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Agenda 05/09/2023 Item #16K 2 (Litigation Settlement between Collier County and Kendall Perrine, LLC)16. K.2 05/09/2023 EXECUTIVE SUMMARY Recommendation to approve the litigation settlement between Collier County and Kendall Perrine LLC and recommendation to approve the acceptance of $12,000 from Kendall Perrine LLC in exchange for a release of lien with a value of $97,309.70, in the code enforcement action entitled Board of County Commissioners v. Kendall Perrine LLC of Collier County, Case No. CES20210012676. OBJECTIVE: To approve the litigation settlement between Collier County and Kendall Perrine LLC and accept payment of $12,000 from Kendall Perrine LLC in exchange for a release of lien. CONSIDERATIONS: As a result of code violations, the Code Enforcement Board (CEB) issued an Order pertaining to violations of the Sign Regulations on March 24, 2022. Kendall Perrine LLC, the property owner, was found guilty of violating Collier County Land Development Code Sections 5.06.06(A)(1), 5.06.06(A)(7), 5.06.06(A)(8), 5.04.06(A)(2), 5.04.06(C)(4), and 5.06.11(A)(1). The code enforcement violations included unpermitted and prohibited signs installed by Fish 41, the tenant of Kendall Perrine LLC. The signage included snipe signs, banners, flutter flags, wall signs, wall graphics, awning graphics, animated /active signs, vehicle signage and an electronic reader board. The signage had been placed on and around the Fish 41 location to drive business to the location as it had suffered financially during the pandemic. The property was brought into compliance on April 20, 2023. Many of the smaller signs were brought into compliance quickly; however, the property continued to incur daily fines until the unpermitted signage was brought into compliance by obtaining a Certificate of Completion. The partner at Fish 41 who was in charge of bringing the property into compliance passed away during the pendency of the code case which led to delays in the permitting process. On March 24, 2023, Kendall Perrine LLC filed a Notice of Appeal in Circuit Court to challenge the constitutionality of the underlying sign regulations contained within the Land Development Code. The County Attorney's Office, along with Code Enforcement, recommends accepting the reduced settlement amount of $12,000 to avoid protracted litigation on this matter. FISCAL IMPACT: If approved by the Board, accrued fines totaling $85,309.70 would be waived and $12,000 would be accepted as full and final settlement of the Code lien. GROWTH MANAGEMENT IMPACT: There is no growth management impact associated with this action. LEGAL CONSIDERATIONS: The terms of the settlement have been reviewed and approved by Code Enforcement and the County Attorney's Office. In the event the recommended settlement is not approved, the County can expect to incur additional costs associated with litigation through Kendall Perrine's appeal to the Collier County Circuit Court and a positive result can never be guaranteed with any degree of certainty. This settlement is reasonable based upon the totality of the circumstances. This item is approved as to form and legality and requires majority vote for Board approval. -CAK RECOMMENDATION: To waive the remaining fines in the amount of $85,309.70 accept payment amount of $12,000 and authorize the Chair to sign the attached release and satisfaction of liens for recording in the Official Public Records. Prepared by: Colleen A. Kerins, Assistant County Attorney ATTACHMENT(S) 1. Notice of Appeal-Perrine (PDF) 2. lien order(l) (PDF) 3. Release-Perrine (PDF) 4. Settlement letter-Perrine(PDF) Packet Pg. 1309 16. K.2 05/09/2023 COLLIER COUNTY Board of County Commissioners Item Number: 16.K.2 Doe ID: 25363 Item Summary: Recommendation to approve the litigation settlement between Collier County and Kendall Perrine LLC and recommendation to approve the acceptance of $12,000 from Kendall Perrine LLC in exchange for a release of lien with a value of $97,309.70, in the code enforcement action entitled Board of County Commissioners v. Kendall Perrine LLC of Collier County, Case No. CES20210012676. Meeting Date: 05/09/2023 Prepared by: Title: Legal Assistant — County Attorney's Office Name: Rosa Villarreal 04/25/2023 9:29 AM Submitted by: Title: County Attorney — County Attorney's Office Name: Jeffrey A. Klatzkow 04/25/2023 9:29 AM Approved By: Review: Code Enforcement County Attorney's Office Office of Management and Budget Office of Management and Budget County Attorney's Office County Manager's Office Board of County Commissioners Thomas landimarino Additional Reviewer Colleen Kerins Level 2 Attorney Review Debra Windsor Level 3 OMB Gatekeeper Review Christopher Johnson Additional Reviewer Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Amy Patterson Level 4 County Manager Review Geoffrey Willig Meeting Pending Completed 04/27/2023 8:29 AM Completed 04/27/2023 8:40 AM Completed 04/27/2023 8:47 AM Completed 04/27/2023 12:00 PM Completed 04/28/2023 9:45 AM Completed 05/03/2023 10:22 AM 05/09/2023 9:00 AM Packet Pg. 1310 16. K.2.a Case #: 11 -2023-CA-001 553-0001 -XX Offense Date: Party Name/Company: Kendall Perrine Llc, File Date: 03/24/2023 Party Type: Plaintiff Status: Pending Name Suffix: Case Type: Other Circuit Civil DOB: Court Type: CA Citation M Court Events Date Time Event Type Location Room Notes Parties No records found Judge: Unassigned Judge Party Name/Company Party Type Sex Race Date of Birth i AKA 'Deceased Sheriffs # Board Of County Commissioners Collier County, FI ' Kendall Perrine Llc Q . Defendant Plaintiff Charges Statute # Count Description Disposition Date Sentence Offense Citation Offense Plea Court Prosecutor Date # Level Date Action Action 1 Dockets 03/24/2023 Image Docket Num Effective Count Description 1 ❑ 2 ❑ 3 ❑ 4 ❑ 5 Sentences 03/24/2023 03/24/2023 03/24/2023 03/24/2023 03/24/2023 0 0 ., 0 0 0 Other Circuit Civil Complaint Standing Order - Circuit Civil Cover Sheet Paid $400.00 on receipt 1351795, Fully Paid Date Count Sentence Confinement Term Credit Time Conditions Status No records found r a Packet Pg. 1311 Fees 16.K.2.a Fees Total Balance + Interest: $0.00 (The fees listed below do not necessarily reflect all outstanding fees on the case. For complete balance information, please contact the Clerk's office.) Effective Due Amount Amount In In Judgment Date Date Description Due Paid Balance Collections Judgment Anterest 03/24/2023 03/24/2023 Circuit Civil $400.00 $400.00 $0.00 $0.00 General $400.00 $400.00 $0.00 $0.00 Fees Plan # Scheduled Pay Amount Balance Due PP No records found Packet Pg. 1312 KENDALL PERRINE. LLC, Respondent/Appellant, vs. BOARD OF COUNTY COMMISSIONERS COLLIER COUNTY. FLORIDA. Petitioner/Appel lee. IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA APPELLATE DIVISION CASE NO.: NOTICE OF APPEAL NOTICE IS HEREBY GIVEN that Respondent/Appellant Kendall Perrine. LI.0 (--Respondent/Appellant'), by and through its undersigned counsel, appeals to the Circuit Court of the Second Judicial Circuit in and for Collier County-. Florida. the Order of the Code Enforcement Board rendered on February 23.202 3 by the Robert Kautinan, Chair. The nature of the Order is a final administrative order. i;i m CERTIFICATE OF SERVICE L L HEREBY CERTIFY that a true and correct copy of the foregoing. has been forwarded via a a� a Federal Express to: Robert Kaufman. Chair, Code Enforcement Board. Collier County Code C 0 Enforcement Department. 2800 North Horseshoe Drive. Naples. Ft. 34104 on this 230 day of 0 March 2023. z r c at E ISRAEL, ISRAEL & ASSOCIATES, P.A. � 6099 Stirling Road Suite 2I 1 ' Da%ie Ft. 13;14 ego Phone: (954) 495-8602 ; Fax: (954) 495-4770 Q w %8 w . i sraellaw fl.com Paue 1 Packet Pg. 1313 16.K.2.a Respectfully submitted. ISRAEL, ISRAEL & ASSOCIATES, P.A. Attorneys for Respondent/Appellant 6099 Stirlin- Road { Suite 211 Davie I FL 33314 Telephone: (954) 495-8602 Facsimile: 54) 495-4170 www.isr ellawfl. om Bv: David B. Israel. Esq. Florida Bar No.: 0984078 disrael(a)israel lawfl.com Eric J. Israel. Esc). Florida Bar No.: 1003655 eiisrael(ct israellawtl.com israellawll(W,ornail.com ISRAEL, ISRAEL & ASSOCIATES, P.A. 6099 Stirlin_ Road , Suite 211 Davie FL > 3314 Prone: 1954) 495-8602 Fax: (954) 495-4770 www.israellw,Oxom Paee 2 Packet Pg. 1314 16. K.2.a rnr I'MR goum V CODE ENFOEQEfm !`ODE RM RC UffM BOARD Case No. — CES20210012676 / BOARD OF COUNTY COMMISSIONERS COLLIER COUNTY, FLORIDA, Petitioner, vs. KENDALL PERRINE, LLC, Respondent(s). ORDER OF THE CODEE rBOARD THIS CAUSE came before the Code Enforcement Board (the "Board") for public hearing on February 23, 2023, upon the Petitioner's Motion for Imposition of Fines/Liens, and the Board, having heard testimony under oath, received evidence and heard argument respective to all appropriate matters, hereupon issues its Findings of Fact, Conclusions of Law, and Order of the Board as follows: On March 24, 2022, Respondent(s), KENDALL PERRINE, LLC, was(were) found guilty of violating Collier County Land Development Code, Ord. No. 04-41, as amended, Sections 5.06.06(A)(1), (Ax6), (A)(7), and (A)(8), 5.04.06(A)(2), 5.06.04(C)(4), and 5.06.11 (AX 1), on the subject property located at 4221 TAMIAMI TRL., Naples, FL 34112, Folio No. 53750240002 (Legal Description: LAKEWOOD UNIT 1 THAT PORTION BLK C DESC AS: COM MOST WLY CNR BLK C, N 50DEG E 165FT TO POB, CONT N 50DEG E 142.07FT, S 39DEG E 420FT, S 50DEG W 307.07FT, N 39DEG W 270FT, N 50DEG E 165FT, N 39DEG W 150FT TO POB), hereinafter referred to as the "Property'), in the following particulars: Unpermitted and prohibited signs, banners, flutter flags, wall signs, wan graphics, awning graphics, animated/active signs, electric reader board, vehicle signage. 2. On the same date as above, the Board issued an Order ordering Respondent(g) to abate the violation(s) on or before March 27, 2022, or a fine of S250.00 per day would be assessed for each day the violation(s) remained thereafter (A copy of the Order is recorded at OR BK 6112, PG 2354). 3. On November 18, 2022, the Board granted a continuance. 4. Respondent(s), having been notified of the date of hearing by certified mail, posting and/or personal service, had Joan Garrick, Property Manager and authorized agent, appear at the public hearing. 5. Prior operational costs of $59.28 incurred by Petitioner in the prosecution of this case have been paid. 6. Operational costs in the amount of S59.70 have been incurred by Petitioner for this hearing. 7. The violation(s) have not been abated as of February 23, 2023. CONCLUSIONS OF LAW Based upon the foregoing facts, the Board makes the following Conclusions of Law: 1. All notices were properly and timely issued, and the Board has jurisdiction pursuant to Chapter 162, Florida Statutes, and Chapter 2, Article DC, Code of Laws and Ordinances of Collier County, Florida Page 1 of 3 cfl r` CD N O O N O N Y) LL U U J J �L L m a c m Y M fV) M Ln m _ •L L d a a� a a Q 0 m 0 z r _ d E s U 2 Q Packet Pg. 1315 16. K.2.a 2. Pwmmt to Section 162.09, Florida Statutes, Petitioner has demonstrated by the preponderance of the evidence that the fines and cost shall be imposed against Respondent(s). Based upon the foregoing Findings of Fact and Conchtaions of Law, and pursuant to the authority granted in Chapter 162, Florida Statutes, and Chapter 2, Article IX, Code of Laws and Ordinances of Collier County, Florida, it is hereby ORDERED that: A. Petitioner's Motion for Imposition of Fines/Lima is GRANTED. B. Daily fines of $250.00 per day are assessed and imposed against Respondents) for 333 days for the period from March 28, 2022, to February 23, 2023, for a total fine amount of S83,250.00. C. Respondent(s) shall pay operational costs in the total amount of $59.70. D. Respondent(s) shall pay fines and costs in the total amount of $83,309.70 or be subject to Notice of Assessment of Lien against all properties owned by Respondent(s) in CoWer_Cou nty,F1orida. _ --- E. The daily fines of $250.00 shall continue to accrue until abatement has been confirmed by a Collier County Code Enforcement Investigator. DONE AND ORDERED this je`L3tlday Of 12023 at Collier County, Florida. CODE ENFORCEMENT BOARD STATE OF FLORIDA COUNTY OF COLLIER The foregoing instrument wap acknowledged before me by means ofXpliyysical Presence or O online notarization, this 44Aday of j - , 2023, by Robert Kaufman, Chair of the Collier County Code Enforcement Board Collier County, Florida .!'Personally Known OR 11 Produced Identification Type of Identification Produced 4 e•'• ,�E+ HUM BUCHILLON C wnlabn tt HH 105119 *.� '4�pcs�� l xp m May 15, 2025 ae�tsd7twa�tNoWrssMon 0 11L 7 L Signature of Notary Public - State of Florida Commissioned Name of Notary Public (PrinUTypelStamp) PAYMENT OF FINES: Any fines ordered to be paid pursuant to this Order may be paid at the Collier County Code Enforcement Department, 2800 North Horseshoe Drive, Naples, FL 34104, Phone: (239) 252-2440, Website: www.colliercowUX Laov. Any release of lien or confirmation of compliance or confirmation of the satisfaction of the obligations of this Order may also be obtained at this location. APPEAL,: Any aggrieved party may appeal a final order of the Board to the Circuit Court within thirty (30) days of the execution of the Order appealed. An appeal shall not be a hearing de novo, but shall be limited to appellate review of the record created within the original hearing. It is the responsibility of the appealing party to obtain a transcribed record of the hearing from the Clerk of Courts. Filing an appeal will not automatically stay this Order. Page 2 of 3 Packet Pg. 1316 16.K.2.a CERTIFICATE OF SERVICE I HEREBY CERTIFY that a hue and correct copy of this ORDER haqbeen sent US. Mail to: KENDALL PERRINE, LLC, 2121 SW 3RD AVE. STE. 101, MIANII, FL 33129, on . 2023. Code Enforcement Official Page 3 of 3 Packet Pg. 1317 INSTR 6375843 OR 6225 PG 1809 RECORDED 3/15/2023 10:43 AM PAGES 3 CLERK OF THE CIRCUIT COURT AND COMPTROLLER, COLLIER COUNTY FLORIDA REC $27.00 COLLIER COUNTY CODE ENFORCEMENT CODE ENFORCEMENT BOARD Case No. — CES20210012676 BOARD OF COUNTY COMMISSIONERS COLLIER COUNTY, FLORIDA, Petitioner, KENDALL PERRIN Respondent(s). THIS CAUSE came before thi 2023, upon the Petitioner's Motion for 1 received evidence and heard argument Conclusions of Law, and Order of the E ,ement Board (the "Board") for public hearing on February 23, Fines/Liens, and the Board, having heard testimony under oath, t..all appropriate matters, hereupon issues its Findings of Fact, On March 24, 2022, Respondcnt(s), KENDAP Collier County Land Development Code, O No. (A)(7), and (A)(8), 5.04.06(A)(2), 5.06.04(C)(4); TAMIAMI TRL., Naples, FL 34112, Folio No: 53 THAT PORTION BLK C DESC AS: COM MOST'1 N 50DEG E 142.07FT, S 39DEG E 420FT, S 50DEG I N 39DEG W 150FT TO POB), hereinafter referred to Unpermitted and prohibited signs, banners, flutter 1 animated/active signs, electric reader board, vehicle NE, LLC, was(were) found guilty of violating 1, as amended, Sections 5.06.06(A)(1), (A)(6), I l(A)(1), on the subject property located at 4221 (002 (Legal Description: LAKEWOOD UNIT 1 �IR BLK C, N 50DEG E 165FT TO POB, CONT 1.07FT, N 39DEG W 270FT, N 50DEG E 165FT, c,",property"), in the following particulars: wall graphics, awning graphics, 2. On the same date as above, the Board issued an Order ordering Respo -ent(s) to abate the violation(s) on or before March 27, 2022, or a fine of $250.00 per day would be assessedfor-each day the violation(s) remained thereafter (A copy of the Order is recorded at OR BK 6112, PG 23541-11 3. On November 18, 2022, the Board granted a continuance. r 4. Respondent(s), having been notified of the date of hearing by certified mail, po ting ndlor personal service, had Joan Garrick, Property Manager and authorized agent, appear at the public hearing S. Prior operational costs of $59.28 incurred by Petitioner in the prosecution of this case have been paid. 6. Operational costs in the amount of $59.70 have been incurred by Petitioner for this hearing. 7. The violation(s) have not been abated as of February 23, 2023. CONCLUSIONS OF LAW Based upon the foregoing facts, the Board makes the following Conclusions of Law: 1. All notices were properly and timely issued, and the Board has jurisdiction pursuant to Chapter 162, Florida Statutes, and Chapter 2, Article IX, Code of Laws and Ordinances of Collier County, Florida. Q Page 1 of 3 Packet Pg. 1318 OR 6225 PG 1810 2. Pursuant to Section 162.09, Florida Statutes, Petitioner has demonstrated by the preponderance of the evidence that the fines and cost shall be imposed against Respondent(s). ORDER Based upon the foregoing Findings of Fact and Conclusions of Law, and pursuant to the authority granted in Chapter 162, Florida Statutes, and Chapter 2, Article IX, Code of Laws and Ordinances of Collier County, Florida, it is hereby ORDERED that: A. Petitionc's`Matin for Imposition of Fines/Liens is GRANTED. B. Daily fines 6fS7'50:0 per day are assessed and imposed against Respondent(s) for 333 days for the period from March 28,`2022toFebruary 23, 2023, for a total fine amount of $83,250.00. C. Respondent(s) shall p4.y'opdrational costs in the total amount of $59.70. D. Respondent(s) shall pay -fines nd costs in the total amount of $83,309.70 or be subject to Notice of Assessment of Lien agdirtstliat operties owned by Respondent(s) in Collier County, Florida. E. The daily fines of S250.00 s�all;cont nue to accrue until abatement has been confirmed by a Collier County Code Enforcement Investigator. �" DONE CND -ORDERED this day tiif~. rf,(. �-i tyst�l j� Kn4el, C1aAc4f Ooor�, i,. and for ;,ollie -Kn Ke�rCy .e ty �:rettheL�c ie rrus2rumcnt is a trua a �rect ; COE Doi igat .I NW, un ,Florida !✓ Deputy Cl� ©L Data i � '' ., �,�'`�j•. STATE OF FLORIDA COUNTY OF COLLIER 2023 at Collier County, Florida. ENFORCEMENT BOARD The foregoing instrument wa acknowledged before me by means of�phys cal Presence or ❑ online notarization, this . f�day of '2023, by Robert Kaufman,"Chair' f the Collier County Code Enforcement Board Collier County, Florida. Personally Known OR ❑ Produced IdentificationGL, Jam_ Type of Identification Produced Signature of1lot#y Public - State of Florida "AY po",c HELEN BUCHILLON Commissioned Mime of Notary Public Commission # HH 105119 (Prifit/'I'nyp/tamp) Expires play 15, 2025 "OF F Q'Bonded ihru Budget Notary Servkee ` PAYMENT OF FINES: Any fines ordered to be paid pursuant to this Order may be paid at the Collier County Code Enforcement Department, 2800 North Horseshoe Drive, Naples, FL 34104, Phone: (239) 252-2440, Website: www.colliercountyfl.gov. Any release of lien or confirmation of compliance or confirmation of the satisfaction of the obligations of this Order may also be obtained at this location. APPEAL: Any aggrieved party may appeal a final order of the Board to the Circuit Court within thirty (30) days of the execution of the Order appealed. An appeal shall not be a hearing de novo, but shall be limited to appellate review of the record created within the original hearing. It is the responsibility of the appealing party to obtain a transcribed record of the hearing from the Clerk of Courts. Filing an appeal will not automatically stay this Order. Q Page 2 of 3 Packet Pg. 1319 *** OR 6225 PG 1811 *** CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of this ORDER has been sent b U.S. Mail to: KENDALL PERRINE, LLC, 2121 SW 3RD AVE. STE. 101, MIAMI, FL 33129, on Aftl—lij 2023. Code Enforcement Official Page 3 of 3 Packet Pg. 1320 16.K.2.c This Instrument Prepared By: Colleen A. Kerins, Esquire Collier County Attorney's Office 3299 E. Tamiami Trail -Suite 800 Naples, FL 34112 (239) 252-8400 RELEASE AND SATISFACTION OF LIEN KNOW ALL MEN BY THESE PRESENTS: That the BOARD OF COUNTY COMMISSIONERS OF COLLIER COUNTY, FLORIDA is the owner and holder of a certain lien against all real and personal property owned by: KENDALL PERRINE, LLC, Respondent The lien was recorded on March 15, 2023, in Official Records Book 6225, Page 1809, in the Official Records of Collier County, State of Florida. The lien secures the principal sum of eighty- three thousand three hundred nine dollars and seventy cents ($83,309.70), plus accrued interest and penalties, if any, and imposes certain obligations against real property situated in Collier County, Florida. Collier County, a political subdivision of the State of Florida, by execution of this Release and Satisfaction of Lien, acknowledges payment as approved by the Board of County Commissioners as satisfaction of the lien and hereby cancels and releases said lien. The Clerk of the Circuit Court is hereby directed to record this Release and Satisfaction of Lien in the Official Records of Collier County, Florida, to acknowledge that the lien ceases to exist. ATTEST CRYSTAL K. KINZEL, Clerk Deputy Clerk Date: Approved as to form and legality R Colleen A. Kerins Assistant County Attorney BOARD OF COUNTY COMMISSIONERS COLLIER COUNTY, FLORIDA Date: Rick LoCastro, Chairperson [23-CED-01712/1786834/11 Packet Pg. 1321 • David B. Israel, Esq. disrael@israellawfl.com • Eric J. Israel, Esq. ejisrael@israellawfl.com April 11, 2023 VIA EMAIL - colleen.kerinsgcolliercountyflgov (7020 0090 0001 2163 8874) AND CERTIFIED MAIL — RETURN RECEIPT REQUESTED Colleen A. Kerins, Esq. Office of the Collier County Attorney 3299 Tamiami Trail E., Suite 800 Naples, FL 34112-5749 Re: Kendall Perrine, LLC v. Board of County Commissioners, Collier County, Florida Appellate Case No.: 11-2023-CA-001553-0001-XX P/A Lakewood Plaza 4221 Tamiami Trail Naples, FL 34112 FOR RESOLUTION PURSPOSES ONLY Dear Ms. Kerins: Undersigned counsel represents Kendall Perrine, LLC with relation to the above referenced matter. As you know, on February 23, 2023, an Order of the Code Enforcement Board was entered against Kendall Perrine, LLC. Attached as Exhibit 1 is a copy of the Order of the Code Enforcement Board for ease of reference. On March 24, 2023, a timely appeal of the Order of the Code Enforcement Board was filed in the Circuit Court of the Second Judicial Circuit in and for Collier County, Florida pursuant to Section 162.11, Florida Statutes. Attached as Exhibit 2 is a copy of the Notice of Appeal for ease of reference. Kendall Perrine, LLC intends to challenge the constitutionality of the subject signage ordinance upon which the Order of the Code Enforcement Board is based on several constitutional basis; as well as on the vagueness of certain provisions of the signage ordinance upon which the Order of the Code Enforcement Board relied and is based. It is the position of Kendall Perrine, LLC that the signage ordinance upon which the Order of the Code Enforcement Board is based violates constitutionality guarantees afforded to Kendall Perrine, LLC as more fully discussed herein below. In addition, certain provisions of the Order of the Code Enforcement Board are so vague that the average person would not have knowledge of the violation upon which any charges are based. As a starting point, we believe that the Order of the Code Enforcement Board is defective because of several reasons. The date of execution of the Order of the Code Enforcement Board a and the date of notarization of said execution, where the execution was purported to have occurred 6099 Stirling Road, Suite 21 1 www.israellawfl.com (954) 495-8602, Direct Davie, FL 33314 9 - Other Offices: Miami Lal<es and West Palm Beach Packet Pg. 1322 Colleen A. Kerins, Esq. Office of the Collier County Attorney April 11, 2023 Page 2 in physical presence of the notary, are almost two (2) weeks in difference. Such a difference in time periods between the execution of the Order of the Code Enforcement Board and date of notarization, which was purported to have been verified in the physical presence of the notary, is not only to the detriment of Kendall Perrine, LLC, but may also invalidate the Order of the Code Enforcement Board based on such a glaring discrepancy. The time periods exceed any reasonable delay and subjects Kendall Perrine, LLC to limitations of its legal and constitutional rights. Further, it is the position of Kendall Perrine, LLC that the Code Enforcement Board failed to take into consideration the conditions which resulted in the situation giving rise to the entry of the Order of the Code Enforcement Board at issue. Just to reiterate, in spite of Kendall Perrine, LLC's assistance towards its tenant at the subject shopping plaza who operates a restaurant, the subject tenant, as a result of the COVID-19 pandemic was in substantial financial difficulties, and was desperate to drive business to the restaurant. As a result of such financial difficulties resulting from the COVID-19 pandemic, the subject tenant installed signage to attempt to drive business to the restaurant. Unfortunately, during the subject time periods, one of the partners of the subject tenant's restaurant passed away which resulted in delays in addressing the signage issues. In addition, the Code Enforcement Board failed to address any of the issues outlined by Sections 162.09 (2)(b) and 2(c), Florida Statutes, as a result the fine imposed were excessive. The failure of the Code Enforcement Board to address any of these issues and the underlying facts in the Order of the Code Enforcement Board at issue shows a complete disregard for Kendall Perrine, LLC's legal and constitutional rights. Such disregard for Kendall Perrine, LLC's legal and constitutional rights is a violation of Kendall Perrine, LLC's due process rights. See Lake Wales u LamarAdver. Assn, 399 So. 2d 981 (Fla. 2d DCA 1981) (When a city ordinance operates to put a petitioner out of business, or so to cripple its business, as to amount to an unreasonable and discriminatory invasion of its rights, this is an exercise of the police power which aesthetics does not warrant). Moreover, some of the specific provisions of the signage ordinance upon which the Order of the Code Enforcement Board is based are vague, improper and unconstitutional catch all provisions which do not provide notice to the party charged and render the Order of the Code Enforcement Board unenforceable due to its reliance on vague provisions of the signage ordinance. See Friends of the Great Southern, Inc. v City of Hollywood, 964 So. 2d 827 (Fla. 4t' DCA 2007) (In order for ordinances which provide decisional authority to be constitutional, they must have mandatory objective criteria to be followed when making a decision. If definite standards are not included in the ordinance, it must be deemed unconstitutional as an invalid delegation of legislative power to an administrative board. Any standards, criteria, or requirements which are subject to whimsical or capricious application or unbridled discretion will not meet the test of constitutionality. An ordinance whereby the city council delegates to itself the arbitrary and unfettered authority to decide where and how a particular structure shall be built or where located ISRAEL, ISRAEL & ASSOCIATES, P.A. 6099 Stirling Road I Suite 2111 Davie I FL 33314 Telephone: (954) 495-8602 1 Fax: (954) 4954770 www.israellawfl.com Packet Pg. 1323 Colleen A. Kerins, Esq. Office of the Collier County Attorney April 11, 2023 Page 3 without at the same time setting up reasonable standards which would be applicable alike to all property owners similarly conditioned cannot be permitted to stand as a valid municipal enactment. Objective criteria are necessary so that: 1. persons are able to determine their rights and duties; 2. the decisions recognizing such rights will not be left to arbitrary administrative determination; 3. all applicants will be treated equally; and 4. meaningful judicial review is available). See also, Southeast Aluminum Supply Corp. v. Metropolitan Dade County, 533 So. 2d 777 (Fla. 3d DCA 1988). Kendall Perrine, LLC believes the signage ordinance to be arbitrary, unreasonable and confiscatory and, thus, unconstitutional. The test for the constitutionality of an ordinance is whether the question of the ordinance meeting the constitutional test of serving the health, safety, morals, or general welfare of the public, is open to dispute or controversy on grounds that make sense and is fairly debatable. See Dozier v. City of Miami, 639 So. 2d 167 (Fla. 3d DCA 1994). A municipal ordinance should be clear, definite and certain in its terms and is invalid if it is so vague that its precise meaning cannot be ascertained. See Naples v. Miller, 243 So. 2d 608 (Fla. 2d DCA 1971). To withstand a challenge for vagueness, an ordinance must provide adequate notice to persons of common understanding concerning the behavior prohibited and the specific intent required. See Easy Way v. Lee County, 674 So. 2d 863 (Fla. 2d DCA 1996). In light of the above, Kendall Perrine, LLC feels confident that an attack on the constitutionality of the subject signage ordinance will result in an invalidation of the subject signage ordinance. However, in light of the expense and time associated with such protracted litigation, Kendall Perrine, LLC would be amenable to a fair and reasonable resolution of the pending lien resulting from the imposition of fines/lien upon the subject property of Kendall Perrine, LLC. Kendall Perrine, LLC would be amenable to a fair and reasonable resolution of the fines/lien for the subject Order of the Code Enforcement Board for the total sum of $12,000.00. In exchange, Kendall Perrine, LLC would expect satisfaction of the Order of the Code Enforcement Board and a release of all subject fines/liens and/or all appropriate such documents clearing title and releasing the subject property. Please note that the claimed subject violations have been fully resolved and cured pursuant to the attached email communication with the Code Enforcement Officer. See email communications attached hereto as Exhibit 3 for ease of reference. Thank you for your time and consideration of the above and we look forward to a fair and reasonable resolution of the subject matter without further litigation on these issues. ISRAEL, ISRAEL & ASSOCIATES, P.A. 6099 Stirling Road I Suite 2111 Davie I FL 33314 Telephone: (954) 495-8602 1 Fax: (954) 495-4770 www.israellawfl.com Packet Pg. 1324 Colleen A. Kerins, Esq. Office of the Collier County Attorney April 11, 2023 Page 4 Yojms-Wry truly, David B. Israel, Enclosures — As Listed Above cc Kendall Perrine, LLC & 4SSOCIATES, P.A. ISRAEL, ISRAEL & ASSOCIATES, P.A. 6099 Stirling Road I Suite 2111 Davie I FL 33314 Telephone: (954) 495-8602 1 Fax: (954) 495-4770 www.israellawfl.com Packet Pg. 1325 16. K.2. d EXHIBIT 1 co N O O r N O N cn W U U J J d _ 'L L d a �a d Y T U 00 N al M co M LO N d _ L d a a� r Q m E d r a� U) _ d E t u c� w El Packet Pg. 1326 COLLIER COUNTY CODE ENFORCEMENT CODE ENFORCEMENT BOARD Case No. — CES20210012676 BOARD OF COUNTY COMMISSIONERS COLLIER COUNTY, FLORIDA, co N Petitioner, CD c N O VS. N (n W KENDALL PERRINE, LLC, U U Respondent(s). J J •L ORDER OF THE CODE ENFORCEMENT BOARD a THIS CAUSE came before the Code Enforcement Board (the "Board") for public hearing on February 23, 2023, upon the Petitioner's Motion for Imposition of Fines/Liens, and the Board, having heard testimony under oath, received evidence and heard argument respective to all appropriate matters, hereupon issues its Findings of Fact, Y Conclusions of Law, and Order of the Board as follows: > FINDINGS OF FACT On March 24, 2022, Respondent(s), KENDALL PERRINE, LLC, was(were) found guilty of violating Collier County Land Development Code, Ord. No. 04-41, as amended, Sections 5.06.06(A)(1), (A)(6), (A)(7), and (A)(8), 5.04.06(A)(2), 5.06.04(C)(4), and 5.06.1 l(A)(1), on the subject property located at 4221 TAMIAMI TRL., Naples, FL 34112, Folio No. 53750240002 (Legal Description: LAKEWOOD UNIT 1 THAT PORTION BLK C DESC AS: COM MOST WLY CNR BLK C, N 50DEG E 165FT TO POB, CONT N 50DEG E 142.07FT, S 39DEG E 420FT, S 50DEG W 307.07FT, N 39DEG W 270FT, N 50DEG E 165FT, N 39DEG W 150FT TO POB), hereinafter referred to as the "Property"), in the following particulars: Unpermitted and prohibited signs, banners, flutter flags, wall signs, wall graphics, awning graphics, animated/active signs, electric reader board, vehicle signage. 2. On the same date as above, the Board issued an Order ordering Respondent(s) to abate the violation(s) on or before March 27, 2022, or a fine of $250.00 per day would be assessed for each day the violation(s) remained thereafter (A copy of the Order is recorded at OR BK 6112, PG 2354). 3. On November 18, 2022, the Board granted a continuance. 4. Respondent(s), having been notified of the date of hearing by certified mail, posting and/or personal service, had Joan Garrick, Property Manager and authorized agent, appear at the public hearing. 5. Prior operational costs of $59.28 incurred by Petitioner in the prosecution of this case have been paid. 6. Operational costs in the amount of $59.70 have been incurred by Petitioner for this hearing. 7. The violation(s) have not been abated as of February 23, 2023. CONCLUSIONS OF LAW Based upon the foregoing facts, the Board makes the following Conclusions of Law: 1. All notices were properly and timely issued, and the Board has jurisdiction pursuant to Chapter 162, Florida Statutes, and Chapter 2, Article IX, Code of Laws and Ordinances of Collier County, Florida. Pagel of 3 Packet Pg. 1327 2. Pursuant to Section 162.09, Florida Statutes, Petitioner has demonstrated by the preponderance of the evidence that the fines and cost shall be imposed against Respondent(s). ORDER Based upon the foregoing Findings of Fact and Conclusions of Law, and pursuant to the authority granted in Chapter 162, Florida Statutes, and Chapter 2, Article IX, Code of Laws and Ordinances of Collier County, Florida, it is hereby ORDERED that: A. Petitioner's Motion for Imposition of Fines/Liens is GRANTED. B. Daily fines of $250.00 per day are assessed and imposed against Respondent(s) for 333 days for the period from March 28, 2022, to February 23, 2023, for a total fine amount of $83,250.00. C. Respondent(s) shall pay operational costs in the total amount of $59.70. D. Respondent(s) shall pay fines and costs in the total amount of $83,309.70 or be subject to Notice of Assessment of Lien against all properties owned by Respondent(s) in Collier_County,.Florida. E. The daily fines of $250.00 shall continue to accrue until abatement has been confirmed by a Collier County Code Enforcement Investigator. DONE AND ORDERED this 23g day of 2023 at Collier County, Florida. CODE ENFORCEMENT BOARD STATE OF FLORIDA COUNTY OF COLLIER The foregoing instrument w acknowledged before me by means of�physical Presence or El online notarization, this . day of�AAZZ , 2023, by Robert Kaufman, Chair of the Collier County Code Enforcement Board Collier County, Florida. A Personally Known OR ❑ Produced Identification Type of Identification Produced. HELENSUCHILLON oty,RYP49,� Commissionr'. HH105119 N c� Explres May 15, 2025 9rFaFrtioQ\ SondkThruBudsaIN&JYS-10as Signature of Notary Public - State of Florida Commissioned Name of Notary Public (Print/Type/Stamp) PAYMENT OF FINES: Any fines ordered to be paid pursuant to this Order may be paid at the Collier County Code Enforcement Department, 2800 North Horseshoe Drive, Naples, FL 34104, Phone: (239) 252-2440, Website: www.colliercountyfl.gov. Any release of lien or confirmation of compliance or confirmation of the satisfaction of the obligations of this Order may also be obtained at this location. APPEAL: Any aggrieved party may appeal a final order of the Board to the Circuit Court within thirty (30) days of the execution of the Order appealed. An appeal shall not be a hearing de novo, but shall be limited to appellate review of the record created within the original hearing. It is the responsibility of the appealing party to obtain a transcribed record of the hearing from the Clerk of Courts. Filing an appeal will not automatically stay this Order. Page 2 of 3 Packet Pg. 1328 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of this ORDER has been nt by U.S. Mail to: K.ENDALL PERRINE, LLC, 2121 SW 3RD AVE. STE, 101, MIAMI, FL 33129, on / 2023. Code Enforcement Official Page 3 of 3 Packet Pg. 1329 16. K.2. d EXHIBIT 2 co N O O r N O N Cn W U U J J d _ 'L L d a �a d Y T U 00 N al M O M LO N d _ L d a a� r Q m E d r a� U) _ d E t u c� w El Packet Pg. 1330 1 KENDALL PERRINE, LLC, Respondent/Appellant, VS. BOARD OF COUNTY COMMISSIONERS COLLIER COUNTY, FLORIDA. Petitioner/Appel lee, IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA APPELLATE DIVISION CASE NO.: 11-2023-CA-001553-0001-XX NOTICE OF APPEAL NOTICE IS HEREBY GIVEN that Respondent/Appellant Kendall Perrine, LLC ("Respondent/Appellant-), by and through its Undersigned counsel, appeals to the Circuit Court of the Second Judicial Circuit in and for Collier County, Florida, the Order of the Code Enforcement Board rendered on February 23, 2023 by the Robert Kaufman, Chair. The nature of the Order is a final administrative order. CERTI FICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been forwarded via Federal Express to: Robert Kaufinan, Chair, Code Entorcement Board, Collier County Code Entorcement Department, 2800 North Horseshoe Drive, Naples, FL 34104 on this 23'd day of March 2023. ISRAEL, ISRAEL & ASSOCIATES, P.A. 6099 Stirling Road l Suite 21 1 1 Davie I FL 33314 Phone: (954) 495_8602 1 Fax: (954) 495_4770 www.israellawfl.com Page 1 Packet Pg. 1331 Respectfully submitted. ISRAEL, ISRAEL & ASSOCIATES, P.A. Attorneys for Respondent/Appellant 6099 Stirling Road ( Suite 21 1 Davie I FL, 33314 Telephone: (954) 495-8602 Facsimile: ,--(�54) 495-770 wwwAsr cllawtl pom In David B. Israel, Esq. Florida Bar No.: 0984078 disraelamisraellawll.com Eric J. Israel. Esq. Florida Bar No.: 1003655 eiisraelAisraellawfl.com israellawll c gmail.com ISRAEL, ISRAEL & ASSOCIATES, P.A. 6099 Stirling Road 1 Suite 21 1 j Davie I FL 33314 Phone: (954) 495-8602'i Fax: (954) 495-4770 www. Israel lawfl_com Page 2 Packet Pg. 1332 COLLIER COUNTY CODE ENFORCEMENT. CODE ENFORCEMENT BOARD Case No. — CES20210012676 BOARD OF COUNTY COMMISSIONERS COLLIER COUNTY, FLORIDA, Petitioner, VS. KENDALL PERRINE, LLC, Respondent(s). ORDER OF THE CODE ENFORCEMENT BOARD THIS CAUSE came before the Code Enforcement Board (the "Board") for public hearing on February 23, 2023, upon the Petitioner's Motion for Imposition of Fines/Liens, and the Board, having heard testimony under oath, received evidence and heard argument respective to all appropriate matters, hereupon issues its Findings of Fact, Conclusions of Law, and Order of the Board as follows: FINDINGS OF FACT On March 24, 2022, Respondent(s), KENDALL PERRINE, LLC, was(were) found guilty of violating Collier County Land Development Code, Ord. No. 04-41, as amended, Sections 5.06.06(A)(1), (A)(6), (A)(7), and (A)(8), 5.04.06(A)(2), 5.06.04(C)(4), and 5.06.11(A)(1), on the subject property located at 4221 TAMIAMI TRL., Naples, FL 34112, Folio No. 53750240002 (Legal Description: LAKEWOOD UNIT 1 THAT PORTION BLK C DESC AS: COM MOST WLY CNR BLK C, N 50DEG E 165FT TO POB, CONT N 50DEG E 142.07FT, S 39DEG E 420FT, S 50DEG W 307.07FT, N 39DEG W 270FT, N 50DEG E 165FT, N 39DEG W 150FT TO POB), hereinafter referred to as the "Property"), in the following particulars: Unpermitted and prohibited signs, banners, flutter flags, wall signs, wall graphics, awning graphics, animated/active signs, electric reader board, vehicle signage. 2. On the same date as above, the Board issued an Order ordering Respondent(s) to abate the violation(s) on or before March 27, 2022, or a fine of $250.00 per day would be assessed for each day the violation(s) remained thereafter (A copy of the Order is recorded at OR BK 6112, PG 2354). 3. On November 18, 2022, the Board granted a continuance. 4. Respondent(s), having been notified of the date of hearing by certified mail, posting and/or personal service, had Joan Garrick, Property Manager and authorized agent, appear at the public hearing. 5. Prior operational costs of $59.28 incurred by Petitioner in the prosecution of this case have been paid. 6. Operational costs in the amount of $59.70 have been incurred by Petitioner for this hearing. 7. The violation(s) have not been abated as of February 23, 2023. CONCLUSIONS OF LAW Based upon the foregoing facts, the Board makes the following Conclusions of Law: I. All notices were properly and timely issued, and the Board has jurisdiction pursuant to Chapter 162, Florida Statutes, and Chapter 2, Article IX, Code of Laws and Ordinances of Collier County, Florida. Page i of 3 Packet Pg. 1333 2. Pursuant to Section 162.09, Florida Statutes, Petitioner has demonstrated by the preponderance of the evidence that the fines and cost shall be imposed against Respondent(s). ORDER Based upon the foregoing Findings of Fact and Conclusions of Law, and pursuant to the authority granted in Chapter 162, Florida Statutes, and Chapter 2, Article IX, Code of Laws and Ordinances of Collier County, Florida, it is hereby ORDERED that: A. Petitioner's Motion for Imposition of Fines/Liens is GRANTED. B. Daily fines of $250.00 per day are assessed and imposed against Respondent(s) for 333 days for the period from March 28, 2022, to February 23, 2023, for a total fine amount of $83,250.00. C. Respondent(s) shall pay operational costs in the total amount of $59.70. D. Respondent(s) shall pay fines and costs in the total amount of $83,309.70 or be subject to Notice of Assessment of Lien against all properties owned by Respondent(s) in Collier-County,.F3ori%.da _ E. The daily fines of $250,00 shall continue to accrue until abatement has been confirmed by a Collier County Code Enforcement Investigator. DONE AND ORDERED this ,,23t,Lday of 2023 at Collier County, Florida. CODE ENFORCEMENT BOARD STATE OF FLORIDA COUNTY OF COLLIER The foregoing instrument w acknowledged before me by means ofXp�sical Presence or ❑ online notarization, this -4Aday of h 2023, by Robert Kaufman, Chair of the Collier County Code Enforcement Board Collier County, Florida. Personally Known OR O Produced Identification Type of Identification Produced �t'A' ?Ve, HELEN BLICHILLON Commission # HH 105119 o< ��OFGL��` Explies May 15, 2025 9ol�doditru6U�elNoterySm�iaa IL� ?::ddJ— Signature of Notary Public - State of Florida Commissioned Name of Notary Public (Print/Type/Stamp) PAYMENT OF FINES:. Any fines ordered to be paid pursuant to this Order may be paid at the Collier County Code Enforcement Department, 2800 North Horseshoe Drive, Naples, FL 34104, Phone: (239) 252-2440, Website: www.collicreountvfl.gov. Any release of lien or confirmation of compliance or confirmation of the satisfaction of the obligations of this Order may also be obtained at this location. APPEAL: Any aggrieved party may appeal a final order of the Board to the Circuit Court within thirty (30) days of the execution of the Order appealed. An appeal shall not be a hearing de novo, but shall be limited to appellate review of the record created within the original hearing. It is the responsibility of the appealing party to obtain a transcribed record of the hearing from the Clerk of Courts. Filing an appeal will not automatically stay this Order. Page 2 of 3 Packet Pg. 1334 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of this ORDER has been sent b U.S. Mail to: I{ENDALL PERRINE, LLC, 2121 SW 3RD AVE. STE. 101, MIAMI, FL 33129, on - T 2023. Code Enforcement Official Page 3 of 3 Packet Pg. 1335 EXHIBIT 3 co N O O r N O N U) W U U J J d _ 'L L d a �a d Y T U 00 N al M co M LO N d _ L d a a� r Q m E d r a� U) _ d E t u c� w El Packet Pg. 1336 From: Joan Garrick To: David Israel; "Mike Pappas" Subject: CES20210012676_KENDALL PERRINE, LLC- Fine imposed Date: Monday, April 10, 2023 10:34:56 AM Good morning Mr. Israel, Please see email below from the Code Officer to the sign company confirming that all prohibited signs are removed. Thanks! Joan Garrick Senior Property Manager iaarrick _mhcreal.com 1601 Forum Place, Suite 700 West Palm Beach, FL 33401 USA www.mhcreal.com Direct +1 561 614 4035 Main +1 561 471 8000 Fax +1 561 640 7855 Bloa I Linkedin I Twitter I Facebook IN From: PulseDee <Dee.Pulse @colliercountyfl.gov> Sent: Friday, April 7, 2023 4:18 PM To: ALLFLORIDASIGNS239@YAHOO.COM Cc: Joan Garrick <jgarrick@mhcreal.com>; PulseDee <Dee.PuIse@colliercountyfl.gov> Subject: RE: CASE CES20210012676_KENDALL PERRINE, LLC- Fine imposed RE: Code CES20210012676 Permit PRSG20221048818 4221 Tamiami TH Fish 41 Leonard, Please see attached photos. The business now has removed all prohibited signs and can now continue the permit process. Please reach out to Jennifer Breining, Sign Plans Reviewer Phone: (239) 252-5573 BreiningJennifer Jennifer.Breining(@colliercountyfl.gov Packet Pg. 1337 Let me know if you have any questions! Thank you, Dee From: Joan Garrick <igarrick(@mhcreal.com> Sent: Thursday, April 6, 2023 3:56 PM To: PulseDee <Dee.PulsePcolliercountyfl.gov> Subject: RE: CASE CES20210012676_KENDALL PERRINE, LLC- Fine imposed EXTERNAL. EMAIL: This email is from an external source. Confirm this is a trusted sender and use extreme caution when opening attachments or clicking links. Hi Dee, Below is the sign company email. Leonard Leonov phone number 239 462-7202 allfloridasigns239Pyahoo.com Joan Garrick Senior Property Manager iaarrick(cDmhcreal.com 1601 Forum Place, Suite 700 West Palm Beach, FL 33401 USA www.mhcreal.com Direct +1 561 614 4035 Main +1 561 471 8000 Fax +1 561 640 7855 Bloa I Link In I Twitter I Facebook 113 From: Joan Garrick Sent: Thursday, March 30, 2023 4:12 PM To: PulseDee <Dee.PulsePcolliercountyfl.aov> Subject: CASE CES20210012676_KENDALL PERRINE, LLC- Fine imposed Hi Dee, Thanks so much for your help. I did notify the sign company. Packet Pg. 1338 Joan Garrick Senior Property Manager jg rrick _ mhcreal.com 1601 Forum Place, Suite 700 West Palm Beach; FL 33401 USA www.mhcreal.com Direct +1 561 614 4035 Main +1 561 471 8000 Fax +1 561 640 7855 Bloa I Link in I Twitter I Facebook 0 From: PulseDee <Dee.Pulse Pcolliercountyfl.gov> Sent: Thursday, March 30, 2023 3:44 PM To: Joan Garrick <igarrick(@mhcreal.com> Subject: RE: CASE CES20210012676_KENDALL PERRINE, LLC- Fine imposed Joan, Looks good! I am sending to sign reviewer to get permit issued also!! From: Joan Garrick <igarrickPmhcreal.com> Sent: Friday, March 24, 2023 12:02 PM To: PulseDee <Dee.PulsePcolliercountyfl gov> Subject: CASE CES20210012676_KENDALL PERRINE, LLC- Fine imposed EXTERNAL FMIAI I.: This email is from an external source. Confirm this is a trusted sender and use extreme caution when opening attachments or clicking links. Good morning Dee, All signs have been removed. Please confirm. Thanks. Joan Garrick Senior Property Manager Packet Pg. 1339 ig rra ickOmhcreal.com 1601 Forum Place, Suite 700 West Palm Beach, FL 33401 USA www.mhcreal.com Direct +1 561 6144035 Main +1 561 471 8000 Fax +1 561 640 7855 BI q I Linkedin I Twitter I Facebook 0 From: PulseDee <Dee.Pulse(@colliercountyfl.gov> Sent: Thursday, March 23, 2023 10:41 AM To: Joan Garrick <igarrick(d)mhcreal.com> Cc: PulseDee <Dee.Pulse(cDcolliercountyfl.gov> Subject: RE: CASE CES20210012676_KENDALL PERRINE, LLC- Fine imposed Joan, Please see status attached 3 photos taken on 3-22-23. There is a night time photo taken 3-5-23. Word document shows signage circled that is still in violation. I am sending photos to the sign reviewer for approval on windows. Thanks, Dee From: Joan Garrick <igarrickPmhcreal.com> Sent: Wednesday, March 22, 2023 5:12 PM To: PulseDee <Dee.PulsePcolliercountyfl.gov> Subject: CASE CES20210012676_KENDALL PERRINE, LLC- Fine imposed EXTERNAL EMAIL: This email is from an external source. Confirm this is a trusted sender and use extreme caution when opening attachments or clicking links. Good afternoon Dee, Please attached pictures. It appears the signs were removed. I left you a message as well to confirm if this meet the requirements. Thanks! Joan Garrick Packet Pg. 1340 Senior Property Manager iaarrick@mhcreal.com 1601 Forum Place, Suite 700 West Palm Beach, FL 33401 USA www.mhcreal.com Direct +1 561 614 4035 Main +1 561 471 8000 Fax +1 561 640 7855 Blog I Linkedin I Twitter I Facebook Under Florida Law, e-mail addresses are public records. If you do not want your e-mail address released in response to a public records request, do not send electronic mail to this entity. Instead, contact this office by telephone or in writing. Packet Pg. 1341