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HomeMy WebLinkAbout2004 09 21 Attached Handed Out by Eloise Sahlstrom, Community Development DepartmentDate: September 21, 2004 ATTACHED HANDED OUT BY ELOISE S AHL S TROM, COMMUNITY DEVELOPMENT DEPARTMENT 09!21104 TUE 16:5a FAX 407 84a 4444 LDDK&R ~100L Lowndes Drosdick Doster Kantor Reed, EA. A T 7 p R N E Y S A T L A W VIA FACSIMILE Ms. Cathy Davidson Code Enforcement Inspector City of tiVinter Springs, Florida JnrveT M. C )URT>vEY biR~.[~rDln; 407118-6353 NORTH EOLt DRNE OFFICE Pos'r OFFICt Bqx 2809 ORLANtJ(J, F .ORIDA 32802-ZBO~ janetcourtn~ y©lowndcs-law.ccm 111 MERITI 5 LAN! FIRMS WaRIDWIDE September 21, 2004 Ra_: Complaint No. 04-0005642, City of Winter Springs Code Enforcenr~ rrt Dear Ms. Davidson: Please be advised that tlus law firm represents Mr. Bartholomew D. Phillips Mr. Phillips ias brought to o7.>r attention a Statement of Violation he has received for alleged non-cc ifoiming uses on property he owns located at 600 Old Sanford Oviedo Road. Please be advised that the property located at 600 Old Sanford Oviedo Roac is >!¢t used fc r a junkyard as described in the Statement of Violation and Notice of Hearing and t gat open outd nor storage is a legal conforming use. it additionally is zoned I-1 and not C-1 as rcflecte~ . in the Statement of Violation. Although. Mr. Plullips has an interest in property nearby that is zoned ,-l , kt~at propf rty is not properly described in the Statement of Violation auld proper notice has not bee i given under the City Code or due process. Please also be advised. that we have been retained to analyze potential eau ces of action ~ /Ir. Phillips possesses against the City of Winter Springs in connection with the zoning c ranges that affect his properties, including but not ]invited to, an unconstitutional violation of the equal protection cla.>se under the U.S. Constitution, unconstitutional discrimination against interstate comme ce under the L ~.S. Constitution, and that enactment of the ordinances was arbitrary and capricious. We ire in the process of undertaking that analysis on his behalf. V truly yours, Janet M. Co ey JMC/jlk c: Mr. Bartholomew D. Phillips (via telecopy) ltiranda. F. Fitzgerald, Esquire Clay Deatherage, Esquire 21 S NURTI I EOl_A L7RTV$ 4SO sC ITiI ORANGE A~~ENU: , SUI"1'E HOO ORLANDO, l1LOlt1UA 32$01-2028 TEL:407-8436(}0 ~ FAX :407-843.4444 ~ www.lowndes-law.com Otu.ANOq Fr,oRmA 32801.3344