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.4] <br /> Land Development Regulations governing all aspects of <br /> development within the City. <br /> 14 . On December 10, 2002 , defendant Sunny Isles Beach <br /> adopted a comprehensive set of Land Development Regulations and <br /> simultaneously repealed certain sections of its own municipal <br /> code and the Miami-Dade County Code which had previously <br /> governed land development within the City. A true and correct <br /> copy of the LDRs is attached to this Complaint as Exhibit "B" <br /> and incorporated herein . <br /> 15 . The above-referenced Land Development Regulations <br /> constitute a "Development Order" as that term is defined in Fla . <br /> Stat . § 163 . 3164 (7) . Moreover, the LDRs constitute a "land use <br /> amendment" (as contemplated by the City' s Comprehensive Plan) <br /> and purport to legalize certain "site plan approvals" which were <br /> previously approved by the City. <br /> 16 . The City, in adopting its Land Development <br /> Regulations, never notified the Town or its residents of its <br /> intention to consider the adoption of the LDRs, and solicited <br /> comments from the Town regarding these proposed regulations . <br /> 17 . All conditions precedent to the filing of this action <br /> have been satisfied or their performance has been waived by the <br /> conduct of the defendant . Moreover, the plaintiffs specifically <br /> reserve their rights to other actions available to them, pending <br /> and proposed . <br /> 5 <br /> SHUBIN & BASS, P.A. <br />