of Miami Hearing Boards
June 17, 2017
Page 2 of 2
Should you have any questions or concerns regarding this letter, please do not
hesitate to phone my direct line at (305) 377-6220. Th._Fi' you.
Si
cc: Victoria Mendez, Esq.
John Greco, Esq.
Francisco Garcia
Jacqueline Ellis
Melissa Tapanes Llahues, Esq.
Thomas Robertson, Esq.
Alicia Garcia
Francisco Martinez
Bercow
BERCOW RADELL FERNANDEZ & LARKIN
ZONING, LAND USE AND ENVIRONMENTAL LAW