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AgdaPkt 2010-11-22 clsd and regular
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AgdaPkt 2010-11-22 clsd and regular
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Last modified
7/9/2012 11:22:57 AM
Creation date
11/18/2010 5:05:06 PM
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Template:
CC Index
CC Index - Document Type
Agenda Packet
Meeting Type
Regular
Agency Type
City Council and Redevelopment Agency
Date
11/22/2010
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i <br /> 8.A <br /> Page 54 <br /> . Third, I was just inforxned this morning by attorneys representing me as Plaintiff in a seemingly large <br /> and complex lawsuit being conducted in the Federal District Court in Connecticut that depositions have <br /> been scheduled in Connecticut for the end of November. Since very substantial sums are involved, I <br /> must direct all my attention to reviewing over 12,000 pages of documents submitted in the earlier phase <br /> of discovery, and I must make myself available in Connecticut as of November 22nd or 23rd to review � <br /> and prepare for as many as six depositions, including my own. I believe if this were a matter before a <br /> court, a continuance would be granted due to such a conflict. In any event, it's clear that without a I <br /> continuance being granted, I will not be able to adequately prepare for this Hearing, and, indeed, may <br /> not even be able to attend! <br /> • Finally, I have referred to this Appeal procedure as a"Hearing" to underscore the fact that your decision <br /> will impact the value of our property and the property of our neighbors, and that an adverse decision will <br /> almost certainly cause the value of our property to decline. I base this conclusion on statements of <br /> neighbors living adjacent to or across from the "Pink Palace" on Ruby, the "Barn Bunker" at 260 Myrtle, <br /> and the "Flying Dutchman" at the crest of the hill on Quartz -- and these are examples only from our <br /> direct neighborhood of decreased property values resulting from similarly flawed Planning Department <br /> decisions! I consider this Appeal to be analogous to our court case in Connecticut; and, therefore, we <br /> need sufficient time to be able to fully prepare a case in support of modifying those three items -- tree, <br /> curved metal roof, invasive deck -- that constitute the entirety of our Appeal. It would be very <br /> unfortunate for all concerned if we were to be denied our "day in court" because of a rigid stance on <br /> scheduling this matter, which, as I believe I have demonstrated above, has no reasonable basis in fact, <br /> law, or equity. <br /> Therefore, I respectfully request that a continuance be granted in the Hearing of our Appeal until February 21, <br /> 2011, or as soon thereafter as possible. <br /> Respectfully Submitted, <br /> Marc Warsowe and Renate W. Albrecht, <br /> Appellants <br /> 3 <br />
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