File Ref. #167
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BEFORE THE CITY OF MIAMI BEACH II. '1 I
MIAMI-DADE COUNTY, FLORIDA 1/;27'!7
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IN RE:
CITY COMMISSION OCTOBER 20, 1999 WAIVER OF
CERTAIN DEVELOPMENT REGULATIONS PURSUANT TO
SECTIONS 142-425(d),(e) OF MIAMI BEACH ZONING
REGULATIONS FOR THE MIAMI CITY BALLET FACILITY
VERIFIED COMPLAINT UNDER SECTION163.3215(4), FLORIDA STATUTES
Pursuant to Section 163.3215(4), Florida Statutes, Complainant, American Riviera
Real Estate Corporation and Palm Court, Inc" file this Verified Complaint as a condition
precedent to the institution of an action pursuant to the cited Section and states as follows:
1. Complainant American Riviera Real Estate Corporation and Palm Court, Inc. are
the owners and lessees of real property located in the City of Miami Beach, Dade
County, Florida, which property is located within 300 feet of the Miami City Ballet
Facility. They are affected parties.
2. On October 20,1999 at a hearing before the City of Miami Beach City
Commission, the City Commission approved Resolution No. 99-23370 Granting a
Waiver of Certain Development Regulations, Pursuant to Section 142-425(d) and (e)
of the City's Zoning Ordinance, for the Miami City Ballet Facility, Located in the Collins
Park Area, within the City's Proposed Cultural Campus; Said Waiver regarding the
Ballet Facility's Required Parking Under Chapter 130 of the Land Development waiving
parking impact fees. This waiver of impact fees and parking requirements is
inconsistent with the Miami Beach Comprehensive Plan and contrary to the
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']
requirement of maximizing off-street parking for each development. See also letter
from Stanley Price to Mayor and Members of the City Commission dated October 20,
1999 filed with the City Clerk.
3. The relief sought by the Complainant is that the City of Miami Beach City
Commission reverse the waiver of impact fees or declare the impact fees waiver to be null
and void.
oixiJi&-
KENT HARRISON ROBBINS
1224 Washington Avenue
Miami Beach, Florida 33139
(305) 532-0500
Florida Bar No. 275484
VERIFICA TION
STATE OF FLORIDA
COUNTY OF MIAMI-DADE
I, KENT HARRISON ROBBINS, (DL R152-508-54-2110 do hereby swear and affirm upon
direct personal knowledge that the information set fo is tr~rrec
KENT HARRISON ROBBINS
P
NOTARY PUBLIC
RAUL QUESADA
~)fo '~ COMMISSION # cc 528524
. EXPtAEI JAN 22, 2000
IONDI!D THRU
.. A1\NmC IONDING CO., INC.
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CERTIFICATE OF SERVICE
I, KENT HARRISON ROBBINS, do hereby certify that service of this Verified
Complaint was made by hand within thirty (30) days after passage of the challenged
resolution, that is, on November 19, 1999 to the office of the Clerk of Miami Beach and City
Attorney, 1700 Convention Center Drive, Miami Beach, Florida 33139~
NT HARRISON ROBBINS
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