LEGAL APPROVAL
MEMORANDUM
January 12, 1989
TO: FILE
FROM: JAMES J. GOLDEN, SENIOR CITY PLANNER
RE: ALHAMBRA SQUARE ACLF
CONDITIONAL USE APPLICATION
On January 4, 1989, the City Commission denied a land use element
amendment/rezoning request for this project. Denial of the
zoning change precluded the further processing of the Conditional
Use application as this application was withdrawn by the agent.
On January 10, 1989, the Planning and Zoning Board deleted this
item from the agenda, which had been continued from the December
19, 1988 special meeting.
~f.~
~ES J(! GOLDEN
JJG:ro
cc Central File
MEMORANDUM
6 January 1989
TO:
File
FROM:
CsA
RE:
Alhambra Square ACLF - Conditional Use and
Land Use Element Amendment and Rezoning
Pursuant to the City Commission meeting of Tuesday, January 3rd
wherein rezoning requests for Alhambra South and Alhambra North
were denied, the referenced conditional use became a moot issue.
"I ra .
Li~w d, k.U/)VtJ~
Carmen s. AHhunziato
/bks
,
MEMORADUM
1
( June 23, 1989
TO: Honorable Mayor and City Commission
FROM: Raymond Rea, City Attorney
SUBJECT: Attached Summons - Milnor Corporation
Attached for your ,information please find a copy of the
summons concerning Milnor corporation (Alhambra Square),
which was received by City Hall today.
~\M+;;1~--
RaymOI\d Rea
City Attorney
RR: lat
attachment
cc: Peter L. Cheney, City Manager
Carmen Annunziato, Planning Director
-RECEIVED.
JU~ " -
rv..l:{l:{\\~G DE.Pl~" ';\
....
4
~
.",-
IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO: f/- ~r 6/7/ A ~
MILNOR CORPORATION, a Florida
corporation; NORMAN J. MICHAEL
and ELISHKA E. MICHAEL, his wife,
Plaintiffs,
vs.
SUMMONS
THE CITY OF BOYNTON BEACH, a
Florida Municipal corporation,
Defendant.
/
THE STATE OF FLORIDA
To Each Sheriff of the state:
(!
"? <) .'
t /..-.J
/ (' ()c:'i!'--
c4J'V
YOU ARE COMMANDED to serve this summons and a copy of the
complaint or petition in this action on defendant:
THE CITY OF BOYNTON BEACH
By Serving: MAYOR GENE MOORE
ci ty Hall
IOO East Boynton Beach Boulevard
Boynton Beach, Florida 33435
or
639 East Ocean Avenue
Boynton Beach, Florida 33435
Each defendant is required to serve written defenses to the
complaint or petition on Robert A, Eisen, Esquire
plaintiff's attorney, whose address is The Law Offices of Robert
A. Eisen, P,A" 4700 Northwest Second Avenue, Corporate Plaza,
suite I03, Boca Raton, Florida 33431
within 20 days after service of this summons on that date,
exclusive of the day of service, and to file the original of the
defenses with the clerk of this court either before service on
plaintiff's attorney or immediately thereafter. If a defendant
fails to do so, a default will be entered against that defendant
for the relief demanded in the complaint or petitioner
Dated on
JUN 2 01989'
19
JOHN B. DUNKLE
As Clerk of the Court
; ,'"){;H:' ;,'~Y'i-.?t"'.,\JVS
' . ., , I j i t ._~ V . ....
By
As Deputy Clerk
IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO: ("L',,' x/'.
0L-(-VI76' /l/tl
MILNOR CORPORATION, a Florida
corporation; NORMAN J. MICHAEL
and ELISHKA E. MICHAEL, his wife,
.r~ .
Plaintiffs,
,', 'I'" J
.J ,,,,,;):
vs.
THE CITY OF BOYNTON BEACH, a
Florida Municipal corporation,
Defendant.
/
NOTICE OF COMPANION CASE
The Clerk of the Circuit Court in and for the Fifteenth
Judicial Circuit is hereby notified that the above-styled case
involves the same parties and the same subject matter as a prior
proceeding styled "Norman J. Michael and Elishka E. Michael, his
wife vs. City of Boynton Beach, Case No, 77-33l6 (CA) L (Ol-A)",
heard by the Honorable Timothy P. Poulton.
It is respectfully
suggested to the Clerk of the Circuit Court that the interests'of
judicial economy would be served by assignment of the
above-styled case to the Honorable Timothy P. Poulton.
DATED this ~() day of June, 1989.
LAW OFFICES OF ROBERT A. EISEN, PA
Attorneys for Plaintiffs
4700 Northwest Boca Raton Blvd.
suite 103
Boca Raton, FL 33431
(407) 994-2090
Florida Bar No. l80l36
~jC\~'
ROBERT A, EISEN
By:
(notice/plead/jat)
IN THE CIRCUIT COURT OF THE
l5TH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
CASE NO: r!), ge! - t:j?t A~)
MILNOR CORPORATION, a Florida
corporation; NORMAN J. MICHAEL
and ELISHKA E, MICHAEL, his wife,
Plaintiff,
. ~,:',\)
,\';-'
.,
vs.
,.,,'
, ' '..:' ~
THE CITY OF BOYNTON BEACH, a
Florida Municipal corporation,
Defendant.
/
COMPLAINT
The Plaintiffs, MILNOR CORPORATION, a Florida corporation,
NORMAN J. MICHAEL and ELISHKA MICHAEL, his wife, by and through
their undersigned attorneys, sue the Defendant, THE CITY OF
,
BOYNTON BEACH, a Florida Municipal corporation and allege as
follows:
ALLEGATIONS COMMON TO ALL COUNTS
1. The Plaintiff, MILNOR CORPORATION ("MILNOR") is a
Florida corporation which owns land in and transacts business in
Palm Beach County, Florida,
2. The Plaintiffs, NORMAN J, MICHAEL and ELISHKA E.
MICHAEL, his wife, ("MICHAEL") are residents of Palm Beach
County, Florida and own land in and transact business in Palm
Beach County, Florida, MICHAEL is the principle shareholder of
MILNOR.
3. THE CITY OF BOYNTON BEACH ("BOYNTON BEACH") is a duly
constituted Florida municipal corporation having governmental
powers pursuant to the Municipal Home Rule Powers Act and a
Charter.
4. MILNOR owns certain real property located within the
municipal
limits of BOYNTON BEACH and being a site of
approximately 4.0l acres situated at the northeast corner of the
intersection of Congress Avenue and Golf Road (S.W. 23rd Avenue),
which real property is more particularly described in Exhibit "A"
attached hereto and made part hereof, and which real property
shall hereinafter be referred to as "Alhambra Square North".
MILNOR has owned the Alhambra Square North property since 1988.
5. MICHAEL presently owns and has owned for the past
nineteen years a 9,45-acre parcel of real property located within
the municipal
limits of BOYNTON BEACH at the southeast
intersection of Congress Avenue and Golf Road (S.W. 23rd Avenue).
This real property shall be referred to as two parcels, the first
parcel being a 4,45-acre parcel situated closest to the
intersection of Congress Avenue and Golf Road (S.W. 23rd Avenue)
and more particularly described in Exhibit "B" attached hereto
and made a part hereof and which real property shall hereinafter
be referred to as "Alhambra Square South"; and the second parcel
being immediately adjacent 'to and east of Alhambra Square South
and consisting of 5.0 acres, more particularly described in
Exhibit "C" attached hereto and made a part hereof, and which
real property shall hereinafter be r::.ferred to as "Alhambra
Square ACLF".
6. The Alhambra Square North I Alhambra Square South and
Alhambra Square ACLF parcels of real property shall hereinafter
collectively be referred to as the "Alhambra Parcels".
7. The use and development of the Alhambra Parcels are
regulated by BOYNTON BEACH through the exercise of its
comprehensive planning and zoning powers.
The Alhambra Parcels
are
more
particularly
designated
by
the
BOYNTON
BEACH
Comprehensive Plan and zoning Regulations as follows:
Parcels
Future Land
Use Element
Zoninq
Alhambra Square North
Moderate density
residential
R-lAA(PUD)
Alhambra Square South
Low density
residential
R-lAA (single
family residential)
Alhambra Square ACLF
Low density
residential
R-1AA (single
family residential)
8. A map showing the Alhambra Parcels and the surrounding
land uses is attached hereto as Exhibit "0" and made a part
hereof. As indicated on the map the Alhambra Square North parcel
is adjacent to Congress Avenue on its west boundary, Golf Road
(S.W. 23rd Avenue) on its south boundary, a BOYNTON BEACH Fire
station on the west half of its north boundary and ten single
family residential lots on the remainder of its north boundary
and east boundary, The A~~ra Square South parcel is adjacent
to Congress Avenue on its &boundary, Golf Road (S.W. 23rd
Avenue) on its north boundary, Alhambra Square ACLF on its east
boundary and a 100 foot canal known as LWDD-C-27, on its south
boundary.
The Alhambra Square ACLF is adjacent to Alhambra
Square South on its east boundary, Golf Road (S,W. 23rd Avenue)
on its north boundary, the fifty foot right of way of Southwest
13th Street on its east boundary along with one single family
residence, and the LWDD-C-27 on its south boundary.
9. On or about September 30, 1988, MILNOR for the Alhambra
North parcel and MICHAEL for the Alhambra South and Alhambra
ACLF parcels submitted applications to BOYNTON BEACH for
amendments to the future land use element of the Comprehensive
Plan, and for rezoning of the Alhambra Parcels, as follows:
Parcels
Future Land
Element Request
Rezoninq Request
Intended
Use
Alhambra Square
North
Office Commercial
C-l(Office
Professional)
Office/
Medical
Alhambra Square Office Commercial C-l(Office Office/
South Professional) Medical/
Banking
Alhambra Square Mul tifamily R-3(Multi- Congruent
ACLF residential family) living
facil i ty,
The applications for amendment to the future land use element and
for rezoning shall collectively be referred to as the
"Applications".
10. The Applications complied with all the procedural
requirements of BOYNTON BEACH and contained among other things
the following submittals:
A. A conceptual master site plan for the Parcels
prepare by Charles Putman & Associates.
B, A traffic analysis prepared by K. S. Rogers, P. E.,
of K. S. Rogers Consulting Engineering, Inc.
C. Planning report prepared by Leigh Robinson Kerr
and Associates.
II. In connection with the Applications on, or about
December 9, 1988, the Planning Department of BOYNTON BEACH issued
its memoranda summarizing the Applications and recommending
denial of the Applications.
l2. On December 15, 1988, at a duly constituted and duly
noticed public hearing, the Planning and Zoning Board of BOYNTON
BEACH heard and considered the applications and recommended
denial of the Applications to the City commission.
13. On January 4, 1989, at a duly noticed and constituted
special meeting of its City Commission, the BOYNTON BEACH City
commission heard and considered the Applications and by motion
declined to submit the Applications for review by the state of
Florida Department of Community Affairs and the Treasure Coast
Regional Planning Agency, Pursuant to the Local Government
Comprehensive Planning Act and Land Development Regulation, the
Applications must be reviewed and commented upon by the state of
Florida Department of Community Affairs and the Treasure Coast
Regional Planning Agency before final action can be taken by
BOYNTON BEACH.
14. Review by BOYNTON BEACH of the Applications is subject
to the provision of its charter, Code of Ordinances and the
provisions of the Local Government Comprehensive Planning Act and
Land Development Regulation.
15. At the time BOYNTON BEACH considered and acted on the
Applications
it
had
a
duly
adopted
comprehensive
plan,
hereinafter referred to as "Comprehensive Plan," to guide the
future development of BOYNTON BEACH.
l6, The Comprehensive Plan provides in pertinent part the
following:
3.3,l.l-"Provide a range of land use types
to accommodate full range of services and
activities. II
3.3.l.2.3-IIEncourage development of commercial
land uses where accessibility is greatest and where
impacts to residential uses are minimized, II
3.3.2.7.2.2-"Conversely, the area to the west of I-95
lacks adequate commercially zoned land to serve future
neighborhood markets."
3.3.3.3-IIIf proposed land use policies are enforced,
future commercial development would be located
as cluster development at major intersections,
3.3.4.2,2-IIEncourage the development of clustered
neighborhood and community commercial centers at
arterial and collector intersections."
3.3.2.7.2.3-"AII proposals for additional commercial
zoning should be accompanied by a traffic impact
analysis which evaluates the effect that such projects
will have on road capacities. These traffic statements
should include all existing and planned projects, and
potential land uses under the future land use as a
basis for estimating future traffic levels. Further
rezoning to commercial land uses should not be
permitted, if such development would create
unacceptable levels of traffic congestion."
17. Congress Avenue is presently a fully developed six lane
arterial north-south roadway within BOYNTON BEACH.
Golf Road
(Southwest 23rd Avenue) is a fully developed two lane east-west
collector in BOYNTON BEACH. Both roads are so indicated in the
Comprehensive Plan.
The traffic study submitted with the
Applications demonstrates that the existing average daily trips
passing the intersection on congress Avenue is 23,896 and on Golf
Road (S.W. 23rd Avenue) 9,165.
The traffic study further
demonstrates that by 1991 the projected traffic on Congress
Avenue passing by the intersection will be 42,64l and on Golf
Road (S.W. 23rd Avenue) l2,066.
Such traffic congestion and in
particular the stop and go traffic associated with a signalized
intersection, render the Parcels unsafe and unfit for low density
residential development.
18. wi th reference to the development proposed for the
Alhambra Parcels the traffic study submitted in connection with
the application concludes:
Although this project is classified as being
a "significant project", it is concluded that
the traffic on any link upon which this
project creates a significant impact does not
exceed capacity during the project's
build-out period. This project, therefore,
can be approved in accordance with the Palm
Beach County Traffic Performance Standards
Ordinance No. 87-18. This proj ect was also
found to be generally in conformance with the
intent of the city's Comprehensive Plan and
this proj ect also can be approved as
submitted.
19. The Comprehensive Plan in Section 3.3.3.5 projected
ultimate land use distributions necessary to provide acceptable
levels of services in BOYNTON BEACH,
within the quadrant of
BOYNTON BEACH wherein the Alhambra Parcels are located the
existing and proposed commercial properties are inadequate to
serve the needs of the community according to the proj ected
ultimate land distributions stated in the Comprehensive Plan. In
the quadrant wherein the Alhambra Parcels are located significant
residential development has occurred which require new commercial
development to serve its needs.
The Alhambra North and the
Alhambra South Parcels were designed to provide community
commercial services such as banking, medical, legal, accounting
and other office related professional services.
20. Development of the Alhambra North and South Parcels as
residential developments pursuant to the future land use element
designation in the Comprehensive Plan and as presently zoned with
single family residences, is not economically feasible and would
result in residential development subjecting the future residents
therein to imminent danger from traffic noise, automobile exhaust
pollution and other dangers and harms not compatible with the
health, safety and welfare of the residents of BOYNTON BEACH,
21. The staff report which accompanied the applications
states that residential development of the Alhambra North and
Alhambra South Parcels would require substantial berming and
reversed frontage layouts in order to buffer any potential single
family development from Congress Avenue and Golf Road (S.W. 23rd
Avenue). This finding by the BOYNTON BEACH Professional Land Use
staff illustrates not only that the Alhambra North and the
Alhambra South Parcels are unsuitable for residential development
but that they are presently spot zoned and incompatible with the
policies of the Comprehensive Plan.
22. The Comprehensive Plan provides that adult congregate
living facility projects should be allowed in all residential
zoning districts and that a full range of housing choices should
be provided within BOYNTON BEACH.
The traffic study submitted
with the applications indicates that the Alhambra ACLF will not
have either a significant nor adverse impact upon roadways within
BOYNTON BEACH,
23. In connection with the instant lawsuit MICHAEL and
MILNOR have retained the undersigned attorneys to represent them
and have agreed to compensate the undersigned attorneys for their
services.
COUNT I
DECLARATORY JUDGMENT
PRESENT ZONING
24. This is an action for declaratory relief pursuant to
Chapter 86 of the Florida Statutes,
25, The common allegations set forth in paragraphs 1
through and including 23 are realleged herein.
26. Pursuant to the implementation of its comprehensive
Plan, BOYNTON BEACH has amended its future land use element and
rezoned similarly situated parcels on the congress Avenue
corridor
from
single
family
residential
designations
to
commercial designations.
27. The current future land use designation of the Alhambra
Parcels in the Comprehensive Plan and the current zoning
classification of the AlhanLbra Parcels deny MILNOR and MICHAEL,
respectively, rtll reasonable uo::e of the Alhambra Parcels.
28, The cur Lent future land use designation of the Alhambra
Parcels in the Comprehensive Plan and the current zoning
classifications of the Alhambra Parcels is internally
inconsistent with other provisions of the Comprehensive Plan and
therefore such present designation and zoning of the Alhambra
Parcels are confiscatory, vague, arbitrary, discriminatory,
illegal, unreasonable, unlawful, unconstitutional, and bear no
rational or debatable relation to the public health, safety,
morals or general welfare of BOYNTON BEACH.
29. Pursuant to the present future land use designations in
the comprehensive Plan and zoning classifications of the Alhambra
Parcels and the internal inconsistency of the designations and
classifications, MILNOR and MICHAEL are in doubt as to their
rights under the BOYNTON BEACH Comprehensive Plan and zoning
regulations and their respective legal and equitable rights and
privileges are affected, impaired and endangered by the
comprehensive Plan and zoning regulations of BOYNTON BEACH.
MILNOR and MICHAEL challenge the constitutionality, both facially
and as applied, and the validity of the present designations and
classifications and are entitled to have this court, by a
declaratory decree, construe and determine the invalidity,
illegality and unconstitutionality of the designations and
classifications, by a Declaratory Decree, and to adjudicate and
determine the future land use designation and zoning of the
Alhambra Parcels.
WHEREFORE, MILNOR and MICHAEL request a Declaratory Judgment
designating the Alhambra Parcels on the future land use element
of the Comprehensive Plan as requested in the Applications, and
zoning the Alhambra Parcels as requested in Applications; and
award of court costs and attorney's fees and such other relief as
the Court may deem just and proper.
COUNT II
FAILURE TO AMEND DES:!:(;olA'J'I.QtLAND TO REZONE
30, This is an action for declaratory relief pursuant to
Chapter 86 of the Florida statutes.
3l. The common allegations set forth in paragraph 1 through
and including 29 are realleged herein.
32. The development of the Alhambra Parcels proposed in the
Applications is economically feasible, would serve the commercial
and congregate living needs of BOYNTON BEACH and would promote
the general health, safety and welfare of BOYNTON BEACH.
33, The sole rationale of the Planning Department, the
Planning and zoning Board and the city council for refusing to
grant the Applications is to maintain Golf Road (S.W. 23rd
Avenue) as a residential corridor. This rationale is
inconsistent with the articulated policies and goals set forth in
the Comprehensive Plan.
34, The present future land use designation of the Alhambra
Parcels in the Comprehensive Plan and the present zoning
classification of the Alhambra Parcels deny MILNOR and MICHAEL,
respectively, all reasonable use of the Alhambra Parcels. The
refusal and denial of BOYNTON BEACH to amend the future land use
element and to rezone the Alhambra Parcels as requested by MILNOR
and MICHAEL respectively in the Applications was arbitrary,
capricious, unreasonable, unconstitutional, unlawful and a
confiscatory legislative act having no debatable relation
whatsoever to the public health, safety, morals or general
welfare.
35, The present future land use designation of the Alhambra
Parcels in the Comprehensive Plan and the present zoning
classifications of the Alhambra Parcels is internally
inconsistent with other provisions of the Comprehensive Plan and
therefore the present designation and classification of the
Alhambra Parcels are confiscatory, vague, arbitrary, discri-
minatory, illegal, unreasonable, unlawful, unconstitutional, and
bear no rational or debatable relation to the public health,
safety, morals or general welfare of BOYNTON BEACH,
36, The future land use ~esignation and zoning requested by
MILNOR and MICHAEL respectively in the Applications and the
development proposed thereunder is consistent with the
Comprehensive Plan. The present future land use designation and
zoning classification of the Alhambra Parcels by BOYNTON BEACH is
not consistent with the Comprehensive Plan; and development of
the Alhambra Parcels pursuant to such present land use
designation and zoning classification is, in fact, inconsistent
with the comprehensive Plan.
37. Pursuant to both the present future land use
designation and zoning classification of the Alhambra Parcels and
the internal inconsistency of the designation and classification,
MILNOR and MICHAEL are in doubt as to their rights under the
BOYNTON BEACH Comprehensive Plan and zoning regulations, and
their respective legal and equitable rights and privileges are
affected, impaired and endangered by the Comprehensive Plan and
zoning regulations of BOYNTON BEACH. The failure of BOYNTON
BEACH to take legislative action to correct the internal
inconsistencies of the present future land use designation and
zoning classification further places MILNOR and MICHAEL in doubt
as to their rights under the BOYNTON BEACH Comprehensive Plan and
zoning regulations and their respective legal and equitable
rights and privileges. MILNOR and MICHAEL challenge the
constitutionality, both facially and as applied, and the validity
of the present existing designations and classifications and are
entitled to have this Court, by a declaratory decree, construe
and determine the invalidity, illegality and unconstitutionality
of such designations and classifications, by a Declaratory
Decree, and to adjudicate and determine the future land use
designation and zoning of the Alhambra Parcels. Further, MILNOR
and MICHAEL challenge the constitutionality, validity and
legality of the refusal of BOYNTON BEACH to amend the designation
and rezone the Alhambra Parcels as set forth in the Application.
MILNOR and MICHAEL are entitled to have this Court, by a
declaratory decree, construe and determine whether the
Applications should have and ought to be granted by BOYNTON BEACH
and to adjudicate and determine the future land use designation
and zoning of the Alhambra Parcels as set forth in the
Application.
WHEREFORE, MILNOR and MICHAEL request a Declaratory Judgment
designating the Alhambra Parcels on the future land use element
of the Comprehensive Plan as requested in the Applications, and
zoning the Alhambra Parcels as requested in Applications; and
award of court costs and attorney's fees and such other relief as
this Court may deem just and proper.
COUNT III
INJUNCTION
38, This is an action for permanent injunctive relief.
39. MILNOR and MICHAEL reallege each and every allegation
set forth in paragraphs 1 through and including 37, above.
40. The present designation of the Alhambra Parcels on the
future land use element of the Comprehensive Plan and the present
zoning of the Alhambra Parcels, and the refusal of BOYNTON BEACH
to redesignate and rezone are arbitrary, capricious, illegal,
unconstitutional, confiscatory and discriminatory,
41. MILNOR and MICHAEL have no adequate remedy at law and
invoke the aid of equity to preserve and protect their property
rights and to protect their rights and privileges under the
BOYNTON BEACH Comprehensive Plan and zoning regulations from the
unlawful and unconstitutional acts of BOYNTON BEACH.
WHEREFORE, MILNOR and MICHAEL request a permanent injunction
ordering and directing BOYNTON BEACH to amend the designation of
the Alhambra Parcels on the future land use element of the
Comprehensive Plan as requested in the Applications, and to
rezone the Alhambra Parcels as requested in the Application, and
such other and further relief as the Court may deem just and
proper, including an award of court costs and attorney's fees.
COUNT IV
DAMAGES
42. This is an action for damages.
43. The allegations set forth in paragraphs I through 41
are realleged herein.
44. The present future land use designation of the Alhambra
Parcels on the BOYNTON BEACH Comprehensive Plan and the present
zoning classification of the Alhambra Parcels deprive MILNOR and
MICHAEL of any and all reasonable use of the Alhambra Parcels.
45, The refusal of BOYNTON BEACH to redesignate and rezone
the Alhambra Parcels is an arbitrary, capricious, illegal,
unconstitutional, confiscatory and discriminatory act of BOYNTON
BEACH.
46, BOYNTON BEACH has redesignated and rezoned parcels
along the Congress Avenue corridor similar to the Alhambra
Parcels and is, therefore, treating similar properties with
similar
characteristics
in
dissimilar
fashions.
Such
discrimination in the use of BOYNTON BEACH's comprehensive
planning and zoning powers is arbitrary, capricious, illegal,
unconstitutional, confiscatory and discriminatory.
WHEREFORE,
MILNOR and
MICHAEL request
an
award
of
compensatory damages each in excess of $5,000,000.00, their
respective court costs and attorneys fees, and such other relief
as the Court may deem just and proper.
LAW OFFICES OF ROBERT A, EISEN, PA
Attorneys for Plaintiff
4700 Northwest Boca Raton Blvd,
suite l03
Boca Raton, Florida 33431
(407) 994-2090
Florida Bar No. 180136
~vlL-
BY:
ESQUIRE
plead/pldmcfj t
EXHIBIT "A"
ALHAMBRA SOUARE NORTH
A parcel of land in section 32, Township 45
City of Boynton Beach, Florida, Palm
particularly described as follows:
South, Range 43 East,
Beach County, more
The East 460 feet of the West 510 feet of the North 380 feet of
the South 420 feet of the Northwest 1/4 of Section 32, Township
45 South, Range 43 East, City of Boynton Beach, County of Palm
Beach, Florida, less and except lands described in Official
Records Book 5402, Page 670,
r
-,
-
EXHIBIT "B"
ALHAMBRA SQUARE SOUTH'
The west 500 feet of the following described property:
Lot 16, Block 16, GOLF VIEW HARBOUR 2ND SECTION, according to the
Plat thereof, as recorded in Plat Book 27, Pages 46 and 47, and
Tracts 2, 3, and 4 GOLF VIEW HARBOUR 3RD SECTION, according to
the Plat thereof, as recorded in Plat Book 30, Page 119 and l20,
Public Records of Palm Beach county, Florida.
, '
I
-
EXHIBlT "c"
AI,HANBRA SQUARE ACI,P
The East 590 feet of the following described property:
Lot l6, Block l6, GOLF VIEW HARBOUR 2ND SECTION, according to the
Plat thereof, as recorded in Plat Book 27, Pages 46 and 47, and
Tracts 2, 3, and 4 GOLF VIEW HARBOUR 3RD SECTION, according to
the Plat thereof, as recorded in Plat Book 30, Page 119 and 120,
Public Records of Palm Beach County, Florida.
, .
EXHIBIT "D"
I
i
I
i
I
I
I ~
I ;
j I
i a
~
(
I
I: !
" I ,
~' s,,~lLV,EB~'~-,,' EmT, ES"
" " ,
!', \,,' .
" @,
" ,
: I-.J:'"
: J--I:,
APPLICANT.
AGENT.
OWNER.
PROJECT NAME.
PROPOSED USE,
LOCATION, '
REQUEST,
APPLICANT,
AGENT.
OWNER,
PROJECT NAME,
PROPOSED USE,
LOCATION.
REQUEST.
APPLICANT.
AGENT.
OWNER,
PROJECT NAME.
PROPOSED USE,
LOCATION,
REQUEST.
<
.
,
,
APPLICATION NO, 1
Milnor Corporation
Charles Putman & Associates, Inc,
Milnor Corporation
Alhambra Square North
Professional/ Medical Office Complex
South Congress Avenue ot Golf Road, Northeast Corner
AMEND THE FUTURE LAND From'Moderaie Density Residential
USE PLAN CONTAINED IN
THE COMPREHENSIVE PLAN To-Office 'Commercial
REZONE. From - R 1 AA (PUD) (Single-Family Residential)
To - Cl (Office/Professional)
APPLICATION NO, 2
..'--~-
Norman J. Michael
Charles Putman & Associates, Inc.
Norman & Elishka Michael
Alhambra Square South
Professional/Medical Office Complex
South Congress Avenue at Golf Road, southeast corner
AMEND THE FUTURE
LAND USE PLAN From-Low Density Residential
CONTAINED IN THE
COMPREHENSIVE PLAN Ta.Office Commercial
REZONE. From - R1AA (Single.Family Residential)
To - CI (Office/Professional)
APPlICA nON NO, 3
Norman J, Michael
Charles Putman & Associates, Inc.
Norman & Elishka Michael
Alhambra Square ACLF
Adult Congregate living Facility (AClF)
Golf Rood at S.W. 13th Street, southwest corner
AMEND THE FUTURE From-Low Density Residential
LAND USE PLAN
CONTAINED IN THE
COMPREHENSIVE PLAN To-High Density Residential
REZONE. From - R1AA (Single-Family Residential)
To - R3 (Multi-Family Residential)
-
'v'"" t:..-"
"4,Y [>
C' I
C
c:
c:
~i":j
. .,'
--=:3' .' ,_
':.
, .' ,..,:
v'
"
., .'
-1' ," " ,I,
ii: ,. " ",
'J.: 1-'
1/':
. ,j
,
.,
"
., :::
"
"
. ";j
, .
'.> .,
,'. .
'.
. : ~
.... ~,
"
'~." :..~
::.. "
~,
." f,
...."1
. :' 'I.'
't 1::
~ . ,. .:
t:.
: , .~.;
.". ;~
',- T
" ' >1
. .'1:
.,', V
,~. .'{.
. ~.. .,
-:1