CE 31 ROYAL PALMS COURT DOCS 2018 LEWIS Attorneys at Law
LWLLONGMAN uw-law.com
��®tee sU WALKER
Reply to: Jacksonville
bdzirden@llw-law.com
February 14,2018
VIA EMAIL
M. Scott Thomas
Rogers Towers,P.A.
818 AIA North, Suite 208
Ponte Vedra Beach,FL 32082
sthomas@rtlaw.com
'Re: Joint Notice of Stay .
Dear Scott:
In accordance with our discussions, please find enclosed the executed Joint Notice of
Stay in the proceeding before the Special Magistrate.
If you would, please keep me apprised of the status of the litigation between your client
and Handler Properties. Thank you
Sincerely,
B nna .Durden
BMD/dr
Enclosure
i
c: Ellen Glasser, Mayor
Joe Gerrity, City Manager
Shane Corbin, Community Development Director
Debbie White, Code Enforcement Officer
Terrence E. Schmidt, Special Magistrate
i
I
JACKSONVILLE TALLAHASSEE TAMPA BAY WEST PALM BEACH
245 Riverside Ave.,Suite 150 315 South Calhoun St.,Suite 830 101 Riverfront Blvd.,Suite 620 515 North Flagler Dr.,Suite 1500
Jacksonville,Florida 32202 Tallahassee,Florida 32301 Bradenton,Florida 34205 West Palm Beach,Florida 33401
T:904.353.6410 T.850.222.5702 T.941.708.4040 T 561.640.0820
F:904.353.7619 F:850.224.9242 F:941.708.4024 F:561.640.8202
See Things Differently'
00944748-I
IN AND BEFORE A SPECIAL
MAGISTRATE
ATLANTIC BEACH,FLORIDA
RSNS,LLC,a Florida limited liability Company,
Petitioner,
V.
CITY OF ATLANTIC BEACH,a Political
Subdivision of the State of Florida,
Respondent.
JOINT NOTICE OF STAY
WHEREAS, Petitioner did file that certain Petition for Relief Pursuant to Section 70.51
of the Florida Statutes ("Petition"), seeking relief from the Order Imposing Fine of the Atlantic
Beach Code Enforcement Board,dated November 29,2017("November Order");and
WHEREAS, the parties did jointly and timely agree on a Special Magistrate,Terrence E.
Schmidt,Esq.,pursuant to the provisions of Section 70.5 1,Florida Statutes;and
WHEREAS, said November Order found Petitioner in violation of certain City of
Atlantic Beach Code of Ordinances provisions and required Petitioner to bring such violations
into compliance on or before January 1,2018;and
WHEREAS, on January 9, 2018, the Code Enforcement Board reconsidered its prior
action and adopted a new order which changed the required date of compliance from on or
before January 1,2018 to on or before July 1,2018.
NOW, THEREFORE, as a result of this change by the Code Enforcement Board, the
Petitioner and Respondent hereby jointly stipulate to stay the proceedings to be implemented
arising from the filing of Petitioner's Petition for Relief as set forth in Section 70.5 1, Florida
00941990-1
Statutes,until July 1,2018, at which time,unless this Joint Notice of Stay is further extended,the
Petitioner and Respondent shall proceed as if the Petition were filed as of July 1, 2018, and in
accordance with the provisions of Section 70.5 1,Florida Statutes.
Petitioner and Respondent have advised the Special Magistrate of this Joint Notice of
Stay,who has stated he has no objection to same.
A.
i
M:SCOTT THOMAS
Florida Bar No. 994898
{ 818 AIA North,Suite 208
Ponte Vedra Beach,FL 32082
(904)473-1400(telephone)
(904)473-1399(facsimile)
i
ATTORNEYS FOR PETITIONER
Primary and Secondary Email Addresses:
S111olluis @rtlaw.colll
ni ellen!-Ya@i-tlawconi
Dated: .o? dol l
LEW S,LONGMAN&WALKER,P.A.
BRtNNM.I5UkQW
Florida Bar No.518786
245 Riverside Avenue,Suite 150
Jacksonville,FL 32202
(904) 353-6410(telephone)
(904) 353-7619(facsimile)
ATTORNEYS FOR ATLANTIC BEACH
Primary and Secondary.Email Addresses:
hdurden C'Ihv-lanr.conl
dreichard@11w-law.conl
Dated: 2 Z"-
ZD l
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