HomeMy WebLinkAboutPre-Publication - Party Status Request Letter - Mary FoehrenbachROBERT N. HARTSELL, P.A.
Federal Tower Building
61 N.E. 1ST Street, Suite C
Pompano Beach, Florida 33060
(954) 778-1052 — Fax (954) 941-6462
www.Hartsell-Law.com
April 12, 2018
Miami City Commission
3500 Pan American Drive
Miami, FL, 33133
Dear Chairman Hardemon and Commissioners,
By way of introduction, my name is Robert Hartsell and I represent Ms. Mary Foehrenbach.
Ms. Foehrenbach lives at 655 NE 55th Terrace, Miami, Florida 33137, directly across the street
from Morningside Park (adjacent). This representation is pro bono. 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, Mary Foehrenbach, I am formally requesting party status for the
appeal to be heard by the Miami City Commission at the meeting scheduled for April 26th, 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 directly adjacent to Morningside Park, she is person whose interests in
the proceeding are adversely affected in a manner greater than those of the general public by virtue
of adjacency and direct impacts. Accordingly, Ms. Foehrenbach 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 12th day of April, 2018.
Sincerely,
/s/ god 7Q, 1a/aideee
Robert N. Hartsell, Esq.
Robert N. Hartsell, P.A.