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G.3 Moratorium
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G.3 Moratorium
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G.3 Moratorium
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9/2/2021 9:40:17 AM
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1/15/2009 10:52:56 AM
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<br />the development of the property, we do believe that the continuing moratorium has been <br />applied to ISM in such a manner as to deprive it due process of the law. We also <br />believe that the moratorium has denied ISM the complete value and use of the property. <br />We intend to pursue inverse condemnation and/or mandamus directing approval of the <br />"higher use" concept plan. <br /> <br />If, in fact, the moratorium which has blocked our use of the property for the last three <br />years is about to terminated, and if the City is likely to approve and be benefited by <br />TSM's modest-density concept plan, we would like to proceed with platting. If, <br />however, the City intends to continue to deny TSM use of the property, I ask that you <br />sign the enclosed acknowledgment of service form and return it to me. <br /> <br />Please contact me after you have received this letter. I hope that we can resolve this <br />.. dispute to our clients' mutual benefit. <br /> <br /> <br />Thomas G. Wallrich <br />TGW/bd <br /> <br />Enclosure <br />
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