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31 . Moreover, and upon information and belief, many of the <br /> administrative site plan approvals which the City seeks to <br /> "grandfather" through its new Land Development Regulation, <br /> contained special exceptions, unusual uses and non-use variances <br /> which had been previously authorized pursuant to Sections 33-31 <br /> 1 (A) (3) , 4 (b) , and (7) of the Miami-Dade County Code and which <br /> have subsequently been declared to be unconstitutional as a <br /> matter of law. <br /> 32 . To the extent that the Land Development Regulations <br /> seek to provide developers with vested rights for approvals <br /> which may in turn be constitutionally defective, the vested <br /> rights provisions of the LDRs are illegal and void. <br /> WHEREFORE, the plaintiffs request an order and judgment <br /> providing the following relief : <br /> a) A declaration that Section 103 . 2 of Sunny Isles <br /> Beach' s Land Development Regulations is void as a <br /> matter of law; <br /> b) An injunction prohibiting enforcement of Section <br /> 103 . 2 of the Land Development Regulations of Sunny <br /> Isles Beach; <br /> c) An award to the plaintiffs of the costs of this <br /> action, including attorney' s fees ; and <br /> d) Such other relief which this Court deems to be <br /> equitable and just . <br /> 11 <br /> SHUBIN & BASS, P.A. <br />