HomeMy WebLinkAboutPre-Publication - Party Status Letter Request - NewmanROBERT N. HARTSELL, P.A.
Federal Tower Building
61 N.E. 1sT Street
Pompano Beach, Florida 33060
(954) 778-1052 — Fax (954) 941-6462
www.Hartsell-Law.com
May 11,2018
Victoria Mendez, Esq.
City Attorney
City of Miami
444 S.W. 2nd Avenue, Suite 945
Miami, FL 33130
Dear Ms. Mendez,
By way of introduction, my name is Robert Hartsell and I represent Ms. JoNel Newman.
Ms. Newman lives at 615 NE 55 Terrace, Miami, Florida 33137. As you are aware, James
Rosenberg is currently appealing the City of Miami Historic and Environmental Preservation
Board's historic designation of Morningside Park, via Resolution HEPB-R-18-001, approved
January 2, 2018 and rendered January 18, 2018.
On behalf of my client, JoNel Newman, I am formally requesting party status for the
appeal to be heard by the Miami City Commission at the meeting scheduled for May 24, 2018.
Pursuant to Section 7.1.4.3(d), Miami 21, my client qualifies as an Intervenor in this proceeding,
as being a property owner less than 500 feet of Morningside Park, she is person whose interests in
the proceeding are adversely affected in a manner greater than those of the general public.
Accordingly, Ms. Newman should be granted status as a party, pursuant to § 7.1.4.3(g), Miami 21,
and permitted to present evidence, call and examine witnesses, cross examine opposing witness
and make final arguments, pursuant to §§ 7.1.4.4(a), 7.1.4.5(b) and 7.1.4.6(g), Miami 21, at the
meeting.
If you have any questions regarding this request, please contact myself at the letterhead
contact information.
Respectfully submitted this llth day of May, 2018.
Sincerely,
/s/ Ra6ent 72. qantQeee
Robert N. Hartsell, Esq.
Robert N. Hartsell, P.A.