HomeMy Public PortalAboutComplaint from ResidentFebruary 20, 2014
Mr. William Thrasher
Town Manager
Town of Gulfstream
100 Sea Road
Town of Gulf Stream, FI 33483
Re: Code Enforcement Special Magistrate Notification
Move for Postponement
Request to Produce Documentation
Interrogatories
Email and Hand Delivered 2/20/14
Rtaylor @gulf- stream.org
Bthrasher @gulf- stream.org
Dear Mr. Thrasher,
At approximately 11:30 a.m. on February 19, 2014 an armed Gulf Stream Police Officer delivered a
summons for appearance in front of the Code Enforcement Special Magistrate on February 25, 2014
regarding the removal of an existing shed. A cursory review of a calendar would reflect that only three
full 'labour' days would expire prior to the scheduled Magistrate's hearing. Obviously, this does not
allow the Respondent adequate preparation time to consult Council, request supporting
documentation, present Interrogatories, secure witness and expert testimony and construct a cohesive
defense. The Town's failure to allow sufficient time between the summons notification date and the
Hearing date is wilful and injurious to the Respondent's right to comprehensively respond to the
Movant's allegations. On January 8, 2014 1 authored an email addressed to yourself requesting, with
respect to the mediation, "to coordinate dates, items of discovery, interrogatories, mediator etc." in an
effort to move this issue forward on a timely scheduled basis. I have enclosed a reproduction of that
correspondence and your response to assist your recollection. It is our assertion that in the interest of
justice, the Special Magistrate Hearing on February 25, 2014 must be postponed.
Request to Produce Documentation:
1. Site Plans, Staff Report and Surveys for the following properties:
A. 2550 Avenue Au Soleil
B. 810 Canary Walk
C. 800 Canary Walk
D. 815 Canary Walk
E. 2564 Avenue Au Soleil
F. 2900 Avenue Au Soleil
G. 2765 Avenue Au Soleil
2. Staff report from 2007/2008 application, 2562 Avenue Au Soleil
3. Site Plan / Survey from 2007/2008 application, 2562 Avenue Au Soleil
4. Code Enforcement Violations, 2562 Avenue Au Soleil
5. All communications between the Town and Homeowners pertaining to accessory structures
and 'sheds' i.e. Code Enforcement Violations, applications etc.
6. Copies of Town Manager issuance of Certificate of Completion 2007/2008 application, 2562
Avenue Au Soleil
7. All photographs, drawings, written documents pertaining to the 'shed' at 2562 Avenue Au Soleil
8. Original permit application, Staff Report, Building Plans for the original structure, 2562 Avenue
Au Soleil
9. Provide all applicable LDR code sections governing accessory buildings and 'sheds'
10. Provide the all LDR's (Land Development Regulations) definitions of 'shed'
11. Provide the all LDR's definitions of 'metal shed'
12. Provide the all LDR's definitions of 'wood shed'
13. Provide LDR's governing sections regarding 'grand fathering' of Building entities
14. Provide all minutes from the Architectural Review Board and the Town Council pertaining to
'sheds' and accessory buildings
15. Provide all LDR code references to 'sheds' in each code cycle since 1970
16. Provide all written Staff Report objections to the 'shed' at 2562 Avenue Au Soleil
17. Provide LDR code section governing the rear, front and side setbacks for irregularly shaped
residential lots
Interrogatories:
1. What year was the year the current LDR adopted?
2. What are the LDR code cycles since 1970?
3. How was the current LDR adopted?
4. Who is the author of the current LDR?
5. What are the qualifications of Staff with respect to Architecture, Land Development, Planning,
Zoning?
Sincere
Quinn I. MikloYU 2562 Avenue Soleil
Gulf Stream, Fl 33483
Quinn Miklos
From: Bill Thrasher <bthrasher @gulf - stream.org>
Sent: Wednesday, January 08, 2014 4:53 PM
To: Quinn Miklos
Subject: RE: Miklos -Swift Residence
Happy New Year to you Quinn.
The Town will proceed to Special Magistrate on this issue. We will preparing your notice as quickly as possible. The
notice will be somewhat helpful to you in your preparation. You will be communicating with Rita as the process
proceeds.
[III
From: Quinn Miklos [ mailto :quinn @miklosarchitecture.coml
Sent: Wednesday, January 08, 2014 3:29 PM
To: Bill Thrasher
Subject: Miklos -Swift Residence
Hello Bill,
Happy New Year. Thank you for arranging my phone conversation with the City Attorney. I was just following up on the
topic of the mediation regarding the Shed issue. I would like to coordinate dates, items of discovery, interrogatories,
mediator etc. When and who should I coordinate these items with?
Thank you
I I I)k
MIKLO
Quinn I. Miklos, NCARB
Registered Architect
Fl. Reg. AR 91602
Miklos and Associates, P.A.
M iklosArch itecture.com
Phone: 561 - 392 -6762
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