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are interpreted by the City' s representatives and applied to the <br /> Land Development Regulations, are in violation of the due <br /> process requirements of the state and federal constitutions and <br /> invalid as a matter of law. <br /> WHEREFORE, the plaintiffs seek a declaratory judgment as <br /> follows : <br /> a) That the Court strike those provisions of the <br /> Comprehensive Plan, relied upon by the City to justify <br /> any inconsistency with the Land Development Regulations, <br /> as unconstitutionally vague and therefore void; <br /> b) That the Court require the City to redraft any defective <br /> sections of the Comprehensive Plan in order that they be <br /> constitutional ; <br /> c) That all approvals made pursuant to the Land Development <br /> Regulations be reversed and rendered void; <br /> d) All such other relief as this Court deems just and <br /> proper. <br /> Dated this 9`h day of January, 2003 . <br /> Respectfully Submitted, <br /> SHUBIN & BASS, P.A. <br /> 46 S .W. First Street <br /> Third Floor <br /> Flori .. w <br /> Ill �� <br /> r <br /> JOH SHUBIN, ESQ. <br /> F . BAR NO. 771899 <br /> 13 <br /> SHUBIN & BASS, P.A. <br />