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HomeMy WebLinkAboutBack-Up DocumentsFiling # 190114756E-Filed 01/19/2024 12:56:19 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO. 2024-000994-CA-01 BHENA'S, INC., a Florida corporation, Plaintiff, vs. CITY OF MIAMI, a municipal corporation and subdivision under the laws of the State of Florida, Defendant. / SUMMONS THE STATE OF FLORIDA: To Each Sheriff/Certified Process Server of the State: 0,0 \" Li- c73 U23 5-6/PrJ YOU ARE COMMANDED to serve this summons with a copy of the Complaint in this action on Defendant: By serving: CITY OF MIAMI c/o Victoria Mendez, City Attorney Office of the City Attorney 444 S.W. 2nd Avenue, Suite 952 Miami, Florida 33130 Defendant is required to serve written defenses to the complaint or petition on: Ariella Gutman, Esq., Haber Law, LLP, 251 NW 23 Street, Miami, FL 33127, within twenty (20) days after service of this summons on that Defendant, exclusive of the date of service, and to file the original of the defenses with the Clerk of this Court either before service on Plaintiffs attorney or immediately thereafter. If a Defendant fails to do so, a default will be entered against that Defendant for the relief demanded in the complaint or petition. Dated this day of I /21/2O24 2024. JUAN FERNANDEZ-BARQUIN Clerk & Comptroller, Miami Dade County In accordance with the Americans with Disabilities Act of 1990, persons needing a special accommodation to participate in this proceeding should contact the Court ADA Coordinator no later than seven (7) days prior to the proceedings. Telephone 1-800-955-8771, for assistance. IMPORTANTP Usted ha sido demandado legalmente. Tiene veinte (20) dias, contados a partir del recibo de esta notificacion, para contestar la demanda adjunta, por escrito, y presentarla ante este tribunal. Una llamada telefonica no lo protege* si usted desea que el tribunal considere su defensa, debe presentar su respuesta por escrito, incluyendo el niimero del caso y los nombres de las partes, interesadas en dicho caso. Si usted no contesta la demanda a tiempo, pudiese perder el caso y podria ser despojado de sus ingresos y propiedades, o privado de sus derechos, sin prevvo aviso del tribunal. Existen otros requisitos legales. Si lo desea, puede usted consultar a un abogado inmediatamente. Si no conoce a un abogado, puede llamar a una de las oficinas de asistencia legal que aparecen en la quia telefonica. Si desea responder a la demanda por su cuenta, al mismo tiempo en que presenta su respuesta ante el tribunal, debera usted enviar por correo o entregar una copia de su respuesta a la persona denominada abajo como "Plaintiff/Plaintiffs Attorney." (Demandate o Abogado del Demandante). IMPORTANT Des poursuites judiciaries ont ete entreprises contre vous. Vous avez 20 jours consecutifis a partir de la date de l'assignation de cette citation pour deposer une reponse ecrite a la plainte ci- jointe aupres de ce Tribunal. Un simple coup de telephone est insuffisant pour vous proteger; vous etes oblige de deposer votre reponse ecrite, avec mention du numero de dossier ci-dessus et du nom des parties nommees ici, si vous souhaitez que le Tribunal entende votre cause. Si vous ne deposez pas votre reponse ecrite dans le relai requis, vous risquez de perdre la cause ainsi que votre salaire, votre argent, et vos biens peuvent etre saisis par la suite, sans aucun preavis ulterieur du Tribunal. I1 y a d'autes obligations juridiques et vous pouvez requerir les services immediats d'un avocat. Si vous ne connaissez pas d'avocat, vous pourriez telephoner a un service de reference d'avocats ou a un bureau d'assistance juridique (figurant a 1'annuaire de telephones). Si vous choisissez de deposer vous-meme une reponse ecrite, it vous faudra egalement, en meme temps que cette formalite, faire parvenir ou expedier une copie au carbone ou une photocopie de votre reponse ecrite au "Plaintiff/Plaintiffs Attorney" (Plaignant ou a son avocat) nomme ci- dessous. 2 Filing # 190043835 E-Filed 01/18/2024 03:32:41 PM IN TI-IE CIRCUIT COURT OF THE l l Tl JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO. BIIENA'S, INC., a Florida corporation, Plaintiff, vs. CITY OF MIAMI, a municipal corporation and subdivision under the laws of the State of Florida, Defendant. COMPLAINT TO QUIET TITLE Plaintiff, BHENA'S, INC., ("Plaintiff'), by and through its undersigned counsel, hereby sues Defendant, the City of Miami, a municipal corporation and subdivision under the laws of the State of Florida ("Defendant") and hereby alleges as follows: PARTIES, VENUE, AND JURISDICTION 1. This is an action to quiet title in real property located in Miami -Dade County, Florida pursuant to Fla. Stat. §65.061. 2. Plaintiff is a Florida corporation that owns real property located in Miami -Dade County, Florida which is at issue in this dispute. 3. Plaintiff is whole owned by an individual Bhena Lall who is a resident of Guyana and does not reside locally. She resides internationally. 4. Defendant is a municipal corporation and subdivision under the laws of the State of Florida and is located in Miami -Dade County, Florida. Page 1 of 8 HABER LAW, P.A. 251 NW 23RD STREET, MIAMI, FLORIDA 33127 5. The Property (as defined below) at issue in this litigation is located within Miami - Dade County, Florida. Thus, venue is proper in Miami -Dade County, Florida pursuant to Fla. Stat. 047.051, and this Court has jurisdiction over the subject matter of this action pursuant to Fla. Stat. §26.012(2)(g). GENERAL ALLEGATIONS 6. Since 2003, Plaintiff has owned the property located at 301 Northwest 25th Street, Miami, Florida 33127 (the "Property"), which is legally described as: Parcel 1: Lot 14, less the South 10 feet, of WOODLAWN TRACT, AN ADDITION TO THE CITY OF MIAMI, according to the Plat thereof, as recorded in Plat Bok 1, at Page 148, of the Public Records of Dade County, Florida now known as Miami - Dade County, Florida ("Parcel 1" )1 and Parcel 2: Lot 13, and the West 35 feet of Lot 14, in Block 1, of HIGH RIDGE, according to the Plat thereof, as.recorded in Plat Book 9, at Page 56, of the Public Records of Dade County, Florida now known as Miami -Dade County, Florida ("Parcel- 2") and Parcel 3: Lot 1, and the East 15 feet of Lot 2, in Block 3, of HIGI RIDGE, according to the Plat thereof, as recorded in Plat Book 9, at Page 56, of the Public Records of Dade County, Florida now known as Miami -Dade County, Florida ("Parcel 3") 7. Plaintiff is the owner of the Property and obtained title by virtue of that certain Warranty Deed dated October 3, 2003 and recorded at OR Book 21726, Page 3565-3566 in the Public Records in and for Miami -Dade County, Florida on October 8, 2003. This address encompasses three (3) parcels; however, the "Property" that is subject to this litigation is limited to Parcel 1. Page 2 of 8 HABER LAW, LLP 251 NW 23RD STREET, MIAMI, FLORIDA 33127 8. Throughout the course of Plaintiff's ownership of the Property, Plaintiff hired a property manager, David Peralta ("Peralta") who mislead Plaintiff as to his operations on the vacant lot and drove the property into disrepair by neglecting same. 9. Plaintiff engaged Peralta to ensure that the property was in compliance with all governmental laws and regulations, safe and secured due to the fact that Plaintiff lives abroad; Although there was no written contract in place, this agreement was put into place as a result of Plaintiff's trust in Peralta, with the expectation that Peralta would advise Plaintiff of any issues with the Property. 10. Peralta created Golden Parking System, LLC D/B/A Omni Parking ("Golden Parking") and sought to formalize a lease agreement with Plaintiff in order to use the Property for parking and valet. Under the terms of the lease, Golden Parking was to undertake all necessary steps to legally operate its parking business. in accordance with all governing laws and regulations. 11. In May of 2021, unbeknownst to Plaintiff, Golden Parking System LLC, run and operated by Peralta, was cited by the City of Miami with Code Enforcement Violations (Case No. CE2021010121), for: (1) alleged unlawful establishment of an unusual or new use without prior approval at hearing; (2) alleged performance of work without a permit and/or permit not finalized; (3) alleged non-conformance of parking lot with the off-street parking guides and standards; (4) alleged failure to register the vacant lot with the City of Miami; (5) alleged failure to maintain the lot in a safe, clean condition by not allowing the accumulation of debris, trash or dense growth of grass; (6) alleged allowance of graffiti on the Property; (7) alleged failure to obtain a valid certificate of use for the type of business being conducted; and (8) alleged failure to obtain a business tax receipt for the type of business conducted. Page 3 of 8 HABER LAW, LLP 251 NW 23RD STREET, MIAMI, FLORIDA 33127 12. The City of Miami's Violation citation, which was posted on the Property in May of 2021, required compliance by June 1, 2021. 13. Pursuant to the Lease in place between Plaintiff and the Golden Parking, Landlord delivered the Property to Golden Parking without any violations or liens thereupon. Additionally, pursuant to the Lease, Golden Parking's obligations included, but were not limited to, the following: (1) obtaining any permit fees relating to Golden Parking's work or which are normally and customarily charged and/or required by any Governmental Authority as a result of, or in connection with Golden Parking's work; (2) obtaining any necessary permits to complete Golden Parking's work; (3) constructing Golden Parking's work in a "good and workmanlike manner" and in compliance with all applicable laws and building codes, lien free, and diligently prosecuted to completion; (4) keeping and maintaining in good order, condition and repair, and in accordance with all Governmental Regulations, the Property, including but not limited to the ground beneath the Property. the Property's foundation, sub -floor, structural components, and non-structural components; (5) removing all graffiti within a reasonable period of time; and (6) paying any penalties imposed for failure to comply with any of these obligations. 14. Pursuant to the Lease, Plaintiff was under the reasonable expectation that: Golden Parking was complying with its obligations under the Lease; that Peralta would notify Plaintiff of any non-compliance with the Lease terms; and Peralta would notify Plaintiff of any violation citations issued against the Property and ensure that Golden Parking would correct any such violations and comply with any such citations. 15. Though service of the subject violation citation was accomplished with the "letter" of the City Code Enforcement by posting the violation citation upon the Property, Plaintiff was not Page 4 of 8 HABER LAW, LLP 251 NW 23RD STREET, MIAMI, FLORIDA 33127 actually placed on notice of such citation due to the fact that neither the Golden Parking, nor Peralta, advised Plaintiff of said violations, and Plaintiff lives abroad. 16. Unfortunately, as Plaintiff also later found out, Golden Parking did not comply with the citation by correcting the violations and notifying the Inspector of such corrections by June 1, 2021. 17. Thereafter, the City of Miami Code Enforcement Board sent, by U.S. Postal Service Certified Mail to Grizel Gil (the registered agent) at his address in Coral Gables, Florida, and to Plaintiff at an address in Miami (despite Plaintiff's mailing address having been updated as of February 2021 to a New York address, as provided in Sunbiz), a "Notice of Violation Summons to Appear" letter, dated September 17, 2021, advising of the non-compliance with the prior violation citation and commanding appearance at a hearing before the Code Enforcement Board on October 13, 2021 at 5:00 p.m. 18. Plaintiff never became aware of this letter and did not appear before the Code Enforcement Board for the hearing on October 13, 2021. 19. At the hearing on October 13, 2021, the Code Enforcement Hearing Board found that the Golden Parking violated the City Code due to the failures listed in paragraph 7 of this Complaint, above. 20. On October 14, 2021, the Code Enforcement Hearing Board issued a "Final Administrative Enforcement Order" (the "Order"): (a) advising the Golden Parking of the Board's findings; (b) instructing the Golden Parking to correct the violations identified therein, advise the Inspector of such correction, and obtain an Affidavit of Compliance by October 14, 2021; (c) imposing daily fines of $1,000.00 per day, to begin accruing thereafter, for failure to comply with such Order; and (d) advising that the Order constitutes a lien against the Property and any other real Page 5 of 8 HABER LAW, LLP 251 NW 23RD STREET, MIAMI, FLORIDA 33127 or personal property owned once it was recorded in the Public Records of Miami -Dade County. A true and correct copy of the Final Administrative Enforcement Order is attached as Exhibit "A." 21. Plaintiff finally received notice of the violations, citation, hearing and Order on December 7, 2021 via e-mail from Patricia Pires (an Administrative Assistant to Fernando L. Ortiz, P.A., Certified Public Accountant) to Bhena Lall, owner of the Plaintiff entity, containing a copy of the Order. 22. Upon receipt of the Order, Plaintiff immediately fired Peralta as its property manager, terminated the lease with Golden Parking and began the process of correcting the violations. 23. The alleged deficiencies were subsequently fully cured by the Plaintiff on September 19, 2023. See Communication from the City and attachments thereto, attached hereto as Exhibit 24. A lien, related to the City of Miami Code Enforcement Board's Final Administrative Enforcement Order, exists upon the Property. 25. Based upon the recorded lien the City imposed daily fines on Plaintiff in the amount of $1,000.00 per day starting on the date of the order, for a total of 705 days, up to and including the date of compliance on September 19, 2023. 26. To date, the total fine imposed amounts to $705,000.00 and constitutes a lien on the Property. 27. Before filing this cause of action, Plaintiff communicated with Defendant in an attempt to mitigate the fines to no avail. 28. All conditions precedent to the filing of this action have been performed, excused or have been waived. Page 6 of 8 HABER LAW, LLP 251 NW 23RD STREET, MIAMI, FLORIDA 33127 COUNT I — QUIET TITLE 29. This is an action to quiet title pursuant to FLA. STAT. §§65.021 and 65.061. 30. Plaintiff incorporates and realleges the allegations in paragraphs 1 through 28 are incorporated as if set forth fully herein. 31. The Final Administration Enforcement Order imposes a lien on the Property. 32. Defendant may claim an adverse interest in the Property by virtue of the aforementioned lien. 33. Defendant does not have a lawful or legitimate interest in the Property, and any interest in the Property, if any, is subordinate and inferior to the Plaintiffs right, title and interest in the Property. 34. Plaintiff is authorized to bring an action to quiet title to the Property and the Other Properties and to clear any cloud on their title. See Section 65.031, Florida Statutes ("An action in chancery for quieting title to, or clearing a cloud from, land may be maintained in the name of the owner or of any prior owner who warranted the title.") 35. Plaintiff has a compelling interest in removing the cloud of title imposed by the Order and the lien because the title of the Property is currently unmarketable. WHEREFORE, Plaintiff respectfully requests that this Court enter a judgment in its favor and against Defendant extinguishing any right or claim that Defendant may have in the Property, and removing any and all clouds on title to the Property, and quieting title in the Plaintiff, together with any and such further relief as this Court deems necessary to protect Plaintiff's rights and interests to the Property. Dated this 181I' day of January 2024. Page 7 of 8 HABER LAW, LLP 251 NW 23RD STREET, MIAMI, FLORIDA 33127 Respectfully submitted, HABER LAW, LLP Counsel for Plaintiff 251 NW 23rd Street Miami, FL 33127 Tel: (305) 379-2400 Fax: (305) 379-1106 E-Mail: service(crhaber.law By: /s/ Ariella Gutman ARIELLA GUTMAN, ESQ. Fla. Bar No. 91447 agutman@haber.law jlewin@haber.law JEREMY APISDORF, ESQ. Fla. Bar No. 671231 j apisdorf,haber.law Page 8 of 8 HABER LAW, LLP 251 NW 23RD STREET, MIAMI, FLORIDA 33127 of lam' THE CITY OF MIAMI, FLORIDA CODE ENFORCEMENT BOARD vs. BEIENAS INC 300 NW 26 ST MIAMI, FL 33127-4118 33127-4118 Tenant: October 14, 2021 CR: CE2021010121 Case No: CE2021010121 Address: 301 NW 25 ST Folio: 0131250330090 Legal: WOODLAWN TR PB 1-148 LOT 14 LESS S I OFT LOT SIZE,4400 SQ FT OR 17232-3232 0696 1 OR 17232-323 1 1095 5 COC 21726-3565 10 2003 2 Hearing Date: October 13, 2021 FINAL ADMINISTRATIVE ENFORCEMENT ORDER The Code Enforcement Board has found you guilty of violating the following laws: - 2160 Unlawfully establishing an unusual or new use without prior approval at hearing. Miami 21 SECT 7.1.2 - 2104 Work performed without a permit andlor permit not finalized. City Code SEC 10-3 (FBC 104, 105), Miami 21 section 7.1,2 - 21 15 Parking lot not conforming with the Off-street parking Guides and Standards., Miami 21, SEC 3.6.3 ART ART 4 TBL 3.7.2 - 1698 Failure to register vacant lot with the City of Miami. City Code SEC 22-1 15 - 21 80 Failure to maintain lot in a safe, clean condition; not allowing accumulation of debris, trash or dense growth of grass, City Code Section 22-1 16, I 17, 1 18 - 2 187 Graffiti on Property. City Code SEC 37-2 - 2111 Failure to Obtain a valid certificate of use for the type of business being conducted. Miami 21 section 7.1.2.1(b). Miami 21 Article 4 - table 3, City Code 2-207 - 2151 Failure to obtain a business tax receipt for the type of business conducted. City Code Chapter 31 You are hereby ordered to correct said violation by October 14, 2021, If you fail to comply by said date, you will thereafter be fined the sum of S1000 per day. It is your responsibility to advise the Inspector immediately after the violation has been corrected to obtain an Affidavit of Compliance. Failure to obtain an Affidavit of Compliance will result in the continuing accrual of the daily fine. This Order shall constitute a lien against the above referenced property and any other real or personal property that you own once it is recorded in the Public Records ofMiami-Dade County. LIENS THAT REMAIN UNPAID FOR THREE (3) MONTHS MAY BE FORECLOSED IN COURT. In addition. the Certificate of Use and Occupational License of any business occupying this property may be suspended or withheld. Operating a business without all required licenses is illegal under state and city law, and is punishable by criminal arrest and/or closing the business. Should you have any questions regarding this Enforcement Order. or if you wish to advise the Code Enforcement Board that the violation has been corrected, please call Yacmany Salvatierra at Cell Phone Number: (786) 696- 0034 or Office Phone Number: (305)416-2087, City of Miami Code Enforcement Board This is to certify that the foregoing is a true and correct copy of the document on file dated October 14, 2021 of the Code Enforcement Board. Officially filed and rendered on October 14, 2021 in the records of the City of Miami, Hearing Boards. n"'; Prepared by: 0Jga,Zarnora • Deputy Clerk of Hearing Boards From: To: Subject: Fvvtl - tonclay at 10 AM RE: 301 NW 25 Street Violations Date: Friday Sepre n,tberP Z 3023 1:58:51 FM Attachments: n5 5 rS imaixi0.eta toctimctalica imnne...:..cm Forwarded message From: Gomez .1r., Luis-1 ircnLsz Date: Toe, Sep 19. 2023 a1 •1:37 PM Subject: RE- Automatic reply. Monday at 10 AM RE: 301 NW 25 Street \'ioLmon, To: Jordan Gimelslein cior I•r loin >lal •inmm> Lauzurique, Marcelo . \I I augBl_k Cc: Troutman. Genesis <+ 11021 11inec_ltLat1.11540..C.0111> Good afternoon Mr Gimelstei n, Inspector was able to comply the last violation remaining. The case shows as open until the pending fine / lien is paid in full. Below is the pending lien in the amount of $705,000.00. Below is the online link for payment details. Attentively, Luis Gomez Field Supervisor - (Central District) City of Miami Department of Code Compliance 444 S.W. 2nd Avenue - 7th Floor Miami, FL. 33130 Department Line: (305) 416-2087 Direct Line: (786) 696-0235 LGomezreatauiiPPV ants Website: J],ttps://..ffis YuliamIpoX.CR.IniCio)'.eC1ll112R1iDepariine11I5S0LgaL7A7,s'IALQAIS.C9Ste.:.C.4117pli.an.c_e Please Share Your Thoughts With Us: hllps://www sulyejinatilaey eomx/,I3YP2MZ AFTER FLOURS C'O))I: COMPLIANCE I:IOTLINE: If you are experiencing a non -emergency issue outside of the hours of operation our after-hours hotline, please call the Miami Police non -emergency line: (305) 579-6111. If you are experience an emergency, please dial 911. From: Gomez Jr., Luis Sent: Tuesday, September 19, 2023 10:50 AM To: Jordan Gimelstein <jgy3)anginielntnju] (.gmaiLcont>; Lauzurique, Marcelo <ML atzarjtae Lmiamig.QY.L.o.m> Cc: Troutman, Genesis <etrounnanO3liniamigov com> Subject: RE: Automatic reply: Monday at 10 AM RE: 301 NW 25 Street Violations Good morning Ole, Gimelstein, I have transferred case It CE2021010121 to Inspector Lauzurique because Ms. Troutman is out on military leave. Inspector Lauzurique. Please see details below to update and comply the last outstanding violation tor subject property I3elow you will see there was a demo permit finalized to resolve the outstanding violation for the parking lot / concrete Perform your field inspection to verify and please update the case in (itys to, You would need to issue an affdaw of compliance once you comply the violation Email bad; to all once complete. Thanks, Luis Gomez, Field Supervisor City of Miami Department of Code Compliance — Central Office 444 SW 2 Ave, 7tt' Floor Miami, FL. 33130 Direct Line (Cell): (786) 696-0235 Departmental Line: (305) 416-2087 1 Gomezr)miam'fnv com AFTER-IIOURS HOTLINE: From: Jordan Gimelstein <jordamdmelsteinggtltail com> Sent: Tuesday, September 19, 2023 7:09 AM To: Troutman, Genesis <otromtnn r(� n'st niE ov com> Cr: Gomez Jr., Luis <J Gonlez , t iia aj sao Equp> Subject: Re: Automatic reply: Monday at 10 AM 18E: 301 NW 25 Street Violations Hi Luis I believe we are complied now with all violations. I had received an automatic response front inspector'froutman. Can you please let me know. Thanks Jordan Gintelstein 305-610-3711 Sent from my iPhone On Sep 16, 2023, at 3:42 PM, Troutman. Genesis <rarn dnt•ut(i0lni•nnigov corn wrote: Thank you for your message. I a If you need immediate arr etau:� Kind Regards, Senior hrpraer Tro;trnan Jordan Gintelstein 305-610-3711 Yet. •t:av ,tt-r. t ags 6-mez (Mb) 69e-02a5 i,,.„=Pre, r6u t ecogI{ ne tfte sender amd lnom• the ennlent is snfe,:l L.. r . • RLN CCN Comments A Notsecurp1 . CFN :Book 'Start Page End Page Date ReCorded Lien Released. Lien Ott 27, 2021 date format: MM/DDIYYYY Pending Lien? Ea Lien Type AC567,',. Lien Cleared? E Cerfify Lien Ei OK To Certify? Installments. Cerfified?LJ Lien Raid, :1 Lien Paid? FA_ Pending Date lOct 15, 2021 Lien Clear Date! Certified Date Amount Certified Jeelitiont. XeWit, Tyne » Type :ere to Amount Entered Idy YSaWatierra on Oct 15, 2021. .Modifted by CCarnpana on Dec 03, 2021. ,New Fee • Quantity. ...tetit., • Save Balance Lien Costs 1705.;:000. 00 : C 4rte 87F Partly sunny " 9A.M 44) 9.119/20.23 Portal initiation Address Zane Polio D:13125t337(i13 Date Compliance•Due. Status Date Complied Violation lnspecto Complied Sep 19;:2023 Complied Jun 1.4, 2i023,; Complied Jun 22;'2023 Complied' Jurt4'2023;. Complied Jun`22;,2023, Complied, Jun 14,,2023 Complied Jun, 4; 2023•, Violation 2104` 2115 1698 2180 2137', 2111. 215'1' Oct 4, 2021', Yacrrtany' Salvatierra Yacmany;saivatiema YacmanySaivaJerra Yacmany'SsJvaJerra Ya latiy Satuatier e :: fcriam} Satvatierra 'Yacros ri5ti �Salvatierm Current Page and Compliance Process Case Type Code. Enforcement NOV Parking on Unimproved Surfaces Status E?pen Tracking:Nurrrber ` Case: Number Description CE2021a1O121 "New Violation work performed wi 1oU e peat1i#.artdlezr prn3it riot fi;rialized. Parking lot not conforming wrth the (J.r:,street parking Guides and Stand . Pai i-re to regeiervacantlot wah-t e Ci:y of It/56 '. enure to maintan lot in a;safe. clean; condition; not allowing accurmulari on Prop.eriy .. to O%tafrr a valid certificae for te type ouiebeing,hfss a business tax recerpt tar the Type oftiusiness,conduct Save 2160 = Unlawfully'estabtist irig:,an ur usua r ; Status Complied inspector l"acir rartySalvatierrai Violation Date ViiaY20, 2021 Violation lime ]0g:17 Alp 3 , Type here to sea u eseripian ly esiaEs[rsiring era tarries tal or ie. use rgrt out pnor ap. V