HomeMy WebLinkAboutAppeal Letter to City CommissionHolland & Knight
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Holland & Knight LLP I www.hkiaw.com
June 16, 2015
VIA HAND DELIVERY
Ms. Christine Hwa
Hearing Boards Coordinator
Office of Hearing Boards
City of Miami
444 SW 2°a Avenue, 3rd Floor
Miami, Florida 33130
In6s Marrero-Priegues
305.789.7776
ines.marrero@hklaw.com
Re: Banner Storage Group, LLC/ Appeal of the Decision by Miami Planning Zoning
and Appeals Board approving the appeal of Warrant No. 14-0059 for Public
Storage Facility at 5609 NE 2 Avenue (PZAB-R-15-034; City File No. 15-
00405wt)
Dear Ms. Hwa,
The undersigned is the legal representative for Banner Storage Group, Inc. ("Banner").
In accordance with Section 7.1.1.5 of Ordinance 13114, the City's Zoning Ordinance (known as
"Miami 21 "), this letter constitutes the timely appeal by Banner of the decision by the Planning
Zoning and Appeals Board, PZAB-R-15-034 (City File No. 15-00405wt) on June 3, 2015,
approving the appeal by two abutting property owners of the Planning Director's Warrant for a
Public Storage Facility at 5609 NE 2 Avenue.
The decision to approve Mr. Pierre's and Ms. Simioni's appeal and rescind the Planning
Director's issuance of the Warrant was not based on substantial competent evidence. The
appellants did not present any substantial competent evidence to demonstrate that the City's
Planning Director erred in approving Warrant No. 14-0059 for a Public Storage Facility per
Section 7.1.2.4 (d) of the Zoning Ordinance. In fact, Mr. Pierre was absent from the PZAB
hearing.
Atlanta I Bethesda I Boston I Chicago I Fort Lauderdale I Jacksonville I Lakeland I Los Angeles I Miami I New York
Northern Virginia I Orlando I Portland I San Francisco I Tallahassee I Tampa I Washington, D.C. I West Palm Beach
Ms. Christine Hwa
Office of Hearing Boards
June 15, 2015
Page 2
We respectfully request a hearing before the City Commission to hear and consider
Banner' appeal of the decision of the Planning Zoning and Appeals Board. Enclosed is a check
in the amount of $ 5,136.20 for the appeal fee.
Should you have any questions regarding the foregoing, please do not hesitate to contact
me at (305) 789-7776 or email me at ines.marrero@hklaw.com.
Respectfully submitted by,
HOLLAND & KNIGHT LLP
Ines Marreo-Priegues
Enclosures