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Motion2 CELU20200000904 FOGGS INVESTMENTS LLCCODE ENFORCEMENT. COLLIER COUNTY, FLORIDA Office of the Special Magistrate BOARD OF COUNTY COMMISSIONERS, COLLIER COI]NTY, FLORIDA Plaintiff, vs.CASE NO.: CELU20200000904 FOGGS INVESTMENTS LLC, ResPondent. MOTION TO DISMISS NOTICE OF VIOLATION IN CASE NUMBER CELU2O2OOOOO9O4 OR LIMIT HEARING COMES NOW, Responden! FOGGS INVESTMENTS LLC, by and through its undersigned counsel, and pursuant to the Rules and Regulations goveming Code Enforcement proceedings in Collier County and files this Motion to Dismiss the Notice of Violation dated May 11,2020, in Case Number CELU20200000904, as a violation ofRespondent's right to procedural due process or, in the altemative, limit the Hearing set for August 7, 2020, on the Notice, and in support thereof, Respondent would state as follows: Notice of Violation l. On May 11,2020, Foggs lnvestments LLC ("Foggs") was served with a Notice of Violation that stated: Description of Conditions CoNtituting the Violation(s): Did witness: The processing/recycling Gravel, Stone/Concrete and earthly material without a conditional use. [Exh A]. 2. Whether a hearing on a Notice ofViolation is conducted by fte Code Enforcement Board or the Special Magistrate, the burden ofproof is on the Prosecutor to show by a preponderance of Page I of 12 evidence that a violation does exist and the violator committed or was responsible for maintaining or allowing the violation to continue. [Section 2-2029(4) Collier County Code ofOrdinances] 3. Foggs will not be required to defend against the stated violation unless Collier County proves, by a preponderance ofthe evidencer, that: a. Foggs was processing gravel, or Foggs was processing stone or Foggs wils processing concrete or Foggs was processing earthly [src] material; or b. Foggs was recycling gravel or Foggs was recycling stone or Foggs was recycling concrete or Foggs was recycling earthly [src] material; and c. Foggs did not have a conditional use to process gravel, or did not have a conditional use to process stone or did not have a conditional use to process concrete or did not have a conditional use to process earthly [sic] material; or d. Foggs did not have a conditional use to recycle gravel, or did not have a conditional use to recycle stone or did not have a conditional use to recycle concrete or did not have a conditional use to recycle earthly [src] material. 4. The Notice ofviolation stated the alleged activity was in violation ofthe collier county Land Development Code ("LDC"), as amended, Section 2.02.03, Prohibited Uses, which reads: Any use or structure not specifically identified in a zoning district as a permitted use, conditional use or accessory use shall be prohibited in such zoning district. [Exh B]. 5. A fair reading ofthe stated violation in the Notice and the stated reference to LDC Section I In those cases initiated by a Notice ofViolation, the County shall proceed first with the presentation of its evidence to prove that a violation has occurred. [Collier County Special Magistrate, Rules and Regulations, Article VII, Section 2(g)1. + Ifbefore the Code Enforcement Board, the county shall present its case first. [collier county code Enforcement Board, Rules and Regulations, Article D((i)1. Page 2 of 12 2.02.03, put Foggs on notice that it could be required to defend against the allegations that it was a.) processing or recycling, b.) that it was processing or recycling gravel, stone, concrete or earthly material, and c.) that such was a violation of its conditional use zoning. Foggs could anticipate that if, in fact, any alleged activity was fomd to be in violation of its conditional use zoning, then that alleged activity would need to cease. 6. The Notice listed the "corrective action" that Foggs must take: 2. Cease any and all unauthorized activity... This corrective action supports Foggs "fair reading" ofthe Notice of Violation. 7. Ifthe above was the relevant entirety ofthe Notice, Foggs would not have any basis for requesting dismissal of the Notice, but the Notice contains much more. The Notice also indicates that Foggs is in violation of LDC Section l.M.0l(A) which reads: (A). The provisions ofthis LDC shall apply to all land, property, and development in the total unincorporated area of Collier County except as expressly and specifically provided otherwise in this LDC. No development shall be undertaken without prior authorization pursuant to the LDC. Specifically, no building, structure, land or water shall be hereafter developed or occupied, and no building, structure or part thereof shall be erected, reconstructed, moved, located, or structurally altered except in conformity the regulations set forth herein and for the zoning district in which it is located. [Exh C]. 8. Foggs is without knowledge as to why LDC Section 1'04.01(4) was included in the Notice.2 There is no reference to a buitding or structure included in the noticed Description ofthe 2 If before the Special Magistrate, the "charging document shall include a statement ofthe facts and circumstances ofthe alleged violation and shall identifo the code or ordinance that has been violated." [collier county Special Magistrate, Rules and Regulations, Article v, Section l]. Ifbefore thr code Enforcement Board, the code Enforcement Investigator files an ..Affidavit of Violation which shall include a statement of the facts and circumstances of the alleged violation and shall identiS the code or ordinance that has been violated.." [Collier County Code Enforcement Board, Rules and Regulations' Article VII, Section ll' Page 3 of 12 Violation, and indeed Code Enforcement knows with absolute certainty that no building or structure is involved. Investigator John Fuentes has been on the Foggs property numerous times since this investigation was opened in luruary,2020, and more importantly, the Description ofthe Violation begins with the phrase, "Did Witness..." Nor is a violation included in the Notice that involves a building or structure of any kind and the inclusion ofthe reference to LDC Section 1.04.01(A) in the Notice of Violation violates due process and the Rules and Regulations goveming any Code Enforcement proceeding. (See, fn.l). 9. That is not all. Apart from requiring all unauthorized activity to cease, the "Order to Correct Violation(s)" directs Foggs to take additional corrective action: l. Must comply with all land use standards of the Collier County Land Development Code 04-41, as amended and adhere to the approved Site Development Plan for said location." The Notice of Violation alleges Foggs is angaged in unauthorized activity related to the processing or recycling of gavel, stone, concrete or earthly material, and should Code Enforcement provide competent and substantial evidonce that any of that is a violation ofFoggs conditional use zoning, then Collier County wants the unauthorized activity to cease. The remainder ofthe requested remedy has no relationship to the stated violation and is not supported by any facts or circumstances in the Notice. Collier County's demand for this corrective action violates due process. There is still more in the Notice. The "order to correct violation(s)" also demands Foggs: 2. "Cease any and all unauthorized aclivity..." which Foggs agrees would be an appropriate remedy if a violation was proved up. But then, the statement of the corrective action continues, ")rlrrcl, is nof permitted, accessory, or an approved conditional use for that location ." Page 4 of 12 In other words, Collier County's demand for corrective action is notjust to cease "any and all unauthorized activity'' related to the alleged processing or recycling of gravel, stone/concrete and earthly materials, but all unauthorized activity. However, the Notice fails to inform Foggs of what other "activity" Collier County had determined is "unauthorized," and fails to again inckude the facts and circumstances that constitute the violation. Collier County can only get the remedy is seeks here ifthe alleged offensive unknown and unauthorized activity is disclosed to Foggs for the first time at the Hearing, again a violation ofhis right to procedural due process. 3. "Must obtain all required Collier County approvals, if applicable, by any means required to operate the processing/recycling activities or remove all related materials all related material and equipment for unapproved uses on said land'" This requested reliefis patently outside the scope ofthe alleged violation, impermissibly invades Foggs constitutional righs as a private property owner and is classic govemmental overreach. If the evidence shows that Foggs was in some way in violation of its conditional use, then it is Foggs' decision, and only Foggs decision, to "obtain all required Collier County approvals to operate the processing/recycling activities, " ,o continue the activity. This demand exceeds Collier County Code Enforcement's authority under both the state and federal constitutions. Furthermore, the alleged violation is for t}te processing or recycling ofgravel, stone, concrete or earthly material- collier county has not alleged Foggs is in violation of its conditional use permit by having gravel, stone, concrete and earthly material on its property to sell, and indeed it cannot3, therefore it is unknown what ..related materials" collier county thinks must be removed. Nor has collier t Foggs conditional use specifically provides that it can sell mulch, stone, fertilizers, pesticidJs and other products...accessory to or required for the planting or maintenance of said plants. [LDC, Section 2.03.01(cX2l). one would assume that stone would include gravel, and "earthly material" would be required for planting. Page 5 of 12 County disclosed in the Notice what "equipment" it deems a violation ofthe LDC and what authority it has to force the removal of that equipment. 10. Finally, the bottom ofthe Notice contains a paragraph ofvery small type that begins with a "t" but refers to nothing else in the Notice. It states: "This violation may require additional compliance and approval from other departments which may be required under local, state and federal regulations, including, but not limited to: right-of-way permit, denotition of strucare, Site Development Plan, Insubstantidl Change to Site Development Plan, and Vafiances along with, payment of impact fees, and any new or outstanding fees requiredfor approval. " There is nothing about the alleged violation or the obvious remedy if the violation is proven by Collier County that relates to these "additional requirements." Collier County seeks to obtain an Order to Comply directed to Foggs, without disclosing any facts and circumstances, much less proving them to get this requested remedy. Once again, the Notice violates Foggs' right to due process and violates the Rules and Regulations goveming any Code Enforcement proceeding' I l. collier county code Enforcement sent Foggs a Notice with a "Description ofconditions Constituting the Violations." To comport with due process, that Notice was required to inform Foggs ofthe specific violation(s), so Foggs understood what collier county must prove to prevail and it could defend against the allegations. Nothing about most of this Notice provides the constitutionally required information and Collier County understands this. 12. what code Enforcement seeks is to do here is use the Notice to Foggs and the ensuing Hearing, to bootstrap remedies for what it apparently perceives are violations committed by Foggs without disclosing the specific violations to Foggs and without assuming the burden ofproviding competent and substantial evidence ofthose violations. It seeks to leave Foggs in the dark and without the opportunity to object and present defenses to the unknown violations at the scheduled Page 6 of 12 hearing. 13. The Notice is nothing but "gotcha govemment" and violates every principle of fair play and procedural due process. Procedural due process protects a citizen from such conduct by a govemmental entity because such conduct undermines the public's confidence that agencies of govemment will be fair and impartial in the enforcement of laws against citizens. 14. Where a Notice violates procedural due process, it must be dismissed 15. Should it be decided that neither the Special Magistrate nor the code Enforcement Board has the authority or discretion to dismiss the Notice of Violation, then it must issue an order limiting the Hearing scheduled for August 7, 2020, to the stated violation' the facts and circumstances constituting that specific violation and, should the violation be proved by Collier County, the obvious and narrow remedy sought in the Notice. There is clear authority for such a limiting order in chapter 162.07 which states in regard to the conduct ofa hearing, that "[F]ormal rules ofevidence shall not apply, but fundamenlal due process shall be observed and shall govern the proceedings )' Ch. 162.07(3), Fla. Stat. (emphasis added) Memorandum of Law Procedural due process imposes constraints on governmental decisions that deprive individuats of liberty or property intetests. Massey v. Charlotte County, Florida,842 So.2d 142,144 (Fla. 2d DCA 2003'), ciring, County ofPasco v Riehl,620 5o.2d229,231(Fla. 2"d DCA 1993). The outlines of procedural due process are well-established. Under the Fourteenth Amendment, the fundamental requisite ofdue process is the opportunity to be heard. Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306, 3 14 ( 1950). An elementary and fundamental requirement of due process in any proceeding to be accorded finality is notice reasonable calculated, under all Page 7 of 12 circumstances, to apprise interested parties ofthe pendency ofthe action and afford them an opportunity to present their objections. Dswson v. Saada,608 So. 2d 806, 808 (Fla. 1992) citing, Mullane, supra. The extent ofprocedural protection varies with the nature ofthe proceeding involved, but due process requires both notice and a real opportunity to be heard "at a meaningful time and in a meaningfulmanner}'Hadleyv.DepartmentofAdministation,4ll So.2d184, 187 (Fla. 1982);. Keys Citizens for Responsible Gov't, Inc. v. Fla. Keys Aqueduct Authority,795 So. 2d 940, 948 (Fla. 2001). The notice has to be of such nature as to reasonably convey the required information. Supra, ciling, Mullane, 339 U.S. at3l4 The Second DCA has addressed what information is required in a notice in the context of a Code Enforcement proceeding. Massey,$42 So. 2d at 145. It found that when considering Chapter 162, it was often necessary to fill the procedural gaps [in Chapter 162] by the common sense application ofbasic principles ofdue process.a Supra. The same would be true of the only slightly more specific notice requirement in the Collier County LDC' [ftr. 2, below] The court cited three relevant factors to decide what process is due: a Chapter 162.06(l) says in relevant part here: .....if a violation is found, the code inspector shall notiry the violator and give him or her a reasonable opportunity to correct the violation' " Section 2-2026 Collier County Code ofordinances states: Ifa violation ofa code or ordinance is believed to exist, the code Enforcement officer shall provide notice and speciff a reasonable time to correct the violation(s). Notice shall be given in iwiting and shall specifu the alleged violation, the required corrective action and the time period for correction. Page 8 of 12 l) the private interest that will b€ affected by the official action; 2) the risk of erroneous deprivation ofsuch interest tlrough the procedure used; and 3) the government's interests and burdens that additional or substitute procedural requirements would entail. Supra al 146, citing Keys Citizens for Responsible Gov't, Inc., 795 So.2d at34849 l) The Private Interest Affected: Foggs clearly has a compelling interest in retaining and conducting its business without govemmental interference. It is not clear from the Notice Collier County sent to Foggs how much of its business Collier County seeks to shut down for unspecified violations ofthe LDC, but even a cursory review ofthe remedies it wants to impose on the business shows how broadly Collier County wants to permanently affect Foggs' business. 2) The Risk of Erroneous Deprivation Through the Procedure Used: The risk to Foggs of an erroneous deprivation based on the Notice, is enormous. Call the Notice "gotcha government," call it "hiding the ball" " bad faith," or cynical govemmental overreach. The remedies Collier County seeks to impose on Foggs represent a deliberate attempt by a govemmental agency to shut down a business, without the necessity of disclosing any concrete violations that would justifi such a shut-down and without the necessity of proving those undisclosed violations with substantial and competent evidence. 3) The Government's Burden for Additional Procedural Requirementss The government has no additional burden here. The Notice provided to Foggs represents the failure ofa govemment agency to do its job and cite, in the Notice, the required specific violations, the required facts and circumstances that indicate a violation ofthe LDC, and the remedies it seeks for those violations as dictated by the Rules and Regulations goveming Code Enforcement Page 9 of 12 proceedings, Collier County Ordinance, the LDC and Florida statutes. It cannot claim that compliance with state and local law and the state and federal constitutions, is unduly burdensome. Appllng the Massel three factor examination ofwhat process is constitutionally required here, it is clear that" at a minimum, FoCgs is entitled to know all the alleged specific violations of the LDC that Collier County seeks to enforce, all the facts and circumstances supporting each violation and what remedy it seeks for each specific violation. In the alternative Massey dictates that due process requires limiting the Hearing to the alleged noticed violation, the facts and circumstances it alleges that support finding a violation and the limited and logical remedy ifa violation is proved by substantial and competent evidence. It can't be argued the Procedures outlined in Article Four ofboth the Code Enforcement Board and Special Magistrate Rules and Regulations cure the due process infirmities. Section 4 requires the Code Enforcement Investigator to submit a charging packet of information detailing the alleged violations to the Secretary of the Board or office of the Magistrate at least fifteen business days prior to the Hearing. While the alleged "violator" is allowed to provide an answer/response packet, it must be submitted five business days prior to the Hearing' There is no specific time stated in the Procedures for delivery ofthe Code Enforcement charging packet to the alleged "violator." Even if it was delivered to the alleged "violator" at the same time it was submitted to the Special Magistrate or the Board, the alleged violator will only have ten days to prepare a defense and has thus been deprived ofthe thirty-day window between delivery of the Notice of violation and the Notice of Hearing and the thirty-day window between the Notice of Hearing and the Hearing to investigate the alleged violations and prepare a defense, including witnesses, documentary evidence and subpoenas. And, it is not clear Collier County is under any Page l0 of 12 obligation to put anything in its charging packet beyond the single violation that was Noticed to Foggs. On July 2, 2020, the Fifth DCA addressed the issue ofnotice in a domestic violence proceeding where the Petitioner, at the Hearing, was allowed to introduce, over objection, evidence of additional acts of domestic violence that were not alleged in the Petition for Injunction. In finding the court erred in allowing the testimony, the 5'h DCA said adequate notice must provide some indication ofthe witnesses to be called and the evidence to be utilized to prove entitlement to relief. I G. G. v. M.5.,2020 WL 3579766. The two new material allegations, raised for the first time at the hearing, deprived the Husband ofthe right to due process as he was given neither proper notice of these allegations nor a full and fair opportunity to prepare to rebut them. The same reasoning applies here. The Notice to Foggs contains an unrelated claim of violation of the LDC, without any alleged facts and circumstances supporting the violation and numerous requests for remedies not even remotely related to the disclosed violation. Foggs has been deprived of proper notice and the oppornrnity to prepare a defense to most of the Notice of Violation. The deprivation constitutes a violation ofFoggs right to procedural due process. The violation ofa litigant's due process right to be heard requires reversal or, in this case, dismissal ofthe notice. S.B.L. v. State,737 So. 2d I l3l (Fla. InDCA 1999), citingto, Riehl, 635 So. 2"d at 19. In the altemative, due process and Florida law require the Hearing be limited to the stated violation, Section 2.02.03 ofthe LCD directly relating to the alleged violation, and the obvious and constitutional remedy stated in the notice for t]re violation. WHEREFORE, Respondent, FOGGS II'n/ESTMENTS LLC, respecttully requests dismissal of the Notice dated May 11,2020, in Case Number CELU20200000904, or limitation of Page 1l of 12 the Hearing set for August 7 ,202A, to accord with procedural due process, and the award of its costs, pursuant to F.S. 57.105. itted on behalf of Respondent by: J. Florida Bar MacALISTER, Esq. :080471 I LAW OFFICES OF COLLEEN J. MacALISTER, P.A 5061 NapoliDive Naples, Florida 34103 Phone: (239)262-3760 FAX: (239) 790-5779 colleen@cjmaclaw.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that three true and correct copies of the foregoing have been mailed by US Mailto the Office of the Special Magistrate, c/o Collier County Code Enforcement, 2800 North Horseshoe Drive, Naples, Florida 34104, and a true and correct copy has been mailed by US Mail to: Collier County Board of County Commissioners, 3301 Tamiami Trail East, Building F, Naples, Florida 34112 on this 12'h day of July 2020. J. MacALISTER Florida Bar No: 080471 I Page 12 of 12 .a COI-UER GOUNTY CG)E ENFORCENE}JT t{oTlcE oFvtoLATloH Ormm FOGC'S II{\€STITENTS LLC lszT0IMM(}KALEE ED NAPLES, FL 3{120 Begtstersd AgGn$ Fogg, Stanley R Jr l-oc.fion: 102?0 lmrml$abc RD, Naples 34120' L6call0n: 10270 |rnrnol(alee RD, Naples Unincorporzted Colla.r CoultY Zooing DiEE rlprca&y u"gal D*crlotion: 25 {8 26 E l/2 Of Nw 114 OF NE 1/4, LESS ORII{E ur 3es2 FG r35 Fotb:19(60006 Caee l{umbec CELUAn000lPlf4 DeE: liay 1t.2020 krveiligrtofi .lohn Fucnkt '|hor*: 239')52b'12'? TAKIHG OEEC IN $R ilonce Fursurnt to Gqdlier Coufi Con$did.t€d CoOe entOrCemed R'guLliom, Collier Counly- Code- of Ler: rnd Ordinencer, Cfreper Z. Articte lX, you aru noEnld th-t ' Ybhtioil(sl ol fhe lolbwing Coj1ior County Ordinenoc6f rnd or PUD Regutatira(:) Gd*ts st the abovedatcritxd bcetion' ffitnencelCorle: Garroral provin,ions l.snd Use. ColLc, County [-€nd DeYolopment ffie &{41 as 'sH*n#d, Section 1 04.01{A} The Collier Ga{n$ Land Opretopncnt Code, 2004-41, As Arnended, S€L{on 2 02 03' ProhrBrted Usee A. t'fie rfovieicnE of thi: LDC shd aFply lo 8lt lard, Prop+{y rnd de|Telcfmc$t rn tne-roEil unirffirporstect a'€e o{ Collier County 6rcopt es erprotfy itii ip"r*ntury ilg,/lded o$Enrisc iritus LDC No derre*r:pment stall bc rndertatren withoqr *or a*ffi$]n prlrJti1f*1DC- Spacifi<zq;, rc buildirq',rfuciure' lsnd of watcr $hsg herea{t€f be ds{€loped. o, grB.ipied, and no hddinE. llruchlfG, or pea fhereot thal be *rected' recptdtuCtX{' mo.r€d, locd€d, or *rt ,arr"ff-ir.&-"i,*rx i, cotfirnt;ry *tn fte' regulations tel torlh llBr€in ard rorrP roftirE disrid in which rl i$ lo61.d.: Any use or slrusture not speciFcally identlfrcd in a zani|lg disBict as a permitted u3e' sonditional us8' or aci:ssory use shall lr€ prohibited in ilclr zoning dtqtrirJ : Ybtatbn Stelue - lnitial DESCRtPTloil oF coNnmoils coilsr]TunfiG-Tl+E vlol-ATl0ll(s)' DE Yfrtnsss: fhe ptos.tt*ii'gl6Eing Gmva' gtoncJConcrete and rerthly metedal wiElout E conditlonal usc. qffi the loBo'ring cocrecrive a6rion{s): lnitiat InsPection l.MuslCornplywithelltandusesilEadardsoftheGolliercounvLandDeveloprnentcode04-4{'er arftEnded and Brr#;;;1;"po**o Stte Derelcpmcrrt Plan iqr sed lrcation' 2ceffieanylauuflautrffiiz€dacriviry*,whlch!snotap€rmitle(t.fficessory.o'EneppfoYed condrtionst uge lar said locahon' EXHIBIT A 3- Must sbtein afl required Collier County aoprcr€ls, if applicabla, hy arry neans rcquirsd to opB,frc the proaessing/recycling adivitiet or re,nove aE lElated met€nal and equiprneni br unapproved used sn said loqstofl, Ot{ OR BEFORE: 05,31120?0 Failure to correct violetions maf rssufr in: l ) Mandatory nolice to *pp".r - t*ance o, a citatron fia( may rc+utt in finet up to t500 and cosl3 af Prmecuiisn. OR 2l CoOe Enhrcement Boarct revis\v that may r€utt in nnes up ta S't0o0 pcf day pcr violaiion, rs 10ng ;rs th€ viotstion remains. and oosts of proseculon- INOUIRIES AXD COMMENTS SHOULD BE DIRECTEO TO CODE ENFORCEMEI{T 2800 ifortr Horseshoe Dr. t*aptes, FL 34104 Pione: 23925?-?{40 FAX 235252'Z3/,O SERVED BY: lnvect{abr Signature John Fuentes Care Nunb*r: CELU202OO000!P{ *' Signature and Ti!08 ol Rec,Pient -PrinteO Nsne of Recipieot Oete :.,r:.,,.tr*llfitiamrarrnqdnrddBodErrnslLoarrh,lrpr@ydfromoanrd.psrbr.fiE.ritfiEhE rb._nqrdrtd,trrdsrlo6d. *r.u urd tdcr.r n3uiliiiil r,a,,c,'s' dt 1atttil'ffi-*qJr,lr, Pfli qry'g;1ffiffiJ f,#ffi ffios,,er.n t*tttt*-t.kriiuiJri* cnrfr |o8b Dq.rdop|natt nHr. ildvrrbnEti u ary fict{ o, outBho(llng fte3 rE"quart{ lo apprutd' Collier County, FL l,and Development Code 2.02.03 - Prohibited Uses Any use or structure not specifically identified in a zoning district as a permitted use, conditional use, or accessory use shall be prohibited in such zoning district. abouLblank lofl EX{IBITB 7l7l2O, r:46 PM Collier County, FL [,and Development Code 1 .04.01 - Generally A. The provisions of this LDC shall apply to all land, property and development in the total unincorporated area of Collier County except as expressly and speciflcally provided otherwise in this LDC. No development shall be undertaken without prior authorization pursuant to this LDC. Specifically, no building , structure , land or water shall hereafter be developed, or occupied, and no building , structure , or part thereof shall be erected, reconstructed, moved, located, or structurally altered except in conformity with the regulations set forth herein and for the zoning district in which it is located. B. The regulations established in this LDC and within each zoning district shall be minimum or maximum limitations, as the case may be, and shall apply uniformly to each class or kind of structure , use, land or water, except where specific provision is made in this LDC. C. ThisLDCshall applytoall division of land and all subdivisions in the total unincorporated area of Collier County, except to the extent as expressly provided herein. lt shall be unlawful for any person to create a subdivision ol or to subdivide, or to otherwise divide, any land in the total unincorporated area of Collier County, except in strict conformance with the provisions of this LDC and any applicable provisions of the Collier County Growth Management Plan (GMP). E)CIIBITC about:blank lofl 7l7l2O, l:44 PM