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NOEL WEISS, ESQ. <br />13700 Marina Pointe Drive, #922 <br />Marina del Rey, California 90292 <br />Telephone: (310) 822-0239 <br />Facsimile: (310) 822-7028 <br />Email Address: :.=:,_"'~''--::;_=--=""=="'~=:.! <br />January 19, 2016 <br />Hand-Delivered at the RPV Council Meeting <br />MEMBERS OF THE RANCHO PALOS VERDES CITY COUNCIL <br />MAYOR KEN DYDA <br />MAYOR PRO TEM BRIAN CAMPBELL <br />COUNCILWOMAN SUSAN BROOKS <br />COUNCILMAN JERRY DUHOVIC <br />COUNCILMAN ANTHONY MISETICH <br />30940 Hawthorne Blvd. <br />Rancho Palos Verdes, California 90275-5391 <br />RE: SUBMISSION OF CLAIMS OF VISTA VERDE HOMEOWNERS VS. CITY <br />OF RANCHO PALOS VERDES OCCASIONED BY CONTINUING PUBLIC <br />NUISANCE BEING COMMITTED BY GREEN HILLS CEMETERY & THE <br />CITY'S REFUSAL TO ABATE THE SAME -REQUEST FOR MEDIATION <br />WITH THE CITY OF RANCHO PALOS VERDES ALONE TO RESOLVE <br />CLAIMS VS. THE CITY <br />Councilmembers: <br />Background: <br />Chapter 17 .28 of the City's Cemetery Zoning Ordinance establishes a 40' set-back <br />development standard controlling where burials occur on cemetery property which <br />abuts a residential zoning district. (Section 17 .028.040(A)(2)). In 1991, Green Hills <br />sought and procured a variance under the City's variance criteria (Chapter 17 .64 of <br />your City's codes) which modified the standard 40' set-back distance to 16' from the <br />boundary of the Vista Verde Condo complex. Until November 17, 2015, the City was <br />in the process of abating the public nuisance created by Green Hills' having violated <br />the foregoing zoning limitation as a result of burials having been effectuated within <br />16' of the boundaries of the Vista Verde condominium property sometime after <br />January 1, 2010. <br />The prior Council on September 1, 2015, voted to approve the recommendation of <br />the City's Planning Commission, consistent with the legal opinion of the City's (then) <br />'1lib\1c · ·· · · <br />C '.'": rt,.,~......k: RECEIVED FROM ·· • OVYJYY~ l ,._... AND MADE A PART OF THE RECORD AJ:, TH <br />COUNCIL MEETING OF ::ran . JJJ <br />OFFICE OF THE CITY CLERK <br />CARLA MORREALE, CITY CLERK