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Alain: <br />Thank you for your email. While we may disagree, we understand the City's position. <br />Please confirm that this email is sufficient to provide notice of appeal of the HPB's <br />September 11 th denial of the Certificate of Appropriateness related to 334 Atlantic. <br />The grounds for appeal include but are not limited to: (i) changed circumstances <br />compelled approval of the Application; (ii) the denial results in an exceptional financial <br />burden to the owner; (ii) the denial results in an unconstitutional, uncompensated <br />taking of owner's property; (iii) the HPB failed to apply the correct law; and (iv) the <br />HPB decision was not supported by competent substantial evidence. <br />Please also provide directions for the $200 filing fee. <br />I will follow up with a supplemental notice further outlining the grounds of the appeal. <br />Best, <br />Ian <br />Ian E. DeMello, Esq. <br />Partner <br />SHUBIN LAW GROUP ITHE EUCLID GROUP <br />;_�A close-up of a logo Description automatically generated <br />Offices in Miami, West Palm Beach & Tampa <br />Phone: (305) 381-6060 <br />Direct: (305) 381-7145 <br />idemello@shubinlawgroup.com <br />Attention: The information contained in this e-mail message is confidential information and privileged. <br />The information contained herein is intended solely for the use of the individual(s) named above. !f the <br />recipient of this message is not the intended recipient, you are hereby notified that any distribution or <br />149 <br />