CEB Minutes 05/23/1996
1996
Code
Enforcement
Board
May 23, 1996
May 23, 1996
VERBATIM TRANSCRIPT OF THE
CODE ENFORCEMENT BOARD
Naples, Florida, May 23, 1996
The Collier County Code Enforcement Board met on this date at 8:04
a.m. in REGULAR SESSION in Building "F" of the Government Complex, East
Naples, Florida, with the following members present:
CHAIRPERSON: M. Jean Rawson
Jim Allen
Charles Andrews
Mireya Louviere, Absent
Celia Deifik, Absent
Louis Laforet
Richard McCormick
ALSO PRESENT: Ramiro Manalich, Asst. County Attorney
Shirley Jean McEachern, Asst. County Attorney
Linda Sullivan, Code Enforcement Director
Maria E. Cruz, Code Enforcement Specialist
Page 1
CODE ENFORCEMENT BOARD OF COLLIER COUNTY. FLORIDA
AMENDED
AGE.NDA
Date: May 23, 1996 at 8:00 o'clock A.M.
Location: Collier County Government Center, Admn. Bldg, 3rd Floor
NOTE: ANY PERSON WHO DECIDES TO APPEAL A DECISION OF THIS BOARD
WILL NEED A RECORD OF THE PROCEEDINGS PERTAINING THERETO, AND
THEREFORE MAY NEED TO ENSURE THAT A VERBATIM RECORD OF THE
PROCEEDINGS IS MADE, WHICH RECORD INCLUDES THE TESTIMONY AND
EVIDENCE UPON WHICH THE APPEAL IS TO BE BASED. NEITHER COLLIER
COUNTY NOR THE CODE ENFORCEMENT BOARD SHALL BE RESPONSIBLE FOR
PROVIDING THIS RECORD.
1. PRELIMINARY MATTERS
2 . ROLL CALL
3 . APPROVAL OF AGENDA
4. APPROVAL OF MINUTES March 28, 1996
5. PUBLIC HEARINGS
A. BCC vs. Pacific Landco and Pacific Land Co. CEB No. 96-010
6. NEW BUSINESS
N/A
7. OLD BUSINESS
B.
BCC vs. Jean Claude Martel CEB No. 96-005
a) Filing of Affidavit of Non-Compliance/Proposed Imposition of
Fines/Liens
b) Filing of Affidavit of Compliance
BCC vs. Jean Claude Martel CEB No. 96-008
a) Filing of Affidavit of Compliance
BCC vs. Joseph M. Hovland CEB No. 96-009
a) Filing of Affidavit of Compliance
A.
C.
8. REPORTS
N/A
9.
NEXT MEETING DATE
June 27, 1996
10 . ADJOURN
May 23, 1996
CHAIRPERSON RAWSON: Everybody ready to go? Collier County Code
~nforcement Board will come to order. Let's start with the roll call
co my left, please.
MR. McCORMICK: Richard McCormick.
MR. LAFORET: Lou Laforet.
CHAIRPERSON RAWSON: Jean Rawson.
MR. ALLEN: Jim Allen.
MR. ANDREWS: Charlie Andrews.
CHAIRPERSON RAWSON: Let the record reflect that Celia Deifik is
in trial this morning, and she is excused. I apologize for the
earliness of the hour. There was a real good reason we set this
for eight o'clock, because obviously we thought we were going to be in
here all day today, and I wanted to have an opportunity to report to
the board members about the attorney situation. The last time we met,
if you'll recall, there was some discussion and some concern, first of
all, that if the county hired an attorney on a permanent basis for us,
that maybe the remuneration was such that very good candidates would
not apply. I have subsequent to that meeting had an opportunity to
meet with the county attorney and with the staff, and I reviewed the
list of applicants, and it became abundantly clear to me that many
very qualified attorneys had, indeed, applied so that that concern was
really not a serious one, and I do believe that Mireya -- and I'm
sorry that she's not here yet -- sat on the selection committee. And
it's my understanding that that selection hasn't been permanently made
yet, but I don't believe there was -- I mean, there should be a
concern by this board that we won't have qualified representation.
The second thing I wanted to report to you was because
Jur second concern, as you will recall, was that we would have someone
to represent our interests in the case of Board of Collier County
Commissioners versus Pacific Land Company. Because of the unique
aspects of that case, it was the concern of this board that we be
adequately advised and represented so that we will know all the legal
ramifications, and we will know what the law is. I'm happy to report
that the county has hired an attorney to represent us. I feel
extremely confident that this law firm is indeed very qualified to
represent us in this particular case, and I want to give you an
opportunity this morning to meet the attorney and the members of his
staff that are here, his associates. And I'm going to give him an
opportunity to say something to you.
We are represented by the law firm of Treiser, Kobza,
and Volpe. In particular Kim Kobza is here as our attorney, and I'd
like to give Kim an opportunity to meet all of you and say a few
words.
MR. KOBZA: Thank you very much, Madam Chairman. I
appreciate your comments. My role for this board, and understanding
that this is a difficult case, and in certain respects it's certainly
factually involved and, you know, there -- there has been much
discussion regarding what law applies and doesn't apply. But my
responsibility to you is to give you clear and concise direction in
terms of the law, in terms of the procedure that you're to follow, and
in terms of any other advice that you may require, whether conflict,
statutes apply or don't apply, how the ordinance mayor may not be
~ead, what type of discretion do you have or do not have under the law
with respect to how the law may apply to the facts of this case, and
Page 2
May 23, 1996
the -- the violations, the alleged violations.
I just got into this case at a very late hour, Friday
afternoon this last week, and have only had the opportunity to review
the -- the notice of violation and the evidentiary packet which was
provided by the county attorney. We have thoroughly reviewed your
ordinances. We've thoroughly reviewed state statutes, but we have not
received any briefing as to the law. There's no -- whether from the
county attorney's office or any other party, we have not received any
statement or any argument whatsoever or positions, nor had we received
them between Friday and today would we be in a position to ad --
advise you as a board as to what our opinions might be and how you
might -- you might -- you might consider the argument, the legal
arguments, that are made -- made to you.
And that's -- that's simply my concern, that you be
properly prepared in terms of our advice to you and that we give you
good, solid and accurate advice that you can be confident will create
the type of record that should be created in this proceeding,
regardless of the outcome of the proceeding. So that's my role.
And what I -- what my intent would be -- and dependent
upon the direction from you, and I take my direction from you. But my
intent would be to, first, answer any questions that you have;
secondly, to perhaps -- and I'm -- I don't want to jump forward to the
-- to the discussion on the continuance, but in the event that the
board does grant the continuance, then we -- as part of that we have
discussed having specific dates by which all attorneys have submitted
all materials to us two weeks in advance of a date certain for this
~oard to have a hearing. And what I would do is provide you with a
~egal memorandum which would give you ac -- that you could read and
and rely upon in terms of how the law -- what the positions of these
two parties are and then what our advice to you would be. So absent
that, I am certainly willing to answer any questions that you may
have.
MR. ANDREWS: Welcome aboard. Kim, I've known you since
you came to town.
MR. KOBZA: Sure. That's right.
MR. ANDREWS: I listen to him about twice a week. Very
capable.
MR. KOBZA: All right. Why, I'm very sensitive to the
role of a municipal attorney. I served as an assistant city attorney
in Norton Shores for seven years, and I've served as a municipal
attorney for 14 townships, 14 boards also for seven years, and I -- I
understand the role of a municipal attorney very well, though, I'm in
private practice today, and I take that role very seriously, and it's
one of giving you -- simply giving you advice, and that's -- that's
how I intend to proceed, is just to give you the best possible legal
advice you can have.
CHAIRPERSON RAWSON: Any board members have any
questions for Mr. Kobza?
MR. LAFORET: Yes. As I read the information charges
presented by the county staff, they're charged with code violations,
county code violations only. There is no other issue. Now, the
county has no regulations, I understand, regarding the application to
~his particular respondent's position. It's my impression, correctly
or incorrectly, that their position is one of at least state and
Page 3
May 23, 1996
probably national decision, not decision of this board. So I'm
rondering if we can proceed strictly with the charges, violations of
county code. And if the results of our decisions are not satisfactory
to the respondent, then they have the right to go elsewhere. But I
don't see that we are responsible for the position they're taking.
It's of state or national.
CHAIRPERSON RAWSON: I'll direct that question to Mr.
Kobza, and he mayor may not be prepared to give you an answer at this
time.
MR. KOBZA: Well, we're not -- starting point, I'm not
sure what the legal positions are or aren't with respect to authority
or whatever. I mean, I just haven't been briefed on what those legal
positions are to be able to respond to that part of your question in
an informed way. I think my caution to you would be that prior to
developing any conclusions, we have to have a full evidentiary record
here because there are certainly factual issues that are involved, and
so as a starting point, until I see law one way or another, I'm not
even in a position really to advise you, and I -- I apologize for
that, but I just haven't seen any --
MR. LAFORET: I wasn't anticipating an answer today,
Counselor.
MR. KOBZA: Sure.
MR. LAFORET: I was -- my attempt was to tell you the
problems that I have with the -- with the situation as it sits now.
CHAIRPERSON RAWSON: Any other questions for --
MR. ANDREWS: Well, I think -- I think we all agree with
~hat. I think -- what, there have been three -- continued three
~imes, and it -- and it's a bunch of attorneys trying to work out
something. I don't kn9w what. And I feel the same way that Mr.
Laforet does, that we're here just for one reason, and that's --
that's to enforce county codes, and we've been informed by our staff
that there is definitely a violation, and we've been prepared since
August, I think, to hear this thing. And then the day before
yesterday I got notice that they want to continue it again. And I see
no sense in it because -- in the continuance, because all -- all we're
going to do is hear the -- hear the case, hear their side of it, and
-- and make a -- make a decision, and I see no sense in putting this
off and off and off and off. I mean, the lawyers are having a ball, I
know, on this one. But -- and every -- seems that every time the
respondent has a different attorney, and they have to go through the
process, and -- which I understand, but we shouldn't have to suffer
for that. We've got other things to do. That's my opinion.
CHAIRPERSON RAWSON: Mr. Andrews, you'll get an
opportunity when we get to that part of the agenda this morning to
vote.
MR. ANDREWS: Well, I understand that, but this went
along with -- with what Mr. Laforet said, and I agree with him.
CHAIRPERSON RAWSON: Any other questions?
Mr. Kobza, would you introduce your associate and your
summer law clerk?
MR. KOBZA: The associate from our office that's helping
in our preparation is Catherine Kidon. Catherine has been with us for
~wo years now, came out of a Washington, D.C. law school. Andrew--
I'm sorry -- your last name?
Page 4
May 23, 1996
MR. REISS: Reiss.
MR. KOBZA: Andrew Reiss just joined us this week as a
~aw clerk from the University of Miami, and Andrew also is very
talented, but this is his summer experience in Naples, Collier
County.
MR. ANDREWS: This is a good one to get trained on.
MR. KOBZA: Right.
CHAIRPERSON RAWSON: Thank you very much.
Well, we'll move on to the approval of today's agenda. Do I have a
motion to approve the agenda?
MR. McCORMICK: I make a motion that we approve the
agenda.
MR. ANDREWS: Second.
MR. McCORMICK: Are there any changes to it?
MS. CRUZ: No changes to the agenda.
MR. ANDREWS: I'll second it.
CHAIRPERSON RAWSON: Moved and seconded that we approve
today's agenda. Any discussion? All in favor?
Let the record reflect that I've just received a message
that Mireya Louviere is ill today and has requested that she be
excused.
The next item is the approval of the minutes of the
March 28th, 1996, meeting. Are there any corrections or additions to
those minutes? Do I hear a motion for approval of those minutes?
MR. ALLEN: I'll so move.
MR. ANDREWS: I'll second it.
CHAIRPERSON RAWSON: Moved and seconded that we approve
_he March 28th, 1996, minutes. All in favor please signify by saying
aye.
So approved.
The next item on the agenda is public hearings, and
there is, as you all well know, only one public hearing that is before
this board today, and that is the Board of County Commissioners versus
Pacific Land Company. So at this time I would call on the county
attorney or the county staff to proceed with -- with that hearing.
MR. MANALICH: May it please the board, fellow counsel.
Good morning, Ramiro Manalich, chief assistant county attorney
appearing on behalf of county staff, also along with Shirley Jean
McEachern, assistant county attorney. I guess the best way to kick
this off is by referring to the conference call that, Madam Chairman,
you had along with my office, Mr. Kobza, and the attorney for Pacific
Land Co. who is here today, Kate English. And at that conference call
Ms. English presented a request for a continuance which was then
reduced to writing and delivered on Monday, and you should have all
received a copy of that request for continuance. I'll let Ms. English
address that request, but I will mention to the members of the board
that essentially the result of the conference call was that the county
position on the continuance is that we would not have objection to the
continuance, although we want to make it very clear we were not
requesting the continuance, but we would not oppose it provided that
this matter would be continued for one month and one month only and
that it be understood that at that next hearing date this matter would
oither be tried or settled to its conclusion. But I'll let at this
time Ms. English then address the matter of the continuance.
Page 5
May 23, 1996
CHAIRPERSON RAWSON: Thank you.
MS. ENGLISH: Good morning. My name is Katherine
Bnglish. I represent Pacific Land Company in the matter of Collier
County Board of County Commissioners versus Pacific Land Company. At
this time I was under the impression from the counsel for the
Independent Traditional Seminole Nation that they wanted to be present
by telephone. Did they contact you about that, Ramiro?
MR. MANALICH: On that point, the counsel for the
Seminoles consists of two legal entities; the Indian Law Resource
Center, Robert Coulter specifically, and also the law firm of Holland
and Knight out of -- in Tallahassee principally, and specifically
Martha Barnett, attorney at law. And we have had obviously ongoing
communication with them. It was my understanding that I was going to
be contacted yesterday by them if they wished to appear today by
telephone. That did not occur.
I did make a call late in the day to their office, was
not able to reach Martha, and left a message. I have not had any
message this morning. My understanding is that we do have the
speakerphone capability here, but I will also inform the board that on
May 10th of this year in one of Ms. Barnett's letters she indicated
that it was the intention of the Independent Traditional Seminole
Nation to intervene in this case formally and that they would be
taking advantage of the opportunity to provide a defense packet or
information. Now, neither of those things have occurred to this
point, but that was their stated intention.
MS. ENGLISH: I spoke with Laura Bellflower late
'Testerday afternoon, probably 5:30, and I think that she tried to
~each you. I know that she was not successful. I spoke with her
seven -- at 7:30 last night. I don't know if she left a message on an
answering service or what, but she asked that we -- that I convey that
request.
MR. MANALICH: Was it their intent then to want to at
least be allowed the opportunity to participate then by speakerphone
today?
MS. ENGLISH: I think they just wanted to listen to what
was going on today.
MR. MANALICH: I should clarify for the members of the
board so we don't get confused, the county position is that there's
only one respondent party in this case, and that is Pacific Land Co.
or Land Company. For the record, will you clarify which?
MS. ENGLISH: For the record, the information I've
received is it's the Pacific Land Company.
MR. MANALICH: Company, okay. Well, in any event, our
position is that they are the only respondent in this case. Now, we
recognize that there are other interested persons or groups in this
matter, one of which may be the Independent Traditional Seminole
Nation, but they have not been charged. They are not a party. We
would maintain that they do not have standing. However, if the board
so directs this morning, we certainly would not be opposed to them
being able to be hooked up to listen to the proceedings via
speakerphone, and my understanding from staff is we have that
capability.
CHAIRPERSON RAWSON: Any discussion on whether or not we
should call and hook the attorneys up so that they can be a part of --
Page 6
May 23, 1996
at least listen to this discussion this morning?
MR. LAFORET: I would like to make a statement. I would
dgree with the county's position that the interests of other parties
are not applicable to appearance before this board. It's not our
business. Only the charges entered by the county would be our
business is my opinion and, therefore, we shouldn't waste county time
and other people's money in having people appear before us when we
can't decide their position.
CHAIRPERSON RAWSON: Any other discussion?
MR. MANALICH: You -- Madam Chairman, in fairness to the
board and to everyone concerned, you may want to -- as Mr. Kobza had
mentioned earlier, you may want to reserve ruling on that type of
issue for that time if and when a motion to intervene is made as far
as intervention. As far as participation by speakerphone, obviously
you'll need to decide that this morning but
CHAIRPERSON RAWSON: Well, in terms of a motion for
intervention, there's not one before us.
MR. MANALICH: Correct.
CHAIRPERSON RAWSON: And so we can't rule on something
that's not before us.
MR. MANALICH: Exactly my point.
CHAIRPERSON RAWSON: But in terms of letting them listen
on the speakerphone, we'll ask our attorney for some advice.
MR. KOBZA: It's not legally required. We haven't
gotten to the point of discussing or deciding whether due process
requires that they be -- that any third parties be parties to this
~ction. At this point it is not legally required. You do have the
liscretion certainly to as a board allow that type of procedure. So
you have the discretion, but you're not legally required to do it.
CHAIRPERSON RAWSON: Thank you. I guess I would ask for
a motion.
MR. McCORMICK: I have no -- no objection to making the
effort to call them, if this case takes the course that I think a
prudent person could -- could follow, that there will be some
following lawsuits and legal battles. I see no reason to -- to keep
out this potential third party at this point. If -- if we can get a
quick hookup, then I see no harm in having them listen in.
CHAIRPERSON RAWSON: Is that a motion?
MR. McCORMICK: That's a motion.
CHAIRPERSON RAWSON: Is there a second?
MR. ALLEN: I'm -- I'm the opposite side. I believe
they have counsel here to represent them.
MS. ENGLISH: I'm sorry. I do not represent the
Independent Traditional Seminole Nation.
MR. ALLEN: I'm sorry. I said that incorrectly, okay.
Had they wanted to be here, they should have had someone present.
This is a public notice. You represent Pacific Land Company;
correct?
MS. ENGLISH: Yes, sir.
MR. ALLEN: I think the third party -- had they needed
had they wanted to be here, they could have had a representative
here. They had all day long to call Mr. Manalich yesterday and didn't
10 it. I think we've extended enough courtesy.
MR. MANALICH: That statement is correct, Mr. Allen, as
Page 7
May 23, 1996
I indicated earlier. But I do want to clarify that as far as their
)hysical attendance here, they had been talking to me about perhaps
participating by speakerphone. I did not indicate any opposition to
that. I mean, I'm not the decision maker, but they were under the
impression, I think, that the speakerphone route might be available
since they're from Tallahassee and the matter might be continued. The
only thing that has happened, though, is that I did not receive any
contact, although Ms. English indicates that apparently an attempt was
made after the office closed yesterday. That's where the matter lies.
MR. ALLEN: I guess my point is that they -- sort of
different than Mr. -- Mr. McCormick's is that the third party, okay,
isn't a part of our discussion today. This is strictly board of
Collier County Code Enforcement versus Pacific Land Company. The
third party is a nonentity.
CHAIRPERSON RAWSON: I'm going to second Mr. McCormick's
motion for the reason that -- and, again, forgive me for thinking like
an attorney. I can't help it after all these years. Since we've had
indication by letter of the intent to intervene, it seems to me that
whether they're not a party today or not and we haven't had that
motion before us to rule on, it looks like they are intent on
requesting that they become a party, nor do I think that it's going to
hurt if they listen since they are probably not going to participate
in the discussion. And it might be helpful, since they may be here
when we get to the hearing point. So I'm going to second Mr.
McCormick's motion.
MR. McCORMICK: Let me add something for clarification,
too. If they're listening in to this hearing, it would be at our
discretion whether or not they participate.
CHAIRPERSON RAWSON: Correct.
MR. McCORMICK: And I think that we can discuss that
again if that opportunity comes up. But my motion is that at this
time we -- we do make the effort and allow them to listen.
CHAIRPERSON RAWSON: Right.
MR. MANALICH: County position is to the extent that the
motion's been made, we would not have a position contrary to the
motion with the clarification that that in no way indicates that the
county is agreeing to intervention. We're talking two different
issues. One is simply being given the opportunity to listen in via
the speakerphone route versus actual intervention and participation in
the case.
MR. LAFORET: I would take a position against the motion
in the respect that it's been known -- this case is almost a year
old. They were aware of the violations. Now then, they're aware of
this hearing, and they haven't shown enough interest to be here.
Well, if that's their lack of interest, why waste time and money on a
speakerphone?
MR. MANALICH:
MR. LAFORET:
here to listen --
MR. MANALICH: Mr. Laforet, just for clarification, I do
feel it's necessary to be clear for the record that I believe that,
you know, Holland and Knight is located in Tallahassee, and their --
their principal attorney is a long ways away, and they they were
told that this subject would be -- a continuance would be discussed
Mr. Laforet --
If they're not interested in attending
Page 8
May 23, 1996
here today and very likely supported by everyone concerned. For that
~eason, they understood that they might have the ability at least to
listen in by speakerphone as opposed to incurring the expense and time
of the long travel. So I don't want it to reflect negatively on
Holland and Knight that they're not physically here, because in the
discussions with me, they understood that although I was opposed and
continue to be opposed to their intervention, they might be able to
listen in by speakerphone as opposed to being here in physical
presence. So I just -- I don't want that to be held against them
because of that background.
MR. ANDREWS: I'd like -- I'd like to ask you a question
about -- about this hookup on this speaker thing. What -- how
complicated is that and how expensive and who pays it?
MR. MANALICH: I believe it's ready to go. We've used
it at other hearings before.
MR. ANDREWS: The thing that -- I really don't have --
have any objections at having them here. I wish they were here to
hear what we have to say if we are going to have that continuance
today. The thing is, we've had so many continuances, that to have it
would seem to be a habit and they just took it for granted that this
is going to be continued and didn't bother coming, but we bother
coming all the time. We're the guys -- so I think it's time that we
pulled the chain the other way and -- and I'm all for going -- as I
spoke before, I'm all for going ahead with the thing. It's incidental
whether they want to listen or not. I don't care.
MR. MANALICH: I don't mean to be an advocate for
~olland and Knight here obviously, but I do want to just be fair on
che record, and that is that in response to your comments, you know, I
don't know why I wasn't contacted yesterday during normal business
hours. However, I can tell you that they have had an ongoing interest
in the matter and have expressed that and contacted me regularly on
that basis. So I don't believe that their nonappearance here today
should be in any way deemed a bad reflection on them or lack of
interest but, again, our position is we would not be opposed to the
motion as presented clarifying that that does not mean we stipulate to
intervention or participation.
CHAIRPERSON RAWSON: While we're still in the discussion
subject, I'd just like to say to the board that, as you know, we have
a lot of discretion. While we are a quasi-judicial board, the rules
of evidence don't strictly apply, and it's always been the position of
this board to let whoever wanted to say something say something. And
we've given a lot of latitude in the past of letting all interested
parties have their say. Then we sift that evidence in making our
determinations, and we decide what weight to give to that evidence.
It seems to me that this is merely a request by an attorney who is
probably going to want to represent the interests of the tenant on the
land to listen in. I don't see how any prejudice would be affected by
allowing them to listen in. And I think we should give everybody
latitude in a case that's as important as this. That's why I seconded
the motion.
MR. ALLEN: Point well made. I'll rescind my
objection.
MR. ANDREWS: You know, I don't know -- I don't think
there's any objection.
Page 9
May 23, 1996
CHAIRPERSON RAWSON: Well, if there's no more
1iscussion, then I'll call for the vote. It's been moved
that we allow the firm of Holland and Knight to listen in
speakerphone to this morning's proceedings. All in favor
motion, please signify by saying aye.
All opposed?
MR. LAFORET: No.
CHAIRPERSON RAWSON: The motion carries. And if the
staff would kindly see if you can get them on the telephone and fix
the speakerphone, we would be appreciative.
MR. ANDREWS: We haven't decided yet whether we're going
to -- whether we're -- whether we're going to approve a continuance,
have we?
CHAIRPERSON RAWSON: No.
MR. ANDREWS: So we
CHAIRPERSON RAWSON:
to the motion.
MR. ANDREWS:
continuance.
MR. MANALICH: Madam Chairman, if I may approach, I
believe this is the speakerphone here.
CHAIRPERSON RAWSON: Yes.
MR. MANALICH: And if you don't mind --
CHAIRPERSON RAWSON: Go right ahead.
MR. MANALICH: I think Ms. English has the direct dial.
Hello. Is this Laura? Hi. This is Ramiro Manalich,
the chief county attorney. How are you? I'm calling you from the
20de Enforcement Board hearing. It's my understanding through Kate
English -- we were not able to speak yesterday, but it's my
understanding through Ms. English that you desire to listen in, and
the board has voted just now to allow you to do that on the
proceedings today. Do you mind if I put you on the speakerphone?
Okay. All right.
She's going to also patch in Ms. Barnett so that both of
them can listen in so it will be just momentarily. We have one of
these phones up in my office; that's why I'm --
Yes. Okay, Martha, good morning. How are you? I'm
about to put you on the speakerphone. We're in the Code Enforcement
Board proceeding. The board has just voted to allow you to listen in
to the proceedings. So if you don't mind, I'll put you on the speaker
now. One moment. Can you hear me?
CHAIRPERSON RAWSON: Can both sides hear? Can you hear
the board? This is Jean Rawson, the -- the chair of the Collier
County Code Enforcement Board. Can you hear the proceedings?
MS. BARNETT: This is Martha Barnett with Holland and
Knight. I can hear you fine. Thank you.
CHAIRPERSON RAWSON: Thank you. We are about to get to
the next item on the agenda, which is the public hearing of Board of
County Commissioners versus Pacific Land Company and Ms. English, who
represents them, is here, and she is about to make a motion, and
hopefully you'll be able to hear her. Go ahead, Miss English.
MS. ENGLISH: Good morning, Martha.
MS. BARNETT: Good morning.
MS. ENGLISH: Members of the board, I'm here today to
and seconded
by
of the
All they're doing is listening in
Oh, they're listening in on the
Page 10
May 23, 1996
request a continuance on the behalf of Pacific Land Company in this
~atter. I know that all of you have received a copy of the motion for
~ontinuance that I submitted to the county attorney's office and to
your attorney earlier this week, and I'd like to briefly state the
grounds on which I'm basing this request. First of all, I was
retained on this matter by Pacific Land Company on May the 9th. I did
not receive a copy of your packet, the enforcement packet, until May
the 8th. Pacific Land Company does recognize the seriousness of this
matter, and I don't want you to think that they have abused the county
when you have been extremely indulgent in granting continuances on
this issue.
From my conversations with the county attorney's office
and with counsel for the Independent Traditional Seminole Nation, I
have discovered that there are a number -- excuse me -- of complex
social and legal issues associated with this matter, particularly in
regard to the state and federal law dealing with the rights of native
Americans. While I recognize that the county has a need to proceed
with this in a timely fashion, I am requesting only a limited
continuance, 30 days, with the understanding that we will appear
before the board at the next meeting to present to you either the
arguments in this case or to present to you an executed settlement
agreement with the parties proceeding to complete the terms of that
agreement in good faith. We have -- I have agreed on the behalf of
Pacific Land Company to submit briefs to your counsel two weeks prior
to the hearing so that he may adequately prepare on this matter. I,
too, would like the opportunity to adequately prepare on this matter
so that I may represent my client's interests in this case. Based on
~he foregoing and on the motion that I filed with your attorney, I
request a limited continuance in this matter for a period of 30 days.
CHAIRPERSON RAWSON: Response from the county?
MR. MANALICH: Madam Chairman, as I alluded to earlier,
the county has at this time no objection to the request for a
continuance with the following clarifications and conditions: The
first is that this be a limited one-month continuance. This matter
has already been pending far too long, and the only thing I take issue
with Ms. English on is in regard to the county sees it as a very
straightforward case regarding the enforcement of rather clear code
provisions. And given that, we believe that all the parties should be
ready to be here in June to have this matter either tried to its
conclusion or to announce any type of final settlement at that time.
We have no objection to Mr. Kobza's request to have some
types of memoranda of law submitted by, I believe, the June 13th date,
and we just want to make it very clear that it is not the county staff
that is requesting this continuance, but we are not opposed as it has
been presented.
CHAIRPERSON RAWSON: Before we vote, let me ask Mr.
Kobza if he has some advice for this board.
MR. KOBZA: Madam Chairman, in one sense I have a very
narrow interest, regardless of how complex or how simple this case is,
but the fact is I was just -- just brought in on your behalf this
Friday and have not had the opportunity to review any law, any facts,
any anything. My interest is in making sure that you as a board have
~he best possible legal advice. I think that's especially important
in this case because whether it goes up on appeal from the county or
Page 11
May 23, 1996
from the -- the perspective of the alleged violator, both parties in
~his type of action do have a right of appeal. Either or both sides
will spend significant resources at that point in time and on future
litigation. The potential -- or let me maybe put it this way: The
disposition of whatever those future actions might be will be directly
dependent upon the procedure that you follow and the record that you
establish here, and for that reason it's extremely important that I be
able and be in a position to give you the best possible advice.
Dealing with virtually no information today, no resources today, it's
-- you know, I cannot confidently be in a position to tell you I can
do that. And for that reason, I did not object and actually supported
the request on that very narrow -- for that very narrow reason, and
that's -- I -- I think it's incumbent upon you to provide absolute due
process to everyone here, and I think to do that you do need to have
proper advice. So my advice to you is if -- and, you know, and I -- I
-- let me put it this way to you. Two weeks from now I would expect
to have these briefs. I expect to have the law sitting on my desk on
June 13th, and I expect to be in a position to give you good advice.
And when June 27th rolls around, which I believe is your board
meeting, labs -- there is no reason from our standpoint that you will
not be in a position to have the best advice available. So that would
be my -- my comments and input to you as a board.
CHAIRPERSON RAWSON: Thank you.
MS. ENGLISH: Mr. Kobza, let me clarify. You said two
weeks from today or three weeks from today?
MR. KOBZA: Let's -- let's have a specific date. June
the 13th, which is a Thursday, whether that's -- I believe it's three
Neeks actually --
MS. ENGLISH: Thank you.
MR. KOBZA: -- from today, but whatever June the 13th is
so that I have two weeks in advance and I don't get materials at the
last minute and I'm in a position of trying to again advise you with
three days' notice; that's -- that's what I would ask for.
MR. MANALICH: Madam Chairman, the county would request
a clarification, which is we have provided essentially the majority of
our case already to the parties as well as to the board. Obviously
we've invited the other party to do so as well. Is -- Mr. Kobza, are
you or is the board requesting further written argument or material or
authority from the county?
MR. KOBZA: The -- the evidentiary packet is the factual
basis and the ordinances. I have not at this point seen any -- let me
-- let me put it this way to you. If -- if you want to rely upon
that, that's certainly within your absolute discretion. To the extent
that you would want to provide any additional legal argument, I would
provide you with the opportunity to do that. But whatever additional
legal argument that you would provide, I would ask you do that by that
date. For instance, you can anticipate what the board's questions may
well be, and you can anticipate what the alleged violators' legal
arguments may be. I don't want to be in a position where those
arguments are being made before this board for the first time without
having the opportunity to properly assess the arguments and provide
independent advice to the board on my own, which is my responsibility,
:0 provide independent advoice -- advice to the board. Likewise, Miss
English, I -- I would -- I would make the same statement as to the
Page 12
May 23, 1996
alleged violator.
MR. MANALICH: The only -- the only concern I have of
that, Mr. Kobza, is that the county may be at a disadvantage because
we have essentially exposed and displayed our case for a number of
months now, which other -- which the other party -- although I know
Ms. English came on board late, but they've had that defense packet at
least for a month, and obviously the nature of the charges have been
well publicized beforehand. Now we're in the position where we don't
know what their defense is going to be.
MR. KOBZA: All right. Yeah.
MR. MANALICH: And we would like an opportunity to react
to what they present.
MR. KOBZA: I absolutely concur with you, and I it
would be my intent that -- and I think maybe the best thing for us to
do would be to collectively, you and myself and counsel for specific
-- Pacific Land Company, to perhaps sit down after the hearing today,
if a continuance should be granted, and develop an understanding as to
procedure. But in the interest of due process and fairness to all
parties, it would be my intent, if we could agree, that all
information be collectively shared and that you have the opportunity
to have the arguments of the alleged -- of -- of Pacific Land Company
in advance of the hearing as well. In other words, it's a concurrent
device. You have everything that they submit. They have everything
that you submit.
MR. MANALICH: Well, the only difference being, though,
that they're going to have the opportunity to tailor their written
~esponses to what we already have of record. What I'm suggesting is
you've mentioned the 13th. Perhaps if the county could have another
week after the 13th -- is there two weeks between the 13th and the
hearing date?
MR. KOBZA: Yes, there is.
MR. MANALICH: Then what I would request is that the
county be allowed at its discretion one week to react in writing to
whatever they submit on the 13th.
MR. KOBZA: I certainly would have no problem with
that.
MS. ENGLISH: I object to that. If you'd like to
develop some sort of procedure for discovery after this meeting if --
should this continuance be granted, I have no trouble with that. But
I have trouble with proceeding at a point where you get all of our
arguments and a chance to respond and we have -- I'm assuming that
we're going to be limited.
MS. BARNETT: Madam Chair, this is Martha Barnett. I
have lost the ability to really hear the discussion among counsel, if
somebody could summarize it for us.
CHAIRPERSON RAWSON: Ramiro, why don't you do that.
MS. BARNETT: Ramiro, you may need to get closer to the
phone because you fade out pretty quickly.
MR. MANALICH: The -- can you hear me, Martha?
MS. BARNETT: I can hear you now. Thank you.
MR. MANALICH: Yes. The discussion is in regard to
counsel for the board, Mr. Kobza, providing that he would like to have
)y June 13th the written legal positions of the parties. And the
county is stating that since we have already presented our charges and
Page 13
May 23, 1996
supporting evidence in writing quite some time ago, that we believe we
~hould be afforded, perhaps, one-week latitude after the 13th to
respond to any of the written legal arguments of Pacific Land Co. Ms.
English has indicated objection to that.
MR. KOBZA: May -- maybe I can help here. The purpose
of the 13th -- let -- let me just maybe make it clear this way, okay?
The purpose for the 13th is to make sure that I have whatever
documents they want to submit to me so that I can advise the board.
Either -- Mr. Ramiro, either you or Miss English can submit any
additional documentation or arguments that you want subsequent to that
date, and certainly I -- I believe by rule and ordinance the board
would be in a position where they would have to consider whatever else
was submitted. It's not a cutoff. It doesn't prohibit you from
responding, nor does it prohibit you, Miss English, from responding.
But what I am saying to both of you, is that if you expect me to
adequately prepare and provide advice to this board, I expect the best
and fullest briefing of -- of the anticipated issues well in advance
of the board meeting. It's -- it's really that simple.
MR. ALLEN: Mr. Kobza, my understanding -- maybe I'm
confused -- is that the only thing we're looking at this morning is
that either we continue or we don't continue.
MR. KOBZA: Right.
MR. ALLEN: And if we don't continue, our Exhibit A is
the only thing in question. Isn't it that simple? I mean, we only
have pages 1 through 34 of Exhibit A that we're talking about this
morning.
MR. KOBZA: I anticipate that there are going to be
~ite a number of legal issues raised with respect to how the
ordinance applies or doesn't apply, what the -- the adequacy of
notice, perhaps. I mean, there could be all types of legal arguments
which I am not in a position to advise you of today, and that's the
problem.
MR. ALLEN: I understand.
MR. KOBZA: You know, that in a nutshell is the
problem. In one sense it is very straightforward, but my discomfort
is that I can't -- you know, I'm trying to give you advice with one
hand tied behind my back here.
MR. ALLEN: I sYmpathize with your position entirely.
MR. KOBZA: All right. .
MR. ALLEN: But, however, we've known that this was
coming for, like, three or four months.
MR. KOBZA: Right.
MR. ALLEN: I think -- I think it's unfair to you to be
brought on board last Friday when we had 90 days' notice. However,
this is a simple issue this morning. We only have pages 1 through 34,
okay. If due process was done, I don't -- I don't see this as -- as a
major scenario.
MR. MANALICH: In regard to the 13th cutoff, the county
would have no problem with that with the proviso, I think, Mr. Kobza
clarified that in -- both parties could additionally supplement after
the 13th, but he expects that the argument and the substance of the
~rgument will be to him on the 13th.
MS. ENGLISH: I concur with Mr. Manalich on this point.
CHAIRPERSON RAWSON: Well, let's do this. We need to
Page 14
May 23, 1996
have the board vote on whether or not the motion for continuance is
going to be granted or not. And thereafter we can talk about when
legal briefs are due. However, the board probably will have no need
to vote on that if the attorneys have reached concurrence here, and if
you all have all agreed that this board will be adequately advised and
informed well in advance of the hearing so that we will be prepared to
proceed, and if you attorneys can reach agreement on that, then
there's no need for the board to vote on that.
But we do need to vote on your motion which has been
made for continuance, and I understand that there is no objection from
the county, although the county makes it clear that they are not
joining in the motion. Is there any discussion on that motion?
MR. McCORMICK: Let me ask a question to Miss English,
this process being new to me. What is going to be included in this
memorandum of law that the respondents haven't been able to put
together up until now?
MS. ENGLISH: Bear in mind that I came -- I was retained
on this matter on the 9th.
MR. McCORMICK: Right. I understand that.
MS. ENGLISH: And most of last week I spent doing
factual investigation trying to figure out what the situation was. At
this point I am only beginning to develop my legal arguments. There
is a lot of research that I need to do. I really am not -- I'm really
not prepared to discuss what those arguments are, but I am concerned
that there are other parties to this who are not sitting at the table,
and without that it would be very difficult for us to reach a complete
adjudication or decision on the matter that would be a just and
equitable resolution to the issue before you. That's my current
concern.
MR. McCORMICK: So the information that you present is
just going to be in response to the -- to the accused violations.
MS. ENGLISH: I cannot tell you that it will be --
MR. McCORMICK: To Pacific Land Company?
MS. ENGLISH: Yes. I will be responding in terms of
Pacific Land Company and responding to the notice of violation, but
there are other issues that are associated with it in terms of
procedure that I need to more closely examine.
MR. McCORMICK: Okay.
CHAIRPERSON RAWSON: Are there any other questions of
either attorney or any other discussion on the motion?
MR. LAFORET: Yes. The attorneys have taken care of
themselves pretty well. I would like to clarify your position that
the board be advised of any communication decided upon by the
attorneys at least 10 days in advance of the hearing not adequate time
because we could get it six O'clock this morning and say that's
adequate for you. Adequate is ten days.
CHAIRPERSON RAWSON: I -- I can share your concern, Mr.
Laforet. That's why at the conference call that Mr. Kobza and I had
with the various attorneys involved in this matter we reached the
tentative agreement that we will have these legal arguments by June
13th so that Mr. Kobza can properly advise this board so that this
board knows what it's doing. I think that this is a very important
case. This case is very likely to be appealed. We want to protect
our record. We want to be sure that we proceed correctly. My concern
Page 15
May 23, 1996
is that we don't do anything to embarrass the Collier County Code
Enforcement Board and that we don't do anything to embarrass Collier
County and that we proceed in a just and proper manner. So I share
your concern, and I've been assured that we are going to get that
information well in advance.
MR. McCORMICK: Madam Chairman.
CHAIRPERSON RAWSON: Yes.
MR. McCORMICK: Are you under the understanding that you
would be included in any additional conference calls between the three
parties, or --
CHAIRPERSON RAWSON: I don't know that.
MR. McCORMICK: Okay.
CHAIRPERSON RAWSON: I don't know the answer to that
question. My attorney would have to advise me.
MR. McCORMICK: Mr. Kobza.
MR. KOBZA: Certainly if it -- let me -- let me go at it
this way. You have the discretion as a board to develop your
procedure, okay. And if it's your desire as a board that the chairman
be a party to whatever calls might take place, then you as a board can
make that determination. I believe that has been past practice of the
board, if I'm correct in that respect.
CHAIRPERSON RAWSON: That -- that is correct, but it's
up to this board.
MR. KOBZA: So you have that d~scretion. You -- you
have the discretion as a board to develop what you believe to be the
appropriate protocol to be followed.
MR. LAFORET: Do I hear correctly from Miss English; are
you in agreement with the stipulations presented by the county? I
heard them present their stipulations on if a continuance is provided,
but I haven't heard your agreement to those stipulations.
MS. ENGLISH: I apologize. I thought I covered that in
my presentation, but I'm happy to go back over them. I requested this
continuance on a limited basis for 30 days with the understanding that
this would -- matter would come before your -- the board meeting at
the end of June to be either -- you would either be hearing legal
arguments, or you would be hearing the circumstances of an executed
settlement agreement -- that was my understanding -- and that by the
13th of this month you would have -- your counsel and the county
attorney's office would have my legal briefs on this matter.
MR. LAFORET: I appreciate your legal description of
what you're going to do, and all you have to do is answer me yes or
no. Do you accept the stipulations of the county on a granting of a
continuance?
MS. ENGLISH: Yes.
MR. LAFORET: All right. Thank you. That's all I
needed.
CHAIRPERSON RAWSON: Well, we're back to the motion for
continuance which is still before this board. And is there any
further discussion or questions to any of the respective counsels in
regard to that motion?
MR. McCORMICK: I don't have any other questions.
just wanted to at some time today state for the record
discussion with Mr. Kobza yesterday, and I just wanted
before we vote on the matter. We discussed if I would
I
that I had a
to say this
have any
Page 16
May 23, 1996
potential conflicts, my emploYment with wilkison and Associates
engineering firm, and it was the advice I received that I didn't have
any conflicts so --
CHAIRPERSON RAWSON: I appreciate that.
MR. McCORMICK: -- I'm here, and that's why I'll be
participating in the vote, too.
CHAIRPERSON RAWSON: I appreciate that, Mr. McCormick,
especially since we're going to need your vote here since we don't
have all of our members present today. Let me say this: You
understand that Mr. Kobza is our attorney, all of us. We can't all
talk to him unless we talk to him at the same time or unless one of
you talks to him alone because of the Sunshine Law. We have to be
very careful about that. But if you have a question like Mr.
McCormick had, you know, feel free to call him and discuss that matter
with him. Whether or not I will participate in any discussions with
the attorneys we should probably reserve on until we decide on the
motion for continuance. If there's no further discussion, I guess I
need a motion.
MR. ANDREWS: I'd -- I'd like to speak again. I made my
little speech to start with, and -- and if I'm wrong -- if I'm wrong
on this, I want -- I want the board to let me know and the staff.
What we're here for today -- originally here for today is to hear a
code violation, a Collier County code violation. That is the only
thing that we can do here is -- is -- is to work entirely on -- on
code -- on the code -- that's what is code enforcement board; am I
right so far? Other words, there's a lot of things come -- coming.
We can fill this place with people and listen to all kinds of stories,
but this is the thing that we're going to decide and -- at the
meeting. And -- and --
CHAIRPERSON RAWSON: I'll defer that question again to
our attorney.
MR. ANDREWS: Okay. So I want to hear from our staff,
too. I haven't heard a thing from the staff today out -- outside of
Ramiro and -- and he says he doesn't care one way or another. If this
is the only thing that we're involved in and these people didn't
choose to come, in case we didn't want to hear it, I just don't see
why we should continue it. I mean, you know, there's been too many
continuances, I mean, and this -- you know, there will be another
one. I don't care what the specifics are. there will be another one,
so -- but am -- am I right? Am I right in what I've said, that this
is what we're here for today, just this one violation, that they
didn't get a permit? And -- all these -- all these legal ones.
CHAIRPERSON RAWSON: Well, I can answer the question
only that, yes, you're correct. That's what we're here for today.
But, as you know, because you've sat on this board probably since its
inception, there are always other things that come up such as notice,
violations of rules of procedure, whether or not due process has been
afforded, jurisdiction. And those things are -- come into play, too.
And I believe what our attorney is telling us is that if some of those
arguments are made by either of the other parties, he needs to be
prepared to advise us on those. In other words, Mr. Andrews, I don't
think that the attorneys are telling us that it's as simple as a
one-issue case.
MR. ANDREWS: Well, I -- I still haven't heard from -- I
Page 17
May 23, 1996
haven't heard from staff. I mean -- you know, there's all kinds of,
you know, state laws and federal laws and all kinds of things that
we're not involved in that. And this is what's going to happen to us
here for sure, have a house full of people, spend all day, and still
wind up doing just exactly what we could do today. That's the way I
feel. And if I'm wrong, I want somebody to say so, staff up there,
the guys that are involved in the thing.
MR. MANALICH: Looks like I'm being pointed at so --
MR. ANDREWS: No, I'm talking about behind you, too.
MR. MANALICH: Okay. Well, Mr. Andrews, today I'm
speaking on behalf of staff, so I can address that.
MR. ANDREWS: Okay.
MR. MANALICH: Can the parties by the speakerphone here
me?
MS. BARNETT: We really -- I can't hear -- I could hear
Mr. Andrews, but that was it.
MR. MANALICH: Let me approach, Madam Chairman, so I'm
closer.
CHAIRPERSON RAWSON: Please.
MR. MANALICH: Can you hear me better now?
MS. BARNETT: Thank you, Ramiro. I can.
MR. MANALICH: Okay. In response, Mr. Andrews, while
the county certainly agrees with you that in our view the issues are
rather straightforward under the code, we are cognizant of the fact
that Ms. English says that that may not be the case. Basically the
county, even though it's very much desirous of proceeding on this
matter today and would have been -- and is, in fact, ready, we also
recognize that we have a record that needs to be defended should this
matter eventually be appealed. And for that reason, based on Mr.
Kobza's comments, based on Miss English's explanation of her late
entry into the case, we do not object to a limited one-month
continuance.
MR. ANDREWS: Okay, thank you.
CHAIRPERSON RAWSON: If there's no other discussion, I
guess we're ready for a motion.
MR. MANALICH: I -- I think, Madam Chairman, there
one other thing that would be involved in your motion.
don't know if this -- through the microphone system can
and Knight people hear me adequately, or are they still
trouble?
MS. BELFLOWER: I can hear. Martha, can you hear?
MR. MANALICH: Can you hear me adequately?
MS. BELFLOWER: Right now I can, Ramiro.
MR. MANALICH: Okay. I'll just keep closer to the
microphone then. In regard to your motion for continuance, I didn't
hear a specific date being mentioned. Obviously the county insists
that it be within the next month. Even though we have taken a strong
position and continued to assert that we do not believe that there are
any other parties other than Pacific Land Company to this case, as I
indicated earlier in my discussion with you, I have correspondence
from Attorney Barnett that indicates a desire to intervene formally in
this action. We are opposed to that but, nonetheless, I feel it's
incumbent on me to bring up that in my discussions with Ms. Barnett,
she did indicate that if June 27th were selected as the next hearing
is
And, again, I
the Holland
having
Page 18
May 23, 1996
day, which I think would be the next date in sequence, that might be
problematic for her for -- to -- on that limited point, I would be
interested in hearing Ms. Barnett's comment.
MS. BARNETT: Madam Chairman.
CHAIRPERSON RAWSON: Yes.
MS. BARNETT: Our -- as many of -- I think as all of you
know, our law firm, Holland and Knight, represents the Independent
Traditional Seminoles. It is our intention to participate in the
proceedings of the Code Enforcement Board and to abide by whatever
your procedures and rules are that you establish such as the ones
you've been talking about today. And Ramiro is correct; the June 27th
date is a problem for me personally. It is also a problem for Tim
Coulter of the National Indian Law Resource Center who has been
working with the county in an effort to try to find an amicable
settlement to this matter. If the 27th is the date that current
parties and everyone agrees to, we will find a way to accommodate our
schedules to that. It would be better to have another day. But if
that is the date, we will -- we will be available and make ourselves
available either through other lawyers or in whatever way we can.
MR. MANALICH: Madam Chairman, I've been informed by
staff that one of the considerations here is that we'll need to check
on the availability of this particular room. It's my understanding
that for an entire day, other than the usual regular scheduled CEB
meeting dates, it can be problematic, so that's something we'd want to
consider. And, again, I don't know if counsel intend to file a
motion, a formal motion for intervention, because I want to make it
perfectly clear that the county's position is in opposition to any
such intervention.
MS. BARNETT: I -- at an appropriate point, Madam Chair,
it might be important to discuss that in terms of a procedure for
having that issue resolved in advance of the hearing or whether that
issue would remain outstanding until the actual hearing before the
Code Enforcement Board.
CHAIRPERSON RAWSON: It would be my preference that if
that motion was going to be made, that it would be made very timely,
very soon, as a matter of fact --
MR. KOBZA: Immediately.
CHAIRPERSON RAWSON: -- and this board have an emergency
very short meeting in order to vote on your motion and hear arguments
on that because it seems if the meeting is on the 27th, that ideally
what we're saying is that we don't want any more than a 30-day
continuance. If this room is not available on the 27th, then it's on
the 26th or the 28th. It's not that important. We just are putting a
limit on the continuance, I think.
What I would rather see, that motion for intervention be
ruled upon by this board prior to that date because on that date we
need to be ready to go. Any attorney want to comment on at least the
chair's position?
MR. KOBZA: Sure. Miss Rawson, we're we're having
someone check on the availability of the room.
CHAIRPERSON RAWSON: Thank you.
MR. KOBZA: -- so that you have that information.
MS. BARNETT: I could not hear that response.
CHAIRPERSON RAWSON: He's having someone check on the
Page 19
May 23, 1996
availability of having this room available for us for a full day.
Basically --
MS. BARNETT: Why don't the -- if I might, and I don't
know if this is the appropriate time, but one of the questions that we
had of the Code Enforcement Board was to -- and perhaps counsel can
just later in conversations discuss with us, is the procedures that
will be followed at the hearing at whatever day that it is actually
scheduled, the time, the amount of time available and the procedures
for witnesses, for evidence or that type of information.
CHAIRPERSON RAWSON: Well, that information will
certainly be given to you, and I think perhaps the -- the county
attorney or the three attorneys that are present here today in a
conference call can certainly discuss that with you. We would
certainly want you to be advised of -- of all of the procedures that
the Code Enforcement Board follows.
MS. BARNETT: Thank you.
MR. MANALICH: Madam Chairman, while we check on the
availability of the room, I'd just like to request on the county's
behalf, if we could, before we leave here today, agree that since the
attorneys for Pacific Land Co. as well as the Holland and Knight firm
are partic -- are at least participating here today, that whatever
notices we give can be given here orally at this meeting without the
necessity of further written notices to be sent out. Is there any
objection to that?
MS. ENGLISH: Pacific Land -- excuse me, Pacific Land
Company has no objection to that on behalf of Pacific.
MR. MANALICH: Okay. Ms. Barnett, were you able to hear
those comments?
MS. BARNETT: It -- Ramiro, it had something to do with
notice, but I'm not sure of what.
MR. MANALICH: Yeah. Essentially Pacific Land Company's
attorney has indicated that they have no objection to the county
request that whatever dates are set here today, that everyone be
considered to be on notice without the necessity of further written
notices being sent out once they're announced here at the meeting
today. Is that okay with you?
MS. BARNETT: I don't -- I don't have any objection to
that. I'm not sure what other notices -- what notices are --
MR. MANALICH: Well--
MS. BARNETT: Maybe it would be better if you would tell
me what notices that would eliminate. Is there a publication
requirement, for example?
MR. MANALICH: No. It's just essentially to get you --
any party written notice of what the next scheduled hearing date is.
MS. BARNETT: Continuance notice. I do not have any
problem with that.
MR. MANALICH: Okay.
MR. LAFORET: Counsel, I have a question for you. If--
if the intervenors or respondents bring out the points of law which
are not included in the Collier County code, are you prepared to call
in people, for instance, like OSHA and the Southern Building Code who
represent national law? Are you prepared, or are you going to have to
in the event of a sudden surprise like that, are you going to have
to ask for a continuance so that you can get consultation?
Page 20
May 23, 1996
MS. McEACHERN: Good morning, Madam Chairman.
MR. LAFORET: Can't hear you.
MS. McEACHERN: I'm Shirley Jean McEachern, assistant
county attorney, here on behalf of staff. The case law says that on
ruling on a motion to intervene, it's in the board's discretion to
grant that and, furthermore, that the inter -- the intervenor takes
the case as they find it and are not to interject new issues unless
the board specifically grants them that right and, therefore,
conceivably no new issues would be presented.
MR. LAFORET: When you refer to new issues, you're
talking of issues that are not included in this document?
MS. McEACHERN: Correct.
MR. LAFORET: Thank you very much, ma'am.
MS. BARNETT: Could we request what she was just reading
from? Is this rules of the board?
CHAIRPERSON RAWSON: She wasn't reading from anything.
She was speaking right off the top of her head.
MS. BARNETT: Oh, okay.
MS. McEACHERN: I think you can find it in Westlaw.
MS. BARNETT: In response to -- just a comment on what I
think I just heard, that certainly the four corners of the document
set forth the specific code violation questions, but there are other
legal questions that may have state or federal bases that can be
raised as a result of actions taken by Collier County and the local
Code Enforcement Board.
MR. KOBZA: I think the point is this board -- if I can
interject, this is precisely the reason that I need to prepare. These
attorneys on both sides have different legal positions. I've got to
be in a position of advising the board, and that is the issue in a
nutshell. The county has a legal position. All these other various
attorneys have legal positions, but it's my responsibility to advise
you once I have their arguments, and that's -- that's basically why
I've said what I've said to this point. You can understand that they
have divergent points of view. And I may come back and tell you we
stay within the four corners of this document. I may come back and
tell you that we don't -- I can't -- today I'm not in a position to be
able to say to you, board, that I -- that I can narrowly define
exactly what the scope of the issues are. I would appreciate having
the benefit of the respective arguments. I don't think it serves the
purpose for those arguments to be made today to this board on these
other various motions which aren't even really before you. So to that
extent -- I -- I did -- I -- Ms. Sinclair from the county manager's
office or, excuse me, county commission office -- manager's office is
correct -- I'm sorry -- has brought in the calendar for this room. On
the 27th of June you have scheduled in this room the hearing -- your
hearing on the Lely matter. So to the extent that you would have any
-- anything to hear on that matter --
MR. MANALICH: Mr. Kobza, if I can interject, since the
county attorney's office is also involved in the prosecution of that
case, I think I can authoritatively tell you that the counsel, Mr.
Bryant, that is handling that case has indicated to me that is a
matter that will be coming forth to you in July, not at that June 27
date.
MR. KOBZA: Okay. So then the board meeting room would
Page 21
May 23, 1996
be available to you the full day on June the 27th.
The next available dates and the only other immediate
dates that would be available to you would be Wednesday, July the
10th, and Friday, July the 12th. Those are the next immediately
available dates in this room.
MR. MANALICH: Is there anything before the 27th?
MS. SINCLAIR: No, not really.
MR. KOBZA: June the 14th, Friday, June the 14th, which
would be the next earliest. So it's either -- for all intents and
purposes, it's either June 27th, July 10th, or July 12th, or you could
go further into July if that was your initiative.
MR. McCORMICK: Well, I would -- if the continuance is
granted, I would expect it would be on our normally scheduled day. I
don't -- I don't know any compelling reason to change it to another
day, and let me continue that the reasons that Mr. Kobza has just
given us, his personal plea, if you will, or his reasons to support
the continuance, unfortunately, I think, are the most compelling
reasons that we need to consider the continuance. I think that we
need to, in determining this case, be able to decide or come to a a
just and fair conclusion. And as it's presented to us today, we
probably could do that. We may and we may not be able to.
. But the second thing that we have to do is try to come
to a resolution that is -- is the most efficient that we can come to
and that is not going to be contested and dragged out. And while I am
really embarrassed or disgusted that this has dragged on as long as it
has -- I wish that it was settled long before it got to us -- I think
that the most prudent position now to -- to bring this to closure
would be to accept the continuance on Mr. Kobza's and the other cases
that have been made by both sides. I think that that will enable us
to -- to decide this matter to completeness in the best manner.
CHAIRPERSON RAWSON: Is that a motion?
MR. McCORMICK: I'll make a motion for the continuance.
I'd like to discuss the -- the board dates and the date that the
memorandums of law are being submitted and filing, but I think that we
should take a vote on the continuance.
CHAIRPERSON RAWSON: And is part of your motion that it
be held, if I understood you correctly, on June 27th, our regularly
scheduled board date?
MR. McCORMICK: Right.
CHAIRPERSON RAWSON: There's been a motion that the
board accept the respondent's motion for continuance for 30 days to be
held on June 27th. Is there a second?
MR. LAFORET: I will second the motion.
CHAIRPERSON RAWSON: Mr. Laforet has seconded it. Is
there any further discussion on the motion for continuance?
MR. ALLEN: I'd like to have one -- just one point. I'd
like to change the date from our regular date to the Friday, June
14th, date because it seems to linger on and on and on. This has been
going on for so long. I think three weeks is adequate time to
prepare. That's three weeks from today.
MS. ENGLISH: I -- I -- I truly apologize to you for my
late entry into this. Absolutely, beyond the shadow of a doubt I will
be prepared to be before you on the 27th with either a settlement or
an argument. I will not request a further continuance. But in all
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May 23, 1996
honesty, based on the matters that I currently am trying to handle, I
cannot be prepared for you on June the 13th.
MR. ALLEN: See, Miss English, that's part of my
problem, okay, is that the apathy that we see for Pacific Land Company
-- they let this matter lie for ten months before they employed you.
MS. ENGLISH: No -- no, sir, they really -- let me make
the case for Pacific on this issue. They are not apathetic. I
realize the board only has the information that you have in your
packet to go on, but there has been a relationship between the
Independent Traditional Seminole Nation and members who are involved
in Pacific Land Company for a number of decades.
The reason that all of this came to pass was the request
of my grandfather who was a friend of the Billies and who requested
that his sons provide land for the Billies to live on. And I know
that this is a matter that you all have not heard at this point, but
there is a long history here and a long and good relationship between
members of Pacific Land Company and the Independent Traditional
Seminole Nation, and we are concerned that that relationship not
suffer because of this, and we are concerned that we reach what is a
just, equitable, and reasonable solution for everybody involved.
We absolutely recognize the need of the county to
proceed with this in a timely fashion, and we recognize that the
county has been extremely generous in allowing us the time to try to
work this out. We also recognize that the time has come for the
rubber to hit the road, and I'm telling you it can hit the road on the
27th. I am not comfortable with the 13th, but I will be before you
with either a settlement to present with the county attorney's office
to you or arguments in this matter. Please do not think because of
the delays that you have seen that it is a matter that Pacific Land
Company has not been intimately interested in and very, very concerned
about, that there is a personal relationship here that is involved in
this matter that is very delicate, and we would like to work this out
to the extent possible.
MR. MANALICH: The county is not opposed to the June 27
date.
CHAIRPERSON RAWSON: There's been a motion and a second
that this matter be continued until June 27th. Is there any further
discussion? Then I'll call for the vote. All in favor, please
signify by saying aye. All opposed?
MR. ANDREWS: No .
MR. ALLEN: No.
CHAIRPERSON RAWSON: Three to two. The motion for
continuance will be granted.
MS. ENGLISH: Thank you.
CHAIRPERSON RAWSON: Now, did I understand from the
three attorneys, including ours, that we have an agreement about the
briefs on the June 13 or -- 13th, or is that something that this board
needs to decide on?
MR. MANALICH: The county is fine with that. My
understanding is June 13, 5 p.m. for the substance of the legal
arguments. If there's need for any supplementation, it can occur, but
Mr. Kobza's intent is to not -- to have the substance of the arguments
by June 13th.
MS. ENGLISH: Yes. On the 13th to be delivered to Mr.
Page 23
May 23, 1996
Kobza's office with copies to the county attorneys and any other
parties involved.
CHAIRPERSON RAWSON: In view of the fact that we have a
consensus among the attorneys, does the board feel a necessity of
putting that to a vote? Okay. Then I'll need one further direction
from this board. It has been, I guess, a question of one of the
members that whether or not I was going to be involved at all in any
conference calls with all of the attorneys involved, and I guess I
need some direction from the board since we are adequately represented
by Mr. Kobza. If you want me to be involved, I will. I guess I need
for you to let me know that.
MR. ALLEN: I'd like to make a motion that you should be
involved.
MR. ANDREWS: I'll second that.
MR. LAFORET: Second, third.
MR. McCORMICK: Yeah, I would -- I would suggest that
you -- Mr. Kobza communicates with you, and at your discretion you are
involved in the conference call or you receive a follow-up from Mr.
Kobza after the conference call, but in that -- I don't think that
changes the motion, that you are involved.
CHAIRPERSON RAWSON: I don't -- I really don't know that
procedurally we need to vote on that. You've given me your direction,
and I can assure you that I -- I will continue to be involved, and Mr.
Kobza and I will continue to have a very good working relationship,
and he will inform me of what's going on in this case. Anything else
on --
MR. McCORMICK: The -- can I -- can I ask for a
clarification?
CHAIRPERSON RAWSON: Yes.
MR. McCORMICK: At one point you mentioned that there
was a third-party intervention, that you suggested that it be prior
CHAIRPERSON RAWSON: That's probably one of those things
that we're going to have to do by conference call with the attorneys.
That's my personal preference. I -- I don't really want to get here
on the 27th and have a half-a-day argument on a motion to intervene.
MR. McCORMICK: That's exactly the reason I brought it
up. I don't want to see anything delay or push us away from the 27th
if
CHAIRPERSON RAWSON: I agree with you, Mr. McCormick.
MR. LAFORET: We'll vote on that today.
CHAIRPERSON RAWSON: We can't vote on a motion to
intervene because it hasn't been formally made to us.
MR. LAFORET: Can we vote on a motion that we will not
accept any intervention?
CHAIRPERSON RAWSON: No. I don't think we can vote on
anything that is not before the board procedurally.
MR. McCORMICK: Well, what I'd like to do, if it comes
about through the conference call, that we do that on that 13th date
that's open, and we're not locked out of this room where we have to do
it on the 27th. Is there any way we can structure that now so that
it's -- we can react to that?
MR. MANALICH: Well, frankly, I think that the county
would appreciate some certainty as to whether this issue is going to
be dealt with or not or what time frame is going to be allowed for it
Page 24
May 23, 1996
to be raised, if at all -- if it at all is going to come up.
MR. McCORMICK: I think it needs to be raised to us
before the 13th of June, and I don't know what date it needs to be
raised to you to prepare for that.
MR. KOBZA: Perhaps I can help provide direction.
MR. McCORMICK: Sure.
MR. KOBZA: Because this is the same concern -- I share
that concern as your counsel. The 14th is the one available date for
this room where you could conduct a hearing on a motion for
intervention or any other motion that might be filed, for that
matter. I think in terms of any procedural matters, getting those out
of the way before a full-day hearing is probably a pretty good idea.
To be prepared, from my standpoint, I would like to see
that motion as soon as possible to be able to give -- to be able to
give you direction. I don't want to see a motion on the 12th and be
asked to give you advice on the 13th. If there's going to be a motion
for intervention, I'd like to see it in the next week, and I -- you
know, I guess -- I would say this, too. You have existing standing
rules in the way that you've dealt with third parties in public. And
we're tending to apply formal rules of -- a motion for intervention is
a formal rule of civil procedure that you might find, for instance, in
a lawsuit. And there's nothing to say, for instance, that regardless
of what motions mayor may not be filed, that there may not be the
opportunity for public input, as you've always had that public input,
and that that would protect the rights of other third parties. I
can't tell you how I'm going to advise the board on that question when
it's raised, but I -- I want you to understand that we haven't -- I
don't believe this board has historically had formal rules of
procedure as you would in a civil litigation matter. And in effect,
this type of thing is a formal -- is -- is analogous to what you would
do in the context of a lawsuit. So I think the board has a lot of
latitude here in terms of what its discretion is in developing the
procedure that you -- you want to follow and that will ensure due
process.
MR. LAFORET: Also I wanted you to understand my
comments are not directed to counsel in this room.
MR. KOBZA: All right.
MR. LAFORET: My comments are directed because we've
been jerked around like puppets on a string on several cases involving
intervention, involving any excuse that you have personally heard in a
legal court, we got it.
MR. ANDREWS: That's right.
MR. LAFORET: We've been as long as three or four years
giving the complainant time, dispose of all his assets, do whatever he
wants to do. Some of them died of old age before we actually got the
case to hear, and we're just tired of it. So that's why you would
know that I'm not addressing the counsel in this room. I'm not
picking on you two counsel because you're new, and you haven't got
prepared; I understand that. The reason I -- only reason that I
seconded his motion is a courtesy to you two counsel, but -- but I'm
not enthusiastic about the thought of being jerked around again for
another four, five years before this case gets heard.
CHAIRPERSON RAWSON: I don't know that we can bring
anything formally to a vote, but I guess we can all sort of pencil in
Page 25
May 23, 1996
the June 14th date. If there's a motion to be heard, we'll let you
all know in a timely fashion.
MR. McCORMICK: Do we need to clarify that the -- an
intervention by any third party that is present today needs to happen
within the next week as was Mr. Kobza's suggestion? Should we make
that a motion and a vote?
CHAIRPERSON RAWSON: It's been moved that any
intervention that's going to be forthcoming by any third party be
filed within a week of today's date. Is there a second to that
motion?
MR. ALLEN: Second that.
MS. BARNETT: Could I comment on that, Madam Chair?
CHAIRPERSON RAWSON: Yes.
MS. BARNETT: I think that certainly our clients will
try to make a decision as to whether and in what form we are going to
participate in the proceedings, but if you adopt that motion, I think
that Ramiro's earlier agreement by counsel that you did not have to
publish notice about the changed hearing dates, you may need to
revisit that because these are public hearings, and traditionally
proceedings before code enforcement boards, members of the public can
come up to and including the day of the hearing and -- and assert
whatever interests they have, including interests as substantially
affects a party. So I think to take -- you know, by telling you we
intend to address this and understand the urgency and the timing and
will -- will -- will accommodate your concerns in that regard, I think
to -- to take a motion that shuts off intervention is at a minimum
going to require some type of notice to the public because there are
other people who might want to participate or feel that they have
standing to participate in this issue.
MR. McCORMICK: The -- the motion that I made maybe
addresses that. I -- the motion was for -- that any third party that
is involved in this proceeding today here in the room or by conference
call, that they would need to make their intervention within a week.
I understand we can't block out other third parties that we don't even
know about without giving them proper notice, and that's why the
motion was -- was made as it was.
MS. BARNETT: I certainly would hope you would not adopt
that motion. I appreciate you giving me a chance to speak even though
we're not parties and just coming from the public. I would certainly
hope you would not adopt that motion at this time. It -- as I said, I
would need time to sit down with the Seminole Indians and talk with
them about this and talk with them about some of the issues that would
be related to intervening or simply participating in these
proceedings. We will abide by whatever rules you all properly
establish and -- to the best of our ability.
MR. MANALICH: Mr. Kobza, would you be able to as
counsel for the board to generate the written notices of the dates
that have been agreed to here at the meeting today just so there's no
lack of clarity on those dates?
MR. KOBZA: Absolutely.
MR. MANALICH: Okay. And I don't think anything in the
motion that I heard presented was intended to say that there would not
be public notification, as there always are, for the code board
meetings. I think -- and Mr. McCormick can correct me if I'm wrong,
Page 26
May 23, 1996
but I think his intent was to simply state to the parties that you who
are participating here today are on notice of what the board and its
counsel expect as far as upcoming dates.
CHAIRPERSON RAWSON: We -- before we vote on Mr.
McCormick's motion, which I believe is that the -- any intervenors be
given a week to file motions to intervene; was that basically your
motion?
MR. McCORMICK: The intervenors that are here today that
are present, that they have the week -- there may be intervenors that
we don't know about, other third parties. I don't think that we can
properly close them off --
CHAIRPERSON RAWSON: Okay.
MR. McCORMICK: -- and give them a week.
CHAIRPERSON RAWSON: Before we vote on the motion, I
think we really do need some advice from our attorney whether or not
our -- anybody's due process rights might be violated.
MR. KOBZA: I don't believe that anybody's due process
rights are being violated. You're trying to accommodate a party that
has identified itself as a potential intervenor. As I understand Miss
Barnett's suggestion, it was that she -- that would not give her
adequate time to prepare, to advise the client and prepare. We have
the same type of -- of time constraints on our part. I would
emphasize that following the rules of the board in the past and the
past practice of the board, regardless of an outcome on a motion for
intervention, there's always a right of public participation in these
hearings. So you -- you're not precluding any and all parties from
potentially participating in your hearings and asserting their
interests, okay. As I --
MS. BARNETT: Would you mind re -- summarizing what he
said? I'm sorry. I couldn't hear it.
CHAIRPERSON RAWSON: I wouldn't even attempt, but I'll
ask Mr. Kobza if he would maybe come up here and let -- or speak right
into the microphone --
MR. KOBZA: Sure.
CHAIRPERSON RAWSON: so that Ms. Barnett can hear
you.
MR. KOBZA: Okay. Miss Barnett, basically what I've
said is this -- the board is trying to accommodate you as a party or
your clients as parties who have identified themselves as potential
intervenors as parties in this action. If the board would -- you
know, first -- starting point, you mayor may not file a motion for
intervention at your discretion in the future. That is to assert
standing as a party. Whatever the outcome of your decision or the
board's ruling on -- on any motion that might be filed, there's
nothing in the past history of the board, I believe, which precludes
public participation in these hearings and the assertion of rights of
what may be substantially affected parties.
I think that procedurally what we want to know is if you
intend to fully participate as a party, that we know that and we know
it soon, and that, I believe, is the intent of the motion. I don't
know that that motion, if granted, which is an issue as to whether I
would even advise the board that they could grant such a motion,
because I understand it to be the county's position that it probably
would not be an appropriate motion, and they may well be correct. I
Page 27
May 23, 1996
can't say that today, but however that would come out, that does not
necessarily mean that just using the normal rules of procedure of this
board that they could not otherwise assert their -- their interest as
substantially affected parties.
MR. MANALICH: Madam Chairman, on behalf of the county,
our stated position is we share the concern of the board's counsel to
eliminate the mystery of who may appear in this action later on. We
think it's pretty straightforward. We've got the right people here
right now with Pacific Land Company. However, we understand that
Holland and Knight and perhaps others that we're not aware of might
assert that they have an interest. We would share the board's
counsel's desire to put some parameters of that window for
participation. We've heard the June 14 date, and we support that.
And, likewise, we want to preserve our objections, even though we
understand that absent the parties participating here today in this
hearing, we cannot foreclose categorically anyone else. We want to
preserve our objections so that even though we agree with having this
window of opportunity through the 14th, as Mr. Kobza announced it, we
don't want by agreeing to that to in any way waive any objections we
may have for further on if other unknowns appear and try to join the
party. We would object to that, but we agree with the limited window
of opportunity for the parties participating today to announce their
-- and come forward with their intentions.
CHAIRPERSON RAWSON: Does everybody understand Mr.
McCormick's motion and the second?
MR. McCORMICK: Let me possibly restate it or clarify.
I'm not sure if I communicated adequately. Not only was the motion to
require this third party to submit within a week but that I would like
our chairman -- to give the chairman discretion to call that meeting
for the 14th whereby we -- we would hear that. If we felt or you felt
that that was going to take up time on the 27th to hear that case
that we want to hear the case on the 27th. So I want to give you the
discretion to call that special meeting on the 14th to hear that
motion of intervention.
CHAIRPERSON RAWSON: The motion has been slightly
amended. Does the seconder agree with the amendment?
MR. ALLEN: Yes.
MR. LAFORET: Could I ask a question?
CHAIRPERSON RAWSON: Yes.
MR. LAFORET: All right. Counselor, any counselor, I
understand there's two types of intervenors: One becomes a party in
the case, and the other is strictly advisory, that they have an
opinion. Which type of intervention would you recommend we tolerate?
And I'm not asking you "now."
MR. KOBZA: Uh-huh.
MR. LAFORET: Look it up.
MR. KOBZA: Uh-huh.
MR. LAFORET: If you ask us to tolerate if any type of
intervention, personally on -- personally at this point until I see
some evidence of the contents of the intervenor, I'm against this
intervention at this late date that I feel had plenty of -- plenty of
. opportunity. However, my opinion is over -- has been overvoted on,
and they're going to consider it. But I would like to know if we
could accept them as merely advisory and not as a party, in which
Page 28
May 23, 1996
case, yes, I would listen to advice and give it as we say in
arbitration, the weight we consider it deserves. So I would
appreciate being informed on that when you get a chance.
MR. KOBZA: Uh-huh.
CHAIRPERSON RAWSON: Is there any other discussion on
the motion that has been seconded? All in favor of that motion,
please signify by saying aye.
All opposed?
The motion carries.
Any other business related to the public hearing of the
Board of County Commissioners versus Pacific Land Company that needs
to come before this board today?
MR. MANALICH: Mr. Kobza, I understand you'll be
reducing to writing these stipulations that have been made here today
with regard to the dates upcoming; is that correct?
MR. KOBZA: That would be my intent, and I would prepare
that for the chairman's signature.
MS. BARNETT: Madam Chair?
CHAIRPERSON RAWSON: Yes.
MS. BARNETT: Can I request that either the board or
through your lawyer provide us with a copy of the procedural rules of
the Code Enforcement Board if you have such rules, and if not,
indicate to us whether you're going to use Section 120 of the Florida
Statutes on Administrative Procedures or what will be the procedural
guidelines for conducting the hearings that are now being scheduled?
CHAIRPERSON RAWSON: Ms. Barnett, I'm sure that the
staff of the county will be happy to provide you with the procedural
rules of the Code Enforcement Board -- that's public record -- and,
you know, a copy of the section of the statute, if -- if it applies.
MS. BARNETT: Now, we actually -- we have the statute,
but I would simply -- what we would like to have is a confirmation of
what -- what rules, procedural rules, are going to apply to these
hearings. These are -- as you know better than I, far better than I,
that these are generally public hearings.
CHAIRPERSON RAWSON: They are public, yes.
MS. BARNETT: And they may not comport in all instances
with formal administrative proceedings, but some of the procedures
that are being established today seem to deal with that, and it would
be very helpful for us in determining our posture and -- and how we
are going to participate in the time frame you set up, if we could
have a clear understanding of how this hearing will be conducted and
what rules will be applied to it.
CHAIRPERSON RAWSON: I think that's a fair request and,
Ms. Cruz, or, Mr. Manalich, do you have any objection to sending that
to Miss Barnett?
MR. MANALICH: No.
CHAIRPERSON RAWSON: You'll have that, Miss Barnett.
MR. MANALICH: Just as a clarification, Madam Chairman,
though, it's my understanding Mr. Kobza can instruct you on this, but
there's no requirement in Chapter 162, the Code Enforcement Board
statute, or Ordinance 92-80 that this be a full-blown Chapter 120
proceeding and, I mean, that would be our position. Basic fundamental
due process will apply as that has been examined by the case law, and
I believe there are some written guidelines that have been reduced to
Page 29
May 23, 1996
writing in the past regarding this board's procedures, and we'll
certainly provide those.
MS. BARNETT: Thank you, Ramiro. That's the kind of
information and specificity that we would like to have so we can plan
in the next week as to what and how we will participate.
CHAIRPERSON RAWSON: Anything else in regard to the
public hearing that needs to come before this board? If not, I guess
we'll close the public hearing.
MS. BARNETT: Madam Chair, I want to thank you for --
and members of the board for allowing us to sit in on this conference
call this morning.
CHAIRPERSON RAWSON: You're very welcome. We'll close
the public hearings at this point in time.
Do you want to have a break before we get to the old
business?
MR. McCORMICK: I think so.
CHAIRPERSON RAWSON: We'll take a ten-minute break.
(A short break was held.)
CHAIRPERSON RAWSON: Okay. The board will come back to
order. We are now to item 7 on our agenda which is -- sorry, item 6,
which is new business, and I presume there is none.
MS. CRUZ: That's correct.
CHAIRPERSON RAWSON: Then we move to item 7, old
business. And the first two, A and B, involve Mr. Martel, who I see
is present here this morning. Yes, Ms. Cruz.
MS. CRUZ: That's correct. For the record my name is
Maria Cruz, code enforcement specialist. Case No. 96-005, BCC versus
Jean Claude Martel, appeared before this board on February 22nd,
1996. After hearing -- this board heard arguments respective to all
the -- to this matter. An order was issued asking Mr. Martel to
comply with the violation. On March 28th this case came back before
this board. Mr. Martel asked -- asked for a contin -- for more time
to be granted in order for him to comply. A i5-day -- a compliance
was granted to Mr. Martel to provide for a variance regarding the
two-story sheds that appeared on his property without permits.
Mr. Martel did obtain those permits. Staff is asking
that even though there was a 15-day period, that Mr. Martel failed to
comply with his order and that there would be a -- an $850 fine
accumulated for those 15 days. Due to that Mr. Martel went through a
lot of effort to comply with the county's order with this board's
order, staff is requesting that no fine be imposed at this time with
the stipulation that Mr. Martel follows the permit guidelines. And if
this permit expires before completing -- before obtaining a
certificate of occupancy, that the fines be retroactive.
CHAIRPERSON RAWSON: Is this on CEB No. 96-005 --
MS. CRUZ: That's correct.
CHAIRPERSON RAWSON: -- only? Anybody have any
questions for Miss Cruz?
MR. ANDREWS: No, sounds pretty good.
CHAIRPERSON RAWSON: Is that in the form of a motion?
MR. ANDREWS: Oh. Yeah, I'll make a motion that we
accept.
CHAIRPERSON RAWSON: It -- it's been moved that we
accept the staff recommendation. Is there a second?
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May 23, 1996
MR. ALLEN: I'll second.
MR. McCORMICK: I'll--
CHAIRPERSON RAWSON: Any discussion?
No. 96-005 we have a motion and a second
recommendation as stated on the record.
by saying aye.
All opposed?
The motion carries.
Moving on to CEB 96-008.
MS. CRUZ: This case, again, appeared on February 22nd,
1996. The -- this board issued a -- an order requesting respondent in
this case, being Jean Claude Martel, to comply to take certain
corrective actions by April 23rd, 1996. Staff conducted inspections
and revealed these inspections revealed that the corrective actions
were taken. At this time I'd like to file an affidavit of
compliance.
CHAIRPERSON RAWSON: I don't believe that requires a
vote. She's filing an affidavit of compliance. Do you need a motion
from us that this case be dismissed?
MS. CRUZ: Please.
MR. LAFORET: So moved.
MR. ALLEN: Second.
CHAIRPERSON RAWSON:
this case be dismissed.
All opposed?
The motion carries. Thank you, Mr. Martel. Thank you
for your cooperation.
MR. MARTEL: Thank you very much.
CHAIRPERSON RAWSON: The next item before this board is
Board of County Commissioners versus Joseph Hovland, CEB No. 96-009.
MS. CRUZ: Madam Chairman, this case, 96-009, involves
Joseph M. Hovland as trustee and the Joseph M. Hovland land trust
number No.1. This case appeared on March 28th '96. This board
issued an order requesting that the respondent take corrective actions
by or before April 27th. Again, reinspections by the code enforcement
staff revealed that these corrective actions were taken. I'd like to
request that an affidavit -- I'd like to file an affidavit of
compliance at this time.
MR. McCORMICK: What were the actions that had to be
taken? Refresh my memory.
MS. CRUZ: He was supposed to complete an installation
of a county-approved landscaping plan within 30 days, which would be
by March 28th, and if he didn't comply by then, he was asked to pay a
hundred dollars per day for each and every day.
MR. McCORMICK: Okay.
CHAIRPERSON RAWSON: And at this time you're filing an
affidavit of compliance, so we probably need a motion to dismiss that
case as well.
MR. McCORMICK: I'll make a motion to dismiss.
CHAIRPERSON RAWSON: Is there a second?
MR. ANDREWS: Second.
CHAIRPERSON RAWSON: All in favor please signify by
saying aye.
All opposed?
In terms of CEB
that we accept the staff
All in favor please signify
It's been moved and seconded that
All in favor signify by saying aye.
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May 23, 1996
Motion carries.
Is there any other old business? Are there any
reports?
MS. CRUZ: No, ma'am.
CHAIRPERSON RAWSON: As you are all very much aware, the
next regular meeting of this board will be on June 27th, although you
should pencil in your calendar the date of June 14th in the event that
this board needs to have a special meeting on a motion to intervene.
We should look forward to having briefs from the various attorneys.
If they have to turn them in by Friday -- Thursday the 13th at five
o'clock, I would assume you'd probably get them the next day. And our
attorney has promised to brief all of us shortly thereafter. So stay
healthy. When you see our other two board members, please insist that
they clear their schedules as well. Is there any other business to
come before this board?
In that case I would entertain.a motion to adjourn.
MR. ANDREWS: They like it so well they don't want to
vote.
CHAIRPERSON RAWSON: Mr. Andrews wants to stay. I'll
make a motion that we adjourn.
MR. ALLEN: Second.
CHAIRPERSON RAWSON: All right. All in favor say aye.
This meeting is adjourned.
*****
There being no further business for the Good of the County, the
meeting was adjourned by Order of the Chair at 10:12 a.m.
CODE ENFORCEMENT BOARD
J
CHAIRPERSON
TRANSCRIPT PREPARED ON BEHALF OF DONOVAN COURT REPORTING
BY: Barbara A. Donovan
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