HomeMy WebLinkAboutSubmittal-Andrew Genden-Complaint for Declaratory Relief, Permanent Injuction and Breach of ContractFilieig # 67027372 E -Filed 01/25/2018 12:04:57 PM
CAROLINE WEISS, individually and
in all other capacities,
Plaintiff,
V.
RANSOM -EVERGLADES SCHOOL, INC.,
Defendant.
Submitted into the Pt )tic
record for it m(s) h, �5
can City Clerk
IN THE CIRCUIT COURT OF THE 11 Tx
JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
CASE NO.
COMPLAINT FOR DECLARATORY RELIEF, PERMANENT INJUNCTION AND
BREACH OF CONTRACT
Plaintiff, CAROLINE WEISS, individually and in all other capacities ("Weiss") hereby files
her Complaint for Declaratory Relief, Permanent Injunction and Breach of Contract against
Defendant, RANSOM -EVERGLADES SCHOOL, INC. ("Ransom"), and in support thereof,
states as follows:
INTRODUCTION
1. This is an action for declaratory relief and permanent injunctive relief, whereby Weiss
seeks to prevent Ransom from developing on property located at 3187 Royal Road, Miami, Florida
33133 together with 3575 Main Highway, Miami, Florida 33133 and 3551 Main Highway, Miami,
Florida 33133, in direct violation of the Agreement By The Parties Ransom And Weiss Executed
& Notarized on July 22, 2010 (the "Agreement"), which is attached hereto as Exhibit "A".
2. Additionally, Weiss has asserted a breach of contract cause of action, wherein she seeks
damages from Ransom, pursuant to its violation of the Agreement.
C,
SCHLESINGER & ASSOCIATES, P.A.
800 BRICKELL AVENUE • SUITE 1400 • MIAMI, FLORIDA 33131 • TELEPHONE 305.373.8993 • FAX 305.373.8098
pMi\( r t, o,ca 0,01 V\-\t�jQ��r�a��n�t uc�o,n ap t
Submitted into the ptblic
record r it rn({ E. , 45
on City Clerk
PARTIES, JURISDICTION & VENUE
3. Weiss is an individual, sui juris and resides in Miami -Dade County, Florida.
4. Ransom is a Florida not-for-profit corporation organized pursuant to Chapter 718, Florida
Statutes, whose directors own and operate a secondary school for grades 6 through 12, which are
located at two (2) separate real properties in Miami -Dade County, Florida.
5. The Court has jurisdiction over this matter under Section 26.012, Florida Statutes, to the
issue involving injunctive relief
6. Venue is appropriate in Miami -Dade County pursuant to Chapter 47, Florida Statutes,
because the causes of action accrued in Miami -Dade County and the property at issue is located in
Miami -Dade County.
7. All conditions precedent to this action have been met, waived, excused or have occurred
and this action was properly commenced.
GENERAL ALLEGATIONS
The Agreement and Ransom's Violation
S. On July 22, 2010, Ransom and Weiss entered into the Agreement, which is valid and
binding on the respective parties.
9. On July 30, 2013, the Agreement was recorded in the Official Public Records of Miami -
Dade County (Book No. 28749/Page Nos. 0057-0064).
10. Pursuant to the Agreement, Ransom provided Weiss with $50,000.00 in escrow for the
pu1-i)oses of makin- Royal Road in Miami, Florida a private street.
11. Since the Agreement was entered into, Ransom has failed to comply with the same.
12. In fact, Ransom has declined to support the abandonment and closure of Royal Road.
z
SCHLESINGER & ASSOCIATES, P.A.
800 BRICKELL AVENUE - SUITE 1400 • MIAMI, FLORIDA 33131 • TELEPHONE 305.373.8993 - FAx 305.373.8098
Submitted into theublic
recur foal "m s) L.1� � t. t,5
on _I _. City Clerk
13. Since entering into the Agreement, Weiss has taken substantial steps in order to ensure the
abandonment and closure of Royal Road as a private street. See "A Community Beautification
Project Proposed By Caroline Weiss", which is attached hereto as Exhibit "B".
14. On several occasions, Weiss sought Ransom's support and cooperation by providing it with
the necessary applications and other documents needed in order for Miami -Dade County to re -plat
Royal Road as a designated private street.
15. Despite repeated requests from Weiss, Ransom did not sign the requisite application
signature documents for the re -plat of Royal Road as a private street.
16. Such signature pages, had they been executed by Weiss and Ransom, would have greatly
assisted in the abandonment and closure of Royal Road as a private street. Thus, Ransom's failure
to cooperate with Weiss is in contravention of the Agreement.
17. In addition to the foregoing, since the execution of the Agreement, Ransom has engaged
in demolition projects on its property and has failed to place screens between its demolition sites
and Weiss' property on Royal Road.
18. Such failure on behalf of Ransom caused dust and debris to travel from Ransom's property
to Weiss' property on Royal Road, which is in violation of the Agreement.
Ransom's Failure to Maintain Property Pursuant to Agreement with Weiss
19. Subsequent to executing the Agreement, Ransom entered into an agreement with Weiss
that it would maintain and extend its southern border wall from Lot 8 of its property located at
3575 Main Highway, Miami, Florida 33133 to the northern edge of Lot 7, which is the property
owned by Weiss at 3187 Royal Road, Miami, Florida 33133.
3
SCHLESINGER & ASSOCIATES, P.A.
800 BRICKELL AVENUE - SUITE 1400 • MIAMI, FLORIDA 33131 � TELEPHONE 305.373.8993 • FAx 305.373.8098
Subnyitted into the p
record for itvm(s) is
on City Clerk
20. In violation of this agreement, Ransom has failed to extend and close such wall from the
northern edge of Lot 7 to the existing wall that is in place on Ransom's property at the southern
end of Lot 8.
21. Such failure by Ransom has caused unwanted ingress and egress from Ransom's property
onto Weiss' property.
Ransom's Proposed Development Plans Violate the Agreement
22. Subsequent to entering into the Agreement, Ransom provided Weiss with its future
development plans in regard to the following properties that it owns: (1) 3575 Main Highway,
Miami, Florida 33133; and (2) 3551 Main Highway, Miami, Florida 33133, which is purchased in
June 2016.
23. These proposed development plans have been submitted to the City of Miami for approval.
24. However, upon reviewing the proposed plans, it is evident that Ransom wishes to further
violate its Agreement with Weiss.
25. Pursuant to these plans, Ransom seeks to demolish the structures located on Lots 9, 10 and
11 of the property that it owns at 3575 Main Highway, Miami, Florida 33133, and construct an
"emergency access" gate on Lot 8 and an "access gate" on Lot 13 on the same property, which
would provide direct access to said property via Royal Road.
26. The Agreement provides that "[i]n the event that the Structures on Lots 9, 10, and 11 are
demolished, a continuous wall will be placed on the northern side of Royal Road commencing
where the existing wall ends at f .ot 8 and continuin ,.4 uninterrupted to the wall at Lot 12 at the
southern property line of the Ransom lots." See Exhibit "A" at ¶ 15.
27. As such, Ransom seeks to violate the Agreement by constructing gate access points on
Royal Road subsequent to the demolition of its existing structures on Lots 9, 10 and 11.
4
SCHLESINGER & ASSOCIATES, P.A.
900 BRICKELL AVENUE - SUITE 1400 • MIAMI, FLORIDA 33131 • TELEPHONE 305.373.8993 • FAx 305.373.8098
Submitted into the pt lie
record for it F11(sY
nn 1 City Clerk
COUNT I — DECLARATORY RELIEF
28. Weiss re -alleges and incorporates paragraphs 1-27 above as if fully set forth herein.
29. Weiss seeks declaratory relief pursuant to Chapter 86, Florida Statutes.
30. The Agreement is a covenant that runs with Ransom's property located at 3575 Main
Highway, Miami, Florida 33133.
31. Weiss is uncertain about the nature of Ransom's rights with respect to the proposed
development on its property.
32. Weiss contends, but Ransom denies, that Ransom is prohibited from its proposed
development of its property, including, but not limited to, the current plans it has filed with the
City of Miami.
33. Weiss contends, but Ransom denies, that this obligation arises from the express terms of
the Agreement.
34. Weiss contends, but Ransom denies, that Ransom cannot proceed with its proposed
development of its property.
35. Ransom contends, but Weiss denies, that its proposed development of its property are
proper.
36. There is a bona fide, actual, present and practical need for a declaration from the Court.
WHEREFORE, Weiss respectfully requests that this Court declare the rights and obligations
of the parties, as follows:
a. that the Agreement is a covenant running with the land;
b. that the Agreement prohibits the proposed development of Ransom's property;
c. that the Court afford supplemental injunctive relief as is necessary and proper to
accomplish the foregoing; and
5
SCHLESINGER & ASSOCIATES, P.A.
800 BRICKELL AVENUE • SUITE 1400 - MIAMI, FLORIDA 33131 - TELEPHONE 305.373.8993 • FAx 305.373.8098
Submitted into the blic
on J/tJ / 1 � C=ity Clerk
d. award Weiss her reasonable attorney's fees and costs pursuant to the Agreement.
COUNT Ii — PERMANENT INJUNCTION
37. Weiss re -alleges and incorporates paragraphs 1-27 above as if fully set forth herein.
38. This is an action for permanent injunctive relief to enforce the restrictive covenants and
easements that run with Ransom's property, the Agreement and the property rights acquired by
Weiss.
39. Ransom had notice of the restrictive covenants and are subject to them.
40. The restrictive covenants contained in the Agreement prohibits the proposed development
on its property.
41. Ransom's proposed site plan constitutes a breach of the restrictive covenant contained in
the Agreement.
42. Weiss has a clear legal right to enforce the restrictive covenant because she is a party to
the Agreement.
43. Furthermore, paragraph 19 of the Agreement provides as follows:
Conditions stated in paragraph 2-18 of this agreement shall be
governed and construed in accordance with the laws of the State of
Florida; (2) any disputes concerning the validity, interpretation or
performance of any of the terms or provisions hereof, or of any right
or obligation of Ransom or Weiss, shall be resolved in accordance
with the laws of the state of Florida, and (3) the prevailing party in
any litigation concerning enforcement of this agreement and/or
conditions contained in the City Commission Resolution shall be
entitled to be reimbursed by the other party for attorney's fees and
court costs, including the costs of appeal.
See Exhibit "A" at ¶ 19.
44. Should Ransom proceed with its proposed development on its property, Weiss will suffer
irreparable injury.
45. Weiss has no adequate legal remedy and injunctive relief is appropriate.
SCHLESINGER & ASSOCIATES, P.A.
800 BRICKELL AVENUE - SUITE 1400 - MIAMI, FLORIDA 33131 - TELEPHONE 305.373.8993 - FAx 305.373.8098
Submitted into thl
Lrecord or it=W t
on City Clerk
WHEREFORE, Weiss requests that the Court grant permanent injunctive relief by issuing an
Order: (1) preventing Ransom from proceeding with its proposed development plans in
contravention of the restrictive covenants and the Agreement; (2) requiring Ransom, to the extent
that it can develop anything on its property, to make that the development is controlled by the
Agreement; (3) awarding Weiss her reasonable attorney's fees and costs pursuant to paragraph 19
of the Agreement; and (4) for such further relief the Court deems proper.
COUNT III — BREACH OF CONTRACT
46. Weiss re -alleges and incorporates paragraphs 1-27 above as if fully set forth herein.
47. Ransom and Weiss entered in a valid contract, the Agreement.
48. Ransom breached the Agreement by failing to: (1) provide its support and cooperation in
regard to the abandonment and closure of Royal Road; (2) place screens on Ransom's property to
prevent dust and debris from traveling onto Weiss' property; and (3) honor other agreements
relative to the same.
49. Weiss has suffered damages as a result of Ransom's aforementioned breach of the
Agreement.
WHEREFORE, Weiss demands judgment in her favor and against Ransom for damages,
interest, attorney's fees, costs and such other and further relief as this Court deems just and proper.
JURY TRIAL DEMAND
Weiss hereby demands a jury trial on all issues so triable.
7
SCHLESINGER & ASSOCIATES, P.A.
800 BRICKELL AVENUE • SUITE 1400 • MIAMI, FLORIDA 33131 - TELEPHONE 305.373.8993 - FAx 305.373.8098
Submitted into the public
record, for i em(s)
on—I L511S City Clerk
SCHLESINGER & ASSOCIATES, P.A.
Attorneys for Caroline Weiss
800 Brickell Avenue, Suite 1400
Miami, FL 33131
Phone: (305) 373-8993
Facsimile: (305) 373-8098
E-mail: mis:u lnisid.com
E-mail: a e��i+mjsj com
E-mail: eservice(a rnsid,corn
By: Is/Michael J. Schlesinger
MICHAEL J. SCHLESINGER
Florida Bar No. 141852
ANDREW S. GENDEN
Florida Bar No. 105156
SCHLESINGER & ASSOCIATES, P.A.
800 BRICKELL AVENUE • SUITE 1400 • MIAMI, FLORIDA 33131 • TELEPHONE 305.373.8993 • FAx 305.373.8098
N'liami-Dade Official Records - Print Document
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record for to t(s}��
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DOCUMENT COVER PAGE
For those documents not providing the required
space on the first page, this cover page must be attached.
It must describe the document in sufficient detail to
prolubit its transference to another document.
An additional recording fee for this page must be remitted.
1?1-�'41 12 -
CFN 201380597967
OR Sk 48749 Pss 0057 - 641 (8v9s)
RECORDED 07/30/4013 15x57313
HARVEY RUVINr CLERK OF COURT
MIAMI-DADE COUNTYr FLORIDA
/j (Spam aabbol a this lice mervad for =ording orrice tree)
Document Title: T�}^.3$ M F_'% RDFS 66 - � (�RfloHit)C (,C t SS
( gam; Beed, Construction Lien, Etc.) T2WTS0 JoL,y -Lr2
Executing Party: WF_15 S
J�Fi'e_F t r �o8P2�S
Legal Description: J 1 1&4 PW, 20 A r-) , —(Z)bftt 0,7- W M+
(If Applicable) SS 75 14,t,-) A 64+ W AtJl M' -t (�,� 331;33
As more fully described in above described document
Return Document To / Prepared By:
O'HaoL, lX� W'Ss
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g(art+ t FL 33133
F.S. 695.26 Requirements for recording instruments affecting real property—
(Relevant excerpts of statute)
(1) No instrument by which the title to real property or any interest therein is i
conveyed, assigned, encumbered, or otherwise disposed of shall be recorded by the +
clerk of the circuit court unless: I
(e) A 3 -inch by 3 -inch space at the top right-hand corner on the first page
and a 1 -inch by 3 -inch space at the top right-hand corner on each subsequent page
are reserved for use by the clerk of the court...
CLK/CT 155 Rev 04/11
Book28749/Page57
CFN#20130597967
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Submitted into tie t)lic
recor for em(S) Z+ j1 , 1
on City Clerk
AGREEMENT BY THE PARTIES
RAMSOM EVERGLADES
AND
CAROLINE WEISS
EXECUTED & NOTARIZED ON JULY 22, 2010
A TOTAL OF 8 PAGES INCLUSIVE
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Submitted into the P bjir
record for enl(s) E 1� � R. I'j
on I L city Cierk
This agreement is entered into this n0 day of,(uly 2010, by and between Ransom Everglades
%("Ransom*) and Caroline Weiss ( se). For and in consideration of ten dollars ($10.00), the
rties agree as follows:
Whereas, the City of Miami issued the Class II Special Permit, Application Number 10-0027,
submitted by Ransom, to the City of Miami in connection with the proposed construction of an
Aquatic Center and other structures to be located on 3575 Main Highway, Miami, Florida (the
'Application'); and
Whereas, Weiss has appealed the Planning, Zoning and Appeals Board Resolution approved on
June 16, 2010; and
Whereas, the parties wish to settle their differences and enter into this agreement; and
Whereas, conditions stated in paragraph 1 will be proffered to the City Commission as conditions
in its resolution; and
Therefore, the parties agree as follows:
Ransom shall provide landscaping on the south side of Ransom's property fine. Said
landscaping and the addition of a concrete wall in place of an existing chain link fence
shag be in accordance with the comprehensive landscape plans attached (Landscaping
Plans of BEA Architecture Dated 7/21/2010 L-01 and L -01a). The obligation to install
such landscaping shall be completed within six (6) months from the time that a permit has
been issued by the City of Miami. Ransom must submit for permit no later than four (4)
months from the time that the Class II permit is final and all applicable appeal periods
have expired.
2. The wall between Lots 7 and 8 will be painted with acoustical paint.
3. Ransom shall maintain the landscaping along the wall frontage located on the southwest
comer of the Upper Campus to include Lot 8 through Lot 13 at the entrance to Royal
Road,
4.)
, Ransom shall make available to Mrs. Caroline Weiss, or her designee, an amount not to
exceed Fifty Thousand and no1100 Dollars ($50,000) for expenses related to seeking
approval from governmental agencies to Gose and abandon (i.e., "dosing') Royal Road
and the costs of plans, permitting, construction, inspection, installation, repairs, and
maintenance of a gate on Royal Road. Mrs. Weiss, or her designee, shall have sole and
exclusive discretion as to the use of such funds, so long as (a) the funds are applied
towards expenses directly related to seeking approval from governmental agencies for
the abandonment and closure of Royal Road, or the cost of construction, installation,
repairs, and maintenance of a gate on Royal Road, and (b) the Royal Road property
owners who have joined in applications for the street 'closing" approve the location and
specifications of the gate. Payment for said costs and expenses shall be made by
Ransom, with the use of Gilberto Pastoriza of Weiss, Serota, Helfman, Pastoriza, Cole &
Boniske, P L. as an escrow agent. Ransom shall authorize disbursement on any and all
invoices related to the Dosing of Royal Road within 5 days of receipt of invoices and
documentation substantiating the costs or expenses to be paid by Ransom.
5. Weiss agrees that any and all obligations of Ransom with respect to expenses related to
seeking approval from governmental agencies regarding the abandonment and closure of
1
i
i
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0S. Royal Road, and costs rafted to the construction of a gate on Royal Road, shall be
limited to those expenses ald costs set forth in the paragraph 4 above.
Ransom shall support the abandonment and closure of Royal Road and shall execute
applications required to be submitted to governmental agencies in connection with the
approval of same, and if asked in writing, shall attend all meetings of local governmental
hearing boards at which the closure of Royal Road and any applications related to same
are scheduled to be heard. Furthermore, Ransom shall execute a letter supporting the
closure of Royal Road, and shalt not object directly or indirectly to any applications for
street closure of Royal Road.
7, Members of the Ransom Community who customarily use the structures on Lots 9, 10,
and 11 will have access to Royal Road as long as the structures on Lots 9, 10, and 11
remain in place. Once the structures on Lots 9, 10, and 11 are demolished, then access
to parking will cease.
8. Ransom shall notify all parents, students, and visitors that they may not park on Royal
Road by having a dedicated box indicating this in their Alumni Log and the Dell and
Cannon publication. Ms. Adeena Weiss shall receive these publications at 3187 Royal
Road, Miami, Florida 33133.
9. Ransom shall maintain its side of the property on Royal Road until the gate is in place
and operational. Ransom shall continue its regular schedule of maintenance. After the
gate is in place, the maintenance of the gate and Royal Road shall be the joint
responsibility of Ransom and Weiss. Each party shall properly insure their respective
interests. Weiss will have the responsibility of securing all legal documents required for a
private street
10. During any construction and demolition, there shall be a screen between the demolition
site and the Weiss property so as to minimize the dust and debris from traveling towards
the Weiss property. Construction will not start any earlier than 7:00 A.M. and will
continue no later than 4:00 P.M., regardless of emergency. No construction is to take
place on Sundays. Construction on Saturdays will not start any earlier than 8:00 A.M.
and will continue no later than 2:00 P.M.
t
111 All outdoor athletic activities will cease at 10:30 P.M. during the weekdays except as
/ required by Florida High School Athletic Association or US Swimming and Water Polo
Association. Outdoor athletic activities on Saturdays will be limited to the hours of 10:00
A.M. to 3:00 RK except as required by Florida High School Athletic Association or US
Swimming and Water Polo Association. No outdoor athletic activities will take place on
Sunday (i.e. pools, athletic field or tennis courts) except the Middle School picnic, once
per year and no more than five (5) community outreach programs per year on weekends
(Saturday or Sunday) on the outdoor athletic venues (i.e. pools, athletic field or tennis
courts).
12. All lights on Ransom's property will be directed onto the Ransom campus. Ransom will
abide by the City's spillage light requirements. Ransom will redirect the two gymnasium
lights onto Ransom's campus, as reflected in Sheet L -01a Prepared by BEA Architects,
and Dated July 21, 2010.
13. In addition to all required notices, Ransom shall notify Weiss of all new plans,
renovations, and modifications in anticipation of new permit applications.
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14. Ransom shall paint, within two months, the walls of the gym and the math and science
building facing the Weiss property to the South, in green to minimize the harshness of the
wails, and to blend in with the landscaping.
15.;In the event that the Structures on Lots 9, 10, and 11 are demolished, a continuous wall
_-' will be placed on the northern side of Royal Road commencing where the existing wall
ends at Lot 8 and continuing uninterrupted to the wall at Lot 12 at the southern property
line of the Ransom lots. The landscaping shall be provided as per Paragraph 1 of this
agreement
18. The alley between the Weiss property and Ransom shall be maintained at all times in an
orderly fashion and not used for dumping or storage, other than for storage of boating
equipment not to exceed five feet in height. Ransom's employees will be directed not
make any bud noises (yelling, music, boom boxes, etc.) In the alley way at any time.
17. The terms and conditions stated in this agreement constitute the only agreement
between Ransom and Weiss. There are no other agreements by and between Ransom
and Weiss. The terms and conditions stated in this agreement supersede any and all
offers that may have been made by Ransom or its agents, or understandings that may
have been reached between Ransom and its agents and Weiss or her agents.
18. Any and all obligations of Ransom set forth in paragraphs 11, 12, 14 and 16 shall
commence within 10 days after the class 11 permit is deemed final and non appealable.
19,' Conditions stated in paragraph 2-18 of this agreement shall be governed and construed
in accordance with the laws of the State of Florida; (2) any disputes concerning the
validity, interpretation or performance of any of the terms or provisions hereof, or of any
right or obligation of Ransom or Weiss, shall be resolved in accordance with the laws of
the state of Florida, and (3) the prevailing party in any litigation concerning enforcement
of this agreement and/or conditions contained in the City Commission Resolution shall be
entitled to be reimbursed by the other party for attomey's fees and court costs, including
the costs of appeal.
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:submitted Into file PPCity
Fecn[k jt�l' it rT�(S�n 3 f/ Clerk
ACCEPTED AND AGREED TO THIS 22nd DAY OF JULY, 2010 BY:
EFF TS
CHAT BOARD OF TRUSTEES
N M EVERGLADES
(STATE OF FLORIDA)
(COUNTY OF DADE)
;��oing trt a nt s acknowledged before me thiso�� day 20j� by
who is Rgrsonally known to me or who has produ
as identification and who did (did not) take an oath.
s*� Name:
awn ►rM • WAb M /rli Notary Public — State of Florida
rrr c. vas tnr. * Commission No.:
• oo ISM My Commission Expires:
r
OLINE WEISS
(STATE OF FLORIDA)
(COUNTY OF DADE)
Thrforegoinginstrument was acknowledged before me thisoZ a day of lvl 20 -`�by
who is personalty kaQ= to me or who has produ
as identification and who did (did not) take an oath.
l IA,4, .` t0aA-4&
Name:
Notary Public — State of Florida
Commission No.:
4NUMaAm" My Commission Expires.
Mwf� NM1 • Mw �f ta14r
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A COMMUNITY BEAUTIFICATION PROJECT PROPOSED BY CAROLINE WEISS
ROYAL ROAD & MAIN HIGHWAY, MIAMI, FLORIDA 33133
PREPARED 8Y: PREPARED FOR: SURVEYOR OF THE RECORD:
Jan Stanbury Caroline Weiss Ford, Armenteros & Manucy, Inc.
ECOTEK Luxury Homes, Inc. 3187 Royal Road 1950 NE 94th Avenue, 2nd Floor
ecotek@usa.com Coconut Groove, Florida 33133 Miami, Florida 33172
786.229.5999 305.477.6472
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CITY OF MIAMI
MONUMENT LINE
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TRACT "A"
(P.B. 80 PG. 24) 20,00'
EXISTING SITE PLAN
FORD, ARMENTEROS & MANUCY INC.
1950 N.W. 94th AVENUE, 2nd FLOOR
MIAMI, FLORIDA 33172
PH (305) 477-6472
80.00'
SET 1/2" IRON PIN
ROC( WALL
EXISTING
MATH CAP L.S. /6557
PROPERTY LINE
aNc+aR
POWER A=86'27'00"
R
A=37.72'
L
°
ANCHOR
R=25.00SET
1/2' IRON PIN
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CAP L& /6557°
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APPROXIMATELY
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LOCATION OF 6'
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STREET CENTER LINE c
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W
/SANITARY Q
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(NO ASBUILT OF RECORD)
/SEWER
MANHOLE
PIN
0 0 0 0 0 0 0 L.B. 06557
4
RIM -17.33
ONLY SERMNG
SIDE OF
0
WARD
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inCHAINWEST
HIGHWAY
o POSTo 63'33'00°�
o m40.82'
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a
°25.00''�ROYA°N
PIN80.00'
LOT 1
P5557
(P.B.
EXISTING SITE PLAN
FORD, ARMENTEROS & MANUCY INC.
1950 N.W. 94th AVENUE, 2nd FLOOR
MIAMI, FLORIDA 33172
PH (305) 477-6472
I- MAIN ENTRANCE VIEW (NORTH EAST SIDE)
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4
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3- MAIN ENTRANCE VIEW (SOUTH WEST SIDE)
2- ROYAL ROAD VIEW
ROYAL ROAD
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s
3- MAIN ENTRANCE VIEW (SOUTH WEST SIDE)
2- ROYAL ROAD VIEW
ROYAL ROAD
4- MAIN HIGHWAY (NORTH EAST SIDE FROM ROYAL ROAD)
t �-
6- MAIN HIGHWAY (SOUTH WEST SIDE FROM ROYAL ROAD)
IA
5- ROYAL ROAD (NORTH WEST SIDE)
4
s
ROYAL ROAD
te� �
1 �',• +- ,1{ f' '+'CYC -A ; e�.
T- MAIN HIGHWAY NORTH EAST VIEW
8- MAIN HIGHWAY SOUTH WEST VIEW
ROYAL ROAD
v.._
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r
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8- MAIN HIGHWAY SOUTH WEST VIEW
ROYAL ROAD
ROYAL GARDENS
LOT 7, BLOCK S
KWAL 4W
MXMT* 41
TRACT "A"
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RANSOM EVERGLADES SCHOOL
ROYAL GARDENS
LOT 13, BLOCK 7
0 wAl.
Mc CORMICK
PROPERTY
LOT 13, BLOCK 8
PROPOSED SITE PLAN
SCALE'N15.
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4 e
VIEW OF THE PROPOSED BEAUTIFICATION