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Shubin Law Group <br />PROFESSIONAL ASSOCIATION <br />Via Email <br />November 12, 2024 <br />Mr. Mauricio Betancur <br />City Clerk <br />City of Sunny Isles Beach <br />18070 Collins Avenue <br />Sunny Isles Beach, FL 33160 <br />Re: Supplemental Notice of Appeal - 334 Atlantic <br />HPB Denial of Certificate of Appropriateness <br />Dear Mr. Betancur: <br />This correspondence is transmitted to you on behalf of George Scholl and Dione Del <br />Monico ("Owners"), the owners of real property located at 334 Atlantic Avenue in the City of <br />Sunny Isles Beach (the "Property"), and is intended to serve as a formal supplemental Notice of <br />Appeal of the City's Historic Preservation Board ("HPB")'s denial of Owners' Application for a <br />Certificate of Appropriateness for demolition ("COA Denial"). <br />I. Background <br />The HPB's COA Denial severely, unreasonably, and unfairly burdens Owner and Owner's <br />Property because it seeks to require Owner to maintain and live in a historically designated <br />structure that is uninsurable, subject to flooding, structurally deficient, and not in compliance with <br />Florida Building Codes, all at a significant, uncompensated financial burden to Owner. I <br />The subject structure was initially designated an individual historic site in 1984 through <br />Dade County Resolution No. 8401. In 2005, following incorporation and formation of the Historic <br />Preservation Board, the City of Sunny Isles ("City") redesignated the structure as an individual <br />historic site through Resolution No. 2005-808, along with the Atlantic Isles Entrance Bridge, <br />Atlantic Isles Lake Bridge, and the Sunny Isles Beach Pier. <br />Since purchasing the Property in 1993, Owners have invested substantial amounts of <br />money into repairing and maintaining the structure in accordance with the relevant historic <br />I Under the City's Code, an undue economic hardship is defined as "[a]n exceptional <br />financial burden that would amount to the taking of property without just compensation, or failure <br />to achieve a reasonable economic return in the case of income-producing properties." § 171-1, <br />City Code. <br />Wts'F PA_m BFAC1 M ArAi TAMPA <br />525 Okeechobee Blvd #1680 100 Southeast 2nd Street #4020 1001 Water Street 4610 <br />West Palm Beach, FL 33401 Miami, FL 33131 Tampa, FL 33602 <br />Shubinlawgroup.com I Tel (305) 381-6060 1 Fax (305) 381-9457 <br />150 <br />